Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF THE NIOSH SITE PROFILE FOR 

NUCLEAR MATERIALS AND EQUIPMENT CORPORATION 

PARKS TOWNSHIP AND APOLLO SITES 

Contract No. 200-2009-28555 

SCA-TR-SP2013-0038 

Prepared by

Rose Gogliotti 

John J. Mauro, PhD, CHP 

Steve Marschke 

Bob Barton 

Nicole Briggs 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

April 2013 

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 the report is 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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S. COHEN & ASSOCIATES: 

Document No. 

SCA-TR-SP2013-0038 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

Effective Date: 

Draft – April 19, 2013 

NIOSH Dose Reconstruction Program Revision No. 

0 (Draft) 

Review of the NIOSH Site Profile for Nuclear 

Materials and Equipment Parks Township and 

Apollo Sites 

Page 2 of 74 

Task Manager: 

__________________________ Date:____________ 

John Mauro, PhD 

Supersedes: 

N/A 

Project Manager: 

__________________________ Date:____________ 

John Stiver, CHP 

Peer Reviewer(s): 

Rose Gogliotti 

John Stiver 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 04/19/2013 Initial issue 

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TABLE OF CONTENTS 

Abbreviations and Acronyms ..........................................................................................................5 

Executive Summary.........................................................................................................................8 

Summary of Primary Findings.............................................................................................9 

1.0 Introduction........................................................................................................................12 

2.0 Special Exposure Cohorts..................................................................................................14 

2.1 Apollo Site Special Exposure Cohort ....................................................................14 

2.2 Parks Township Site Special Exposure Cohort .....................................................14 

3.0 Scope and Approach to the Review of the Site Profile......................................................16 

3.1 Review Scope.........................................................................................................16 

3.2 Review Process ......................................................................................................17 

3.3 Report Organization...............................................................................................17 

4.0 Review of Internal Dose during Operations ......................................................................18 

4.1 SEC Restricted Monitoring Data ...........................................................................18 

4.1.1 Apollo Special Exposure Cohort ...............................................................18 

4.1.2 Parks Township Special Exposure Cohort.................................................19 

4.2 Overview of Data Completeness and Accuracy ....................................................19 

4.3 Items Requiring Clarification ................................................................................20 

4.4 Uranium .................................................................................................................20 

4.4.1 Urine Bioassay...........................................................................................20 

4.4.2 Air Sampling..............................................................................................22 

4.5 Plutonium...............................................................................................................24 

4.6 Thorium..................................................................................................................28

4.7 Mixed Fission Products..........................................................................................28 

4.8 Recycled Uranium .................................................................................................29 

4.9 Sealed Sources .......................................................................................................30 

4.10 In-Vivo Counting...................................................................................................30 

4.11 Air Sampling..........................................................................................................31 

4.12 Incidents at Both Sites ...........................................................................................32 

5.0 Review of External Dose during Operations .....................................................................33 

5.1 Special Exposure Cohort Restricted Monitoring Data...........................................33 

5.1.1 Apollo Special Exposure Cohort ...............................................................33 

5.1.2 Parks Township Special Exposure Cohort.................................................34 

5.2 Overview of Completeness and Accuracy.............................................................34 

5.3 Items Requiring Clarification ................................................................................34 

5.4 Source Term...........................................................................................................35 

5.5 NTA Neutron Dosimetry .......................................................................................36 

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5.6 Photon Dose Adjustments......................................................................................38 

5.7 External Unmonitored Worker Analysis ...............................................................39 

5.8 Occupational Medical Exposure ............................................................................43 

6.0 Review of the Residual Period...........................................................................................44 

6.1 External Dose.........................................................................................................44 

6.1.1 External Dose at the Apollo Site................................................................44 

6.1.2 External Dose at the Parks Township Site.................................................45 

6.1.3 External Beta Dose at Both Sites...............................................................46 

6.2 Internal Dose..........................................................................................................46 

6.2.1 Apollo Site .................................................................................................46 

6.2.2 Parks Township Site ..................................................................................48 

7.0 SC&A Review of NUMEC Worker Interviews.................................................................52 

8.0 Overview of NUMEC Cases..............................................................................................55 

8.1 Ambient Dose ........................................................................................................60 

8.2 Radiological Incidents and Accidents at NUMEC ................................................60 

8.2.1 Parks Township Site ..................................................................................60 

8.2.2 Apollo Site .................................................................................................61 

9.0 References..........................................................................................................................62 

Appendix A: Analysis of Annual Organ Dose .............................................................................67 

Appendix B: Review of Claimant External Monitoring Data ......................................................69 

LIST OF TABLES 

Table 1. In-Vivo MDAs for Pu-239 and Am-241.........................................................................27 

Table 2. Excerpt from Table 6-2 in the Site Profile......................................................................34 

Table 3. Table 6-5 Reproduced from the Site Profile...................................................................38 

Table 4. Overview of Claimant Sampling by Year.......................................................................40 

Table 5. Dose Rates at 1 Meter above a Contaminated Floor, Calculated with MCNP 

(mrads/hr per dpmα/m2

) .................................................................................................46 

Table 6. Summary of NUMEC Claims in NOCTS.......................................................................55 

Table 7. Diseases of the [Redact] Claimants Examined by SC&A ..............................................56 

Table 8. External Dose for Individuals Not Covered by the SEC ................................................57 

Table 9. Missed Dose for Individuals Not Covered by the SEC ..................................................57 

Table 10. Medical Dose for Individuals Not Covered by the SEC...............................................58 

Table 11. Internal Dose for Individuals Not Covered by the SEC ...............................................59 

Table 12. Incident Dose for Individuals Not Covered by the SEC...............................................59 

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ABBREVIATIONS AND ACRONYMS 

Advisory Board, Advisory Board on Radiation and Worker Health 

ABRWH, or Board 

AEC U.S. Atomic Energy Commission 

Am americium 

AmBe americium-beryllium 

AMAD activity median aerodynamic diameter 

ANL-E Argonne National Laboratory-East 

ATR Advanced Test Reactor 

AWE Atomic Weapons Employer 

BAPL Bettis Atomic Power Laboratory 

B&W Babcock & Wilcox (Company) 

Be beryllium 

Bq/d Becquerel per day 

BZ breathing zone 

BZA breathing-zone air 

CATI computer-assisted telephone interview 

CEP Controls for Environmental Pollution 

CFR Code of Federal Regulations 

Co cobalt 

Cs cesium 

DOE U.S. Department of Energy 

DOL U.S. Department of Labor 

dpm disintegrations per minute 

dpmα/m2 disintegrations per minute alpha per square meter 

dpm/L disintegrations per minute per liter 

DU depleted uranium 

DWE daily weighted exposure 

EE Energy Employee 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 

2000 

FFTF Fast Flux Test Facility (Hanford) 

GA general air 

GSD geometric standard deviation 

h or hr hour 

HASL Health and Safety Laboratory 

HEU highly enriched uranium 

ICRP International Commission on Radiological Protection 

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IMBA Integrated Modules for Bioassay Analysis 

Ir iridium 

keV kiloelectronvolt, 1,000 electronvolts 

kg kilogram 

L liter 

LANL Los Alamos National Laboratory 

LEU low-enriched uranium 

m meter(s) 

m

2 square meter(s) 

m3 cubic meter(s) 

MAC maximum allowable concentration 

mBq millibecquerel 

MDA minimum detectable activity (or amount) 

MDC minimum detectable concentration 

MDL minimum detectable level 

MeV megaelectronvolt, 1 million electronvolts 

μg/L micrograms per liter 

mR/hr milliroentgen per hour 

mrad millirad 

mrem millirem 

nCi nanocurie 

NIOSH National Institute for Occupational Safety and Health 

NOCTS NIOSH DCAS Claims Tracking System 

NRC U.S. Nuclear Regulatory Commission 

NTA nuclear track emulsion, type A 

NUMEC Nuclear Materials and Equipment Corporation 

OCAS Office of Compensation Analysis and Support, now called Division of 

Compensation Analysis and Support (DCAS) 

ORAUT Oak Ridge Associated Universities Team 

pCi picocurie 

Po polonium 

Pu plutonium 

RaLa radioactive lanthanum 

rem roentgen equivalent man 

RF resuspension factor 

Rh rhodium 

Ru ruthenium 

RU recycled uranium 

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SC&A S. Cohen and Associates 

sec second 

SEC Special Exposure Cohort 

Sr strontium 

SRDB Site Research Database 

SS stainless steel 

Tc technetium 

Th thorium 

ThO2 thorium dioxide 

TIB technical information bulletin 

TLD thermoluminescent dosimeter 

TRIGA Training, Research, Isotope General Atomics (Reactor) 

TRU transuranic 

U uranium 

UF6 uranium hexaflouride 

U.S.C. United States Code 

WBC whole-body count 

ZPPR Zero Power Plutonium [or Physics] Reactor 

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EXECUTIVE SUMMARY 

On September 26, 2008, the National Institute for Occupational Safety and Health (NIOSH) 

issued ORAUT-TKBS-0041 (ORAUT 2008), which provides data and guidance for dose 

reconstruction of workers at the Nuclear Materials and Equipment Corporation (NUMEC) 

Apollo Nuclear Fuel Facility (Apollo Site), located in Apollo, Pennsylvania. The site profile was 

revised on June 2, 2009 (ORAUT 2009a), to include the NUMEC Parks Township Site located 

in Parks Township, Pennsylvania. The site profile was revised again on February 26, 2010 

(ORAUT 2010), to adjust the minimum detectable concentration (MDC) of plutonium (Pu) in 

urine and to incorporate updated information and references. On November 26, 2012, during the 

course of this review, NIOSH issued another revision of the site profile (ORAUT 2012a), which 

was initiated in response to a change in guidance regarding medical x-ray exposures and 

assigning doses during the residual period. This report presents a review of the most recent 

revised site profile, as originally requested by the Advisory Board on Radiation and Worker 

Health (Advisory Board) during the full board meeting held in Oakland, California, February 

28–29, 2012. 

The major activities at the Apollo Site included uranium conversion activities in support of 

commercial nuclear power plants and uranium scrap recovery. The primary function of the 

Parks Township Site was the fabrication of Pu fuel, the preparation of highly enriched uranium 

(HEU) fuel, and the production of zirconium/hafnium bars. The Parks Township Site also 

manufactured americium (Am)-beryllium (Be) neutron sources, Pu-238 pacemakers, and highactivity radiography sources, including cobalt-60 (Co-60) and iridium-192 (Ir-192). The Parks 

Township Site also handled and processed cesium-137(Cs-137), Am-241, Be-7, polonium-210 

(Po-210), Pu-238/239, depleted uranium (DU), thorium (Th), and other transuranic (TRU) and 

fission product elements for use in source production and radiographic examination programs, 

including spent fuel examination. Uranium hexafluoride (UF6) cylinders were also stored at the 

facility. In summary, both facilities were involved in a very broad range of activities, for which 

a wide variety of potential internal and external exposures are of concern. 

Among the reasons that the Advisory Board requested that SC&A review the NUMEC site 

profile are that (1) NUMEC is one of the sites for which a Special Exposure Cohort (SEC) was 

granted and, therefore, the site profile was never reviewed until now, and (2) many dose 

reconstructions were performed for workers not covered by the SEC. The dose reconstructions 

were apparently a challenge because of a limited amount of available data. This is an especially 

interesting site profile because NIOSH clearly made an effort to use the available data (despite 

their limitations) to reconstruct doses to 117 workers who were not covered by the SEC (see 

Section 7 of this report). NUMEC and sites like it for which a large SEC was granted, but many 

dose reconstructions were performed for uncovered claimants, are unique because of the 

challenges associated with performing dose reconstructions with limited data. In light of what 

SC&A learned from this review, SC&A recommends to the Board and the Dose 

Reconstruction Subcommittee that a special effort be made to review dose reconstructions 

from sites for which SECs were granted because of the unique challenges associated with 

performing these dose reconstructions. 

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SUMMARY OF PRIMARY FINDINGS 

The following presents SC&A’s primary findings for the NUMEC Apollo and Parks Township 

site profile, ORAUT-TKBS-0041 (ORAUT 2012a). 

Finding 1: Clarification is needed about the start and end dates of Parks Township Site 

operations. 

Finding 2: The site profile should provide guidance on what level of uranium enrichment should 

be assumed for those urine bioassay results that are expressed in units of micrograms (μg/L) per 

liter. 

Finding 3: Some guidance is needed on how to perform dose reconstructions prior to 1959, and 

what approach should be used for missed and unmonitored exposures. 

Finding 4: Uranium inhalation recommendations for the Apollo Site need to take into 

consideration the method discussed by Davis and Strom (2008) for dealing with uncertainties in 

daily weighted exposure (DWE). This technique was evaluated and found to be appropriate in 

the site profile review for the Fernald Feed Materials Production Center (Fernald). 

Finding 5: Inadequate information is given to replicate NIOSH’s determination of median 

inhalation concentration of uranium. The NIOSH result could not be replicated, and it appears 

that relevant information has been omitted from the Health and Safety Laboratory (HASL) 

studies reported in Appendix A to the site profile. 

Finding 6: The site profile would benefit from a discussion demonstrating that the Hanford Site 

fuel grade mix, as opposed to the weapons-grade or commercial-grade plutonium, is limiting for 

the full range of plutonium mixes and ages that were used at NUMEC. In addition, given the 

complexity of this subject, a review of actual dose reconstructions would provide greater insight 

into how this matter is actually being addressed. 

Finding 7: The minimum detectable activities (MDAs) for Am-241 lung counting are very low. 

The counting method should be further explored in order to give them credibility. 

Finding 8: The site profile would benefit from a more thorough discussion of the possible use of 

air sampling data to reconstruct internal plutonium exposures and to take into consideration the 

additional data provided by Crosby 1967 and NUMEC 1967. 

Finding 9: It does not seem appropriate to use ORAUT-OTIB-0054 (ORAUT 2007a) to 

reconstruct the internal exposures of workers at NUMEC who might have been exposed to mixed 

fission products because ORAUT-OTIB-0054 states that its guidance “does not apply to 

determination of intakes where radionuclides have been purposely extracted and concentrated as 

for heat generation sources, medical uses, or waste handling operations that caused significant 

alteration to the source term to which workers were exposed.” For example, Table 5-1 of the site 

profile indicates that the fission products handled at NUMEC are sources used for various 

research and operations purposes and are not actually fuel or spent fuel and would not 

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necessarily be present in the same ratios as in reactor fuel. Also, the fission product mix given in 

ORAUT-OTIB-0054 does not contain the same radionuclides as the fission product mixes given 

for the NUMEC Laundry in the 1975 effluent release report (Williams 1967) and for in-vivo 

count results in Caldwell 1969. The NUMEC mixes include Co-60, which the ORAUT-OTIB0054 mix omits, further demonstrating the inapplicability of ORAUT-OTIB-0054 to NUMEC. 

Finding 10: Internal dose reconstructions performed for NUMEC personnel might need to be 

revisited in light of changes to the Fernald site profile (ORAUT 2004) with respect to recycled 

uranium (RU). Also, additional direction is needed with respect to which workers or operations 

should be assigned RU intakes. 

Finding 11: NIOSH should explain whether the concerns expressed in the Pantex site profile 

(ORAUT 2007d) about the Helgeson chest count data might also apply to chest count data at 

NUMEC performed by Helgeson for NUMEC workers. 

Finding 12: Table 6-2 and the associated text in Section 6.3.2 of the site profile should be 

reviewed and modified as needed to correct any oversights, inconsistencies, or errors. 

Finding 13: Given our understanding that it is NIOSH’s position that external exposures at the 

Parks Township Site can be reconstructed with sufficient accuracy, it appears that the description 

of the sources and circumstances responsible for external exposures need to be better developed, 

if possible. 

Finding 14: The site profile should provide justification for why adjustment factors are not 

required for neutron exposures estimated using nuclear track emulsion Type A (NTA) film, 

considering that it appears that the neutron energy spectrum likely extended to well below 1 

mega-electronvolt (MeV). For example, Table 6-8 of the site profile indicates that the energy 

range of neutron exposures extended from 0.1 to 2 MeV. 

Finding 15: The markedly different photon energies associated with the operations at NUMEC 

would indicate the possible need for adjustment factors for the results of film badge dosimeters, 

which are not provided in the site profile. 

Finding 16: NIOSH should consider developing a universal coworker model based on NUMEC 

claimant records, or specify a more consistent basis for assigning external doses beyond the 

medical x-rays associated with the site. 

Finding 17: The site profile should include guidance for deriving non-penetrating doses to skin 

and other organs from beta emitters associated with surface contamination during the residual 

period. 

Finding 18: General air (GA) samples, as opposed to breathing zone (BZ) samples, should be 

used as the starting point for reconstruction of radionuclide intake rates during the residual 

period. 

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Finding 19: SC&A recommends that NIOSH use a resuspension factor of about 1E-5 per meter 

to derive the airborne dust loading for the beginning of the residual period, or perhaps simply 

assume that the average general air dust loading observed during the operational period is 

applicable to the beginning of the residual period. 

Finding 20: The site profile makes no reference to radionuclides other than uranium during the 

residual period at Apollo. 

Finding 21: There is conflicting guidance on how aged plutonium mixtures should be treated 

during the residual period at Parks Township. 

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1.0 INTRODUCTION 

On September 26, 2008, the National Institute for Occupational Safety and Health (NIOSH) 

issued ORAUT-TKBS-0041 (ORAUT 2008), which provided data and guidance for dose 

reconstruction of workers at the Nuclear Materials and Equipment Corporation (NUMEC) 

Apollo Nuclear Fuel Facility (Apollo Site), located in Apollo, Pennsylvania. This site profile 

was revised on June 2, 2009 (ORAUT 2009a), to include the NUMEC Parks Township Site 

located in Parks Township, Pennsylvania. The site profile was revised again on February 26, 

2010 (ORAUT 2010), to adjust the minimum detectable concentration (MDC) of plutonium (Pu) 

in urine and to incorporate updated information and references. The site profile was again 

revised on November 26, 2012 (ORAUT 2012a), to address changes in NIOSH procedures for 

performing dose reconstructions during residual periods and medical x-ray examinations 

required as a condition of employment. This report presents a review of the most recent revised 

site profile, “Site Profile for Nuclear Materials and Equipment Corporation, Apollo and Parks 

Township, Pennsylvania” (ORAUT 2012a), hereafter referred to as the “site profile”), as 

requested by the Advisory Board on Radiation and Worker Health (Advisory Board) during the 

full board meeting held in Oakland, California, February 28–29, 2012. (Note: The site profile 

was revised once more subsequent to authorization by the Board for SC&A to review the site 

profile). 

Section 2 of the site profile presents a detailed description of the operations that took place at the 

two NUMEC sites. In summary, as described in the site profile, the Apollo Site operated under 

License Number SNM-145 and Source Material License Number C-3762, which the U.S. 

Atomic Energy Commission (AEC) issued in 1957. The major activities at the Apollo Site 

included uranium (U) conversion activities in support of commercial nuclear power plants and 

uranium scrap recovery. From 1958 to 1983, the Apollo Site was used for small-scale research 

and production of low-enriched uranium (LEU), highly enriched uranium (HEU), and thorium 

(Th) fuels. By 1963, the majority of the Apollo Site was dedicated to the production of uranium 

fuel. The Apollo Site facility provided enriched uranium to the naval reactors program and 

included a plutonium plant and storage area, metals and hafnium complex, and uranium 

hexafluoride (UF6) storage facility. Table 2-1 of the site profile summarizes the buildings and 

time periods in which various operations took place and is useful in identifying the types of 

exposures and operations that workers might have experienced while working at the Apollo Site, 

including internal and external exposures to various chemical and physical forms of depleted, 

natural, and enriched uranium, fission products, transuranic (TRU) elements, plutonium, 

thorium, and cobalt-60 (Co-60). Most operations involved uranium chemical conversion 

required to support research and to manufacture fuel for commercial operations, for military 

purposes, and in support of the weapons complex. 

Notable among Apollo Site operations is the receipt of enriched UF6 in “birdcages,” which were 

used as the starting point to convert the enriched UF6 to various uranium oxides. The 

implications of these operations are that, in addition to photon and beta exposures, enriched UF6 

creates the potential for neutron exposures by fission neutrons and alpha/neutron reactions. 

During the uranium conversion processes, a filter cake was produced that was then dried and 

perhaps manually handled (not necessarily under a hood), which created an enhanced potential 

for the production of airborne uranium particulates. 

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Another notable operation at the Apollo Site was the receipt of thorium dioxide (ThO2), which 

was granulated in hoods, pelletized into thorium fuel, and machined under a ventilated hood. In 

addition, limited quantities [500 kilograms (kg)] of plutonium were handled as part of the Apollo 

Site research program. 

The primary function of the Parks Township Site was the fabrication of plutonium fuel, the 

preparation of HEU fuel, and the production of zirconium/hafnium bars. The operations were 

primarily to provide fuel for the Hanford Fast Flux Test Facility (FFTF) and other U.S. 

Department of Energy (DOE) reactors. The Parks Township Site also manufactured americiumberyllium (AmBe) neutron sources, Pu-238 pacemakers, and high-activity radiography sources, 

including Co-60 and iridium-192 (Ir-192). The site also handled and processed cesium-137 

(Cs-137), Am-241, Be-7, polonium-210 (Po-210), Pu-238/239, depleted uranium (DU), Th, and 

other TRU and fission product elements for use in source production and examination programs, 

including spent fuel examination. Uranium hexafluoride cylinders were also stored at the 

facility. 

In summary, the Apollo and Parks Township facilities were involved in a very broad range of 

activities, for which a wide variety of potential internal and external exposures are of concern. 

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2.0 SPECIAL EXPOSURE COHORTS 

Both the Apollo and Parks Township NUMEC sites have been added to the Special Exposure 

Cohort (SEC). This site profile review is performed within the context of these SEC assignments 

and their implications regarding the performance of dose reconstructions for workers not covered 

within the cohort. Therefore, this site profile review emphasizes those time periods and exposure 

scenarios that are not covered by the SECs, and also partial dose reconstructions for exposure 

scenarios that the SEC evaluation report claims can be reconstructed. This section briefly 

summarizes the SECs, identifying those technical areas that establish the basis for performing 

partial dose reconstructions and dose reconstructions for time periods that are not covered by the 

SECs. 

2.1 APOLLO SITE SPECIAL EXPOSURE COHORT 

According to the site profile, NIOSH issued an SEC for the Apollo Site for the period January 1, 

1957, through December 31, 1983 (NIOSH 2007a), for an aggregate number of workdays 

totaling at least 250 days, within the parameters established for one or more classes of employees 

in the SEC. NIOSH’s reasons for issuing the SEC (i.e., those exposure scenarios and time 

periods for which NIOSH believes it does not have sufficient data to perform dose 

reconstructions for all workers with sufficient accuracy) are as follows: 

• Uranium internal exposure before 1960 for lack of bioassay monitoring; 

• Thorium and plutonium internal exposures for lack of monitoring data, 

process descriptions, and source term data; 

• Potential ambient radiation dose from stack releases; 

• Dose from radium-beryllium and polonium-beryllium neutron source 

fabrication operations; 

• Internal doses where the bioassay data was based on NUMEC Apollo 

contractor, Controls for Environmental Pollution [CEP], from 1978 through 

1983, because of concerns on data quality. 

2.2 PARKS TOWNSHIP SITE SPECIAL EXPOSURE COHORT 

According to the site profile, NIOSH issued an SEC for the Parks Township Site for the period 

June 1, 1960, through December 31, 1980 (NIOSH 2008), for an aggregate number of workdays 

totaling at least 250 days, within the parameters established for one or more classes of employees 

in the SEC. NIOSH identified the following primary issues for recommending this SEC: 

• Thorium internal exposures for lack of monitoring data and process 

descriptions; 

• Internal exposures for work with irradiated fuel and fabrication of radiation 

sources for lack of monitoring data, process descriptions, and source term 

data; 

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• Internal dose where bioassay data were based on NUMEC Apollo contractor, 

Controls for Environmental Pollution, from 1976 through 1980, because of 

concerns on data quality 

Although NIOSH determined that doses associated with the above exposure scenarios cannot be 

reconstructed, partial dose reconstructions during this time period can be completed when 

applicable monitoring data are available. Partial dose reconstructions can also be completed for 

time periods not covered by the SEC. Therefore, NIOSH concluded that, for individuals with 

cancers not covered by the SEC or for time periods not covered by the SEC, partial dose 

reconstructions are possible. Consequently, this review focuses on the data and dose 

reconstruction methodologies that are available and might be used by NIOSH to reconstruct 

exposures to workers not covered by the SEC. 

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3.0 SCOPE AND APPROACH TO THE REVIEW 

OF THE SITE PROFILE 

This review was performed in accordance with the following procedures and guidelines: 

• “SC&A Standard Operating Procedure for Performing Site Profile Reviews” (SC&A 

2004), which was approved by the Advisory Board. 

• “Data Access and Interview Procedure” (ABRWH 2009a), which provides for 

appropriate onsite coordination and data access protocols in conjunction with the 

Advisory Board, NIOSH, and DOE. 

• “Department of Energy Classification Review of Documents” (ABRWH 2009b), which 

provides for appropriate security clearance reviews. 

3.1 REVIEW SCOPE 

The NUMEC Apollo/Parks Township site profile (ORAUT 2012a) serves as site-specific 

guidance to support dose reconstructions for claimants under the Energy Employees 

Occupational Illness Compensation Program Act of 2000 (EEOICPA). It provides the health 

physicists who conduct dose reconstructions on behalf of NIOSH with consistent general 

information and specifications to support their individual dose reconstructions. SC&A prepared 

this site profile review to provide the Advisory Board with an evaluation of whether and how the 

site profile can support dose reconstruction decisions. 

To date, the site profile has not been supplemented by site-specific technical information 

bulletins (TIBs). SC&A reviewed other documents pertinent to NUMEC, including those cited 

in the NIOSH Site Research Database (SRDB) and worker interviews performed by NIOSH. 

SC&A critically reviewed the NUMEC Apollo/Parks Township site profile, as well as 

supplementary and supporting documents, against the following three evaluation criteria: 

• Determine the completeness of the information gathered by NIOSH, with a view to 

assessing its adequacy and accuracy in supporting individual dose reconstructions. 

• Assess the technical merit of the data/information. 

• Assess NIOSH’s guidelines for the use of the data in dose reconstructions. 

SC&A’s review of the NUMEC Apollo/Parks Township site profile and supplemental 

documentation focused on the quality and completeness of the data that characterize the facility 

and its operations, and on the use of these data in performing dose reconstructions. The scope 

and depth of the review focused on aspects or parameters of the site profile that would be 

particularly influential in dose reconstructions, bridging uncertainties, or correcting technical 

inaccuracies. 

Our review carefully considered the radiation environments to which workers were exposed and 

the levels of exposure the workers received in that environment through time. We also 

considered the hierarchy of data used for developing dose reconstruction methodologies, 

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including dosimeter readings and bioassay data, coworker and workplace monitoring data, and 

process description information or source term data. 

3.2 REVIEW PROCESS 

SC&A’s draft report and preliminary findings will subsequently undergo a multi-step issues 

resolution process. Issues resolution includes a transparent review and discussion of draft 

findings with members of the Advisory Board Working Group, petitioners, claimants, and 

interested members of the public. Prior to and during the resolution process, the draft report is 

reviewed by the DOE Office of Health, Safety and Security to confirm that no classified 

information has been incorporated into the report. 

All review comments apply to Revision 02 of the Apollo and Parks Township site profile 

(ORAUT 2012a), which is the most recent published version. NIOSH conducted site expert 

interviews with former NUMEC Apollo Site and Parks Township Site workers to help obtain a 

comprehensive understanding of the radiation protection program, site operations, and historic 

exposure experience that SC&A consulted in the course of this review. 

3.3 REPORT ORGANIZATION 

This report is organized into the following sections: 

Executive Summary 

1.0 Introduction 

2.0 Special Exposure Cohort 

3.0 Scope and Approach to the Review of the Site Profile 

4.0 Review of Internal Dose during Operations 

5.0 Review of External Dose during Operations 

6.0 Review of the Residual Period 

7.0 SC&A Review of NUMEC Worker Interviews 

8.0 Overview of NUMEC Cases 

9.0 References 

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4.0 REVIEW OF INTERNAL DOSE DURING OPERATIONS 

Section 5 of the site profile addresses internal exposure at the NUMEC facilities and the data 

sources, assumptions, models, and protocols that should be used to reconstruct internal 

exposures. Section 5.1 of the site profile summarizes the different types of internal exposure 

scenarios that were present at the NUMEC facilities. Table 5-1 of the site profile summarizes 

the potential radionuclides and fuel types that an Energy Employee (EE) might have been 

exposed to at NUMEC sites. The radionuclides include: 

• Various chemical and physical forms of uranium over a range of enrichments 

• Naturally occurring Th-228 and Th-232 

• Mixtures of isotopes of plutonium of various ages and chemical forms 

• Technetium (Tc) and TRU 

• A variety of fission and activation products 

This section presents a review and commentary on the completeness and accuracy of the internal 

monitoring data as described in the site profile and its supporting documentation. 

It is important to keep in mind that the data and protocols for reconstructing internal doses at the 

Apollo and Parks Township Sites, as described in the site profile and reviewed here, must take 

into consideration that SECs were granted for both facilities, largely due to concerns about the 

ability to reconstruct internal exposures with sufficient accuracy. For this reason, this section 

begins with a reiteration of the SEC, followed by a description of the data and dose 

reconstruction methods described in the site profile, and then SC&A’s review of those data and 

protocols. 

4.1 SEC RESTRICTED MONITORING DATA1 

The site profile states that bioassay data generated from Controls for Environmental Pollution 

(CEP) cannot be used in dose reconstructions. SC&A investigated this claim and found that, in 

1994, CEP was convicted of data falsification related to the Sandia National Laboratory bioassay 

program. Following this incident, the U.S. Nuclear Regulatory Commission (NRC) and DOE 

issued notices warning that CEP data should be questioned. Therefore, CEP data cannot be used 

for dose reconstruction, but they can be used to determine risk of potential exposure. 

4.1.1 Apollo Special Exposure Cohort 

The Apollo SEC petition evaluation report (NIOSH 2007a) evaluated the feasibility of 

reconstructing internal doses at the Apollo Site. It identified a number of internal dose 

1

 This section is somewhat redundant with the material provided in Section 2.0. However, we include it 

here because the quoted material in Section 2.0 was taken directly from the site profile, and the material describing 

the scope of the SEC provided in this section was taken from the SEC petition evaluation report, which is a little 

different than the description provided in the site profile. Therefore, we include both sources of information in this 

report. 

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monitoring areas where dose could not be accurately reconstructed (in addition to the CEP 

bioassay issue noted in Section 4.1 above): 

• Internal monitoring records from 1957 through 1959 do not appear to exist. 

• Information on thorium operations is not available. 

• No monitoring data, process description or source term data exist for plutonium or 

concerning neutron source fabrication. 

• Potential elevated ambient radiation levels from stack releases are not well 

documented. 

Based on these findings, NIOSH concluded that the information pertaining to internal dosimetry 

was inadequate for determining internal exposures with sufficient accuracy. 

4.1.2 Parks Township Special Exposure Cohort 

The Parks Township SEC petition evaluation report (NIOSH 2008) evaluated the feasibility of 

reconstructing internal doses at the Parks Township Site. It identified a number of internal dose 

monitoring areas where dose could not be accurately reconstructed (in addition to the CEP 

bioassay issue noted in Section 4.1 above): 

• Information on thorium operations and monitoring is not available. 

• There is a lack of information on fabrication of radiation sources and work with 

irradiated fuels. 

Based on these findings, NIOSH concluded that the information pertaining to internal dosimetry 

was inadequate for determining internal exposures with sufficient accuracy. 

4.2 OVERVIEW OF DATA COMPLETENESS AND ACCURACY 

Dose reconstruction for NUMEC workers was significantly complicated by the lack of internal 

monitoring information because of concerns over data falsification by CEP. Notably absent from 

the site profile are instructions on how to assign radionuclide intakes for the purpose of 

reconstructing internal doses for employees who worked at both NUMEC facilities and are not 

covered by the SEC. Because the facilities were located roughly 5 miles apart, it was fairly 

common for employees to work at both sites or go between sites. The amount of time workers 

might have spent at each site (i.e., daily, weekly, monthly, or on occasion) is not apparent from 

our review of the literature and selected cases. Because the sites’ source terms differ, some 

guidance should be given to dose reconstructors on how to assign this dose, so that it is 

consistently assigned among cases. Typically, when a claimant worked at multiple facilities, 

dose reconstructors take into consideration doses that might have been experienced at different 

locations and at different time periods; however, this does not seem possible for the NUMEC 

sites, because the frequency of workers going between sites is not well documented. 

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Another overarching concern is that air concentrations of uranium could not be confirmed by our 

review. Although NIOSH attempted to quantify these concentrations, SC&A does not believe 

they are adequately captured in the site profile. This is discussed further in Section 4.11. 

4.3 ITEMS REQUIRING CLARIFICATION 

There seems to be some uncertainty about the start date of operations at the Parks Township Site. 

Section 2.2.1 of the site profile indicates that the site was not authorized to begin work until 

1961, but Table 2-4 of the site profile indicates that many of the locations were operational in 

1960. Additionally, Section 2.2.3.3 indicates that Building C was not used from construction 

until 1973 and Section 2.2.5 states that all operations in Building C ceased in 1978, yet Table 2-4 

indicates that operations in Building C began in 1969 and lasted till 1980. 

Finding 1: Clarification is needed regarding the start and end dates of Parks Township 

Site operations. 

4.4 URANIUM 

The uranium source term is summarized in Table 5-2 of the site profile. It appears that uranium 

was predominately handled at the Apollo Site, though there was also some risk of uranium 

exposure at the Parks Township Site. Table 5-2 of the site profile presents the isotopic mix of 

the various types of uranium (i.e., U-234, U-235, U-236, and U-238) that were handled at 

NUMEC as a function of enrichment, including natural and depleted uranium and uranium 

enriched to 2%, 3.5%, and 93%. 

4.4.1 Urine Bioassay 

Section 5.2.2 of the site profile presents the analytical methods used for the evaluation of 

uranium in urine and feces samples, the minimum detectable activities (MDAs), and the 

sampling frequencies for different categories of workers. The site profile explains that about 100 

urine bioassays were conducted each month, and the results were expressed in terms of 

micrograms per liter (μg/L) or disintegrations per minute per liter (dpm/L), depending on the 

time period and laboratory performing the analysis. The site profile recommends that the dose 

reconstructor assume the chemical form of the uranium that is limiting for the type of cancer 

under consideration, which is a claimant-favorable strategy. However, for those urine analysis 

results expressed in terms of μg/L, no guidance is provided regarding what level of enrichment 

should be assumed. Figure 1 shows that, at higher levels of enrichment, the number of 

picocuries per liter (pCi/L) associated with a given μg/L of uranium in urine could be more than 

10 times higher than at low levels of enrichment. 

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0.1 

1 

10 

100 

0.1% 1.0% 10.0% 100.0%

 Percent Enrichment

 S

pecific activity (

pCi/μg) 

Note: Figure 1 shows the sum of the specific activities of the three naturally occurring isotopes of 

uranium—U-234, U-235, and U-238—for different degrees of enrichment. The data are taken 

from Table 5-2 of the site profile. Natural uranium and DU were assigned “enrichments” (i.e., 

mass fractions of U-235) of 0.25% and 0.72%, respectively. Our independent calculations of three 

of these values show good agreement with the specific activity of natural uranium. However, the 

NIOSH values for 2% and 93% (HEU) enrichments are 12.5% and 5% higher, respectively, than 

our values. 

Figure 1. Total Specific Activity of Uranium Isotopes as a Function of Enrichment 

Finding 2: The site profile should provide guidance about what level of uranium 

enrichment should be assumed for those urine bioassay results that are expressed in units 

of μg/L. 

Early controls at NUMEC for uranium appear to be minimal. Prior to 1963, it seems likely that 

large intakes of uranium occurred without acknowledgment and follow-up action. The 

maximum allowable concentration (MAC) in urine until 1963 was 500 dpm/L for 93% enriched 

uranium. Attachment A provides the results of an evaluation of the organ doses associated with 

a MAC of 500 dpm/L of natural uranium. These values are also applicable to various levels of 

enriched uranium, because the dose conversion factors for the various isotopes of uranium are 

quite similar. The daily intake rates of Type M and Type S natural uranium that result in 

500 dpm/L at the end of a year of chronic exposures are 212 Bq/d and 5,772 Bq/d, respectively. 

Note that for Type M uranium, the peak annual effective dose is 11.5 rem, and for Type S 

uranium the peak annual effective dose is 41.8 rem. Clearly, the doses associated with 1 MAC 

are quite high. 

NUMEC also did not use breathing zone (BZ) air samples prior to this time. As a result, large 

localized intakes of uranium could have been missed without an adequate bioassay program. 

Health physicists at NUMEC preferred to use fecal sampling, because they found it identified 

intakes more consistently than urinalysis. 

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SC&A compared the NIOSH recommendations regarding the reconstruction of internal doses 

against a random sampling of SRDB files and found the recommended dose reconstruction 

protocol to be compatible with the monitoring information of the time. However, the site profile 

is silent on how uranium intake should be reconstructed prior to late 1959, which corresponds to 

the beginning of the bioassay program. Because uranium processing started nearly 2 years 

before this date, some guidance should be given to dose reconstructors, if possible. 

The site profile does not mention missed dose and could benefit from a discussion on this topic. 

The site profile mentions that non-radiation workers were monitored annually, yet no guidance is 

provided with respect to missed dose or assigning doses to workers who were not monitored, but 

perhaps should have been monitored. 

Finding 3: Some guidance is needed on how to perform dose reconstructions prior to 1959, 

and what approach to use for missed and unmonitored exposures. 

4.4.2 Air Sampling 

SC&A reviewed the Health and Safety Laboratory (HASL) studies, which involved fixed BZ air 

sampling for uranium workers during 1959–1961. The studies were used to determine average 

daily weighted exposure (DWE) for various jobs working with uranium. NIOSH assumed that 

these data had a lognormal distribution, with the highest DWE representing the upper 95th 

percentile and the lowest representing the bottom 5th percentile. NIOSH analyzed these data and 

found the median [210 dpm per cubic meter (m3) = 94.6 pCi/m3] of the assumed lognormal 

distribution. NIOSH recommends assigning this intake rate to all uranium workers. 

SC&A considered this method and believes that it is claimant neutral, rather than claimant 

favorable. It is our understanding that the NIOSH analysis uses average airborne uranium 

concentration values after removing all high and low BZ air samples. SC&A was unable to 

replicate the NIOSH median value of 210 dpm/m3 using the values in Attachment A to the site 

profile. SC&A reviewed the HASL reports and found that the locker room and laundry areas are 

omitted from Attachment A. Repeated analysis of general air (GA) samples taken from the 

changing area of uranium workers showed a 1966 DWE of 563 dpm/m3

 (Schnell 1966). 

Concentrations of this magnitude are not reflected by the NIOSH-modeled median dose. 

Because SC&A was not able to reproduce the median airborne uranium concentration value 

assigned by NIOSH, even using the omitted values, SC&A elected to compare this 

recommendation with the recommendations for a uranium facility in the TIB, Internal Dose 

Overestimates for Facilities with Air Sampling Programs, ORAUT-OTIB-0018 (ORAUT 

2005a). This document recommends assigning a limiting airborne uranium concentration of 

1,330 dpm/m3

, which is substantially higher than the value recommended in the NUMEC site 

profile. SC&A therefore questions the validity and claimant-favorability of the default airborne 

uranium dust concentrations adopted for NUMEC. 

A NUMEC study (Caldwell et al. 1967) indicates that the fixed BZ air samplers used in the 

HASL studies likely underestimated dose. Around 1965, NUMEC began using lapel samplers as 

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a screening technique. Following their use, NUMEC health physicists compared the results of 

BZ versus GA sampling; Figure 2 summarizes some of these results. 

Source: Caldwell et al. 1967, pg. 14) 

Figure 2. Reliability of Air Sampling 

NUMEC health physicists determined that the fixed BZ samplers failed to identify greater than 

permissible exposures roughly 73% of the time. This study also found that more than 50% of the 

time, personal air samples tested showed concentrations 7 times that of stationary samples. Ten 

percent of the time, the concentrations differed by a factor of 20. This indicates that the fixed 

samplers used in the HASL studies several years earlier likely underestimated dose. 

It is important to stress that a DWE represents the AVERAGE air concentration experienced by a 

particular worker on the day that the measurements were taken, without regard to the uncertainty 

inherent in the measurements or the representativeness of the DWE for all workers in that job 

type at all times; the HASL air sampling studies made no attempt to characterize the uncertainty 

in DWEs. Davis and Strom (2008) conducted an uncertainty analysis of DWE for 6 facilities 

that processed uranium, thorium, and radium and recommend a geometric standard deviation 

(GSD) of 5 to account for variability and uncertainty in the measurements. This technique was 

evaluated as part of the SEC petition evaluation review for the Fernald Feed Materials 

Production Center (Fernald) and found to be appropriate in principle for that site. SC&A 

believes that the NUMEC site profile would benefit by adopting the recommendations in Davis 

and Strom (2008) for uncertainty in DWE. 

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Finding 4: Uranium inhalation recommendations for the Apollo Site need to take into 

consideration the method discussed by Davis and Strom (2008) for dealing with 

uncertainties in DWE. This technique was evaluated and found to be appropriate in the 

site profile review for the Fernald Feed Materials Production Center (Fernald). 

Finding 5: Inadequate information is given to replicate NIOSH’s determination of median 

inhalation concentration of uranium. The NIOSH result could not be replicated, and it 

appears that relevant information has been omitted from the HASL studies reported in 

Appendix A to the site profile. 

4.5 PLUTONIUM 

The Parks Township Site received its first shipment of plutonium in June 1960, but did not 

receive a license to handle it prior to March 1961. This was the first plutonium license ever 

granted to a commercial facility. 

The largest concern for internal exposure at the Parks Township Site is plutonium inhalation. 

Plutonium operations started on a small scale, doing research and development. Although it is 

not clear exactly when, the site eventually evolved into large-scale productions, receiving two 

Zero Power Plutonium (later Physics) Reactor (ZPPR) orders, each the largest plutonium orders 

of their time. 

Section 5.2 of the site profile addresses the various chemical and physical forms of plutonium 

handled at the facility. It explains that three types of plutonium were handled at NUMEC: 

reactor grade, weapons grade, and fuel grade. However, because information is lacking about 

the actual composition of plutonium handled at a given location and at a given time, the site 

profile recommends assuming Hanford Site (Hanford) reference fuel-grade plutonium (ORAUT 

2012c), using the mixture identified in Table 5-3 of the NUMEC site profile. 

In order to understand Table 5-3 of the site profile, we needed some background information 

about the various grades of plutonium that were handled and produced at Hanford. Plutonium 

mixtures were categorized by their weight percent of Pu-240. When the reactors were operated 

to produce plutonium for weapons, the target mixture was about 6% Pu-240, a mixture referred 

to as “weapons grade.” When the reactor was operated to produce power, the mixture in the fuel 

rods when removed from the reactor was nominally 12% Pu-240, a mixture referred to as “fuel 

grade.” There were a few exceptions in radiochemistry laboratories where purified Pu-238 and 

Pu-239 experiments were performed, for example, in Building 325 C-Cell. There is evidence at 

Los Alamos National Laboratory (LANL) that plutonium produced at Hanford in the 1940s had 

less Pu-240, perhaps closer to 3%, but documentation of that at Hanford has not been found 

(ORAUT 2009b). Tables 5-3 and 5-4 of the Hanford site profile (ORAUT 2012c) give the 

activity composition of weapons-grade (6%) and fuel-grade (12%) plutonium in 5-year 

increments up through 20 years. The dose reconstructors are told, when Pu-238 or Pu-239 are 

measured in the bioassay analysis, to use 20 years, so that the dose is maximized by assuming 

the longer decay time. When Am-241 is measured and the intake is estimated using in-growth of 

Am-241 from the decay of Pu-241, the dose is maximized by assuming the shorter decay time of 

5 years. The site profile further states that a best estimate of intake can be made by assuming a 

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10-year decay time, as this is midway between the possible low and high ages of plutonium from 

Hanford. If the actual age of the fuel is known, then that age can be used in the intake and dose 

analysis. The Hanford site profile states that, for intakes since about 1999, a 20-year-old fuelgrade mixture could be assumed. 

In the 1970s, work at Hanford was using material with much more Pu-241 and with Pu-240 at 

26%. In addition, the Plutonium Finishing Plant sometimes recycled plutonium from other DOE 

sites, the United Kingdom, and commercial reactors, and these materials often had higher Pu-240 

and Am-241 content. The Hanford site profile also states that, “use of the 6% mixture is the 

default starting point for limiting doses based on chest counts” (ORAUT 2012c). 

Our review of this section of the Apollo and Parks Township site profile reveals that, overall, the 

site profile data for the plutonium mixtures are quite accurate. However, it is not appropriate to 

assume that all the plutonium can be generalized or averaged as NIOSH has done by using a 

10-year decay time as a midpoint. This is especially troublesome considering the fact that 

Hanford handled other percentage mixtures of plutonium over the years, including pure Pu-238 

and Pu-239, as well as recycled plutonium from other DOE sites, the United Kingdom, 

commercial reactors, and ZPPR fuel mixtures; these materials often had higher Pu-240, Pu-241, 

and Am-241 contents. 

The site profile explains that the age of the plutonium should be selected to give the benefit of 

the doubt to the claimant. This is done by assuming that the age is 20 years when plutonium is 

measured, and 5 years if the method of analysis is to measure Am-241 in the urine sample. This 

strategy appears to be fundamentally sound. However, a review of a few actual dose 

reconstructions would help to judge that this strategy is actually being implemented in a 

claimant-favorable manner. Furthermore, it is not apparent that the Hanford reference fuel-grade 

plutonium mix, as opposed to reactor grade or weapons grade, is limiting. SC&A’s finding on 

this point is as follows: 

Finding 6: The site profile would benefit from a discussion demonstrating that the 

Hanford fuel-grade mix, as opposed to the weapons-grade or commercial-grade plutonium, 

is limiting for the full range of plutonium mixes and ages that were used at NUMEC. In 

addition, given the complexity of this subject, a review of actual dose reconstructions would 

provide greater insight into how this matter is actually being addressed. 

Section 5.2.1 of the site profile provides guidance for reconstructing plutonium intakes and doses 

using urine and fecal bioassay data, presumably from non-CEP labs. Tables 5-4 and 5-5 of the 

site profile present minimum detectable concentrations [MDCs, also often referred to as 

minimum detectable levels (MDLs) or minimum detectable activity or (MDA)] for urine and 

fecal analyses, respectively, as a function of date (beginning in October 1961) and radionuclide. 

The remainder of the section describes the analytical methods that were used to measure 

plutonium in urine and fecal samples. 

SC&A reviewed the MDCs for plutonium in urine bioassays, as reported in Table 5-4 of the site 

profile, and found that they are reasonable, but that there are some inconsistencies within the site 

profile itself, and that the values are not entirely consistent with those reported by others. For 

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example, for the period October 1961–December 1965, the MDC in the site profile is tabulated 

as 0.28 dpm/L, error of 0.01–0.48 dpm/L. However, Section 5.2.1.2 of the site profile reports a 

sensitivity of about 0.44±0.20 dpm/L in 1964. This factor of 2 should be reconciled. In addition, 

for this same time period, LANL ORAUT-TKBS-0010-5 (ORAUT 2009b) reports an MDC that 

corresponds to 0.18 dpm/L [based on 0.2 dpm per 24 hours (24h) and an assumed excretion of 

1.4 L]; for this period, ORAUT-TKBS-0011-5 for Rocky Flats (2007c) reports MDCs of about 

0.30 dpm/L [reported values varied from 0.44 dpm/24h (about 0.3 dpm/L) to 0.54dpm/24h]; and 

International Commission on Radiological Protection (ICRP) Publication 10 (1968) reports a 

limit of detection of 0.06 pCi/24h (0.13dpm/24h, about 0.1 dpm/L), based on a 1964 paper from 

Jackson and Taylor (1964). 

Observation: For this time period, the reported MDCs for NUMEC are higher than the ones 

reported by LANL and the one reported in ICRP Publication 10 (1968). The NUMEC MDCs are 

comparable to the ones reported by Rocky Flats. NIOSH should clarify some of these 

differences. 

For the period January 1966–December 1975, the MDCs for Pu-238 and Pu-239 in the NUMEC 

site profile are reported as 0.06 dpm/sample, with an error of 0.03 dpm/sample. For the same 

time period, the MDCs for Pu-238 and Pu-239 at LANL are similar; i.e., about 0.05 dpm/L 

(based on a MDC of 0.07 dpm/24h, as reported in ORAUT 2009a). However, the MDCs for 

Rocky Flats were higher at about 0.39 dpm/L (based on 0.54 dpm/24h, as reported in ORAUT 

2007c). ICRP Publication 54 (1989) reports an MDA of 0.01 Bq/L (about 0.6 dpm /L) for 

Pu-238 and Pu-239. This is much greater than the MDAs reported by LANL and NUMEC. 

Observation: It is difficult to comment on the NUMEC MDCs for this period of time because 

there is no description of the process that was used, and the MDCs are very low. On the other 

hand, LANL reports similar detection limits. 

For the year of 1999, the MDCs reported in the site profile varied from 0.0025 to 0.044 pCi/L for 

Pu-238 and 0.0025 to 0.045 pCi/L for Pu-239/240, without any information on the techniques 

that were used. It is difficult to believe that NUMEC could achieve the lower-end MDC of 

0.0025 pCi/L. For the same time period, the MDCs for Pu-238 and Pu-239 at LANL were 

0.008 pCi/24h (about 0.006 pCi/L), as reported in ORAUT 2009a. The MDC for Rocky Flats in 

1999 was 0.02 dpm/24h (0.009 pCi/24 hr and about 0.0064 pCi/L), as reported in ORAUT 

2007c. ICRP Publication 78 (1997) reports an MDC of 1 mBq/L (0.027 pCi/L). 

For fecal analysis, the only reported MDC is 0.1 dpm/sample for the period 1966–1977. No 

specification of the method used is given. For the same time period, there are no reported MDCs 

for Pu-238 and Pu-239 feces analysis at LANL (ORAUT 2009a) or at Rocky Flats (ORAUT 

2007c). ICRP Publication 54 (1989), reports an MDA of 0.01 Bq/sample (0.6 dpm/sample). 

ICRP Publication 78 (1997) reports 1 mBq/sample or 0.06 dpm/sample. 

Observation: Although possible, the MDC for the period 1966–1977 for feces bioassay appears 

to be low. 

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For lung counting, plutonium and americium counting started in 1966 and was conducted on a 

regular basis in 1968. Table 1 reproduces Table 5-9 from the site profile. 

Table 1. In-Vivo MDAs for Pu-239 and Am-241 

In vivo MDAs for 

239

Pu, 241Am.a 

239Pu MDA (nCi) 241Am (nCi) 

Year Minimum Maximum Counts Minimum Maximum Counts 

1968 NRb NRb NRb 0.13 0.38 17 

1969 NRb NRb NRb NRb NRb NRb 

1970 NRb NRb NRb NRb NRb NRb 

1971 NRb NRb NRb NRb NRb NRb 

1972 9 11.5 3 0.13 0.13 1 

1973 5.6 15.6 46 0.11 0.21 28 

1974 5.44 21.3 122 0.09 0.22 96 

1975 4.8 19.9 133 0.11 0.21 104 

1976 5 20.3 109 0.11 0.19 91 

1977 4.4 19.6 113 0.09 0.19 88 

1978 4.7 19 132 0.1 0.19 100 

1979 5.16 24.3 168 0.08 0.26 132 

1980 5.03 28.2 132 0.09 0.21 94 

1981 7.21 27.8 55 0.12 0.2 31 

1982 7.12 34.3 77 0.12 0.21 44 

1983 9.41 15.6 6 0.12 0.16 4 

1984 8.67 22.32 9 0.12 0.15 5 

1985 8.84 31.07 31 0.11 0.22 29 

a

 From a review of worker dosimetry records (Boyd 2006a,c,d,g,h,j). Values for 1968 through 1971 are 

based on the Helgeson system, with remaining values for the University of Pittsburgh system. b

 NR = none reported. 

Source: ORAUT 2012a, Table 5-9 

ORAUT-TKBS-0010-5 (ORAUT 2009b) reports MDCs for Am-241 lung counting at LANL for 

1977 and for the period 1980–1984. The MDC for both periods is about 0.3 nanocuries (nCi), 

higher than the NUMEC maximum MDAs for 1972–1985. The MDCs for Am-241 at Rocky 

Flats were about 1 order of magnitude higher than at NUMEC until 1976, when high-purity 

germanium detectors were used, and the MDCs were comparable to the NUMEC-listed ones 

(ORAUT 2007c). ICRP Publication 54 (1989) reports an MDC of 20 Bq (0.54 nCi) for Am-241 

lung counting. 

Finding 7: The MDAs for Am-241 lung counting are very low, and the counting method 

should be further explored in order to give them credibility. 

At LANL, the lung count MDAs for Pu-239 were much higher than the ones reported for 

NUMEC. ICRP Publication 54 (1989) reports an MDC of 2,000 Bq (54 nCi) for Pu-239 lung 

counting, a value similar to the MDCs from LANL and much higher than the MDCs for 

NUMEC. 

Observation: The results of Pu-239 measured directly should be used with caution, as it is very 

difficult to detect the low-energy emissions from Pu-239. 

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Air sampling for plutonium in Fab 5 at the Parks Township Site can be used to establish an 

average or default inhalation intake for plutonium workers. During 1967, approximately 400 BZ 

samples were taken in the scrap recovery area of Fab 5, and documentation indicates that 

additional data might exist (Crosby 1967, NUMEC 1967). However, the site profile does not 

present these data or guidance on how the data might support dose reconstructions. 

Finding 8: The site profile would benefit from a more thorough discussion of the possible 

use of air sampling data to reconstruct internal plutonium exposures and to take into 

consideration the additional data provided by Crosby 1967 and NUMEC 1967. 

4.6 THORIUM 

Section 5.2.3 of the site profile addresses thorium exposures, essentially explaining that there are 

few data, and that it will be difficult to reconstruct these exposures. Additionally, it is unclear if 

thorium areas were remediated prior to the final decontamination of either site. It appears that, 

sometime in late 1963 or early 1964, the Apollo Site did work for Bettis Atomic Power 

Laboratory (BAPL) fabricating ThO2 pellets (Forscher 1963). When bioassay data are available, 

they should be used; however, there is a potential that many thorium exposures were missed. 

The site profile states that air sampling was used rather than urinalysis, because urinalysis is not 

a reliable method for estimating thorium intake. 

The SEC petition evaluation reports for both the Apollo and Parks Township Sites found that 

there are insufficient information, air sampling, and bioassay data on thorium operations to 

bound thorium dose. SC&A reviewed the documentation on the SRDB for evidence of thorium 

work and found only minimal information on thorium processes, time frames, and cleanup. 

SC&A concurs that sufficient information is not available to accurately characterize thorium 

dose at either site. SC&A assumes that no attempt has been made or will be made to reconstruct 

internal thorium exposures for workers not covered by the SEC. 

4.7 MIXED FISSION PRODUCTS 

Section 5.2.4 of the site profile states that some bioassay data exist (presumably gross 

beta/gamma analysis of urine samples) that can be used to reconstruct internal exposures to 

mixed fission and activation products, including Co-60, Cs-137, strontium-90 (Sr-90), Tc-99 

(from RU), and ruthenium-106 (Ru-106)/rhodium (Rh). Exposure to mixed fission and 

activation products was possible at both sites, and the site profile acknowledges that it was 

difficult to adequately address which areas had a risk of exposure. At the Apollo Site, this 

exposure was linked to the commercial laundry facility; at the Parks Township Site, this 

exposure came from Building A. However, SC&A could not locate any specific information on 

the fission and activation product source terms at NUMEC. 

The site profile recommends that, if bioassay data are available (presumably expressed in terms 

of gross beta/gamma analyses per liter of urine), the dose reconstructor should assume the mix of 

radionuclides specified in ORAUT-OTIB-0054 (ORAUT 2007a). Though ORAUT-OTIB-0054 

was previously given a favorable review by SC&A for its intended purpose, we question its 

applicability to the NUMEC facilities. For example, in the following excerpt from page 9 of 

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ORAUT-OTIB-0054, the last sentence indicates that ORAUT-OTIB-0054 might not apply to 

internal exposures to fission and activation products at NUMEC: 

This guidance applies to a broad scope of reactor operations including plutonium 

production reactors (low enrichment, low burnup, Zircaloy or aluminum 

cladding), research reactors [modest enrichment, modest burnup, stainless-steel 

(SS) or Zircaloy cladding; e.g., Training, Research, Isotope General Atomics 

(TRIGA) reactors], high-enrichment, high-burnup reactors [e.g., Idaho National 

Laboratory’s Advanced Test Reactor (ATR), fuel from naval reactors], and fast 

breeder reactors [e.g., Hanford’s Fast Flux Test Reactor (FFTF), Argonne 

National Laboratory–West’s experimental breeder reactors]. It does not apply to 

radioactive lanthanum (RaLa) operations, which involved very short-cooled fuel 

but was performed in hot cells. It also does not apply to determination of intakes 

where radionuclides have been purposely extracted and concentrated as for heat 

generation sources, medical uses, or waste handling operations that caused 

significant alteration to the source term to which workers were exposed. 

Finding 9: It does not seem appropriate to use ORAUT-OTIB-0054 (ORAUT 2007a) to 

reconstruct the internal exposures of workers at NUMEC who might have been exposed to 

mixed fission products, because ORAUT-OTIB-0054 states that its guidance “does not 

apply to determination of intakes where radionuclides have been purposely extracted and 

concentrated as for heat generation sources, medical uses, or waste handling operations 

that caused significant alteration to the source term to which workers were exposed.” For 

example, see Table 5-1 of the site profile. Also, the fission product mix given in ORAUTOTIB-0054 does not contain the same radionuclides as the fission product mixes given for 

the NUMEC Laundry in the 1975 effluent release report (SRDB #20081) and for in-vivo 

count results in SRDB #19970. The NUMEC mixes include Co-60, which the ORAUTOTIB-0054 mix omits. 

4.8 RECYCLED URANIUM 

Joynar (1962) indicates that RU was present at both NUMEC sites. From this document, it 

appears that most, if not all, of the processing was done at the Apollo Site, and that the Parks 

Township Site was used for storage. Additionally, Portsmouth Gaseous Diffusion plant received 

over 300 kg of RU from NUMEC during 1972 (Wilcoxon 1999). Potential contaminates in RU 

were not consistently monitored as part of the bioassay program. 

Section 5.2.5 of the site profile advises dose reconstructors to use ORAUT-TKBS-0017-5 

(ORAUT 2004) and ORAUT-OTIB-0060 (ORAUT 2007b) to assign dose to the unmonitored 

radionuclides associated with RU. SC&A looked at these documents in the context of NUMEC 

dose reconstruction and found them to sufficiently address assigning dose from RU 

contaminates. SC&A notes that the site profile does not instruct dose reconstructors when to 

assign dose from unmonitored radionuclides associated with RU. It is unclear if this should be 

considered whenever a uranium bioassay is present or if some other criterion should apply. 

Additionally, the RU section is separated from the uranium section on internal dose assessment, 

which increases the likelihood that this dose would be missed by dose reconstructors. 

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In addition, the site profile recommends assuming the mix of radionuclides (relative to uranium 

observed in bioassay samples) as adopted for use at Fernald. SC&A agrees with this strategy. 

However, it is important to recognize that the mix of radionuclides comprising RU at Fernald has 

been modified as a result of the ongoing review of the Fernald site profile (ORAUT 2004) and 

SEC petition evaluation report (NIOSH 2006). 

Finding 10: Internal dose reconstructions performed for NUMEC personnel might need to 

be revisited in light of changes to the Fernald site profile (ORAUT 2004) with respect to 

RU. Also, additional direction is needed with respect to which workers or operations 

should be assigned RU intakes. 

4.9 SEALED SOURCES 

Records at the Parks Township Site indicate that sealed sources were made, though there appears 

to be minimal evidence establishing for whom the sources were created, the processes and 

controls in place, and exposure history. Neutron sources (Po-210/Be) and gamma sources were 

created in hot cells located in the plutonium facility in Fab 4. SC&A concurs with the findings 

of the SEC petition evaluation report (NIOSH 2008) that there are insufficient documentation 

and bioassay records to reconstruct dose from the fabrication of sealed sources. However, if 

bioassay data exist, an attempt should be made to quantify potential dose, with the caveat that 

care must be taken when using ORAUT-OTIB-0054 as the methods for reconstructing dose 

based on gross beta/gamma analysis of urine samples for the reasons discussed above in 

Section 4.6. 

4.10 IN-VIVO COUNTING 

Section 5.3 of the site profile addresses in-vivo counting for Pu-239, Am-241, uranium, and 

some fission products, which began around 1966 following an incident. SC&A found that, prior 

to March 25, 1968, whole-body counting (WBC) was not used at NUMEC. The facilities hired a 

mobile unit to assay 33 employees deemed to be at high risk for potential exposures. Of those 

assayed, 8 (6 for U-235 and 2 for Pu-239) had intakes giving a dose greater than the maximum 

permissible concentration (Caldwell 1968b). NUMEC believed that the working conditions 

leading to these intakes were resolved. Assays done on 38 individuals showed persistent 

problems with uptakes of U-235 and Pu-239 (Caldwell 1968a). Scans became somewhat more 

commonplace beginning at least as early as 1982. Records show that EEs were permitted to 

decline WBC scans if they desired. 

The site profile further states that from 1966 to 1969, lung counting was performed by the 

University of Pittsburgh. However, the site profile also states that, “In 1968 and 1971, Helgeson 

performed whole-body counts on individuals for fission products, 235U, 241Am, with 239Pu 

estimated from the 241Am results based on expected activity ratios for 239Pu/241Am” (Caldwell 

1968b). SC&A is concerned about this statement, because it is known that the Helgeson data 

were flawed and invalid for uranium chest measurements as late as 1989 or later. NIOSH states 

in the Pantex technical basis document (ORAUT 2007d, Section 5.2.2.3, page 23) that the 

Helgeson uranium data in 1989 at Pantex were likewise flawed and biased and could not be used 

for dose reconstruction. According to “Pantex Plant – Occupational Internal Dose,” ORAUTNOTICE: This report has been reviewed for Privacy Act information and has been cleared for distribution. 

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TKBS-0013-5, Revision 01 (ORAUT 2007d): “Note: Dose reconstructors should not use data 

from the Helgeson in vivo counts.” 

Finding 11: NIOSH should explain whether the concerns expressed in the Pantex site 

profile (ORAUT 2007d) about the Helgeson chest count data might also apply to chest 

count data at NUMEC performed by Helgeson for NUMEC workers. 

4.11 AIR SAMPLING 

Section 5.4 and Attachment A to the site profile address and present the results of five separate 

HASL reports prepared by the AEC that investigated airborne uranium exposures at the Apollo 

Site in selected time periods from 1959 to 1961. The following excerpt from the site profile 

concisely describes these investigations: 

The air samples consisted of radioactive particulates on filters from breathing 

zones and general areas during processing. The alpha activity measured on the 

filter was used to determine the airborne alpha activity concentrations. When 

multiple samples at a location were collected, the AEC used the mean air 

concentration in subsequent calculations. The AEC matched air concentration 

determinations with information about worker categories, locations, tasks, and 

time at each location or task. 

In addition, Section 5.6 of the site profile describes the uranium and plutonium air sampling 

programs and discusses investigations that established correlations between the breathing-zone 

air (BZA) sampling data, the GA sampling data, and bioassay data. The site profile states the 

following about these investigations: 

The correspondence between lapel sampler data and early fecal clearance for 

plutonium showed very good agreement, but fixed-station BZA samplers and 

general area air sampling usually underestimated airborne concentrations. Fifty 

percent of the lapel air sample results at Apollo showed concentrations seven 

times greater than the stationary air samples. The median of the ratio of lapel 

BZA to GA concentrations results was found to be ~7 at the Apollo and Parks 

Township sites [Caldwell et al. 1967).

Though SC&A did not review the results of these investigations, investigations of this type are 

not common and are considered to be indicative of a thorough health physics oversight program. 

The site profile explains that, when used in combination with the results of the bioassay 

programs, process knowledge, work location, and job descriptions, internal doses can be 

reconstructed for many workers, and that coworker models can be developed for many workers 

lacking bioassay data. SC&A concurs with this statement. 

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4.12 INCIDENTS AT BOTH SITES 

Section 5.5 of the site profile explains that dosimetry records should indicate if an individual 

exceeded the 40 maximum permissible concentration-hours exposure limit over a time period 

less than 1 work week. If this level of exposure continued for an entire year, the worker would 

exceed the annual limit for internal exposures. These records, along with other health physics 

practices described in the site profile, if kept faithfully, would represent a reliable source of data 

that would allow the reconstruction of internal doses to workers involved in an incident 

associated with a potential for a relatively high level of internal exposure. 

Sections 5.5.1 and 5.5.2 of the site profile list incidents at the two NUMEC facilities. SC&A 

reviewed the incidents mentioned in the site profile in comparison to the records found in the 

SRDB. The incidents selectively mentioned in the site profile are seemingly a random sampling; 

they should not be seen as encompassing all incidents at the sites. Incidents and large 

overexposures at both sites appear to have been fairly common during the early years of 

operation. Dosimetry, bioassays, personal BZ air sampling and Computer-Assisted Telephone 

Interview (CATI) report statements should be used to establish potential incidents and 

overexposure. 

It is noteworthy that the site profile section on the Apollo Site also indicates that none of the 

incident reports refer to worker exposures attributable to the incidents. In order to explore the 

degree to which incidental exposures were actually documented, SC&A sampled some cases to 

determine if any incidents are explicitly addressed as part of the dose reconstruction. Section 8 

summarizes the results of these investigations. 

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5.0 REVIEW OF EXTERNAL DOSE DURING OPERATIONS 

Section 6 of the site profile addresses external exposures at the NUMEC facilities and the data 

sources, assumptions, models, and protocols that should be used to reconstruct external 

exposures. Section 6.2 of the site profile summarizes the different types of external exposure 

scenarios that were present at the NUMEC facilities, which included neutron, gamma, and beta 

exposures associated with manufacturing or handling Pu, Th, HEU, Pu-Be, and fission and 

activation products. Table 6-1 of the site profile summarizes the sources and types of external 

exposures. Section 6.3 (Table 6-2) of the site profile describes the types of dosimetry used at 

NUMEC to detect and quantify these sources of external exposures, and Table 6-3 presents the 

MDLs for the various dosimeters as a function of time. Adjustments required to convert 

dosimeter readings to deep dose for photon and neutron exposures and non-penetrating dose for 

beta exposures are addressed in detail. The following presents a review and commentary on the 

completeness and accuracy of the external dosimetry data as described in the site profile and its 

supporting documentation. 

5.1 SPECIAL EXPOSURE COHORT RESTRICTED MONITORING DATA 

5.1.1 Apollo Special Exposure Cohort 

The Apollo SEC petition evaluation report (NIOSH 2007a) evaluated the feasibility of 

reconstructing external doses at the Apollo Site. It states the following (page 18): 

NIOSH has concluded that information pertaining to external dosimetry is 

inadequate to ensure that sufficiently accurate external exposures can be 

reconstructed for the NUMEC Apollo operations. 

The NUMEC site profile states that data on the neutron source fabrication are lacking. NIOSH 

concluded that, because of this lack, it cannot accurately bound these doses during operations. 

However, NIOSH also states that, although external monitoring is inadequate for dose 

reconstruction, if information is available, it should be used: 

Although NIOSH has determined in this evaluation that there is a lack of 

sufficient data to permit estimating and/or reconstructing NUMEC Apollo 

external doses with sufficient accuracy, NIOSH does intend to use any available 

external data that may be included in an individual’s file (and that can be 

interpreted using existing NIOSH dose reconstruction processes or procedures) 

to support a partial external dose reconstruction for non-presumptive cancers 

and/or cases that have less than 250 working-days of employment. 

SC&A assumes that NIOSH made these statements, which appear to conflict somewhat, because 

there are external dosimetry data that will be used to support partial dose reconstructions for 

workers not covered by the SEC. The NUMEC site profile does mention the lack of information 

relating to neutron source fabrication, but it is not clear that this lack extends into the external 

dose reconstruction. SC&A conducted a review of the available dosimetry records and 

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determined that there was sufficient external monitoring to generate a coworker model. This is 

discussed in further detail below. 

5.1.2 Parks Township Special Exposure Cohort 

In the Parks Township SEC petition evaluation report (NIOSH 2008), NIOSH did not feel that it 

was necessary to do an adequacy determination for external dose based on the inadequacies in 

internal dose data. This is a different approach from what NIOSH did for the Apollo Site. It 

appears that, based on inspection of the SEC petition evaluation report, NIOSH believes that 

external exposures at the Parks Township Site can be reconstructed with sufficient accuracy. 

5.2 OVERVIEW OF COMPLETENESS AND ACCURACY 

The NUMEC dosimetry program was fairly complex, as it needed to address a wide range of 

energies and types of radiation. For example, the “I” and “R” dosimeters supplied by Landauer, 

Inc., were complex devices that incorporated several neutron- and gamma-detection components 

into one overall device. In many ways, the dosimetry program was on a par with the Argonne 

National Laboratory-East (ANL-E) dosimetry program. These programs were similar in that 

multiple vendors and technologies were used in a wide variety of radiation fields over several 

decades. The discussion of external dosimetry in the NUMEC site profile runs 11 pages, 

compared with 32 pages in the (pre-review) ANL-E site profile (ORAUT 2006). The NUMEC 

site profile needs additional sections on data discrepancies, common issues, gaps in energy 

response for neutron dosimetry, and other items. 

SC&A observes in general that a more detailed assessment of the external program is needed. 

For example, were badges worn in multiple locations, and if so, how is the record to be 

interpreted? How were gaps and inconsistencies in the data handled? For example, if one 

component of a multi-component badge was lost or damaged or conflicted with the reading from 

another component of the same badge, how was this addressed? No mention of lead aprons is 

made in the site profile. Was any protective gear used throughout the history of the site? 

Likewise, no mention is made of pouches or badge protection in a potentially dirty industrial 

setting. Contemporaneous photographs showing protective equipment and dosimetry wear 

practices would be informative. The description of the multi-component badges would benefit 

from additional discussion of the cutover between components, such as albedo and track etch 

neutron detection. On a positive note, the Landauer “I” and “R” dosimeters were the most 

comprehensive dosimeters that Landauer provided at the time and may indicate that NUMEC 

was using the best available technologies to monitor workplace exposures. 

5.3 ITEMS REQUIRING CLARIFICATION 

Table 6-2 in the site profile describes the dosimeters used throughout the period in question: 

Table 2. Excerpt from Table 6-2 in the Site Profile 

1976–present Landauer or equivalent TLD 

(Z1 dosimeter - 1990) 

Comprised of 3 TLD-700 chips for monitoring beta, X-ray, 

and gamma exposure. Insensitive to neutron radiation. 

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The Landauer “Z1” dosimeter described also contained a CR-39 track etch device for fast 

neutron detection. This fact should be added to the description, assuming the Z1 was indeed in 

use for the period described. 

Section 6.3.2 of the site profile appears to be inconsistent with Table 6-2: 

Workers were monitored for neutron exposures with nuclear track emulsion, 

Type A (NTA) film from commercial venders until about 1968, and with TLDs 

thereafter. In addition, criticality dosimetry monitoring was done with an array 

of area critical assemblies that fed into a central system. This system existed from 

at least 1963; in September 1963, each visitor and employee was issued an 

indium foil criticality dosimeter as part of each security badge (NUMEC 1963). 

From 1968 forward, the facility did not use only a thermoluminescent dosimeter (TLD) for 

neutron monitoring, but also track etch, according to Table 6-2 of the site profile. Also, 

Table 6-2 describes the method for deriving the fast neutron dose that involved subtraction of the 

thermal dose. It is not clear if this was determined from a cadmium-filtered film badge or not. 

Table 6-2 lists multiple technologies, including NTA, CR-39, Albedo TLD, and (implied) 

thermal neutron photographic film. The text in Section 6.3.2 only lists NTA and TLD for routine 

dosimetry, but mentions indium foil criticality dosimeters that are not addressed in the table. 

Finding 12: Table 6-2 and the associated text in Section 6.3.2 of the site profile should be 

reviewed and modified as needed to correct any oversights, inconsistencies, or errors. 

5.4 SOURCE TERM 

Table 6-1 of the site profile lists radioactive source manufacturing operations as a potential 

source of gamma and neutron exposure. Given that large quantities of beta-emitting materials 

were used to produce sources, there would have been a significant potential exposure to large 

beta fields, especially during non-routine operations and unusual events. While there is 

extensive discussion of the fuel manufacture and processing activities, the site profile provides 

little detail on the source manufacturing operations. 

The brief discussion of potential beta radiation fields in Section 6.2.1 is limited and does not 

mention source production operations. NUMEC produced AmBe and other alpha-N sources, so 

there would have been exposure potential for the entire manufacturing cycle, including 

processing, storage, waste handling, maintenance, and transportation. The modest source of 

neutron exposure, UF6 cylinders, is mentioned as a potential neutron source in Section 6.5.2.3. 

Metrics need to be added that account for the quantity and size of sources produced, along with 

protocols for transfers, storage, and so forth. 

In the body of the text, there is no mention of the considerable license limits that NUMEC was 

authorized to possess for source production (Tables 2-4 through 2-8 of the site profile). Several 

beta-emitting nuclides, including Ir-192, Cs-137 and Co-60, were used to manufacture sources. 

Did routine operations protect operators from all beta dose due to the penetrating nature of the 

gamma emissions? Regardless, there is a concern in the following situations: incidents, 

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transferring materials in and out of hot cells and gloveboxes, spills, plant and equipment 

maintenance, and waste handling. In some of these situations, the amount of radioactive material 

might be low compared with possession limits, but beta exposure would likely be the primary 

concern for unshielded or minimally contained situations. Given that these situations would 

involve highly non-uniform fields, some discussion of badging practices, extremity results, and 

use of local shielding would be helpful. The external dosimetry section needs expansion to 

include some metrics on the amount of material handled, worker protection, and other relevant 

information. Issues associated with non-uniform exposures to non-penetrating radiation at this 

site are highlighted here, because skin cancers are not covered by the SEC. For example: 

• What was the throughput of sources, how large were they, and what kinds of facilities 

were used for processing? 

• Were the glovebox gloves lead loaded, and if so, what was their effective attenuation for 

17 and 60 kiloelectronvolt (keV) x-rays? 

• How was non-uniform exposure addressed, and where was the body dosimeter worn? 

• Did all glovebox workers wear wrist badges? 

• How was the extremity dose adjusted due to the wear location of the wrist badge, 

especially for beta dose?

• Did either facility switch to finger TLD rings at any point? 

Finding 13: Given our understanding that it is NIOSH’s position that external exposures 

at the Parks Township Site can be reconstructed with sufficient accuracy, it appears that 

the description of the sources and circumstances responsible for external exposures need to 

be better developed, if possible. 

5.5 NTA NEUTRON DOSIMETRY 

From 1958 to 1970, the NUMEC sites used only NTA to monitor non-thermalized neutrons. 

NTA is only able to monitor neutrons 800 to 1,000 keV and up. No provision is contained in the 

site profile to address exposures below this energy range. Indeed, Section 6.4.2 expressly states, 

“However, at this time, the neutron dosimeter readings should be used without correction for this 

effect.” Note that this section also implies that NTA can be used for energies between 500 and 

800 keV. The ANL-E site profile and others use an 800- or 1,000-keV threshold. Other sources 

list 1,000 keV as the threshold for NTA response. As has been the case in a number of site 

profiles, there is an inconsistent approach to the energy cutoff for NTA neutron dosimetry. We 

believe that the assumption that NTA film responds down to 500 keV is not justified by the 

technical data, and is not claimant favorable. 

Other site profiles, such as ANL-E’s, demonstrate that there needs to be a thorough consideration 

of the limitations of the NTA technology for the period in question. Given the range of neutron 

source terms and the uncertainty regarding the response of the dosimeter, an assessment of 

potentially missed dose is needed. At the very least, a correction factor of 4 may be warranted 

for plutonium-handling facilities, as was suggested for the ANL-E site profile. Other situations 

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in which workers might have been exposed to neutrons with energies below 1 MeV should also 

be evaluated. 

Finding 14: The site profile should provide justification for why adjustment factors are not 

required for neutron exposures estimated using NTA film, considering that it appears that 

the neutron energy spectrum likely extended to well below 1 MeV. For example, Table 6-8 

of the site profile indicates that the energy range of neutron exposures extended from 0.1 to 

2 MeV. 

According to Section 1.3.1 of the site profile: 

An SEC has been identified that includes all AWE employees who were monitored 

or should have been monitored for exposure to ionizing radiation while working 

at the NUMEC site in Apollo, Pennsylvania, from January 1, 1957, through 

December 31, 1983, for a number of work days aggregating at least 250 work 

days or in combination with work days within the parameters established for one 

or more other classes of employees in the SEC. 

As one of the reasons for granting the SEC, NIOSH determined that it is not feasible to 

reconstruct doses from radium-beryllium and polonium-beryllium neutron source fabrication 

operations. However, the site profile states that “partial doses can be estimated for workers for 

whom applicable monitoring data are available.” This statement suggests that it might be 

possible for NIOSH to perform partial dose reconstructions for workers exposed to other sources 

at this site who were not included in the SEC class. Furthermore, an SEC was also granted for 

the NUMEC facility in Parks Township, Pennsylvania, from June 1, 1960, through December 31, 

1980. That SEC was based on the inability to reconstruct internal doses. Consequently, NIOSH 

may attempt to perform partial dose reconstructions for workers exposed to neutron radiation at 

this site who were not included in the SEC class. The dosimetry methods that might be used to 

reconstruct neutron doses to workers at either facility who are not included in the respective SEC 

classes need to be examined. 

Dosimeters containing NTA film were used to monitor external exposures to neutron radiation of 

NUMEC personnel at the Apollo and Parks Township Sites from 1957 through May 1968. The 

energy response of the NTA film was long known to depend on the neutron spectra to which the 

badge was exposed. Some sites, such as Mound Laboratory, therefore sought to calibrate the 

films using sources that were similar to the neutron emitters that were being processed on site. If 

the neutron spectrum of the calibration source closely matches the spectrum of the neutron 

sources to which the workers are exposed in the course of their employment, then the NTA film 

dosimetry records, with proper adjustments for effective dose, can yield reasonable estimates of 

the doses from external exposure to neutron radiation. If the workers were exposed to sources 

with neutron emission spectra that were lower in energy than those emitted by the calibration 

source, the NTA film dosimetry reports underestimated the neutron dose. Conversely, if the 

neutron spectra in the workplace had higher energies than those of the calibration source, the 

doses were overestimated. 

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According to Section 6.4.2 of the site profile: 

NTA film has a characteristic decreasing response to neutron radiation at 

energies below about 500 to 800 keV, depending on the extent of photon fogging 

and the overall process to develop and read the tracks [ORAUT 2006]. However, 

at this time, the neutron dosimeter readings should be used without correction for 

this effect. 

The site profile gives no justification for this directive to dose reconstructors (i.e., no correction 

factors are needed). NIOSH needs to examine any existing NTA film calibration records to 

determine how well the calibration methods corresponded to the actual neutron exposures of 

workers at the two sites and during various time periods. Absent such information, NIOSH 

should apply claimant-favorable correction factors. A detailed discussion and analyses of the 

correction factors for NTA film exposed to various neutron spectra versus the sources used to 

calibrate the film are presented by R. Anigstein and D. Olsher in SC&A (2010). 

5.6 PHOTON DOSE ADJUSTMENTS 

Section 6.5.2.2 of the site profile recommends that no adjustments are needed for shallow or 

deep dose photon exposures. The difference in dosimeter response between Am-241 and 

plutonium x-rays can be significant, especially where beta is also a consideration. The potential 

for either over-response to Am-241 or under-response to plutonium x-rays needs to be addressed 

for various mixtures of radiation and for the differing dosimetry technologies, processors, and 

time periods. 

The site profile discussion of low-energy photon adjustments includes wording that seems 

irrelevant or misleading (page 57): 

Table 6-5 summarizes the gamma energy distribution for NUMEC plutonium in 

comparison with Hanford plutonium. Beta energies are included as well as 233U 

and 241Am, which have similar overall photon and beta properties. 

Table 6-5 presents this information as follows: 

Table 3. Table 6-5 Reproduced from the Site Profile 

Energy-photon NUMEC plutonium (

241Am & 233U) Hanford plutonium 

<30 keV 15 25 

30–250 keV 82 75 

>250 keV 3 0 

Energy-beta NUMEC plutonium (

241Am & 233U) Hanford plutonium 

>15 keV 100 100 

It is unclear what the authors intended by describing all beta energies for Am-241 as being 

>15 keV, as Am-241 and U-233 are alpha emitters. 

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The site profile extensively references and excerpts Gamma Spectrum Measurements and the 

Interpretation of Absorbed Dose during Plutonium Fuel Fabrication (Caldwell and Judd 1966), 

a paper on the use of the Eberline film dosimeter at NUMEC. Section 6.4.1 of the site profile 

implies that the data in this paper are to be used for the entire history of and all programs at the 

NUMEC sites. This is problematic, because the data presented in the paper were limited to 

6 months for NUMEC’s plutonium laboratory and hot cell facility operations, and were only 

intended to address plutonium dosimetry issues. Aside from the specific discussion of the 

Caldwell and Judd (1966) paper, the site profile offers no discussion of other sources of exposure 

or work environments. Section 6.5.2.2 of the site profile recommends no adjustments to the 

NUMEC recorded shallow and deep doses based (presumably) on the Caldwell and Judd paper, 

and does not justify the statement that, “The existing recorded doses provide a realistic estimate 

of the actual doses.” 

Many other operations took place at NUMEC beyond the plutonium and specific hot cell work 

described in the contemporaneous Caldwell and Judd (1966) paper. Likewise, a number of 

differing dosimetry technologies were in use, including several types of film badge holders and 

possibly film emulsion. The appropriateness of generalizing the Caldwell and Judd data for 

plutonium work and to the entire NUMEC dosimetry program has not been assessed and needs 

to be considered. 

Finding 15: The markedly different photon and neutron energies associated with the 

operations at NUMEC would indicate the possible need for adjustment factors for the 

results of film badge dosimeters, which are not provided in the site profile. 

The remaining issues that need to be explored are adequacy of coverage of workers who had the 

potential to experience the various types of external exposures, and the degree to which a 

claimant-favorable coworker model has been developed to reconstruct the external doses to 

workers who were not monitored or adequately monitored, but had the potential to experience 

external exposures. The following sections address these issues. 

5.7 EXTERNAL UNMONITORED WORKER ANALYSIS 

Section 6.5 of the site profile provides instructions for reconstructing external exposures to 

recorded beta, gamma, and neutron exposures. SC&A notes that Table 6-7 of the site profile 

instructs dose reconstructors to assign zero dose to workers who were not monitored, apparently 

because NIOSH believes that all workers who had the potential for significant exposure were 

issued personal dosimeters. The implication is that there is no need for a coworker model for 

external exposures, including beta and gamma exposures. This is in contrast to the Parks 

Township SEC petition evaluation report (NIOSH 2008), which states the following: 

However, during an AEC inspection in 1967 ([AEC 1967]), the inspectors noted 

that the radiation dose rate in an unrestricted area exceeded 2 mrem/hr, thus 

exceeding regulatory requirements for unrestricted areas. Surveys of unrestricted 

areas (NUMEC, 1968) were conducted between 1966 to 1968 also indicate 

periodic dose rates approximately 12 mR/hr in unrestricted areas outside the 

scrap recovery facility (FAB-5). Although most of the dose rates were relatively 

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low (background levels to < 0.5 mR/hr) around the facility, these periodic higher 

dose rates in unrestricted areas indicate that at various times unmonitored 

workers could have been exposed to low to moderate doses of radiation. In 

addition, NIOSH has limited documentation that associates job titles and/or job 

assignments with specific radiological operations from which to develop a coworker model for these unmonitored workers. 

Additionally, in the interviews conducted by NIOSH with former NUMEC employees, most EEs 

reported not being monitored despite having exposure risk. These matters are important and are 

explored in depth in the following sections of this report. 

In order to determine the external monitoring coverage of the worker population at NUMEC, 

SC&A took a random sample of 40 available claimants (20 from the Apollo Site and 20 from the 

Parks Township Site) who were employed during various operational and residual time periods 

(19572–1995). These 40 claims were examined to determine which employed years contained 

external dosimetry records. It should be noted that this study did not attempt to compile actual 

film badge data to determine any gaps within each monitored year,3 nor did this study attempt to 

compare the relative magnitude of film badge results among the different sampled claimant job 

categories. SC&A’s main objective was to determine the degree to which workers were, in fact, 

monitored. 

The number of sampled claimants employed by year, as well as the availability of external 

monitoring records for those claimants, are summarized in Table 4 and Figure 3. 

Table 4. Overview of Claimant Sampling by Year 

Year 

# of 

Sampled 

Claims 

# of Sampled 

Claims with 

Monitoring 

Data 

% of Sampled 

Claims with 

Monitoring 

Data 

Year 

# of 

Sampled 

Claims 

# of Sampled 

Claims with 

Monitoring 

Data 

% of Sampled 

Claims with 

Monitoring 

Data 

1958 1 0 0.0% 1977 16 7 43.8% 

1959 3 0 0.0% 1978 14 9 64.3% 

1960 5 0 0.0% 1979 14 7 50.0% 

1961 8 3 37.5% 1980 12 5 41.7% 

1962 13 2 15.4% 1981 12 4 33.3% 

1963 15 2 13.3% 1982 12 7 58.3% 

1964 16 6 37.5% 1983 10 4 40.0% 

1965 14 4 28.6% 1984 6 2 33.3% 

1966 14 3 21.4% 1985 6 2 33.3% 

1967 18 7 38.9% 1986 6 4 66.7% 

2

 None of the claimants sampled were employed in 1957, so this study begins in 1958. 3

 Based on claimant CATI reports and information in the site profile, routine badging was exchanged on a 

monthly basis. A worker being identified as having been monitored in a given year does not necessarily indicate 

that the external dosimetry records were complete for that year. 

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Table 4. Overview of Claimant Sampling by Year 

Year 

# of 

Sampled 

Claims 

# of Sampled 

Claims with 

Monitoring 

Data 

% of Sampled 

Claims with 

Monitoring 

Data 

Year 

# of 

Sampled 

Claims 

# of Sampled 

Claims with 

Monitoring 

Data 

% of Sampled 

Claims with 

Monitoring 

Data 

1968 20 8 40.0% 1987 6 4 66.7% 

1969 17 6 35.3% 1988 6 3 50.0% 

1970 18 7 38.9% 1989 6 6 100.0% 

1971 18 8 44.4% 1990 7 4 57.1% 

1972 16 6 37.5% 1991 8 4 50.0% 

1973 16 7 43.8% 1992 8 3 37.5% 

1974 18 10 55.6% 1993 7 3 42.9% 

1975 17 9 52.9% 1994 6 4 66.7% 

1976 17 8 47.1% 1995 4 3 75.0% 

Figure 3. Overview of Claimant Sampling by Year 

As seen in Table 4 and Figure 3, the random sample of 40 claimants covers most operational 

years at NUMEC, as well as the residual period. The percentage of claimants monitored for 

external radiation was generally in the 30%–70% range and increased as time went on at the site. 

The average percentage of claimants with external monitoring over the period of interest was 

approximately 42%; no external monitoring data could be located for the 40 sampled claimants 

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until 1961. A more detailed description of the claimant population sampled is shown in 

Appendix B to this report. 

As can be seen in Appendix B, SC&A examined a wide variety of job titles at NUMEC in the 

random claimant sample, including: 

• Technicians (nuclear fuel fabrication, laboratory, powder, quality control, health and 

safety, electronics). 

• Operators (liquid waste/waste tank, furnace, dissolver, glovebox, press operator, truck 

driver). 

• Administrative (secretary, receptionist, supervisor, foreman, health and safety manager, 

accounting clerk). 

• Other plant jobs (chemist, chemical engineer, laborer, security guard, janitor, 

maintenance man). 

Therefore, the random sampling appears to represent an appropriate cross section of the types of 

jobs and associated exposure potential experienced at the site. As shown in Table 4, exactly half 

(20) of the claims examined had no external monitoring available in their dosimetry file. 

However, 9 of the 20 claims with no external monitoring did have some internal monitoring 

(urinalysis or WBC) that might serve as an indicator of exposure potential. 

CATI reports for this group of unmonitored workers indicate that 14 of the 20 EEs worked in 

radiological areas on a routine or semi-routine basis, 2 of the 20 only entered radiological areas 

on rare occasions, and 2 of the 20 did not enter radiological areas. The remaining CATI reports 

did not indicate whether the claimants entered radiological areas. Job titles among workers with 

no available external monitoring included technicians, operators, laborers, furnace, and 

maintenance workers. All of these job titles would presumably subject the worker to external 

exposure sources. 

The method by which reconstruction of external dose was handled for claimants with no or 

insufficient external monitoring was not consistent among the sample population. For example, 

SC&A observed the following external dose reconstruction methods among the sampled 

claimant population: 

• Reconstruction of medical x-ray doses only (reference numbers: 2, 4–6, 10, 13–15, 20, 

24, 32, 34, and 40; these reference numbers are described in Appendix A). 

• External dose reconstructed based on DOE quarterly or annual dose limits at the time 

(reference numbers: 29 and 33). 

• External dose reconstructed based on “coworker studies for other DOE sites” (reference 

number: 27), coworker dose from the Rocky Flats Plant (reference number: 30) or 

simply “coworker studies” (reference numbers: 23, 27, 30, and 39). 

• External dose reconstructed based on ORAUT-OTIB-0004 (ORAUT 2005c). 

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Finding 16: NIOSH should consider developing a coworker model based on NUMEC 

claimant records or specify a more consistent basis for assigning external doses beyond the 

medical x-rays associated with the site. 

5.8 OCCUPATIONAL MEDICAL EXPOSURE 

NUMEC apparently did not have a medical x-ray department during the operational years. 

Many EEs have blank claimant medical records; however, scans were done and analyzed offsite, 

which could potentially explain the absence of records in some EEs’ files. 

It is clear that during at least 1963, annual, new hire, and termination posterior-anterior scans 

were performed. Additionally, EEs who worked with beryllium received two posterior-anterior 

examinations per year. There is no evidence indicating that lateral or lumbar scans were used at 

either site. There is no other site-specific information on x-ray examinations available. Earlier 

versions of the site profile recommended using ORAUT-OTIB-0006 (ORAUT 2005b) to assign 

dose. However, Section 3.0 of the site profile concludes that medical exposures should not be 

assigned if the medical exposures were performed offsite. This is consistent with the new policy 

in ORAUT-OTIB-0006 that states the following: 

A recent NIOSH interpretation of the EEOICPA statute is that the statute defines 

covered radiation as the radiation received by a covered employee at a covered 

facility during a covered period (NIOSH 2010). This interpretation affects how 

X-ray dose should be assigned if the X-rays were taken at a site or location that is 

not defined under the statute as a covered facility, such as offsite locations 

including private physicians’ offices, clinics, or local community hospitals. 

Except in limited circumstances concerning residual radiation, only radiation that 

the employee received at a covered facility can be included in dose 

reconstruction. [ORAUT 2011b] 

ORAUT-OTIB-0079 (ORAUT 2011a) provides additional guidance on offsite x-ray 

examinations. SC&A confirmed that examinations occurred off site, though the cited file 

(NUMEC 1963) in the site profile is unavailable on the SRDB. Because there is no evidence to 

suggest that NUMEC had onsite x-ray examination facilities, and the site profile states that they 

were performed at a “local clinic or hospital,” these examinations are not eligible to be included 

in the dose reconstruction. 

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6.0 REVIEW OF THE RESIDUAL PERIOD 

The residual period for the NUMEC Apollo Site covers 1984 through 1995, and the residual 

period for the NUMEC Parks Township Site covers 1981 through 2004. Section 7.0 of the site 

profile discusses the estimation of exposure during the residual periods. 

As of August 23, 1978, NUMEC had completed decommissioning of its HEU processing at the 

Apollo Site. All process and related equipment were removed by this date. NUMEC indicated 

that access to the area was controlled to authorized personnel. In 1982, the NRC conducted a 

confirmatory survey to identify the remaining HEU inventory during decommissioning. The 

NRC report indicates uranium contamination levels in terms of grams of uranium per unit 

surface area. The NRC estimated the total grams of uranium remaining on and in the floors, 

walls, pad, and ceiling at the Apollo Site to be 35,548.55 grams of total uranium, with about 

23,743.27 grams of U-235 (NRC 1982). 

Decontamination for the Apollo Site was completed from 1984 to June 1992. In June 1992, the 

NRC approved the Apollo decommissioning plan. Decommissioning occurred from June 1992 

to 1995. The NRC staff reviewed the Babcock & Wilcox (B&W) groundwater monitoring data, 

final termination survey, and a confirmatory survey in 1996. On April 14, 1997, after notifying 

the Pennsylvania Department of Environmental Protection, the NRC issued a letter to B&W 

terminating the Apollo license (PDEP 2008). 

The Parks Township Site ceased work for DOE operations in 1980. Decontamination and 

decommissioning of the facilities began in 1978 at Building C and continued through several 

phases for all facilities. Starting in 1994, B&W began final decontamination and 

decommissioning at the Parks Township Site to the extent permitted under the terms of its 

license. In January 1996, B&W submitted a site-wide decontamination and decommissioning 

plan, with subsequent plan revisions in 1997 and 1998. In October 1998, the NRC approved 

Revision 3.1 of the plan. Demolition and removal of all facilities were started at that time. All 

decommissioning activities had been completed by January 2002. All waste had been shipped to 

a licensed waste disposal facility, and the final status survey had been performed. After B&W 

completed 2 years of groundwater monitoring that showed that site ground water was within 

established limits, the NRC terminated the license and released the site for unrestricted use on 

August 24, 2004 (PDEP 2008). 

Because the site profile states that the SEC periods cover the operations periods (i.e., January 1, 

1957, through December 31, 1983, for the Apollo Site and June 1, 1960, through December 31, 

1980, for the Parks Township Site), the residual period is not covered under the SEC. Hence, 

reconstruction of doses during the residual period is of particular importance. 

6.1 EXTERNAL DOSE 

6.1.1 External Dose at the Apollo Site 

For the Apollo Site, the site profile recommends that, for workers who have personal dosimetry 

data during the residual period, the data should be used for dose reconstructions. The site profile 

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also explains that, since non-Atomic Weapons Employer (AWE) radiological activities 

continued at the Apollo Site after 1983, the dosimetry readings would place an upper bound on 

the external exposures from residual radioactivity associated with AWE operations. For workers 

without personal dosimetry during the residual period, the site profile recommends that dose 

reconstruction be based on the assumption that workers were exposed to surface contamination 

levels associated with the average surface contamination measured at the end of the operational 

period [4.97E6 dpm/m

2

 (GSD = 7.91)], and that the contaminant was natural uranium. SC&A 

refers to this strategy as “the OTIB-0070 approach,” because it is compatible with the basic 

guidance provided in ORAUT-OTIB-0070, Revision 01 (ORAUT 2012b). SC&A concurs with 

this basic strategy, because it places a plausible upper bound on the average surface 

contamination that might have been present during the beginning of the residual period, and the 

external dose conversion factor for natural uranium is limiting as compared to enriched uranium. 

It also appears that the external dose rate derived in this manner for the residual period at the 

Apollo Site is assumed to remain constant throughout the residual period, which is also a 

bounding assumption, because residual surface contamination would be expected to decline by 

natural attenuation as it ages. 

6.1.2 External Dose at the Parks Township Site 

For the Parks Township Site, actual recorded dosimetry results are used for the period of 1981– 

1983, when available, because Apollo was still performing work for DOE during that time. 

External dose estimates assume either HEU or plutonium exposure, depending on the EE’s work 

location. The site profile advises defaulting to uranium exposure if a work location cannot be 

determined. SC&A finds this guidance to be claimant favorable, because it assumes a monitored 

EE may have visited Apollo during the years it was still operational and thus been at risk of 

DOE-related exposures. 

For workers without personal dosimetry during the residual period, NIOSH used the same 

approach as for the Apollo site uranium external dose. NIOSH used the average surface 

concentration at the end of the residual period [2.74E5 dpm/m

2

 (GSD= 4.97)] to estimate the 

annual external dose to workers using the OTIB-0070 approach. Assuming the plutonium 

isotopic composition listed in Table 5-3 of the site profile, NIOSH reported all organ doses were 

below 0.001 rem. NIOSH concluded no external dose from potential plutonium exposure need 

be assigned to EEs at Parks Township. SC&A independently calculated plutonium dose using 

the dose conversion factors from Federal Guidance Report 12, Table III.3 (EPA 1993), and 

found that the dose to each organ assuming 20-year aged plutonium is less than 0.0001 rem per 

year. SC&A agrees that external dose from plutonium during the residual period can be omitted 

from Parks Township dose assessments. 

For Parks Township workers that were unmonitored during the residual period, but are thought 

to have worked in Building C or come in contact with HEU, the site profile advises dose 

reconstructors to assign the same residual external dose as Apollo. SC&A finds this to be 

reasonable, because no information on air concentrations of plutonium at Parks Township is 

available. The Apollo site handled more uranium for longer times than Parks Township, so this 

is thought to be a bounding approach. 

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6.1.3 External Beta Dose at Both Sites 

No beta exposure is assigned to workers for the residual period at the Parks Township or Apollo 

Sites. Previous analyses performed in support of SC&A’s review of Battelle-TBD-6000 

(Battelle 2007) revealed that the skin dose 1 meter above a surface contaminated with residual 

uranium from beta emission is 100 times greater than the dose from penetrating radiation. 

Table 5 presents the results of SC&A’s previous calculations, as provided in our review of 

Battelle-TBD-6000. 

Table 5. Dose Rates at 1 Meter above a Contaminated Floor, 

Calculated with MCNP (mrads/hr per dpmα/m2) 

Radiation Breast Testes Skin 

Electrons 1.19E-09 2.58E-10 2.13E-08 

Gammas 1.17E-10 1.29E-10 1.37E-10 

Bremsstrahlung 1.18E-11 1.32E-11 1.11E-11 

Total 1.32E-09 4.00E-10 2.15E-08 

Source: Battelle 2007. 

As shown in Table 5, direct beta rays (electrons) are the major contributors to skin dose. This 

matter was addressed as part of the Procedures Subcommittee issues resolution process, and 

NIOSH agreed with this concern and revised the original Battelle-TBD-6000 (Battelle 2006). In 

fact, Battelle-TBD-6000 was revised (Battelle 2011), and Table 3.10 (page 26) of that revision 

presents updated beta dose rates from a contaminated floor that are a little higher than the values 

presented in Table 5 above. Therefore, SC&A believes that this part of the NUMEC site profile 

needs to be amended in accordance with the guidance provided in the latest version of TBD6000. 

Finding 17: The site profile should include guidance for deriving non-penetrating doses to 

skin and other organs from beta emitters associated with surface contamination during the 

residual period. 

6.2 INTERNAL DOSE 

6.2.1 Apollo Site 

The site profile states that when bioassay records exist during the residual period, these records 

should be used to reconstruct internal doses. The site profile also states that if the bioassay data 

are from CEP records, they cannot be used to reconstruct internal doses because of CEP’s 

confirmed involvement in data falsification. CEP records can only be used to establish exposure 

risk. SC&A concurs with this strategy. When bioassay records are not available or cannot be 

used, the site profile recommends the following coworker model, which is based on modeling 

resuspension of residual contamination. 

In order to reconstruct resuspended uranium particles, the site profile recommends using the 

median air activity 210 dpm/m3 that NIOSH derived from the HASL studies done during 1959– 

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1961. These studies were used to determine the average BZ concentrations experienced by 

various workers involved in the process of converting UF6 into uranium dioxide, uraniumzirconium scrap recovery, and coating of uranium products in 1959–1961. As discussed earlier, 

SC&A has concerns with the methods used by NIOSH to develop the median uranium air 

concentration for use during operations. However, SC&A considers the use of airborne dust 

loading and intake rates observed during operations to be a reasonable starting point for 

bounding the initial airborne dust loading and intake rates during the residual period. SC&A 

suggests that GA samples, as opposed to BZ samples, be used for the residual period, because 

BZ samples are more closely associated with the direct generation of aerosols in the BZ of 

workers during operations. General air (GA) samples are more closely associated with the 

overall average airborne dust loading and associated intakes that might result from resuspension 

processes during the residual period. 

Finding 18: General air (GA) air samples, as opposed to BZ samples, should be used as the 

starting point for reconstruction of radionuclide intake rates during the residual period. 

Given the average annual airborne dust loading during operations, the site profile estimates the 

surface contamination level at the beginning of the residual period by assuming the airborne dust 

settles at a rate of 0.00075 meters per second (m/sec) over the course of 1 year, as follows: 

210 dpm/m3 × 31,536,000 sec/year × 0.00075 m/sec = 4.97E6 dpm/m

2 

Based on previous site profile reviews, SC&A concurs with the deposition velocity of 

0.00075 m/sec; this value represents the settling velocity of 5 micron activity median 

aerodynamic diameter (AMAD) particles. Extensive empirical measurements performed at the 

Hanford Metals Handling Facility confirm the validity of this assumption (Adley 1952). 

The assumption that the buildup accumulates for a period of 1 year seems intuitively reasonable, 

because it can be assumed that there was some degree of periodic housekeeping that would 

remove the loose contamination from surfaces during operations. 

Given the surface residual contamination, the site profile uses a resuspension factor (RF) of 1 × 

10-6/m to derive the airborne dust loading at the beginning of the residual period, as follows: 

4.97E6 dpm/m2

 × 1 × 10-6/m = 4.97 dpm/m3 

The NUMEC site profile was originally prepared before issues related to RFs were addressed by 

the Procedures Subcommittee (i.e., ORAUT-OTIB-0070) and also by the Battelle-TBD-6000 

Work Group. The outcome of those issue-resolution activities was an agreement among the 

participants (i.e., NIOSH, SC&A, and the Advisory Board) that an RF of 1 × 10-6/m is 

appropriate for sites that have been cleaned up, such that there was little removable 

contamination. However, at facilities where the surface contamination was not cleaned up, such 

as at Apollo, an RF on the order of 1 × 10-5/m is more appropriate. Using an RF of 1 × 10-5/m, 

the initial airborne dust loading during the residual period would be about 50 dpm/m3. This 

aspect of ORAUT-OTIB-0070 (site-specific RF) was not incorporated into the latest revision of 

the site profile. 

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Finding 19: SC&A recommends that NIOSH use an RF of about 1E-5/m to derive the 

airborne dust loading for the beginning of the residual period, or perhaps simply assume 

that the average GA dust loading observed during the operational period is applicable to 

the beginning of the residual period. 

The site profile further recommends that, as time goes by, the dust loading declines by the factors 

listed in Table 4-2 of ORAUT-OTIB-0070. This rate of decline in the residual contamination is 

an attenuation rate of 0.00067/day (0.067%/day). SC&A finds this depletion technique to be 

consistent with the most current guidance on source term depletion. 

SC&A notes that the site profile is silent regarding any residual radioactivity other than uranium, 

even though the facility worked with thorium, plutonium, and other radionuclides. 

Finding 20: The site profile makes no reference to radionuclides other than uranium 

during the residual period at Apollo. 

6.2.2 Parks Township Site 

The site profile explains that, when bioassay data are available, they should be used to establish 

internal dose during the residual period, unless the samples were analyzed by CEP, which did not 

produce reliable results. CEP results, however, should be used to indicate intake potential. 

No formal air monitoring studies were conducted at the Parks Township Site; however, it is 

known that plutonium was the largest component of the source term at the site. NIOSH 

compiled 105 GA samples, which were collected from 1966 to 1982. These data were fit to a 

lognormal distribution, as shown in Figure 4, which was excerpted from Figure 7-1 of the site 

profile. 

Using this distribution, the average daily air concentration was estimated to be 11.6 dpm/m3 

(GSD=7.91). SC&A reviewed the available air monitoring information and found that the 

methods NIOSH used are appropriate. SC&A did not attempt to reproduce this value, but 

believes it is reasonable, given the GA sample results. NIOSH then used the average air 

concentration to estimate the surface concentration of plutonium to be 2.74E5 dpm/m

2

 after 

1 year of continuous deposition. 

11.6 dpm/m3

 × 31,536,000 sec/year × 0.00075 m/sec = 2.74E5 dpm/m

2 

This surface concentration is favorable to claimants at the end of the operating period. The 

deposited material is assumed to be resuspended and inhaled during the residual period. The 

amount of resuspension was assumed to reduce with time, due to fixing of the material on 

surfaces and to depletion. The depletion factors that were applied to each year are described in 

Table 4-2 of ORAUT-OTIB-0070. The use of the RF of 1 × 10-6/m is appropriate for sites like 

Parks Township that have been somewhat decontaminated prior to the residual period. 

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Source: ORAUT 2012a, Figure 7-1 

Figure 4. Parks Township Site General Air Sampling Analysis 

Because the plutonium is based on gross alpha GA monitoring results, the activity represents the 

total alpha activity. NIOSH properly converted the results to represent fractional alpha activity 

of each radionuclide for ages of plutonium ranging from fresh to 20 years as is listed in Table 7-4 

of the site profile. NIOSH instructs dose reconstructors on the age of the plutonium mixtures to 

assign for each year of residual period for both best-estimate and minimizing cases. On the 

following page of the site profile (i.e., page 67), however, Table 7-3 assumes 100% of the 

mixture is Pu-239 for ingestion and inhalation intake. SC&A finds this guidance to be 

conflicting and believes it could lead to inconsistencies in dose reconstruction. NIOSH should 

clarify how aged plutonium during the residual period should be accounted for. 

Finding 21: There is conflicting guidance on how aged plutonium mixtures should be 

treated during the residual period at Parks Township. 

SC&A noted that on page 67, the following passage should be updated to reflect ingestion intake 

rather than simply intake. 

The daily intake rate (dpm/d) is estimated to be 0.2 times the average daily air 

concentration in units of dpm/m3

. Using the air concentration at the end of 

operations of 11.6 dpm/m3

, an intake rate of 580 dpm/yr is obtained for 239Pu for 

250 workdays per year for the first year of the residual period (1981). 

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The site profile also recognizes that work with uranium in Building C could contribute to internal 

dose for workers during the residual period. Because there was insignificant air monitoring done 

at Parks Township, NIOSH used the Apollo monitoring results shifted back 3 years (different 

start years of residual period) to model potential uranium intakes during the residual years. 

Accordingly, this approach to assigning internal doses to uranium to Parks Township workers for 

the residual period makes use of surrogate data from Apollo, and must meet the Board’s five 

surrogate data criteria, as follows: 

Criterion 1 pertains to the overarching principle, as set forth in 42 CFR Part 82.2, that, when 

performing dose reconstruction, greatest weight should be given to personnel dosimetry and 

bioassay data, followed by workplace monitoring data, followed by site-specific coworker data. 

In keeping with this principal, surrogate data acquired from other sites should also follow this 

hierarchy. In this case, there are no bioassay data that could be used as a surrogate. As such, it 

was necessary to make use of the air sampling data from Apollo as the starting point for this dose 

reconstruction. We believe that this criterion is met. 

The second criterion, referred to as “exclusivity constraints,” pertains to those applications of 

other site data where there are no or very little monitoring data available. In those cases, the use 

of the surrogate data as the basis for individual dose reconstruction would need to be very 

stringently justified. This judgment needs to take into account not only the amount of surrogate 

data being relied on relative to data from the site, but also the quality of the surrogate data 

relative to data available for the site in question. In this case, the use of Apollo data as a 

surrogate for Parks Township is a bounding approach, because Apollo handled more uranium for 

longer periods of time than Parks Township. Parks Township was also decontaminated 

somewhat prior to the start of residual period. If an EE’s work location is unknown, the site 

profile recommends assigning the higher dose of the two models. Since it is unlikely an EE 

received the highest intake of both uranium and plutonium simultaneously, SC&A finds this 

method to be claimant favorable and meets criterion 2. 

Criterion 3 is concerned with similarities and differences between the site (or sites) where the 

surrogate data were generated and the site where the surrogate data are being utilized. The 

uranium operations at Apollo were much more extensive than those at Parks Township. Hence, 

we believe that this criterion is met in a claimant-favorable manner. 

Criterion 4 is concerned with differences between the time periods when the surrogate data were 

collected and the time periods when the operations took place for which the surrogate data are 

being applied. The main concern is whether working conditions and processes varied between 

the different periods. The two facilities were contemporaneous. However, the uranium 

operations at Parks Township were much more limited than those at Apollo. We believe the 

intent of this criterion is met. 

Criterion 5 is concerned with whether the conditions giving rise to exposures at one facility can 

plausibly occur at another facility. The nature of the uranium operations at Apollo was 

considerably more severe than those at Parks Township, and in this regard, one could argue that 

the circumstances at Apollo might not have been plausible at Parks Township. However, it is 

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plausible that for some locations and types of operations, the conditions could have been similar 

for at least some time periods. Hence, we believe that this criterion is met. 

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7.0 SC&A REVIEW OF NUMEC WORKER INTERVIEWS 

A NIOSH team (which included representatives from NIOSH and Oak Ridge Associated 

Universities) conducted an SEC Outreach meeting during the spring of 2007 and interviewed 

[less than nine] former workers from the NUMEC facilities. SC&A was not present during 

these interviews, but has reviewed the interview notes documented in the SRDB. The interview 

notes also include some information obtained from NIOSH team CATI reports. This section is 

not intended to reproduce the interview notes in detail, but rather to convey their “flavor” and 

report on a few areas of interest. 

[Less than nine] of the workers reported working at both the Apollo and Parks Township sites, 

and the [redact] worker was employed at the latter only. The workers’ collective employment at 

NUMEC spanned the period from 1958 through 2000; the shortest tenure was 6 years and the 

longest 37 years. The interview notes often do not explicitly recount the exact positions that the 

workers held or exactly where in the plant they worked, but they appeared to have performed a 

variety of functions in different areas, including in labs and in offices, and handled a variety of 

radioactive substances; at least one appears to have worked in a production position. 

The interviewers asked about personal radiation monitoring instruments and protective 

equipment provided. Only one worker reported being assigned a dosimeter (e.g., film badge) on 

a regular basis. Others said that dosimeters were assigned on occasion for specific jobs. Another 

worker noted that, “most people did not wear badges until sometime in the 1980s.” One worker 

reported that dosimeters were used only in the plutonium facility, and that the labs and uranium 

facilities were not monitored. One production worker recalled wearing an apparatus on the face 

close to a hotcell to monitor dose to the worker’s eye. The same worker stated that, “radiation 

exposure was not a concern” at the site. 

Several of the interviewees stated that workers were provided coveralls, lab coats, hats, socks, 

shoes, shoe covers, and respirators as needed, while other workers (presumably those judged not 

to require such protection by nature of their jobs and locations) stayed in their street clothes in 

the facility. During the early years, fume and hoods were only located in some laboratory areas 

(e.g., not in the Spectroscopy Lab) and protective clothing (lab coats) was not provided in all 

areas. Showers were available in change-out rooms for production workers, but they were not 

required to use them before leaving the plant. Workers were aware that air monitoring was 

performed onsite, and one interviewee stated that “radiation people” monitored the air both 

indoors and outdoors. 

The interviewers asked if the interviewees could recall any special medical testing related to their 

employment, such as an annual chest x-ray or urinalysis. One worker reported having an annual 

physical that included urinalysis and x-rays, and thought these physicals were limited to 

engineers. Another production worker recalled having nasal smears and WBCs (white blood cell 

counts), as well as urine, blood, and fecal sampling. Only one other worker recalled having 

WBCs done. One of the interviewees, a [redact], reported being responsible for checking blood 

and urine for abnormal cells. This interviewee also [redact] (although the interviewee did not 

elaborate on the reason for the tracking). 

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The interviewers asked about radionuclides present onsite, specifically thorium. One worker 

recalled thorium work started around the time the worker was hired (1961) and lasted for 2 to 

3 years. The work was done for W.R. Grace under a single contract. Thorium was processed 

into pellets, sintered, and then processed into tubing. Thorium operations were always dry and 

used the same equipment and techniques as dry uranium operations. There was much less 

thorium work done than uranium work. 

The interviewers also asked about offices located in the production facility. Most workers were 

aware of these offices and had visited them. The workers recalled that there were limited access 

controls and people were free to go anywhere in the facility. There was a double door interlock 

entryway into the production area, but it could be accessed by lab and office workers. Multiple 

workers reported “yellow dust” and smoke coming out of production areas on a regular basis. 

An interviewee noted the following: 

They would check guys going out of the production area. Anyone found to be 

contaminated would then be decontaminated. At one point, they started 

monitoring personnel coming to work from home and found some individuals to 

be contaminated. 

One interviewee recalled walking through yellow powder in the parking lot on many occasions, 

and recalled being told that the operators “...would press pellets while smoking cigarettes and 

eating lunch at the same countertops.” 

The interviewers asked the workers about any accidents that might have occurred at the plant and 

were particularly interested in the 1963 fire mentioned in the site profile. Only one worker 

recalled the event. This worker remembered a “severe explosion” in the D-vault after pyrophoric 

uranium carbide stored there spontaneously combusted. The [redact] ran in with street clothes 

and applied Metal-X to put out the fire. The fire lasted 45 minutes to an hour, but the [redact]’s 

personal decontamination took hours and all the worker’s clothes were discarded. The vault was 

unvented as an engineering control to limit releases. The worker recalled, “...smoke from the 

fire was heavy and drifted throughout the entire plant to some degree.” Contamination from the 

event spread widely and required a lot of work to clean up. The interviewers noted that this 

[redact] contained a record of 5 follow-up urinalysis samples. Although certainly not of the 

same magnitude as the 1963 fire, the [redact] interviewed claimed that accidents occurred in the 

production area almost weekly, and that workers then ran out spreading yellow dust and wearing 

contaminated clothing to the nurse’s station (the [redact] also noted that three of the seven 

[redact] came down with breast cancer, which the interviewee felt seemed disproportionately 

high). 

SC&A believes that the NIOSH interview notes are not very thorough or systematic, often 

lacking adequate time period, location, and job function information associated with interviewee 

responses. This inadequacy generally hinders determination, for example, of what personnel 

monitoring occurred where, during what time period, and while performing which job. In 

addition, interviews would have benefited from the interviewers asking follow-up questions to 

clarify or elaborate statements. Nonetheless, review of the interview records helped to confirm 

the working conditions at NUMEC. SC&A found these interviews to sufficiently address the use 

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of thorium at Apollo and the 1963 vault fire, and we believe that it is unlikely that further 

interviews would result in any additional significant information, especially since both facilities 

are part of the SEC. In addition, it is unlikely that worker interviews could address the site 

profile concerns raised by SC&A elsewhere in this document, which deal primarily with data 

adequacy and dose reconstruction methodology. Hence, SC&A believes there is no need for 

additional interviews at this time, although they may still be needed as part of the issues 

resolution process associated with the NUMEC site profile review. 

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8.0 OVERVIEW OF NUMEC CASES 

Due to the limitations of the data in the site profile and the associated limitations of the guidance 

provided in the site profile, we elected to incorporate a new section into the review of this site 

profile. This section describes the efforts made by NIOSH to perform dose reconstructions for 

NUMEC employees, with the objective of gaining a better understanding of the guidance 

provided in the site profile and how it was implemented. We made a special effort to investigate 

cases that might have been associated with accidents. As can be seen by this overview, NIOSH 

has made a concerted effort to reconstruct doses to workers not covered by the SEC, 

notwithstanding the limitations of the data. It is important to emphasize that this overview is 

not intended as a dose reconstruction review, nor should it be considered a replacement for 

a dose reconstruction review. 

Table 6 summarizes the claims in the NIOSH OCAS Claims Tracking System (NOCTS) 

database. In total, 271 claims from individuals who worked at NUMEC are in NOCTS, 

including individuals who worked only at the Apollo Site, only at the Parks Township Site, or at 

both sites. There are 66 claims under the SEC, with 56 of those being identified during the two 

mass pulls and the remaining 10 subsequently identified. The bottom row shows that 117 dose 

reconstructions were completed by NIOSH and sent to the U.S. Department of Labor (DOL) 

after the SECs were enacted. 

Table 6. Summary of NUMEC Claims in NOCTS 

Current Case Status Apollo Parks 

Township 

Apollo/ 

Parks 

Township 

Total 

Active 

Active – Out of Pending 

Active – Reinstated 

DOL Return – SEC Pulled 

DOL Returned – Out of Pending 

DOL Returned – Pending 

DOL Returned – Submitted 

NIOSH Admin Closed 

Pulled 

SEC Pulled 

Submitted 

1 

1 

1 

2 

1 

1 

11 

1 

4 

45 

110 

0 

0 

0 

0 

0 

0 

2 

0 

1 

7 

33 

1 

0 

0 

1 

0 

0 

5 

0 

1 

11 

31 

2 

1 

1 

3 

1 

1 

18 

1 

6 

63 

174 

Total Cases 178 43 50 271 

Mass SEC Pull for Apollo (1957–1983) 

Mass SEC Pull for Parks Township (1960–1980) 

37 

0 

0 

7 

9 

3 

46 

10 

Dose Reconstruction Draft Sent after SEC 

(Apollo: 1/4/2008; Parks Township: 7/3/2008) 

63 27 27 117 

To determine why dose reconstructions were being performed after the SECs and the basic 

approach used, given data limitations, SC&A examined [redact] dose reconstructions generated 

after the SEC dates; [redact] from the Apollo Site, [redact] from the Parks Township Site, and 

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[redact] from both the Apollo and Parks Township Sites. Each dose reconstruction contained 

the following explanation of the SEC: 

To qualify for compensation under the SEC, a covered employee must meet the 

class definition, have worked at the facility for an aggregate of 250 days, and 

have one of the 22 specified cancers, which include (with some exceptions) the 

following cancers: bone, renal, leukemia, lung, multiple myeloma, lymphomas, 

bile ducts, brain, breast (male and female), colon, esophagus, gall bladder, liver, 

ovary, pancreas, pharynx, salivary glands, small intestine, stomach, thyroid, and 

urinary bladder. For claims in which the energy employee worked at the facility 

but did not meet the above SEC criteria for compensation, a partial dose 

reconstruction will be completed. 

The dose reconstruction also included the following statement for each claimant: 

. . . did not meet the criteria for compensation under the SEC. Therefore, NIOSH 

was required to conduct a partial dose reconstruction for [the EE’s] claim. As a 

result of the SEC class for the NUMEC Apollo and Parks Township Plants, 

NIOSH has determined, and the Secretary of Health and Human Services has 

concurred, that certain doses cannot be reconstructed. These doses include 

uranium internal dose before 1960 at the Apollo Plant, internal dose from 

thorium and plutonium when monitoring data are lacking, internal dose based on 

bioassay data provided by Controls for Environmental Pollution (1976–1983), 

ambient dose from stack releases (internal and external), external dose for 

unmonitored workers, and neutron dose from radium-beryllium and poloniumberyllium source fabrication. 

Table 7 shows the diseases that afflicted the [redact] claimants examined by SC&A. As 

indicated by the passage quoted above, none of these diseases are included in the SEC. 

Table 7. Diseases of the [Redact] Claimants Examined by SC&A 

ICD Code Disease Description 

[redact] [redact] 

[redact] [redact] 

[redact] [redact] 

[redact] [redact] 

[redact] [redact] 

[redact] [redact] 

[redact] [redact] 

[redact] [redact] 

[redact] [redact] 

[redact] [redact] 

[redact] [redact] 

For these [redact] cases, we reviewed the dose reconstructions from the perspective of which 

doses were assigned in order to gain a better understanding how NIOSH “navigated” its way 

around the data limitation and performed partial dose reconstructions as best it could. Tables 8 

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through 12 summarize how each partial dose reconstruction was performed for those individuals 

who were not covered by the SEC. 

Table 8. External Dose for Individuals Not Covered by the SEC 

Claim # External Dose 

[

[redact] 

redact] No external dose monitoring records were found.

a 

No dosimetry records were available.a 

[redact] Dosimetry records were available for only part of the employment period. 

Dosimetry results that were less than half the limit of detection stated in the site profile have been 

treated as missed dose in accordance with the “External Dose Reconstruction Implementation 

Guideline” (NIOSH 2007b). 

No dosimetry records were available. Information in the telephone interview record indicates that 

the claimant was not monitored for external radiation.

a 

This worker would be expected to have potential for exposure to only residual external sources of 

ionizing radiation. This is consistent with the lack of dosimetry records for this claimant. 

According to the information provided in the site profile, external radiation doses for unmonitored 

workers at the NUMEC plants during the remediation periods can be reconstructed based on 

guidance in the site profile. Therefore, the external dose that has been assigned in this assessment 

was that based on guidance in the site profile. During the remediation periods, dose from 

occupationally required medical x-rays are not to be included in the dose reconstruction. The 

external dose assigned for work at the Apollo Site was based on guidance in Section 7.1.1 and 

Table 7-1 of the site profile, and based on guidance in Section 7.1.2 and Table 7-2 of the site 

profile for work at the Parks Township Site. 

[redact] 

[redact] 

[

[redact] 

redact] No dosimetry records were available.a 

No dosimetry records were available.a 

Dosimeter records were available for part of the claimant’s employment at the Parks Township 

facility covering the period. According to the information provided in the site profile, external 

radiation doses for workers at the NUMEC plants can only be reconstructed using existing 

dosimetry records. Therefore, the external dose assigned is limited to the dose based on the 

available dosimetry records. The dosimetry records only provide information on exposure to 

penetrating photon radiation. 

No dosimetry records were available.a 

[redact] 

[redact] 

Source: Summarized from excerpts of claimant dose reconstruction reports in the NOCTS database. a

 According to the information provided in the site profile for the NUMEC Apollo and Parks Township Sites, 

external radiation doses for unmonitored workers at the NUMEC plants cannot be reconstructed because there is 

insufficient information on radiological activities for dose reconstruction. Therefore, since no estimation techniques 

can be employed to derive an external radiation dose for a given cancer, the only external dose that has been

assigned in this assessment was that received from occupationally required medical x-rays. 

Table 9. Missed Dose for Individuals Not Covered by the SEC 

Claim # Missed 

[redact] Not discussed in the dose reconstruction because there are no dosimetry records. 

Not discussed in the dose reconstruction because there are no dosimetry records. 

Based on information provided in the site profile, and per the requirements of the External Dose

Reconstruction Implementation Guideline (NIOSH 2007b), missed dose was assigned based on 

the dosimeter’s limit of detection. 

Based on information provided in the site profile, and per the requirements of the External Dose

Reconstruction Implementation Guideline (NIOSH 2007b), missed dose was assigned based on 

the dosimeter’s limit of detection. 

Not discussed in the dose reconstruction, because there are no dosimetry records. 

Not discussed in the dose reconstruction, because there are no dosimetry records. 

Not discussed in the dose reconstruction, because there are no dosimetry records. 

[redact] 

[redact] 

[redact] 

[redact] 

[redact] 

[redact] 

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Claim # Missed 

[redact] Based on information provided in the site profile, and per the requirements of the External Dose 

Reconstruction Implementation Guideline (NIOSH 2007b), missed dose was assigned based on 

the dosimeter’s limit of detection. The dose to the [redact] was based on guidance in the 

technical information bulletin, Monte Carlo Methods for Dose Uncertainty Calculations (ORAUT 

2005d). 

[redact] Not discussed in the dose reconstruction, because there are no dosimetry records. 

Source: Summarized from excerpts of claimant dose reconstruction reports in the NOCTS database. 

Table 10. Medical Dose for Individuals Not Covered by the SEC 

Claim # Medical 

[redact] Based on information in the site profile and an assumed pre-employment, annual, and termination 

x-ray procedures, a total x-ray dose in rem was assigned. 

Based on information in the site profile and an assumed pre-employment, annual, and termination 

x-ray procedures, a total x-ray dose in rem was assigned. 

Based on information in the site profile and an assumed pre-employment (1967 and 1972), annual, 

and termination (1971 and 1977) x-ray procedures, a total x-ray dose of ... rem was assigned.

Based on information in the site profile and an assumed pre-employment, annual, and termination 

x-ray procedures, a total x-ray dose in rem was assigned. 

During the residual period, medical x-ray doses are not to be included in the dose reconstruction, 

because the work is not directly related to DOE employment. 

Based on information in the NUMEC site profile and guidance in the technical information

bulletin, ORAUT-OTIB-0079, Guidance on Assigning Occupational X-Ray Dose under EEOICPA 

for X-Rays Administered Off Site (ORAUT 2011a), no medical x-ray dose has been assigned in

this dose reconstruction.

Based on information in the site profile and guidance in ORAUT-OTIB-0079 (ORAUT 2011a), no

medical x-ray dose has been assigned in this dose reconstruction.

Based on information in the site profile and guidance in ORAUT-OTIB-0079 (ORAUT 2011a), no

medical x-ray dose has been assigned in this dose reconstruction.

Based on information in the site profile and guidance in ORAUT-OTIB-0079 (ORAUT 2011a), no

medical x-ray dose has been assigned in this dose reconstruction.

[redact] 

[redact] 

[redact] 

[redact] 

[redact] 

[redact] 

[redact] 

[redact] 

Source: Summarized from excerpts of claimant dose reconstruction reports in the NOCTS database. 

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

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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

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Table 11. Internal Dose for Individuals Not Covered by the SEC 

Claim Internal 

[redact] Internal dose monitoring records were reviewed. Only a single measurement result was evident 

for non-naturally occurring radionuclides and showed an activity less than the level of detection 

for the given radionuclide and bioassay method. The bioassay record shows monitoring for 

uranium in urine.b 

[redact] According to the information provided in the site profile, internal radiation doses can only be 

determined for workers with applicable monitoring data. Therefore, because no bioassay data are 

available for this claimant, no estimation techniques can be employed to derive an internal dose. 

[redact] Some measurement results for non-naturally occurring radionuclides showed an activity less than 

the level of detection for the given radionuclides and bioassay method. The bioassay records 

include monitoring for plutonium in urine and feces and for uranium in urine and lung.b 

[redact] Monitoring records were found. The urine data beyond 1975 were not used in the internal dose 

analysis, because the sample analyses were performed by CEP and are not to be used in dose 

reconstructions. The lung counts beyond 1975 are valid and were used in the dose reconstruction, 

because they were not performed by CEP. All fecal analysis results were taken before 1975 and 

are considered valid.b 

[redact] Because no bioassay data were available, the internal dose is based on guidance for the residual 

period from the site profile. 

[redact] According to the information provided in the NUMEC site profile, internal radiation doses at the 

NUMEC Apollo Site prior to 1960 cannot be reconstructed, because there is insufficient 

information on radiological activities for dose reconstruction during this time period. In addition, 

internal dose based on bioassay data provided by CEP cannot be used to reconstruct dose (1976– 

1983). Internal doses can only be determined for workers with applicable monitoring data. 

Because no bioassay data are available, no estimation techniques can be employed to derive an 

internal dose. 

[redact] The bioassay records include monitoring (radiometric and fluorometric) for uranium in urine for 

much of the claimant’s employment. Two chest counts were also taken (1971 and 1976) showing 

U-235 in the lungs at about the detection limit.b 

[redact] Most measurement results for non-naturally occurring radionuclides showed an activity less than 

the level of detection for the given radionuclides and bioassay method. The bioassay records 

include monitoring for plutonium in urine, with all results being less than the detection limit. The 

records also include monitoring for uranium in urine with all but one result being less than the 

detection limit. All of the bioassay sampling results were taken during the employment period at 

the Park Township plutonium facility.b 

Internal dose analyses were performed for plutonium and uranium. 

[redact] Because no bioassay data are available, no estimation techniques can be employed to derive an 

internal dose. 

Source: Summarized from excerpts of claimant dose reconstruction reports in the NOCTS database.

b

 A computer code, the Integrated Modules for Bioassay Analysis (IMBA), was used to estimate intakes of 

radionuclides and the subsequent annual organ doses. 

Table 12. Incident Dose for Individuals Not Covered by the SEC 

Claim Incidents (also see the next section) 

The interview summary includes a description of an incident when two piles of powder began to 

react. One of the piles was then apparently moved to stop the reaction. The potential radiological 

exposure consequences of this incident cannot be determined from the available information. 

However, internal dose from an intake of uranium and other associated radionuclides has been 

applied as described above. 

No radiological incidents were included in the telephone interview record or in the employment 

records. 

[redact] 

[redact] 

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Claim Incidents (also see the next section) 

The telephone interview record indicates that the claimant was involved in a spill that resulted in 

work limitations, fecal and urine bioassay analyses, and testing at Pittsburgh (presumably wholebody or lung counts). The employment records include two incidents in which fecal sampling was 

performed for plutonium. The potential dose from the stated incidents is included in the assigned 

dose as far as the bioassay analyses captured the intakes and exposures. 

The telephone interview record included two incidents. Because all available valid bioassay data 

have been used to provide an overestimate of intake and internal dose, the potential dose from 

these incidents has been included in the internal dose assignment to the extent possible under the 

limitations of the SEC. 

No radiological incidents were included in the telephone interview record or in the employment 

records. 

No radiological incidents were included in the employment records. 

No radiological incidents were included in the telephone interview record or in the employment 

records. 

Because the claimant’s partial internal dose resulted in a probability of causation greater than 

50%, to expedite this claim per the provisions of 42 CFR 82.10(k)(l), a detailed analysis of the 

information provided (including any incidents identified) was not conducted. 

No radiological incidents were included in the telephone interview record or in the employment 

records. 

Source: Summarized from excerpts of claimant dose reconstruction reports in the NOCTS database. 

8.1 AMBIENT DOSE 

According to the information provided in the site profile for the NUMEC Apollo and Parks 

Township Sites, onsite ambient radiation doses at the NUMEC plants cannot be reconstructed, 

because there is insufficient information on environmental releases for dose reconstruction. 

Therefore, no ambient radiation dose was assigned in any of the NUMEC dose reconstructions. 

8.2 RADIOLOGICAL INCIDENTS AND ACCIDENTS AT NUMEC 

The site profile briefly describes incidents and accidents that occurred at both the Apollo and 

Parks Township Sites, and also states that dose reconstructors should try to reconstruct the doses 

to workers involved in accidents. In order to evaluate the degree to which these guidelines were 

followed, we reviewed NUMEC cases to confirm that a reasonable effort was made to assign 

doses to workers who might have been involved in any of the numerous incidents and accidents 

that occurred at both facilities. We are indebted to the excellent post-accident exposure reports 

prepared by Roger Caldwell (see the numerous Caldwell citations in the reference list). The 

following summarizes our observations about the efforts made by NIOSH to reconstruct doses to 

workers who were involved in accidents at the Parks Township and Apollo Sites and are not 

included in the SEC. 

8.2.1 Parks Township Site 

Section 5.5.2 of site profile for NUMEC describes four serious radiological accidents that 

occurred at the Parks Township Site between January 1966 and December 1967. All of the 

events associated with these incidents were monitored and recorded in great detail by the Parks 

Township Site Health Physicist at the time, Roger Caldwell (Caldwell et al. 1969). The records 

show that all of the employees directly and indirectly involved were carefully monitored with 

nasal smears and/or bioassays following the accidents. It was found that only the one or two 

[redact] 

[redact] 

[redact] 

[redact] 

[redact] 

[redact] 

[redact] 

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employees who were directly involved in the accidents were seriously exposed. SC&A reviewed 

the 25 claims associated with the NUMEC Parks Township Site that are currently in the NIOSH 

system. One of these employees was directly involved in a major radiological incident at the 

Parks Township Site, which was described in the CATI report and documented in the DOE 

records for this case. Using this information, NIOSH calculated potential internal dose to this 

employee specifically from the documented accident. The documentation of these incidents 

allows the dose reconstructors to evaluate which workers had potential exposures from these 

incidents. SC&A determined that these incidents appear to be adequately addressed by NIOSH 

in the dose reconstructions. 

8.2.2 Apollo Site 

Section 5.5.1 of site profile for NUMEC describes three radiological incidents at the Apollo Site. 

Two of the incidents involved a large number of personnel. In April 1974, low-enriched UF6 

was accidently released into the plant. Nasal smears were collected from all of the personnel 

involved, and they all had readings within the allowable limits. In February 1963, an explosion 

and fire occurred in the uranium vault involving HEU. This incident is commonly referred to by 

the workers as “the vault fire.” NIOSH states in the site profile that there is no information on 

worker exposures for this incident. SC&A sampled 10 of the 86 claims associated with the 

NUMEC Apollo Site that are still under review by NIOSH and DOL. It should be noted that 

many of the 86 Apollo Site claims have been pulled, due to the fact that they are now 

compensable under the NUMEC SEC. SC&A reviewed the CATI reports and dose 

reconstruction reports for 10 sampled cases. [Redact] specifically mentioned the vault fire in the 

CATI reports, and they both stated that the entire plant had to be evacuated and shut down for 2 

or 3 days. In all of the sampled Apollo Site cases, the dose reconstructors followed the 

procedures in Section 1.3.1 of the site profile, which states that “partial doses can be estimated 

for workers for whom applicable monitoring data are available.” For cases in which no internal 

dose monitoring data are available, NIOSH does not attempt to assign any internal dose. For 

[redact], the employee indicated being involved in the vault fire, but was also regularly 

monitored with bioassays. Therefore, NIOSH indicated that they were able to capture any 

exposure that this employee received during the incident. SC&A agrees with this assessment; 

however, there could be individuals who were exposed during the 1963 fire, but were not 

monitored. SC&A believes that additional information should be gathered pertaining to the 1963 

fire at the Apollo Site, perhaps in the form of site visits, in order to determine the extent and 

magnitude of worker exposures from this incident. 

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9.0 REFERENCES 

ABRWH 2009a. “Data Access and Interview Procedure,” ABRWH-PROC-010. Advisory 

Board on Radiation and Worker Health, Cincinnati, Ohio. June 2009. 

ABRWH 2009b. “Department of Energy Classification Review of Documents,” ABRWHPROC-011. Advisory Board on Radiation and Worker Health, Cincinnati, Ohio. June 2009. 

Adley, F.E., Gill, W.E., Scott, R.H., Study of Atmospheric Contamination in the Melt Plant 

Building, USAEC report HW-233352(Rev.), April 4, 1952. 

AEC 1967. Letter from L.D. Low (AEC) to Dr. Zalman Shapiro (President of NUMEC), U.S. 

Atomic Energy Commission. September 5, 1967. [SRDB Ref ID: 27213] 

Battelle 2006, “Site Profile for Atomic Weapons Employers that Worked Uranium Metals,” 

Battelle-TBD-6000, Rev. 0, 12/13/2006 

Battelle 2007. “Site Profiles for Atomic Weapons Employers that Worked Uranium and 

Thorium Metals,” Battelle-TBD-6000. Battelle. May 25, 2007. 

Battelle 2011, “Site Profile for Atomic Weapons Employers that Worked Uranium Metals,” 

Battelle-TBD-6000, Rev. 1, June 17, 2011. 

Boyd, C.C. Jr., 2006a, “BWXT Records Request,” letter with attachments (collection of external 

dosimetry records 1960–1976, internal dosimetry records 1960–1981, in-vivo counting records 

1968–1985, Occupational Exposure Histories 1978) to S. L. Hinnefeld (NIOSH Taft 

Laboratories), BWXT Services, Lynchburg, Virginia, October 25. [SRDB Ref ID: 27060] 

Boyd, C.C. Jr., 2006c, “BWXT Records Request,” letter with attachments (collection of internal 

dosimetry records 1972–1975, 1979–1987, report of exposure to airborne radioactivity 1976, invivo reports 1980–1981) to S.L. Hinnefeld (NIOSH Taft Laboratories), BWXT Services, 

Lynchburg, Virginia, October 25. [SRDB Ref ID: 27062] 

Boyd, C.C. Jr., 2006d, “BWXT Records Request,” letter with attachments (collection of external 

dosimetry records 1973, internal dosimetry records 1974, 1977, 1978, occupational exposure 

histories 1982, 1983, 1985, incident exposure reports 1975) to S.L. Hinnefeld (NIOSH Taft 

Laboratories), BWXT Services, Lynchburg, Virginia, October 25. [SRDB Ref ID: 27063] 

Boyd, C.C. Jr., 2006g, “BWXT Records Request,” letter with attachments (collection of in-vivo 

counting results, 1970–1976) to S.L. Hinnefeld (NIOSH Taft Laboratories), BWXT Services, 

Lynchburg, Virginia, October 25. [SRDB Ref ID: 27066] 

Boyd, C.C. Jr., 2006h, “BWXT Records Request,” letter with attachments (collection of 

occupational exposure histories 1970–1976, work restrictions 1975, external exposure records 

1975, 1995–1998) to S.L. Hinnefeld (NIOSH Taft Laboratories), BWXT Services, Lynchburg, 

Virginia, October 25. [SRDB Ref ID: 27067] 

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

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
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Boyd, C.C. Jr., 2006i, “BWXT Records Request,” letter with attachments (collection of in-vivo 

count results 1968, 1971–1980, external dosimetry reports 1970, 1976) to S.L. Hinnefeld 

(NIOSH Taft Laboratories), BWXT Services, Lynchburg, Virginia, October 25. [SRDB Ref ID: 

27069] 

Caldwell, R.D., 1968a. “Exposure Report,” SPM-414 1968. NUMEC, Parks Township, 

Pennsylvania. April 1968. [SRDB Ref ID: 18150]. 

Caldwell, R.D., 1968b. “Whole Body Counting Data March–April 1968.” NUMEC, Parks 

Township, Pennsylvania. April 1968. [SRDB Ref ID: 18151]. 

Caldwell, R.D., 1969. Letter from Roger D. Caldwell (NUMEC) to Lawrence D. Low (AEC) 

reporting overexposures in the plutonium facility. November 4, 1969. [SRDB #19970] 

Caldwell, R.D., and W.C. Judd, 1966. Gamma Spectrum Measurements and the Interpretation 

of Absorbed Dose During Plutonium Fuel Fabrication, Nuclear Materials and Equipment 

Corporation, Apollo, Pennsylvania. [SRDB Ref ID: 22776] 

Caldwell, R.D., T. Potter, and E. Schnell, 1967. “Bioassay Correlation with Breathing Zone 

Sampling.” Apollo, Pennsylvania. [SRDB Ref ID: 29599]. 

Caldwell, R., T. Potter, and E. Schnell, ca. 1969. Radiological Emergency Experience in an 

Industrial Plutonium Plant, Nuclear Materials and Equipment Corporation, Apollo, 

Pennsylvania. [SRDB Ref ID: 22778] 

Crosby, E., 1967. “Individual Dosimetry Data PU Facility.” NUMEC, Parks Township, 

Pennsylvania. [SRDB Ref ID: 19734]. 

Davis, A.J., and D.J. Strom, 2008. “Uncertainty and Variability in Historical Time-Weighted 

Average Exposure Data.” Health Physics, Volume 94, Number 2, pp. 145–160. February 2008. 

EPA (1993). External Exposure to Radionuclides in Air, Water, and Soil, Federal Guidance 

Report No. 12 EPA-402-R-93-081. U.S. Environmental Protection Agency, Washington, DC. 

Forscher, F., 1963. “Feasibility Report # 47, BAPL Order 73-T-316512-M (NUMEC 3A358), 

letter to C.A. Keller”. U.S. Atomic Energy Commission, Oak Ridge Operations Office, Nuclear 

Materials and Equipment Corporation, Apollo, Pennsylvania. October 22, 1963. [SRDB Ref ID: 

11965, p. 3]. 

ICRP 1968. International Commission on Radiation Protection. “Evaluation of Radiation Doses 

to Body Tissues from Internal Contamination due to Occupational Exposures,” ICRP Publication 

10, 1968. 

ICRP 1989. International Commission on Radiation Protection. “Individual Monitoring for 

Intakes of radionuclides by Workers,” ICRP Publication 54, 1989. 

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
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ICRP 1991. International Commission on Radiation Protection. “1990 Recommendations of the 

International Commission on Radiation Protection.” ICRP Publication 60, 1991. 

ICRP 1997. International Commission on Radiation Protection. “Individual Monitoring for 

Internal Exposure of Workers, ICRP Publication 78, 1997. 

ICRP 2002. International Commission on Radiation Protection. “Basic Anatomical and 

Physiological Data for use in Radiological protection Reference Values, ICRP Publication 89, 

2002. 

Jackson, S., and N.A. Taylor, 1964. In: Assessment of Radioactivity in Man, Vol. I, IAEA, 

Vienna, p. 169. 1964, STI/PUB/84. 

Joynar, F.E., 1962. “Procedure for Recovery of Uranium Scrap.” NUMEC, Apollo, 

Pennsylvania [SRDB Ref ID: 11959]. 

NIOSH, 2006. SEC-00046, 10/25/2006. 

NIOSH 2007a. NIOSH (National Institute for Occupational Safety and Health), 2007a. “SEC 

Petition Evaluation Report: Petition SEC-00080,” Rev. 0. Office of Compensation Analysis and 

Support, Cincinnati, Ohio. August 31, 2007. (Apollo Site) 

NIOSH 2007b. “External Dose Reconstruction Implementation Guideline,” OCAS-IG-001, 

Rev. 3. Office of Compensation Analysis and Support, Cincinnati, Ohio. November 2007. 

NIOSH 2008. “Petition Evaluation Report: Petition SEC-00108,” Rev. 0. Office of 

Compensation Analysis and Support, Cincinnati, Ohio. March 14, 2008. (Parks Township) 

NIOSH 2010. “Radiation Exposures Covered for Dose Reconstructions under Part B of the 

Energy Employees Occupational Illness Compensation Program Act,” DCAS-IG-003, Rev. 1. 

Division of Compensation Analysis and Support, Cincinnati, Ohio. October 5, 2010. 

NRC 1982. “Holdup at Babcock and Wilcox’s Pennsylvania Operations High Enriched Uranium 

Facilities.” Region 1, U.S. Nuclear Regulatory Commission. May 13, 1982. 

NUMEC 1963. “Health and Safety Manual,” Third Edition. Nuclear Materials and Equipment 

Corporation, Apollo, Pennsylvania. [SRDB Ref ID: 11957]. 

NUMEC 1967. “Individual Dosimetry Data 1967.” Nuclear Materials and Equipment 

Corporation, Parks Township, Pennsylvania [SRDB Ref ID: 19733]. 

NUMEC 1968. “Unrestricted Area Radiation Surveys from 1966 to 1968.” Nuclear Materials 

and Equipment Corporation. [SRDB Ref ID: 19731]. 

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ORAUT 2004. “Technical Basis Document for the Fernald Environmental Management Project 

(FEMP) – Occupational Internal Dose,” ORAUT-TKBS-0017-5, Rev. 00. Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. May 28, 2004. 

ORAUT 2005a. “Internal Dose Overestimates for Facilities with Air Sampling Programs,” 

ORAUT-OTIB-0018, Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, Ohio. 

August 9, 2005. 

ORAUT 2005b. “Dose Reconstruction from Occupationally Related Diagnostic X-ray 

Procedures,” ORAUT-OTIB-0006, Rev. 03. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. December 21, 2005. 

ORAUT 2005c. “Estimating the Maximum Plausible Dose to Workers at Atomic Weapons 

Employer Facilities,” ORAUT-OTIB-0004, Rev. 03 PC-1. Oak Ridge Associated Universities 

Team, Cincinnati, Ohio. November 18, 2005. 

ORAUT 2005d. “Monte Carlo Methods for Dose Uncertainty Calculations,” ORAUT-OTIB0012, Rev. 00. Oak Ridge Associated Universities Team, Cincinnati, Ohio. February 14, 2005. 

ORAUT 2006. “Argonne National Laboratory – East – External Dosimetry,” ORAUT-TKBS0036-6, Rev. 00. Oak Ridge Associated Universities Team, Cincinnati, Ohio. February 9, 2006. 

ORAUT 2007a. “Fission and Activation Product Assignment for Internal Dose-Related Gross 

Beta and Gross Gamma Analyses,” ORAUT-OTIB-0054, Rev. 00 PC-1. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. November 19, 2007. 

ORAUT 2007b. “Internal Dose Reconstruction,” ORAUT-OTIB-0060, Rev. 00. Oak Ridge 

Associated Universities Team, Cincinnati, Ohio. February 6, 2007. 

ORAUT 2007c. “Rocky Flats Plant – Occupational Internal Dose,” ORAUT-TKBS-0011-5, 

Rev. 2. Oak Ridge Associated Universities Team, Cincinnati, Ohio. August 17, 2007. 

ORAUT 2007d. “Pantex Plant – Occupational Internal Dose,” ORAUT-TKBS-0013-5, Rev. 01. 

Oak Ridge Associated Universities Team, Cincinnati, Ohio. June 22, 2007. 

ORAUT 2008. “Site Profile for Nuclear Materials and Equipment Corporation, Apollo, 

Pennsylvania,” ORAUT-TKBS-0041, Rev. 00. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. September 26, 2008. 

ORAUT 2009a. “Site Profile for Nuclear Materials and Equipment Corporation, Apollo and 

Parks Township, Pennsylvania,” ORAUT-TKBS-0041, Rev. 01. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. June 2, 2009. 

ORAUT 2009b. Los Alamos National Laboratory-Occupational Internal Dose, ORAUT-TKBS0010-5, Rev. 10. Oak Ridge Associated Universities Team, Cincinnati, Ohio. October 15, 2009. 

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ORAUT 2010. “Site Profile for Nuclear Materials and Equipment Corporation, Apollo and 

Parks Township, Pennsylvania,” ORAUT-TKBS-0041, Rev. 01 PC-1. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. February 26, 2010. 

ORAUT 2011a. “Guidance on Assigning Occupational X-Ray Dose Under EEOICPA for 

X-Rays Administered Off Site,” ORAUT-OTIB-0079, Rev. 00. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. January 3, 2011. 

ORAUT 2011b. “Dose Reconstruction from Occupational Medical X-Ray Procedures,” 

ORAUT-OTIB-0006, Rev. 03 PC-1. Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. June 20, 2011. 

ORAUT 2012a, “Site Profile for Nuclear Materials and Equipment Corporation, Apollo and 

Parks Township, Pennsylvania” ORAUT-TKBS-0041, Rev. 02. Oak Ridge Associated 

Universities Team, Cincinnati, Ohio. November 26, 2012. 

ORAUT 2012b. “Dose Reconstruction during Residual Periods at Atomic Weapons Employer 

Facilities,” ORAUT-OTIB-0070, Rev. 01. Oak Ridge Associated Universities Team, Cincinnati, 

Ohio. March 5, 2012. 

ORAUT 2012c. “Hanford Site-Occupational Dose,” ORAUT-TKBS-0006-5, Rev. 5. Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. November 5, 2012. 

PEDP 2008. “Pennsylvania Decommissioning Site Surveys,” Pennsylvania Department of 

Environmental Protection, Commonwealth of Pennsylvania [SRDB Ref ID: 43949]. 

SC&A 2004. “SC&A Standard Operating Procedure for Performing Site Profile Reviews,” 

Rev. 1. S. Cohen & Associates, McLean, Virginia. May 13, 2004. 

SC&A 2010. “Sensitivity of NTA Film to Neutron Sources at Mound Laboratory,” Rev. 1. 

Authors R. Anigstein and D. Olsher, SC&A, Inc., Vienna, Virginia. July 22, 2010. 

Schnell, E., 1966. “Elevated Airborne Levels in Change Room September 1966.” NUMEC, 

Pennsylvania. September 22, 1966 [SRDB Ref ID: 18114]. 

Wilcoxon, R., 1999. “Department of Energy Recycled Uranium Project, Conversion/Enriching 

Site Portsmouth GDP,” p. 19. [SRDB Ref ID: 93873] 

Williams, R. 1967. Letter from Robert Williams (NUMEC) to James P O'Reilly (NRC Deputy 

Director) documenting the radioactive effluents discharged to unrestricted areas for compliance 

purposes. February 27, 1967. [SRDB #20081] 

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APPENDIX A: ANALYSIS OF ANNUAL ORGAN DOSE 

This attachment presents the annual organ doses in rem to a worker chronically exposed to 

airborne natural levels of Type M and Type S uranium, which result in an observed 

concentration of uranium in urine at the end of the year of 500 dpm/L (i.e., the MAC used at 

NUMEC). Urine excretion rate is assumed to be 1.6 L/d (male’s excretion rate from ICRP 89, 

2002). The daily intake rate of Type M and Type S uranium are 212 Bq/d and 5,772 Bq/d, 

respectively. 

INTAKE 212 Bq/d inhalation Type M AMAD 5μm 

considering 1.6 L/d excretion rate 

Dose in rem Natural uranium: 48.9% U-238 and U-234 and 2.2% U-235 

Time (Years) 1 2 3 4 5 6 7 

============== 

Adrenals 2.63E-02 2.11E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.50E-02 

Bladder Wall 2.80E-02 2.14E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Bone Surface 2.91E+00 2.17E+00 1.27E+00 1.05E+00 9.23E-01 8.19E-01 7.32E-01 

Brain 2.62E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Breasts 2.63E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Esophagus 2.63E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

St Wall 2.96E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

SI Wall 3.46E-02 2.11E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

ULI Wall 7.73E-02 2.17E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

LLI Wall 1.78E-01 2.35E-02 1.59E-02 1.52E-02 1.51E-02 1.50E-02 1.50E-02 

Colon 1.21E-01 2.25E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Kidneys 2.75E+00 1.09E+00 4.70E-01 3.63E-01 3.11E-01 2.71E-01 2.37E-01 

Liver 1.17E-01 1.72E-01 1.62E-01 1.51E-01 1.42E-01 1.33E-01 1.24E-01 

Muscle 2.62E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Ovaries 2.63E-02 2.10E-02 1.57E-02 1.52E-02 1.50E-02 1.50E-02 1.49E-02 

Pancreas 2.63E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Red Marrow 3.12E-01 2.60E-01 1.62E-01 1.33E-01 1.13E-01 9.77E-02 8.45E-02 

ET Airways 5.33E+01 3.21E+01 3.61E+00 4.16E-01 6.00E-02 2.00E-02 1.55E-02 

Lungs 9.55E+01 1.42E+01 7.95E-01 1.09E-01 2.67E-02 1.65E-02 1.51E-02 

Skin 2.62E-02 2.10E-02 1.57E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Spleen 2.62E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Testes 2.62E-02 2.10E-02 1.57E-02 1.51E-02 1.50E-02 1.50E-02 1.49E-02 

Thymus 2.63E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Thyroid 2.62E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Uterus 2.62E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Prostate 2.62E-02 2.10E-02 1.58E-02 1.52E-02 1.51E-02 1.50E-02 1.49E-02 

Rem. ICRP-60, 8.06E-02 4.79E-02 2.21E-02 1.89E-02 1.81E-02 1.76E-02 1.72E-02 

1991 

Eff. Dose: 1.15E+01 1.78E+00 1.47E-01 5.81E-02 4.38E-02 3.92E-02 3.60E-02 

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

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 19, 2013 

Revision No. 

 0 (Draft) 

Document No. 

SCA-TR-SP2013-0038 

Page No. 

 68 of 74 

INTAKE 5,772 Bq/d inhalation Type S AMAD 5μm 

Dose in rem Natural uranium: 48.9% U-238 and U-234 and 2.2% U-235 

Time (Years) 1 2 3 4 5 6 7 

============== 

Adrenals 2.62E-02 3.24E-02 3.15E-02 3.19E-02 3.24E-02 3.29E-02 3.34E-02 

Bladder Wall 2.49E-02 2.83E-02 2.85E-02 2.97E-02 3.07E-02 3.16E-02 3.23E-02 

Bone Surface 2.56E+00 2.89E+00 2.60E+00 2.48E+00 2.34E+00 2.19E+00 2.05E+00 

Brain 2.33E-02 2.75E-02 2.79E-02 2.93E-02 3.05E-02 3.13E-02 3.21E-02 

Breasts 2.62E-02 3.26E-02 3.16E-02 3.20E-02 3.25E-02 3.29E-02 3.34E-02 

Esophagus 2.69E-02 3.37E-02 3.23E-02 3.25E-02 3.29E-02 3.32E-02 3.36E-02 

St Wall 1.25E-01 3.35E-02 3.14E-02 3.18E-02 3.22E-02 3.27E-02 3.31E-02 

SI Wall 2.73E-01 3.66E-02 3.25E-02 3.24E-02 3.25E-02 3.28E-02 3.31E-02 

ULI Wall 1.55E+00 8.42E-02 5.50E-02 4.77E-02 4.29E-02 3.99E-02 3.81E-02 

LLI Wall 4.54E+00 2.06E-01 1.07E-01 8.28E-02 6.68E-02 5.62E-02 4.93E-02 

Colon 2.83E+00 1.36E-01 7.73E-02 6.27E-02 5.32E-02 4.69E-02 4.28E-02 

Kidneys 2.44E+00 1.85E+00 1.49E+00 1.29E+00 1.13E+00 9.99E-01 8.93E-01 

Liver 1.06E-01 1.96E-01 2.34E-01 2.57E-01 2.70E-01 2.75E-01 2.75E-01 

Muscle 2.47E-02 2.98E-02 2.96E-02 3.05E-02 3.13E-02 3.21E-02 3.27E-02 

Ovaries 2.39E-02 2.76E-02 2.80E-02 2.93E-02 3.04E-02 3.13E-02 3.20E-02 

Pancreas 2.54E-02 3.10E-02 3.04E-02 3.11E-02 3.18E-02 3.24E-02 3.29E-02 

Red Marrow 2.76E-01 3.38E-01 3.14E-01 3.01E-01 2.84E-01 2.64E-01 2.44E-01 

ET Airways 2.60E+03 4.01E+03 2.68E+03 1.80E+03 1.20E+03 8.05E+02 5.39E+02 

Lungs 3.48E+03 1.16E+03 5.94E+02 4.31E+02 3.20E+02 2.45E+02 1.91E+02 

Skin 2.37E-02 2.82E-02 2.85E-02 2.97E-02 3.08E-02 3.16E-02 3.23E-02 

Spleen 2.53E-02 3.10E-02 3.05E-02 3.12E-02 3.18E-02 3.24E-02 3.30E-02 

Testes 2.32E-02 2.74E-02 2.78E-02 2.92E-02 3.03E-02 3.12E-02 3.20E-02 

Thymus 2.69E-02 3.37E-02 3.23E-02 3.25E-02 3.29E-02 3.32E-02 3.36E-02 

Thyroid 2.43E-02 2.92E-02 2.91E-02 3.02E-02 3.11E-02 3.19E-02 3.25E-02 

Uterus 2.34E-02 2.74E-02 2.79E-02 2.93E-02 3.04E-02 3.13E-02 3.21E-02 

Prostate 2.34E-02 2.74E-02 2.79E-02 2.93E-02 3.04E-02 3.13E-02 3.21E-02 

Rem. ICRP-60 1.36E+00 2.07E+00 1.39E+00 9.47E-01 6.46E-01 4.46E-01 3.12E-01 

Eff. Dose: 4.18E+02 1.39E+02 7.14E+01 5.18E+01 3.86E+01 2.95E+01 2.31E+01 

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

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 19, 2013 

Revision No.  0 (Draft) 

Document No. 

SCA-TR-SP2013-0038 

Page No. 

 69 of 74 

APPENDIX B: REVIEW OF CLAIMANT EXTERNAL MONITORING DA

For Privacy Act reasons, each claimant was given an arbitrary reference number (1–40) in column 1 to replace thidentification number. Columns 2 through 4 present the claimant’s job title, NUMEC work site, and approximat(years); column 5 shows how many of those employed years contain at least some external monitoring data. Colwhether the worker had internal monitoring in his or her dosimetry file, such as WBCs or urinalysis samples, whwhether the worker had significant exposure potential. Columns 7 and 8 contain information from the claimant’work locations and badging practices specific to their work experience at NUMEC. Column 9 contains any addiinformation about the dose reconstruction specific to each claimant. 

Specific Information on Job Title, Work Duration, Available Dosimetry, and CATI-Based Information 

Exposure Potential for the 40 Sampled Claimants 

Summary of Sampled Claimants CATI Info 

Ref Add

. 

Number Job Title NUMEC Work Site 

Approximate 

Length of 

Employment 

(years) 

Years with 

Available 

External 

Monitoring 

Data 

Internal 

Monitoring 

Data 

Work in 

Radiological 

Area 

Badging 

Practices 

1 Technician Parks Township 5.8 6 Yes Yes Routine 

External doscompleted dconfirmationfor compens

2 Technician Parks Township 0.5 0 No Yes Unknown 

Dose reconsno external mclaimant; exbased on me

3 

Nuclear 

Fuel 

Fabricating 

Technician 

Parks 

Township 

and Apollo 

7.9 2 Yes Yes Routine 

External badpartial dose medical x-raunmonitored 

4 Laborer Parks Township 0.6 0 No Yes Intermittent 

Dose reconsno external mclaimant; exbased on me

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

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 19, 2013 

Revision No.  0 (Draft) 

Document No. 

SCA-TR-SP2013-0038 

Page No. 

 70 of 74 

Summary of Sampled Claimants CATI Info 

Ref Add

. 

Number Job Title NUMEC Work Site 

Approximate 

Length of 

Employment 

(years) 

Years with 

Available 

External 

Monitoring 

Data 

Internal 

Monitoring 

Data 

Work in 

Radiological 

Area 

Badging 

Practices 

5 Secretary Parks Township 5.4 0 No Rare Instances Routine 

Dose reconsclaimant had monitoring dunable to locDOE_Respo

6 Receptionist 

Parks 

Township 

and Apollo 

3.7 0 No No Not Badged 

Dose reconsno external mclaimant; exbased on me

7 Security Guard Parks Township 

and Apollo 

32.7 16 Yes Yes Intermittent 

External badpartial dose medical x-raunmonitored 

8 Technician Parks Township 5.7 2 Yes Yes Intermittent 

External doscompleted dconfirmationfor compens

9 Security Guard Parks Township 

and Apollo 

31.8 21 Yes Yes Routine 

External badsufficient foreconstructio

10 

Supervisor, 

Lab 

Technician 

Parks 

Township 

and Apollo 

10.7 0 Yes Yes Not Badged 

Dose reconsno external mclaimant; exbased on me

11 Security Guard Parks Township 

and Apollo 

2.2 3 Yes Yes Routine 

External doscompleted dconfirmationfor compens

12 Security Guard Parks Township 

and Apollo 

31.6 19 Yes Yes Routine 

External doscompleted dconfirmationfor compens

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

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 19, 2013 

Revision No.  0 (Draft) 

Document No. 

SCA-TR-SP2013-0038 

Page No. 

 71 of 74 

Summary of Sampled Claimants CATI Info 

Ref Add

. 

Number Job Title NUMEC Work Site 

Approximate 

Length of 

Employment 

(years) 

Years with 

Available 

External 

Monitoring 

Data 

Internal 

Monitoring 

Data 

Work in 

Radiological 

Area 

Badging 

Practices 

13 Technician 

Parks 

Township 

and Apollo 

0.5 1 No Yes Routine 

External dosonly for secoemploymentbased only o

14 Maintenance Man Parks Township 1.4 0 No Yes Not Badged 

Dose reconsno external mclaimant; exbased on me

15 Powder Technician Parks Township 

and Apollo 

2.9 0 No Rare Instances Not Badged 

Claimant indequipment oremainder of radioactive mreconstructioexternal monclaimant; exbased on me

16 

Quality 

Control 

Technician 

Parks 

Township 2.2 3 Yes Yes Routine 

External doscompleted dconfirmationfor compens

17 Lab Technician Parks Township 

and Apollo 

1.5 1 Yes Yes Not Badged 

External badpartial dose 

18 Maintenance Man Parks Township 7.8 4 Yes Yes Routine 

External doscompleted dconfirmationfor compens

19 Dissolver Operator Parks Township and Apollo 7.3 0 Yes Yes Routine External dos

completed dconfirmationfor compens

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

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 19, 2013 

Revision No.  0 (Draft) 

Document No. 

SCA-TR-SP2013-0038 

Page No. 

 72 of 74 

Summary of Sampled Claimants CATI Info 

Ref Add

. 

Number Job Title NUMEC Work Site 

Approximate 

Length of 

Employment 

(years) 

Years with 

Available 

External 

Monitoring 

Data 

Internal 

Monitoring 

Data 

Work in 

Radiological 

Area 

Badging 

Practices 

20 Engineer Parks Township 4.4 0 Yes Yes Intermittent 

Dose reconsno external mclaimant; exbased on me

21 Press Operator Parks Township and Apollo 15.9 14 Yes Yes Routine External dos

completed dconfirmationfor compens

22 

Health and 

Safety 

Manager 

Parks 

Township 

and Apollo 

36.9 26 Yes Yes Routine 

External doscompleted dconfirmationfor compens

23 Accounting Clerk Apollo 0.4 0 Yes No Not Badged 

No film badgthough the cadministrativdose assignesites” 

24 Operator/ Technician Parks Township 

and Apollo 

14.9 0 Yes Yes Routine 

Dose reconsno external mclaimant; exbased on me

25 

Health and 

Safety 

Technician 

Parks 

Township 

and Apollo 

5.9 2 Yes Yes Routine 

External doscompleted dconfirmationfor compensExternal dos

26 Laborer Apollo 2.0 0 No Yes Not Badged completed d

confirmationfor compens

27 Janitor Apollo 7.3 1 Yes Yes Unknown 

External dos“coworker ssites” 

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

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 19, 2013 

Revision No.  0 (Draft) 

Document No. 

SCA-TR-SP2013-0038 

Page No. 

 73 of 74 

Summary of Sampled Claimants CATI Info 

Ref Add

. 

Number Job Title NUMEC Work Site 

Approximate 

Length of 

Employment 

(years) 

Years with 

Available 

External 

Monitoring 

Data 

Internal 

Monitoring 

Data 

Work in 

Radiological 

Area 

Badging 

Practices 

28 Secretary 

Parks 

Township 

and Apollo 

8.4 0 No No Not Badged 

External doscompleted dconfirmationfor compens

29 Chemist Apollo 0.3 0 No Yes Unknown 

No DOE reson NOCTS fradiation dosthe DOE ann

30 Electronics Technician Apollo 0.7 0 Yes Yes Unknown No external 

coworker doPlant were u

31 Glove Box Worker Parks Township 

and Apollo 

15.5 12 Yes Unavailable Unavailable 

External doscompleted dconfirmationfor compens

32 Disolver Operator Apollo 2.8 0 No Yes Unknown 

Dose reconsno external mclaimant; exbased on me

33 Maintenance Man Apollo 0.5 0 Yes Yes Unknown 

No DOE reson NOCTS fradiation dosthe DOE quatime 

34 

Operator/ 

Truck 

Driver 

Apollo 24.6 0 Yes Yes Not Badged 

Dose reconsno external mclaimant; exbased on meExternal dos

35 Furnace Worker Apollo 0.7 0 Yes Unknown Unknown completed d

confirmationfor compens

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

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 
Effective Date: 

April 19, 2013 

Revision No.  0 (Draft) 

Document No. 

SCA-TR-SP2013-0038 

Page No. 

 74 of 74 

Summary of Sampled Claimants CATI Info 

Ref Add

. 

Number Job Title NUMEC Work Site 

Approximate 

Length of 

Employment 

(years) 

Years with 

Available 

External 

Monitoring 

Data 

Internal 

Monitoring 

Data 

Work in 

Radiological 

Area 

Badging 

Practices 

36 

Lab 

Technician/ 

Foreman 

Apollo 32.0 26 Yes Yes Routine 

External doscompleted dconfirmationfor compens

37 Chemical Engineer Apollo 14.2 15 Yes Yes Routine 

External doscompleted dconfirmationfor compens

38 

Liquid 

Waste 

Operator 

Apollo 34.8 3 Yes Yes Routine 

Dose reconsno credible eare availablereconstructeOTIB-0004 

39 Waste Tank Operator Apollo 16.7 2 Yes Unavailable Unavailable Dose recons

external dos“coworker s

40 Maintenance Man Apollo 2.1 0 No Yes Not Badged 

Dose reconsno external mclaimant; exbased on me

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

However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Work

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