Rev. 01 UNC Petitioner Issues 11-03-11 

White Paper: 

SEC-00116 United Nuclear Corporation Petitioner Issues 

By: 

Ray Clark 

1. Introduction and Purpose 

United Nuclear Corporation (UNC), located in Hematite, Missouri, manufactured uranium 

metal and uranium metal compounds from natural and enriched uranium for use as nuclear 

fuel. The facility became operational in 1956, initially producing uranium products for use in 

the naval fuel program. Specifically, the site was used to convert government-owned and 

leased uranium hexafluoride (UF6) gas of various uranium-235 (U-235) enrichments to 

uranium oxide, uranium carbide, uranium dioxide pellets, and uranium metal. These 

products were manufactured for use by the federal government and government contractors 

and by commercial and research reactors approved by the Atomic Energy Commission 

(AEC). Research and development was also conducted at the site, as were uranium scrap 

recovery processes (Site Assessment, 2005, pdf p. 16). 

This white paper addresses the specific issues raised by the petitioners regarding those items 

not addressed in the body of the SEC-00116 UNC Evaluation Report (NIOSH, 2010). 

2. Background 

From its inception in 1956 through 1974, the Hematite facility was used primarily in support 

of government contracts that required production of high-enriched uranium (HEU) products. 

From 1974 through the plant closure in 2001, the focus was on commercial fuel production 

(Decommissioning Plan, 2005, pdf p. 16). The Hematite plant used enriched uranium 

derived in part from recycled fuel, resulting in the potential for the presence of trace amounts 

of transuranic radionuclides, neptunium-237 (Np-237), plutonium-239/plutonium-240 

(Pu-239/240), and americium-241 (Am-241) (Hard-To-Detect Radionuclides, 2009, pdf p. 

10). For an approximately nine-month period in 1964, UNC also blended thorium dioxide 

powder with uranium dioxide powder to produce fuel pellets for use in fuel assemblies for 

the Elk River Reactor (Pellet Plant Data, 1964; Swallow, 1963; Swallow, 1964a). 

The primary source of the internal radiation exposure was deposition of alpha-emitting 

materials via inhalation and ingestion of airborne uranium and thorium (and progeny). 

Operations at the UNC-Hematite facility potentially would have resulted in external 

exposures primarily to uranium and uranium decay products. 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

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Rev. 01 UNC Petitioner Issues 11-03-11 

3. Petitioner Issues 

Issue 1: Recycled uranium may have been processed at the site. Therefore, it is suspected 

that some of the enriched uranium trucked into the Hematite plant may have contained 

neptunium, plutonium, and other transuranics as well as fission products, including 

technetium-99. 

Response 1: NIOSH recognizes that recycled uranium was processed at the site and that 

there exists the potential for intakes of transuranic radionuclides, neptunium and plutonium, 

as well as technicium-99. Intakes of these contaminants found in recycled uranium can be 

estimated by using uranium bioassay data and assuming ratios for the contaminants present. 

Details of this approach are described in ORAUT -OTIB-0004. NIOSH has evaluated site 

sampling and analysis data to ensure that application of the contaminant ratios presented in 

ORAUT-OTIB-0004, relative to uranium, will result in bounding and claimant-favorable 

dose estimates for UNC workers. This evaluation has been documented in a recent NIOSH 

white paper entitled Exposure to Transuranics from Recycled Uranium Buried at United 

Nuclear Corporation. 

Issue 2: Many of the workers at the Hematite site worked bare-handed without proper 

protective masks, clothing, gloves, and other protective equipment, etc. 

Response 2: Dose reconstructions for this site are based on internal and external dosimetry 

data. Site workers were issued external radiation monitoring devices (e.g., film badges); 

internal dose reconstructions are based on internal monitoring (e.g., urine bioassay data). 

Issue 3: The petition quotes the following statement from a NIOSH Report of Dose 

Reconstruction: 

Even in instances when radiation dosimetry data are available, they rarely specify dose to 

an organ and are often based on monitoring procedures that do not meet modern 

standards. 

Response 3: This quotation was taken from boilerplate language included in the introduction 

section of all NIOSH dose reconstruction reports. The introduction section is provided to 

explain why dose reconstructions are necessary. For example, if an applicant submits a claim 

for lung cancer, NIOSH must consider all available dosimetry and other available 

information to estimate the radiation dose to the lung. NIOSH must also consider the 

monitoring limitations and account for dose that could have been missed by monitoring. 

Issue 4: The workers at the Hematite site were also exposed non-radioactive substances, 

such as strong mineral acids (hydrochloric, hydrofluoric, and nitric) and extremely hazardous 

volatile organic chemicals, including but not limited to trichloroethylene, perchloroethylene, 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

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Rev. 01 UNC Petitioner Issues 11-03-11 

and other volatile organic chemicals that were sometimes used as cleaning agents to mop the 

shop floors. 

Response 4: Although NIOSH does not dispute that chemical exposures may have occurred 

at the site, cancers due to chemical exposures are not covered by the EEOICPA program. 

Issue 5: Workers often wore their work clothes home, thus contaminating their homes and 

families. 

Response 5: In interviews conducted with two recently-retired managers (employed 

[redacted] and [redacted], respectively), both stated that workers were required to shower 

before leaving the plant and were monitored with Geiger counters after the showers (Personal 

Communication, 2009a; Personal Communication, 2009c). NIOSH has found other evidence 

that personnel monitoring for contamination was performed on workers prior to exiting the 

plant. Affidavits provided with the petition also confirm this. In any case, NIOSH does not 

dispute that workers could have brought some contamination home with them at times. Dose 

reconstructions at this site are based on internal and external dosimetry data. Internal dose to 

workers due to the presence of contamination at their homes is accounted for with bioassay 

measurements. Family members who may have received radiation dose from contamination 

at home are not covered by the EEOICPA program. 

Issue 6: Although the Hematite site is designated as an Atomic Weapons Employer (AWE) 

facility and not a Beryllium Employer (BE), beryllium was present at the Hematite site. The 

petitioners request that the Department of Energy and the Department of Labor add a BE 

designation to the present classification. 

Response 6: Facility designations for beryllium are not determined by NIOSH. Although 

beryllium is covered under the EEOICPA, NIOSH only conducts occupational radiation dose 

reconstructions for compensation under The Act. 

Issue 7: A limited amount of work with thorium compounds was performed at the facility as 

part of early research into the use of thorium in the fuel cycle. 

Response 7: NIOSH recognizes that thorium was processed at the site during a well-defined 

period of time in 1964, and that the potential for thorium intakes existed as a result of those 

operations. A method for bounding thorium intakes, based on air monitoring data, is 

described in the NIOSH technical basis document for UNC, DCAS-TKBS-0008. NIOSH has 

also evaluated the representativeness of the available air monitoring data in a recent white 

paper entitled Representativeness and Applicability of United Nuclear Corporation Air 

Sampling for Reconstructing Thorium Intakes. 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

Page 3 of 8 
 

 

 

 

Rev. 01 UNC Petitioner Issues 11-03-11 

Issue 8: According to the petition: One cold night when all skilled plant personnel was 

scheduled off, a criticality occurred. Apparently an anhydrous ammonia tank had leaked. 

Response 8: The “criticality” mentioned appears to have been a toxic chemical spill and not 

a nuclear criticality. A criticality event did occur at a United Nuclear site in Wood River 

Junction, Rhode Island (Wood River Incident, 1964). However, NIOSH has not found any 

evidence or indications of a criticality accident ever occurring at the Hematite site. 

Compensation for exposure to toxic chemicals is not authorized under the EEOICPA. 

Issue 9: No site profile of the Hematite facility has been performed. 

Response 9: Although a site profile is not a prerequisite for the performance of dose 

reconstruction, NIOSH developed DCAS-TKBS-0008, Technical Basis Document for the 

United Nuclear Corporation Hematite, Missouri, which provides a site profile for 

UNC-Hematite. 

Issue 10: The employees did not receive routine internal monitoring such as bioassays, 

blood samples, and breath tests. 

Response 10: During the AWE operational period for UNC-Hematite (1958 through 1973), 

workers were monitored by bioassay and required to submit urinalysis samples on a specified 

frequency (ranging from monthly to every three-to-six months, depending on job assignment 

and year). Although the bioassay program was discontinued in 1961, air sampling continued 

in both process and non-process areas and the data were evaluated by the site for potential 

internal doses. A routine bioassay program was re-instituted in December 1962 (UNC In 

Vivo, 1963-1965). Examples of existing internal data are in the following documents (listed 

in detail in the References section): 

Reference SRDB Ref ID Reference SRDB Ref ID 

Bioassay Results, 1964 62390 In Vivo Counts, 1967-73 62419 

Bioassay Results, 1965 62386 Special Bioassay, 1970 62373 

Bioassay Results, 1966 62383 UNC urinalysis, 1962-1964 11713 

Bioassay Results, 1967 62381 UNC urinalysis, 1963-1964 11714 

Bioassay Results, 1968 62379 Various Authors, 1963 11724 

Bioassay Results, 1969 62377 Whole Body, 1969 62334 

HP Standards, 1968 62363 Whole Body Counts, 1968-73 62412 

In Vivo and Bioassay, 1960s 62338 Whole Body Issues, 1968-69 62429 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

Page 4 of 8 
 

 

 

Rev. 01 UNC Petitioner Issues 11-03-11 

Issue 11: The former Atomic Energy Commission, the Department of Energy, the Nuclear 

Regulatory Commission, nor NIOSH has thorough personnel monitoring data. As far as we 

know, NO Hematite personnel radiation dose records have been provided to NIOSH and 

possibly do not exist. 

Response 11: NIOSH has obtained bioassay, air sampling, and external dosimetry data in 

sufficient quantity and quality to adequately represent internal and external dose for the 

UNC-Hematite class under evaluation over the entire operational period (see Sections 6.1, 

6.2, and 6.3 of the UNC Evaluation Report) (NIOSH, 2010). These data can also be used to 

support the evaluation of the UNC-Hematite external dose over the site’s Residual Radiation 

period. See Response 10 for a list of documents containing internal data. 

Issue 12: Initial plans for decommissioning the site were being made in 1973. However, the 

site was not dismantled; instead, it remained active as a commercial manufacturer until 2000 

without a proper decommissioning. Residual contamination is evidently present and just as 

radioactive today. 

Response 12: NIOSH understands that the site has remained operational after 1973 and that 

residual contamination has persisted at the site throughout the Residual Radiation period. 

The site is designated an AWE site from 1958-1973; the Residual Radiation period is from 

1974 through October 2009. Knowledge of the AEC process operations performed during 

the operational period, and the available data for the associated timeframes, support NIOSH’s 

ability to reconstruct dose during the Residual Radiation period at the site. For the UNCHematite residual period, only the personnel exposures to AEC-related residual radioactivity 

are assessed. This topic is discussed further in Sections 7.2.2 and 7.3.2 of the UNC 

Evaluation Report (NIOSH, 2010). 

Issue 13: A report sent from Westinghouse dated November 14, 2006 that includes an 

"alleged" bioassay of [name redacted] could, in fact, be a falsified document. (Exposure 

Data, 2006) 

Response 13: An affidavit provided in the petition (NIOSH, 2010) states: 

At the end of each work week I took home a specimen bottle, which I returned at the 

beginning of the next work week with a urine sample. 

A second affidavit provided in the petition states there were: 

...no breath tests [or] internal monitoring. [I] did have urine test[s]. [I] had whole body 

counts yearly. 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

Page 5 of 8 
 

 

 

Rev. 01 UNC Petitioner Issues 11-03-11 

Both of these petitioners’ periods of employment encompassed the period of the petitioner 

cited in Issue 12 and their statements show that a monitoring program did exist. 

Based on its review and assessment of the available data in the SRDB and in NOCTS, 

NIOSH has not found evidence that would corroborate the petitioner’s claim of falsified or 

destroyed personnel monitoring records. During data capture visits to the Hematite site in 

March and April 2009, NIOSH verified that hundreds of records boxes and other data files 

were present in multiple on-site locations and maintained under appropriate document 

control procedures, including key access and Westinghouse administrator control. 

4. References 

Bioassay Results, 1964, Various handwritten bioassay results for Hematite workers; United 

Nuclear Corporation; 1964; SRDB Ref ID: 62390 

Bioassay Results, 1965, Various handwritten bioassay results for Hematite workers; United 

Nuclear Corporation; 1965; SRDB Ref ID: 62386 

Bioassay Results, 1966, Various handwritten bioassay results for Hematite workers; United 

Nuclear Corporation; 1966; SRDB Ref ID: 62383 

Bioassay Results, 1967, Various handwritten bioassay results for Hematite workers; United 

Nuclear Corporation; 1967; SRDB Ref ID: 62381 

Bioassay Results, 1968, Various handwritten bioassay results for Hematite workers; United 

Nuclear Corporation; 1968; SRDB Ref ID: 62379 

Bioassay Results, 1969, Various handwritten bioassay results for Hematite workers; United 

Nuclear Corporation; 1969; SRDB Ref ID: 62377 

DCAS-TKBS-0008, Technical Basis Document for the United Nuclear Corporation, 

Hematite, Missouri, Rev. 0; National Institute for Occupational Safety and Health (NIOSH), 

Division of Compensation Analysis and Support; March 21, 201l; SRDB Ref ID: 93712 

Decommissioning Plan, 2005, Hematite Decommissioning Plan, DO-04-004, Rev. 2; 

Westinghouse; August 2005; SRDB 56413 

Exposure Data, 2006, Exposure Data for [Name redacted], Westinghouse; letter from J. A. 

Buddie (Westinghouse) to R. Thogmartin (U.S. Dept. of Labor) with attached 1972 letter 

from Gulf United Nuclear Fuels Corporation; November 14, 2006; SRDB Ref ID: 102230 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

Page 6 of 8 
 

 

 

Rev. 01 UNC Petitioner Issues 11-03-11 

Hard-To-Detect Radionuclides, 2009, Derivation of Surrogates and Scaling Factors for 

Hard-To-Detect Radionuclides, DO-08-008, Rev. 0; Westinghouse; July 2009; SRDB 78741 

HP Standards, 1968, H. P. Standards (Manual), interoffice memo with Health Physics 

Standards from L. J. Swallow to D. G. Darr; United Nuclear Corporation; August 12, 1968; 

SRDB Ref ID: 62363 

In Vivo and Bioassay, 1960s, Various Personnel Selected for Whole-Body Counting Based 

on Urinalysis Results; United Nuclear Corporation; various dates in the 1960s; SRDB Ref 

ID: 62338 

In Vivo Counts, 1967-73, In-Vivo Count Results (ugm U-235), United Nuclear Corporation; 

1973; SRDB Ref ID: 62419 

NIOSH, 2010, SEC Petition Evaluation Report for Petition SEC-00116, United Nuclear 

Corporation; National Institute for Occupational Safety and Health (NIOSH); January 28, 

2010; SRDB Ref ID: 101606 

ORAUT -OTIB-0004, Estimating the Maximum Plausible Dose to Workers at Atomic 

Weapons Employer Facilities, Rev. 03 PC-2, Oak Ridge Associated Universities; December 

6, 2006; SRDB Ref ID: 36191 

Pellet Plant Data, 1964, Pellet Plant Station Alpha Activity Data Sheets, United Nuclear 

Company; various dates throughout 1964; SRDB Ref ID: 62343 

Personal Communication, 2009a, Personal Communication with [redacted] (various titles); 

Telephone Interview by ORAU Team and NIOSH; February 4, 2009; SRDB Ref ID: 61673 

Personal Communication, 2009c, Personal Communication with [redacted] (various titles); 

Telephone Interview by ORAU and NIOSH Team; February 12, 2009; SRDB Ref ID: 61676 

SEC-00116 Petition, 2008, Special Exposure Cohort Petition, Hematite Site, State of 

Missouri, June 13, 2008, [petitioner names redacted], SEC Form B petition with supporting 

documents; received by NIOSH June 19, 2008; OSA Ref Id: 106292 

Site Assessment, 2005, Historical Site Assessment, Hematite Former Fuel Cycle Facility 

Decommissioning, Westinghouse Electric Company LLC; 2005; SRDB Ref ID: 56469 

Special Bioassay, 1970, Bio-Assay Special Issue Log, United Nuclear Corporation, 1970; 

SRDB Ref ID: 62373 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

Page 7 of 8 
 

 

 

Rev. 01 UNC Petitioner Issues 11-03-11 

Swallow, 1963, Health Physics Problems Associated with Thoria, correspondence to A. 

Edelmann (Nuclear Science & Engineering); October 31, 1963; SRDB Ref ID: 62315 

Swallow, 1964, SNM-33 Amendment to Permit Blending Fully Enriched UO2 with Natural 

ThO2 in the Pellet Plant, correspondence to Mr. Donald Nussbaumer (U.S. Atomic Energy 

Commission); March 31, 1964; SRDB Ref ID: 56730 

UNC In Vivo, 1963-1965, In Vivo Monitoring Data Results and Correspondence for 8-19-63 

to 8-25-65; SRDB Ref ID: 17041 

UNC Urinalysis, 1962-1964, UNC Uranium in Urine Sample Results for 12-3-62 to 1-24-64; 

SRDB Ref ID: 11713 

UNC Urinalysis, 1963-1964, UNC Uranium in Urine Sample Results for 6-14-63 to 1-4-64; 

SRDB Ref ID: 11714 

Various authors, 1963, UNC Bioassay Program Information and Some Results for 4-19-63 to 

11-4-63; various authors; SRDB Ref ID: 11724 

Whole Body, 1969, Whole Body Counting Results; interoffice memo from D. G. Darr to L. 

J. Swallow; United Nuclear Corporation; March 13, 1969; SRDB Ref ID: 62334 

Whole Body Counts, 1968-73, Results of Hematite Whole Body Counts, memos and results, 

United Nuclear Corporation; various dates; SRDB Ref ID: 62412 

Whole Body Issues, 1968-69, Various documents related to whole body counting parameters, 

results, job re-assignments, personnel restrictions, United Nuclear Corporation; 1968-1969; 

SRDB Ref ID: 62429 

Wood River Incident, 1964, Report of the AEC Technical Review Committee on the 

Criticality Incident of July 24, 1964, at the Wood River Junction, Rhode Island, Plant of the 

United Nuclear Corporation; report written November 6, 1964; SRDB Ref ID: 4533 

This is a working document prepared by NIOSH or its contractor for use in discussions with the ABRWH or its 

Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH 

or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This 

document represents preliminary positions taken on technical issues prepared by NIOSH or its contractor. 

Page 8 of 8