Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health

REVIEW OF THE NIOSH SITE PROFILE FOR THE 

KANSAS CITY PLANT 

Contract No. 200-2009-28555 

SCA-TR-SP2012-0006, Revision 1 

Prepared by 

Ron Buchanan 

Joyce Lipsztein 

John Mauro 

Arjun Makhijani 

Joseph Porrovecchio 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, VA 22182 

November 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 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.
Effective Date:

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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

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S. COHEN & ASSOCIATES:

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program

Document No.

SCA-TR-SP2012-0006

Effective Date:

Draft – November 14, 2013

Revision No.

1 – (Draft)

REVIEW OF THE NIOSH SITE PROFILE FOR 

THE KANSAS CITY PLANT Page 2 of 58

Task Manager:

__________________________ Date:____________

Joseph Porrovecchio

Supersedes:

Rev. 0

Project Manager:

__________________________ Date:____________

John Stiver, CHP

Reviewer(s):

 John Mauro

 John Stiver

 Arjun Makhijani

 

Record of Revisions

Revision 

Number

Effective 

Date Description of Revision

0 (Draft) 09/06/2012 Initial issue

1 (Draft) 11/14/2013 Includes new information and revisions to the original report as a result of site 

visits, data capture and interviews. New findings related to potential internal 

exposures to magnesium thorium alloy particulates, uranium, and perhaps highfired uranium particulates associated with machining uranium and exposure to 

Th-230 and metal tritides are also included.
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TABLE OF CONTENTS

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

Preface..............................................................................................................................................7

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

1.0 Introduction........................................................................................................................11

1.1 Scope of the Review ..............................................................................................11

1.2 Report Organization...............................................................................................12

2.0 Background Information....................................................................................................13

2.1 Summary of the History of Kansas City Plant (KCP) Operations.........................13

2.2 Description of KCP’s Radiation Protection Program............................................13

3.0 Occupational Medical Dose...............................................................................................14

4.0 Occupational Environmental Dose ....................................................................................15

5.0 Internal Dose......................................................................................................................16

5.1 Introduction and Overview ....................................................................................16

5.2 Uranium .................................................................................................................16

5.2.1 Powder Activity Median Aerodynamic Diameter .....................................18

5.2.2 Annual Sum of Bioassay Measurements ...................................................19

5.2.3 Bioassay Coworker Model.........................................................................20

5.2.4 Chronic Uranium Intake ............................................................................20

5.2.5 Early Uranium Work..................................................................................21

5.3 Other Radionuclides...............................................................................................23

5.3.1 Magnesium-thorium Alloy .........................................................................24

5.3.2 Thorium-230 Exposures.............................................................................25

5.3.3 Metal Tritides.............................................................................................25

6.0 External Dose during Operations.......................................................................................27

6.1 Background............................................................................................................27

6.1.1 Accuracy/Completeness of Dose Records.................................................29

6.1.2 Beta Dose ...................................................................................................30

6.1.3 Moderated Neutron Dose...........................................................................30

6.1.4 Neutron-to-Photon Ratios..........................................................................32

6.2 Coworker Data Issues............................................................................................33

6.2.1 Dosimeter Response to Low-Energy Photons ...........................................33

6.2.2 KCP Site Profile Text Issues......................................................................34

7.0 Incident Records ................................................................................................................36

References......................................................................................................................................37

Attachment 1: Site Expert Interview Summary............................................................................41
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ABBREVIATIONS AND ACRONYMS

Advisory Board

or Board Advisory Board on Radiation and Worker Health

AEC Atomic Energy Commission

AHU air handling units

ALARA As Low As Reasonably Achievable

AMAD activity median aerodynamic diameter

AP anterior-posterior

AWE Atomic Weapons Employer

BNL Brookhaven National Laboratory

cc cubic centimeter

CFR Code of Federal Regulations

cm

2

square centimeter

D-T deuterium-tritium

DCF dose conversion factor

DOE (U.S.) Department of Energy

DOELAP DOE Laboratory Accreditation Program

dpm disintegrations per minute

DU depleted uranium

EDM Electrical Discharge Machining

EEOICPA Energy Employees Occupational Illness Compensation Program Act

ES&H Environmental Safety and Health

FRC Federal Records Center

g/cm3gram per cubic centimeter

GM Geiger-Muller

GSA General Services Administration

GSD geometric standard deviation

HEPA High Efficiency Particulate Air

Hp personal dose equivalent at tissue depth d (d = 10 mm or 0.07 mm)

HR Human Resources

HVAC Heating, Ventilation, and Air Conditioning

ICRP International Commission on Radiological Protection

IH Industrial Hygiene

KCP Kansas City Plant
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LASL Los Alamos Scientific Laboratory

m

3

cubic meter

μCi/m3 microcurie per cubic meter

μg/cm3 microgram per cubic centimeter

μg/L microgram per liter

μm micron

MDL minimum detectable level

MeV million electron volt

mg/cm2 milligram per square centimeter

MOU Memorandum of Understanding

mrem millirem

MSDS Material Safety Data Sheet

MTs metal tritides

NARA National Archives and Records Administration

NCRP National Council on Radiation Protection and Measurements

NDT Non-Destructive Testing

NIOSH National Institute for Occupational Safety and Health

NNSA National Nuclear Security Administration

n/p neutron-to-photon ratio

NOCTS NIOSH OCAS Claims Tracking System

NTA Nuclear Track A (film)

NYOO New York Operations Office

OBT organically bound tritium

ORAUT Oak Ridge Associated Universities Team

PBS Public Building Services

pCi picocuries

PDF Portable Document Format

PPE Personal Protective Equipment

PuBe plutonium beryllium

QA Quality Assurance

QC Quality Control

R&D research and development

RadCon Radiological Control

RADEC Radiation Detection Capability
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RCRA Resource Conservation and Recovery Act

rem Roentgen equivalent man

RGD radiation generating device

RTV Room Temperature Vulcanization

RWA Radiation Work Authorization

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

SRDB Site Research Database

SRS Savannah River Site

STCs special tritium compounds

TBD Technical Basis Document

TEM Tooling and Equipment Maintenance

TLD thermoluminescent dosimeter

TMA Thermo Analytical, Inc.

TQM Total Quality Management

U3O8 an impure mixture of uranium oxides obtained during the processing of 

uranium ore

UO2 uranium oxide

VOC Volatile Organic Compound
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PREFACE 

This report presents Revision 1 to the original Kansas City Plant (KCP) Site Profile Review 

dated September 2012. This revision is necessary because at the time of preparation of the 

original review, it was not possible to perform the site visits, records review and interviews as is

normally done for most site profile reviews. This situation arose as a result of a worker strike 

and reduction in staff at KCP at the time. This revision specifically includes new information

and revisions to the original report as a result of site visits, data captures, and interviews 

performed subsequent to the issuance of the original site profile review. This revision contains 

notations that reveal the changes transitioning from the original to the current version. 

Noteworthy are new findings related to potential internal exposures to magnesium thorium alloy 

particulates, uranium and perhaps high-fired uranium particulates associated with machining 

uranium, and exposure to Th-230 and metal tritides. Also, our research identified a number of 

questions that might warrant additional worker interviews.
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EXECUTIVE SUMMARY

This report presents Revision 1 to the original review of ORAUT-TKBS-0031, Site Profile for 

the Kansas City Plant (ORAUT 2006), which provides data and guidance for dose reconstruction 

of workers at the Kansas City Plant (KCP) located in Kansas City, Missouri. This review was 

conducted in accordance with SC&A’s Board-approved Standard Operating Procedure for 

Performing Site Profile Reviews (SC&A 2004). Under these guidelines, SC&A is charged with 

evaluating the approach set forth in the site profiles that is used in the individual dose 

reconstruction process. These documents are reviewed for their completeness, technical 

accuracy, adequacy of data, consistency with other site profiles, and compliance with the stated 

objectives, as defined in SC&A (2004).

The following presents our findings.

Finding 1: Without specific information regarding the chemical form and particle size 

distribution of uranium exposure experienced by a worker, dose reconstructors should use 

default assumptions regarding particle size and chemical form of uranium that result in the 

highest dose to the organ of concern.

Finding 2: It appears that high-fired uranium oxide (UO2) was handled at KCP and this subject 

needs to be explicitly addressed in the site profile and information provided to dose 

reconstructors in terms of solubility factors.

Finding 3: The bioassay data summarized in Table 12 of the site profile appear to be incomplete, 

which raises concerns regarding their use in developing a coworker model.

Finding 4: SC&A believes that the default chronic pattern of intake used in the uranium 

coworker model, which apparently is being applied to all workers, may not apply to many 

workers. Our review of actual cases reveals that many workers have legible bioassay records 

and show patterns of excretion rates that indicate that the coworker model may not be claimant 

favorable for all workers.

Finding 5: The system used to categorize workers by administrative code for the purpose of 

implementing the coworker model might result in misassignments that result in underestimates 

of reconstructed doses.

Finding 6: The site profile should address the degree to which uranium exposures may have 

occurred pre-1959 (i.e., prior to the date bioassay data are available) and the method used to 

reconstruct the doses.

Finding 7: The Site Profile should address issues associated with inhalation exposures during 

uranium fires in both the pre- and post-1958 periods. The nature and number of incidents in 

these periods remains to be established.

Finding 8: The nature and extent of work with depleted uranium during and after 1997 as well as 

any intakes that may have resulted remain to be established.
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Finding 9: Further evaluation is warranted in regard to the processes and isotopes contributing to 

liquid radioactive waste shipments from the Kansas City Plant, the time period during which 

these activities and shipments occurred, and the potential for unmonitored internal exposures 

from spills, leaks, cleanup, and routine handling/storage of contaminated drums. An 

investigation into whether thallium liquid waste was present is also needed.

Finding 10: The site profile needs to address internal exposures to magnesium-thorium alloy.

Finding 11: The site profile needs to address the potential internal exposure to thorium-230 at 

the KCP site.

Finding 12: The site profile needs to discuss the degree to which metal tritides were present and 

how doses would be reconstructed to account for this potential source of exposure, with 

particular attention to any incidents that may have occurred.

Finding 13: There appears to be limited information available to the dose reconstructor with 

respect to the nature of the work performed by the workers. This issue warrants further 

investigation, along with the investigation of the legibility/accuracy/completeness of the 

database(s) used for dose reconstruction, in order to assess the ability to reconstruct worker doses, 

as supplemented with the coworker model. Subsequent to the original site profile review, 

interviews revealed that worker training records do exist that indicate the qualifications required 

to work in specific areas and perform tasks specific to potential exposure to radioactivity. These 

records should be more thoroughly researched in the site profile.

Finding 14: It appears that there are large time periods where beta exposure records are lacking, 

making it difficult to reconstruct beta doses for workers during those time periods and for 

developing a coworker model that can cover those time periods. In addition, the details of beta 

exposures are lacking.

Finding 15: The scarcity of positive neutron doses might be explained, in part, by the limited 

ability of NTA film to detect neutron energies below ~1 MeV. Additionally, neutron exposures 

may have been missed during neutron area surveys, because the only neutron survey instrument 

listed in Table 5 (ORAUT 2006, p. 13) is a Nuclear Chicago Model #2715, and this instrument 

may not have correctly responded to the pulsed neutron fields with the generator(s) being 

operated in the microsecond pulse mode, which was typical at KCP, as indicated in Table 4 

(ORAUT 2006, p. 12). An analysis of the workplace shielding and other parameters is needed to 

develop an adjustment factor for badge readings to take missed neutron dose into account.

Finding 16: The fading of the NTA film as a function of time, temperature, and humidity was 

not addressed in the site profile, nor were there any correction factors provided. Lower-energy 

moderated neutrons would show even more fading as compared to the higher-energy neutrons. 

Additionally, the angular response of NTA film and polycarbonate neutron dosimeters was not 

addressed, which generally requires a 30% correction factor.
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Finding 17: During the data capture, we determined that neutron detection instrumentation was 

checked and may have been calibrated at KCP using some types of neutron sources. The site 

profile should investigate this situation further as a potential source of exposure to workers.

Finding 18: Neutron-to-Photon (n/p) ratios require additional investigation in order to develop a 

recommended approach for dose reconstructors.

Finding 19: It may not always be correct to assume that unmonitored workers experienced 

exposures that were generally lower than those experienced by monitored workers, because 

monitoring in the early years may not have been as thorough as would be desired. In addition, as 

discussed in previous findings, coworker categories are ambiguous and might result in 

inappropriate coworker dose assignments.

Finding 20: A correction factor for exposures to photon radiation might be needed, due to the 

differences between the actual photon energy distributions created largely by x-ray machines, 

and the relatively high-energy photons associated with Co-60, which was used for calibration of 

dosimeters. This issue is especially of concern regarding exposures to skin and shallow organs.

Finding 21: The status of accident records needs to be determined. Specifically, NIOSH needs 

to establish whether accidents (internal and external) are included in the records in NIOSH’s 

possession or whether they need to be obtained and included. Further, NIOSH needs to establish 

rather than assume that the doses relating to fragile radioactive source incidents were 

insignificant from a compensation point of view.

An SC&A site visit was performed during the preparation of the original site profile review in 

order to supplement the information provided in the Site Research Database (SRDB). At that 

time, it was clear that there was a need for additional data capture activities, including worker 

interviews, in order to complete our investigations. These additional data capture activities were 

performed and establish the bases for this revision. However, there is a need for even further 

data capture for two reasons:

(1) One interviewee stated there were former employees that held the same troubled concerns 

that KCP operations resulted in health impacts that should be more thoroughly investigated 

and that these workers did not have the opportunity to tell their story. 

(2) At the completion of certain campaigns, areas and departments were demobilized, 

converted to other uses, and records expunged. A site map of building activities and how 

they changed over time would be important for dose reconstruction and interpretation of 

records and interviewee explanations.
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1.0 INTRODUCTION

On January 1, 2006, the National Institute for Occupational Safety and Health (NIOSH) issued 

ORAUT-TKBS-0031, Site Profile for the Kansas City Plant (ORAUT 2006), which provides 

data and guidance for dose reconstruction of workers at the Kansas City Plant (KCP) located in 

Kansas City, Missouri. This report presents a review of the site profile, as requested by the 

Advisory Board on Radiation and Worker Health (the Board) during the full board meeting held 

in Manhattan Beach, California, in February 2010.

1.1 SCOPE OF THE REVIEW

SC&A reviewed the KCP Site Profile for the following attributes, in accordance with SC&A’s 

Board-approved Standard Operating Procedure for Performing Site Profile Reviews (SC&A 

2004):

 Objective 1: Completeness of Data Sources

 Objective 2: Technical Accuracy

 Objective 3: Adequacy of Data

 Objective 4: Consistency among Site Profiles

 Objective 5: Regulatory Compliance and Quality Assurance

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

process. Resolution includes a transparent review and discussion of draft findings with members 

of the Advisory Board Work Group, petitioners, claimants, and interested members of the public. 

Prior to and during the resolution process, the draft report is reviewed by the U.S. Department of 

Energy (DOE), Office of Health, Safety, and Security, to confirm that no classified information 

has been incorporated into the report.

The NIOSH KCP site profile contained information and references that led to the discovery of 

additional information that was not addressed in the site profile. SC&A’s review efforts 

included a data capture plan and a keyword data search of DOE records. Analysis of the search 

results identified approximately 50 boxes of unclassified site records of potential interest at the 

National Archives and Records Administration (NARA) Federal Records Center (FRC) in 

Lenexa, Kansas, and approximately 70 additional boxes of indeterminate classification status at 

the KCP National Nuclear Security Administration (NNSA) site. A scanning level review of the 

unclassified records revealed a significant number of dose reconstruction-related records that 

were subsequently added to the SRDB. Subsequent to the original site profile review, SC&A 

and the Work Group reviewed the remaining boxes at the site. A number of former workers 

from the Bannister Complex (including NNSA and non-NNSA workers) were interviewed. The 

onsite interviews of NNSA workers were completed after the original site profile review was 

issued. This revision to SC&A’s original site profile review reflects the new information 

obtained from additional data captures, records reviews, and worker interviews.
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1.2 REPORT ORGANIZATION

In accordance with directions provided by the Advisory Board and with site profile review 

procedures prepared by SC&A and approved by the Advisory Board, this report is organized into 

the following sections:

 Preface 

 Executive Summary

 Introduction

 Background Information

 Occupational Medical Dose

 Occupational Environmental Dose

 Internal Dose

 External Dose during Operations

 Attachment 1: Site Expert Interview Summary
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2.0 BACKGROUND INFORMATION

2.1 SUMMARY OF THE HISTORY OF KANSAS CITY PLANT (KCP) 

OPERATIONS 

As described in Section 2 of the site profile, the KCP has its origins as a World War II facility to 

assemble engines for navy planes, and continues to operate today in the fabrication of nonnuclear components for the nuclear weapons programs. Many aspects of KCP’s testing and 

manufacturing programs in support of the fabrication of weapons involved the use of uranium, 

radiation sources, and x-ray facilities, and the plant has maintained a formal radiation protection 

program since 1958. Tables 2, 3, and 4 of the site profile present categories of KCP activities 

and descriptions of radiation sources and electronic devices that could have resulted in internal 

and external exposures. These activities involve handling of uranium oxide powders, industrial 

x-ray units, x-ray devices for the measurement of the density and thickness of components, 

neutron generators and neutron sources, Cs-137 and Co-60 for radiography and testing of 

components, and beta-emitting sources for gauges. Other types of electronic equipment, such as 

electron beam welders, also had the potential to cause external exposures to x-rays. Our more 

recent data capture efforts and site visits uncovered information indicating other potential 

sources of exposures, such as magnesium-thorium alloy, Th-230, and metal tritides, which are 

addressed in this revision of our review of the site profile

2.2 DESCRIPTION OF KCP’S RADIATION PROTECTION PROGRAM

Sections 2.5 and 2.6 of the site profile describe the radiation protection program at KCP. This 

program was first described in 1964, although it began operations 20 years earlier. Table 5 

presents a listing of radiation detection equipment, and Section 2.6 summarizes the radiological 

records maintained for about 4,400 workers. The following summary of the records was 

extracted directly from page 13 of the site profile.

• Positive deep, shallow, and extremity doses were first recorded in 1950.

• Positive neutron doses were first recorded in 1966.

• Before about 1959, the recorded deep and shallow doses were essentially 

equal.

• Recorded extremity dose was higher in 1951 and 1952 than in any other year.

• Relatively high shallow dose (in comparison with deep dose) was recorded 

from 1959 to 1964 and during 1973.

• Recorded neutron dose is typically equal to recorded deep dose and to 

recorded shallow dose. The shallow dose is typically equal to the deep dose.

• There are comparatively few records with positive neutron dose.

• The only years with recorded positive uranium bioassay results are 1959 to 

1971.
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3.0 OCCUPATIONAL MEDICAL DOSE

Section 3.0 of the site profile describes the occupational medical exposures experienced by 

workers, which apparently has a long history beginning with routine chest x-rays in 1949. 

Detailed instructions are provided for reconstructing occupational medical exposures, drawing 

heavily from ORAUT-OTIB-0006 (ORAUT 2005) and making use of historical records that 

provide the type of frequency of medical x-ray examinations for different categories of workers. 

SC&A has previously reviewed OTIB-0006, and we have no comments on this section of the site 

profile.
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4.0 OCCUPATIONAL ENVIRONMENTAL DOSE

Section 4 and Appendix A of the site profile address the reconstruction of occupational 

environmental dose. In order to place an upper bound on potential occupational environmental 

exposures experienced by unmonitored workers, the site profile uses the simplifying assumption 

that the average annual airborne concentration of uranium outdoors is equal to 1% of the median 

indoor concentration, as provided in Table 11 of the TBD (i.e., 5.49E-13 μg/cm3). As described

in Attachment A to the TBD, this rule of thumb is a screening methodology recommended in 

NCRP Report No. 123, Screening Models for Releases of Radionuclides to Atmosphere, Surface 

water, and Ground (NCRP 1996). SC&A agrees with this basic strategy for bounding the 

average annual outdoor airborne concentrations of uranium and their associated doses. 

Attachment A of the site profile also addresses the airborne concentration of depleted uranium 

(DU) that might have been experienced by workers on the roof working near the airborne 

effluent release point. The site profile concludes that the 1% rule of thumb also works for these 

workers. When one considers building wake effects, along with the fact that such workers would 

not have been involved in maintenance work close to the effluent release point for extended 

periods of time, and the fact that the wind direction varies, it seems unlikely that even these 

workers would experience protracted exposures in excess of 0.01 of the indoor airborne 

concentrations of uranium.

Based on the above discussion, we concur with the approach used in the site profile to derive 

occupational environmental doses.
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5.0 INTERNAL DOSE

This section presents a brief description of the material provided in the site profile with respect to 

the type of operations that took place at KCP and the type of data that are available for 

reconstructing internal exposures at the facility. This is followed by a description of the 

instructions provided in the site profile for reconstructing internal exposures, and a critical 

review of those instructions and the data upon which they are based.

5.1 INTRODUCTION AND OVERVIEW

Section 5.0 of the site profile describes the data available and the methods for performing 

internal dose reconstructions at KCP. As described in Section 5, from 1958 through about 1971, 

the primary source of internal exposure was machining items containing DU oxide. The site 

profile also explains that, after 1971, operations changed and the potential for internal exposure 

to uranium became minimal because the process did not result in airborne uranium. In addition, 

the site profile explains that the potential for internal exposure to other sources of radionuclides 

is also considered minimal because the other sources, such as Cs-137 and Co-60, were sealed.

5.2 URANIUM

Uranium oxide (UO2) was ordered by KCP in 10,000-lb lots and had the mass and radiological 

characteristics described in Table 9 of the site profile. One of the more important parameters 

describing the uranium is that the powder used to make the uranium had an activity median 

aerodynamic diameter (AMAD) of 1.175 microns and a geometric standard deviation (GSD) of 

2.48. However, the site profile explains that there is uncertainty regarding the particle size 

distribution of the aerosols of uranium produced during machining.

Table 10 of the site profile provides information on the gross alpha contamination levels on 

surfaces in various locations at the KCP, as measured from 1962 to 1969. Both average and 

maximum contamination levels are presented in units of dpm/100 cm2; presumably the values 

refer to removable contamination. Table 11 of the site profile presents statistical data 

characterizing the airborne DU concentration in units of μCi/m3from 1958 through 1970. These 

data are all useful for the purpose of deriving internal doses from uranium.

Most importantly, the site profile indicates that there are bioassay records for individual workers 

written on cards, but the site profile states that these are nearly illegible. The implications are 

that it might not be possible to reconstruct uranium intakes for individual workers based on their 

personal bioassay records. However, electronic data in the form of statistical summaries of the 

individual records are available in the Site Research Database (SRDB), which can be used to 

build a coworker model. The following describes the coworker model developed in the site 

profile to support dose reconstruction for workers that were not monitored or whose records are 

illegible.

Section 5.1.3 of the site profile presents statistical data in electronic bioassay records 

characterizing the concentrations of uranium in urine samples collected from workers from 1959 

through 1971 expressed in units of μg/L, and the associated derived inhalation rates expressed in 
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units of pCi/day. The site profile explains that NIOSH assumed that the minimum detectable 

level (MDL) was 10 μg/L, which is presumably used to derive missed dose. The site profile also 

explains that the frequency of bioassay sampling varied for different individuals and time periods. 

These data are provided in Table 12 of the site profile, which is reproduced here as Table 1 

because of its importance to dose reconstruction.

Table 1: Statistical Parameters of Recorded DU in Urinea

Year

Recorded Annual Urine Concentrationb Lognormal Fit Chronic Intakes (pCi/d)c

No. of Workers 

Reported

Concentration (μg/L) Concentration (μg/L)

Mean Maximum Median GSD 5th Median 95th

1959 214 4.125 52.60 2.642 2.675 1.05E+02 6.42E+02 3.92E+03

1960 281 36.58 140. 19.53 3.813 7.79E+02 4.75E+03 2.89E+04

1961 123 51.40 192.1 37.44 2.402 1.49E+03 9.10E+03 5.55E+04

1962 148 4.327 15.75 3.162 2.508 1.26E+02 7.69E+02 4.69E+03

1963 211 10.96 72.00 7.564 2.532 3.02E+02 1.84E+03 1.12E+04

1964 219 5.627 78.38 3.888 2.431 1.55E+02 9.46E+02 5.76E+03

1965 175 9.572 38.00 5.583 3.422 2.23E+02 1.36E+03 8.27E+03

1966 223 6.432 45.05 4.214 2.640 1.68E+02 1.02E+03 6.24E+03

1967 159 5.438 21.50 3.574 2.713 1.43E+02 8.69E+02 5.30E+03

1968 11 6.055 6.600 6.052 1.029 2.42E+02 1.47E+03 8.97E+03

1969 [redacted] 0.15 0.150 0.150 1.000 5.99E+00 3.65E+01 2.22E+02

1970 59 11.64 45.00 7.576 2.686 3.02E+02 1.84E+03 1.12E+04

1971 47 0.03596 0.1000 0.02993 1.903 1.19E+00 7.28E+00 4.44E+01

ALL [redacted] 14.1 192.1 5.5 4.7

a. All bioassay measurements.

b. The recorded annual sum of urine concentration is the sum of all bioassay results for the year. There is one sum 

for each person-year record. The listed statistics are based on the analysis of the data, which are the sums of all 

bioassay data for every person for that year.

c. Chronic intakes that produce the urinary excretion per day on the 365th day of intakes corresponding to the 

median excretion from the lognormal fit, and 5th and 95th percentile intakes using a GSD of 3. Assumes 

5-micron (μm) AMAD particle size; intakes for 1-μm AMAD particle size, 10.97 g/cm3density, and absorption 

Type S are smaller.

Source: ORAUT-TKBS-0031, Table 12 (ORAUT 2006)

The footnotes provide important information. Specifically, footnote b indicates that the tabulated 

concentrations are based on the sums of all bioassay results for a given year. Presumably this 

means that in 1959, there were 214 workers with reported bioassay samples and, if you added up 

the uranium concentrations observed in urine samples for each worker and divided by the 

number of samples collected in that year for that worker, you would get the average annual 

uranium concentrations in the urine of 214 workers for 1959. Then you would simply report the 

maximum, average, median, and GSD of this population of 214 values. Using these values, 

chronic intake rates are derived by estimating the chronic intake rate that would give you the 

indicated concentration of uranium in urine on the last day of that year.

Footnote b and the accompanying text state that the intake rates were based on an assumed 

5-micron AMAD and Type S uranium, because these assumptions result in higher intake rates 

than if 1-micron AMAD or other than Type S is assumed when calculating intake rates based on 

measured uranium concentrations in urine. We agree with this strategy. However, as discussed 

below, we have some concerns regarding the assumption that the intakes were chronic.
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Table 13 of the site profile provides the number of bioassay measurements and the total and 

average uranium concentrations in urine sorted by occupational description over the years 1959 

to 1971. If a dose reconstruction is being performed for a worker with a known job category, 

this table could help in assigning intakes to unmonitored workers or for workers whose bioassay 

records are illegible.

Given this information, Section 5.1.4 of the site profile provides guidance on deriving internal 

doses to uranium using the above-described tables. The site profile instructs the dose 

reconstructor to try to assign each worker undergoing dose reconstruction to one of the following 

four categories (ORAUT 2006, p. 22):

(1) workers routinely exposed to airborne or loose material, (2) workers 

occasionally exposed, (3) workers rarely exposed or exposed only to very low 

workplace airborne or contamination levels, and (4) workers with little or no 

potential for radiological exposure. Unmonitored workers in category 1 should 

be assigned the 95th percentile intakes; category 2 to the median intakes; category 

3 to the 5th percentile intakes; and category 4 workers should be assigned internal 

exposures per the environmental section of this document.

Given the above description of the coworker model, which apparently is intended to be used for 

most, if not all, workers due to the illegibility of the individual worker records, the following 

presents SC&A’s review of the coworker model and the data upon which it is based.

5.2.1 Powder Activity Median Aerodynamic Diameter

The KCP had substantial quantities (10,000-lb lots) of UO2 onsite at various times. Machining 

and grinding of DU metal creates fine dust available for intake by workers, and NIOSH states 

that (ORAUT 2006, p. 18):

In fitting bioassay data, dose reconstructors may wish to start with a 1-μm AMAD, 

a GSD of 2.5, a density of 10.97 g/cm3, a lung solubility Type S, and f1 of 0.002 

(ICRP 1995). However, it is not known what impact processes at KCP had on the 

particle size of uranium. Use of the default 5-μm AMAD particle size is also 

acceptable unless it is known that the intake was of unaltered UO2 powder. 

(Emphasis added.)

SC&A evaluated internal doses associated with inhaling uranium and determined that, since the 

Atomic Weapons Employer (AWE) activities at KCP involved handling substantial quantities of 

UO2 powder, it does not appear to be appropriate to use the default option of 5-μm AMAD. 

Detailed information regarding processes, chemical forms, and handling conditions has not been 

available for evaluation. Since program(s) utilizing UO2 powder were most likely classified, and 

workers in general were strongly discouraged from discussing work activities, it is likely that 

claimants (particularly survivors) would not be aware of an energy employee’s exposure to 

powdered material. Without specific information regarding the chemical form and particle size 

distribution experienced by a worker, dose reconstructors should use combinations of 1- and 
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5-μm AMAD and Types M and S uranium, and use those assumptions that result in the highest 

dose to the organ of concern.

During review of records located at KCP and worker interviews, SC&A determined that the UO2

powder procured by KCP was to be “...made by high firing U3O8 at 1800oC...” (Ulitchny et al. 

no date, PDF [Portable Document Format] p. 5). The site profile does not clearly indicate that 

NIOSH is taking into account high-fired uranium in its assumptions regarding solubilities and in 

reconstructing dose from uranium intakes at KCP. SC&A recommends modification of the site 

profile to include adequate information on this matter.

Finding 1: Without specific information regarding the chemical form and particle size 

distribution of uranium exposure experienced by a worker, dose reconstructors should use 

default assumptions regarding particle size and chemical form of uranium that result in the 

highest dose to the organ of concern.

Finding 2: It appears that high-fired UO2 was handled at KCP and this subject needs to be 

explicitly addressed in the site profile.

5.2.2 Annual Sum of Bioassay Measurements

 

The KCP has developed and maintained a radiological records database that contains records for 

all monitored worker exposures at KCP for all years of record. According to NIOSH (ORAUT 

2006), the database contains exposure data for about 4,400 workers. Page 19 of the site profile 

states the following:

The available data are shown on an annual basis and might be the sum of one or 

more bioassay measurements. If the individual case information does not yield 

additional information, dose reconstructors should make the claimant favorable 

assumption that the recorded bioassay quantities represent a single bioassay 

measurement taken at the end of the calendar year.

SC&A reviewed the files of 528 claimants (see Table 2), and 50 of these workers had uranium 

results. Table 2 presents the results of that review. In each year, the reviewers noted some 

unreadable results, but the majority of the results, with the exception of 1970, were legible. The 

site profile leaves the reader with the impression that it is not plausible to perform dose 

reconstructions using the workers’ bioassay data, but instead appears to recommend the use of 

the claimant-favorable assumption described above. SC&A found that it is possible to 

reconstruct the internal uranium exposures of many claimants using the workers’ bioassay results. 

We suggest that the site profile make it clear that the workers’ bioassay records should be used 

when available as opposed to the coworker model.

Observation: The site profile should state that the coworker model should be used when it is 

not possible to use the workers’ bioassay records, presumably because they are illegible, 

incomplete, or lacking.
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Table 2: Claimant File Review of Uranium Bioassay

Year No. of Workers

Range of Annual 

Average Worker 

Excretion Rates 

(μg/L )

Max Individual 

Excretion Rate 

(μg/L )

Total No. Samples

1959 [redacted] 0–3.9 3.9 32

1960 11 0–10 72 28

1961 [redacted] 0–20 70 8

1962 [redacted] 0–1.5 4.3 5

1963 [redacted] Not reported 16.5 11

1964 [redacted] Not reported 5.3 12

1965 11 Not reported 16.5 16

1966 14 Not reported 13 21

1967 11 Not reported 20 16

1968 [redacted] 0 6 5

1969 [redacted] 0 0.6 7

1970 10 0–14 25 10

1971 [redacted] 0 0 3

Notes: Frequency of monitoring not related to results.

 Frequency did not increase after high result.

5.2.3 Bioassay Coworker Model

Table 12 of the site profile (p. 20), which summarizes the electronic bioassay records, shows 

[redacted] with [redacted]. In contrast, SC&A’s review of the records upon which Table 12 is 

based (refer to Table 2 above) reveals that [redacted] workers among the claimant group had 

bioassay records in 1969. Consequently, Table 12 appears to be incomplete, which raises 

questions regarding the use of the data in Table 12 as the basis for a coworker model. During the 

December 2012 site visit, SC&A and the Work Group identified records added to the SRDB that 

contain bioassay data specifically addressing uranium. These additional data should be reflected 

in the coworker model for dose reconstruction.

Finding 3: The bioassay data summarized in Table 12 of the site profile appear to be incomplete, 

which raises concerns regarding its use in developing a coworker model.

5.2.4 Chronic Uranium Intake

For the purpose of reconstructing internal exposures using the coworker model, the site profile 

presumes that intakes of uranium dust are chronic. The derivation of chronic intake rates based 

on the sums of individual results in a year may result in a less-than-favorable dose reconstruction 

for some workers. Our analysis of the claimant data has shown that some workers have high 

results in 1 month, followed by very low results in the following sampling period. For example, 

one worker had [redacted], on the order of [redacted]. The worker’s results were below the 

MDL in 1960, [redacted] in January, below the MDL in February, [redacted] in May, and 

[redacted] in July and December. This pattern of excretion rate results is not characteristic of 

chronic intakes, and averaging concentrations in urine to obtain an average annual chronic intake 

rate would result in an underestimate of internal exposures.
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The pattern of high results was not uniform among workers. In 1960, another worker presented 

the following excretion rate results: 0 in January, 14 μg/L in February, 10 μg/L in April, and 

42 μg/L in December. This same worker in 1961 presented 20 μg/L in June and 70 μg/L in 

December. A third worker in 1961 had a result equal to 0 in August and a result equal to 

20 μg/L in December.

In addition, Nasca (2005a) includes the following uranium bioassay results for an individual 

worker in 1960: 0 in January, 29 μg/L in February, 0 in April, 39 μg/L in May, and 66 μg/L in 

December. In the same document, a worker presented the following results in 1960: 35 μg/L in 

January; 0 in February, April and May; followed by 20 μg/L in September; and 0 in December. 

Those results are not characteristic of chronic intakes.

Finding 4: SC&A believes that the default chronic pattern of intake used in the uranium 

coworker model, which apparently is being applied to all workers, may not apply to many 

workers. Our review of actual cases reveals that many workers have legible bioassay records 

and show patterns of excretion rates that indicate that the coworker model may not be claimant 

favorable for all workers.

In addition to issues related to Table 12 of the site profile, we also have concerns regarding the 

way in which the site profile categorizes unmonitored workers for the purpose of implementing 

the coworker model. On page 22 of the NIOSH site profile, workers are grouped into the 

following four exposure categories: (1) workers routinely exposed to airborne or loose material, 

(2) workers occasionally exposed, (3) workers rarely exposed or exposed only to very low 

workplace airborne or contamination levels, and (4) workers with little or no potential for 

radiological exposure.

SC&A is concerned that the use of Table 13 of the site profile and this system to categorize 

workers might lead to less than claimant-favorable dose reconstructions. For example, our 

review of the SRDB revealed that administrative support/clerical/work planner Occupational 

Code Category 450 has a relatively high average bioassay measurement. In e-mail 

correspondence with Richard Traub (Battelle) regarding KCP Occupational Codes, Nasca 

explained that Category 450 includes not only secretaries with no expected exposures, but also 

work planners who are expected to show uranium uptakes (Nasca 2005b). Thus, workers with a 

high potential of exposures are classified in the same code as workers not expected to have any 

exposures to uranium.

Finding 5: The system used to categorize workers by administrative code for the purpose of 

implementing the coworker model might result in misassignments that result in underestimates 

of reconstructed doses.

5.2.5 Early Uranium Work

The NIOSH site profile states that uranium work started in 1958. However, the dates provided in 

Section 5.0 are primarily attributed to correspondence with a radiation safety staff member. An 

SC&A site expert interview indicates this individual was hired in 1989, and the correspondence 

cited in the site profile (Nasca 2005a) indicates that the staff member had limited data available 
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regarding early uranium operations. Evidence from retrieved site documents suggests that 

uranium work started much earlier. For example:

 History of Production Machining of Uranium, written in 1952, includes a survey of 

uranium machining work in various areas (Mahaffey 1952). Starting on PDF page 17, a 

section titled “Slug machining in the Kansas City Area” states that KCP machined slugs 

for SRS and for Argonne Critical Experiment CP-6, which is indicative of earlier 

uranium work. Pages 57 and 58 of this file show a diagram of the uranium slug produced 

for the Argonne Critical Experiment.

 Production reports for Atomic Energy Commission (AEC) New York Operations Office 

(NYOO) Tonawanda Area from November 1951 refer to eight “scalped” uranium billets 

shipped from “Bendix Aviation Company” to Simonds Saw and Steel in October 1951 

(NYOO 1951; Malone 1951a), 51 tons of “turned ingots” shipped to Simonds in 

November 1951 (NYOO 1951), two carloads of Bendix billets en route to AlleghenyLudlum steel in January 1952 (NYOO 1952a), approximately 10 tons of DuPont rods 

scheduled for shipment to Kansas City in January 1952 (Malone 1952), and 355 ingots 

sent from Bendix to Lake Ontario Ordnance Works in April 1952 (NYOO 1952b).

 Correspondence from the Tonawanda Sub-Office in June 1951 states over 100 tons of 

uranium rods were to be held for shipment to KCP (Malone 1951b). Documentation of a 

363-slug canning run at Argonne National Laboratory states, “the majority of the 

uranium slugs were turret lathed at Kansas City. . . ” (Laing 1952, PDF p. 2).

This early uranium work raises two questions: 

Question (1): How will reconstruction of routine uranium exposures during the early years be 

performed? 

This remains an open question since the amount of work completed, the dates, and the 

similarities and differences between working conditions (e.g., work place ventilation) before 

1959 and those after that date have not yet been established.

Finding 6: The site profile should address the degree to which uranium exposures may have 

occurred pre-1959 (i.e., prior to the date bioassay data are available) and the method used to 

reconstruct the doses.

Question (2): Is there a possibility of incidents such as uranium fires during that time period that 

needs to be addressed as a source of internal exposures during the early years before the 

availability of bioassay data?

With respect to Question 2, the machining of uranium at various sites during the early years was 

often associated with fires due to the pyrophoric nature of uranium metal. SC&A did not 

identify reported incidents of uranium fires in its initial review. However, one interviewee 

described involvement in follow-up after a fire in a radioactive machining area. SC&A suggests 

that NIOSH take advantage of recent work performed under the direction of TBD-6000 Work 
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Group, which addresses this specific issue. No treatment of this likelihood is presented in the site 

profile. 

Finding 7: The Site Profile should address issues associated with inhalation exposures during 

uranium fires in both the pre- and post-1958 periods. The nature and number of incidents in 

these periods have not yet been established.

SC&A noted above that site expert correspondence is cited as a primary source of information 

regarding the start date of uranium handling. The site profile also references this correspondence 

(Nasca 2005a) in stating that the DU oxide project ended in 1972, there is no removable 

contamination with the process used to shape uranium metal since 1997, and intakes of DU after 

1972 are not likely. SC&A notes that the site expert does not specifically identify start and end 

dates for the DU oxide work in this letter, nor does he mention the post-1997 process in this 

particular correspondence. SC&A also noted that the document describing product 

specifications for uranium dioxide (Ulitchny et al. 1998) was revised in 1997 and 1998; it is not 

clear why the product requirements would be updated in the late 1990s if the program that used 

DU oxide was discontinued in 1972. In any case, it would be desirable to substantiate the 

conclusions of the cited correspondence with documentation affirming DU oxide program start 

and end dates, the absence of uranium handling from 1972–1996, and the process and exposure 

potential (or lack thereof) for post-1996 uranium work.

SC&A is also aware of the potential for even DU to include recycled uranium once Hanford 

established its recycling program in the early 1950s. A cursory search of available documents 

did not reveal explicit mention of KCP as a recipient, but the potential for trace contaminants 

may exist.

Finding 8: The nature and extent of work with depleted uranium during and after 1997 as well 

as any intakes that may have resulted remain to be established. 

5.3 OTHER RADIONUCLIDES

Section 5.2 of the site profile addresses internal exposures other than uranium, explaining that 

there were no significant worker intakes other than uranium. SC&A originally concurred with 

this position. However, subsequent data captures uncovered information indicating that workers 

might have been exposed to other radionuclides, including thorium, metal tritides, and 

magnesium-thorium alloy, all of which have the potential to cause internal exposures.

Records uncovered by SC&A contain correspondence regarding multiple liquid radwaste 

shipments from KCP to Los Alamos. This includes evidence of liquid radwaste spills, radiation 

levels, and clean-up costs at KCP and Los Alamos are described. According to a Los Alamos 

summary (LASL 1962), KCP shipped 585 drums, containing approximately 3,386 cubic feet of 

low-level waste for disposal during the first 6 months of 1962. Bendix Industrial Hygiene staff 

characterized the waste as “solids and water-soluble cutting oil” and “contaminated cutting oil” 

(Schiltz 1962), which may be consistent with “wet” machining of Mg-Th alloy (Bendix 1975) or 

other radioactive materials. Some correspondence (Clayton 1962; Schiltz 1962) describes vented 

containers that spilled during transit and/or unloading, which may not have significant 
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implications for KCP workers. Other concerns noted by Los Alamos include barrels that were 

rusted and leaking from the bottom (Reichman 1962a; Reichman 1962b), which may imply 

potential exposures to KCP personnel. 

The interview summary (Attachment 1) contains a mention of thallium liquid waste. The site 

profile only lists thallium as “beta scope, thickness gauges” (ORAUT 2006, Table 3, p. 11). The 

issue of thallium liquid waste also appears to warrant further investigation. Thallium metal 

dissolved in mercury was included in waste shipments circa early1970’s to LASL (Porrovecchio 

2013). SC&A notes that the SRDB shows no documents for the search term “thallium” or “Tl204” or “

204Tl”. However, site records not in the SRDB may contain such information.

Finding 9: Further evaluation is warranted in regard to the processes and isotopes contributing 

to liquid radioactive waste shipments from KCP, the time period during which these activities 

and shipments occurred, and the potential for unmonitored internal exposures from spills, leaks, 

cleanup, and routine handling/storage of contaminated drums. An investigation into whether 

thallium liquid waste was present is also needed.

SC&A reviewed several classified documents describing the origin and shipment of radioactive 

scrap, the handling of radioactive material, and operational accounts. Notes from this review are 

available on the SRDB (Porrovecchio 2013).

5.3.1 Magnesium-thorium Alloy 

Records uncovered by SC&A include a compilation of multiple sub-documents on the topic of 

magnesium-thorium operations at KCP. Internal correspondence identifies the Mg-Th alloy 

program as RADEC (McKay 1970). Operations included “drilling, grinding, filing, sanding, 

buffing, welding, pickling, and chemical milling” (Bendix 1963). This program is not mentioned 

in the NIOSH site profile (ORAUT 2006). A memo written by C.S. Triplett of Health and Safety 

(Triplett 1970) states that the thorium-232 levels “approached” the permissible limit of 9 × 10-11

μCI/cc (with no health and safety concerns); however, the daily committed bone surface dose 

from this level of air concentration (assuming Type M) would be about 7 rem (assuming an 

inhalation rate of 1.2 m3/hour and 8 hours per day). Accordingly, this program appears to have 

been a significant source of internal exposure and needs to be addressed in the site profile. 

Further evidence indicates machining of Th-Mg alloy seems to have been a long-term activity at 

KCP:

 McKay (1970) notes that over 200 hours of machining and sheet metal process work had 

been approved for the current fabrication request (September 1970).

 Health and Safety Guides issued and revised indicate operations with Mg-Th occurred in 

the 1960s and 1970s (Bendix 1963; Bendix 1970; Bendix 1975). These documents 

indicate machining operations in the Model Shop, Tool Room, and Department 851. 

Both solid and liquid wastes were generated.

 Documentation reflects consideration of health and fire hazards as far back as 1961 

(Stewart 1961).
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 SC&A notes from classified documents (Porrovecchio 2013) include the following 

observations: machining of polyurethane foam containing an alloy of metals was 

described in a document dated March 1972. A source document dated May 1974 

indicates disposal of Mg-Th radioactive scrap—approximately 46 barrels (55-gal size) 

accumulated over time. The scrap material was accounted for as normal operation losses 

and shipped to LASL for disposal. A document dated June 1965 indicates that 

polyurethane foam machining occurred in D/22, D/217-22 and D25 areas.

It is clear Mg-Th alloy handling was a long-term activity at KCP and may have presented a 

chronic exposure potential to workers. SC&A was not able to confirm beginning and ending 

dates for these activities, but dates should be addressed in the site profile, along with an approach 

for dose reconstruction.

Finding 10: The site profile needs to address internal exposures to Mg-Th alloy.

5.3.2 Thorium-230 Exposures 

Facilities Radioisotopes Data compiled by DOE Albuquerque Operations Office notes that 

12 curies of thorium-230 were present at KCP in solid waste form (DOE-AL 1990). The 

document indicates the inventory data are from the 1980s; it does not indicate for what purpose, 

or during what period, Th-230 was used at KCP. Additional evidence (Porrovecchio 2013) 

indicates thorium-230 being used at KCP in documentation of normal operational losses and its 

transfer to LASL for burial in 55-gal drums as radioactive scrap (accumulated in approximately 

46 barrels) through 1974.

Finding 11: The site profile needs to address the potential internal exposure to thorium-230 at 

the KCP site.

5.3.3 Metal Tritides

The Department of Energy (DOE) and its predecessor agencies have undertaken missions 

involving work with hazardous and/or exotic materials and agents, and byproducts of their 

production, storage, and use. Included in these exotic materials are metal tritides (MTs) and 

organically bound tritium (OBT), referred to collectively as special tritium compounds (STCs) 

(DOE 2004). KCP is not typically identified as a site involved in handling STCs, but KCP 

workers may have had contact with STCs as a byproduct of the work they conducted on 

components received from other facilities. One example of processes where STCs may create a 

potential for exposure include tritium targets for neutron generators (DOE 2004). There are any 

number of locations where these materials may be encountered, such as gloveboxes, fume hoods, 

ventilation systems, weapons components, and fuel storage basins (DOE 1997). STCs are 

categorized by physical form (e.g., liquid/vapor, particulate, or large solid form) and by 

solubility (e.g., insoluble, partially soluble, soluble). At some facilities, they refer to metal 

tritides as stable or unstable, which is a measure of how easily the tritium is released from the 

metal in air or aqueous material. Insoluble metal tritides (i.e., stable metal tritides) include 

hafnium, titanium, europium, and zirconium tritide. Soluble forms of MTs include uranium, 

lithium, and palladium tritide (DOE 1994; DOE 2004). 
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Krueger and Meunier (1987) investigated an employee concern regarding potential exposure to 

erbium tritide from particulate contamination of a data analyzer unit. This unit had been used in 

tests and returned to KCP. Tritium contamination was deposited in and on the unit, which was 

“cleaned” prior to shipment to KCP, but its interior not decontaminated, as was the practice. 

Bioassay resulted in no significant exposure, and the unit was returned to Sandia for cleaning.

The NIOSH site profile mentions 14.7 MeV neutron generators (Table 4). These were likely 

transferred from Pinellas, and were referred to as “controlatrons.” According to Lutz (1995), 

Pinellas sent 52 controlatrons to KCP from 1980 to 1990 and 1 from 1991 to 1995. A Material 

Safety Data Sheet (MSDS), with reference to Pinellas but not to KCP, states the neutron 

generator contains a small quantity of erbium tritide in a vacuum tube. The MSDS also states 

there would be no exposure potential unless the tube was broken and the temperature was in 

excess of 500°C (GE 1976).

Finding 12: The site profile needs to discuss the degree to which metal tritides were present and 

how doses would be reconstructed to account for this potential source of exposure, with 

particular attention to any incidents that may have occurred.
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6.0 EXTERNAL DOSE DURING OPERATIONS

This section presents a brief description of the material provided in the site profile with respect to 

the type of operations that took place at KCP and the type of data that are available for 

reconstructing occupational external exposures at the facility. This is followed by a description 

of the instructions provided in the site profile for reconstructing external exposures, and a critical

review of those instructions and the data upon which they are based.

6.1 BACKGROUND

Section 6.0 of the site profile, which addresses external radiation exposures at KCP, explains that 

the sources of external exposure at KCP were primarily associated with fabrication and quality 

control testing of non-nuclear weapons components, and that clear descriptions of those activities 

are not readily available due to their classified nature. However, Table 3 of the site profile lists 

the external radiation sources at KCP, and Table 4 lists the radiation-generating devices (RGDs), 

which consisted of beta, gamma, x-ray, and neutron emitting/generating sources. Section 6.3 of 

the site profile describes the dosimeter technology that was used to record worker exposure to 

photon, beta, and neutron exposures associated with the variety of sources, and RGDs used at 

KCP over the years. This section reviews the data, models, and assumptions used in the site 

profile to reconstruct external exposures to KCP workers.

As explained in the site profile, because of its long history, a variety of personnel dosimetry 

devices were employed over the years, and an effort was made in the site profile to compare 

these different methods, so that dose reconstructions for different time periods can be performed 

in terms of a common metric, namely Hp(10) for penetrating dose and Hp(0.07) for nonpenetrating dose.

Section 6.4 presents the methods recommended in the site profile to perform external dose 

reconstruction. Section 6.4.1 explains that external dosimetry exists for most workers, but some 

workers were not monitored. The site profile takes the position that workers who were not 

monitored experienced exposures that generally were lower than those experienced by monitored 

workers. This might be true in general, but it might not apply to all workers. Figure 2 of the site 

profile presents a statistical analysis of the annual penetrating dose experienced by all workers as 

compiled by NIOSH for 1950 through 2003. Also, Table 15 of the site profile presents a 

statistical analysis of the exposures for each year from 1950 through 1990. Because of its 

importance, Table 15 is reproduced here as Table 3:

Table 3: Statistical Parameters of Recorded Penetrating Annual Doses

Year

Arithmetic, All Recorded Dose Lognormal, dose>0

No. of 

Workers

Dose, rem No. of 

Workers

Dose, rem GSD Mean Maximum Median 95%

1950 46 7.09E-02 6.47E-01 29 5.01E-02 5.54E-01 4.31E+00

1951 227 2.78E-01 5.32E+00 158 4.97E-02 2.02E+00 9.52E+00

1952 233 1.91E-01 5.90E+00 220 2.45E-02 7.42E-01 7.96E+00

1953 103 1.37E-01 5.32E+00 72 2.13E-02 4.50E-01 6.38E+00

1954 65 1.61E-01 2.99E+00 21 1.19E-01 4.74E+00 9.39E+00

1955 41 9.18E-02 4.18E-01 25 1.10E-01 4.59E-01 2.39E+00
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Table 3: Statistical Parameters of Recorded Penetrating Annual Doses

Year

Arithmetic, All Recorded Dose Lognormal, dose>0

No. of 

Workers

Dose, rem No. of 

Workers

Dose, rem GSD Mean Maximum Median 95%

1956 26 2.89E-01 1.75E+00 26 1.35E-01 1.07E+00 3.52E+00

1957 65 5.24E-01 7.89E+00 36 1.77E-01 6.33E+00 8.80E+00

1958 301 3.90E-02 8.43E-01 89 5.44E-02 4.84E-01 3.78E+00

1959 464 8.97E-03 2.30E-01 72 3.57E-02 1.78E-01 2.66E+00

1960 1,043 1.21E-02 1.35E+00 165 4.53E-02 2.31E-01 2.70E+00

1961 948 2.39E-02 5.90E-01 400 3.17E-02 1.64E-01 2.72E+00

1962 700 1.25E-02 1.65E+00 59 4.25E-02 4.53E-01 4.22E+00

1963 597 1.18E-02 1.63E+00 100 3.65E-02 2.02E-01 2.83E+00

1964 530 6.85E-03 6.90E-01 59 3.09E-02 1.97E-01 3.08E+00

1965 436 1.35E-03 8.00E-02 26 1.66E-02 5.59E-02 2.09E+00

1966 415 2.32E-03 2.00E-01 27 2.54E-02 8.95E-02 2.15E+00

1967 370 1.71E-03 2.50E-01 20 2.06E-02 7.14E-02 2.13E+00

1968 469 1.75E-03 3.50E-01 5 1.10E-01 6.84E-01 3.04E+00

1969 577 (a) 0.00E+00 0

1970 580 1.60E-03 3.20E-01 29 1.61E-02 7.47E-02 2.54E+00

1971 575 9.39E-04 2.00E-01 16 2.02E-02 9.09E-02 2.50E+00

1972 195 1.19E-02 4.26E-01 68 2.04E-02 8.61E-02 2.40E+00

1973 199 9.86E-02 1.81E+01 69 1.87E-02 1.09E-01 2.91E+00

1974 169 1.30E-02 8.80E-02 67 2.86E-02 6.89E-02 1.71E+00

1975 150 5.72E-03 8.60E-02 44 1.25E-02 5.96E-02 2.58E+00

1976 126 9.65E-03 2.48E-01 53 1.37E-02 7.34E-02 2.77E+00

1977 123 5.45E-03 3.00E-01 12 2.76E-02 1.72E-01 3.04E+00

1978 152 7.53E-03 1.25E-01 18 4.55E-02 2.25E-01 2.64E+00

1979 162 2.69E-03 8.30E-02 17 2.12E-02 5.64E-02 1.81E+00

1980 185 4.19E-03 1.33E-01 22 2.74E-02 8.49E-02 1.99E+00

1981 210 4.12E-03 1.20E-01 24 2.72E-02 9.27E-02 2.11E+00

1982 209 2.00E-03 5.20E-02 22 1.67E-02 3.72E-02 1.63E+00

1983 226 2.98E-03 3.14E-01 12 2.76E-02 2.06E-01 3.39E+00

1984 216 1.89E-02 3.57E+00 18 2.44E-02 2.80E-01 4.41E+00

1985 201 4.67E-02 8.66E+00 49 1.41E-02 8.34E-02 2.95E+00

1986 194 3.22E-03 5.50E-02 27 2.05E-02 4.71E-02 1.66E+00

1987 196 1.65E-03 4.00E-02 20 1.18E-02 4.82E-02 2.35E+00

1988 188 3.52E-03 1.80E-01 11 4.62E-02 1.81E-01 2.29E+00

1989 233 8.03E-04 1.60E-02 17 1.09E-02 1.37E-02 1.15E+00

1990b217 1.16E-03 4.10E-02 17 1.37E-02 2.50E-02 1.44E+00

a. Recommend using values for 1968. All 1969 recorded doses = zero.

b. Recommend using values for 1990 for all subsequent years.

Source: ORAUT-TKBS-0031, Table 15 (ORAUT 2006)

Given these data, the site profile makes the following recommendation:

Dose reconstructors should assign the ambient environmental dose to an 

unmonitored worker with minimal potential for radiation exposure from KCP 

operations, median coworker dose to an unmonitored worker with minimal 

likelihood of actual workplace exposure and the 95th percentile coworker dose to 

workers with a potential for workplace radiation exposure for each year of 

employment without a recorded dose. There should not, typically, be a significant 
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neutron exposure of unmonitored workers because sources of neutron radiation 

were very limited. 

The following presents SC&A’s review of the data and the instructions provided in the site 

profile. 

6.1.1 Accuracy/Completeness of Dose Records 

Page 13 of the site profile (ORAUT 2006) states that: 

KCP has developed and maintained a radiological records database that contains 

records for all monitored worker exposures at KCP for all years of record. The 

database contains exposure data for about 4,400 workers. 

Dose reconstructors should use recorded doses from the KCP database to 

supplement the hard-copy original dosimeter processing information submitted by 

DOE because the respective claims are often difficult to read. 

SC&A’s review of several KCP claimant files on the NIOSH OCAS Claims Tracking System 

(NOCTS) database indicates that some of the original dose records are indeed difficult to read, if 

not illegible. Apparently, there are hard copies and an electronic KCP database that contain the 

dose records for the workers; however, the accuracy and completeness of neither data source was 

addressed in the site profile. From the hardcopies examined of a limited number of claimant 

records, it would be difficult to decipher the correct recorded dose, and sometimes the dates, 

bringing into question the accuracy of the electronic database, if it was populated from the 

hardcopy records. 

SC&A searched the 731 KCP claims on the NOCTS database using occupation descriptions that 

may indicate potential exposure, such as mechanics/repairers, machinists and engineers 

contained in Table 13 of the KCP site profile. SC&A scanned 61 of these cases for DOE 

external dose files and found that 14 cases contained external exposure records. It was found 

that for most of these 14 cases, the external dose records only had one sheet of data, generally 

listing dose for only 1, 2, or 3 years (maximum of 7 years). This information is summarized in 

Figure 1 below. 

Figure 1: Number of External Exposure Records during a Given Year for 

14 Cases with Records 

0

1

2

3

4

5

1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010

Records during year
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Some workers had the same job title for many years, and the work period covered a wide range 

from 1951 to the present. It seems highly unlikely that workers (of those analyzed) would be 

monitored for only a year or two if they were performing the same task for many years. 

Additionally, as shown in Figure 1, the external dose records of these 14 cases seem to be 

centered around the mid-1960s, with very few outside that time period.

Finding 13: There appears to be limited information available to the dose reconstructor with 

respect to the nature of the work performed by the workers. This issue warrants further 

investigation, along with the investigation of the legibility/accuracy/completeness of the 

database(s) used for dose reconstruction, in order to assess the ability to reconstruct worker doses, 

as supplemented with the coworker model. Subsequent to the original site profile review, 

interviews revealed that worker training records do exist that indicate the qualifications required 

to work in specific areas and perform tasks specific to potential exposure to radioactivity. These 

records should be more thoroughly researched in the site profile.

6.1.2 Beta Dose

Page 25 of the site profile indicates that beta dose was measured from 1950–1964. However, 

prior to 1964, exposure record forms did not have a column to enter beta dose. Table 3 (ORAUT 

2006, p. 11) covers 1964–1987 and not the entire period (1958–1972 and 1997) of DU 

operations, which could involve beta exposure.

The geometry of the worker’s body parts with respect to the radiation source was not described. 

The use of gloveboxes/fume hoods was not mentioned; these fixtures would alter the dose 

received to the different organs in comparison to the badge worn on the chest. Sufficient details 

concerning the potential for beta exposure from the various electron-producing and beta-emitting 

sources, as a function of time and work location, are lacking in the TBD.

Finding 14: It appears that there are large time periods where beta exposure records are lacking, 

making it difficult to reconstruct beta doses for workers during those time periods and for 

developing a coworker model that can cover those time periods. In addition, the details of beta 

exposures are lacking.

6.1.3 Moderated Neutron Dose

The site profile states that neutron generators (D-T producing 14.7 MeV mono-energetic 

neutrons) and radioisotope neutron sources (PuBe producing an average energy of 4.5 MeV 

neutrons) were used at the KCP from the 1960s to 2004. These neutron sources are listed in 

Table 4 of the site profile (ORAUT 2006, p. 12). NTA film and polycarbonate neutron 

dosimeters can be calibrated to medium-energy neutron sources in the energy range of 1 MeV to 

15 MeV. However, in any occupied working area, there will be neutron shielding in the form of 

moderating (hydrogenous) material between the neutron source and the workers, which degrades 

the neutron energy and creates gamma radiation from neutron-capture reactions. Some of these 

moderated neutrons will fall below the ~1 MeV thresholds of the NTA film and polycarbonate.
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SC&A considers this a form of missed dose that would not be recorded on the workers’ records. 

If a significant fraction of the dose is less than 1 MeV, a detectible neutron dose will not be 

recorded, even though an actual neutron dose was received. 

This may partly account for the NIOSH statement (ORAUT 2006, p. 27):

Overall, the recorded neutron dose is a relatively insignificant component of the 

worker dose.

During the onsite data capture activities, SC&A received documentation of phantom exposure 

studies conducted on an anthropomorphic phantom (Honeywell 2013; Nasca 2013a and 2013b). 

Continual exposure of the phantom to pulse neutron operations produced total neutron exposures 

of less than 1 mrem over several months. Workers involved in these particular operations may 

have been exposed to small neutron doses. 

The site profile does not provide any information (as a function of time) concerning the physical 

setup, shielding, operating parameters (neutron output and usage fraction), and specific use of the 

generated neutron fields to allow for an evaluation of the potential neutron exposures to the 

workers. There are no neutron spectrum data for KCP (ORAUT 2006 p, 27). Rather, the site 

profile simply assumes a spectrum of 0.1 to 2 MeV. While this is claimant favorable for dose, it 

does not take into account the fact that neutrons below ~1 MeV would not be represented well in 

the badge readings. Hence an analysis of the workplace shielding and other parameters is needed 

to develop an adjustment factor for badge readings to take missed neutron dose into account. 

Additionally, job titles and/or training documentation associated with potential neutron 

exposures are necessary to evaluate the recorded neutron dose records and to assist the dose 

reconstructor in assigning neutron doses.

Finding 15: The scarcity of positive neutron doses might be explained, in part, by the limited 

ability of NTA film to detect neutron energies below ~1 MeV. Additionally, neutron exposures 

may have been missed during neutron area surveys, because the only neutron survey instrument 

listed in Table 5 (ORAUT 2006, p. 13) is a Nuclear Chicago Model #2715, and this instrument 

may not have correctly responded to the pulsed neutron fields with the generator(s) being 

operated in the microsecond pulse mode, which was typical at KCP, as indicated in Table 4 

(ORAUT 2006, p. 12). An analysis of the workplace shielding and other parameters is needed to 

develop an adjustment factor for badge readings to take missed neutron dose into account.

Neutron Dosimetry Correction Factors

Section 6.3.2 of the site profile describes the personal neutron dosimetry systems employed at 

the KCP, including techniques and exchange frequencies provided in Table 14 (ORAUT 2006, 

p. 25). One of our concerns is that quarterly exchange of NTA film can result in complete loss 

of countable track and yield zero dose recordings for low-level and/or low-energy neutron 

exposures. This is illustrated in a 1974 article by L. Phillips (Phillips 1974, pdf p. 18), which 

describes tests run at Brookhaven National Laboratory (BNL) to determine NTA track fading. 

The results, using a relatively high-energy bare PuBe neutron source, are shown in Figure 2.
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Figure 2: Percent of Original Tracks vs. Time 

Finding 16: The fading of the NTA film as a function of time, temperature, and humidity, was 

not addressed in the site profile, nor were there any correction factors provided. Lower-energy 

moderated neutrons would show even more fading as compared to the higher-energy neutrons. 

Additionally, the angular response of NTA film and polycarbonate neutron dosimeters was not 

addressed, which generally requires a 30% correction factor. 

Finding 17: During the data capture, we determined that neutron detection instrumentation was 

checked and may have been calibrated at KCP using some type of neutron sources. The site 

profile should investigate this situation further as a potential source of exposure to workers. 

6.1.4 Neutron-to-Photon Ratios 

Page 27 of the site profile (ORAUT 2006) states the following:

KCP worker recorded positive neutron dose was recorded a total of 35 times over 

a period from 1966 through 1996, with most instances occurring in the 1980s 

with good dosimetry capabilities, from a total of 14,758 annual dose records. In 

all cases, except for 2, the recorded annual deep dose is equal to the recorded 

annual neutron implying all recorded deep dose resulted from the neutron 

dose. ... As such, the recommended approach is to use a neutron to photon dose 

ratio of 1:1 as a conservative estimate of neutron dose to the few workers with 

any potential of neutron exposure. 

In light of concerns regarding the reliability of NTA film with respect to lower-energy neutrons, 

it is not apparent that there is a sound basis for assigning an n/p ratio of 1:1. In other site profile 

reviews, SC&A has stated that n/p ratios can be used to derive neutron doses if a reliable set of 

paired data of neutron and photon measurements are available and employed instruments that 
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can detect the full range of neutron energies. It does not appear that this approach was used to 

derive the n/p ratio of 1:1.

Finding 18: Neutron-to-Photon (n/p) ratios require additional investigation in order to develop a 

recommended approach for dose reconstructors.

6.2 COWORKER DATA ISSUES

Page 26 of the site profile (ORAUT 2006) states the following:

...it is reasonable to assume that any unmonitored dose would be less than the 

dose received by monitored workers.

Figure 2 of the site profile, which presents a lognormal probability plot of KCP recorded annual 

penetrating dose (ORAUT 2006, p. 27), shows the probability of occurrence versus the annual 

dose (mrem) for 1950–2003. This plot indicates a median dose of around 20 mrem/year and a 

95th percentile of around 70 mrem/year. Table 15 (ORAUT 2006, p. 28) provides a list of 

coworker doses as a function of year for the period of 1950–1990. There appears to be a 

reasonable amount of data available for this coworker model. However, it would be useful to 

obtain a spreadsheet of the data in Table 15 to allow creation of a plot consisting of dose versus 

year to better visualize trends and abnormalities in the data.

Table 15 also shows that there were 577 workers monitored during 1969, with all zero recorded 

doses. This appears to be unusual, because the adjacent years had approximately the same 

number of workers monitored with the median and 95th percentile doses both positive. To use 

the information in Table 15 as coworker data, the reason for the 1969 abnormality needs to be 

investigated to determine if there were problems with the dosimetry system (which may have 

spilled over into other years) or if the lack of recorded positive dose was a result of other 

influences, such as changes in operations, lost records, etc.

Finding 19: It may not be always correct to assume that unmonitored workers experienced 

exposures that were generally lower than those experienced by monitored workers, because 

monitoring in the early years may not have been as thorough as would be desired. In addition, as 

discussed in previous findings, coworker categories are ambiguous and might result in 

inappropriate coworker dose assignments. Furthermore, Table 15 may reflect decreased average 

recorded doses, as the number of zero dose records included may not be a complete accounting 

of the actual dose to workers. Refer to Finding 11, which may have some applicability to this 

finding.

6.2.1 Dosimeter Response to Low-Energy Photons

Page 24 of the site profile (ORAUT 2006) states the following:

The photon energy spectra in KCP workplaces have not been measured. The 

spectra are related to the configuration of the X-ray machines, the process, and 

the extent of shielding. However, regardless of the precise spectra, significant 
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photon radiation would have been readily measured at KCP by the available 

dosimeter technology during all years of operation.

And on p. 28, it is stated:

The energy of prevalent photons based on the radiation sources is readily 

measured, so no adjustment of recorded dose would be likely based on the 

response characteristics of the different dosimeters.

However, on p. 25, it is stated:

Eberline standard (three-chip, TLD-100) TLD – used from 1983 through 1990. 

This dosimeter employs one chip under a 10-mg/cm2filter to measure the shallow 

or skin dose and one or two chips under a 285-mg/cm2filter to measure the deep 

or whole-body dose (TMA 1990). The use of this dosimeter was terminated due to 

its inability to pass DOELAP lower energy photon performance testing 

categories... 

The dosimeters were apparently calibrated using Co-60 (ORAUT 2006, p. 24), which is a 

relatively energetic photon source (1.17 and 1.33 MeV). However, numerous x-ray-producing 

units were used at the KCP, as listed in Table 4 (ORAUT 2006, p. 12). These x-ray machines 

produced a wide spectrum of primary and scattered photons down to very low energies. The 

dosimeters calibrated using Co-60 may not have correctly responded to these lower-energy 

photons. Therefore, a correction factor may be needed, especially for determining the dose to 

skin and shallow organs.

Finding 20: A correction factor for exposures to photon radiation might be needed, due to the 

differences between the actual photon energy distributions created largely by x-ray machines, 

and the relatively high-energy photons associated with Co-60, which was used for calibration of 

dosimeters. This issue is especially of concern regarding exposures to skin and shallow organs.

6.2.2 KCP Site Profile Text Issues

The following areas need clarification/correction to provide more definitive information for the 

reader or dose reconstructor:

 Radiation Sources – Table 4 (p. 12.) provides a list of the typical radiation sources used 

at the KCP. The 230-curie Cesium Irradiator is listed as used for “Calibration of 

radiation detection instruments.” However, this would be a very large source to use for 

calibration of instruments; most likely it was an irradiation source for parts or inspection, 

not for calibrating instruments.

 Neutron Dosimeters – The text in Section 6.3.2 (p. 25) discusses only the Lexan 

neutron detector, but lists other neutron detectors in Table 14. The text should provide 

information concerning all types of neutron detectors used at the KCP. Additionally, 

Table 14 is incomplete for the 1961–1967 and 1967–1973 time periods, because the type 
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of neutron detector is not specified (1967–1973 only lists “film,” not specifically NTA 

film).

 Shallow Dose Uncertainty – Section 6.5.4 (p. 31) discusses using Tables 19 and 20 for 

determining the uncertainty for shallow doses. However, Section 6.5.3 recommends an 

alternative approach for photon dose that is simpler; the KCP site profile should state 

whether this alternative approach also is applicable to shallow dose.

 MDL Method not Applicable to Gaps in Records – The last paragraph on page 26 

reads:

Dose reconstructors should use Method 1 if there is sufficient information 

and only occasional missed doses, and Method 2 if significant doses are 

zero or missing. Use Method 2 for workers who were monitored with 

missing or zero recorded dose or who worked in an area or an occupation 

where positive dose would be expected but was not recorded.

The term “missing” in this content refers to the lack of entry in the dose records, or the 

lack of dose records. Therefore, assigning dose based on Method 2 (MDL of the 

detector) is scientifically incorrect, because the worker did not wear a monitor, or the 

results were not recorded. Instead, coworker or adjacent recorded doses in the worker’s 

records should be used to fill this gap.

 Incorrect Table Reference – The last paragraph on page 33 of Section 6.6 states “...is to 

use the organ DCFs for an AP exposure geometry as indicated in Tables 6 and 7.” 

However, Tables 6 and 7 are from Section 3 for occupational medical exposures. It 

appears that this statement should refer to Tables 21 and 22 in this section.
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7.0 INCIDENT RECORDS

A 1980 internal Bendix memorandum states that accident records were excluded from the data 

due to the Privacy Act: 

The Bendix Kansas City Division records for personnel having Radiation 

Exposure' data includes 4,326 individuals. Data for Occupational and Industrial 

accident records are not included because these records are excluded from 

coverage by the Privacy Act as stipulated in our prime contract. [Williams 1980]

This memorandum indicates that accidents may be systematically excluded from corporate 

records. It is unclear if accidents are reflected in individual worker records or in the data 

compilation that NIOSH is using. This applies to both internal and external dose data.

An interviewee was involved in the Pm-147 cleanup. They used protective equipment in doing 

this work, such as laboratory clothes and perhaps a hood. The worker had a film dosimeter. The 

worker [who was at KCP for over 30 years] did not remember any other incidents. The worker 

recalled using a respirator during the Pm-147 cleanup. The respirator was a full-face unit 

referred to as a “moon face.” The site profile discusses the Pm-147 incident and notes that [less 

than 9] workers were found to have some contamination (ORAUT 2006, p. 23). The site profile 

also notes that other “fragile and relatively unsealed” sources were also used but dismisses the 

dosimetric implications as “comparatively insignificant”:

KCP operations do include the use of several radioactive sources that can be fragile and 

relatively unsealed, as occurred with the 147Pm source incident. However, any intakes 

from KCP use of various small sources would probably be comparatively insignificant.

[ORAUT 2006, p. 23]

The conclusion that exposures resulting from small sources would “probably be comparatively 

insignificant” does not have analytical support in the site profile. Moreover, in light of the 1980 

memorandum quoted above (Williams 1980), it is important to establish whether there were 

small-source incidents and to show that the implications were “comparatively insignificant.”

Finding 21: The status of accident records needs to be determined. Specifically, NIOSH needs 

to establish whether accidents (internal and external) are included in the records in NIOSH’s 

possession or whether they need to be obtained and included. Further, NIOSH needs to establish 

rather than assume that the doses relating to fragile radioactive source incidents were 

insignificant from a compensation point of view.
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

REFERENCES

42 CFR 82, 2002. Methods for Radiation Dose Reconstruction under the Energy Employees

Occupational Illness Compensation Program Act of 2000; Final Rule, Federal Register, Vol.67, 

No. 85, May 2, 2002, p. 22314.

Battelle 2011. Site Profiles for Atomic Weapons Employers that Worked Uranium Metals. 

Battelle-TBD-6000. Rev. 01. National Institute for Occupational Safety and Health (NIOSH); 

Cincinnati, Ohio; Division of Compensation Analysis and Support (DCAS); effective June 17, 2011; 

SRDB Ref ID: 101251

Bendix 1963. Magnesium-Thorium (3.5% Max) Alloy – Suggested Care and Handling Methods, 

Bendix Corporation, Kansas City, Missouri, March 12, 1963. SRDB 108264, PDF pp. 32–34.

Bendix 1970. Revised Health and Safety Guide for Handling Magnesium-Thorium in 

Department 851, Kansas City, Missouri, August 28, 1970. SRDB 108264, PDF pp. 27–29.

Bendix 1975. Revised Health and Safety Guide for Handling Magnesium-Thorium in 

Department 851, Kansas City, Missouri, July 16, 1975. SRDB 108264, PDF pp. 3–6.

Clayton, D.S., 1962. Letter from D.S. Clayton (Los Alamos Scientific Laboratory) to P.C. 

Disinger (Bendix), Los Alamos, New Mexico, March 13, 1962. SRDB 38160, PDF pp. 128–129.

DOE (U.S. Department of Energy) 1988. Radiation Protection for Occupational Workers, DOE 

Order 5480.11, U.S. Department of Energy, Washington, D.C. December 21, 1988.

DOE 1994. Primer on Tritium Safe Handling Practices, DOE-HDBK-1079-1994, U.S. 

Department of Energy, Washington, DC. December 1994.

DOE 1997. Linking Legacies, DOE/EM-0319, Office of Environmental Management, 

Washington, DC.

DOE 2004. Radiological Control Programs for Special Tritium Compounds, DOE-HDBK1184-2004, U.S. Department of Energy, Washington, DC. September 2004.

DOE-AL (U.S. Department of Energy Albuquerque Operations Office) 1990. Facilities 

Radioisotopes Data, Pre-Decisional Draft, Albuquerque, New Mexico, December 1990. SRDB 

13225.

GE (General Electric) 1976. Material Safety Data Sheet – MC3051 Neutron Generator Trng. 

Unit, General Electric Company, St. Petersburg, Florida, May 31, 1976. SRDB 12188.

Honeywell 2013. Honeywell FM&T Kansas City Plant Personal Dosimetry History [2000–

2012], Honeywell FM&T Kansas City Plant, Kansas City, Missouri. July 2013. SRDB 126817.
Effective Date:

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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.

ICRP (International Commission on Radiological Protection), 1995. Age-Dependent Doses to 

Members of the Public from Intake of Radionuclides: Part 4 Inhalation Dose Coefficients, ICRP 

Publication 71, Pergamon Press, Oxford, England.

Krueger, R.L. and J.J. Meunier, 1987. Employee Concern Investigation Report, Environmental 

Services, Bendix Corporation, Kansas City, Missouri. October 12, 1987. SRDB 108267.

Laing, E.C., 1952. April Triple Dip Canning Program, Metallurgy Division, Argonne National 

Laboratory, Argonne, Illinois, April 5, 1952. SRDB 101212.

LASL (Los Alamos Scientific Laboratory) 1962. Disposal of Radioactive Waste – Los Alamos 

Scientific Laboratory, January 1, 1962 through June 30, 1962, Los Alamos, New Mexico, 1962. 

SRDB 38160, PDF pp. 162–165.

Lutz, P.R., 1995. Memo from P.R. Lutz to D.S. Santos and D.M. Herrig, Subject: Return of 

Controlatrons/Zetatrons to LMSC (Lockheed Martin Specialty Components), December 6, 1995. 

SRDB 13203, pp. 4–5.

Mahaffey, J.W., 1952. History of Production Machining of Uranium, FMPC-28, National Lead 

Company of Ohio, Cincinnati, Ohio, June 16, 1952. SRDB 44238.

Malone, F.W., 1951a. Weekly Production Reports for November 8, 1951, November 15, 1951, 

and November 22, 1951, [AEC] New York Operations Office, Tonawanda Sub-Office, Model 

City, New York. November 1951. SRDB 61144.

Malone, F., 1951b. Requirements for NYX Job, [AEC] New York Operations Office, 

Tonawanda Sub-Office, Model City, New York. June 27, 1951. SRDB 92911.

Malone, F.W., 1952. Weekly Progress Report January 21, 1952, [AEC] New York Operations 

Office, Tonawanda Sub-Office, Model City, New York. February 4, 1952. SRDB 61171.

Mann, Jennifer, 2012. “Suit filed over government test-spraying in St. Louis during Cold War.” 

St. Louis Post-Dispatch. November 21, 2012. stltoday.com. Accessed October 7, 2013.

McKay, C.P., 1970. Memo from C.P. McKay to I.C. Schrieber, Subject: Magnesium-Thorium 

Parts – Radec Program, Bendix Corporation, Kansas City, Missouri, September 9, 1970. SRDB 

108264, p. 30.

Nasca, B.M., 2005a. Letter from B.M. Nasca to R.J. Traub, Subject: “Re: E-mail dated 2/8/05, 

Uranium Bioassay.” Dosimetry records of four individuals were attached to this letter. February 

9, 2005. SRDB IDs 015928 and 049002.

Nasca, B.M., 2005b. E-mail from B.M. Nasca to R.J. Traub, Subject: “Re: KCP Occupation 

Codes.” February 25, 2005. SRDB ID 15925.

Nasca, B.M., 2013a. Radiation Data for Neutron Area – Phantom Badge Dose (at Neutron 

Tube), spreadsheet data updated January 18, 2013. SRDB 126817.
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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.

Nasca, B.M., 2013b. Radiation Data for Neutron Area - Phantom Badge Dose (at X-ray Tube), 

spreadsheet data updated March 2010. SRDB 126817.

NCRP (National Council on Radiation Protection and Measurements) 1996. Screening Models 

for Releases of Radionuclides to Atmosphere, Surface Water, and Ground, Report 123 I, 1-316, 

Bethesda, Maryland.

NYOO (New York Operations Office) 1951. Tonawanda Area Progress Report, [AEC] New 

York Operations Office, Tonawanda Sub-Office, Model City, New York, November 1951. 

SRDB 67129, PDF pp. 53–59.

NYOO 1952a. Progress Report, Tonawanda Area, January 1952, [AEC] New York Operations 

Office, Tonawanda Sub-Office, Model City, New York, January 1952. SRDB 67129, PDF 

pp. 89–90.

NYOO 1952b. Progress Report, Tonawanda Area, April 1952, [AEC] New York Operations 

Office, Tonawanda Sub-Office, Model City, New York, April 1952. SRDB 67129, PDF pp. 98–

104.

ORAUT 2005. 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 2006. Site Profile for the Kansas City Plant, ORAUT-TKBS-0031, Rev. 00 PC-1, Oak 

Ridge Associated Universities Team, Cincinnati, Ohio. January 6, 2006.

Phillips, L., 1974. Personnel Dosimetry. Brookhaven National Laboratory, Upton, New York. 

SRDB 22429.

Porrovecchio, J., 2013. Unclassified/redacted notes from Joe Porrovecchio's review of KCP 

classified documents, Germantown, Maryland, July 18, 2013. SRDB 127001.

Reichman, N.H., 1962a. Letter from N.H. Reichman (LASL) to R.F. Steinman (Bendix), Los 

Alamos, New Mexico, April 9, 1962. SRDB 38160, pp. 143–144.

Reichman, N.H., 1962b. Letter from N.H. Reichman (LASL) to R.F. Steinman (Bendix), Los 

Alamos, New Mexico, May 25, 1962. SRDB 38160, p. 154.

Runkle, G.E, 1997. Memo from G.E. Runkle (DOE-AL) to D.A. Gurule (DOE-KC), Subject: 

Internal Dosimetry Radiation Monitoring for Personnel Working with Depleted Uranium, U.S. 

Department of Energy, Albuquerque Operations Office, Albuquerque, New Mexico. February 4, 

1997. SRDB 126817.

SC&A 2004. Standard Operating Procedure for Performing Site Profile Review, S. Cohen and 

Associates, McLean, Virginia. March 18, 2004.
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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.

Schiltz, J.O., 1962. Letter from J.O. Schiltz (Bendix) to D.D. Meyer (LASL), Kansas City, 

Missouri, March 28, 1962. SRDB 38160, pp. 134–135.

Stewart, A.E., 1961. Memo for file, Subject: Magnesium-Thorium Alloy (HK31A), Bendix 

Corporation, Kansas City, Missouri, July 12, 1961. SRDB 108264, p. 49.

TMA (Thermo Analytical, Inc.) 1990. Radiation Dosimetry: TLD Service for Personnel & 

Environmental Monitoring, TMA Eberline, Albuquerque, New Mexico.

Triplett, C.S., 1970. Summary of Air Samples of Magnesium-Thorium Project in D/851, Bendix 

Corporation, Kansas City, Missouri, November 5, 1970. SRDB 108264, pp. 16–20.

Ulitchny, M.G., et al. 1998. Uranium Dioxide (U), KCP Document 4562260, Issue H, Kansas 

City, Missouri, October 1998. SRDB 14693.

Williams, L.K., 1980. Internal Memorandum to B. L. Moore, Acting Area Manager. Subject: 

Privacy Act Sytem of Records – Personnel Radiation Exposure Records – DOE 35 and 

Occupational and Industrial Accident Records – DOE 33, Bendix Corporation, Kansas City, 

Missouri. May 16, 1980. SRDB 111879.
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ATTACHMENT 1: SITE EXPERT INTERVIEW SUMMARY

INTRODUCTION 

As technical support contractor for the Advisory Board on Radiation and Worker Health 

(Advisory Board), S. Cohen and Associates (SC&A) has been tasked with reviewing the site 

profile for the Kansas City Plant (KCP) that was prepared by the National Institute for 

Occupational Safety and Health (NIOSH). One component of SC&A’s review is a series of 

interviews with site experts, including current and former site workers. The purpose of worker 

interviews is to hear first-hand accounts of past radiological control and personnel monitoring 

practices, and to better understand how operations and safety programs were implemented at the 

site over time.

Joe Porrovecchio (SC&A); Josie Beach, Brad Clawson and John Poston (Advisory Board KCP 

Work Group); Grady Calhoun (NIOSH); and Jack Fix (ORAUT) participated in a site tour and 

conducted onsite, secure interviews with nine current and former KCP employees during a site 

visit December 3–6, 2012. Participants were identified by SC&A, the site coordinator, site 

health physics, and advocates involved with site concerns, with selections based on availability 

and relevance to subject matter. Nine site experts were interviewed on this visit, including KCP 

personnel who led the tour.

Joseph Porrovecchio and Dr. Robert Bistline (SC&A) also conducted unclassified, offsite 

interviews with five former GSA employees at the Bannister Federal Complex (KCP) that were 

non-DOE employees in October 2011; these interviews were conducted in conjunction with 

review of unclassified records at the Federal Records Center in Lenexa, Kansas.

Interviewees were briefed on the background of the Energy Employee Occupational Illness 

Compensation Program Act (EEOICPA) and the purpose of the interviews. Workers were asked 

to supply names and contact information for follow-up. Participants in offsite interviews were 

directed not to disclose sensitive or classified information. Written notes and interview 

summaries were submitted to KCP for classification review.

Interviewees were given the opportunity to review their individual interview summaries for 

accuracy and completeness. This is an important safeguard against missing key issues or 

misinterpreting information.

 The offsite interviewees received written interview summaries by mail or e-mail after the 

interview notes and typed interview summaries had been cleared by KCP. Two of the 

individuals (40%) did not respond to SC&A’s request for review of the written summary.

 For the onsite interviews, KCP provided a classified computer and a display monitor to 

facilitate real-time entry and review of interview notes/summaries. All of these 

interviewees reviewed and verbally approved the content of written summaries during the 

interviews.
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 Responses were received from 60% of the offsite interviewees and 100% of the onsite 

interviewees (86% overall). Information obtained from non-responders has been 

withheld from this master summary.

The workers whose interviews are summarized below represent the time period from 1951 

through the present (December 2012). Their employers at the Bannister Federal Complex 

included Bendix, Allied, Allied-Signal, Honeywell, Atomic Energy Commission, Energy 

Research and Development Administration, Department of Energy (DOE), General Services 

Administration (GSA), National Archives, and Department of Defense.

The work categories and programs collectively represented by the interviewees include the 

following:

 Administrative, clerical

 Chemical stores

 Electronics

 Engineering

 Facility management, maintenance, construction trades

 Inspection and testing

 Manufacturing, fabrication

 Production, operations, assembly

 Radiation Safety

 Transportation

 Telemetry

 Tool and equipment repair

The information provided by the workers and site experts is invaluable in helping SC&A to 

better understand the operations at KCP. This summary report is not a verbatim presentation of 

the material contained in the interview notes, nor is it a statement of SC&A findings or 

opinions—it is a consolidated summary of statements, opinions, observations, and comments that 

the interviewees communicated to SC&A. The sole intent of this summary is to communicate to 

the Work Group, the Advisory Board, and other interested parties information acquired by 

SC&A during these interviews.

Although an abundance of good information was provided during the tour and in interviews, 

this summary concentrates on areas that could potentially impact claimants’ dose assignments 

in the dose reconstruction program under the EEOICPA. Comments are included in brackets 

where SC&A has provided clarification to the site expert’s statement.

Information provided by the interviewees is based entirely on their personal experience at KCP. 

The site experts’ recollections and statements may need to be further substantiated; however, 

they stand as critical operational feedback and reality reference checks. This interview summary 

is provided in that context. Key issues raised by site experts are similarly reflected in SC&A’s 

review discussions, either directly or indirectly. Information from all interviewees who reviewed 

and approved their individual interview summaries has been consolidated into this summary 
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document. Where conflicting observations and statements have been received, both perspectives 

are presented.

The information gathered has been categorized into topical areas:

 Facilities and Operations

 Maintenance and Construction Trades

 Radiological Control

 External Monitoring

 Internal Monitoring

 Incidents and Accidents

 Waste Management and Environmental Monitoring

 Medical X-ray Examinations

 Radiological Records

 Miscellaneous Comments

FACILITIES AND OPERATIONS

[The interviewees, collectively, provided their characterization of the facilities and operations at 

KCP, as follows.]

[KCP shared space in the Bannister Federal Complex with several other agencies, including 

Internal Revenue Service, National Archives, Department of Defense, U.S. Marine Corps, and 

GSA. GSA is responsible for some aspects of facility administration and maintenance.] 

There was shared air between both sides of the complex. In the Building 1 basement, Corridor 

16 goes north-south through the entire building. Q corridor went east to west to the wall 

demarking GSA/Honeywell side (column 26 demarks the moveable wall that separates GSA 

from DOE in the same 67-acre building).

[Some work areas previously utilized for DOE/NNSA (National Nuclear Security 

Administration) activities were later transferred to GSA.]

 Building 41 is a little building in the north parking lot. There was construction in 

Building 41 while an interviewee worked there. It was used for a farmers market after 

2000. Building 41 was a very messy, filthy building before it was refurbished. When 

GSA took over the building (~1973–1975), the building was dusty, and they had to clean 

it up. [GSA workers] disposed of waste from Building 41. Whatever was there went to 

the landfill.

 About 1991–1992: A wall was taken down between GSA and DOE areas in Building 1. 

They moved the partition about 100–150 yards, with GSA taking over the CASAU area 

from Honeywell. [Acronym definition is not known.]

The workforce at KCP went from 2,000 to 9,000 employees during a build-up in the 1960s. 

Staffing level was reduced in 1974. There was another buildup in 1978 until the mid-1980s.
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The following past and present activities at KCP involved radioactive materials and radiationgenerating devices: 

 Industrial radiography for NDT [Non-Destructive Testing]

 Telemetry

 Neutron radiation pulse operations

 Sealed-source handling (typically Health Physics lab and check sources)

 Analytical science lab boron analysis

 Formerly, beta backscatter analysis for measuring thickness of plating

 DU [depleted uranium] process etching (1997–2010)

 Machining parts (1960s)

[Interviewees were asked if they had experience or knowledge regarding (1) a project that used 

uranium oxide in a powder form and (2) a microelectronics facility operated by KCP at Sandia 

National Lab in Albuquerque, New Mexico (~1975–1991).] 

 None of the individuals available for interviews had knowledge of the uranium oxide

project, although one interviewee thought there may have been some material in the 

waste.

 Some interviewees knew about the microelectronics facility, but they never worked there. 

One worker had taken a tour of the microelectronics facility at Sandia.

Some interviewees indicate job titles are well-defined; several workers observed that the titles 

are not closely associated or correlated with radiological work. An interviewee said job titles 

changed over time; in the 1990s, for the first time, job descriptions were printed out and signed 

by employees.

Training records are likely the best evidence of locations where persons worked. Currently, an 

RWA [Radiation Work Authorization] provides evidence of radiation workers on a specific 

project. Medical screening records [may also be useful for identifying radiological workers]. An 

interviewee thought it would be difficult to associate job descriptions with potential for radiation 

exposure; the worker’s employment records do not indicate anything like this until 1991. The 

previous Radiation Safety Coordinator for Telemetry maintained lists of radiation workers in the 

Telemetry area; these go back to about 1990.

An interviewee suggested that examples of radiological worker training, qualifications, etc.,

would be good sources of supplemental information.

A worker [1960s era] recalled that Department 22 was the only department that worked with 

radioactive material other than x-rays. The security badge had a ‘22’ on the credential, and this 

was required for entry.

When asked about the use of thorium at KCP, a Radiation Safety worker was only aware of 

small check sources. The interviewee has no knowledge of any processed thorium at KCP. 

There may have been some [consideration of thorium projects], but the interviewee is not aware 
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of any confirmed thorium. Often national projects are scoped at each site to review capabilities. 

There typically is no follow-up documentation to indicate that the project was not established or 

was conducted at other sites.

Manufacturing

[Fabrication and machining activities involved a number of skilled crafts.] A General Machinist 

manufactured, machined, and fabricated parts. As a production worker, an interviewee deburred 

and degreased manufactured parts. Tool and Die makers and model makers were involved in 

lead fabrication, processing and planning of tools/jigs, fixtures and molds. A Tool and Die 

Apprentice participated in a 6-year formal certified training program. There were model makers 

in the Model Shop and in the engineering shop. A Sheet Metal Fabricator participated in R&D 

[research and development] and engineering processes for process prove-in [development and 

implementation of a manufacturing production process].

Interviewees worked in the Model Shop, engineering shop, Helpers Paint Shop, RTV [Room 

Temperature Vulcanization] Shop, TEM (Tooling and Equipment Maintenance) shop, Sheet 

Metal Shop, vapor blast shop, plating shop, welding shop, Lab Shop, heat treat EDM (Electrical 

Discharge Machining), and Chemical Stores.

Other positions in machining areas included drill operator, lathe operator, machine operator, and 

(at the model shop) model maker.

A machine area worker recalls being loaned out to other organizations during the period of 

employment. [A machinist] worked in about all areas [over the worker’s] career. Departments 

22 (radioactive area), 24, 25, and 48 (plastics) were all within a common area. The worker was 

required to punch out each day from the home department.

An interviewee could not remember exactly the facility layout, but does remember the general 

activities. The interviewee milled uranium and also worked with uranium plugs that were shiny 

in appearance; the worker would inscribe a radius on the plugs.

[A machine area worker recalls work with uranium “chips.”] This likely occurred in about 1961 

or later. The worker could not recall what was done with the uranium chips. Within a couple of 

weeks, the chips would turn a golden color. A liquid solvent was used during the machining, but 

the worker could not remember what was done with the material after the work was done. The 

interviewee also worked on machining depleted uranium (DU) items, in oil bath and solvents,

which the worker did not like because the material would splash on the worker. The scrap DU 

items were placed within 55-gallon barrels.

The worker was sure that they cleaned up the uranium chips at the end of each shift. [The chips 

were] placed into barrels, which the worker believes contained a liquid solvent—it may have 

been carbon tetrachloride. Workers may have placed concrete in the barrels on top of the liquid 

solvents and over the uranium chips. The barrels were then quite heavy. The interviewee was 

unaware of barrels being buried at KCP; the worker thought they were sent to New Mexico. A 

young worker used to swab the floor with carbon tetrachloride. The carbon tetrachloride was 
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used for many purposes, such as cleaning the floor, washing the lathe tools, washing hands, etc. 

It would evaporate nearly instantly.

An interviewee remembered work in the model shop [prior to 1971] on material that came from 

the “gold room” that may have been radioactive. The worker recalled machining the part until a 

vacuum was released. The worker was not aware of the materials involved and was not required 

to wear a dosimeter. The part had to be mounted into a Plexiglas jig prior to machining. The 

piece was returned to the gold room after machining. Access to the gold room was secured. 

[Current Radiation Safety staff was not present at this time and is not familiar with this project.]

Telemetry

Telemetry was not active until about 1975. The Telemetry Department has basically stayed in 

the same location. There was a temporary relocation (a few months) in about 1989 for a 

renovation. Telemetry [activities are conducted] in the basement area.

An Inspector and Tester Electronics inspect all products prepared by telemetry technicians.

A Telemetry worker has some association with DU items; the worker did inventory on product 

control numbers as part of the receipt verification. The worker did not actually handle the 

uranium and is not aware of the use of the depleted uranium bars.

Interviewees worked with low-level radiation sources. [They identified the following radioactive 

items that are received, handled, and shipped:]

 Barium bolts used to calibrate the lead probe in the neutron tester

 Tritium target assemblies in the neutron generators

 X-ray source

 Sealed sources (e.g., Cs-137 and Am-241) used for calibration

There is hands-on work with the barium bolts. The barium bolts, tritium [assemblies in the 

neutron generator], and Cs-137 check source are described as sealed or encapsulated sources. 

The neutron generators [tritium target assemblies] are not opened at KCP, but are returned to 

Sandia.

Test Equipment staff designs and maintains the test equipment that uses the electronic neutron 

generator. One interviewee was responsible for maintaining health physics records and provided 

phantom exposure records indicating extremely low worker doses associated with neutron 

generator operations.

A radiological worker with Rad Worker I training has worked on portable neutron detectors. 

The worker procured a gamma source (perhaps Cs-137) to calibrate the detectors. The source

was kept in a locked cabinet.
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Health for factual accuracy or applicability within the requirements of 42 CFR 82.

MAINTENANCE AND CONSTRUCTION TRADES 

[The interviewees involved with construction and maintenance, collectively, provided a 

description of construction and maintenance activities at KCP, as follows.]

[GSA workers responsible for facility maintenance entered parts of the facility where work was 

conducted for DOE/NNSA.] There was roof access to both sides for maintenance. [Workers 

noted controls, including] guard post and escort for access into [NNSA] areas.

Workers occasionally went over on the Honeywell side of the roof to do maintenance of 

ventilation systems. GSA maintained 16 building air handling units (AHU) on the roof with 

60-horsepower motors; the 8 AHUs on the west side handled heat. Exhaust air went out of roof 

“dog houses” and there was a possibility for air exchange between exhaust and intake. There 

was shared air on the one ventilation unit that was split between GSA and NNSA, and there was 

an unlocked door between that they could go through anytime. [To the best of the worker’s 

knowledge], there was no lockout/tagout for HVAC [Heating, Ventilation, and Air Conditioning] 

repair or maintenance. When they worked on the roof [flat roof surface and dome shaped 

concrete 18 inches thick at the columns and about 6 inches thick at the center], the radiation 

generating equipment was below them. [GSA workers] maintained all HVAC systems on roofs, 

but did not work on HEPA [High Efficiency Particulate Air] filter systems. That may have been 

done on the DOE/NNSA side.

[GSA workers] also went on the east side of the main Honeywell building to work on condensate 

pumps. The pumps were in a pit with orange slime and they pumped into a lagoon located east 

of the pit. A barrel wash (skid wash) area was located by the pit. Barrels were washed when 

they came in, and the water went into the lagoon.

[A GSA worker] did not handle radioactive material and is not aware of surveys for radioactive 

contamination in the work area. The worker did not have a dosimeter, submit samples for 

bioassay, sign an access log, or wear personal protective equipment (PPE). The worker does not 

recall working around other people who were monitored or wearing PPE.

MOU stands for “Memorandum of Understanding.” These were agreements between DOE and 

GSA. [There were] MOUs [between the agencies] from 1974 through 1993. In the event of a 

spill or incident on the DOE side, GSA would send its maintenance crew, and DOE would pay 

from its fund. The interviewee does not know how often the MOUs were used.

RADIOLOGICAL CONTROL

[The interviewees, collectively, provided their characterization of the radiation protection 

organization and practices at KCP, as follows.]

Interviewees generally stated that KCP is supportive of all DOE orders [DOE 1988 was 

specifically discussed] and is continually improving to strive for excellence. [Relevant standards 
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have been] the DOE Radiological Control (RadCon) Manual,1then 10 CFR [Code of Federal 

Regulations] 835.2

One interviewee indicated that KCP did not share information [for national security reasons] 

with workers that were not involved with handling radioactive materials about what activities 

took place. 

Access to Site and Work Areas 

Access controls for the facility involve a gated entry to the complex requiring DOE clearance. 

Access to the NNSA facility is controlled by badge controls and guard posts at entry points. 

[Interviewees describe the evolution of access controls as follows:] [In the 1970s], workers 

handed their badges to a guard at each entrance. Badge readers were installed about 1990, and 

turnstiles were installed about 10 years ago [early 2000s].

[When asked about access controls and measures to prevent non-rad workers from entering 

radiation areas], an interviewee remembered it was difficult to gain access to the plant. The 

security credential had a number which indicated the area authorized for entry. A worker 

vaguely recalled signing in when entering an area—possibly to receive a dosimeter to be used 

while machining. 

In the past, lists were used to identify workers who could enter an area. Training records may 

provide evidence of work area access. The access is not associated with job title. RWA 

documentation may also provide evidence of worker access to specific work areas. Security 

records may indicate worker access approval. 

For some positions, such as messenger, a worker had access to many areas. The worker does not 

recall being in the immediate area with radiation, but may have had access to the area. The 

worker has no recall of being monitored and was not aware of whether there was any radiation. 

An interviewee went to x-ray, medical, and worked in Department 45. The worker was 

uninformed as to whether or not the work areas contained radioactive material. The worker 

observed barrels marked radioactive, but there were none in the interviewee’s shop.

An interviewee said that security badges were marked with a designation (i.e., 1, 2, 3, etc.) which 

controlled which areas could be entered. Another interviewee explained that a blue security 

badge was required for general plant access. For Department 22, the security badge was marked 

with a “22,” which was required for access. An interviewee noted that [security ID] badges were 

changed only after they became old and unrecognizable. ID badges would turn color and not be 

recognizable and then would be changed. 

 

1

 This statement references a prior version of U.S. Department of Energy Radiological Control Manual

(DOE/EH-0256T), which was revised in April, 1994. 

2 This statement references a prior version of 10 CFR 835, Occupational Radiation Protection, which has 

subsequently been revised.
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An interviewee signed an access log when entering certain areas, but that practice was not 

instituted until the 1990s.

The Telemetry Department involves a Badge reader, which approves personnel on an access list. 

[Workers on the access list] do not need to sign an access log. [An unmonitored individual] can 

come in as a visitor, but must be escorted. They cannot be working the equipment and they 

cannot be alone. This is specified in the RWA. An access log [showing entry to the department] 

does not mean the person entered the radiation area. The radiation area of the Telemetry 

Department involves requirements for dosimetry and staff are trained radiological workers. 

Anyone in the radiation area must have a dosimeter.

There are technicians who are not allowed to enter certain areas because of mandatory training 

requirements.

Control of Sealed Sources

There was a KCP initiative to reduce the number of [radioactive] sources following the 1989 

Pm-147 incident. The tracking of sources has become much more stringent following the release 

of a DOE RadCon Manual.

Certainly in earlier days, the requirements were much less demanding. These varied over the 

years. There are documents of KCP periodic inventories of precious metals and radioactive 

sources. A specific issue was noted pertaining to Co-60 sources used historically; there is 

significant information that was collected in the KCP Site Profile.

Sources are distributed throughout the plant in various work areas according to where the source 

is used. The radiation safety representative has a key to the locked sources storage. At each 

department, since 1989, there is an authorized list.

A 24/7 source log is kept for each source and location, indicating removal, location, and return. 

The interviewee does not know the history of the log books, but this information should be 

available from document control. Telemetry workers definitely had these log books in the 1980s. 

The emphasis has been on knowing the location of the source.

Other Administrative Controls

KCP uses RWAs for workplace reviews. The Health and Safety group determines appropriate 

controls and PPE for each project.

[In response to a query regarding training and records at KCP], an interviewee said that the 

RWA is relatively recent with the associated training and protective equipment requirements for 

workers. During earlier years, there was greater emphasis on “need to know” requirements.

A worker [who machined uranium] does not remember receiving any radiation training. The 

worker was aware of radioactive material, but does not remember being informed of the specific 

material with which he was working. Information regarding the material being worked was 
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typically not known or discussed. Workers were strongly discouraged from discussing the work 

being done.

An interviewee said employees were not told what was potentially contaminated and what 

hazards were present, if any. The worker is suspicious of KCP management because they did not 

did not inform [the worker] about hazards. This worker is suspicious of activities that, for 

national security purposes, were not revealed to workers that may have been exposed to 

hazardous chemicals or radiation. The interviewee worked in many trades and crafts at KCP, 

was unaware of activities nearby, and was not informed. Even after the fact, the worker [still 

wants to know] what went on in the work areas.

A Telemetry worker noted that there was not a lot of data on neutron generators [in the late 

1970s], but dosimeters were worn at all times. There was less understanding on low radiation 

level safety, but over time, improvements were made. The company made improvements over 

time, but was never lax in safety.

[When asked if work areas, machines, or sources were posted or labeled as radioactive], an 

interviewee recalled that doors on the secured area were marked, and the worker does remember 

seeing radiation signs in areas. [The worker was employed at KCP over 30 years.] Another 

interviewee recalls radioactive signs on the door of Department 22 and also on the barrels.

Telemetry work areas, machines, or sources are posted or labeled as radioactive. A barrier chain 

and the yellow/magenta stripe are used as work zone controls. Two interviewees [whose 

employment dates from the 1970s] said, in their experience, radioactive materials have always 

been labeled appropriately. An interviewee is not aware of any time when labeling was not used. 

There was always an exclusion area [posted] with the signs, perhaps marked with a chain. The 

worker would need to sign an RWA periodically.

Workers [from radiological machining areas] recalled that clothing was provided, including 

shoes. Shoes were painted red or orange on the toes to clearly designate shoes not to be worn 

outside the work areas. The KCP-issued clothes were to be worn within the plant. There was a 

clothes change room with a shower. Workers showered before going home. There were lowlevel positive GM [Geiger-Muller] readings on clothing [in Department 22], but these clothes 

were changed prior to leaving; workers changed coveralls before they went to lunch. Showers 

were taken at the end of each shift.

An interviewee said that eating was done in the clothes change area and not in the work area. 

The worker remembers going to a cafeteria for meals. The worker’s hat and marked shoes were 

most likely left in the change area upon egress. The worker smoked at that time, but believes 

this was done in the change area only. Another worker recalled there was no drinking, eating or 

smoking in the Department 22 work area. For example, you could go out to get a cup of coffee, 

but you could not return to the work area with the coffee.

[When asked if eating/drinking was allowed in the work area where radioactive materials were 

handled, a Telemetry worker said], “Absolutely not.” Another worker [with experience in 

Telemetry and Testing areas] indicated that it was acceptable to smoke in the radiation area in 
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the earlier years. The interviewee said they were allowed to drink, eat, and smoke until a few 

years ago (i.e., such as with the barium bolt). Another Telemetry worker recalled that there may 

have been a time when food was allowed; however, there is concern that food/drink could affect 

the devices, so this is discouraged. The interviewee does not know when changes were made.

[A worker who was not assigned to radiological areas] said there were vending machines in the 

work area with snacks and drinks. The general consensus was that you could eat, drink, and 

smoke. Another worker [who is not aware of handling radioactive materials] also recalls 

workers smoked and ate at the work place so as to continue production and not have time to 

congregate.

Although [an unmonitored] worker observed that other workers changed clothes down to 

underwear, the worker personally did not shower or change clothes before going home.

Honeywell employees had their own cafeteria; Department of Defense and U.S. Marine Corps 

employees shared a different facility. An interviewee saw other workers who came to the 

cafeteria in their work coveralls. There were two cafeterias on the DOE side, one in GSA area, 

and one in IRS area.

Personal Protective Equipment (PPE)

A worker from the machine area remembers wearing canvas shoe covers. The worker also 

remembered using respirators on occasion, but does not recall the time period or the work 

activity. The worker was checked out to use a respirator, but it was hard to breathe while using 

one.

There were about five workers per shift in Department 22. Some workers, such as engineers, 

could enter the area, but they were required to wear the shoe booties so they did not track residue 

outside the area.

Respirators, gloves, and other PPE are often used for chemical safety purposes rather than for 

radiation work. For example, workers involved in the potting shop (handling a two-part 

chemical mixture) wear respirators.

An interviewee has used safety glasses. Another interviewee recalls using safety glasses and 

“paper lab coats that were not very good.”

Surveillances

An interviewee recalls cleaning up black powder residue in the machining area, but there was 

little support. The worker recalls using a Geiger counter to check general radiation levels. 

Cleaning was done primarily using a brush and a dust pan. The residue was primarily a black 

dust-like material. The dust was disposed into a bag inside a barrel. The barrels were sealed and 

removed when full. The material was U-235 for the machined parts. Interviewees were not 

aware of air sampling in the work area.
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A machine area worker remembers using a GM counter to check that tools were cleaned before 

turning them into the tool crib. The worker does not recall using the GM to self-check for 

personal contamination. Another worker recalls [self-survey] only at the end of a shift following 

removal of the outer clothing; the interviewee does not recall detecting any remaining 

contamination on skin.

A worker [who did not have a dosimetry badge] was never evaluated for skin contamination. 

The worker never used survey equipment to check for contamination on skin or clothing. The 

worker [does not believe skin rashes were handled appropriately]. The onsite medical officer 

issued [cortisone] cream to apply to the rash [rather than investigating potential causes].

Radiation Safety is responsible for any radiological shipments coming or going. [A worker 

involved with incoming and outgoing shipments] did not conduct surveys; the worker recalls 

occasions when health and safety did a survey.

Neutron probe testers are used to check the neutron generator output. Health Physics swipes 

neutron probe test units for contamination. Swipes are done when any generator is changed—

upon entry into the plant and also prior to shipment. Maintenance technicians receive these 

shipments; shipping containers are not opened until health physics is present.

[When asked about practices related to decontaminating, decommissioning, or surveying areas 

where radioactive materials had been handled in the past], an interviewee does not know and is 

“waiting to get this information from the company today.” [KCP personnel indicated] swiping 

and frisking surveys are performed. DOE 5400.5, and currently a new order number with the 

same criteria table, [establishes release criteria] for unrestricted use.

Interviewees were generally not aware of air sampling for radioactive material in their work 

areas. Some interviewees indicated air monitoring is not done for radiation, but chemical air 

sampling is used for certain projects. Air sampling was done after 2002 for a beryllium study.

One interviewee indicated that an area of 230,000 square feet of GSA space occupied by NNSA 

was contaminated [possibly with beryllium] and not cleaned for 8 years. GSA PBS [Public 

Buildings Service] Region 6 was prevented [by red tape] from ridding itself of this 

contamination. [SC&A is not certain if the interviewee was referring to beryllium contamination 

or radiological contamination.]

EXTERNAL MONITORING

[The interviewees, collectively, provided their characterization of how external monitoring was 

performed at KCP, as follows.]

Workers were aware that Department 22 involved radiation, and they were issued film 

dosimeters while working in Department 22. An interviewee had a security badge that stayed 

with the worker all the time. There were dosimeters on a board that were taken upon entry into 

the Department 22 area. An interviewee does not recall anyone receiving a positive dosimeter 

reading.
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[A worker] remembered wearing a pencil dosimeter, [and seeing other workers wearing them] 

sometimes. The worker does not remember wearing a film badge.

An interviewee entered areas where other workers wore dosimeter badges and/or special safety 

equipment. No one assigned to work in an interviewee’s shop had dosimeter badges.

There have been changes in monitoring practices over the years, primarily in consideration of the 

technology that is currently available. Dosimeters have changed over time, as well as the 

exchange period. Telemetry workers said dosimeters are currently exchanged every 6 months. 

An interviewee recalls the exchange period changing from monthly to every 6 months. There are 

lists of neutron workers who are issued a neutron dosimeter. An interviewee is aware of ring 

dosimeters used at one time for handling the barium bolts, but this is not the worker’s area of 

responsibility.

NIOSH mentioned a letter discovered in 1995 describing personal neutron monitors in Telemetry 

in which the phantom neutron dosimeters showed an unexpected increase in the neutron dose. 

The increase was such that assignment of personal dosimeters was reinstated. [Radiation Safety 

staff] thought this may have been attributed to transfer of work from Pinellas that resulted in 

greater neutron doses. These workers still have assigned neutron dosimeters. There was a time 

in which there was emphasis on reducing the number of assigned dosimeters to workers who do 

not exceed 100 mrem per year.

[Interviewees who worked in Telemetry] do not recall any time in which neutron dosimeters 

were not used in the Telemetry radiation area. An interviewee was not familiar with a situation 

in 1995 regarding re-assigning neutron dosimeters to workers based on readings from the 

ambient phantom dosimeters.

An interviewee [who is monitored for neutrons] has not witnessed anyone in a radiation area 

who was not wearing a dosimeter. If this situation had occurred, the worker would stop [the 

person without appropriate dosimetry] from entering the area.

ALARA [As Low As Reasonably Achievable] is emphasized at the plant. A Telemetry worker’s 

reported doses are generally zero. The interviewee recalled one unusual incident in which the 

storage location of the sealed sources was moved near where the dosimeters were stored, and this 

was detected by the dosimeters.

The question of potential exposure of GSA employees on the roof was raised. An interviewee 

stated that neutron radiation from the neutron testers would have to pass through the first floor 

and then the second floor prior to arriving at the roof where GSA employees may be present. 

KCP has monitoring data for workers within about 3 feet from these sources. The dose to any 

workers on the roof would be exceedingly small.
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INTERNAL MONITORING

[The interviewees, collectively, provided their characterization of how internal monitoring was 

performed at KCP, as follows.]

Workers from Department 22 received periodic urinalysis [estimated 30–90 day intervals]. One 

interviewee did not have knowledge of participation in a urine bioassay program, recalling that 

urinalysis was part of a routine physical. Another worker was aware of urine bioassay, but does 

not recall receiving any urinalysis results; the worker does not recall if urinalysis was done upon 

completing work in Department 22.

INCIDENTS AND ACCIDENTS 

[The interviewees, collectively, provided their recollection and understanding of what incidents 

occurred at KCP, and how they were handled and documented, as follows.]

An interviewee recalls hearing of fires in the machining area, but did not personally witness any 

fires. The worker remembers a follow-up to a fire in Department 22 in which the ceiling piping 

was highly rusted or corroded. Even the tops of the cabinets were “rusty.” Another interviewee 

does not recall any fires in the Department 22 machining area.

An interviewee was involved in the Pm-147 cleanup. They used protective equipment in doing 

this work, such as laboratory clothes and perhaps a hood. The worker had a film dosimeter. The 

worker [who was at KCP for over 30 years] did not remember any other incidents. The worker 

recalled using a respirator during the Pm-147 cleanup. The respirator was a full face unit 

referred to as a “moon face.”

[On one occasion], contamination (unusual black powder) was discovered on the surface of 

product returned to KCP [after] a flight test. Bioassay was performed; results were negative. 

There should be documentation available from Health Physics for this incident.3The 

interviewee is not aware of another problem of this type [having occurred]. There was an 

investigation of a potentially leaking generator, but no contamination was found.

An interviewee heard there was detection of contamination on a swipe sample [from neutron 

generator surveillance] many years ago. The interviewee was not personally involved and did

not know details of the event.

On one occasion, [non-rad workers] at the model shop received and opened a box [apparently 

delivered to their area in error]. After removing the packaging and “a small unit,” they found a 

red label at the bottom of the box saying “RADIOACTIVE MATERIAL INSIDE.” The 

interviewee took the box to the ES&H [Environmental Safety and Health] Director. The worker 

never heard anything more about the incident.

 

3 A safety department investigation report (Krueger and Meunier 1987) independently documents the 

occurrence described by the interviewee.
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A [redacted] was assigned to a job outside the Model Shop. It was a special job: the Model 

Shop supervisor [interviewee] was involved in setting up the work area in an outside department, 

clearing the set-up through safety, getting the set-up functioning, and setting up screening to 

close in the machining process. Shortly after the job was completed, the [redacted] it 

[redacted]. Soon after that, Industrial Hygiene (IH) staff came to the Model Shop and wanted to 

speak with [redacted] about possible contamination of the machined parts. When [redacted]

returned to work, the IH staff member came to the shop with [redacted] other people to question 

[redacted]. The supervisor asked about the source of the suspected contamination but was not 

told. The supervisor was not observed or monitored for the substances that may have affected 

the [redacted]. The supervisor wrote a memo about the incident, but the [KCP management] 

person who received it was not interested in following up.

There was a glovebox explosion that apparently involved lead, but not radiation. An 

interviewee recalls this incident was documented.

[Nearby but offsite] explosions in the 1990s shook the building, dropping all sorts of debris and 

dust that was cleaned up by workers in respective work areas.

The KCP interviewees were not aware of any building evacuations other than for tests.

WASTE MANAGEMENT & ENVIRONMENTAL MONITORING

[The interviewees, collectively, provided their characterization of waste management and 

environmental monitoring practices at KCP, as follows.]

[A worker in Department 22] was not responsible for handling waste. Someone else would 

remove the material from the work areas.

About 1982, they were digging up the parking lot East of Building 41. [An interviewee recalls] 

dump trucks were removing soil all night for 4–5 weeks.

An interviewee [who had responsibility for incoming and outgoing] shipments initially did not 

recall shipping any waste offsite. The worker subsequently mentioned a vague recollection of 

classified waste shipments to Los Alamos. The worker remembers there being little waste. 

There was one barrel in a secured, controlled access area near the upstairs test cells. The worker 

handled incoming radioactive shipments by placing the material into a secured container. [When 

asked about direct handling of radioactive material, the worker said], probably not, but there may 

have been some in the waste, such as the tritiated exit signs. [Typically], everything was 

packaged, and the worker placed the packages into drums. The worker does recall thallium 

liquid and solid waste being stored. [When asked about a project that used uranium oxide in a 

powder form], the worker thought there may have been some material in the waste.

The current waste management group (3 years ago) handles shipments and RCRA [Resource 

Conservation and Recovery Act]. ES&H record keeping is archived.

[When asked about field and environmental characterization data, Radiation Safety staff 

recalled] an incident involving the recovery of radioactive waste on the north side of KCP. Since 
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KCP does not have any routine emissions or waste production, there is limited characterization 

activity that the interviewee can recall.

[Workers in several areas were involved in chemical waste disposal.] These areas include the 

Plating Shop, Paint Shop, RTV, and Chemical Stores. An interviewee kept a log of source 

materials, such as paint, used in the work area. In the 1990s, an interviewee was involved in 

collection of VOC [volatile organic compound] data. [An individual] was in charge of VOC 

records for the plant. Another interviewee was involved in cleaning up spills of materials such 

as sealants and glue. They used vermiculite. Waste from the cleanup was taken to the landfill. 

The interviewee does not recall specific incidents, but everything was a big deal after 2002. 

Sometimes NNSA would evacuate the building because of odors.

[An advocate] has documents regarding the chemical inventory and environmental test results for 

Building 41.

MEDICAL X-RAY EXAMINATIONS

[The interviewees, collectively, provided their recollections of the x-ray examinations at KCP, as 

follows.]

[An interviewee whose employment dated back to the late 1950s] recalled receiving a physical 

about every 90 days from an in-house medical organization. The interviewee thought this was a 

full physical to include an x-ray and urinalysis.

RADIOLOGICAL RECORDS

[The interviewees, collectively, provided knowledge of their understanding of the completeness 

and adequacy of radiological and medical records, as follows.]

A Microsoft Access® database contains KCP dose history since 1949. Radiation Safety 

personnel hired sub-contractors through a temp agency to enter the internal and external 

dosimetry data for each worker who had hard copy records. Some work was performed by a 

KCP administrative staff member. Since the employee dose history database entry was 

contracted out, Radiation Safety staff set up a QA [Quality Assurance]/QC [Quality Control] 

system and documented audits performed on the database entries.

An annual rems report is sent to DOE each year. Radiation Safety staff also maintains a wholebody dose history report that could be useful. There are also the area dosimeter data for 

Telemetry and other areas that may be of interest. The data are primarily for x-ray departments.

The following supplemental documents received from interviewees have been added to the 

SRDB:

 Memorandum regarding internal monitoring for personnel working with DU (Runkle 

1997)

 Radiation data for neutron area – phantom badge dose at neutron tube (Nasca 2013a)
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 Radiation data for neutron area – phantom badge dose at x-ray tube (Nasca 2013b) 

 KCP personnel dosimetry history – annual whole body external dose (Honeywell 2013) 

MISCELLANEOUS COMMENTS 

[The interviewees, collectively, provided additional comments they wished to include in the 

summary for consideration, as follows.] 

Interviewee(s) concerns regarding non-radiological and non-DOE worker occupational health: 

[A 1960s-era worker] recalled some activity involving carbon tetrachloride at KCP. The worker 

recalls that beryllium was their favorite metal with which to machine. [An interviewee who was 

employed into the 1990s] remembered some industrial type accidents and has participated in the 

5-year testing cycle for berylliosis. Another interviewee and a coworker machined 99% pure 

beryllium in the lab-model building. When the lab-model shop was shut down, they cleaned it 

up.

[An interviewee raised concerns regarding the general safety culture at the site. The interviewee 

recalled a 1996–1997 memo from Karen Clegg, President of Allied Signal that said] the attitude 

on safety was “Cavileer” [sic].4

President Bill Clinton stated that safety was lax; production was 

the goal. Employees’ participation in matters of safety was resisted, as seen when TQM (Total 

Quality Management) was introduced—about 1986. Some TQM efforts were suspended (model 

shop, tool room) when employees insisted on aiding with workplace safety suggestions. The 

interviewee indicated personnel records in HR [Human Resources] [as sources to support this 

statement]. 

NBC Action News investigated conditions at KCP. They reported that falsehoods as to 

conditions at the plant were made to five federal agencies by the plant. Meeting minutes of the 

Community Advisory Panel indicate employees are afraid to report anything that occurred 

related to accidents, incidents, and injuries. The St. Louis Post-Dispatch last month revealed a 

1950s release of a “smoke screen” of contamination over populated areas.5

Other interviewees stated the organization has a high focus on safety that has improved over time. 

An interviewee noted there was definite improvement [in the overall safety program] over the 

years. With a Department of Health & Safety [in the early 1990s], the improvement was 

tremendous. The worker was not aware of any deficiencies. Another interviewee stated safety 

has always been a prime area of concern; [the approach included] more proactive activities with 

the arrival of the Voluntary Protection Program. 

 

4

 Interviewee did not have a copy of the memo available. The date was estimated based on interviewee’s 

recollection. 

5

SC&A located an article online that appears to be consistent with interviewee’s description (Mann 2012). 

This article is not directly related to KCP or Kansas City; it appears to illustrate the worker’s concern regarding 

government failure to disclose hazards associated with weapons development to affected individuals. 
Effective Date:

November 14, 2013

Revision No.

1 (Draft)

Document No.

SCA-TR-SP2012-0006

Page No.

58 of 58

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.

An interviewee observed, “It is human nature to anticipate there may be unknown issues; 

however, I have never experienced that the company has kept anything from me that would be 

potentially harmful.”

[In regard to non-radiological but general safety culture, a GSA worker expressed significant 

concern regarding beryllium exposure, protections, and medical surveillance.] The GSA PBS 

Region 6 occupational focus centered on asbestos ingestion, and GSA did not furnish safety 

equipment until the Federal Labor Relations Authority’s 1991 decision forced GSA to pay for 

Hazardous Duty Risk. [GSA initiated a medical surveillance program in 1985.] In 1988, 1989, 

and 1990, several maintenance workers had positive findings, including [redacted]. In 1991, a 

different pulmonary specialist assessed the [redacted] x-rays as negative. Since x-ray readings 

and disease symptoms are essentially the same for beryllium and asbestos [exposure], PBS chose 

to accept the 1991 readings to be negative. They did complete physicals and chest x-rays that 

identified medical issues and then killed the program. The interviewee has not been satisfied 

with GSA’s response to requests to resolve the conflicting medical opinions. The interviewee 

provided supplemental documentation regarding the medical surveillance program and [redacted]

efforts to obtain resolution of conflicting medical opinions.] GSA Inspector General investigated 

from 1999 on and found GSA without credibility regarding its Safety and Health federal 

requirements. These earlier years of improper Safety and Health should also be exposed for the 

GSA employees, especially those who provided maintenance in contaminated areas.