Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health

A FOCUSED REVIEW OF THE SEC PETITION AND NIOSH 

EVALUATION REPORT FOR UNITED NUCLEAR CORPORATION, 

PETITION SEC-00116 

Contract No. 200-2009-28555 

SCA-TR-SEC2010-0017

Prepared by 

J. Mauro 

R. Leggett 

N. Briggs 

J. Porrovecchio 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

September 2010 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42CFR82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
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distribution as redacted. However, this report is pre-decisional and has not been reviewed by the 

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Document No. 

 SCA-TR-SEC2010-0017 

Effective Date: 

 Draft – September 30, 2010 

S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 

0 (Draft) 

A FOCUSED REVIEW OF THE SEC PETITION AND 

NIOSH EVALUATION REPORT FOR UNITED 

NUCLEAR CORPORATION, PETITION SEC-00116 

Page 2 of 37 

Task Manager: 

______________________________ Date:____________ 

John Mauro, PhD, CHP 

Supersedes: 

N/A 

Project Manager: 

______________________________ Date:____________ 

John Mauro, PhD, CHP 

Peer Reviewers: 

 U. Hans Behling 

 Robert Anigstein

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 09/29/2010 Initial issue 
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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................4 

1.0 Background and Statement of Purpose................................................................................6 

2.0 Description of UNC-Hematite Facilities and Operations....................................................9 

3.0 Summary of Issues Raised in SEC Petiton-00116.............................................................10 

4.0

............................................................................12 

Focused Review of External Dosimetry Data and External Dosimetry Protocols for 

Workers at United Nuclear Corporation

4.1 External Gamma and Beta Dosimetry ...................................................................12 

4.2 External Neutron Dosimetry..................................................................................17 

5.0

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

Focused Review of Internal Dosimetry Data and Internal Dosimetry Protocols for 

Workers at United Nuclear Corporation

5.1

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

Summary of the NIOSH Evaluation Report for SEC Petition-00116: 

Methods of Monitoring for Intake of Radionuclides, Levels of Intake 

Identified, and Implications for Dose Reconstruction as Assessed by 

NIOSH

5.2 SC&A Review Comments.....................................................................................22 

6.0 Summary of Findings.........................................................................................................29 

7.0 References..........................................................................................................................32 

Attachment A: Detailed Summary of the SEC-00116 Petition Issues..........................................35 

Attachment B: United Nuclear Corporation EEOICPA Claimants..............................................36 

Attachment C: Individual Film Badge Results for United Nuclear Corp. Personnel ...................37 
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ABBREVIATIONS AND ACRONYMS 

Advisory Board Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

ALARA As low as reasonably achievable 

AWE Atomic Weapons Employer 

BE beryllium 

CATI Computer-Assisted Telephone Interview 

CFR Code of Federal Regulations 

Ci curies 

cm centimeter 

DOE U.S. Department of Energy 

dpm disintegrations per minute 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

g/cm3

 grams per cubic centimeter 

GM Geometric mean 

HEU Highly enriched uranium 

ICRP International Commission on Radiological Protection 

kg kilogram 

L liter 

LOD limit of detection 

m3 cubic meter 

MAC Maximum allowable concentration 

MCNP Monte Carlo N-Particle (computer code) 

mL milliliter 

mr milliRoentgen 

mrad millirad 

mrem millirem 

mrep millirep 

NIOSH National Institute for Occupational Safety and Health 

NOCTS NIOSH OCAS Claims Tracking System 

n s 

-1 neutrons per second 

ORAUT Oak Ridge Associated Universities Team 
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NOTICE:

ORO Oak Ridge Operations 

OTIB ORAUT Technical Information Bulletin 

PAS personal air sampling 

pCi picocuries 

pdf portable document format 

PPE personnel protective equipment 

SC&A S. Cohen and Associates (SC&A, Inc.) 

SEC Special Exposure Cohort 

SRDB Site Research Database 

TBD Technical Basis Document 

Th thorium 

ThO2 thorium dioxide 

U uranium 

UF4 uranium tetrafluoride 

UF6 uranium hexafluoride 

UO2 uranium dioxide 

UNC United Nuclear Corporation 

μCi microcurie
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1.0 BACKGROUND AND STATEMENT OF PURPOSE 

In September of 2009, S. Cohen and Associates (SC&A, Inc.) submitted a draft review of the 

Site Profiles for Atomic Weapons Employers that Refined Uranium and Thorium – Appendix D: 

United Nuclear Corp., Revision 0 (Allen 2008), to the Advisory Board on Radiation and Worker 

Health (Advisory Board) and NIOSH for discussion/resolution of six findings identified by 

SC&A (SC&A 2009). However, the Advisory Board’s Work Group on TBD-6000/6001 elected 

to postpone any discussion/resolution of the findings on behalf of Revision 0, due to forthcoming 

changes NIOSH planned to introduce in Revision 1 of Appendix D. This revision (Allen 2010) 

was issued on April 30, 2010. 

In response to NIOSH’s revision, SC&A was tasked to evaluate Appendix D, Revision 1, and 

assess whether findings previously identified for Revision 0 have been adequately addressed. 

That report, titled A Critical Review of Revision 1 of the NIOSH Site Profile for the United 

Nuclear Corporation, Missouri, Addendum to SCA-TR-SP2009-004 (SC&A 2010), was 

delivered to NIOSH and the Board on June 24, 2010. The purpose of that report was to serve as 

an addendum to SC&A’s evaluation of Allen 2008. SC&A had originally identified six findings 

in our review of Allen 2008, as follows: 

 Finding 1 concerned the methods used to reconstruct medical doses. Our review of 

Revision 1 of Appendix D (Allen 2010) found that this issue has not been resolved. 

 Finding 2 concerned the very limited information NIOSH used as the basis to reconstruct 

external doses. Our review of Revision 1 found that this finding may have been 

adequately addressed, pending SC&A’s review of the new dosimetry data that NIOSH 

employed in revising external whole-body and skin doses. 

 Finding 3 concerned the lack of guidance for reconstructing neutron doses. Our review 

of Revision 1 determined that this finding has been partially addressed, in that NIOSH 

presented a bounding model for assigning neutron doses. A further discussion of this 

issue is presented in Section 4.2 of this report. 

 Finding 4 concerned conflicting statements regarding how internal dose was to be derived 

(i.e., it was not clear whether air sampling or bioassay data were to be used), and also 

what appeared to be the use of dose reconstruction procedures that significantly underestimated internal doses. Our review of Revision 1 determined that this finding has been 

partially addressed, but further discussions may be required to justify NIOSH’s 

recommended use of the geometric mean for the coworker model. 

 Finding 5 concerned insufficient information regarding methods that will be used to 

reconstruct doses to workers during the residual period. Our review of Revision 1 

determined that this finding was not addressed/resolved. 

 Finding 6 concerned insufficient information that would allow the validation of default 

external doses estimates during the residual period. Our review of Revision 1 determined 

that this finding was not addressed/resolved. 
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A meeting of the newly constituted TBD-6001 Work Group was held on July 7, 2010. One of 

the topics addressed at that meeting was SC&A’s findings regarding Revision 1 to Appendix D, 

which will hereafter be referred to as simply “Appendix D.” At the meeting, Hans Behling, 

principal author of SC&A’s review of Appendix D, summarized his findings. One of the 

important questions that was posed to SC&A during the meeting was whether we believed that 

any of the issues raised by SC&A rise to the level of a Special Exposure Cohort (SEC) issue. 

This became an important question, because on January 28, 2010, NIOSH issued its evaluation 

report for SEC Petition-00116 dealing with United Nuclear Corporation (NIOSH 2010). SC&A 

was not explicitly tasked to review the petition or the evaluation report; however, we were asked 

to give our initial impressions regarding possible SEC issues as part of our review of 

Appendix D. Dr. Behling responded to this question by stating that there appeared to be a 

considerable amount of film badge and bioassay data that could be used to reconstruct external 

and internal doses and to develop coworker models. However, as indicated in the findings of our 

review of Appendix D, we would like to look more closely at the possible issues related to data 

completeness and data adequacy before we offer an SC&A position regarding whether SEC 

issues remain that might need to be addressed. 

During the work group meeting, Dr. Mauro recommended that SC&A prepare a statement of 

work for a focused review of the SEC petition and evaluation report. That report could be used 

by the work group to help judge whether to recommend to the Advisory Board that NIOSH’s 

recommendations regarding the petition be approved or to withhold a recommendation until 

certain issues are resolved. 

On July 13, 2010, Dr. Mauro transmitted the following recommendations for a focused review of 

Findings 2, 3, and 4, identified in our review of Appendix D: 

Finding 2 – Download the new external dosimetry data, load the data into a database, and 

check if the data are of sufficient quality and are adequate to build a coworker model that can 

be used for different time periods, operations, and job categories. 

Finding 3 – Confirm that neutron exposure data are adequate for building a coworker model. 

Finding 4 – Conduct a more detailed investigation of the internal dosimetry data to ensure 

adequacy for use in building a coworker model 

On July 13, 2010, SC&A received an e-mail from Henry Anderson, Chairman of the TBD-6001 

Work Group, directing us to proceed with the recommended work. This report presents the 

results of SC&A’s investigations pertaining to this matter. The report is organized into six 

sections. Following this introduction, Section 2 briefly describes the Atomic Weapons Employer 

(AWE) activities that took place at United Nuclear. Section 3 presents a summary of the issues 

identified in the petition, and the degree to which the evaluation report and Appendix D address 

these issues. Section 4 presents our focused review of external dosimetry issues, and Section 5 

presents our focused review of internal dosimetry issues. Section 6 presents a summary of our 

findings regarding this matter, along with a discussion of the concerns raised by the petitioner. 
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NOTICE:

Please note that, at the time of the preparation of this report, a site visit and interviews of 

workers, claimants, and petitioners had not yet been performed. This report will be amended 

upon completion of that work.
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2.0 DESCRIPTION OF UNC-HEMATITE FACILITIES AND 

OPERATIONS 

The production facilities at the United Nuclear Corporation (UNC)-Hematite site consisted of 

two main buildings, each with several thousand square feet of floor space. An incoming storage 

and blending building and an outgoing storage building were located between the two main 

buildings. 

The main function of the UNC-Hematite plant was production of uranium metal and uranium 

compounds from natural and enriched uranium feed stocks for use as fuel in nuclear reactors, 

including the U.S. Navy’s submarine reactors. Starting in 1959, the facility processed unirradiated uranium scrap for the recovery of enriched uranium for use in the Atomic Energy 

Commission’s (AEC’s) nuclear weapons complex. 

Operations at UNC-Hematite included conversion of uranium hexafluoride (UF6) to uranium 

dioxide (UO2) powder, which was pressed into pellets and furnace-fired into a ceramic form 

suitable for loading into fuel assemblies. Chemical conversions of UF6 to uranium carbide and 

uranium metal and various research and development projects were also conducted. In general, 

an increase in U-235 enrichment was associated with work conducted in the Green Room (low 

enrichment, about 2%–5% U-235), Blue Room (intermediate enrichment, about 5%–20% 

U-235), and Red Room (high enrichment, greater than about 20% U-235). The Blender Room 

was used for both low and intermediate enrichment operations. Work in the Item Plant at 

Hematite was often classified and likely involved highly enriched uranium. 

Approximately 9 tons of natural thorium was on site for a specific project conducted in 1964. 

Thorium dioxide (ThO2) powder was mixed with UO2 powder to produce Th-U fuel pellets for 

use in fuel assemblies for breeder reactors. Each pellet consisted of a blend of 97% ThO2 and 

3% UO2 (U-235 enrichment of about 93%) that had been compressed and heated in a furnace. 

Operational and monitoring data indicate that thorium exposures from the 1964 operations and 

cleanup of residual thorium dioxide posed a potential internal hazard to workers.
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3.0 SUMMARY OF ISSUES RAISED IN SEC PETITON-00116 

Before proceeding with a focused review of external and internal dosimetry issues in 

Appendix D and in the evaluation report, this section presents a summary of the concerns raised 

in the petition. SC&A carefully reviewed the petition and condensed the petition into the 

following six concerns:1 

Concern #1. Transuranics are not included in the site profile for Hematite Site operations and 

dose reconstruction (Appendix D). This is a significant finding that should be considered. 

Indications that recycled uranium may have been brought to the Hematite Site for salvage or 

research were likewise not addressed in the site profile. 

Concern #2. The dose reconstruction protocols and the dosimetry data upon which the protocols 

depend, as delineated in the site profile, may not be consistent with actual occupations and task 

assignments at the Hematite facility, the source term (inclusive of transuranics), the extent of 

residual contamination, the extent of bioassay data applied to claimants, personal protective 

equipment, and housekeeping practices. 

Concern #3. While there are indications that Geiger counter scans were used to monitor workers 

leaving contaminated areas, and that at times clothing was replaced if found to be contaminated, 

accepted as low as reasonably achievable (ALARA) protocols were not always implemented at 

the site. Specifically, the lack of adequate decontamination of personnel leaving the site could 

have resulted in the contamination of workers’ homes, resulting in internal and external 

exposures of workers and their families. [Redacted]. 

Concern #4. Internal and external dose reconstructions are challenged by petitioners’ 

recollections of bioassay results not being shared, lack of testing, lack of annual medical exams 

(including blood tests), lack of confidence in personal dosimetry badge results, and both acute 

(incidents) and chronic (allegation of negligence) exposure to contaminants. Worker job 

categories and exposure assumptions may not be consistent with duties performed by workers. 

For example, security guards performed laboratory technician work. Also, inadequately trained 

and monitored security guards responded to incidents. 

Concern #5. Actual conditions/incidents at the site may have a bearing on the appropriateness of 

site profile assumptions. For example, petitioners reported incidents with possible acute 

exposures, and possible criticality incidents. 

Concern #6. The site profile should specifically address other petitioner comments and 

allegations. These allegations deal with falsification of data, fundamental disregard for human 

life, lack of quality control, lack of dissemination of important information, and secondary 

exposure (i.e., exposures of family members) to contamination. 

1

 The actual petition is over 90 pages and we did our best to briefly summarize the salient concerns raised 

by the petition. We welcome feedback from the petitioners regarding the degree to which we captured their 

concerns in this very abbreviated summary. 
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NOTICE:

A more detailed accounting of the issues raised in the petition is provided in Attachment A. 

We would like to point out that the evaluation report does not specifically address the individual 

concerns raised by the petitioners. In the sections that follow, we try to assess the degree to 

which these concerns have a direct bearing on the ability of NIOSH to perform internal and 

external dose reconstructions that are scientifically sound and claimant favorable.
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4.0 FOCUSED REVIEW OF EXTERNAL DOSIMETRY DATA AND 

EXTERNAL DOSIMETRY PROTOCOLS FOR WORKERS AT 

UNITED NUCLEAR CORPORATION 

4.1 EXTERNAL GAMMA AND BETA DOSIMETRY 

Following the publication of Revision 1 to Appendix D, SC&A issued an addendum to its 

original site profile review on June 17, 2010 (SC&A 2010). In that addendum, SC&A explains 

that the use of film badge data adequately addresses the concerns of Finding 2. However, SC&A 

states that we “intend to request access to these data and upon our review, will provide the work 

group with a final opinion regarding Finding 2.” In addition, the work group authorized SC&A 

to perform a focused review of the external dosimetry data with regard to data adequacy and 

completeness required as part of a review of an SEC petition and evaluation report. In 

accordance with the direction of the work group, SC&A further reviewed Appendix D, the 

NIOSH SEC Petition Evaluation Report for SEC-00116 (NIOSH 2010), and all of the available 

external monitoring documents for personnel at UNC, which include the following: 

 External Exposure Reports 1963. External Radiation Exposure Reports for various 

months in 1963. United Nuclear Corp. SRDB Ref ID 62274. 

 External Exposure Reports 1964. External Radiation Exposure Reports for various 

months in 1964. United Nuclear Corp. SRDB Ref ID 62272. 

 External Exposure Reports 1965. External Radiation Exposure Reports for various 

months in 1965. United Nuclear Corp. SRDB Ref ID 62271. 

 Tabulation Sheet 1966. Tabulation Sheet – Dosimetry Records, Year 1966. United 

Nuclear Corp. SRDB Ref ID 62180. 

 Tabulation Sheet 1967. Tabulation Sheet – Dosimetry Records, Year 1967. United 

Nuclear Corp. SRDB Ref ID 62267. 

 Tabulation Sheet 1968. Tabulation Sheet – Dosimetry Records, Year 1968. United 

Nuclear Corp. SRDB Ref ID 62187. 

 Tabulation Sheet 1969. Tabulation Sheet – Dosimetry Records, Year 1969. United 

Nuclear Corp. SRDB Ref ID 62266. 

 Tabulation Sheet 1970. Tabulation Sheet – Dosimetry Records, Year 1970. United 

Nuclear Corp. SRDB Ref ID 62231. 

 Tabulation Sheet 1971. Tabulation Sheet – Dosimetry Records, Year 1971. United 

Nuclear Corp. SRDB Ref ID 62229. 
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 Tabulation Sheet 1972. Tabulation Sheet – Dosimetry Records, Year 1972. United 

Nuclear Corp. SRDB Ref ID 62227. 

 Tabulation Sheet 1973. Tabulation Sheet – Dosimetry Records, Year 1973. United 

Nuclear Corp. SRDB Ref ID 62225. 

 AEC Compliance Inspection Report 1958. U.S. Atomic Energy Commission. SRDB Ref 

ID 3822, p. 14. 

 AEC Compliance Inspection Report 1960. U.S. Atomic Energy Commission. SRDB Ref 

ID 3944, pages 45–59. 

 AEC Compliance Inspection Report 1960. U.S. Atomic Energy Commission. SRDB Ref 

ID 7145, pages 44–58 

 AEC Compliance Inspection Report 1961. U.S. Atomic Energy. SRDB Ref ID 56196. 

SC&A reviewed each of these documents and compiled all of the available film badge data into 

an Excel spreadsheet, presented in its entirety in Attachment C, and summarized here in Table 1. 

We were able to verify all of the statements made by NIOSH in Appendix D of TBD-6001 and 

the evaluation report regarding the UNC film badge records. From an SEC perspective, we 

reviewed the external dosimetry data, as reproduced and reorganized in Attachment C, for data 

completeness and data adequacy. Specifically, we investigated the degree to which sufficient 

data are available to reconstruct the external doses to workers and/or develop external dosimetry 

coworker models for all workers for the time periods of concern by job category and job location. 

For those time periods, job categories, and or job locations where there are limited or no external 

dosimetry data, we investigated whether plausible upper-bound external doses could be assigned 

to those workers using the existing data. 

The film badge results are presented in various forms throughout the period of 1958 through 

1973. Therefore, NIOSH developed different approaches for the UNC coworker model for each 

year of the operational period, as presented in Tables D.2 and D.3 of Appendix D. These 

methods are described below, along with the data descriptions. Individual measurements are not 

available for the years 1958 through 1960, but various compliance inspection reports summarize 

the personnel doses for those years. 
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Table 1. Summary of Film Badge Results for UNC Personnel 1961–1973 

Year No. of Monitored 

Workers 

Range of Average Exposures (rem/week) 

Gamma Beta 

1961 45 0-0.035 0-0.675 

1962 98 0-0.28 0-1.74 

1963 38 0.01-0.28 0-1.3 

1964 29 0-0.16 0-0.85 

1965 16 0-0.14 0-0.36 

Cumulative beta-gamma annual exposure (rem) 

Min Max Median Average 

1966 139 0 6.35 0.15 0.44 

1967 127 0 1.61 0.12 0.22 

1968 176 0 5.98 0.13 0.36 

1969 186 0 3.12 0.13 0.39 

1970 213 0 4.91 0.19 0.38 

1971 64 0 0.67 0.02 0.09 

1972 93 0 2.57 0.06 0.19 

1973 64 0 6.64 0.04 0.43 

1958

The following is the summary of the doses received by personnel during the year 1958: 

Permanent operating personnel at Hematite plant are monitored on a weekly 

basis while rotating personnel are monitoring monthly. Complete individual 

exposure records and summaries are maintained on all employees and were 

reviewed. The average exposure of Hematite plant personnel during the past year, 

as indicated by the records, was 80 mrad due to beta radiation and 36 mrad due 

to gamma radiation. The maximum single six months accumulative exposure 

recorded as due to beta was 2525 mrad while the maximum due to gamma was 

380 mrad. No single weekly exposure in excess of the permissible weekly 

exposure was noted. (AEC Compliance Inspection Report 1958, p.14) 

NIOSH assigned coworker beta and gamma doses for the year 1958 using the following method: 

A yearly missed dose based on 20 mr (LOD/2) per week was added to the average 

values to derive a geometric mean (GM) for both the beta dose and the gamma 

dose. The yearly missed dose was also added to the maximum values (adjusted to 

an annual dose) to produce values at the 95th percentile. (Allen 2010) 

SC&A found the method used to assign coworker dose for the year 1958 to be scientifically 

sound. The inclusion of weekly missed dose in the model is a claimant-favorable approach. 

1959

The following is the summary of the doses received by personnel during the year 1959: 
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Records for the current monthly program show an average weekly exposure, 

monthly and quarterly cumulative exposures. The weekly records show exposures 

to 100 mrep  and the monthly record shows exposures to 240 mrem  with 

averages of 80–90 mrep. Gamma readings to 15 mrem for the monthly program 

are also recorded. The above quoted exposures are all for operations personnel 

while the recorded exposures for pilot plant, laboratory and maintenance 

personnel have all been less. The records reflect no personnel exposures that 

have exceeded the permissible limits of 10 CFR 20. (SRDB 7145, p.50) 

NIOSH assigned coworker beta and gamma doses for the year 1959 using the following method: 

Since it is not clear when in 1959 the exchange frequency changed, missed dose 

was assigned based on a weekly exchange frequency for the entire year. Missed 

dose was added to the maximum recorded values and used to represent the 95th

percentile dose. Missed dose was added to the average beta dose and used to 

represent the GM beta dose. The GM gamma dose was assigned based on the 

GM beta dose adjusted using the average beta to gamma ratio between 1961 and 

1965. (Allen 2010) 

As with the assigned doses for 1958, SC&A found the inclusion of missed dose to be 

scientifically sound and claimant favorable. However, SC&A does have a concern regarding the 

use and calculation of beta-gamma ratios. 

Finding 1. There is a need for better documentation of the beta-gamma ratios used to 

reconstruct external doses. 

NIOSH states that the gamma doses were calculated based on beta-gamma ratios developed from 

the data from 1961–1965. In order to develop these ratios, the values that were below the LOD/2 

should not have been included in the calculation. Since these ratios were not published in 

Appendix D of TBD-6001, it is not clear how they were calculated. In addition, NIOSH should 

have presented a correlation coefficient between the beta and gamma values in order to 

demonstrate that there is a robust and consistent relationship between the beta and gamma 

measurements observed at UNC. 

1960

The following is the summary of the doses received by personnel during 1960: 

Records of film readings for 1960 show no exposures greater than the 10 CFR 20 

limits prior to January 1, 1961, with some few readings up to 100 mrem/wk but 

the majority of the readings were near the threshold of the film or no greater than 

50 mrem/wk. (AEC Compliance Inspection Report 1961, p.13) 

NIOSH used the same method for the assignment of coworker doses for the year 1960 as for the 

year 1959. There is no mention of the addition of missed dose, but the values in Table D.2 are 

comparable to those for 1959. We therefore find favorably for 1960, but like 1959, we have 
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distribution as redacted. However, this report is pre-decisional and has not been reviewed by the 

ABRWH for factual accuracy or applicability within the requirements of 42 CFR 82. 

concerns regarding the bases and claimant favorability of the beta/gamma ratios used to derive 

the doses. 

1961–1973

Starting with the year 1961, the individual film badge records for each worker are documented 

and available. For the years 1961 and 1962, the monthly data are presented as average weekly 

beta and gamma exposures in units of either mrep per week or rem per week. The cumulative 

quarterly totals are also given for each worker for each month of 1961 and 1962. For the years 

1963 through 1965, the external monitoring data are presented as monthly exposures to beta and 

gamma in units of rem per month. The cumulative quarterly totals are also presented for each 

worker for these years. For the years 1966 through the end of the operational period in 1973, the 

film badge records are presented as an annual combined beta-gamma exposure for each worker. 

For 1961 through 1965, when separate beta and gamma values are available, NIOSH used those 

data to develop GM and 95th percentile doses. For the years 1966 through 1973, when only the 

annual combined beta-gamma doses are available, NIOSH used the beta-gamma dose ratios: 

Using the 1961 through 1965 data, a ratio of beta to gamma was calculated for 

each of those years, and the average of that ratio was applied to the 1966 through 

1973 data to derive annual beta and gamma dose at the GM and the 95th

percentile. (Allen 2010) 

Finding 2. How were the beta-gamma ratios derived, and how will they be used in a 

claimant-favorable way for reconstructing external doses for 1961 through 1965? 

SC&A has a finding regarding the use of the data for the period 1961 through 1965. It is not 

clear from the procedures in Appendix D if the values below the LOD/2 are included in the 

model. In order to develop a claimant-favorable model, all values below the LOD/2 should be 

adjusted to the LOD/2, which in this case would be 20 mrem. For the 1966 through 1973 time 

period, SC&A has the same concern regarding the derivation of the beta-gamma dose ratios. It is 

not clear if the values below the LOD/2 were included in the model, and a correlation coefficient 

has not been presented demonstrating the relationship between the beta and gamma exposures at 

UNC. 

SC&A also reviewed the UNC external monitoring data from the point of view of data adequacy. 

We wanted to determine if the film badge data used to develop the external coworker model 

described in Appendix D adequately represents all work locations and all job functions 

performed during the operational period at UNC. Section 5.2.2.1 of the SEC evaluation report 

(NIOSH 2010) indicates that the potential for external radiation exposure existed “primarily from 

operations in the Red Room, Blue Room, Green Room, and Item Plant” related to uranium 

enrichment processes. The information contained in the AEC Compliance Inspection Report for 

1960 (p. 50) indicates that the highest recorded external exposures were received by the 

operations personnel, and the workers involved in the pilot plant, the laboratory, and 

maintenance had lower recorded external exposures. In the existing UNC coworker model 

(Allen 2010, Tables D.2 and D.3), NIOSH recommends that the operators should be assigned the 
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95th percentile doses from the coworker model, while other workers should be assigned the GM 

values from the model. SC&A agrees with the assumption that the highest potential for external 

exposure existed for operators involved in uranium enrichment processes, particularly in the Red 

Room, Blue Room, Green Room, and Item Plants, and that the assignment of the 95th percentile 

doses for the operators is claimant favorable. However, does the film badge data used in the 

development of the coworker model adequately represent the individuals and work locations 

with the highest potential for exposure? 

In order to determine the adequacy of the data for the model, SC&A extracted all of the UNC 

claimants from the NOCTS database. Since we could determine the job titles and work locations 

for each of the monitored workers listed in the original film badge records referenced by NIOSH 

in the evaluation report, we decided to perform a search of the NOCTS database and review the 

Computer-Assisted Telephone Interview (CATI) reports and Department of Energy (DOE) 

records for those individuals. For each of the workers, SC&A listed their employment period, 

job titles, work locations, and whether or not they had available film badge records during the 

operational period, all of which is presented in Attachment B and summarized below in Table 2. 

Of the 54 claimants, 47 of them worked at UNC during the operational period. Of these 47 

claimants, [redacted] appeared to only have worked at the Mallinckrodt Destrehan Street facility, 

instead of the Hematite facility. Finally, SC&A determined that 15 of the UNC claimants are 

described as some type of operator that has available film badge data referenced by NIOSH in 

their evaluation report and reviewed by SC&A. Attachment B also shows that most of the 27 

Hematite claimants with film badge records worked in all areas of the facility, particularly the 

uranium enrichment rooms, and therefore the data do represent a cross section of the entire 

facility, including those rooms with the potential for the highest exposure. 

Table 2. Summary of Review of UNC Claimants from NOCTS Database 

Total # of 

UNC 

claimants 

# of claimants 

from operational 

period 

# of claimants 

from Hematite 

facility 

# of claimants from 

Hematite facility with 

film badge records 

reviewed by SC&A 

# Operators from list of 

Hematite claimants with 

film badge records 

reviewed by SC&A 

54 47 39 27 15 

Source: AEC Compliance Inspection Report 1960a, p.45. 

SC&A concludes that, except for Findings 1 and 2, which appear to be site profile as opposed to 

SEC issues, there appears to be sufficient external dosimetry data to reconstruct external doses or 

to develop external dose coworker models that are scientifically sound and claimant favorable. 

4.2 EXTERNAL NEUTRON DOSIMETRY 

Finding 3. Neutron doses assigned to UNC workers are based on bounding estimates that 

are not scientifically correct. The calculations potentially underestimate the doses from the 

scenario described by the model. However, the scenario overestimates the neutron 

exposure and needs to be based on assumptions that can be related to the actual operations 

at UNC. 
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According to Section 7.3.5 of the evaluation report: 

Due to the absence of neutron monitoring data, an alternative approach for 

bounding neutron doses employs the methods provided in ORAUT-OTIB-0024, 

Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium and 

Thorium Compounds. 

However, the evaluation report does not give any details on this approach. Such details are 

furnished in Appendix D (Allen 2010). The method of assigning neutron doses prescribed in 

Appendix D utilizes a set of bounding assumptions and is based on ORAUT-OTIB-0024 

(Hysong et al. 2005). Hysong et al. (2005, Table 5.2) lists dose rates from neutrons generated by 

the (α,n) reaction at 1 ft and 3 ft from point sources of various compounds of natural uranium—

the dose rates are tabulated as rem/h per gram of uranium. In order to estimate the neutron dose 

rates from enriched UF6, Allen scaled the dose rates from natural uranium to the specific 

activities of 20% or 93% enriched uranium. He then multiplied by the mass in grams, assuming 

100 kg of 20% or 50 kg of 93% enriched uranium. Operators are assumed to be exposed to the 

20% enriched uranium source at a distance of 1 ft for 500 h/y, and to the 93% source at the same 

distance for an additional 500 h/y. Supervisors are assumed to be exposed to the same sources 

for equal amounts of time, but at a distance of 3 ft, while all other workers are assigned one-half 

the supervisors’ dose. 

SC&A (2007) has reviewed Hysong et al. (2005). We calculated the dose rates from a point 

source of UF6 using the Los Alamos SOURCES4C computer code to generate the neutron 

spectrum and MCNP to compute the resulting doses. We found that the doses tabulated for 

UF4/UF6 by Hysong et al. (2005, Table 5.2) were 27% higher than our calculated UF6 rates. 

Thus, assigning these doses to a point source of separated natural uranium in the form of UF6 is 

not scientifically correct, but it is claimant favorable. 

Simply scaling by the total specific activity of enriched uranium, as was done by Allen (2010), is 

not a valid way of estimating the dose, since the neutron emission rate is not proportional to the 

total alpha activity of uranium of different isotopic compositions, nor is the neutron energy 

spectrum constant. For example, U-234 constitutes about 49% of the total activity of natural 

uranium, but over 96% of the activity of 93% enriched uranium (highly enriched uranium or 

HEU). According to Hysong et al. (2005, Table 4-3), the neutron yield of a fluorine target 

subjected to alpha radiation from U-238 is ~50,900 n s-1 Ci-1, while the yield from U-234 is 

~125,000 n s-1 Ci-1, more than twice as high. Thus, 93% enriched uranium would produce a 

significantly higher neutron flux, and consequently a much higher dose rate per unit activity, 

than natural uranium. 

We next question the assumption that an operator could not be exposed to more than 50 kg of 

HEU due to criticality concerns. For a bare sphere of HEU in the form of pure uranium metal, 

the critical mass is approximately 54 kg.2 However, the critical mass will be different for UF6. 

First, the HEU metal has a density of 18.6 g/cm3, while UF6 has a density of 5.09 in crystalline 

2

 Estimated by interpolation from Forsberg and Hopper 1998, Table 1.
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NOTICE:

form, while granulated or powdered material would have a significantly lower bulk density. 

Lower density would lead to a larger critical mass. Furthermore, the material would most likely 

not be spherical, the most compact shape which enhances criticality. On the other hand, the 

increased neutron emission from UF6 might enhance criticality. In addition, fluorine, a relatively 

low-Z nucleus, would cause more neutrons to be thermalized, thus enhancing fission of U-235. 

Therefore, it is not possible to determine the critical mass of highly enriched UF6 without 

performing further analyses. Since in at least one case (North 1959), the manager of the 

Hematite plant requested 100 kg of uranium metal, 93% enriched, in the form of UF6, it is 

possible that a worker could at some time be exposed to such a quantity, unless NIOSH could 

demonstrate by presenting data or performing a criticality analysis on UF6 that the quantity 

would be limited. We further observe that even if the HEU were stored in smaller quantities, a 

worker could have been exposed to more than one such source. Cylinders containing HEU were 

stored in racks—more than one cylinder could be placed in a single rack (AEC Compliance 

Inspection Report 1960a, p. 45). 

Thus, for a truly bounding calculation, NIOSH should consider increasing the quantity to 100 kg 

HEU, and calculating the neutron dose rate from 93% enriched uranium, using the SOURCE-4C 

computer code to generate accurate neutron spectra and MCNP to calculate the resulting doses. 

It is very unlikely that a worker would receive a higher neutron dose than that calculated at a 

distance of 1 ft from a 100-kg 93% HEU source for 500 h/y and a 50-kg 20% enriched source for 

another 500 h/y.3

The doses presented in Appendix D are prescriptive, meaning that dose reconstructors are 

directed to employ them to calculate actual doses to claimants, rather than use them as bounding 

estimates. The distinction is important. Whereas it is appropriate for NIOSH to use bounding 

estimates in an efficiency process in cases where it is clear that overestimating doses will 

nevertheless result in a denial of compensation, bounding estimates may not be appropriate in 

calculating doses in cases where the decision whether or not to compensate cannot be foretold. 

Thus, the final consideration is the plausibility of the scenario adopted by Allen (2010). It is 

quite unlikely that each organ would be at a distance of 1 ft (30.5 cm) from these sources for the 

specified duration. 

If NIOSH wishes to employ a bounding estimate in an efficiency process, the model should be 

revised in light of the above observations. However, NIOSH needs to develop a more realistic 

model to perform dose reconstructions in which a bounding model is not appropriate. For such 

cases, it would be advisable to interview site experts to determine the handling conditions of 

enriched uranium, and construct realistic scenarios. As discussed above, the SOURCES-4C code 

could be used to generate neutron spectra, and MCNP used to calculate the doses. 

3

 North (1959) requested 50 kg of ~20% enriched uranium in the form of UF6. 
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5.0 FOCUSED REVIEW OF INTERNAL DOSIMETRY DATA AND 

INTERNAL DOSIMETRY PROTOCOLS FOR WORKERS AT UNITED 

NUCLEAR CORPORATION 

5.1 SUMMARY OF THE NIOSH EVALUATION REPORT FOR SEC PETITION00116: METHODS OF MONITORING FOR INTAKE OF RADIONUCLIDES, 

LEVELS OF INTAKE IDENTIFIED, AND IMPLICATIONS FOR DOSE 

RECONSTRUCTION AS ASSESSED BY NIOSH 

Beginning in 1957, UNC-Hematite plant operating personnel submitted urinalysis samples on a 

3- to 6-month basis, depending on work assignments. The sampling program was based on job 

assignment and not designed to monitor all UNC-Hematite workers. Urinalyses generally were 

performed by vendors. Little information on analytical techniques is provided, other than that 

the focus was on exposure to U-235 and alpha radioactivity. Different analytical protocols, 

including “enriched” and fluorometric uranium techniques, were used, and “gross counting 

methods” were used. The enriched uranium techniques and gross counting methods are not 

described in the evaluation report. In addition, SC&A is not familiar with the term “enriched 

uranium techniques.” 

Reported urinary uranium levels occasionally included a breakdown by job categories that 

included operators, technicians, engineers, foremen, and guards. UNC-Hematite adopted 

various action levels for uranium in urine at different times. These were typically on the order 

of 45–50 dpm/L of urine. The maximum level recorded during the period 1957–1960 was 

329.9 dpm/L. The average level was 3–5 dpm/L. 

Major changes in the internal monitoring program occurred in January 1961 and December 1962: 

The urinalysis sampling program was discontinued as of January 1, 1961. Plant 

management cited two primary factors: The program, in their view, had been in 

place for a sufficient period of time to furnish “reliable data for an overall 

evaluation of concentrations that may be routinely found in urinalysis samples 

from personnel working in the licensee’s Hematite plant.” Secondly, the 

program’s cost was compared to its value “as a real and practical device for 

routinely measuring radiation exposure.” The plant determined that bioassay 

services would be provided “where desirable or necessary” as required by 

10 C.F.R. 20 (Compliance, 1961, pdf p. 14). (NIOSH 2010, p. 21)

 

The program was re-instituted in December 1962 following operational events 

where several plant operators in the Red Room had higher intakes to airborne 

radioactive materials than expected and a higher probability of reportable 

overexposures during the first six months of the program. These intakes exceeded 

10 C.F.R. 20 limits and were reported to AEC officials. (NIOSH 2010, p. 21)

After its restart in December 1962, the program was continued throughout the covered 

operational period (i.e., through 1973). However, NIOSH considered the analytical results for 
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the period 1971–1973 unreliable and adopted other methods for reconstructing doses for this 

time period. 

In-vivo measurements of U-235 in the chest were made at the Y-12 plant in Oak Ridge for 

some UNC-Hematite workers during the years 1963, 1964, and 1965. Emphasis was on 

workers who had received exposures exceeding 10 CFR 20 limits, as revealed by bioassay 

measurements in December 1962 and early 1963. According to plant correspondence, 

probable causes of the high exposures included a lack of appropriate containment associated 

with the milling of uranium oxides and surface (hand) contamination. The workers were 

tracked for 3 years to confirm that U-235 levels in the body had decreased. In-vivo 

measurements of U-235 were made routinely during the period 1968–1973. 

Measurements of removable contamination by smear samples were identified for the years 

1961–1964, 1966, and 1971–1972. This information was limited to partial years. The samples 

were collected from equipment, floors, and other surfaces, for both clean and potentially 

contaminated areas. 

In addition to the elevated intakes discovered in late 1962 and 1963, there were a number of 

other incidents resulting in elevated intake of uranium during the covered operational period. 

The incidents included releases of UF6 and UO2 in indoor work areas during 1966–1969, and 

various spills and releases in 1970. 

Monitoring for potential intakes of thorium and chain members resulting from the project 

conducted in 1964 was limited to air samples. Thorium dioxide was specified as the compound 

of interest. Of 200-plus available air samples taken during UNC-Hematite’s thorium work, more 

than 75% of the measured air concentrations were less than 2 × 10-11

μCi/mL, the Maximum 

Allowable Concentration (MAC) established by UNC-Hematite for thorium work. 

Approximately 10% of the recorded concentrations were more than 5 times the MAC; most of 

these appear to have been associated with identified events, such as spills. The maximum result 

for the data representing UNC-Hematite’s Th-U fuel effort was 800 times the MAC and was 

associated with a spill. Based on the information found in the air sample data sheets, the air 

samples represent a combination of general area, breathing zone, lapel, stack, and hood air 

sample data. There is no indication that air samples were specifically analyzed for thorium 

isotopes. 

NIOSH concluded that UNC-Hematite conducted a credible, effective radiation safety program 

aimed at identifying and minimizing radiation exposures to every worker: 

It is clear from [NIOSH’s review] that a credible radiation safety program was in 

effect at UNC-Hematite during 1958–1973 in conjunction with significant 

regulatory oversight by the Atomic Energy Commission. (NIOSH 2010, p. 36)

Reviewed correspondence provided insights into UNC-Hematite management’s 

commitment to evaluate each individual’s internal exposures. Emphasis was 

placed on identifying a priori those individuals with significant potential for 

elevated radiation exposures, or a posteriori employing corrective measures to 
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prevent re-occurrence. This included reassignments and job rotations employed 

as “ALARA-equivalent” measures to reduce unnecessary exposures... (NIOSH 

2010, p. 37) 

The primary radionuclide of concern for internal exposure was uranium, except that thorium was 

the main concern in one area of the plant during production of thorium-uranium fuel pellets in 

1964. 

NIOSH also concluded that dose estimates for monitored UNC-Hematite workers for intakes of 

uranium during the operational period may be derived from bioassay (urine) data supported, or in 

some cases replaced, by air monitoring data and in-vivo measurements: 

In summary, bioassay and air sampling data are available in sufficient quantity 

and quality to adequately represent internal dose for the UNC-Hematite class 

under evaluation over the entire operational period... Reliable routine urinalysis 

data are available for the entire operational period with the exception of 1961–62 

and 1971–73... The available air sample data, including BZ [breathing zone] and 

GA [general area] data, are available and can be used to supplement the bioassay 

data, or as the primary source of internal monitoring data for the period from 

1961–1962. (NIOSH 2010, p. 34) 

[The available] resources support the ability to reconstruct uranium dose using 

methods that are more precise than a bounding dose estimate. (NIOSH 2010, 

p. 42) 

For the purpose of bounding doses from internally deposited uranium associated with the 

weapons-related residual radioactivity remaining after the end of AEC-related operations, 

NIOSH intends to use the method defined in Appendix D. The method involves determining a 

maximum air concentration, assumed to settle and accumulate over a predetermined amount of 

time at the end of the operations period. NIOSH would calculate the airborne concentration for 

use in this method by using bounding intake rates for the UNC-Hematite operational period. 

According to the evaluation report, there is no indication that air samples collected during the 

Th-U fuel work in 1964 were specifically analyzed for thorium isotopes. Some uranium may 

have also been collected on the filters. NIOSH concluded that a bounding estimate of the 

concentration of thorium in air can be obtained by assuming that all activity collected on the 

filters represents thorium deposition. The airborne concentrations determined by air sampling 

would be converted to personnel intake rates by applying a standard breathing rate and exposure 

time. 

5.2 SC&A REVIEW COMMENTS 

(1) The Site Profile (Allen 2010) suggests that airborne uranium will be treated as either Type M 

or Type S material in NIOSH dose reconstructions, generally depending on whichever gives 

the higher dose estimates. According to AEC inspection reports, the uranium compounds 

handled at this site included hexafluoride, dioxide, trioxide, diuranate, tetrafluoride, nitrate, 
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sulfate, and fluoride. Some of these compounds or their converted forms in air or in the 

lungs behave as Type F materials (ICRP 1994, Annexe F.). 

Finding 4. If dose estimates are to be based in some cases on air sample data alone (an 

undesirable situation for a dose reconstructor), it is necessary to consider the possibility of 

inhalation of Type F material to avoid underestimates of doses to systemic tissues. 

(2) SC&A agrees that the bioassay (urinary uranium) data provide the best available information 

for purposes of reconstructing doses to UNC-Hematite workers from uranium intakes. 

However, the sparse sampling scheme used in the bioassay program (at most four routine 

samples per year, depending on the job) severely limits the confidence that can be placed in 

the reconstructed doses for monitored workers. Such a sparse sampling scheme may fail to 

reveal high, short-term intakes of uranium, even for periods in which in-vivo chest 

measurements are also available, particularly for uranium compounds that behave as Type F 

material. Some UNC-Hematite workers could have had multiple short-term inhalation 

intakes of UF6, say, over an extended period, that yield high doses to bone surface without 

ever having quarterly urinary uranium concentrations approaching the action levels used at 

UNC-Hematite or lung burdens detectable by in-vivo measurements. The coupling of the 

bioassay data with air sampling data decreases, but does not eliminate, the possibility of 

grossly underestimating doses to some workers from internally deposited uranium, 

particularly in the early years of operation when air sampling was also extremely sparse. For 

example, an AEC inspection report dated August 18–19, 1958, states that complete air 

surveys were made of the entire plant “at least twice a year,” and that some sampling was 

done in the plant “at least one week out of every month.” This is incredibly spotty air 

sampling that lends little support to dose reconstructions based on the sparse bioassay 

program. 

Finding 5. Contrary to NIOSH’s claim, SC&A believes it is not feasible to “reconstruct 

uranium dose using methods that are more precise than a bounding dose estimate” for UNCHematite based on the sparse routine sampling scheme used in the bioassay program, even when 

supported by air sampling data and in-vivo measurements. NIOSH should describe a method for 

deriving bounding doses based on available bioassay data for those periods for which the routine 

bioassay program was in place.

(3) For periods in which there was no routine bioassay program, NIOSH intends to rely on air 

monitoring data to reconstruct doses from radionuclide intakes due to lack or unreliability of 

bioassay data. A poor correlation between air monitoring data and bioassay data has been 

observed in a number of studies of radiation or chemical workers. Particularly poor 

correlations have been historically observed for static air monitoring, but breathing zone data 

have also been found to be unreliable predictors of bioassay data (Marshall 1976; Parker et al. 

1990; Britcher and Strong 1994; Eckerman and Kerr 1999; Snapp et al. 2004; Whicker 2004; 

Liden and Waher 2010). 

Figure 1 illustrates the poor correlation (in this case, lack of correlation) that may occur between 

air sampling data and bioassay data for uranium. The data are for operators in the high 

enrichment facility at UNC-Hematite in 1960, during a period of elevated concentrations of 
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uranium in air in that facility (Zeitlin 1960). The air sampling value for each worker represents a 

time-weighted value over the 4-week period prior to urine sampling after the weekend of the 

fourth week. 

Figure 1. Relationship of Concentrations of Uranium in Air and Urine for 15 Operators in 

the High Enrichment Facility at UNC-Hematite in the Mid-1960s 

The use of air sampling data to reconstruct doses from intakes during 1961–1962 is particularly 

troubling for two reasons. First, the frequency of air sampling appears to have been dramatically 

reduced in 1961–1962, the same period in which there was no routine bioassay program. Second, 

it was discovered after the reinstatement of the bioassay program in December 1962, that 

uranium intakes by some workers far exceeded the levels anticipated from air measurements. 

Although average airborne concentrations of uranium determined for each job did not exceed 

maximum permissible limits, concentrations of uranium in urine in a number of workers far 

exceeded typical levels seen in 1957–1960. Extremely high levels were found in [redacted] 

operators in the Red Room. Data for [redacted] of these workers is shown in Figure 2. 

The following statements are from a letter dated December 23, 1963, from UNC (Kuhlma 1963) 

to the AEC: 

We recognized in April of this year [1963] that our air sampling program was 

insufficient to provide proper control of exposures. A threefold increase in the 

frequency of air sampling was instituted. 

A systematic urinalysis program was adopted in December of 1962 as a backup to 

air sample data, and will be continued as a routine part of the UNC Health 

Physics program. 
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Prior to discovery of the problem [of unexpectedly high intakes] through our 

Bioassay Program, average airborne concentrations determined for each job did 

not exceed maximum permissible limits... An intensive investigation to determine 

the cause of the high bio-assay results disclosed occasional local concentrations 

as high as 10-9 μCi/ml associated with the milling of UO2. 

Figure 2. Urinary Uranium Concentrations in [Redacted] at UNC-Hematite, Discovered 

after Reinstatement of the Bioassay Program in December 1962 

Hand contamination was found to be an additional contributor to the problem. 

[This] is believed to have resulted in the inhalation of active material transferred 

from the hands to cigarettes or from the hands to the air in the breathing zone of 

the [redacted] during rest periods off the job. 

Although the exposures of greatest concern were thought to have occurred in the Red Room, it 

should not be assumed that the design of the air sampling program or the adequacy of air 

samples as predictors of intake were any worse for this area than for other areas of the UNCHematite facility. In particular, there is no reason to expect that the problems of an insufficient 

number of air samples, local air concentrations at work stations that far exceed concentrations 

revealed by air samplers, and hand contamination as a source of significant inhalation and 

ingestion intakes were confined to a particular area of operations. Presumably, monitoring and 

safety procedures would not have been more lax in the high enrichment area than in other areas 

of the plant. 

 

Finding 6. In view of the poor correlation between air sampling data and biological 

measurements frequently reported in the literature, NIOSH should demonstrate the 

feasibity of deriving reasonable bounding dose estimates based largely or wholly on air 

sampling data for the UNC-Hematitie site for the periods 1961–1962 and 1971–1973. 

(4) In contrast to NIOSH’s favorable review of the radiation safety program at UNC-Hematite, 

SC&A believes this program had serious limitations, particularly through early 1963. 

Examples of demonstrated or apparent inadequacies in the radiation safety program are given 
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below. Some of these examples repeat problems mentioned in the above comments by 

SC&A. 

a. The air sampling program through 1958 was grossly inadequate. According to an AEC 

Inspection Report dated August 18–19, 1958: Complete air surveys are made of the 

entire plant at least twice a year and some sampling is done in the plant at least one week 

out of every month. 

b. No full-time health physicist was assigned to the Hematite plant, at least in the first few 

years of operation (AEC Compliance Inspection Report 1958). 

c. The routine bioassay program in place through 1960 was too limited, but nevertheless 

was probably the most instructive part of the radiation safety program with regard to 

identifying uranium intakes. The elimination of this program in 1961 is puzzling, 

particularly in view of uranium exposure problems that occurred in 1960 (Zeitlin 1960). 

UNC-Hematite management later explained the elimination of the bioassay program from 

1961 through 1962 as follows: (1) The program had been in place for a sufficient period 

of time to furnish “reliable data for an overall evaluation of concentrations that may be 

routinely found in urinalysis samples from personnel working in the licensee’s Hematite 

plant,” and (2) The program’s cost was compared to its value “as a real and practical 

device for routinely measuring radiation exposure.” Part 1 of this explanation is taken by 

SC&A to mean that it is not necessary to continue a bioassay program at a uranium 

facility once typical rates of urinary excretion of uranium by workers have been 

established; this position is difficult to understand. Part 2 of the explanation suggests that 

UNC-management thought the bioassay program was too costly, in view of the fact that it 

was not a practical means of routinely measuring radiation exposure, which is contrary to 

NIOSH’s conclusion that reliable dose estimates can be derived from the bioassay data 

collected at UNC-Hematite. In any case, the elimination of the bioassay program proved 

to be a major error, when it was discovered in late 1962 and early 1963 that intakes by 

some workers were far higher than expected on the basis of air sampling data. 

d. The air sampling frequency had been greatly increased in 1959 and 1960, compared with 

sampling frequency in earlier years, but was greatly reduced in 1961, just as the bioassay 

program was eliminated. This reduction in air sampling frequency is difficult to 

understand and may also have been an important contributor to the lack of recognition of 

dramatically increased intakes sometime between January 1961 and December 1962. 

e. The evaluation report suggests that UNC-Hematite discovered that elevated uranium 

intakes were occurring in the 1961–1962 timeframe, reported the situation to the AEC, 

and decided to restart the bioassay program: 

The program was re-instituted in December 1962 following operational 

events where several plant operators in the Red Room had higher intakes to 

airborne radioactive materials than expected and a higher probability of 

reportable overexposures during the first six months of the program. These 

intakes exceeded 10 C.F.R. 20 limits and were reported to AEC officials. 
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UNC-Hematite management presented a similar picture: 

Prior to discovery of the problem [of unexpectedly high intakes] through our 

Bioassay Program, average airborne concentrations determined for each job 

did not exceed maximum permissible limits... An intensive investigation [was 

started] to determine the cause of the high bio-assay results (Kuhlman 1963).

However, it appears to have been AEC inspectors and not the UNC-Hematite radiation 

safety program that recognized that potentially important safety issues had arisen during 

1961–1962. Staff from AEC Oak Ridge Operations (ORO) inspected the UNC-Hematite 

facilities on August 30, 1962 (the previous AEC inspection was in early 1961). A 

number of non-compliance issues were identified and immediate actions were specified 

by the inspectors, including urinalyses for all production personnel and others thought to 

have had a potential exposure (Shoup and Heacker 1962). A letter from the Manager of 

AEC ORO to the vice president of UNC (AEC 1962) summarized findings from the 

inspection, including: 

 Air and surface contamination and methods of operation were such that personnel 

may receive exposures above limits 

 Existing emergency procedures were not adequate, and the responsible personnel did 

not have sufficient familiarity with UNC dosimetry systems to evaluate radiation 

exposures in the event of an emergency 

 Control of contamination was generally inadequate 

 Facilities and methods for storing special nuclear materials were inadequate and 

hazardous, in that special nuclear materials were stored in processing areas 

It is apparently the result of an AEC inspection, rather than UNC-Hematite monitoring, 

that revealed the inadequacies of the UNC-Hematite radiation safety program and led to 

the reinstatement of the bioassay program, the substantial increase in air sampling, and a 

detailed investigation into the causes of the discrepancies in air sampling data and 

uranium intakes. 

f. An indication that UNC-Hematite was not entirely open with the AEC concerning 

potential exposure problems at the site comes from a letter from the Division of Industrial 

Inspection, Department of Labor and Industrial Relations, State of Missouri (Cummings 

1964). The letter describes problems with the plant and its management existing in 1963. 

The letter states, “The Atomic Energy Commission inspectors have been notifying these 

plants in advance of their inspections... United Nuclear Corporation has apparently been 

shutting down production as much as 90% during the Atomic Energy Commission 

inspections.” 

Finding 7. The radiation safety program at UNC-Hematite had serious limitations that 

severely hamper and possibly preclude the reconstruction of doses from intake of 
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radionuclides over some extended periods. The most problematic period was 1961–1962, 

when there was reduced air sampling and no routine bioassay program. 

(5) Only a bare-bones description of the thorium program is provided in the NIOSH evaluation 

report. It appears that NIOSH found little information on the thorium program, judging from 

the repetition of essentially the same brief information in every section. The only available 

monitoring data for thorium and progeny are said to be air sampling data, assumed to 

represent ThO2 concentrations, but apparently representing only gross alpha measurements. 

There is no indication that air samples were analyzed for specific thorium isotopes. All of 

the uncertainties associated with air sampling for uranium, described earlier, apply to thorium. 

Finding 8. Considerably more information is needed before an assessment of the feasibility 

of reconstructing doses to thorium workers, even upper-bound doses, can be made.
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6.0 SUMMARY OF FINDINGS 

The results of our focused review of the SEC Petition-00116 and NIOSH evaluation report are as 

follows: 

Finding 1. There is a need for better documentation of the beta-gamma ratios used to reconstruct 

external doses. 

Finding 2. How were the beta gamma ratios derived and how will they be used in a claimantfavorable way for reconstructing external doses for 1961 through 1965? 

Finding 3. Neutron doses assigned to UNC workers are based on bounding estimates that are not 

scientifically correct. The calculations potentially underestimate the doses from the scenario 

described by the model. However, the scenario overestimates the neutron exposure and needs to 

be based on assumptions that can be related to the actual operations at UNC. 

Finding 4. If dose estimates are to be based in some cases on air sample data alone (an 

undesirable situation for a dose reconstructor), it is necessary to consider the possibility of 

inhalation of Type F material to avoid underestimates of doses to systemic tissues. 

Finding 5. Contrary to NIOSH’s claim, SC&A believes it is not feasible to “reconstruct uranium 

dose using methods that are more precise than a bounding dose estimate” for UNC-Hematite 

based on the sparse routine sampling scheme used in the bioassay program, even when supported 

by air sampling data and in-vivo measurements. Also, NIOSH should describe a method for 

deriving bounding doses based on available bioassay data for those periods for which the routine 

bioassay program was in place. 

Finding 6. In view of the poor correlation between air sampling data and biological 

measurements frequently reported in the literature, NIOSH should demonstrate the feasibity of 

deriving reasonable bounding dose estimates based largely or wholly on air sampling data for the 

UNC-Hematitie site the periods 1961–1962 and 1971–1973. 

Finding 7. The radiation safety program at UNC-Hematite had serious limitations that severely 

hamper and possibly preclude the reconstruction of doses from intakes of radionuclides over 

some extended periods. The most problematic period was 1961–1962, when there was reduced 

air sampling and no routine bioassay program. 

Finding 8. Considerably more information is needed before an assessment of the feasibility of 

reconstructing doses to thorium workers, even upper-bound doses, can be made. 

Before concluding, we would like to offer the following observations regarding the six petitioner 

concerns summarized in Section 2: 

Concern #1. Transuranics are not included in the site profile for Hematite Site operations and 

dose reconstruction. This is a significant finding that should be considered. Indications that 
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recycled uranium may have been brought to the Hematite Site for salvage or research were not 

addressed in the site profile used as the basis for dose reconstruction. 

 

SC&A concurs with this concern. 

Concern #2. The dose reconstruction protocols and the dosimetry data upon which the protocols 

depend, as delineated in the site profile, may not be consistent with actual occupations and task 

assignments at the facility, the source term (inclusive of transuranics), the extent of residual 

contamination, the extent of bioassay data applied to claimants, personnel protective equipment, 

and housekeeping practices. 

SC&A concurs with this concern. 

Concern #3. While there are indications that Geiger counter scans were used to monitor workers 

leaving contaminated areas, and that at times clothing was replaced if found to be contaminated, 

accepted ALARA protocols were not always implemented at the site. Specifically, the lack of 

adequate decontamination of personnel leaving the site could have resulted in the contamination 

of workers’ homes, resulting in internal and external exposures of workers and their families at 

home. [Redacted]. 

 

Certainly, this concern needs to be addressed. However, it is best viewed as a subset of several 

of the internal dosimetry findings SC&A has identified above. 

Concern #4. Internal and external dose reconstructions are challenged by petitioners’ 

recollections of bioassay results not being shared, lack of testing, lack of annual medical exams 

(including blood tests), lack of confidence in personal dosimetry badge results, and both acute 

(incidents) and chronic (allegation of negligence) exposure to contaminants. Worker 

occupational category and exposure assumptions may not be consistent with claimant duties 

performed. For example, security guards performed laboratory technician work. Also, 

inadequately trained and monitored security guards responded to incidents. 

Certainly, this concern needs to be addressed. However, it is best viewed as a subset of several 

of the internal dosimetry findings SC&A has identified above. 

Concern #5. Actual conditions/incidents at the site may have a bearing on the appropriateness of 

site profile assumptions. For example, petitioners reported incidents with possible acute 

exposures and possible criticality incidents. 

Our review revealed that, when incidents occurred, there were extensive bioassay investigations 

as a follow-up to the incidents. However, due to the hiatus on bioassays monitoring in 1961 and 

1962, this concern needs to be explicitly addressed for those years. 

Concern #6. The site profile should specifically address other petitioner comments and 

allegations. These allegations deal with falsification of data, fundamental disregard for human 

life, lack of quality control and dissemination of important information, and secondary exposure 

to contamination. 
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Follow-up interviews with workers regarding this concern will help to gain a better 

understanding of the extent to which falsification of records may have occurred. If there is 

evidence that records falsification might have occurred, a review of the records and data with 

regard to this concern is recommended.
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7.0 REFERENCES 

10 CFR 20. Standards for Protection Against Radiation, U. S. Atomic Energy Commission; Federal 

Register; November 17, 1960; SRDB Ref ID: 62588. 

AEC Compliance Inspection Report 1958. U.S. Atomic Energy Commission. SRDB Ref ID 

3822, p.14. 

AEC Compliance Inspection Report 1960a. U.S. Atomic Energy Commission. SRDB Ref ID 

3944, pages 46–59. 

AEC Compliance Inspection Report 1960b. U.S. Atomic Energy Commission. SRDB Ref ID 

7145, pages 44–58. 

AEC Compliance Inspection Report 1961. U.S. Atomic Energy Commission. SRDB Ref ID 

56196. 

AEC 1962. Letter from the Manager of AEC ORO to the Vice President of United Nuclear 

Corporation summarizing inspection findings. September 5, 1962. 

Allen, D. 2008. “Site Profiles for Atomic Weapons Employers that Refined Uranium and 

Thorium – Appendix D: United Nuclear Corp.,” Battelle-TBD-6001 Appendix D, Revision No. 0. 

Effective Date: March 14, 2008. 

Allen, D. 2010. “Site Profiles for Atomic Weapons Employers that Refined Uranium and 

Thorium – Appendix D: United Nuclear Corp.,” Battelle-TBD-6001 Appendix D, Revision No. 1. 

Effective Date: April 30, 2010. 

Britcher, A.R. and R. Strong 1994. “Personal air sampling – a technique for the assessment of 

chronic low level exposure?” Radiat. Protect. Dosim., 53, 59-62, 1994. 

Cummings 1964. Letter from Don L. Cummings, Director of the Division of Industrial 

Inspection, State of Missouri, to Senator Edward Long. February 5, 1964. SRDB 17045 

Eckerman, K.F and G.D. Kerr 1999. Y12 uranium exposure study. Oak Ridge National 

Laboratory ORNL/TM-1999-114. Oak Ridge, Tennessee. 

Forsberg, C.W., and C.M. Hopper 1998. “Definition of Weapons-Usable Uranium-233,” 

ORNL/TM-13517. http://www.ornl.gov/sci/criticality_shielding/HopperPubs/DefWeaponsUsableU233ORNLTM13517.pdf.

Hysong, R., W.C. Proctor, and J.J. Vollmer 2005. “Estimation of Neutron Dose Rates from 

Alpha-Neutron Reactions in Uranium and Thorium Compounds,” ORAUT-OTIB-0024. 
Effective Date: 

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distribution as redacted. However, this report is pre-decisional and has not been reviewed by the 

ABRWH for factual accuracy or applicability within the requirements of 42 CFR 82. 

ICRP (International Commission on Radiological Protection) 1994. “Dose Coefficients for 

Intakes of Radionuclides by Workers,” ICRP Publication 68. Annals of the ICRP, 24(4). 

Tarrytown, New York: Elsevier Science, Inc. 

Kuhlman, C.W. 1963. Letter from C.W. Kuhlman (United Nuclear Corporation) to the Atomic 

Energy Commission, dated December 23, 1963. Atomic Energy Clearing House. Volume 10 

No. 3. January 20, 1964. 

Liden, G. and J. Waher 2010. “Experimental Investigation of the Concept of a 'Breathing Zone' 

using a Mannequin Exposed to a Point Source of Inertial/Sedimenting Particles Emitted with 

Momentum,” Ann. Occup. Hyg. 54:100 - 116. 

Marshall, M. 1976. Air sampling in laboratories and workplaces at AERE, Harwell, Ann. Occup. 

Hyg., 19:153-157. 

NIOSH 2010. SEC Petition Evaluation Report Petition SEC-00116. National Institute for 

Occupational Safety and Health, Cincinnati, Ohio. January 28, 2010. 

North, E.D. 1959. Letter to Lyall Johnson, Chief, Licensing Branch, Division of Licensing & 

Regulation, U.S. Atomic Energy Commission, from E.D. North, Hematite Plant Manager. 

SRDB 3944, p.6. 

Parker, R.C., R.K. Bull, D.C. Stevens, and M. Marshall 1990. “Studies of aerosol distributions 

in a small laboratory containing a heated phantom.” Ann. Occup. Hyg. 34:35-44. 

SC&A 2007. “Task 3: Review of NIOSH/ORAUT Procedures and Methods Used For Dose 

Reconstruction (Supplement 1),” SCA-TR-TASK3-0001, Rev. 1, SC&A, Inc.: Vienna, Virginia. 

August 2007. 

SC&A 2009. Review of the NIOSH Site Profile for the United Nuclear Corporation, Missouri, 

Battelle-TBD-6001, Appendix D. SC-TR-SP2009-0004, Revision 0. SC&A, Inc.: Vienna, 

Virginia. September 10, 2009. 

SC&A 2010. A Critical Review of Revision 1 the NIOSH Site Profile for the United Nuclear 

Corporation, Missouri, Addendum to SCA-TR-SP2009-0004. SCA-TR-SP2010-0004-ADD. 

SC&A, Inc.: Vienna, Virginia. June 17, 2010. 

Shoup, C.S. and H.V. Heacker 1962. Letter from C.S. Shoup and H.V. Heacker (AEC ORO) to 

United Nuclear Corporation. Lists a number of non-compliance issues identified and immediate 

actions specified by inspectors. September 4, 1962. 

Snapp, L.A., M.L. Souleyrette, and K.G. Veinot 2004. “Practical use of personal air sampling 

(PAS) data in the internal dosimetry program at the Y-12 National Security Complex.” Midyear 

Health Physics Society Meeting, pp. 78–86. 
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distribution as redacted. However, this report is pre-decisional and has not been reviewed by the 

ABRWH for factual accuracy or applicability within the requirements of 42 CFR 82. 

NOTICE:

Whicker, J.L. 2004. “Relationship of air sampling measurements to internal dose: a review.” 

Midyear Health Physics Society Meeting, pp. 73–77. 

 

Zeitlin, F. 1960. Letter from F. Zeitlin (Mallinckrodt Chemical Works, Nuclear Division) to H.L. 

Price (AEC, Director, Division of Licensing & Regulation). December 16, 1960. SRDB 17606.
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ATTACHMENT A: DETAILED SUMMARY OF THE SEC-00116 PETITION 

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ATTACHMENT B: UNITED NUCLEAR CORPORATION EEOICPA CLAIM

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NOTICE: This report has been reviewed for Privacy Act information and has been cleared for 

distribution as redacted. However, this report is pre-decisional and has not been reviewed by the 

ABRWH for factual accuracy or applicability within the requirements of 42 CFR 82. 
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ATTACHMENT C: INDIVIDUAL FILM BADGE RESULTS FOR UNITED 

NUCLEAR CORP. PERSONNEL 

Attachment C (pages 43–91 of the original document) was redacted in its entirety for 

Privacy Act protection.