DRAFT 

The following cross references are intended to support the NMI SEC Petition application 

sections E5, F1 and F2, for the years 1970 – 1983. We have been requested to describe 

specific dates and plant locations for unplanned and unmonitored activities that resulted 

in exposure of NMI employees to radiation contamination. In an attempt to comply with 

this request, we do not wish this response to replace the many exposure incidents or poor 

safety practices described in the various affidavits. The affidavits further provide 

evidence of general safety practices that were inadequate and management decisions and 

behavior that introduced additional safety risks. 

After more than 40 years it is difficult to be specific as to dates. We have tried to 

reference published technical reports, internal reports and memos, where available, to 

bracket time periods. 

A number of employees have since passed away. These include 

with whom worked, and , 

during the period 1978 to 1980s. was a 

who has passed away. 

, co-petitioner, was in the 1978 – 1983 time frame. 

 was assigned to support his staff efforts to 

. Many of his activities and exposures can be 

confirmed by him. Indeed, he was also exposed to many of the same unmonitored 

exposures. 

Incidents for unmonitored exposures can be characterized as both discrete, or chronic and 

daily. Discrete incidents may be associated with unique experiments and may number 

from one to a dozen, or more separate exposures. These exposures could be limited to 

one or several, depending upon the type of work and length of time the experiments were 

conducted. Chronic and daily exposures may be associated with standard operating 

procedures, such as drinking from Gatorade stations in process areas. 

As for the lost records requirements of Section F2 of the application, NIOSH has a better 

feel for this deficiency than the petitioners. The petitioners are aware that in many of the 

claims that have been submitted there are large gaps in the records of exposure. NIOSH 

should be able to review the limited number of NMI claims to assess the degree to which 

records are unavailable. For the time period of this petition, there appears to be a 

significant loss of exposure data. 

In cases of general work area monitoring, the petitioners are aware that much of the area 

monitoring that was performed was done poorly and did not reflect accurate area 

exposures. We will attempt to specifically identify these situations. In some cases, 

employees in their effort to increase output to meet production goals and bonuses would 

by-pass monitoring efforts in order to make their jobs easier. 

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The list of unmonitored exposures was based primarily upon the affidavit submitted by 

 Citations by page, section and paragraph number refer to areas of this 

affidavit where specific unmonitored exposures are referred to. Other affidavits and their 

sections are identified specific to the appropriate affidavit. 

Additional photos have been uncovered. These photos were from an album that 

documented the in the mid 1970s. 

What is remarkable is the limited use of work uniforms or no protective gear. Workers 

are shown performing standard process steps in their reusable work clothes along with 

personal clothing. In many cases even work gloves were not being worn. Personal 

glasses, but not safety glasses were worn. By the mid-1980s plastic safety glasses were 

required to be worn over prescription glasses in order to reduce radiation exposure to the 

eyes. 

For some period after work gloves were required in the 1980s, their contamination and 

overuse was noted to be a problem. This required the more frequent retirement of used 

work gloves, particularly in . However, in the 1970s work glove use was not 

required. Workers were free to augment their uniforms with personal clothing. This was 

found to be a problem as these clothing articles were not cleaned by the outside source 

used for uniform cleaning. Even this outside source proved to be a problem as uniforms 

were not totally decontaminated upon cleaning. 

 loading heat treat furnaces. The 

same furnaces mentioned in the maintenance 

exposures. No work gloves, personal prescription 

glasses. 

Unloading furnace billets. 

No work gloves, personal 

prescription glasses. 

Butting derby.. No work 

gloves, no safety glasses. 

(deceased) preparing 

extrusion billets. No 

work gloves, personal 

prescription glasses, 

personal sweat shirt. 

1400 ton extrusion press where eating, 

smoking & drinking were allowed. 

Unloading extrusion billets. No work 

gloves, no safety glasses. 

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E5 (?) or F.2 Unmonitored, unrecorded or inadequately monitored 

exposure incidents. 

The following sections of specific affidavits support this section of our petition. 

Affidavit: 

Exposure:	 1. Salt Water Processing of Uranium Machine 

Chips Resulting in Unmonitored Fire and Explosion 

Type of Exposures: Fire during testing. No respirators or PAM worn. 

Page: 2 

Paragraph: 1 – 6 

Other supporting documents: Test stand photo, page 2 

Plant Building: D 

Process Area: Empty area where large caliber CNC machining was later 

installed. 

Date: early 1979 

Number of Incidents: One 

Personnel Exposed: 

Witnesses: 

Exposure: 2. Development of a Foam Encapsulation 

Alternative to Concrete for Machine Turning 

Packaging for Shipment and Burial Resulting in 

Unmonitored Fires and Airborne Exposures 

Type of Exposures: Fires involving foam encapsulated DU chips being tested or 

during processing for test package preparation. No 

respirators or PAMs worn. 

Page: 3 - 5 

Paragraph: 4 – 9 

Other supporting documents: page 3 and 4 photographs, Appendix D- Foam

 Encapsulation reports and photos 

Plant Building: Building and area 

Process Area: inside and outside 

Date: 1979 – 1981 

Number of Incidents: 12-15 

Personnel Exposed: 

Witnesses: 

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Exposure: 3. Uranium Chemical Recycling Development 

Resulting in Unmonitored Airborne Releases of 

Uranium Tetrafluoride, Uranium Oxides and Uranyl 

Fluoride, and their hydrates 

Type of Exposures: HF acid treatment of DU machine chips permitting the 

release of acid fumes and airborne contamination. Para 1 - 5 

Hydrated UF4 precipitate decanting, washing, drying, ball 

milling and magnesium blending with the use of respirators 

or PAMs. Para 2, 3 

Lab scale reductions in an unvented resistance heating lab 

furnace. Para 6 

Opening and breaking out mini derbies using a hammer 

without respirator or PAM use. Para 7 

Page: 5 - 6 

Paragraph: 1 – 7 

Other supporting documents: Page 5 photographs, USAARDC Report No. ARLCDCR-83018, Appendix D 

Plant Building: 

Process Area: 

Date: 

Number of Incidents: 

Personnel Exposed: 

Witnesses: 

Building 

 1980 – 1983 

Chronic, Daily over several years of experiments 

Exposure: 4. Continuous Induction Solutionizing of Uranium 

Bars and Unmonitored Contaminated Process 

Water Exposures 

Type of Exposures: Contaminated quench water of DU at 850 oC – water spray 

on clothing, face and hands. Para 1 - 3 

Lack of PAM monitoring Para 4 

The use of contaminated work gloves with no monitoring of 

gloves to determine the appropriate time for replacement. 

(general observation) 

Page: 6 - 7 

Paragraph: 2 – 4 

Other supporting documents: photograph on page 6 

Plant Building: 

Process Area: 

motor generators 

Date: 1979 

Building C 

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Number of Incidents: 20 over a two month period 

Personnel Exposed: 

Witnesses: 

Exposure: 5. Uranium Alloy Development and Unmonitored 

Exposure to Used Crucibles 

Type of Exposures: Crucible mold wash application to previously used furnace 

crucibles without the use of respirators, safety glasses or ring 

badges. Para 1, 2 

Drinking coffee during melting and casting Par 3 

Crucible lid pacification resulting in flash flame and 

detonation of vapor deposited DU and daughter products 

without the use of respirators. Para 4 - 6 

Post casting crucible inspection without the use of 

respirators. Para 7 

Failure to rotate used tooling to permit a cooling off period 

for radioactive daughter product decay. Para 9 

Lack of safety glasses used during all activities. Para 8 

Drinking from Gatorade stations in area. Page 18 

Para 4 

Page: 7 – 8, 18 

Paragraph: 2 – 9, 4 

Number of Incidents: 

Personnel Exposed: 

Witnesses: 

Other supporting documents: Page 7 Photographs of my foundry work 

Plant Building: Building 

Process Area: 

Date: 1979 – 1982 

24 over several years 

Exposure: 6. UF4 Reduction Process Development and 

Unmonitored Airborne Exposures 

Type of Exposures: Reduction Vessel burn throughs para 3, 12, 13 

Magnesium fluoride slag removal para 6 

UF4/Magnesium blending station para 3, 4 

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Page: 

Paragraph: 

Other supporting affidavits: 

Plant Building: 

Process Area: 

Date: 

Number of Incidents:
 

Personnel Exposed: 

Witnesses: 

Exposure: 

Type of Exposures: 

Reduction vessel transfer spilling of UF4 para 3, 7 

Sweeping spilled UF4 para 4, 5 

Manually packing reduction vessels para 7 

Vacuuming spilled UF4 causing clogged vent systems para 8 

Power failures causing vent system shutdown para 8 

Power failures causing furnace explosions para 8 

Failure to rotate used tooling to permit a cooling off period 

for radioactive daughter product decay. Para 10, 13, 24 

Enriched uranium recycling and associated exposures to 

radon and fission products. Para 13, 14, 17 – 21 

Unmonitored Radon exposures Para 17 – 23 

Moist storage impact on unmonitored Radon exposures Para 

13 - 16 

 8 - 12 

3 – 8, 10, 13 – 14, 17 - 24 

, Page 1, Para 9 

, Page 4 - Para 1-2, Page 5 - Para 1-8, Page 6 – 

Para2 

, Page 3 - Para 3-7, Page 4 – Para 1 

Building
 

 1979 - 1982 

Chronic, daily 

, 

7. Patented Carousel Chip Cleaning & Drying 

System to Prep Machine Chips for Briquetting 

Resulting in Fires and Unmonitroed Airborne 

Contamination 

Carousel operation para 1 - 6 

DU chip handling without ring badges para 4 

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DU fires without respirators or PAMs para 5 - 6 

Page: 12 - 13 

Paragraph: 1 - 6 

Other supporting documents: US Patent No. 4,501,073 Award Diagram & 

USAARDC Report No. ARLCD-CR-83018 

Plant Building: Building 

Process Area: near 300 ton extrusion press 

Date: 1980 - 1983 

Number of Incidents: 

Personnel Exposed: 

Witnesses: 

Exposure: 8. Uranium Penetrator Test Range Fragment 

Recycling and Unmonitored Airborne Exposure to 

Contaminated Dust 

Type of Exposures: Emptying waste drums and screening sand/fragments without 

respirators, PAMs or ring badges para 1 - 2 

Page: 13 - 14 

Paragraph: 1 - 4 

Other supporting documents: Photos and USAF AFATL Report No. AFATLTR-82-49 Appendix D 

Plant Building: 

Process Area: 

Date: 

Number of Incidents: 

Personnel Exposed: 

Witnesses: 

Exposure: 9. Developmental Molten Salt Recycling of Uranium 

 Chips and Unmonitored Airborne Exposure 

Type of Exposures: Handling very dry DU machine chips para 1 – 4 

Manually dropping chips into molted salt potsPara 1 - 2 

DU chip fires para 2 

Page: 14 

Paragraph: 1 - 4 

Other supporting documents: Photos and USAF AFATL Report No. AFATLTR-82-49 Appendix D 

Plant Building: Building 

Process Area: near 300-Ton Press 

Date: 1981 - 1982 

Number of Incidents: 6 months of active processing 

120 days of processing, 6 fires 

Building 

 1981 - 1982 

6 months of active processing 

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Personnel Exposed: 

Witnesses: 

Exposure: 10. Off Site Heat Treatment Experiments and 

 Unmonitored Exposures 

Type of Exposures: Uranium transport to Cleveland para 1 – 2 

Page: 14 - 15 

Paragraph: 1 - 4 

Other supporting documents: none 

Plant Building: 

Process Area: 

Date: 

Number of Incidents: two weeks 

Personnel Exposed: 

Witnesses: 

Exposure: 11. Off Site Ordnance Testing and 

Unmonitored/Unavailable Exposures 

Type of Exposures: DU explosive testing Para 1 - 3 

Target inspections Para 2 

Page: 15 - 16 

Paragraph: 1 - 3 

Other supporting documents: Photos and Final Technical Reports, Appendix D 

Plant Building: 

Process Area: 

Date: 1980 - 1987 

Number of Incidents: 50 

1981 

Test sites 

Personnel Exposed: 

Witnesses: 

Exposure: 12. Unmonitored Exposures - Heat Treatment 

Furnace Maintenance 

Type of Exposures: Airborne exposures during furnace maintenance Para 1 - 3 

Page: 16 

Paragraph: 1 - 3 

Other supporting documents: none 

Plant Building: 

Process Area: 

Date: 

Number of Incidents: numerous 

Personnel Exposed: 

Witnesses: 

Building 

 1978 - 1983 

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Exposure: 13. Unmonitored Exposures – Uranium Liner 

Forming 

Type of Exposures: Airborne exposures during DU part forming Para 1 - 3 

Page: 16 - 17 

Paragraph: 1 - 3 

Other supporting documents: none 

Plant Building: 

Process Area: 

Date: 

Number of Incidents: numerous 

Personnel Exposed: 

Witnesses: 

Exposure: 14. Unmonitored Exposures – Extrusion Press 

Type of Exposures: Airborne exposures during DU extrusion of bare billets with 

molten salt Para 1 - 2 

Page: 17 

Paragraph: 1 - 2 

Other supporting documents: none 

Plant Building: 

Process Area: 

Date: 

Number of Incidents: 12 

Personnel Exposed: 

Witnesses: 

Exposure: 16. Plant Material Handling, Employee Access and 

Traffic Pattern Contamination 

Type of Exposures: physical spread of contamination to uncontrolled internal and 

external areas 

Page: 18 – 19 Para 1 - 3, Page 21 – Section 17 – Para 12-14 

and 17-19, Page 20 – Section 17 – Para 4, Page 22 – Section 

17 – Para 21 

Paragraph: 1 - 10 

Number of Incidents: numerous 

Personnel Exposed: 

Witnesses: 

The following are additional unmonitored exposures that are described in various 

sections of the affidavit submitted by . These exposures were not reviewed 

separately but were discussed in various sections. 

Building 

 1978 - 1983 

, , 

Building 

 1978 - 1983 

Other supporting documents: other affidavits 

Plant Building: 

Process Area: 

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Exposure: 17. Unmonitored Radon Exposure 

Type of Exposures: Radon generation and unmonitored exposures as a result of 

spent fuel rod recycling and the presence of unexpected 

radionuclides in government furnished DU 

Page and Paragraph: Page 19 - Section 17 - Para 2, Page 20 - Section 17 - Para 5, 

Page 22 - Section 17 - Para 27 

Other supporting documents: DoE spent fuel recycling, Utah Dept. of Public Health report 

on moist versus arid DU storage the impact on radon 

generation 

Plant Building: 

Process Area: 

Date: 1970 - 1983 

Number of Incidents: chronic and daily 

Personnel Exposed: 

Witnesses: 

Exposure: 18. Unmonitored Exposures - Post enriched uranium 

use and failure to decontaminate process areas after 

enriched license expiration 

Type of Exposures: airborne and external 

Page and Paragraph: Page 20, Section 17, Para 4-6 

Page 20, Section 17, Para 10 

Other supporting documents: DoE spent fuel recycling, 1993 Division of Waste 

Management report, EPA Report EPA-402-R-06-011 Page 

32 

Plant Building: 

Process Area: 

Date: 1970 - 1983 

Number of Incidents: chronic and daily 

Personnel Exposed: 

Witnesses: 

Exposure: 19. Unmonitored Exposures – DoE Recycling of 

Spent Fuel Rods and unknown DU contamination 

with Fission Products 

Type of Exposures: airborne and external 

Page and Paragraph: Page 22, Section 17, Para 26 

Page 20, Section 17, Para 10 

Other supporting documents: DoE spent fuel recycling, 1993 Division of Waste 

Management report, EPA Report EPA-402-R-06-011 Page 

32 

Plant Building: 

Process Area: 

Date: 1970 - 1983 

Number of Incidents: chronic and daily 

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Page 18, Section 16, Para 4 

Personnel Exposed: 

Witnesses: 

Exposure: 20. Unmonitored Exposures – Gatorade Stations in 

DU Process Areas 

Type of Exposures: internal 

Page and Paragraph: 

, Page 1, Para 4 

, Page 2, Para 3 

, Page 6, Para last 

, Page 7, Para 2 

Other supporting documents: DoE spent fuel recycling, 1993 Division of Waste 

Management report, EPA Report EPA-402-R-06-011 Page 

32 

Plant Building: 

Process Area: 

Date: 1970 - 1983 

Number of Incidents: chronic and daily 

Personnel Exposed: 

Witnesses: 

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