Existence of Mg-Th Alloy at RFP 

Based on Worker Statements 

Response Paper 

Rev. 1 

National Institute for Occupational 

Safety and Health 

August 13, 2014 

J. S. Bogard and Dan Stempfley 

Oak Ridge Associated Universities Team
 

-

Reviewed by Dr. James W. Neton and LaVon B. Rutherford, CHP 

Division of Compensation Analysis and Support
 

Page 1 of 13 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
Response                        Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

WORKER STATEMENTS AND BACKGROUND 

This assessment and response to worker statements that magnesium-thorium (Mg-Th) alloy 

plates existed and were used/handled/processed on-site at the Rocky Flats Plant (RFP) was 

reinstated as an issue by the current SEC-00192 RFP petitioner (via email on May 31, 2013) in 

relation to ongoing Board working group reviews and follow-ups associated with the SEC-00192 

RFP ER that was presented by NIOSH to the Board in September 2012. The petitioner discussed 

that she was approached by a former RFP worker who wished to remain anonymous regarding 

this issue. The email stated: 

Earlier this month a former Rocky Flats worker related to me thru a third party (who wants 

to remain anonymous) information concerning the use of magnesium thorium alloy plates at 

Rocky Flats. You may remember that Dow workers submitted affidavits that Dow shipped 

these plates to Rocky Flats. 

The information relayed to me was, "They were brought in on the 903 pad send [sic] to 881 

to refine then sent to the MOD center for modification to fit the Semi Trucks as to make them 

bullet proof. A Semi bed was brought in stripped down and the sheets were refined to help 

armor plate the trucks for transport of materials. He also said they were used in the Train 

cars for support!" 

This issue was originally brought up in 2007 as part of the SEC-00030 RFP ER Board working 

group review and assessment during which former Dow-Madison workers provided affidavits 

(associated with the Dow-Madison SEC evaluation) indicating that one of the customers of the 

Dow-Madison Thorium Sheets (Mg-Th alloy plates) included Rocky Flats, Colorado (SRDB 

39868). The affiant indicated that work was performed with this thorium material at DowMadison from 1962-1975, but did not provide any specific information on when the shipments 

might have been made to RFP. No corroborating evidence for the assertion that Mg-Th alloys 

were used or present at RFP was found during the research into Mg-Th alloy efforts in the DOE 

complex over the applicable time period. NIOSH interviewed RFP personnel who would have 

been aware of the receipt of these types of materials and none were aware that Mg-Th alloy was 

ever present or used in any significant quantity at RFP (SRDB 53614, pdf pp. 66-67). 

NIOSH identified two other Colorado facilities in the proximity of Rocky Flats that handled 

nuclear materials, and specifically handled Mg-Th alloys or nuclear weapons or related 

equipment that would have used Mg-Th alloys in their design (Rocky Mountain Arsenal and 

Lockheed Martin-PJKS Test Facility). As part of its follow-up, NIOSH also interviewed the 

Page 2 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

                                                            

 

 

 

 

 

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

Dow individual who had stated that Mg-Th alloys were sent from Dow to RFP. He was asked 

about the possibility that the Mg-Th could have been shipped to one of these other locations 

instead of RFP. The individual indicated that this was a possibility (he was not aware of the 

existence of the other two facilities). This conclusion, which was presented by NIOSH at the 

6/11/2007 Board meeting, was concurred with by the Board’s RFP working group that was 

reviewing the SEC-00030 RFP issues1 This conclusion was later challenged during the June 

2008 Board meeting by Dr. Dan McKeel (a Dow-Madison petitioner representative2

) in a 

discussion3

 about the claim that Dow-Madison shipped Mg-Th alloy plates to RFP. 

MG-TH-RELATED SRDB RESULTS INITIALLY IDENTIFIED DURING THE 

SEC-00192 ER INVESTIGATION 

In late 2013, during the investigation for the SEC-00192 RFP ER, an initial search of the Site 

Research Database (SRDB) was conducted to determine if a link could be established between 

Mg-Th alloy and RFP. This search included all listed sites and provided the following 

documents containing information on Mg-Th alloy (see Table 1 for additional details). 

	 SRDB 34093: A 2007 FOIA request “for records that pertain to shipments of thoriummagnesium alloy metal between the Dow Chemical Company at its Madison, Illinois, facility 

or at the Walnut Creek-Pittsburgh, California, dual facility and the Rocky Flats nuclear 

weapons facility in Colorado between 1951 and 1973” resulted in a response from the DOE 

Office of Legacy Management identifying 10 documents (all are shipping orders – SRDB 

34079-34087; 34089). The identified documents however are all for shipments of Pu samples 

from Rocky Flats (Dow) to Savannah River (du Pont) from 1957 – 1959. [Bold emphasis 

added.] 

1 As documented in the June 11, 2007 transcript (SRDB 53613, pdf pp. 133-138 and 266-227). 

2

 Although Dr. McKeel is listed in the SEC tracking system as a petitioner representative for the SEC-00079

 Dow Madison petition, he self-identified as a co-petitioner from the Southern Illinois Nuclear Workers during 

the June 2008 Board meeting (SRDB 53615, pdf p. 32) 

3 As documented in the June 23, 2008 transcript (SRDB 53615, pdf pp. 12-23, 31-66, 89-96, 136-142, 192-197, 

207-211, and 213-218) 

Page 3 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
Response                        Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

	 SRDB 37754: SRS Responses to FOIAs that contain a 2007 FOIA from an East Alton, 

Illinois attorney regarding magnesium-thorium alloy metal. 

	 SRDB 39990: SC&A’s 2006 review of the NIOSH ER for Rocky Flats has no estimate of 

dates when Mg-Th might be present at Rocky. Their finding (SRDB 39990, pdf p. 18) states, 

“It is clear from NUREG-1717 and the other considerations presented above that knowledge 

of the approximate quantities, periods, and processing status of the magnesium-thorium 

alloy is needed before any reliable conclusions can arrived at regarding doses to Rocky Flats 

workers from this material.” [bold emphasis added] 

	 SRDB 71079: Production of Magnesium Thorium Alloy, 1954-1973, with production data 

taken from Minerals Yearbook Metals and Materials, indicates that Dow Madison produced 

Mg Th alloy from 1954-1965 and from 1967-1973. [Bold emphasis added.] 

	 SRDB 53614: A Focused Review of Operations and Thorium Exposures at the Dow 

Chemical Company Madison Plant, in which four former RFP managers state that Mg-Th 

alloy was never used in any process for development or fabrication of weapons components. 

	 SRDB 53615: The notes of ABRWH Board Meeting 56 in June 2008 on the Dow Chemical 

SEC petition state that DOE concluded that Dow Madison made thorium magnesium alloys 

HK31A and HM21A for use in nuclear weapons in 1957 and 1958 (SRDB 53615, pdf p. 32) 

and that Mg Th alloys were used in atomic weapons from 1956 – 1969 (SRDB 53615, pdf p. 

38). [bold emphasis added] 

ADDITIONAL SEARCH RESULTS IDENTIFIED DURING THE SEC-00192 ER 

INVESTIGATION 

During the SEC-00192 RFP ER investigation in late 2013 (as a consequence of the results listed 

above), additional research and reviews were conducted on topics potentially related to the 

existence of Mg-Th alloys at RFP. Searches were performed with key words that included the 

terms “magnesium” and “thorium” as well as their acronyms. These searches identified further 

search terms, including HK-31 and HK-31A (an acronym used to identify Mg-Th). These 

additional searches identified the following SRDB documents relating to Mg-Th operations in 

the AEC/DOE complex. See Table 1 for additional details. 

Page 4 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
Response                        Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

 SRDB 39989 (related to Dow Chemical): 1957 internal Dow memo regarding firefighting 

concerns associated with Mg-Th alloys. 

 SRDB 29584 (related to Dow Chemical): A 1959 letter from Dow to the AEC regarding 

ventilation for Mg-Th welding. 

 SRDB 39905 (related to Dow Chemical): 1958 Dow spectrographic analysis results for dust 

samples obtained from sanding HK-31. 

 SRDB 39980 (related to Dow Chemical): 1957 analytical results for air samples obtained 

during hand sanding HK-31. 

 SRDB 39985 (related to Dow Chemical): 1957 Dow internal memo making a correction to a 

previous letter regarding exposure to HK-31. 

 SRDB 40000 (related to Dow Chemical): 1957 Dow nternal memo explaining the new 

federal law passed in January 1957 that places a limit on the external radiation a worker can 

receive. 

 SRDB 40017 (related to Dow Chemical): 1957 Dow internal memo documenting sample 

turnover of two dust samples collected during hand sanding of HK-31. 

 SRDB 51843 (related to Dow Chemical): 1958 Dow internal memo documenting sample 

turnover of three dust samples collected during sanding of HK-31 with vertical metallurgical 

sanding discs. 

 SRDB 71077 (related to Dow Chemical): Undated description of the composition, hardness, 

and strength of HK-31A material. 

 SRDB 114404 (related to Wyman-Gordon in Massachusetts): 1994 report on a 1993 survey 

of Mg-Th residual contamination on the W-G site. 

Page 5 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
Response                        Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

	 SRDB 108264 (related to the Kansas City Plant, a.k.a. Bendix): A variety of operational 

documents from the 1960s and 1970s related to Mg-Th alloy and a Bendix association to 

Dow Chemical. 

	 SRDB 128435 (related to the Kansas City Plant, a.k.a. Bendix): Two 1970 memos discussing 

fabrication of Mg-Th units to be machined as part of the RADEC program. 

	 SRDB 128158 (related to the Kansas City Plant): Two 1972 memos listing personnel who 

had received physicals, orientation, and/or clearances to work with Mg-Th waste. 

	 SRDB 128181 (related to the Kansas City Plant): 1970 document specifying the health and 

safety procedures to be followed when handling Mg-Th (2% Th). 

SITE VISIT, DATA CAPTURE, AND INTERVIEW RESULTS FROM THE SEC-00192 

ER INVESTIGATION 

In December 2013, an additional site visit and data capture was performed at the Environmental 

Management Consolidated Business Center (EMCBC) in Denver, Colorado. This effort was 

focused on FBI raid issues, neptunium issues, and Mg-Th issues. It included classified document 

reviews and interviews and generated the following Mg-Th-related results. See Table 1 for 

additional details. 

	 SRDB 129610 (related to Rocky Flats): EMCBC documents on the SST (safe, secure 

transport) and SSR (safe, secure railcar – from ATMX rail system) Modification Center, 

Books 1-4 (documents classified); classified document reviews for Mg-Th with the 

unclassified and released notes indicating no related information was identified. 

	 SRDB 129509 (related to Rocky Flats): EMCBC J. Blair interview; discussed SST and SSR 

work and provided photos of related operations; performed as a classified interview with the 

unclassified and released notes indicating that no Mg-Th-related information was identified. 

	 SRDB 129608 (related to Rocky Flats): EMCBC railcar procedures; classified document 

reviews for Mg-Th with the unclassified and released notes indicating no related information 

was identified. 

Page 6 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

	 SRDB 129613 (related to Rocky Flats): EMCBC documents on the SSR; classified 

interviews for Mg-Th with the unclassified and released notes indicating no related 

information was identified. 

	 SRDB 129511, 129782, and 130557 (related to Rocky Flats): [name redacted for privacy] 

interview; Mg-Th and any related operations; classified interviews for Mg-Th with the 

unclassified and released notes indicating no related information was identified. 

	 SRDB 130248 (related to Rocky Flats): [name redacted for privacy] interview; among other 

things, discussed Mg-Th operations; classified interviews for Mg-Th with the unclassified 

and released notes indicating no related information was identified. 

	 SRDB 130198 (related to Rocky Flats): RFP thorium shipment/receipt records for 1952-1976 

with no indication or support of Mg-Th operations. 

As indicated in the interviews, the armor/shielding plate installation operation associated with 

the potential use of Mg-Th alloys was performed at a specific location at RFP. Individuals who 

were directly involved in the [redacted for privacy]were interviewed in regard to the use of MgTh alloys [redacted for privacy]. In addition, documentation and procedures associated with the 

[redacted for privacy]were reviewed. While most of the information and documentation remains 

classified, the information that was released based on the reviews does not corroborate the use of 

Mg-Th alloys at RFP for this or any other operations. 

NIOSH followed up on interviews and information indicating that RFP may have collaborated 

with Sandia National Laboratory (SNL) on the design of the armor plating installed on 

vehicles/equipment at RFP. Because SNL documentation related to the armor plating could 

potentially contain information on plating composition, NIOSH requested a key word search of 

classified and unclassified SNL documents for anything related to this operation. The 

SNL-Albuquerque contact responded on June 2, 2014 that no related documentation was 

discovered in their searches. The SNL-Livermore contact responded on August 6, 2014 that no 

related documentation was discovered in their searches. Therefore, this potential SNL 

information pathway was considered non-responsive and closed for the purpose of this review. 

Page 7 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

GENERAL CONCLUSION 

Based on the research performed for this assessment, the conclusion is that there is no 

corroborating evidence for the use of Mg-Th at the RFP site. It is likely that there is confusion 

between RFP and other Denver-area sites, as well as confusion regarding Mg-Th alloy plates and 

other similar materials at RFP. All of the available information for Mg-Th alloys for other sites 

falls within the timeframe of the most recent proposed SEC class for RFP (1952-1983); 

therefore, if any undocumented Mg-Th operations did occur at RFP (that were responsive to 

these other sites’ operations), the RFP operational dates would be covered under the existing 

RFP SEC class. 

See Table 1 below for additional details on the Mg-Th-related results listed in this response 

paper. 

Page 8 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

 

 

 

 

 

 

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

Additional Details from Relevant SEC-00192 Investigation Results 

Table 1 provides additional details on the results of the Mg-Th-related searches, data captures, 

document reviews, and interviews conducted for SEC-00192 RFP ER, as summarized earlier in 

this response. 

Table 1: SEC-00192 Investigation Results Related to Mg-Th (on pages 8-13) 

SRDB Ref ID Title Relevant Information 

Mg-Th-related SRDB Results Initially Identified During the SEC-00192 ER Investigation 

34093 

RE: Freedom of 

Information (FOIA) 

Request F2007-

00179 

Letter from Director, Office of Legacy Management, to FOIA requestor 

about shipments of thorium-magnesium alloy between Dow Chemical Co. 

(Madison IL or Walnut Creek-Pittsburgh CA facilities). Refers to shipping 

forms SFJ-SDA-7P, SFJ-SDA-9P, SFJ-SDA-12P, SFJ-SDA-13P, SFJSDA-13P-C, SFJ-SDA-14P, SFJ-SDA-15P, SFJ-SDA-16P, SFJ-SDA17P, and SFJ-SDA-18P. 

Note: Examination of these documents shows that each one is a record of 

Pu metal sent from RFP to SRS. 

37754 SRS Responses to 

FOIAs 

Contains a 2007 FOIA from an East Alton, IL attorney regarding 

magnesium-thorium alloy metal. DOE LM provided 10 responsive 

documents. Note: These documents are shipping records for gram 

quantities of Pu metal from Rocky Flats to SRS. 

39868 Affidavits of former 

Dow workers 

Many of the affiants (pdf pp. 3, 9, 11) state that their knowledge of the 

destination of Mg-Th alloy was hearsay, although six affiants claim 

certainty in the destination of Mg-Th shipped from Dow Madison (pdf 

pp. 9, 11, 13, 17, 18, 42). One ( pdf p. 9) states, “I worked in [redacted 

for privacy] during the 1980's [redacted for privacy]. These were 

then shipped to Collinsville to be reamed out and then shipped to Rocky 

Flats.” Note: There is nothing to indicate that Rocky Flats used 

[redacted for privacy] in its fabrication activities, although these 

might have been used at Rocky Mountain Arsenal. 

Page 9 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

 

 

 

 

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

Table 1: SEC-00192 Investigation Results Related to Mg-Th (on pages 8-13) 

SRDB Ref ID Title Relevant Information 

39990 

RFETS SEC Petition 

Review: Internal 

Dose Issues for 

Thorium and Other 

Radionuclides, 

(Working Draft, 

February 15, 2007) 

In its December 27, 2006 report, NIOSH also reviewed whether Rocky 

Flats received thorium from the Dow Madison plant and concluded that no 

pure thorium shipments occurred between these two sites. However, 

NIOSH also found that magnesium alloy containing up to three percent 

thorium was shipped from Dow Madison to Rocky Flats: ... The 

December 27, 2006 NIOSH report does not explore the amounts of alloy 

that were shipped, or whether the alloys were processed in a way that 

could have exposure potential. During the January 9, 2007 Working 

Group teleconference call, NIOSH stated that the worker interviewed on 

this topic remembered that alloys were shipped by the truckload. The 

frequency of such shipments is unknown. SC&A notes here that a single 

truckload with ~10 metric tons of 3% thorium alloy would contain 300 

kilograms of thorium. This material is not included in the Rocky Flats 

thorium inventory records. Yet, it could exceed the amounts that NIOSH 

has discussed to date. 

53613 

Minutes of the 

ABRWH June 2007 

Meeting 

 As a sidebar to the thorium issue, Dr. Brant Ulsh also offered a 

possible explanation for the conflicting testimony between Rocky 

Flats workers and Dow Chemical workers as to large shipments of 

thorium/magnesium alloy from the Dow Madison plant to Rocky 

Flats. Rocky Flats workers on the shipping/receiving authorization 

committee were interviewed, the people who were in charge of 

receiving materials that came onto the site, and nobody had 

recollection of magnesium alloy from Dow Madison or from anywhere 

else. (pdf pp. 12-13) 

 It is known that magnesium alloy was used in the aircraft industry and 

in missile construction because of its heat resistance, light weight and 

strength, and affidavits submitted by Dow Madison workers have 

indicated their alloys were used in missiles, specifically the Titan 

missile. It is also known that Titan missile work was performed in 

Colorado at Rocky Mountain Arsenal, not at Rocky Flats. 

Page 10 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

 

 

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

Table 1: SEC-00192 Investigation Results Related to Mg-Th (on pages 8-13) 

SRDB Ref ID Title Relevant Information 

53613 

(Cont.) 

Minutes of the 

ABRWH June 2007 

Meeting 

(Cont.) 

 Dr. Ulsh offered his personal knowledge that, as a former Denver 

resident, unless you worked at one of the two facilities, even Colorado 

residents got Rocky Mountain Arsenal and Rocky Flats confused. 

 Mr. Griffon had asked Dr. Ulsh to contact the individual from Dow 

Madison who had indicated he had seen the crates of alloy going to 

Rocky Flats, which Dr. Ulsh did. He asked the worker if it were 

possible the facility was Rocky Mountain Arsenal rather than Rocky 

Flats, and the person indicated that he did not know there were two 

different facilities. 

 Dr. Ulsh submitted that confusion between the two facilities is the 

most plausible explanation, with Rocky Flats workers and Dow 

Madison workers offering conflicting testimony. There is no evidence 

in the inventory records that magnesium alloy came to Rocky Flats, 

and no evidence that it was found in the chem risk reports that 

inventoried radionuclides and toxic chemicals. There is no evidence 

that magnesium alloy ever came to Rocky Flats. 

53614 

A Focused Review of 

Operations and 

Thorium Exposures 

at the Dow Chemical 

Company Madison 

Plant 

pdf pp. 66-67, Attachment G: Four [name redacted for privacy]who 

worked at Rocky Flats starting in the 1950s for 25 to over 35 years stated 

that Mg-Th alloy was never used in any process for development or 

fabrication of weapons components. The only Mg-Th alloy on the site that 

these former workers were aware of was in pennants that served to secure 

parts on a conveyor line in Bldg 776. These parts were provided by the 

company that fabricated and installed the conveyor system. Each of these 

former workers stated that he would have known if any significant amount 

of magnesium or magnesium alloy were present on site. 

Page 11 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

 

 

 

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

Table 1: SEC-00192 Investigation Results Related to Mg-Th (on pages 8-13) 

SRDB Ref ID Title Relevant Information 

53615 

ABRWH Board 

Meeting 56, Vol II - 

Day 2, June 2008 

pdf pp. 217-218: Dr. (Dan) McKeel (Petitioner or Petitioner Rep): I had 

just one thing I needed to clarify for the record and that is apropos to Mr. 

Elliott's comment about Rocky Mountain Arsenal. As soon as that 

suggestion was made that the Dow workers at Madison had confused - got 

confused in their testimony, I asked them specifically; and what they 

testified to, what they believe, what they saw with their eyes was Rocky 

Flats, and there is no Rocky Flats Arsenal. They saw the words Rocky 

Flats. Nobody saw the words Rocky Mountain Arsenal so I think that is a 

straw man. It is not what they saw. It is against their testimony. And they 

say - at least 11 affidavits - that they sent thorium alloy, the same kind 

used in nuclear weapons, to Rocky Flats in large [unintelligible]. 

71079 

Production of 

Magnesium thorium 

Alloy, 1954-1973 

Document consists of a table summarizing the production of magnesium 

thorium alloy from 1954-1973 using information from the Minerals 

Yearbook Metals and Materials (1960-73). Bureau of Mines: Ecology and 

Natural Resources Collection. Accessible at: 

<http://digicoll.library.wisc.edu/cgi-bin/EcoNatRes/ EcoNatResidx?type=browse&scope=ECONATRES.MINERALSYEARBK>. The 

production company, some metallurgical details, and use of the alloy are 

provided. The only mention of DOE/AWE sites is an entry for the 

production by Dow Chemical Co. (Madison IL) for the years 1954-1965 

and 1967-1973 of HK31A alloy for “atomic weapons parts and present 

[sic] at LLNL/Sandia.” The remaining entries indicate use of the alloy for 

military applications (Navy and guided missiles, Navy aluminum and 

magnesium castings, jet engines); aerospace industry components, 

missiles and rockets; valves, metering pumps and control packages; and 

ground tillers. 

Additional Search Results Identified During the SEC-00192 ER Investigation 

SRDB 39989 Mg-Th Fires 

Related to Dow Chemical: 1957 memo relaying firefighting concerns 

associated with Mg-Th alloys. The memo states that no protection is 

needed against thorium, but high concentrations of its daughter products, 

as well as too much MgO, make the use of a respirator very desirable. 

Page 12 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

 

 

 

 

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

Table 1: SEC-00192 Investigation Results Related to Mg-Th (on pages 8-13) 

SRDB Ref ID Title Relevant Information 

SRDB 29584 Ventilation for 

Mg-Th Welding 

Related to Dow Chemical: A 1959 letter from Dow to the AEC on Mg-Th 

welding. The letter asserts that Mg-Th welding in shops with high 

ceilings plus time factors of operation permit production without resorting 

to local exhaust ventilation. The letter further explains variations in 

thorium air sampling levels as a function of the placement of the air 

sampler relative to the point of welding and the welder’s mask. The letter 

requests AEC feedback. 

SRDB 39905 Dust Sample Results 

from Sanding HK-31 

Related to Dow Chemical: 1958 Dow spectrographic analysis results for 

dust samples obtained from sanding HK-31. The report asserts that if the 

operation is intermittent and of fairly short duration, neither local exhaust 

nor a respirator would be required. 

SRDB 39980 Air Sample Results 

from Sanding HK-31 

Related to Dow Chemical: 1957 analytical results for air samples obtained 

during hand sanding HK-31. The report concludes that there is no hazard 

to the health of workmen who are hand sanding HK-31. 

SRDB 39985 Exposure from 

Handling HK-31 

Related to Dow Chemical: 1957 Dow internal memo making a correction 

to a previous letter regarding exposure to HK-31. The correction changes 

the exposure unit from “mr/wk” to “r/wk”. The correction also states that 

even continuous handling would comply with the NCRP limit. 

SRDB 40000 External Radiation 

Related to Dow Chemical: 1957 Dow nternal memo explaining the new 

federal law passed in January 1957 that places a limit on the external 

radiation a worker can receive. The permissible level would be set at onethird the legal level. The letter concludes that HK-31 external exposure 

presents no legal or safety issue for Dow workers. 

SRDB 40017 

Dust Samples 

Collected During 

Hand Sanding of 

HK31 Alloy 

Related to Dow Chemical: 1957 Dow internal memo documenting sample 

turnover of two dust samples collected during hand sanding of HK-31. 

There are no analytical results. 

SRDB 51843 

Dust Samples 

Collected While 

Sanding HK31 with 

Vertical 

Metallurgical 

Sanding Discs 

Related to Dow Chemical: 1958 Dow internal memo documenting sample 

turnover of three dust samples collected during sanding of HK-31 with 

vertical metallurgical sanding discs. There are no analytical results. 

SRDB 71077 HK31A Material 

Description 

Related to Dow Chemical: Undated description of the composition, 

hardness, and strength of HK-31A material. 

Page 13 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

 

 

 

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

Table 1: SEC-00192 Investigation Results Related to Mg-Th (on pages 8-13) 

SRDB Ref ID Title Relevant Information 

SRDB 114404 

October 1993 

Sampling and 

Radiological 

Analyses, Mg-Th 

Disposal Area 

Related to Wyman-Gordon in Massachusetts: 1994 report on a 1993 

survey of Mg-Th residual contamination on the W-G site. The report 

concludes that sample levels were well within the EPA standards. 

SRDB 108264 

Operational 

Documents Related 

to Mg-Th Alloy 

Related to the Kansas City Plant, a.k.a. Bendix: A variety of operational 

documents from the 1960s and 1970s related to Mg-Th alloy and a Bendix 

association to Dow Chemical. 

SRDB 128435 

Development Support 

Project Using 

Magnesium-Thorium 

Alloy 

Related to the Kansas City Plant, a.k.a. Bendix: Two 1970 memos 

discussing fabrication of Mg-Th units to be machined as part of the 

RADEC program. One memo estimates the number of machining hours 

anticipated for various ordered units. 

SRDB 128158 

Physicals, 

Orientation, and 

Clearances for 

Mg-Th Waste 

Handling 

Related to the Kansas City Plant, a.k.a. Bendix: Two 1972 memos listing 

personnel who had received physicals, orientation, and/or clearances to 

work with Mg-Th waste. 

SRDB 128181 

Health and Safety 

Guide for Handling 

Magnesium-Thorium 

in Dept. 851 

Related to the Kansas City Plant: 1970 document specifying the health and 

safety procedures to be followed when handling Mg-Th (2% Th). The 

procedures specify worker orientation and physicals; wearing bib and 

gloves; no eating or drinking while work in progress; machining “wet”; 

arc welding with filtered exhaust; dedicated machines; waste segregation. 

Site Visit, Data Capture, and Interview Results from the SEC-00192 ER Investigation 

SRDB 129610 SST and SSR 

Modification Center 

Related to Rocky Flats: EMCBC documents on the SST (safe, secure 

transport) and SSR (safe, secure railcar – from ATMX rail system) 

Modification Center, Books 1-4 (documents classified); classified 

document reviews for Mg-Th with the unclassified and released notes 

indicating that no related information was identified. 

SRDB 129509 

Interview Regarding 

SST and SSR Work 

at RFP 

Related to Rocky Flats: EMCBC [name redacted for privacy] 

interview; discussed [name redacted for privacy] work and provided 

photos of related operations; performed as a classified interview with the 

unclassified and released notes indicating that no Mg-Th-related 

information was identified. 

SRDB 129608 RFP Railcar 

Procedures 

Related to Rocky Flats: EMCBC railcar procedures; classified document 

reviews for Mg-Th with the unclassified and released notes indicating that 

no related information was identified. 

Page 14 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
                       

 

 

 

 

 

Response Paper: Existence of Mg‐Th Alloy at RFP Based on Worker Statements

Table 1: SEC-00192 Investigation Results Related to Mg-Th (on pages 8-13) 

SRDB Ref ID Title Relevant Information 

SRDB 129613 Safe-Secure Railcar 

(SSR) Program Plan 

Related to Rocky Flats: EMCBC documents on the SSR; classified 

interviews for Mg-Th with the unclassified and released notes indicating 

that no related information was identified. 

SRDB 129511, 

129782, and 

130557 

Interview Notes 

Regarding Mg-Th 

Work at RFP 

Related to Rocky Flats: [name redacted for privacy] interview; MgTh and any related operations; classified interviews for Mg-Th with the 

unclassified and released notes indicating that no related information was 

identified. 

SRDB 130248 

Interview Notes 

Regarding Mg-Th 

Work at RFP 

Related to Rocky Flats: [name redacted for privacy] interview; 

among other things, discussed Mg-Th operations; classified interviews for 

Mg-Th with the unclassified and released notes indicating that no related 

information was identified. 

SRDB 130198 

RFP Thorium 

Shipment/Receipt 

Records for 1952-

1976 

Related to Rocky Flats: RFP thorium shipment/receipt records for 1952-

1976 with no indication or support of Mg-Th operations. 

Page 15 of 14 

This working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) 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. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.