SEC Petition Evaluation Report

Petition SEC-00195 

Report Rev #:0 Report Submittal Date: August 30, 2012 

Subject Expert(s): Edward D. Scalsky, Toshihide Ushino, Jason Davis, and Roger Halsey

Site Expert(s): N/A

Petition Administrative Summary

Petition Under Evaluation

Petition # Petition 

Type

Petition

Receipt Date

Qualification 

Date

DOE/AWE Facility Name

SEC-00195 83.13 October 20, 2011 January 17, 2012 Nuclear Metals, Inc.

Petitioner-Requested Class Definition

All employees who worked in Buildings A, B, C, D, E, the Butler Building, external storage containers, and 

outside areas immediate to plant grounds at the Nuclear Metals, Inc. facility in West Concord, Massachusetts, 

during the period from January 1, 1970 through December 31, 1983.

Class Evaluated by NIOSH

All employees who worked at the Nuclear Metals, Inc. facility in West Concord, Massachusetts, during the period 

from January 1, 1958 through December 31, 1983.

NIOSH-Proposed Class to be Added to the SEC

All Atomic Weapons Employees who worked at the facility owned by Nuclear Metals Inc. (or a subsequent 

owner) in West Concord, Massachusetts during the period from October 29, 1958 through December 31, 1979, 

for a number of work days aggregating at least 250 work days, occurring either solely under this employment or 

in combination with work days within the parameters established for one or more other classes of employees 

included in the Special Exposure Cohort.

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status

N/A N/A N/A N/A

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name

N/A N/A

ORAU Lead Technical Evaluator: Edward D. Scalsky ORAU Peer Review Completed By: Michael Kubiak

Peer Review Completed By: [Signature on File] 9/4/2012

Sam Glover Date

[Signature on File] 9/4/2012 SEC Petition Evaluation Reviewed By:

J. W. Neton Date

[Signature on File] 9/4/2012 SEC Evaluation Approved By:

Stuart L. Hinnefeld Date
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Evaluation Report Summary: SEC-00195, Nuclear Metals, Inc.

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH)

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition

Petition SEC-00195 was received on October 20, 2011, and qualified on January 17, 2012. The 

petitioner requested that NIOSH consider the following class: All employees who worked in Buildings 

A, B, C, D, E, the Butler Building, external storage containers, and outside areas immediate to plant 

grounds at the Nuclear Metals, Inc. facility in West Concord, Massachusetts, during the period from 

January 1, 1970 through December 31, 1983. 

Class Evaluated by NIOSH

Based on its preliminary research, NIOSH expanded the petitioner-requested class. The start date of 

the evaluated class was changed from the date petitioned to be consistent with the Nuclear Metals, Inc. 

movement of operations from the Hood Building in Cambridge, Massachusetts, to their new facility at 

2229 Main Street in Concord, Massachusetts in 1958. NIOSH evaluated the following class: All 

employees who worked at the Nuclear Metals, Inc. facility in West Concord, Massachusetts, during 

the period from January 1, 1958 through December 31, 1983. NIOSH has determined that the 

information gained during recent data capture efforts warrant further analysis for the years post-1979. 

NIOSH believes the availability of breathing zone data starting in 1980, along with increased bioassay 

monitoring beginning in the late 1970s, may impact post-1979 dose reconstruction feasibility 

determinations. Because the continuing analysis affects only post-1979, NIOSH has determined that 

it is appropriate to proceed with the pre-1980 feasibility evaluation while continuing to analyze the 

impact that the data have on post-1979 dose reconstruction. NIOSH is therefore reserving its 

feasibility determination for the period from January 1, 1980 through December 31, 1983 pending full 

assessment of the available post-1979 data. NIOSH is continuing to evaluate the feasibility of 

sufficiently accurate dose reconstruction for the period from January 1, 1980 through December 31, 

1983. 

NIOSH-Proposed Class to be Added to the SEC 

Based on its full research, to date, of the class under evaluation, NIOSH has defined a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes all Atomic Weapons Employees who worked at the facility owned by Nuclear 

Metals Inc. (or a subsequent owner) in West Concord, Massachusetts during the period from October 

29, 1958 through December 31, 1979, for a number of work days aggregating at least 250 work days, 

occurring either solely under this employment or in combination with work days within the 

parameters established for one or more other classes of employees included in the Special Exposure 

Cohort. The class under evaluation was accepted (see Section 3.0 below) because radiation doses 

potentially incurred by members of the proposed class may not have been adequately monitored 

through personal monitoring or through area monitoring. The NIOSH-proposed class does not 

comprise the entire evaluated class because: (1) the Department of Labor has recently determined the 
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start of Atomics Weapons Employer operations at the Nuclear Metals, Inc. Concord, Massachusetts 

site to be October 29, 1958; and (2) NIOSH is still evaluating information gained during recent data 

capture efforts for the years post-1979. NIOSH believes the availability of breathing zone data 

starting in 1980, along with increased bioassay monitoring beginning in the late 1970s, may impact 

post-1979 dose reconstruction feasibility determinations. Consequently, NIOSH is continuing to 

evaluate the feasibility of sufficiently accurate dose reconstruction for the period from January 1, 1980 

through December 31, 1983 

Feasibility of Dose Reconstruction

Per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it does not have access to 

sufficient information to: (1) estimate the maximum radiation dose, for every type of cancer for which 

radiation doses are reconstructed, that could have been incurred in plausible circumstances by any 

member of the class; or (2) estimate radiation doses of members of the class more precisely than an 

estimate of maximum dose. Information available from the site profile and additional resources is not 

sufficient to document or estimate the maximum internal and external potential exposure to members 

of the proposed class under plausible circumstances during the specified period. 

The NIOSH dose reconstruction feasibility findings are based on the following: 

• Principal sources of internal radiation for members of the proposed class included exposures to 

natural, depleted, and enriched uranium, thorium oxides and metals existing either separately or as 

alloys, and uranium and thorium progeny. The primary modes of exposure were likely inhalation 

and ingestion, with entry through wounds also being possible during the processing of these 

metals. 

• Early operations at the Concord facility consisted primarily of research and development in 

fundamental metallurgy, physical metallurgy, chemical metallurgy, fuel element development and 

manufacture, and high temperature materials. In the mid-1970s, the focus of Concord site 

radiological operations shifted to large-scale production including the manufacture of depleted 

uranium shields, counter weights, and armor penetrators; the manufacture of metal powders 

including thorium; and continued reactor fuel development. 

• Internal exposure monitoring data available to NIOSH include: 

o urine bioassay results for most years in the evaluation period except 1968, 1972, and 1975 

(with the number of urinalysis results increasing dramatically from 1978 through 1983);

o approximately 500 lung counting results beginning in 1982; 

o summary air data for the pre-1975 period giving only maximum, minimum, and average 

air concentrations; and 

o 28,000 breathing zone and work area air sample results during the period 1980 through 

1983. 

• NIOSH has been unable to obtain sufficient internal monitoring data specific to enriched uranium, 

thorium, uranium progeny, or thorium progeny for the period through December 1979 and is 

continuing to evaluate available data for the period 1980 through 1983. Consequently NIOSH has 

determined that it does not have access to sufficient personnel monitoring, workplace monitoring, 

or source term data to estimate with sufficient accuracy internal exposures to enriched uranium, 
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thorium, uranium progeny, and thorium progeny, for Nuclear Metals, Inc. workers during the 

period from October 29, 1958 through December 31, 1979. NIOSH found that it may be feasible 

to reconstruct internal doses from natural and depleted uranium for employees during the 

recommended SEC period from October 29, 1958 through December 31, 1979, using available

claimant and site monitoring data, and information in established procedures such as Site Profiles 

for Atomic Weapons Employers that Worked Uranium Metals, Battelle-TBD-6000. 

• Principal sources of external radiation for members of the proposed class included exposures to 

gamma and beta radiation associated with handling and working in proximity to natural, depleted, 

and enriched uranium and thorium oxides and metals existing either separately or as alloys. The 

modes of exposure were direct radiation, submersion in potentially-contaminated air, and exposure 

to contaminated surfaces.

• External monitoring data available to NIOSH consist of film badge and thermoluminescent 

dosimeter results covering the entire operational period under evaluation. NIOSH has determined 

that reconstruction of external doses, including occupational medical doses, is likely feasible for 

the period from October 29, 1958 through December 31, 1983. 

• Pursuant to 42 C.F.R. § 83.13(c)(1), NIOSH determined that there is insufficient information to 

either: (1) estimate the maximum radiation dose, for every type of cancer for which radiation 

doses are reconstructed, that could have been incurred under plausible circumstances by any 

member of the class; or (2) estimate the radiation doses of members of the class more precisely 

than a maximum dose estimate.

• Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed 

at Nuclear Metals, Inc. during the period from October 29, 1958 through December 31, 1979, but 

who do not qualify for inclusion in the SEC, may be performed using these data as appropriate. 

Health Endangerment Determination

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is required because 

NIOSH has determined that it does not have sufficient information to estimate dose for the members 

of the proposed class. 

NIOSH did not identify any evidence supplied by the petitioners or from other resources that would 

establish that the proposed class was exposed to radiation during a discrete incident likely to have 

involved exceptionally high-level exposures. However, evidence indicates that some workers in the 

proposed class may have accumulated substantial chronic exposures through episodic intakes of 

radionuclides, combined with external exposures to gamma, beta, and neutron radiation. 

Consequently, NIOSH has determined that health was endangered for those workers covered by this 

evaluation who were employed for at least 250 aggregated work days either solely under this 

employment or in combination with work days within the parameters established for one or more 

other SEC classes. 
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Table of Contents

1.0 Purpose and Scope ........................................................................................................................ 11

2.0 Introduction .................................................................................................................................. 11

3.0 SEC-00195, Nuclear Metals, Inc. Class Definitions .................................................................... 12

3.1 Petitioner-Requested Class Definition and Basis ................................................................ 12

3.2 Class Evaluated by NIOSH ................................................................................................. 13

3.3 NIOSH-Proposed Class to be Added to the SEC ................................................................ 14

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ........................................................... 14

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 15

4.2 ORAU Technical Information Bulletins (OTIBs) ............................................................... 15

4.3 Facility Employees and Experts .......................................................................................... 15

4.4 Previous Dose Reconstructions ........................................................................................... 16

4.5 NIOSH Site Research Database .......................................................................................... 17

4.6 Documentation and/or Affidavits Provided by Petitioners ................................................. 17

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 18

5.1 Nuclear Metals, Inc. Plant and Process Descriptions .......................................................... 18

5.1.1 Operations (1958-1972) ........................................................................................... 21

5.1.2 Operations (1972-1979) ........................................................................................... 22

5.1.3 Health Physics Program Practices and Inspections ................................................. 27

5.2 Radiological Exposure Sources from Nuclear Metals, Inc. Operations .............................. 29

5.2.1 Internal Radiological Exposure Sources from Nuclear Metals, Inc. Operations .... 29

5.2.1.1 Uranium .................................................................................................... 29

5.2.1.2 Thorium .................................................................................................... 29

5.2.1.3 Radon/Thoron ........................................................................................... 30

5.2.1.4 Recycled Uranium .................................................................................... 30

5.2.2 External Radiological Exposure Sources from Nuclear Metals, Inc. Operations ... 30

5.2.2.1 Photon ....................................................................................................... 31

5.2.2.2 Beta ........................................................................................................... 33

5.2.2.3 Neutron ..................................................................................................... 34

5.2.3 Incidents .................................................................................................................. 34

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 35

6.1 Available Nuclear Metals, Inc. Internal Monitoring Data ................................................... 35

6.1.1 Urine Bioassay Data ................................................................................................ 35

6.1.2 Air Monitoring Data ................................................................................................ 41

6.1.3 In Vivo Counting Bioassay Data .............................................................................. 43

6.1.4 Surface Contamination Data .................................................................................... 44

6.2 Available Nuclear Metals, Inc. External Monitoring Data .................................................. 45

6.2.1 Personnel Monitoring .............................................................................................. 45

6.2.2 Area Monitoring ...................................................................................................... 47
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7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 48

7.1 Pedigree of Nuclear Metals, Inc. Data ................................................................................. 48

7.1.1 Internal Monitoring Data Pedigree Review ............................................................. 48

7.1.2 External Monitoring Data Pedigree Review ............................................................ 49

7.2 Evaluation of Bounding Internal Radiation Doses at Nuclear Metals, Inc. ........................ 50

7.2.1 Evaluation of Bounding Process-Related Internal Doses ........................................ 51

7.2.1.1 Urinalysis Information and Available Data .............................................. 51

7.2.1.2 Lung Counting Information and Available Data ...................................... 52

7.2.1.3 Airborne Levels ........................................................................................ 52

7.2.2 Methods for Bounding Internal Dose at Nuclear Metals, Inc. ................................ 53

7.2.3 Internal Dose Reconstruction Feasibility Conclusion ............................................. 53

7.3 Evaluation of Bounding External Radiation Doses at Nuclear Metals, Inc. ....................... 54

7.3.1 Evaluation of Bounding Process-Related External Doses ....................................... 54

7.3.1.1 Personnel Dosimetry Data ........................................................................ 55

7.3.1.2 Area Monitoring Data ............................................................................... 55

7.3.2 Nuclear Metals, Inc. Occupational X-Ray Examinations ....................................... 56

7.3.3 Methods for Bounding External Dose at Nuclear Metals, Inc. ............................... 56

7.3.3.1 Methods for Bounding Operational Period External Dose ....................... 56

7.3.4 External Dose Reconstruction Feasibility Conclusion ............................................ 57

7.4 Evaluation of Petition Basis for SEC-00195 ....................................................................... 58

7.5 Summary of Feasibility Findings for Petition SEC-00195 .................................................. 58

8.0 Evaluation of Health Endangerment for Petition SEC-00195 ...................................................... 60

9.0 Class Conclusion for Petition SEC-00195 ................................................................................... 60

10.0 References .................................................................................................................................... 63

Attachment One: Data Capture Synopsis .............................................................................................. 71

Tables 

Table 4-1: No. of Nuclear Metals, Inc. Claims Submitted Under the Dose Reconstruction Rule ........ 16

Table 5-1: Nuclear Metals, Inc. 1959-1972 and 1983 Workforce Population ...................................... 18

Table 5-2: Nuclear Metals, Inc. Building Details .................................................................................. 20

Table 5-3: Principal Radiation Emissions from Natural Uranium and Short-lived Decay Products .... 32

Table 5-4: Principal Radiation Emissions from Th-232 and its Short-Lived Decay Products ............. 33

Table 6-1: Number of Urinalysis Results by Year (1958-1983) ........................................................... 36

Table 6-2: Alpha Air Sample Results from AEC Studies and Inspection Reports (1959-1974) .......... 41

Table 6-3: Number of Air Samples by Year (1980-1983) .................................................................... 43

Table 6-4: Lung Count Results by Year (1982-1986) ........................................................................... 44

Table 6-5: Nuclear Metals, Inc. Dosimeter Program ............................................................................ 45

Table 6-6: Nuclear Metals, Inc. Number of Badges per Year ............................................................... 46
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Table 7-1: Summary of Feasibility Findings for SEC-00195 ............................................................... 59

Figures 

Figure 5-1: Diagram of Nuclear Metals, Inc. ........................................................................................ 21

Figure 6-1: Number of Urinalysis Results by Year at Nuclear Metals, Inc. ......................................... 37
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SEC Petition Evaluation Report for SEC-00195

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: 

Edward D. Scalsky, Oak Ridge Associated Universities. The rationales for all conclusions in this 

document are explained in the associated text.

1.0 Purpose and Scope

This report evaluates the feasibility of reconstructing doses for all employees who worked at the 

Nuclear Metals, Inc. facility in West Concord, Massachusetts, during the period from January 1, 1958 

through December 31, 1983. It provides information and analyses germane to considering a petition 

for adding a class of employees to the congressionally-created SEC. The Department of Labor (DOL)

has recently determined the start of Atomic Weapons Employer (AWE) operations at the Nuclear 

Metals, Inc. Concord, Massachusetts site to be October 29, 1958 (DOL, 2012). For completeness, this 

report does include information on Nuclear Metals, Inc. operations prior to October 29, 1958, even 

though such operations are not included in any SEC recommendations for the facility in Concord, 

Massachusetts.

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83, 

and the guidance contained in the Division of Compensation Analysis and Support’s (DCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, DCAS-PR-004.1

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

reconstructions.2 

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

 

1 DCAS was formerly known as the Office of Compensation Analysis and Support (OCAS).

2 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas.
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sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose.

 

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, then NIOSH must determine that there is a reasonable likelihood that such 

radiation doses may have endangered the health of members of the class. The regulation requires 

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

members of a class when it has been established that the class may have been exposed to radiation 

during a discrete incident likely to have involved levels of exposure similarly high to those occurring 

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

who were employed for at least 250 aggregated work days within the parameters established for the 

class or in combination with work days within the parameters established for one or more other SEC 

classes. 

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioner(s) and the 

Advisory Board on Radiation and Worker Health (Board). The Board will consider the NIOSH 

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.

3

 

3.0 SEC-00195, Nuclear Metals, Inc. Class Definitions 

The following subsections address the evolution of the class definition for SEC-00195, Nuclear 

Metals, Inc. When a petition is submitted, the requested class definition is reviewed as submitted. 

Based on its review of the available site information and data, NIOSH will make a determination 

whether to qualify for full evaluation all, some, or no part of the petitioner-requested class. If some 

portion of the petitioner-requested class is qualified, NIOSH will specify that class along with a 

justification for any modification of the petitioner’s class. After a full evaluation of the qualified 

class, NIOSH will determine whether to propose a class for addition to the SEC and will specify that 

proposed class definition. 

3.1 Petitioner-Requested Class Definition and Basis

Petition SEC-00195 was received on October 20, 2011, and qualified on January 17, 2012. The 

petitioner requested that NIOSH consider the following class: All employees who worked in Buildings 

 

3 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas.
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A, B, C, D, E, the Butler Building, external storage containers, and outside areas immediate to plant 

grounds at the Nuclear Metals, Inc. facility in West Concord, Massachusetts, during the period from 

January 1, 1970 through December 31, 1983.

The petitioner provided information and affidavit statements in support of the petitioner’s belief that 

accurate dose reconstruction over time is impossible for the Nuclear Metals, Inc. workers in question. 

NIOSH deemed the following information and affidavit statements sufficient to qualify SEC-00195 

for evaluation: 

The petitioners indicated there were many unmonitored uranium airborne and external 

exposures. They provided many examples including a video that showed an explosion that 

occurred when workers were passivating the furnace lid during the process of reducing UF4

(green salt) to a uranium metal derby. The petitioners also offered evidence of many 

violations of regulations that showed Nuclear Metals, Inc. failed to perform the surveys 

necessary to assure that employees exposed to airborne uranium-238 and associated alpha, 

beta, and gamma emitting daughters were not exposed to concentrations exceeding those 

specified in 10 C.F.R. Section 20.103 (Supporting Doc, 1974-2006). In addition, the 

petitioners indicated how hazardous the process was for receiving green salt. The green salt 

was supplied in 55-gallon drums weighing approximately 2,000 lbs. Some of the drums 

leaked, spilling green salt over the shop floor and equipment. The drums were emptied, one at 

a time, in a conical blender and mixed with magnesium granules. The mixture was transferred 

to the “bomb”, capped with graphite, and contained in a one-inch thick steel cap bolted to the 

vessel. The petitioners stated that this was a hazardous operation that constantly exposed 

workers to significant airborne contamination (Affidavits, 2011).

Based on its Nuclear Metals, Inc. research and data capture efforts, NIOSH determined that it has 

access to internal and external dosimetry data for Nuclear Metals, Inc. workers during the time period 

under evaluation. However, NIOSH also determined that internal dosimetry records are not complete 

for all time periods or for all radionuclides. NIOSH concluded that there is sufficient documentation 

to support, for at least part of the requested time period, the petition basis that internal radiation 

exposures and radiation doses may not have been adequately monitored at Nuclear Metals, Inc., either 

through personal monitoring or area monitoring. The information and statements provided by the 

petitioner qualified the petition for further consideration by NIOSH, the Board, and HHS. The details 

of the petition basis are addressed in Section 7.4. 

3.2 Class Evaluated by NIOSH

Based on its preliminary research, NIOSH expanded the petitioner-requested class because NIOSH 

determined that work from a DOE site, the Hood Building in Cambridge, Massachusetts, was likely 

transferred to the Nuclear Metals, Inc. site in Concord in 1958, and such work warranted a NIOSH 

evaluation beginning in 1958. NIOSH designated the time period of the class to be evaluated to be 

consistent with the move of operations from the Hood Building to the Nuclear Metals, Inc. new 

facility at 2229 Main Street Concord, Massachusetts in 1958. Therefore, NIOSH defined the 

following class for evaluation: All employees who worked at the Nuclear Metals, Inc. facility in West 

Concord, Massachusetts, during the period from January 1, 1958 through December 31, 1983. The 

January 1, 1958 start date corresponded with the AWE period start date listed in the DOE Office of 

Health, Safety and Security facility database.
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3.3 NIOSH-Proposed Class to be Added to the SEC

Based on its research of the class under evaluation, NIOSH has defined a single class of employees for 

which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSH-proposed class 

to be added to the SEC includes all Atomic Weapons Employees who worked at the facility owned by

Nuclear Metals Inc. (or a subsequent owner) in West Concord, Massachusetts during the period from 

October 29, 1958 through December 31, 1979, for a number of work days aggregating at least 250 

work days, occurring either solely under this employment or in combination with work days within 

the parameters established for one or more other classes of employees included in the Special 

Exposure Cohort. 

Notes: The DOL has determined that the period from January 1, 1958 through October 28, 1958 is 

not included in the covered AWE designation for the Nuclear Metals, Inc., Concord, 

Massachusetts facility (DOL, 2012). 

As explained further in Section 7 of this report, NIOSH has determined that the information 

gained during recent data capture efforts warrant further analysis for the years post-1979. 

NIOSH believes the availability of breathing zone data starting in 1980, along with increased 

bioassay monitoring beginning in the late 1970s, may impact post-1979 dose reconstruction 

feasibility determinations. Because the continuing analysis affects only post-1979, NIOSH 

has determined that it is appropriate to proceed with the pre-1980 feasibility evaluation while 

continuing to analyze the impact that the data have on post-1979 dose reconstruction. 

NIOSH is therefore reserving its full assessment of the available post-1979 data and will 

continue to evaluate the feasibility of sufficiently accurate dose reconstruction for the period 

from January 1, 1980 through December 31, 1983. 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class

As is standard practice, NIOSH completed an extensive database and Internet search for information 

regarding Nuclear Metals, Inc. The database search included the DOE Legacy Management 

Considered Sites database, the DOE Office of Scientific and Technical Information (OSTI) database, 

the Energy Citations database, and the Hanford Declassified Document Retrieval System. In addition 

to general Internet searches, the NIOSH Internet search included OSTI OpenNet Advanced searches, 

OSTI Information Bridge Fielded searches, Nuclear Regulatory Commission (NRC) Agency-wide 

Documents Access and Management (ADAMS) web searches, the DOE Office of Human Radiation 

Experiments website, and the DOE-National Nuclear Security Administration-Nevada Site Officesearch. Attachment One contains a summary of Nuclear Metal, Inc. documents. The summary 

specifically identifies data capture details and general descriptions of the documents retrieved.

In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

numerous data sources to determine information relevant to determining the feasibility of dose 

reconstruction for the class of employees under evaluation. This included determining the availability 

of information on personal monitoring, area monitoring, industrial processes, and radiation source 

materials. The following subsections summarize the data sources identified and reviewed by NIOSH. 
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4.1 Site Profile Technical Basis Documents (TBDs) 

A Site Profile provides specific information concerning the documentation of historical practices at 

the specified site. Dose reconstructors can use the Site Profile to evaluate internal and external 

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

individual monitoring data. A Site Profile consists of an Introduction and five Technical Basis 

Documents (TBDs) that provide process history information, information on personal and area 

monitoring, radiation source descriptions, and references to primary documents relevant to the 

radiological operations at the site. The Site Profile for a small site may consist of a single document. 

Although there is not a specific Site Profile for Nuclear Metals, Inc., as part of NIOSH’s evaluation

detailed herein, it examined the following TBD for insights into Nuclear Metals, Inc. operations or 

related topics/operations at other sites: 

• Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, Battelle-TBD-6000; 

Rev. 1; June 17, 2011; SRDB Ref ID: 101251 

4.2 ORAU Technical Information Bulletins (OTIBs) 

An ORAU Technical Information Bulletin (OTIB) is a general working document that provides 

guidance for preparing dose reconstructions at particular sites or categories of sites. NIOSH reviewed 

the following OTIBs as part of its evaluation:

• OTIB: Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium and Thorium 

Compounds, ORAUT-OTIB-0024; April 7, 2005; SRDB Ref ID: 19445

• OTIB: Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures, ORAUTOTIB-0006, Rev. 03 PC-1; December 21, 2005; SRDB Ref ID: 20220

• OTIB: Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-rays 

Administered Off Site, ORAUT-OTIB-0079, Rev. 00; January 1, 2011; SRDB Ref ID: 89563

4.3 Facility Employees and Experts

To obtain additional information, NIOSH interviewed eight former Nuclear Metals, Inc. employees. 

Interviewee selection was based on individual availability and the potential knowledge of Nuclear 

Metals, Inc. working conditions during the period under evaluation. Information obtained during the 

interviews contributed to the general knowledge of Nuclear Metals, Inc. conditions and monitoring 

practices. 

• Personal Communication, 2012a, Documented Communication with a Plant Engineer; Telephone 

Interview by ORAU Team; March 5, 2012, 10:00 AM EST; SRDB Ref ID: 111249 

• Personal Communication, 2012b, Documented Communication with a Plant Engineer; Telephone 

Interview by ORAU Team; March 8, 2012, 3:30 PM EST; SRDB Ref ID: 111248

• Personal Communication, 2012c, Documented Communication with a Plant Manager; Telephone 

Interview by ORAU Team; March 8, 2012, 10:00 AM EST; SRDB Ref ID: 111247
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• Personal Communication, 2012d, Documented Communication with a Machine Operator; 

Telephone Interview by ORAU/NIOSH Team; March 7, 2012, 2:00 PM EST; SRDB Ref ID: 

111246

• Personal Communication, 2012e, Documented Communication with a REP Machine Operator; 

Telephone Interview by ORAU Team; March 27, 2012, 12:00 PM EST; SRDB Ref ID: 114279

• Personal Communication, 2012f, Documented Communication with a Senior Health Physicist; 

Telephone Interview by ORAU Team; April 17, 2012, 2:00 PM EST; SRDB Ref ID: 114280

• Personal Communication, 2012g, Documented Communication with a Health Physics Technician; 

Telephone Interview by ORAU Team; March 27, 2012, 9:00 AM; SRDB Ref ID: 114281

• Personal Communication, 2012h, Documented Communication with a Foundry Worker; 

Telephone Interview by ORAU Team; March 26, 2012, 11:00 AM; SRDB Ref ID: 114282 

In addition to the eight interviews conducted, three worker outreach meetings were held in Concord, 

Massachusetts on March 14 and March 15, 2012. The meetings consisted of a presentation and 

discussion-type format. Approximately 50 former workers and owners of the company attended these 

meetings. Significant insight into the operations and potential problems were identified and 

discussed. 

4.4 Previous Dose Reconstructions

NIOSH reviewed its NIOSH DCAS Claims Tracking System (referred to as NOCTS) to locate

EEOICPA-related dose reconstructions that might provide information relevant to the petition 

evaluation. NIOSH reviewed each claim to determine whether internal and/or external personal 

monitoring records could be obtained for the employee. Table 4-1 summarizes the results of this 

review. (NOCTS data available as of August 7, 2012) 

Table 4-1: No. of Nuclear Metals, Inc. Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 23

Total number of claims submitted for energy employees who worked during the period under 

evaluation (January 1, 1958 through December 31, 1983) 19

Number of dose reconstructions completed for energy employees who worked during the period

under evaluation (i.e., the number of such claims completed by NIOSH and submitted to the 

Department of Labor for final approval). 16

Number of claims for which internal dosimetry records were obtained for the identified years in the 

evaluated class definition 15

Number of claims for which external dosimetry records were obtained for the identified years in the 

evaluated class definition 18
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4.5 NIOSH Site Research Database

NIOSH also examined its Site Research Database (SRDB) to locate documents supporting the 

assessment of the evaluated class. One thousand six hundred twenty documents in this database were 

identified as pertaining to Nuclear Metals, Inc. These documents were evaluated for their relevance to 

this petition. The documents include historical background on locations, licenses, process 

descriptions, radiological training, hazards associated with uranium, external dosimetry monitoring 

data, air sample data, urinalysis data, lung counts, medical program, and the radiological control 

program. 

4.6 Documentation and/or Affidavits Provided by Petitioners

In qualifying and evaluating the petition, NIOSH reviewed affidavits as well as multiple supporting 

documents submitted by the petitioners. Brief descriptions and summaries are provided below: 

• Ten Affidavits from Former Nuclear Metals, Inc. Workers; various dates and multiple versions 

with extensive support documentation (e.g., reports, statements, photographs, movie clip, contract 

numbers, newsletters); DSA Ref IDs: 115097, 115105, 115107, 115119, 115557, 115558, 

115640, 115703, 116321, 116322, 116553, 116554, 116561, 116574, 116737, 116930, 116931, 

117078, 117079

• Various Atomic Energy Commission, Nuclear Regulatory Commission, and Nuclear Metals, Inc. 

Documents Describing Site Health and Safety Inspection Violations, Necessary Corrective 

Actions, On- and Off-Site Contamination Problems, and Archival Documents; multiple authors; 

multiple dates; DSA Ref ID: 115098

• South Carolina Administrative Law Proceedings in 2002; filed on June 27, 2002; DSA Ref ID: 

115115

• Dumping on History: A Radioactive Nightmare in Concord, Massachusetts, article that details the 

burial of 3,800 drums of radioactive waste; Ed Ericson, Jr.; Jan-Feb 2004; DSA Ref ID: 115113, 

pdf pp. 9-10 

• Uranium Movement at the Nuclear Metals, Inc./Starmet Site Concord, Massachusetts, 2000 report 

of the isotopic content of the holding basin at Nuclear Metals, Inc.; Radioactive Waste 

Management Associates; September; DSA Ref ID: 115113, pdf pp. 13-25

• Nuclear Metals, Inc. Claim Statistics, reconstructed from employee and claimant interviews; DSA 

Ref ID: 115099

• A List of Prior Nuclear Metal, Inc. Employees, contact information was obtained from September 

13, 2000 Starmet (Nuclear Metals, Inc.) employee list; DSA Ref ID: 115111

• Limited List of Contracts Awarded to Nuclear Metals, Inc.; DSA Ref ID: 115110

• Nuclear Metals, Inc. Unmonitored Exposure Matrix Summary, summary includes dates ranging 

from 1967 through 1983; DSA Ref IDs: 115703, pdf pp. 30-35 and 116303
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5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH

The following subsections summarize both radiological operations at the Nuclear Metals, Inc. site

from January 1, 1958 through December 31, 1983, and the information available to NIOSH to 

characterize particular processes and radioactive source materials. From available sources NIOSH has 

gathered process and source descriptions, information regarding the identity and quantities of each 

radionuclide of concern, and information describing processes through which radiation exposures may 

have occurred and the physical environment in which they may have occurred. The information 

included within this evaluation report is intended only to be a summary of the available information. 

5.1 Nuclear Metals, Inc. Plant and Process Descriptions 

Nuclear Metals, Inc. was located at 2229 Main Street, Concord, Massachusetts, on 30 acres of land 

during the evaluated time period, but later expanded to 46.4 acres of land in 1990 when Nuclear 

Metals purchased adjacent properties from the Memorial Drive Trust (MDT) (MACTEC, 2004). For 

the period evaluated by NIOSH, the Nuclear Metals, Inc. workforce, based on various contracts held 

during different times, varied from approximately 60 to over 650 workers. The number of employees 

decreased during the period from 1960 through the mid-1970s. The number of employees (obtained 

from various inspection reports) increased rapidly starting in the latter half of the 1970s, peaking 

around 1982 through 1983 to over 650. Table 5-1 shows the Nuclear Metals, Inc. workforce 

population from 1959 through 1972. In the years not represented in the table below, NIOSH has 

found no indication regarding the number of employees per year. However, an inspection report for 

August 1983 states “The NMI workforce has doubled in recent years to a present strength of 654 

employees.”

Table 5-1: Nuclear Metals, Inc. 1959-1972 and 1983

Workforce Population

Month and Year No. of 

Employees SRDB Ref ID

October 1959 275 25090, pdf p. 48

October 1960 350 25090, pdf p. 70

July 1961 250 25090, pdf p. 74

January 1962 165 25090, pdf p. 80

September 1962 167 25090, pdf p. 88

October 1963 156 25090, pdf p. 96

February 1964 154 25090, pdf p. 98

August 1964 167 25090, pdf p. 101

October 1964 163 25090, pdf p. 104

May 1965 143 25090, pdf p. 106

November 1965 135 25090, pdf p. 114

May 1966 128 25090, pdf p. 119

July 1970 100 109544, pdf p. 6

July 1971 80 105866, pdf p. 6

July 1972 50 105867, pdf p. 4

August 1983* 654 112167, pdf p. 5

Note: 

* The number of employees between 1972 and 1983 has not been identified.
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Nuclear Metals, Inc work evolved from the Massachusetts Institute of Technology (MIT) 

Metallurgical Laboratory, which began experimental work on producing uranium metal in the spring 

of 1942 using a process involving melting and casting. This work continued from 1942 through 1946, 

at which time the work performed under Manhattan Engineer District (MED) contracts was relocated 

to the Hood Building in Cambridge, Massachusetts. The MED, and subsequently the Atomic Energy 

Commission (AEC), owned the Hood Building which was located adjacent to the MIT campus. In 

1954, Nuclear Metals Inc. was established and assumed the work that MIT had been performing in the 

Hood Building. Operations at the Hood Building continued until October 29, 1958, when the work 

was again relocated to Concord, Massachusetts. The Hood Building was acquired by the General 

Services Administration (GSA) for disposition when it was declared surplus to government needs. 

The GSA turned the building over to the Department of Health, Education, and Welfare, which, in 

turn, deeded the property to MIT with the proviso that the property be used for educational purposes 

and MIT pay for the demolition (MIT, 1963). The Hood building was subsequently demolished after 

which it was released by the AEC on July 11, 1963 (DOE, 2010). 

On August 29, 1957, Nuclear Metals purchased approximately 30 acres of undeveloped property and 

constructed and occupied the original Concord facility buildings by March 1958 (MACTEC, 2004, 

pdf p. 21). The information available to NIOSH associated with the March 1958 occupancy date is 

limited to a Health and Safety Plan document produced by a SUPERFUND contractor (MACTECH, 

2004). NIOSH has no further information specifying whether or not radioactive materials could have 

arrived on the Concord site from the Hood Building facility prior to March 1958. Although Nuclear 

Metals, Inc. occupied the Concord Facility buildings in March 1958, there are indications that 

operations did not begin until October 1958 (Monitoring, 1955-1966, pdf p. 39). The start date for 

AWE operations at the Concord facility is determined by DOL to be October 29, 1958 (DOL, 2012). 

In a letter to NIOSH, DOL states “... Nuclear Metals was legally a DOE contractor between July 1, 

1954 and October 28, 1958 due to the AEC's ownership of the Hood Building. Nuclear Metals only 

became an AWE when it left the Hood Building for Concord, MA, on October 29, 1958.” 

The original facility consisted of three principal buildings, designated as Buildings A, B, and C. 

Building A contained office space and research laboratories. Building B contained services (e.g., 

cafeteria, laboratories, etc.). Building C was initially configured for use as the main production 

facility and included foundry equipment for melting metals, extrusion presses, metal working 

equipment, pickling and etching tanks, and electroplating equipment (MACTEC, 2004, pdf p. 21). 

Later, additional buildings were added. Table 5-2 lists the main buildings at Nuclear Metals, Inc., as 

well as each building’s year of construction, physical dimensions, type of structure, and a brief 

description of the building’s function. 
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Table 5-2: Nuclear Metals, Inc. Building Details

Building Year 

Constructed

Dimensions

(ft)

Area

(ft2)

Structure 

Type Building Function

A 1958 216 x 80 x 26 34,000 2 story Building A was used for office space, 

laboratory work, and quality control.

B 1958 97 x 60 x 26 11,130 2 story

Initially Building B contained the boiler 

room, which serviced the entire 

complex, electrical switch room, 

telephone entrance room, toilets and 

locker rooms, and the company clinic.

C 1958 200 x 130 x 26 26,000 1 story with a 

mezzanine

Building C housed the foundry, which 

was the heart of all the processes that 

were involved in the production of 

depleted uranium (DU) penetrators and 

most of the other work.

D 1978 280 x 160 x 26 44,800 High Bay, 

1 story

Building D was built to expand the 

production capability and housed the 

copper removal/pickling operation, long 

rod straightening, outgas/solution heat 

treatment, aging, re-machining, quality 

control, and finish machining.

E 

1983

Occupied in 

1984

200 x 223 x 20 39,300 High Bay, 

1 story

Building E included closed-loop 

pickling, resource recovery area, waste 

treatment and recovery, acid splitting, 

coolant recovery, quality control, and 

waste processing.

Butler 1 1958 64 x 32 1,800 Pre-engineered

Butler Building 1 was unrestricted and 

used for non-DU related purposes. 

However Butler 1 had previously been 

used for packing and storing DU 

components.

Butler 2 1960 64 x 32 1,800 Pre-engineered Butler Building 2 was unrestricted and 

used for non-DU related purposes. 

Butler 3 1976 60 x 40 2,400 Pre-engineered Butler Building 3 was used for storing 

DU components.

Butler 4 1977 80 x 60 4,800 Pre-engineered Butler Building 4 was unrestricted and 

used for non-DU related purposes. 

Tank 

House 1958 Not stated 1,200 2-level slab on 

grade

The Tank House was used for receipt of 

process-contact water which was 

received and then gravity fed into two 

3,700 gallon, diked, wooden-cypress 

tanks. This process-contact water was 

ultimately pumped into the resource 

recovery unit in Building E. 

Source: ACI, 1994, pdf p. 20
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Figure 5-1 shows a diagram of the Nuclear Metals, Inc. facility. 

Figure 5-1: Diagram of Nuclear Metals, Inc.

Source: ACI, 1994, pdf p. 26, with enhanced text

The Concord, Massachusetts site was originally a specialty metal research and development facility 

that was licensed to possess low-level radioactive substances. After 1972, Nuclear Metals, Inc. 

developed a manufacturing orientation. Building D was constructed in 1978 to expand the production 

capabilities of the facility. Building E was constructed in 1983 and occupied in January 1984 and was 

used to house the radioactive waste-processing operations (MACTEC, 2004, pdf p. 22). 

In 1990, Nuclear Metals, Inc. acquired adjacent properties designated as Parcels A and B from the 

Memorial Drive Trust (MDT), which owned land to the west and south of the Nuclear Metals, Inc. 

property. At the same time, MDT acquired Lots C and D from Nuclear Metals, Inc. The Nuclear 

Metals, Inc. property then consisted of approximately 46 acres (MACTEC, 2004, pdf p. 22). On 

October 1, 1997, Nuclear Metals, Inc. changed its name to Starmet Corporation (Quinn, 2001, pdf p. 

13). 

5.1.1 Operations (1958-1972)

In the beginning of operations, after the transfer to Concord, operations consisted primarily of 

research and development in fundamental metallurgy, physical metallurgy, chemical metallurgy, 

engineering and product development, fuel element development and manufacture, and high 

temperature materials (MACTEC, 2004, pdf p. 29). Many, if not all of these operations were carried 
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over from the work at the Hood Building. Most of the operations at the Concord site were for the 

United States Atomic Energy Commission (AEC) and the Department of Defense (DOD). Additional 

activities were completed for private industry in the investigation and development of materials for 

missiles, airframes, and other components. Examples of the operations performed at the Hood 

Building and transferred to the Concord site are presented below; non-radiological operations are 

included here for completeness only (MACTEC, 2004, pdf p. 29).

• Conducting studies of the causes of brittleness in beryllium. 

• Determining the original phase diagrams for alloys of uranium-beryllium, zirconium, hafnium, 

tungsten and other special metals. 

• Alloying uranium for specific properties, including corrosion resistance and high stress-rupture 

characteristics. Similar studies were conducted to achieve higher strength in beryllium.

• Using unique techniques for testing and evaluating fuel elements and fuel-element materials.

• Developing high-strength zirconium alloys for use as cladding on fuel elements.

• Conducting electroplating studies. 

• Conducting basic studies of corrosion in zirconium and uranium alloys, and the oxidation 

mechanism for zirconium.

• Learning the effects of liquid-metal environments on zirconium and uranium alloys.

• Developing cermets, including beryllium-beryllium oxide and stainless steel-uranium oxide. 

• Developing original methods of chemical analysis for various constituents in beryllium, uranium, 

and zirconium alloys. 

• Conducting oxidation studies of graphite, platinum, and refractory metals. 

• Developing and fabricating inter-metallic compounds of uranium. 

• Developing melting and casting techniques for beryllium and uranium alloys. 

• Developing machining methods for uranium, thorium, beryllium, yttrium, and other metals.

• Performing technical and economic evaluation of proposed reactor-fuel types and fabrication 

procedures. 

• Submarine reactor fuel elements.

• Producing fuel elements for several different reactors at National Laboratories.

• Developing methods of extrusion and drawing seamless molybdenum tubing and molybdenum 

tubing clad inside and out with other metals such as stainless steel.

• Developing extrusion methods for niobium and tantalum. 

• Investigating materials and design problems in nose-cone reentry studies, with particular emphasis 

on the use of materials in combination. 

5.1.2 Operations (1972-1979) 

In the mid-1970s, the focus of Concord site operations shifted from research and development to 

large-scale production. Large-scale production included the manufacture of depleted uranium (DU) 

shields, counter weights, and armor penetrators; the manufacture of metal powders, beryllium and 

beryllium alloy-parts production; and the manufacture of specialty titanium parts. Reactor fuel 

development, which began at the MIT facilities in the 1940s, also continued during this period. The 

following is a summary of some of the processes conducted at Nuclear Metals, Inc. and are included 

because they are all potential sources of exposure.
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Process Descriptions by Building

Below is a general description of the processes within the individual buildings of Nuclear Metals, Inc. 

at the Concord site. 

Building A

Building A was used for office space, laboratory work, and quality control. About 60 percent of the 

building was built as laboratory space for analytical chemistry, chemical metallurgy, physical 

metallurgy, metallography, applied physics, and a glass shop. The laboratories included vacuum 

furnaces, induction heating, machine shop, X-Ray equipment, electromagnets, and traditional 

laboratory equipment. Building A is connected to Building B (MACTEC, 2004, pdf p. 33). 

Building B

Originally, Building B was completely unrestricted with no activities related to DU (ACI, 1994, pdf p. 

11). Building B contained the boiler room, which serviced the entire complex, electrical switch room, 

telephone entrance room, toilets and locker rooms, and the company clinic. Portions of Building B 

were converted for other uses during facility operations. Building B is connected to Building A and 

Building C (MACTEC, 2004, pdf p. 33). 

Building C 

Building C housed the foundry, which was the heart of all the processes that were involved in the 

production of DU penetrators and most of the other work performed by Nuclear Metals, Inc. at the 

Concord site. 

Foundry Operations-Melting and Casting

A DU melt typically consisted of one DU derby weighing approximately 600 kg, approximately 200

kg DU recycle and titanium metal sponge. As an option, a melt charge could consist of 100% 

approved DU recycle. The charge was melted under vacuum in a zirconia-coated graphite crucible. 

The coating prevented reaction between the molten uranium and graphite. Following a hold at 1400o

C to uniformly distribute the titanium in the alloy, the melt was poured into yttria-coated molds. One 

melt produced nine ingots. Upon removal from the molds, ingots were inspected for surface quality 

and length. Major equipment used in this process included induction furnaces, cleaning stations, and 

various sawing equipment (ACI, 1994, pdf p. 12). 

Billet Assembly

Ingots were assembled into airtight copper cans and evacuated prior to extrusion. Each ingot was 

checked for surface condition, ingot-to-can fit, and melt-lot identification. The ingots were then 

slipped into lengths of copper tube blocked at one end. A copper endplate equipped with an 

evacuation tube was welded onto the open end. The evacuation tube was then connected to a vacuum 

system and each billet assembly was evacuated. The evacuation tube was then crimp-sealed to form a 

leak-tight assembly (ACI, 1994, pdf p. 12). 

Extrusion Operations 

Extrusions were accomplished in a 1,400 ton Loewy extrusion press. Billets were loaded into ovens 

and maintained at 600o C for one hour minimum prior to extrusion. Dies and liner assemblies were 

preheated to 370o C. The die was lubricated and the billets were pushed through the die at a constant 

ram speed. Immediately upon exiting the extrusion press, each rod was automatically transferred to a 
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forced/air/water mist cooling bed. Major equipment used in this process included a 1,400 ton press, 

billet and cooling furnaces, and a bar handling system (ACI, 1994, pdf pp. 12-13).

Building D

Building D was built to expand the production capability and housed the copper removal/pickling 

operation, long rod straightening, outgas/solution heat treatment, aging, re-machining, quality control, 

and finish machining. 

Copper Removal/Pickling Operation 

The copper sheath on the extruded bars was removed by acid digestion in a sulfuric acid-hydrogen 

peroxide solution. The acid solution was pumped into Building E where it was regenerated by 

electorwinning the copper and precipitation of UO4. The closed-loop pickling system was the only 

major component used in this operation. 

Long Rod Straightening 

After removal of the copper sheath, extruded rods were straightened using a Sutton Rotary 

Straightener (two-roll) to facilitate subsequent cutting operations. The “straightener” guides and rolls 

were set such that the work piece would transit along the “pass line” and proper deflection was 

provided to achieve the desired straightened end product. The rod stock was cut into blanks of 

appropriate length by sawing. After an initial crop to remove front extrusion imperfections, a front 

chemistry sample was cut and identified. Blanks were cut and identified in sequence until finally no 

material remained of sufficient length to yield a blank. A rear chemistry sample was then cut and 

identified. The major piece of equipment used in this process was the Sutton Rotary Straightener

(ACI, 1994, pdf p. 14). 

Outgas/Solution Heat Treatment

Solution heat treatment of DU blanks was carried out in a multi-step operation involving: 

• Outgas

• Rotary Straighten

• Solution/Quench 

• Rotary Straighten

Blanks up to 32 inches in length could be vacuum outgassed in an AVS vacuum solution heat-treat 

furnace which had been modified for this purpose. The blanks were heated to 850o C under vacuum 

and held for sufficient time to ensure a hydrogen content of less than one part per million. The blanks 

were then cooled under vacuum into the alpha temperature range (500-700o C) and then rapidly 

cooled to ambient temperature (ACI, 1994, pdf p. 15). 

Some distortion occurs during outgassing. In order to facilitate the next induction heat-treat step, each

blank was rotary straightened under minimal stress conditions. Induction solution heat treatment was 

accomplished in a vertical induction unit. Blanks were fed at a controlled rate through an induction 

coil where they were heated to a surface temperature in air of 950-1000o

 C. The blanks were then 

progressively quenched in agitated water. Additionally an automated induction furnace was in place 

that would ensure a continuous flow of parts as production quantities increased. Having been 

quenched into water, some distortion of the blanks would have occurred. All blanks were again 
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straightened using predetermined parameters. Major equipment used in this process included 

outgassing furnaces, a rotary straightener, degreaser, and a horizontal induction unit (ACI, 1994, pdf 

p. 15). 

Aging

All DU blanks were aged in recirculating inert-gas furnaces. Time-temperature parameters were 

selected to achieve the mechanical properties required. Two recirculating inert-gas furnaces were 

used in this operation (ACI, 1994, pdf p. 15). 

Pre-Machining

Finish machining required a precision pre-machined blank with a uniform diameter and flat ends 

perpendicular to the bar axis. These requirements were met by centerless grinding to the desired 

finished diameter. The ends were faced flat and perpendicular to the bar axis (ACI, 1994, pdf p. 16). 

Finish Machining 

DU penetrator blanks were turned into their final configuration on Computer Numerical Control 

(CNC) lathes. All feeds, speeds, and depths of cut were commensurate with production requirements 

(ACI, 1994, pdf p. 16). 

Quality Control 

Quality Control Inspectors supported large-caliber DU penetrator programs in Building D through a 

number of processes including: selection of mechanical test bars after aging runs, laser marking of DU 

bars and finished penetrators, in-process inspection and measurements and inspection of DU bars, and 

final inspection of finished penetrators. Equipment utilized during Quality Control operations 

included a laser marker, various comparators, gauges, run-out fixtures, and ancillary support 

equipment (ACI, 1994, pdf p. 16). 

Building E

Closed-Loop Pickling, Resource Recovery Area 

In Building D copper clad was removed from extruded-uranium rod stock by etching a 5% (by 

volume) sulfuric acid solution using hydrogen peroxide as the oxidant. After the copper was removed 

from the rod stock, the solution was transferred to electrowinning in Building E for electrolytic 

recovery of copper and concurrent regeneration of sulfuric-acid value. The acid solution was then 

recycled back for additional copper removal after the addition of hydrogen peroxide to remove 

residual uranium. The slurry, containing gypsum and precipitated uranyl peroxide, was separated by 

filtration and then disposed of in an approved land burial site. The filtrate, containing the copper, was 

transferred to electrowinning for copper recovery and recycle (ACI, 1994, pdf p. 17). 

Waste Treatment and Recovery

Waste liquors, which consisted of floor-wash waters, steam-cleaning water, closed-loop pickling rinse

water, and other waste-process waters, were collected in two tanks for storage. The waste waters were 

then transferred to the Waste Water Treatment areas where lime and acid were added to agglomerate 

residual oils and adjusted the pH of the solution to 5. The resultant slurry was allowed to thicken and 

was then filtered to remove the solids. The liquid solution was then oxidized with hydrogen peroxide 

and neutralized to a pH above 7 (between 9.7 and 7.5). The neutralized liquor was then evaporated in 

the pulse combustion dryer, where the steam produced was exhausted into the atmosphere after the 
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solids separation and HEPA filtration. The solids (including the filter cake) were collected and 

packaged for disposal in an approved burial site (ACI, 1994, pdf p. 18). 

Acid Splitting

Oil-bearing aqueous liquors, such as machine coolant and steam-cleaning water, were treated by 

adding sulfuric acid and aluminum sulfate. The liquor was then allowed to settle and the oil fraction, 

which floats to the surface, was removed. The liquor was neutralized to a pH of 8.5 to allow the 

aluminum to react to form aluminum hydroxide, which agglomerated any residual oil remaining in the 

liquor. After settling, the aqueous phase was removed and the agglomerated solids were removed. 

The oils and agglomerated solids were then transferred to waste processing for solidification and 

subsequent disposal (NSWC, 1997, pdf p. 18).

Coolant Recovery 

Machine coolant was treated to remove tramp oil and solids by allowing it to settle and then 

separating the oil from the fine solids by centrifuge. The oil was transferred for acid splitting and the 

solids transferred to waste processing for disposal. The treated coolant was monitored to ensure high 

quality and additional coolant concentrated pH adjusters and other additives were added as required. 

The coolant was then recycled back to machining. 

Quality Control 

The Quality Control Laboratory, Calibration Laboratory, Bond Room holding area, final inspection, 

and offices were located in Building E. The first floor of the Quality Control Laboratory contained 

inspection equipment, including equipment for powder analyses, hardness testing, tensile testing, 

radiography, helium-leak testing, and all forms of final inspection. Outside of the main Quality 

Control Laboratory was equipment for performing ultrasonic inspection and hardness testing of DU 

bars. The Quality Control Calibration Laboratory was contained in an environmentally controlled 

enclosure. Adjacent to the Calibration Laboratory was a fenced-in area for the Quality Control Bond 

Room where non-conforming material was temporarily stored. This area was also used for 

refurbishing DU aircraft counterweights (ACI, 1994, pdf p. 19). 

Waste Processing

Decontamination systems and waste-processing systems were located in Building E. 

Decontamination systems included a water-blasting booth, composed of a skid-mounted 20,000 psig, 

100 HP unit, with walk-in-booth 16’(L) x 12’(W) x 8’(H). It was used for concrete surface cleaning 

and cutting, surface coating removal, and with abrasive slurry, the ability for cutting up a 2” thick 

metal plate. Other systems included a detergent cleaning tank, 4’(L) x 4’(W) x 3’(H), 1⁄2 HP, 

centrifugal pump with spray bars, locally fabricated, for less aggressive cleaning of small parts, an 

acid etching tank, 120 gallon capacity, used with H2SO4 and H2O2 solution, locally fabricated, for 

aggressive cleaning of metal objects and inaccessible surfaces (e.g., threaded holes, etc.), a steam 

cleaner (for light cleaning, grease removal, etc.), and a portable scarifyer (for light cleaning of 

concretes slabs and asphalt). Other waste-processing equipment included a cutting and grinding 

booth, 8’(L) x 8’(W) x 9’(H), fully ventilated into a HEPA filtration system, locally fabricated. A 

band saw and acetylene cutting torch were also utilized for initial preparation and scrap material 

sizing. The dry, active waste was processed utilizing a dual-drive shredder and various compactors. 

Machine coolant and oils were processed using a solidification pan-type mixer with ventilation at the 

reaction chamber and a five-gallon capacity. The processing of pyrophorics via encapsulation was 
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accomplished by using a ring mill pulverizer (with spray bars, reservoir, and pumping), a cement 

mixer (with 40 ft3 capacity), a skip hoist, and a dust control unit. The encapsulation line also utilized 

an unbagging station for opening sand and cement bags and cement molds (a cylindrical split-form 

type designed by Nuclear Metals, Inc.) as well as a cement vibrator and a cement mixer. In addition 

to the standard waste-packaging techniques this area also housed a bulk bag-filling station with dust 

control venting (ACI, 1994, pdf p. 19). 

Butler Buildings

Butler Building 3 was used for storing DU components. Butler Buildings 1, 2, and 4 were 

unrestricted and were used for non-DU related purposes, although Butler Building 1 had previously 

been used for packing and storing DU components (ACI, 1994, pdf p. 20). 

Tank House

The Tank House was used for receipt of process-contact water, which was received and then gravity 

fed to two 3,700 gallon, diked wooden cypress tanks. This process-contact water was ultimately 

pumped into the resource recovery unit in Building E (ACI, 1994, pdf p. 20). 

Powder Manufacturing

Metals were converted to powder by the Rotating Electrode Process (REP) equipment. A bar of metal 

was rotated in a helium-filled chamber where it was melted by an electric arc. As the metal was 

liquefied, it spun off and solidified into a powder. Metals used included aluminum, steel, titanium, 

and nickel-based super alloys. These powders were used in the photocopier industry, electronic 

component cleaning mediums, and for surgical implants. Thorium rods were also used in this process. 

Fuel Manufacturing

Work with enriched uranium (EU) for fuel was conducted at Nuclear Metals, Inc. from 1958 until 

August 1973, although fuel work continued with natural uranium after 1973. Work producing DU 

penetrators started in the early 1960s; however, full production work started in the mid-1970s and 

continued throughout the period evaluated for this class. There were also several hundred to 

thousands of applications for DU, such as counterweights for aircraft, sheet metal for protection of 

tanks from armor-piercing bullets, sinkers and shaped charges for the oil industry, etc. 

5.1.3 Health Physics Program Practices and Inspections

As indicated above, Nuclear Metals, Inc. was involved in research in many aspects of metallurgy, 

materials development, and new product development. In many instances it was necessary to develop 

new methods and procedures to accomplish their mission. In performing those functions they were 

often unaware of the radiological hazards they might encounter or the effort that would be required to 

work in a radiological environment. As a result, it took many years for their radiological safety 

program to evolve. The program deficiencies are documented in the various inspection reports by the 

regulatory agencies (e.g., Inspection Report, Dec1973-Jan 1974, pdf pp 5-7) (Inspection Report, 

March 1973, pdf pp 6-7). 

The quality of the contamination monitoring and control programs appears to have degraded after the 

mid-1960s. There were problems with spills and contaminations. The inspection report from 

February 10, 1964, noted that a significant uranium spill was found on the floor (Monitoring, 1955-

1966, pdf p. 98). The workers were aware of the spill but did not report it to the Safety Department. 
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The AEC inspection report dated May 1, 1973, noted that lack of trained HP personnel and lack of a 

routine program for surveys for personnel and contamination was a shortcoming (Inspection Report, 

Dec1973-Jan1974). A February 15, 1974, inspection report noted that a significant amount of 

undetected beta-gamma contamination existed in the work area (Inspection Report, Dec1973-

Jan1974). Management was unable to guarantee that employees always changed clothes before 

leaving the plant. Inspectors revisited the plant and visited employees’ homes and found 

contamination (Inspection Report, Dec1973-Jan1974, pdf p. 24).

As an example of a practice that resulted in the spread of contamination, the petitioners stated that 

during the period from 1973 through 1975 there were no restrictions for entering the process area. 

The volume of DU increased after 1974, but the Health & Safety practices did not change. The 30-

mm Ammunition Factory was set up on the 2nd floor of the H-shaped Building B; and the DU chips 

were collected on carts, wheeled down the hallway and down the elevator. No effort was made to 

decontaminate the cart. Chip dust was embedded in the floor. 

The Nuclear Metals, Inc. radiological program developed slowly, and in 1981 the inspection report 

from the Massachusetts Department of Labor and Industries (Inspection Report, Dec1981) stated “The 

Radiation Safety Program has been strengthened in keeping with the Company's continued growth. 

The Health Physics staff has been augmented. A full time Training Specialist has been employed and 

is used to provide orientation training to new employees, particularly in the area of Radiation Safety. 

Health Physics personnel devote an increased percentage of their time in the work areas reviewing 

procedures and surveilling work habits of employees.” 

The report continued “The number of stationary air monitoring systems has been increased in the 

foundry and reduction areas. Evaluation of the air samples and area wipes are now performed inhouse, thereby eliminating or reducing the delay attending previous off-site processing and reporting.” 

Nuclear Metals, Inc. continued to improve their program as documented in the January 4-5, 1983 

inspection report (Inspection Report, Jan1983, pdf pp. 2-3). Nuclear Metals, Inc. augmented their HP

staff by six technicians in order to achieve HP coverage during all operating shifts. They hired an 

industrial hygienist and a health physicist. The Employee Training program was expanded in 1982 in 

terms of the coverage relative to the radiation protection procedures and practices. In addition to the 

orientation training for new employees, refresher training was given to all radiation workers at four 

month intervals. Nuclear Metals, Inc. fabricated charge trays for storing derbies between various 

production activities; the shielded trays were provided with 1/4 in. aluminum covers to reduce 

bremstrahlung and served to reduce beta exposures to charge preparation workers in the foundry. 

Nuclear Metals, Inc. required more frequent washing of floors and surveillance to ensure employees 

exiting radiation areas properly surveyed their clothing and shoes. It is expected that these 

improvements in the Health Physics program, which began modestly around 1978-1979 along with 

the increased bioassay, as shown in Table 6.1 and Figure 6.1, are indicative of their improving ability 

to appropriately monitor the personnel and the workplace and to provide sufficient information and 

data adequate to support NIOSH dose reconstructions. 
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5.2 Radiological Exposure Sources from Nuclear Metals, Inc. Operations

The following subsections provide an overview of the internal and external exposure sources for the 

Nuclear Metals, Inc. class under evaluation.

5.2.1 Internal Radiological Exposure Sources from Nuclear Metals, Inc. Operations

Inhalation of airborne contamination during the various processes, inhalation of resuspended 

contamination, and associated ingestion were the primary sources of internal exposure to Nuclear 

Metals, Inc. workers. Various processes mentioned in Section 5.1 were capable of producing airborne 

contamination, thereby subjecting the workers to an internal exposure hazard. In addition, there were 

many fires that were unmonitored and explosions during the pacification of the furnace lid (Furnace 

Explosion, unspecified date).

5.2.1.1 Uranium 

The amount of uranium in the Nuclear Metals Inc. facility at any one time is not known to NIOSH; 

however, according to the Nuclear Metals Inc. 1981 NRC license, they were authorized to have 

2,500,000 kg of DU, 25,000 kg of natural uranium (NMI, 1981), and a maximum of 714 kg EU

(ORNL, 1996) for fuel production in a license issued in November 1964. 

NIOSH has identified information pertaining to the manufacture of highly enriched uranium fuel 

elements; however, these processes are classified and are not discussed in this document. Highly 

enriched uranium (93% enriched U-235) was used in the development of fuel for Argonne National 

Laboratory (Quinn, 2001).

DU was used for manufacturing counterweights to balance control surface movements on commercial 

and military aircraft, balance weights on nose cones and rockets, sinker bars used by well loggers to 

overcome the oil well head pressure when lowering instruments into the hole, and armor penetrators 

for the military.

At the time of the move from Cambridge to Concord in 1958, there was approximately 10 tons of 

uranium (natural and enriched) and one ton of thorium in storage at the Hood Building (Monitoring, 

1955-1966, pdf p. 36). 

5.2.1.2 Thorium 

Nuclear Metals, Inc. did work with thorium at MIT and the Hood Building before moving to the 

Concord facility. The work continued at Concord during the period of this evaluation and beyond. As 

indicated previously, one ton of thorium was transferred to Concord from the Hood building in 1958. 

Other work that was performed with thorium included the following: 

• In the 1960s Nuclear Metals, Inc. extruded thorium into rods for British and French companies 

(Thorium, 2012). 

• Thorium rods were converted into powder (Thorium, 2012).

• Nuclear Metals, Inc. extruded thorium powder (Thorium, 2012).
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• Nuclear Metals, Inc. cast thorium into billet size followed by machining, jacketing, extrusion, 

pickling, and machining to REP-24 size (1-inch) (Thorium, 2012). Section 5.1.2 provides a brief 

description of the REP process. 

• Nuclear Metals, Inc. received thorium billets from Tennessee Nuclear Specialties and returned the 

material in powder form or rod stock (Personal Communication, 2012c).

• Nuclear Metals, Inc. manufactured tungsten electrodes for use in REP-2 (Personal 

Communication, 2012c).

NIOSH has not identified the quantity of thorium used in the processes listed above during the period 

of evaluation. 

5.2.1.3 Radon/Thoron 

As indicated above, thorium work continued after the move from the Hood Building to the Concord 

site. There are indications that radon/thoron may have been a concern; however, NIOSH has not 

identified any monitoring data for radon/thoron during the evaluated period. 

5.2.1.4 Recycled Uranium

Fission products may have been present in small quantities due to the use of recycled uranium that 

was part of the uranium used in the production at Nuclear Metals, Inc. There is no evidence that 

monitoring for fission products was performed. However, fission products were not identified in the 

whole-body/chest counts reviewed by NIOSH. NIOSH has established procedures and ratios to 

determine possible exposures to recycled contaminants (Battelle-TBD-6000). 

5.2.2 External Radiological Exposure Sources from Nuclear Metals, Inc. Operations 

Based on information and documentation available to NIOSH, the potential for external radiation 

doses from thorium, uranium, and uranium decay products existed at the Nuclear Metals, Inc. site. 

Although Nuclear Metals, Inc. is best known for the production of DU penetrator rounds, the facility 

was also used to produce reactor fuel elements for the Fermi Test Reactor (CP-5) from the mid-1960s 

until 1974 (Quinn, 2001). Nuclear Metals, Inc. was also licensed to handle thorium and thorium 

oxides. 

Both U-235 and U-238 are primarily alpha-particle emitters. However, U-235 does emit a 185-keV 

photon in 54% of its decays. Most of the external dose from U-238 comes from its short-lived Th234, Pa-234m, and Pa-234 decay products. From an external dose standpoint, the most significant 

radiations from these decay products of U-238 are (1) the 2.29-MeV beta particles from Pa-234m, and 

(2) the photons emitted by Pa-234m with energies as large as 1.926 MeV. 

During casting operations, the decay products of U-238 float to the top surface of the molten metal 

and remain as surface residues (Progress Report, Jul-Dec1952, pdf p. 105). These surface residues 

result in an increased exposure potential because of the high beta and photon energies that are 

 

4 REP-2 is the rotating-electrode process whereby rods of thorium or other metals were turned into powder form. REP-2 is 

just one of the versions of the REP process.
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associated with the Pa-234m and Pa-234 nuclides. The Pa-234 nuclide emits a number of high-energy 

photons and has a specific activity that is approximately 2 × 1015 times larger than the specific activity 

of its U-238 parent (Henderson, 1991). For Pa-234, the percentages of photons with energies of 30 to 

250 keV and 250 keV or more are about 7% and 93%, respectively. For U-238 in equilibrium with its 

short-lived Th-234, Pa-234m, and Pa-234 decay products, the percentages of photons with energies of 

30 to 250 keV and 250 keV or more are about 82% and 18%, respectively. 

In addition to the process materials on hand, Nuclear Metals, Inc. possessed two industrial X-ray units 

and was licensed for up to 40 mCi of unencapsulated Ir-192 for tracer studies and 45 Ci of Ir-192 in 

the form of a film coating a copper thimble. At the time Nuclear Metals, Inc. was transferring 

operations to the West Concord facility, the company possessed only 5 μCi of unsealed Ir-192 and 10 

Ci of Ir-192 film (Monitoring, 1955-1966, pdf p. 42). In January 1960, Nuclear Metals, Inc. acquired 

a 100 kV medical X-ray machine (Monitoring, 1955-1966, pdf p. 52). By July 31, 1960, Nuclear 

Metals, Inc. was using a total of five industrial X-ray production devices. In the X-ray Laboratory 

there were three diffraction X-ray machines: (1) a North American Phillips was operated at 35 kV and 

20 mA; (2) a Norelco machine was operated at 45 kV and 20 mA; and (3) a Picker machine was 

operated at 35 kV and 10 mA. In the Analytical Chemistry Laboratory, a Norelco Spectrometer was 

operated at 50 kV and 40 mA. In the production area, a Norelco Searchray was run at 150 kV and 5 

mA (Monitoring, 1955-1966, pdf p. 60). 

5.2.2.1 Photon 

Nuclear Metals, Inc. workers handled depleted and enriched uranium metals. External exposures to 

photon radiation would have resulted from the immediate daughter radionuclides in the uranium decay 

chain. The uranium progeny that result in the most significant photon exposures include Th-234 and 

Pa-234m (Rad Handbook, 1970). Note that these isotopes have relatively short half-lives and can be 

assumed to be in equilibrium with the parent U-238. Because of their short half-lives, the exposure 

potential from these isotopes would travel with the parent and will not be considered separately.

The majority of the photons from uranium metals are in the 30-250 keV energy range. Solid uranium 

objects provide considerable shielding of the lower-energy photons and harden the spectrum, causing 

the majority of the photons emitted from a solid uranium object (such as a billet or rod) to have 

energies greater than 250 keV. While it is recognized that solid uranium sources will have a hardened 

photon spectrum, exposure to a thin layer of uranium on a surface will result in a larger fraction of 

exposure to lower-energy photons (Battelle-TBD-6000).
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Table 5-3 shows the primary isotopes and photon energies associated with uranium. 

Table 5-3: Principal Radiation Emissions from Natural Uranium and Short-lived Decay Products

Radionuclide Half-life Beta Energy (MeV Max) Photon (x or γ) Energy (MeV)

U-238 4.468 x 109 years None x: 0.013 (8.8%)

Th-234 24.1 days 0.096 (25%) x: 0.013 (9.6%)

0.189 (73%) γ: 0.063 (3.8%)

γ: 0.093 (5.4%)

Pa-234m 1.17 minutes 2.28 (98.6%) γ: 0.765 (0.2%)

~1.4 (1.4%) γ: 01.001 (0.6%)

U-235 7.038 x 109 years None x: 0.013 (31%)

x: 0.090-0.105 (9.3%)

γ: 0.144 (10.5%)

γ: 0.163 (4.7%)

γ: 0.186 (54%)

γ: 0.205 (4.7%)

Th-231 25.5 hours 0.206 (15%) x: 0.013 (71%)

0.288 (49%) γ: 0.026 (14.7%)

0.305 (35%) γ: 0.084 (6.4%)

U-234 244,500 years None x: 0.013 (10.5%)

γ: 0.053 (0.2%)

Notes:

Source: Rad Handbook, 1998

Intensities refer to the percentage of disintegrations of the nuclide itself, not to original parent of series. 

Gamma percentages are given in terms of observable emissions, not transitions.

Thorium has a significant number of higher-energy photons in the Th-232 decay chain. Based on the 

half-lives of the progeny, only a partial equilibrium is possible; therefore, it is conservative to state 

that equilibrium would be reached in this decay chain. It has been assumed that Ra-228 and Th-228 

progeny were in equilibrium with Th-232. Under this assumption, the progeny are the major source 

of both penetrating and non-penetrating external exposure. 
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Table 5-4 shows the primary isotopes and photon energies associated with thorium and its progeny. 

Table 5-4: Principal Radiation Emissions from Th-232 and its Short-Lived Decay Products

Radionuclide Half-life Beta Energy (MeV Max) Photon (x or γ) Energy (MeV)

Th-232 1.405 x 1010 years None 0.059 (0.19%)

0.126 (0.04%)

Ra-228 5.71 years 0.389 (100%) 0.0067 (6 x 10-5%)

Ac-228 6.25 hours 0.983 (7%) 0.338 (11.4%)

1.014 (6.6%) 0.911 (27.7%)

1.115 (3.4%) 0.969 (16.6%)

1.17 (32%) 1.588 (3.5%)

1.74 (12%) ---

2.08 (8%) ---

(+33 more βs) ---

Th-228 1.9116 years

None

0.084 (1.19%)

0.132 (0.11%)

0.166 0.08%)

0.216 (0.27%)

Bi-212 60.55 minutes 1.59 (8%) 0.040 (1%)

2.246 (48.4%) 0.727 (11.8$)

--- 1.620 (2.75%)

Tl-208 3.1 minutes 1.28 (25%) 0.277 (6%)

1.52 (21%) 0.5108 (21.6%)

1.80(50%) 0.583 (85.8%)

--- 0.860 (12%)

--- 2.614 (100%)

Notes:

Source: Rad Handbook, 1998

Intensities refer to the percentage of disintegrations of the nuclide itself, not to original parent of series. 

Gamma percentages are given in terms of observable emissions, not transitions.

5.2.2.2 Beta

Radiation fields from uranium are frequently dominated by contributions from daughter-product 

radionuclides. For example, nearly the entire beta radiation field from DU comes from the daughter 

radionuclide Pa-234m, and to a lesser extent from Th-234. During melting and casting operations 

these daughter elements may concentrate on the surface of the castings and equipment, producing beta 

radiation fields of up to 20 rad per hour. 

Table 5-3 shows the principal beta emitters and their energies for the uranium present at Nuclear 

Metals, Inc. As indicated, there are a significant number of high-energy beta radiations that represent 

a shallow dose exposure concern for site workers. Workers who handled the uranium would have 

received shallow dose exposures. The primary exposure areas would have been the hands and 

forearms, the neck and face, and other areas of the body that might not have been covered. 
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5.2.2.3 Neutron 

Neutrons were not measured at Nuclear Metals, Inc. and were not expected to be a source of exposure 

for the class under evaluation. However, neutrons could arise from the α-n reaction with light 

elements (e.g., beryllium and fluorine), interactions with the oxides, and through spontaneous fission. 

According to Battelle-TBD-6000, uranium oxides would be the most common generators of (α,n) 

reactions. The intensity of the radiation field from these reactions increases as a function of the 

enrichment. However, quenching and brushing off the rods would minimize this source of neutrons. 

Spontaneous fission yields and (α,n) yields in oxides are provided in Table 3.5 of Battelle-TBD-6000. 

The significance of each of these sources of neutrons may be evaluated using the methods described in 

ORAUT-OTIB-0024, Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium 

and Thorium Compounds (see Section 7.3 of this report). 

5.2.3 Incidents

NIOSH did not identify any documented accidents at the Nuclear Metals, Inc. site that resulted in 

exceptionally high personnel exposure levels (i.e., such as a criticality event). However, small fires, 

material spills, and loss of contamination control occurred throughout the plant. There are petitioner 

references to many unmonitored fires and airborne exposures (Affidavit, 1970-1983). The employees 

were not monitored by personal air monitors and workers were not wearing personal protective 

clothing. An incident report dated September 17, 1981, states that a green salt spill occurred in the 

Reduction Area. Personal air monitors and respirators were issued (Incident, 1981-1984, pdf pp. 6-7).

There were problems with spills and contaminations. The inspection report from February 10, 1964, 

noted that a significant uranium spill was found on the floor (Monitoring, 1955-1966, pdf p. 98). The 

workers were aware of the spill but did not report it to the Safety Department. The AEC inspection 

report dated May 1, 1973, noted that lack of trained HP personnel and lack of a routine program for 

surveys for personnel and contamination was a shortcoming (Inspection Report, Dec1973-Jan1974). 

A February 15, 1974, inspection report noted that a significant amount of undetected beta-gamma 

contamination existed in the work area (Inspection Report, Dec1973-Jan1974). Management was 

unable to guarantee that employees always changed clothes before leaving the plant. Inspectors 

revisited the plant and visited employees’ homes and found contamination (Inspection Report, 

Dec1973-Jan1974, pdf p. 24).

In April 1981, a probable overexposure of an individual to airborne concentration of DU took place 

(Incident, 1981, pdf p. 3). The problem was first recognized by high urinary concentration of DU 

(935 μg/L) in a urine sample taken on April 6, 1981. The NRC document states that the worker was a 

recent hire who had been grinding and polishing DU and that the ventilation on the grinding machine 

had not been working properly for some period of time prior to the April 6th sample. A whole-body 

count on the individual was performed in October 1981. In the internal NRC letter from the Materials 

Radiological Protection Section to the Materials Safety Section, dated December 8, 1981, a request 

was made to evaluate the health significance of concentration of uranium in worker urine exceeding 

the licensee’s guide of 120 micrograms per liter (Monitoring, 1981b). On December 30, 1981, NRC 

contracted a consultant to evaluate the health significance of this intake (Incident, 1981, pdf p. 2).
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6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH

The following subsections provide an overview of the state of the available internal and external 

monitoring data for the Nuclear Metals, Inc. class under evaluation.

6.1 Available Nuclear Metals, Inc. Internal Monitoring Data

Discussed below are the available bioassay, air monitoring, lung count, and surface contamination 

data that are available to NIOSH. It is uncertain whether NIOSH has captured all existing urinalysis 

data. Information on sample preparation, if any, has not been located. Most of the urinalysis sample 

datasheets indicate that the samples were analyzed for total uranium by fluorometric methods. Some 

samples were analyzed for EU using alpha proportional counters. NIOSH has not identified any 

information related to sample preparation prior to counting. 

6.1.1 Urine Bioassay Data 

This section attempts to present in chronological order the number of urine bioassay samples and, 

where possible, the results or range of results for enriched uranium, uranium, depleted uranium, and 

thorium during the period of evaluation. There is some overlap in the various sections to maintain the 

continuity of the presentation provided in the source documents. 

The bioassay monitoring program was carried over to the Concord facility from the Cambridge 

facility. Urinalysis results for 1968, 1972, and 1975 have not been located. The number of urinalyses 

jumped dramatically from 1978 through 1983 following a DU ammunition contract and a 

recommendation by a Health Physics consultant for monthly sampling starting in the first quarter of 

1978; biweekly sampling starting later that same year.

The inspection report from October 1960 stated that natural uranium was being melted intermittently 

and very little thorium melt work was being performed (Monitoring, 1955-1966, pdf p. 71). Some EU 

work may also have been in progress. Inspectors found that only select groups of workers were 

subjected to periodic urinalysis and some workers were found to be smoking in the work area. After 

the inspection, Nuclear Metals, Inc. added most of the workers to the urinalysis program and banned 

smoking in any radioactive material area. 

The workload was low in April 1961 (Monitoring, 1955-1966, pdf p. 65). Urinalysis was performed 

every six months on production workers and all results were well below allowable concentrations. 

Air sample results were negligible. Workers working closely at the extrusion process with aluminumclad natural uranium were provided with respirators. The October 1961 inspection report 

(Monitoring, 1955-1966, pdf p. 77) stated that urinalysis had not been done for a long time. Nuclear 

Metals, Inc. reduced the urinalysis frequency because of low air activity, but expected to start the 

program in the winter months for personnel records. A wipe test in the production area showed 

activity less than 5 dpm/100 cm2 and a fixed alpha air contamination result showed no activity. 

Early urine samples were analyzed by the AEC New York Operations Office Health and Safety 

Laboratory. Many samples analyzed by the AEC sometimes took several months for the results to be 
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returned. One example indicates the samples were received on May 9, 1958, with the results reported 

on October 15, 1959 (Monitoring 1955-1959, pdf p. 37). A July 1961 inspection report (Monitoring, 

1955-1966, pdf p. 74) stated that urinalysis in the future will be performed by the AEC and partly by a 

private consultant. Later sample results are written on the Nuclear Metals Health and Safety 

Department Medical Sample forms. Examination of datasheets starting September 1974 reveals that 

the urine samples were analyzed by a consulting radiochemist, located in Cambridge, Massachusetts 

(Monitoring, 1974-1977, pdf p. 20). In October 1982, the consultant was replaced by Bolton & 

Galanek, Inc. (Monitoring, 1982, pdf p. 34). 

Table 6-1 and Figure 6-1 indicate the number of urinalysis results by years that were available to 

NIOSH. There are datasheets for 101 urinalysis results, apparently from the mid-1960s, which do not 

include the year that the sampling was performed (Monitoring, 1960-1969, pdf pp. 17-27). There are 

medical sample datasheets for 69 additional urine samples from 1964 (Monitoring, 1960-1969, pdf pp. 

47-51) and datasheets for 67 additional urine samples from 1976 and 1977 (Monitoring, 1973-1977, 

pdf pp. 6-12), but the results have not been found. 

Table 6-1: Number of Urinalysis Results by Year (1958-1983)

Year Uranium Depleted 

Uranium

Enriched 

Uranium Total SRDB Ref ID

1958 15 - - 15 24978, 10512

1959 96 - 24 120 24978, 26863

1960 82 - 38 120 29172

1961 52 - - 52 29172

1962 278 - 4 282 10512, 29172

1963 14 - - 14 10512, 29172

1964 310 - - 310 10512, 29172

1965 144 - - 144 29172

1966 19 - - 19 29172

1967 103 - - 103 29172

1968 - - - - -

1969 10 - - 10 29172

1970 12 - 11 23 28439

1971 11 - - 11 28439

1972 - - - - -

1973 24 - - 24 25057

1974 25 - - 25 25057, 28440

1975 - - - - -

1976 46 - - 46 25057, 28440

1977 136 - - 136 25057, 28440

1978 368 - - 368 29195

1979 837 - - 837 25049, 28442

1980 1,987 - - 1,987 29174

1981 4,020 - - 4,020 29175

1982 6,080 - - 6,080 28443

1983 - 435 - 435 25074

Note:

Cells with a dash (-) indicate that there was no data available for the year specified.
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Figure 6-1: Number of Urinalysis Results by Year at Nuclear Metals, Inc.

Most of the urinalysis samples were analyzed for total uranium by fluorometric methods. Some 

samples were analyzed for EU using alpha-proportional counters. 

Enriched Uranium

The Commonwealth of Massachusetts, Department of Labor and Industries, DOH October 1959 

inspection report (Monitoring, 1955-1966, pdf p. 48) states that urine samples were collected from 

workers handling natural uranium, EU, and beryllium. Approximately 50% of the employees were 

expected to provide urine samples at varying periods during the year. If the employees handled EU or 

beryllium, a urine sample was to be obtained before and after the job exposure. Urine samples were 

also to be collected following an accident. 

The DOH inspection letter dated May 26, 1965, stated that very little work with EU was being carried 

out (Monitoring, 1955-1966, pdf p. 106). Work (CP-5) was being performed with uranium-aluminum 

alloy with 16% to 20% uranium with uranium enriched to 93%. 

In 1968, Nuclear Metals, Inc. completed machining work for 350 gm of U-235 in the form of 

zirconium-uranium oxide (Inspection Report, Jul1968, pdf p. 6). Some work with natural uranium 
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and DU also took place. Work making U-235 shot was planned. U-235 inventory on June 30, 1968 

included: 25,372 gm of contract material (U-235, 75%) and 2,561 gm of U-235 (75%) under SNM-65 

(Inspection Report, Jul1968, pdf p. 9). Records of urinalysis from 1968, if any are available, have not 

been located by NIOSH. 

The AEC inspection report from inspections conducted in December 1969 (Inspection Report, 

Dec1969, pdf p. 2) noted that CP-5 (EU) fuel fabrication was in process. They also identified 

weakness in the Nuclear Safety and Health Physics programs. Nuclear Metals, Inc. failed to collect a 

number of surveys and air samples. All workers who came in direct contact with radioactive material 

were supposed to provide urine samples annually. Sample results were reviewed for January 1969 

through October 1969. The samples that were analyzed by the fluorometric method were all < 5 μg/L. 

The individuals performing the CP-5 fuel element fabrication work were also sampled and the 

samples were analyzed by the radiometric method for U-235. The maximum sample result was 14.4 

dpm/1 (Inspection Report, Dec1969, pdf p. 10). Existing inventory at the time of the inspection was 

19.1 kg (42.1 lbs) of uranium with greater than 75% enrichment; 21,263 lbs (9,645 kg) of DU; zero 

natural uranium; and zero thorium. 

An AEC Inspection Report dated August 5, 1970, stated that Nuclear Metals, Inc. completed work on 

CP-5 fuel in March 1970 (Inspection Report, Jul1970, pdf p. 2). There was no work with special 

nuclear material planned. Work performed was in progress manufacturing DU shielding devices for 

radiography sources. This same inspection report noted that bioassay results for the CP-5 fuel were 

available and that the results showed no problem with internal deposition. At the completion of the 

CP-5 fuel element contract on March 9, 1970, urine samples were collected from eleven personnel 

that had been involved with material handling. A review of the bioassay results revealed that the 

uranium sample result of 308 dpm/L was contaminated. The result of a resample on April 12, 1970 

was 14 dpm/L. The report noted that all personnel working in the facility would be sampled during 

the calendar year 1970. The other sample results were less than 50 dpm/L (Inspection Report, 

Jul1970, pdf p. 10).

Uranium

There were 15 urinalysis results for November and December 1958. 

Urinalysis for uranium was not performed from November 28, 1960 through most of 1961 

(Monitoring, 1955-1966, pdf pp. 78, 92-102). There are records of 49 urinalyses for uranium 

performed in December 1961 (Monitoring, 1955-1966, pdf pp. 92-97). 

Urine samples from all operational workers were collected from September 1962 through November 

1962, and were analyzed for uranium by the AEC Laboratory (Monitoring, 1955-1966, pdf p. 96). 

The average excretion rate was 0.001 mg/L, with the highest being 0.015 and 0.020 mg/L. 

Six sample results from 1965 indicated that the workers were handling uranium and thorium, but the 

samples were analyzed for uranium only. The results were analyzed using the fluorometric method, 

with the high value being 30 μg/L (Monitoring, 1960-1969, pdf p. 46). Starting in 1977, the samples 

were analyzed at Murray M. Bolton Jr. Company for uranium mass and gross beta-gamma activity, 

expressed in dpm. 
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In September 1965, each plant employee was given a urinalysis to determine the excretion rate of 

uranium. With the exception of a few, all results showed an excretion rate of less than 5 μg/L. 

According to the report, a few higher values were found among workers and non-exposed personnel 

such as guards. One guard showed a uranium excretion rate of 35 μg/L. A total of 144 urine sample 

results from 1965 have been located (Monitoring, 1955-1966, pdf p. 114). 

An inspection report of a site visit on August 18, 1964, indicated that urinalysis for uranium had been 

completed for all personnel (154 people were checked). The report stated that one employee (a nurse 

who was not directly exposed) had the highest result of 0.005 mg/L, four employees results wee 0.002 

mg/L, and ten employee results were 0.001 mg/L. The remaining results were below 0.001 mg/L 

(Monitoring, 1955-1966, pdf pgs. 101, 104). 

A job involving 400-500 lbs of thorium for Savannah River was expected. There is a bioassay 

datasheet with six sample entries from June 11, 1965, indicating that the material being handled was 

uranium and thorium, but the samples apparently were only analyzed for uranium. Three samples 

were < 5μg/l, with the other results being 5, 20, and 30 μg/l (Monitoring, 1960-1969, pdf p. 46). 

NIOSH has not found information indicating the possible uranium/thorium ratios of the material.

A total of 12 personnel provided urine samples during the last six months of calendar year 1970. A 

review of the sample analyses records showed that all results were less than 15 dpm/1 (Inspection 

Report, May1971 pdf p. 8). 

An April 1973 AEC inspection report noted 13 violations including failure to monitor for airborne, 

surface, and personnel contamination. Workers were found to be leaving the work area without 

monitoring. The latest entry in the records showed the urine samples were from May 31, 1972 with 

the maximum concentration of 8.4 +/- 2.2 d/m due to uranium. However, the actual results were not 

located by NIOSH (Inspection Report, Mar1973 pdf p. 11). Results of seven urine samples were 

analyzed for uranium in April. The results were analyzed by radiometric methods and reported in α 

dpm/L, which ranged from 3.0 to 8.1 α dpm/L. The same samples were analyzed by fluorometry with 

the results ranging from <1.0 to 6.0 μg/l. Another ten urine samples were analyzed in December. 

However, the December sample results do not identify what the urine samples were analyzed for 

(NIOSH assumes the analyte to be uranium). However, the results ranged from <1.0 to 7.5 μg/l 

(Monitoring, 1973-1977, pdf pp. 2-3).

During the inspection on December 27-29, 1973 the inspector stated: 

 “Examination of bioassay records revealed that seven employees submitted urine samples on 

April 18, 1973 and that eleven employees submitted urine samples on August 23, 1973, all of 

which were analyzed. The maximum results determined by the radiometric method and the 

fluorometric method were 81 and 25 dpm alpha/liter, respectively. The previous urine samples 

were submitted on May 31, 1972. It appears possible, based on the degree of contamination 

control exercised by the licensee, that many of the samples submitted were contaminated. This 

coupled with the inability to determine when an uptake was received, if received, makes it 

apparent that it would be impossible to establish the degree of internal deposition which 

occurred in any case” (Inspection Report, Dec1973-Jan1974 pdf p.21). 

There were a total of 25 uranium urinalysis sample results from 1974 (Monitoring, 1973-1977, pdf pp. 

4-5; Monitoring, 1974-1977, pdf pp. 19-21). Of these 24 samples, three were dated February 28 and 
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ranged from < 5 to 18 +/- 5 dpm/L; 11 samples that were dated September 16 ranged from <1 to 4.5 

μg/L; and the other 11 samples were dated October 2 and ranged from < 1 to 4.8 μg/L. There were 

also three nasal smear results and nine fecal sample results for three workers collected and analyzed 

for uranium and gross beta and gamma from September (Monitoring, 1974-1977, pdf pp. 20-21). 

The urinalysis results from 1975 have not been located. There were a total of 46 urinalysis results 

from 1976 (Monitoring, 1974-1977, pdf pp. 13-16). Most of these results were < 1 μg/L with the 

highest being 2.1 μg/L. There were datasheets from 1976 and 1977 listing 41 names without results 

(Monitoring, 1973-1977, pdf pp. 6 - 12). There were a total of 136 urinalysis results for uranium from 

1977, with most of the results being < 1 μg/L and the highest result being 18 μg/L (Monitoring, 1974-

1977, pdf pp. 2-12). 

In a letter dated November 30, 1978, a health physics consultant stated that he recommended that the 

urinalysis frequency be increased during the first quarter of 1978 to a monthly basis as to check on the 

air sampling program (Levin, 1978, pdf p. 2). Following the analysis, the letter recommended 

increasing the urinalysis frequency for the CNC lathe workers to biweekly. There were a total of 368 

uranium urinalysis results from 1978. These samples spanned the period from May to December and 

represented the frequency recommended by the consultant. A NIOSH inspection of the results 

indicated the months of June, July, August, and December had the highest average results 

(Monitoring, 1978, pdf pp. 2 - 17). 

Depleted Uranium

The principal uranium work in August 1965 was to cast source holders using DU (Monitoring, 1955-

1966, pdf p. 111). Approximately 5,000 lbs of DU was used from January to early August. 

Occasionally there were orders involving normal and EU for manufacturing the prototype fuel 

element. The August 1965 facility visit report (Monitoring, 1955-1966, pdf p. 111) noted that 

urinalysis results had been fairly constant with an average of less than 20 μg/L (Monitoring, 1955-

1966, pdf p. 111). During this timeframe, very little work was done with EU. 

A total of 19 uranium urine sample results were identified from 1966. With the exception of one 

result reported as 50 μg/L, all other results were <10 μg/L. For 1967, 107 urine sample results have 

been found; with all but three samples having results <5 μg/L (Monitoring, 1960-1969, pdf pp. 3-11, 

14-16, 23). Additionally, there are 101 bioassay results from this period without the entry of the year 

the samples were obtained (indications are that the samples are from either 1966 or 1967) 

(Monitoring, 1960-1969, pdf pp. 17-27). 

All 435 samples in 1983 were analyzed for uranium. The sample results were reported in μg/L and 

also in activity in units of μCi/L using the specific activity of depleted uranium (3.6 X 10-7 μCi/μg ) as 

given in Appendix B of 10 C.F.R. 20. Approximately 12% of the samples were over 10 μg/L, of 

which 5 were > 20 μg/L (the highest being 41 μg/L) with the remainder being within the range of 1-10 

μg/L (Monitoring, 1983a, pdf pp. 2-13). 

Thorium

The thorium record for the Colonie Interim Storage Site from July 12, 1962, indicates that it received 

560 lbs of thorium from Nuclear Metals, Inc. (Thorium Receipts, 1959-1962, pdf p. 2, line 12). 
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On June 23, 1970, the Feed Materials Production Center shipped 10,408 kg of thorium nitrate 

tetrahydrate (TNT) to Nuclear Metals, Inc. (Thorium Shipments, 1952-1985, pdf p. 115). 

As noted above relative to uranium sampling: six sample results from 1965 indicated that the workers 

were handling uranium and thorium, but the samples were analyzed for uranium only; and a job 

involving 400–500 lbs of thorium for Savannah River was indicated with bioassay datasheets (June 

1965) indicating that the material being handled was uranium and thorium, but the samples apparently 

were only analyzed for uranium. 

NIOSH has not identified any bioassays for thorium. 

6.1.2 Air Monitoring Data 

The inspection reports by the regulatory agencies from the late 1950s through the mid-1970s refer to 

monthly air sampling and analyses. These inspection reports typically listed only the average and 

maximum concentrations found at various locations within the Nuclear Metals facility. Individual air 

sample datasheets from the period prior to 1980 have not been located. Results of airborne beryllium 

and uranium studies conducted by AEC at Nuclear Metals, Inc. in July 1959 and September 1960 

were found (NMI, 1959, pdf p. 4; NMI, 1960, pdf p. 5). Table 6-2 shows the air sample results from 

the AEC studies and the captured inspection reports. 

Table 6-2: Alpha Air Sample Results from AEC Studies and Inspection Reports

(1959-1974)

Date Concentration (μCi/ml) SRDB 

Average Minimum Maximum Ref ID

3/24/1959 8.00E-13 - 1.00E-12 10505, pdf p. 4

4/28/1960 - - 7.00E-12 25090, pdf p. 57

7/11/1960 4.00E-14 - 1.00E-13 10497, pdf p. 5

7/24/1961 Negligible Negligible Negligible 25090, pdf p. 75

7/7/1961-10/16/1961 - 1.00E-14 9.93E-12 25090, pdf p. 81

5/14/1962-6/14/1962 - 2.00E-13 2.40E-12 25090, pdf p. 89

5/13/1963-7/8/1963 - Negligible 3.70E-13 25090, pdf p. 97

12/24/1964*-2/1/1964 - 1.50E-12 5.30E-12 25090, pdf p. 107

2/1/1964-3/29/1964 - 2.00E-13 1.80E-12 25090, pdf p. 107

8/11/1965 1.00E-13 - 1.80E-13 25090, pdf p. 112

5/28/1965-7/28/1965 - 2.00E-14 2.50E-13 25090, pdf p. 115

2/7/1966-3/24/1966 - 1.00E-14 1.20E-13 25090, pdf p. 120

10/3/1969 1.00E-12 - 2.1E-12 105852, pdf p. 7

9/7/1973 - - 3.00E-12 106825, pdf p. 11

Nov 1973-May 1974 9.00E-14 - - 105872, pdf p. 8

February 1974 - - 1.40E-13 105872, pdf p. 8

Notes: 

Cells with a dash (-) indicate that there was no data available for the date specified.

“Negligible” entries are taken from the documents.

* This appears to be a typo. Most likely this was intended to be 12/24/1963.

An inspection report stated that in 1959 air samples were intended to be obtained during every 

operation involving EU or special jobs involving natural uranium (Monitoring, 1955-1966, pdf p. 48). 

Twelve monitors were located throughout the plant work areas and the paper-filter samples were to be 

changed every two weeks.
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The AEC inspection reports from inspections conducted in December 1969 (Inspection Report, 

Dec1969, pdf p. 7) noted that there were eleven locations in the plant where air samples were 

collected continuously (i.e., 24 hours each day for seven days/week). The samples were to be 

collected and analyzed on a monthly frequency. The inspector further noted that the location of each 

of the in-plant samplers were observed and “the selected locations appear to provide a satisfactory 

general air sample of the work locations.”

A May13-14, 1971 inspection report stated that the fixed-air sampler results for December 1970 were 

a maximum of 1.4 x 10-12 uCi/ml and average of 5 x 10-14

 uCi/ml. For the calendar year, the 

maximum air contamination level was 7 x 10-14 uCi/ml and the average was 3 x 10-14 uCi/ml. 

Contamination survey results were at low levels (Inspection Report, May1971).

In an April 1973 AEC inspection report, the inspector observed that there were two fixed-air monitors 

in the foundry area where DU was processed. One was located above the cubicle (hood) on the 

furnace platform. The other was about 8 ft above the floor at a location that was remote from the area 

in which the source material was processed (Inspection Report, Mar1973, pdf p. 10).

A February 1974 AEC inspection report states that Nuclear Metals, Inc. failed to make surveys 

necessary to assure that employees exposed to airborne uranium-238 and associated alpha, beta and 

gamma-emitting daughters were not exposed to concentrations exceeding those specified in 10 C.F.R. 

§ 20.103, Exposure of Individuals to Concentrations of Radioactive Material in Restricted Areas. 

Specifically, the surveys Nuclear Metals, Inc. conducted did not measure alpha and beta-gamma 

concentrations in workers' breathing zones (Inspection Report, Dec1973-Jan1974, pdf p. 5).

Nuclear Metals, Inc. countered the inspection finding stating: 

“Our method of continuous in plant monitoring as described in our license application has been in 

effect for several years. Our sampling heads are located from six to eight feet above the floor, 

and sample air just above the breathing level of personnel. Program of air monitoring will 

continue, under new schedule/calendar control. Special air samples will be taken during June to 

provide data for correlation with normal sampling stations. This will be done periodically with 

portable air samplers” (Inspection Report, Dec1973-Jan1974, pdf p.10). 

However, the inspector examined the corrective action taken and noted that the air sampling 

performed measured only alpha activity and did not measure workers' breathing zone air (Inspection 

Report, Dec1973-Jan1974, pdf p.10). The inspectors discussed the use of lapel air samplers with the 

licensee.

Use of a lapel air sampler was initiated on April 8, 1974 (Inspection Report, May1974, pdf p. 8). At 

the time of the inspection, the lapel samplers were used on four occasions by workers while 

machining penetrators. The maximum result on lapel was ~1,600 dpm beta-gamma/m3

. 

Air sample results starting from 1980 through 1983 have been located (Monitoring, 1980-1983). The 

total number of breathing zone air sample results found in the database from 1980 through 1983 is 

approximately 15,300. The total in-plant stationary air sample results for the same period is 

approximately 12,800, with the combined total number of air samples of approximately 28,100 for the 

1980 through 1983 period. Table 6-3 shows the number of air samples by year for 1980 through 
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1983. All air samples were analyzed for gross alpha, and nearly all were analyzed for gross beta also. 

No isotopic studies on air samples appear to have been performed. 

Table 6-3: Number of Air Samples by Year (1980-1983) 

Breathing Zone (BZA)

YearButler (B3)CAFCharge PrepCNCFoundryMachine ShopMisc.ReductionRoof1400 Ton PressTOTAL BZAIn-Plant & CAFTOTAL Air Samples

1980 - - - - - - - 1,230 - - 1,230 816 2,046

1981 37 999 - - 1,266 258 - 3,327 78 - 5,965 11,852 17,817

1982 13 1,051 69 - 1,828 809 58 1,775 - - 5,603 145 5,748

1983 131 213 - 45 1,064 - 486 312 157 94 2,502 - 2,502

Note:

Cells with a dash (-) indicate that there was no data available for the location specified.

NIOSH has determined that the information gained during recent data capture efforts warrant further 

analysis for the years post-1979. NIOSH believes the availability of breathing zone data starting in 

1980, along with increased bioassay monitoring beginning in the late 1970s, may impact post-1979 

dose reconstruction feasibility determinations. Because the continuing analysis affects only post1979, NIOSH has determined that it is appropriate to proceed with the pre-1980 feasibility evaluation 

while continuing to analyze the impact that the data have on post-1979 dose reconstruction. 

6.1.3 In Vivo Counting Bioassay Data 

The workers at Nuclear Metals, Inc. were not in vivo counted until 1974. After the discovery of 

contamination on employee cars in 1974, an AEC senior radiation specialist discussed the possibility 

of whole-body counting (there were two whole-body counters located at MIT) those employees with 

potential exposure to airborne concentrations (Knapp, 1974). Nuclear Metals replied that the 

company intended to perform whole-body counting. An apparent AEC note and an AEC inspection 

report stated that five foundry workers who worked with DU were lung-counted on January 18, 1974, 

and the measured activity was at background level (Inspection Report, May1974, pdf p. 9; 

Monitoring, Feb1974). However, the actual in vivo count data and the information on the counting 

instrument have not been located.

Following a discovery of a probable overexposure of an individual to airborne concentrations of DU 

in April 1981, a whole-body count on the individual was performed in October 1981 (Incident, 1981, 

pdf p. 3). The whole-body count showed the presence of 8 mg of DU. The document does not reveal 

where the whole-body count was performed. 

Starting in the summer of 1982, Nuclear Metals brought in a Helgeson Scientific Mobile Whole-Body 

Counter trailer in order to perform lung counting for selected workers. Approximately 500 lung 

counts were taken from 1982 through 1986 by Helgeson Scientific Services. Table 6-4 shows the 

results of the lung counts during this period. NIOSH has located the schedule for the 1982 lung 

counts (Monitoring, 1982-1983). The lung count spectrums were analyzed for U-235, DU, and Th234 (Monitoring, 1982-1983). One employee showed a high count due to short-lived Th-234 and was 
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subjected to work restriction pending investigation. NIOSH has access to 1983 lung count results 

(Monitoring, 1983b; Monitoring, 1982-1985). 

Table 6-4: Lung Count Results by Year (1982-1986)

Year

No. of 

Lung 

Counts

DU (mg) U-235 (μg)

Max Min Ave. STD 

DEV Max Min Ave. STD DEV

1982 103 154.3 1.7 7.5 15.4 83.0 0.0 16.1 23.7

1983 106 11.0 2.0 4.6 1.9 63.0 0.0 5.4 15.2

1984 114 10.3 1.7 4.4 1.8 54.0 0.0 8.1 17.3

1985 78 8.6 2.0 4.6 1.4 74.0 0.0 5.9 17.2

1986 100 32.2 1.9 4.9 3.3 69.0 0.0 1.3 8.8

6.1.4 Surface Contamination Data

The DOH inspection report dated October 27, 1959, stated that contamination surveys were performed 

biweekly at posted stations, and the plan was to perform surveys at 66 stations, some of them daily

(Monitoring, 1955-1966, pdf p. 48). Inspection reports noted that the surface contamination levels 

were low through 1960. The highest monthly wipe test reading was October 18, 1960, at 22 locations 

which showed a highest reading of 68 dpm/100 cm2 (Monitoring, 1955-1966, pdf p. 71). The 

maximum fixed contamination was 750 dpm/100 cm2

. Though the inspection reports noted that 

contamination surveys were performed routinely, individual datasheets have not been located. 

As with urinalysis and air sampling, the quality of the contamination monitoring and control program 

degraded after the mid-1960s. There were problems with spills and contaminations. The inspection 

report from February 10, 1964, noted that a significant uranium spill was found on the floor 

(Monitoring, 1955-1966, pdf p. 98). The workers were aware of the spill but did not report it to the 

Safety Department. 

The AEC inspection report dated May 1, 1973, noted that lack of trained HP personnel and lack of a 

routine program for surveys for personnel and contamination was a shortcoming (Inspection Report, 

Dec1973-Jan1974). A February 15, 1974, inspection report noted that a significant amount of 

undetected beta-gamma contamination existed in the work area (Inspection Report, Dec1973-

Jan1974). Management was unable to guarantee that employees always changed clothes before 

leaving the plant. Inspectors revisited the plant and visited employees’ homes and found 

contamination (Inspection Report, Dec1973-Jan1974, pdf p. 24).

Petitioners stated that during the period from 1973 through 1975 there were no restrictions for 

entering the process area. The volume of DU increased after 1974, but the Health & Safety practices 

did not change. The 30-mm Ammunition Factory was set up on the 2nd floor of the H-shaped 

Building B. The DU chips were collected on carts, wheeled down the hallway and down the elevator. 

No effort was made to decontaminate the cart. Chip dust was embedded in the floor. 
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6.2 Available Nuclear Metals, Inc. External Monitoring Data

Discussed below are the available personnel and area monitoring data that are available to NIOSH.

6.2.1 Personnel Monitoring

Nuclear Metals, Inc. workers received regular film badge service beginning before operations were 

transferred to the Concord facility. External monitoring data available to NIOSH consist of film 

badge results covering the entire operational period under evaluation. Nuclear Metals, Inc. film badge 

service was provided by Tracerlab and Landauer while at the Cambridge facility. Prior to relocating 

to the new facility at West Concord, Nuclear Metals, Inc. switched to film badge service provided by 

Nucleonics Corporation of America (NCA) (Monitoring, 1955-1966, pdf p. 15). Controls for 

Radiation, Incorporated (CRI) were evaluated on a trial basis during this time period (Monitoring, 

1958-1959). In February 1968, Nuclear Metals, Inc. switched to a film badge service provided by 

Landauer, who supplied film badges for the company up through the end of the evaluation period 

(Monitoring, 1966-1967; Monitoring, 1968-1969). Table 6-5 presents the dosimetry program 

information. 

Table 6-5: Nuclear Metals, Inc. Dosimeter Program

Dosimeter 

Type

Dosimeter 

Provider Period of Use Exchange Frequencya

MDSb

(mrem)

Skin Deep

β/γ film NCA 10/01/1958 - 10/26/1959 4 weeks - 10

β/γ film CRI 10/26/1959 - 05/01/1961 6 weeks 10 5

β/γ film NCA 05/01/1961 - 02/07/1968 6.5 weeks - 10

β/γ film Landauer 02/07/1968 - 12/31/1983 4 weeks 10 40

Notes:

The dash (-) indicates that data were not provided. a The exchange frequency was established from dosimetry reports.

b Estimated minimum detectable sensitivity (MDS) typical of film dosimeter capabilities (Monitoring, 1960-

1961; Monitoring, 1961-1962; Monitoring, 1968-1969). 

NIOSH has examined available external records and has determined that not all of the workers in the 

class under evaluation were monitored for external radiation exposure for the entire 1958 through 

1983 period. External dosimetry used at Nuclear Metals, Inc. appears to have targeted professionallevel staff employees who had a known potential for occupational exposure. Beginning in July 1960, 

all plant personnel, including administrative staff, wore film badges (Monitoring, 1955-1966, pdf p. 

60). During this time period, badges were exchanged and processed twice a quarter with the 

exception of the badges worn by administrative staff. Administrative badges were serviced annually 

(Monitoring, 1955-1966, pdf p. 96). Sometime prior to August 9, 1964, the policy shifted toward 

badging all employees except for administrative personnel (Monitoring, 1955-1966, pdf p. 104). 

Table 6-6 provides a summary of dosimeter badges for the evaluated period, 1958 through 1983. 
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Table 6-6: Nuclear Metals, Inc. Number of Badges per Year

Year Number 

of Badges SRDB Ref ID Year Number of Badges SRDB Ref ID

1958 98a 25034 1971 604 25046

1959 341b 25034; 28468 1972 364 25046; 25054

1960 1424 28468 1973 433 25054

1961 1196 25038 1974 451 25054

1962 1071 25037 1975 368 25054

1963 828 25037 1976 462e 25054

1964 979c 25037 1977 811 25054; 25072; 

113268; 113279

1965 1284 25037; 29184 1978 942 25054; 25055

1966 902 25045 1979 2615 25054; 25058

1967 617 25045 1980 4230 25054; 29132; 

113198

1968 312d 25045; 28465 1981 5422 28481; 28483

1969 622 25040 1982 7078 28582; 28584

1970 688 25046 1983 7739 29151; 29154

Notes:

a Records prior to relocation to Concord are not included in this total. b There are missing records for 9/5/1959 through 12/31/1959. c There are missing records for 1/1/1964 through 2/24/1964, 3/30/1964 through 7/6/1964, and 8/19/1964 

through 9/19/1964. d There are missing records for 6/15/1968 through 9/23/1968. This is a transition period from Nucleonic to 

Landauer/Gardray badge service. 

e There are missing records for the month of March. 

In 1981, Nuclear Metals, Inc. initiated the use of a Harshaw TLD badge system, which combined the 

photo identification and a TLD. These TLDs were read in-house on a monthly exchange frequency. 

An NRC Renewal Application states that film badges and extremity badges were issued in addition to 

TLDs for any individuals expected to receive more than 25% of the 10 C.F.R. pt. 20 limits (NMI, 

1981). NIOSH does not currently have access to the in-house TLD records. 

Neutrons 

NIOSH reviewed available Nuclear Metals, Inc. documentation to identify records related to neutron 

exposures. While Nuclear Metals received and processed both depleted and enriched uranium, 

neutron exposures were not identified as a radiological concern by plant personnel either as a 

component of routine plant operations or the external dose monitoring program. The AEC’s 10 

C.F.R. pt. 20 1961 regulations, Sections 20.201 (Surveys) and 20.202 (Personnel Monitoring), only 

generally referred to the need to conduct surveys and provide monitoring devices. No specific 

requirement existed to conduct neutron surveys and track neutron personnel exposures (10 C.F.R. pt. 

20). AEC licensing inspection reports did not cite the lack of routine neutron monitoring as a concern 

or recommend any action in this regard. No radiological monitoring records specifying exposure to 

neutron radiation were identified. 

A technical basis exists to justify the lack of routine neutron monitoring. A NIOSH Hazard 

Evaluation Report for the Portsmouth Gaseous Diffusion Plant, that was cited and discussed in 
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Portsmouth Gaseous Diffusion Plant – Occupational External Dose, assessed neutron dose rates on 

contact and at one meter from high EU (ORAUT-TKBS-0015-6; Cardarelli, post-1996). The report 

explored several radiation exposure scenarios, including different enrichments and worker stay times 

and concluded that, as a percentage of the applicable regulatory dose limits, neutron monitoring was 

unnecessary. 

Because NIOSH did not identify radiological survey records addressing neutron personnel exposures, 

the neutron dose at Nuclear Metals, Inc. will be estimated using other methods. Further discussion is 

provided in Section 7 of this report. 

6.2.2 Area Monitoring

NIOSH identified records addressing the conduct of routine site radiation and contamination surveys 

in clear and contaminated areas of the Nuclear Metals plant. Surveys were required per the plant’s 

Health Physics Manual and licensing requirements (Inspection Report, Jul1970; NMI, 1960; 

Monitoring, 1979-1982; AEC, 1973). Although Nuclear Metals, Inc. policies required the completion 

of biweekly direct-radiation surveys (NMI, 1960), NIOSH has access to only limited survey data. 

A survey of the mezzanine packaging area conducted on September 17, 1979, consisted of 21 

measurements. The highest two measurements of 20 and 25 mR/hr were recorded on the work 

benches. The next highest measurement of 2.0 mR/hr was recorded at a distance of 2 feet from loaded 

material carts (Monitoring, 1979-1982, pdf p. 2). The highest readings from a 1982 area radiation 

survey conducted in the cafeteria were 0.2 mrem/hr for β/γ and 0.08 mR/hr for only gamma 

(Monitoring, 1979-1982, pdf p. 7). A survey of the foundry area conducted in the same year yielded 

maximum readings of 15 mrem/hr for β/γ and 2.5 mR/hr gamma (Monitoring, 1979-1982, pdf p. 9). 

At the request of the NRC, Oak Ridge Associated Universities conducted an environmental survey of 

the site in February 1983. The survey consisted of direct gamma exposure rate measurements

acquired using a sodium iodide scintillator, as well as soil samples taken from on-site and off-site

locations. The maximum exposure rate from the direct gamma surveys was 280 μR/hr. Out of 41 onsite soil samples, the highest concentrations were 2711 pCi/g, 36 pCi/g, and 3.9 pCi/g for U-238, U235, and Th-232, respectively. Eleven additional soil samples were taken near the on-site holding 

basin, resulting in maximum radionuclide concentrations of 628 pCi/g (U-238), 12 pCi/g (U-235), and 

2.8 pCi/g (Th-232). Samples taken offsite resulted in maximum concentrations of 1.4 pCi/g (U-238), 

0.4 pCi/g (U-235), and 1.5 pCi/g (Th-232) (Rocco, 1983). 

NRC compliance investigations suggest that Nuclear Metals, Inc. may not have maintained strict 

adherence to the survey requirements. In 1969, the company was cited for failing to obtain smears of 

designated floor areas on a biweekly or monthly basis (AEC, 1969). In a similar assessment 

conducted in 1973, the assessor noted that surveys were not being properly recorded in logbooks. 

Instead, the survey results were recorded on smear envelopes that were not retained after the samples 

were analyzed and the data recorded in a final report (AEC, 1973). 
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7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH

The feasibility determination for the class of employees under evaluation in this report is governed by 

both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must establish whether 

or not it has access to sufficient information either to estimate the maximum radiation dose for every 

type of cancer for which radiation doses are reconstructed that could have been incurred under 

plausible circumstances by any member of the class, or to estimate the radiation doses to members of 

the class more precisely than a maximum dose estimate. If NIOSH has access to sufficient 

information for either case, NIOSH would then determine that it would be feasible to conduct dose 

reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might assure that NIOSH can estimate either the maximum doses that 

members of the class might have incurred, or more precise quantities that reflect the variability of 

exposures experienced by groups or individual members of the class. This approach is discussed in 

DCAS’s SEC Petition Evaluation Internal Procedures which are available at 

http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation Report examine:

• The sufficiency and reliability of the available data. (Section 7.1) 

• The feasibility of reconstructing internal radiation doses. (Section 7.2) 

• The feasibility of reconstructing external radiation doses. (Section 7.3) 

• The bases for petition SEC-00195 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of Nuclear Metals, Inc. Data

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The 

feasibility evaluation presupposes that data pedigree issues have been settled. 

7.1.1 Internal Monitoring Data Pedigree Review

The available internal monitoring data, based on urinalysis results located by NIOSH, are of sufficient 

quality, but the quantity is insufficient to adequately represent all potential exposures for the class 

under evaluation. As presented in Table 6-1 and Figure 6-1 in Section 6.1, bioassay data for the 
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period under evaluation, except for the years 1968, 1972, and 1975 when little work was being 

performed, have been located. 

NIOSH has not located any bioassay data for thorium. Therefore, an internal monitoring data 

sufficiency and pedigree evaluation is not possible for this data type. 

The urine samples from the beginning of the monitoring period were analyzed by the AEC 

Laboratory. Sample results collected later are either hand-written or typed on Nuclear Medals, Inc. 

medical sample forms. Starting in September 1974, the samples were analyzed by a private 

consultant. These results are presented in printed reports or computer printouts. 

The available urinalysis data from Nuclear Medals, Inc. are original reports, and are therefore primary 

data sources. They are mostly legible and use appropriate reporting units. Therefore, no additional 

pedigree review was performed for those data.

Nuclear Medals, Inc. initiated annual lung counts for approximately 100 select employees starting in 

the summer of 1982. The number of lung counts performed from 1982 through 1986 was 501. 

Helgeson Scientific analyzed the lung count spectrum for U-235, depleted uranium, and Th-234. 

The lung count results from 1982 through 1986 are available in the original Helgeson computer 

printouts, therefore original data. As a result, no additional pedigree review was performed for those 

data.

The AEC inspection reports from the period under evaluation reference air samplers in use and 

presents average air sample results. Fixed-air samplers were located in the plant. Though air sample 

data sheets from 1958 to 1979 have not yet been located, the average alpha sample results extracted 

from the AEC inspection reports from 1959 through early 1974 are summarized in Table 6-2. 

A large number of air sample results from 1980 through 1983 were located. All air samples from 

1980 through 1983 were analyzed for gross alpha, and nearly all were analyzed for gross beta. Like 

urinalysis data, the number of air samples spiked in 1981. 

The air sample data from 1980 through 1983 are contained in original reports, and are therefore 

primary data sources. Therefore, no additional pedigree review was performed for those data. 

 

In summary, internal monitoring data are available to NIOSH, but NIOSH is unable to verify that all 

pertinent data have been located. The quality of the data available to NIOSH is sufficient, but the data 

available to NIOSH do not adequately represent all possible internal dose contributors for the Nuclear 

Metals, Inc. class under evaluation over the entire evaluation period. Minimal thorium-234 specific 

monitoring data (lung counts) have been found by NIOSH. No monitoring data specific to thorium232, thorium progeny, or uranium progeny have been found by NIOSH.

7.1.2 External Monitoring Data Pedigree Review

The external monitoring data, based on film badge dosimetry results, are available in sufficient quality 

to adequately represent the class under evaluation. As mentioned previously, company policy with 

regard to issuance of dosimeters varied between providing dosimetry to all employees and limiting 
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dosimetry to all employees with the exception of administrative staff (Monitoring, 1955-1966, pdf pp. 

60, 104). However, NIOSH has been unable to determine whether the available film badge results 

constitute the entire collection of monitoring data. Limited description of the badging policy is 

available. Therefore, NIOSH is unable to determine the percentage of workers that are represented in 

the available data. With limited exceptions (some reported badge contaminations), no problems were 

reported by the analysis vendor in evaluating the film badges. 

The available external dosimetry data are primary source documents that contain the personnel 

monitoring (film badge) results for individual workers across the site. The data are legible and 

appropriate reporting units were used. For all data available, results are identified by worker names. 

NIOSH believes that the available personnel monitoring data include data that represent the 

maximally-exposed work group and work scenario during the Nuclear Metals, Inc. operational period. 

NIOSH believes that external monitoring data obtained from workers associated with the production 

activities can be used to likely bound external exposures to all members of the class under evaluation. 

In summary, the available external dosimetry monitoring data are available in sufficient quality to 

adequately represent external photon and beta dose for the Nuclear Metals, Inc. class under evaluation 

over the entire evaluation period, but NIOSH is unable to definitively judge the quantity of available 

monitoring data. The dosimetry data are the primary data source that will be used to calculate external 

dose for the Nuclear Metals, Inc. class under evaluation. 

NIOSH did not identify any neutron dosimetry data; therefore, a pedigree review of neutron external 

dosimetry data was not possible. Based on its review of the available information, the potential 

neutron dose was evaluated using guidance contained in ORAUT-OTIB-0024, Estimation of Neutron 

Dose Rates from Alpha-Neutron Reactions in Uranium and Thorium Compounds (see Section 7.3 of 

this report).

7.2 Evaluation of Bounding Internal Radiation Doses at Nuclear Metals, Inc.

The principal source of internal radiation doses for members of the class under evaluation was the 

potential inhalation and ingestion of airborne natural uranium, EU, DU, uranium compounds, and 

thorium by employees directly involved in the foundry, machining, extrusion, welding, grinding, and 

reduction process in making DU derbies. Intake of radioactive material was also possible through 

wounds that may have occurred during the processing of these metals. Other employees were 

potentially exposed to the re-suspension of contamination on surfaces during the course of their work 

with non-radioactive materials, and inhalation of smoke and fumes from fires and explosions 

(Loewenstein, 1954; Incident, 1982a; Incident, 1982b; Incident, 1996). The following subsections 

address the ability to bound internal doses, methods for bounding doses, and the feasibility of internal 

dose reconstruction. 

As indicated in Section 6.1.2 above, NIOSH has determined that the information gained during recent 

data capture efforts warrant further analysis for the years post-1979. NIOSH believes the availability 

of breathing zone data starting in 1980, along with increased bioassay monitoring beginning in the late 

1970s, may impact post-1979 dose reconstruction feasibility determinations. Because the continuing 

analysis affects only post-1979, NIOSH has determined that it is appropriate to proceed with the pre1980 feasibility evaluation while continuing to analyze the impact that the data have on post-1979 

dose reconstruction. NIOSH is therefore reserving its full assessment of the available post-1979 data 
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and will continue to evaluate the feasibility of sufficiently accurate dose reconstruction for the period 

from January 1, 1980 through December 31, 1983. 

7.2.1 Evaluation of Bounding Process-Related Internal Doses

NIOSH located urinalysis data for 23 out of 26 years under evaluation. Except for the initial lung and 

whole-body counts performed in 1974 and 1981, results from the on-site lung counts performed from 

1982 onward, using the on-site lung counter, are found in Helgeson Scientific reports. Air sample 

results from the period prior to 1980 have not been located, but the average and the maximum 

concentrations for the inspection periods from 1959 to 1974, as evaluated by AEC inspectors, are 

available in the inspection reports from that period. 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal doses of members of the class under evaluation.

7.2.1.1 Urinalysis Information and Available Data 

In 1958 when Nuclear Metals, Inc. relocated to the Concord facility, a bioassay program was carried 

over from their Cambridge facility. The number of urinalyses varied year-to-year, but NIOSH has 

only identified urinalysis results for 23 out of 26 years. The number of urinalyses started to increase 

in 1977, and the maximum number of urinalysis results was 6,080 in 1982. The urinalysis program 

also included some on-site contractors. The urine samples were analyzed for uranium, DU, and EU. 

Other categories of workers who may have been exposed to airborne activities were not monitored 

routinely. Although many of the operations conducted with uranium at Nuclear Metals, Inc. were also 

conducted with thorium, none of the urine samples were analyzed for thorium and there is insufficient 

process information to relate potential thorium exposures to known or calculated uranium exposures. 

NIOSH has identified 2,600 uranium urine bioassay results for the twenty-two year period 1958 

through 1979; and 12,500 uranium urine bioassay results for the four year period 1980 through 1983. 

As presented in Section 5.1.3 above, the radiological operations at Nuclear Metals, Inc. prior to the 

1980 era improvements in the Health Physics program resulted in multiple inspection deficiencies and 

incidents. Because of the noted deficiencies in the site radiological controls prior to 1980, NIOSH 

cannot verify that the sometimes sparse urine data available prior to 1980 represent the worst case 

possible exposures at the Concord site during that period. Furthermore, because the urine bioassay 

data for the period 1980 through 1983 represent the period of improving health physics practices at the 

site, NIOSH cannot verify that the preponderance of 1980-1983 data sufficiently represent potential 

uranium intakes that may have occurred during the earlier period of apparently more lax controls 

through 1979. Additionally, NIOSH has identified no urine bioassay specific for thorium. Therefore 

NIOSH has concluded that there is insufficient urinalysis data to support its ability to bound the 

internal dose from enriched uranium, thorium, uranium progeny, and thorium progeny for the period 

from October 29, 1958 through December 31, 1979. NIOSH is continuing to evaluate the adequacy of 

available urine bioassay data for estimating doses beginning in 1980. 
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7.2.1.2 Lung Counting Information and Available Data 

The production rate for DU ammunition was at or near its maximum when Nuclear Metals, Inc.

started to have annual lung counts performed on its production employees in 1982. The measured 

maximum lung burden in a worker was 154.3 mg of depleted uranium and 83.0 ug of U-235 in 1982. 

The highest average lung burden was 7.5 mg of DU, and 16.1 ug of U-235, again in 1982. The lung 

burdens measured after 1982 were substantially lower.

In contrast, the [redacted] workers who were lung-counted at MIT in 1974 were reported to have 

measured activity at background levels, and one [redacted] lung count in [redacted] following a 

suspected overexposure, had a measured activity of 8 mg of DU. Lung counts were only performed 

for 100 or so production workers annually starting in 1982. Workers prior to 1982 and other workers 

who may have been exposed to smoke and fume from numerous fires and explosions and resuspended particles were not monitored. NIOSH has only limited lung count data for the period 1958 

through 1979, and is continuing to evaluate the adequacy of available in vivo bioassay data for 

estimating doses beginning in 1980. NIOSH has concluded that the available lung count data are 

insufficient to support the ability to bound the internal dose from enriched uranium, thorium, uranium 

progeny, and thorium progeny for the period from October 29, 1958 through December 31, 1979.

7.2.1.3 Airborne Levels

In 1958 when Nuclear Metals, Inc. relocated to the Concord facility, Nuclear Metals, Inc.’s principal

work was research and development. The quantities of the materials handled were limited. Nuclear 

Metals, Inc. installed twelve fixed-air samplers in the factory floor for monthly air sampling and 

analysis. The air samples were analyzed for gross alpha and gross beta. The original air sample data 

sheets from prior to 1980 have not been located. However, the maximum and average alpha airsample concentrations for the inspection periods were found in the AEC inspection reports. 

Nuclear Metals, Inc. shifted work from research and development to large-scale production in the 

1970s, manufacturing weights and then DU ammunition for the military. The use of lapel air 

samplers was initiated at this time. With the increase in production, the number of air samples 

increased. NIOSH located over 28,000 fixed- and breathing-zone air sample data from 1980 through 

1983. For the period prior to 1980, NIOSH has only inspection reports by the regulatory agencies 

from the late 1950s through the mid-1970s (see Table 6-2 above). Reports are available for only 31 of 

the 255 months during the period October 1959 through December 1979. Available reports refer to 

monthly air sampling and analyses and typically list only the average and maximum concentrations 

found at various locations within the Nuclear Metals facility. Individual air sample datasheets from 

the period prior to 1980 have not been located. NIOSH has determined that the air monitoring data 

available prior to 1980 are insufficient to support the ability to bound the internal dose from enriched 

uranium, thorium, uranium progeny, and thorium progeny for the period from October 29, 1958 

through December 31, 1979. 

As indicated in Section 6.1.2 above, NIOSH has determined that the information gained during recent 

data capture efforts warrant further analysis for the years post-1979. NIOSH believes the availability 

of breathing zone data starting in 1980, along with increased bioassay monitoring beginning in the late 

1970s, may impact post-1979 dose reconstruction feasibility determinations. Because the continuing 

analysis affects only post-1979, NIOSH has determined that it is appropriate to proceed with the pre1980 feasibility evaluation while continuing to analyze the impact that the data have on post-1979 
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dose reconstruction. NIOSH is therefore reserving its full assessment of the available post-1979 data 

and will continue to evaluate the feasibility of sufficiently accurate dose reconstruction for the period 

from January 1, 1980 through December 31, 1983. 

7.2.2 Methods for Bounding Internal Dose at Nuclear Metals, Inc.

Based on the evaluations presented above, NIOSH has been unable to locate sufficient urine bioassay 

data, lung count data, or air monitoring data adequate to support sufficiently accurate dose 

reconstruction of internal dose from enriched uranium, thorium, uranium progeny, and thorium 

progeny for the period from October 29, 1958 through January 31, 1979. NIOSH has reserved the 

period from January 1, 1980 through December 31, 1983 pending further evaluation of information 

gained during recent data capture efforts. NIOSH found that it may be feasible to reconstruct internal 

doses from natural and depleted uranium for employees during the recommended SEC period from 

October 29, 1958 through December 31, 1979 using available claimant and site monitoring data, and 

information in established procedures such as Site Profiles for Atomic Weapons Employers that 

Worked Uranium Metals, Battelle-TBD-6000. 

7.2.3 Internal Dose Reconstruction Feasibility Conclusion

NIOSH has concluded that it did not locate sufficient data, including bioassay results and air 

monitoring data, to estimate with sufficient accuracy the total internal dose from exposures to 

enriched uranium, thorium, uranium progeny, and thorium progeny during the period from October 

29, 1958 through December 31, 1979. NIOSH found that it may be feasible to reconstruct internal 

doses from natural and depleted uranium for employees during the recommended SEC period from 

October 29, 1958 through December 31, 1979 using available claimant and site monitoring data, and 

information in established procedures such as Site Profiles for Atomic Weapons Employers that 

Worked Uranium Metals, Battelle-TBD-6000. 

NIOSH has determined that the information gained during recent data capture efforts warrant further 

analysis for the years post-1979. NIOSH believes the availability of breathing zone data starting in 

1980, along with increased bioassay monitoring beginning in the late 1970s, may impact post-1979 

dose reconstruction feasibility determinations. Because the continuing analysis affects only post1979, NIOSH has determined that it is appropriate to proceed with the pre-1980 feasibility evaluation 

while continuing to analyze the impact that the data have on post-1979 dose reconstruction. NIOSH is 

therefore reserving its full assessment of the available post-1979 data and will continue to evaluate the 

feasibility of sufficiently accurate dose reconstruction for the period from January 1, 1980 through 

December 31, 1983. 

Although NIOSH found that it is not possible to completely reconstruct internal radiation doses for the 

period from October 29, 1958 through December 31, 1979, NIOSH intends to use any internal 

monitoring data that may become available for an individual claim (and that can be interpreted using 

existing NIOSH dose reconstruction processes or procedures). Dose reconstructions for individuals 

employed at Nuclear Metals, Inc. during the period from October 29, 1958 through December 31, 

1979, but who do not qualify for inclusion in the SEC, may be performed using these data as 

appropriate. 
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7.3 Evaluation of Bounding External Radiation Doses at Nuclear Metals, Inc.

The principal source of external radiation doses for members of the evaluated class was photon and 

beta (electron) radiation associated with AEC operational activities, including handling radioactive

materials during production or research activities. Thorium, uranium metal, and uranium compounds 

from depleted and enriched uranium constituted the principal external radiation dose-producing 

material sources for members of the class. 

As of the date of this evaluation, NIOSH has located individual external monitoring records for 

Nuclear Metals, Inc. employees associated with uranium material processing during the operational 

period under evaluation. Documentation retrieved from the site verifies that an established personnel 

external monitoring program existed for photon and beta radiation exposures, as reflected in the 

individual external monitoring records. Neutron personnel exposures were not tracked as a 

component of the routine external dosimetry program. A suggested approach to likely bound neutron 

dose in lieu of monitoring data is provided in Section 7.3.3.1. 

Employment at Nuclear Metals, Inc. involved routine medical X-ray examinations required as a 

condition of employment; therefore, occupational X-rays are also a source of external radiation dose. 

The following subsections address the ability to bound external doses, methods for bounding doses, 

and the feasibility of external dose reconstruction. 

7.3.1 Evaluation of Bounding Process-Related External Doses

NIOSH has located external monitoring records for beta and gamma radiation for Nuclear Metals 

workers associated with uranium processing during the class period under evaluation. Individual 

dosimetry data for the operational period is the preferred data source for evaluating the external 

radiation doses for members of the Nuclear Metals, Inc. class. As discussed in this evaluation, the 

available personnel monitoring data include data from uranium process workers that represent the 

maximally-exposed work group and work scenario during the Nuclear Metals, Inc. operational period

(NMI, 1959, pdf p. 7; Fire Prevention, unspecified, pdf p. 4; Monitoring, 1955-1966, pdf p. 114). 

NIOSH believes that external monitoring data obtained from workers associated with the production 

activities can likely be used to bound external exposures to all members of the class under evaluation. 

However, no dosimetry data were identified related to potential personnel exposures to neutrons; 

therefore, an approach for bounding neutron doses is provided in Section 7.3.3.1. 

NIOSH will use the appropriate methodology and external uranium dose reconstruction assumptions 

and approach described in Battelle-TBD-6000. NIOSH will also use individual dosimetry data in 

conjunction with this methodology and to validate or adjust any assumptions, as appropriate. The 

monitoring data and methodologies available to NIOSH support its ability to likely bound external 

dose associated with Nuclear Metals, Inc. uranium operations. 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related external doses of members of the class under evaluation.
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7.3.1.1 Personnel Dosimetry Data

NIOSH has located records documenting the implementation of an external monitoring program for 

beta and photon exposure at Nuclear Metals, Inc. A routine external monitoring program for neutron 

exposure did not exist at the site. 

Photon 

The available personnel external monitoring data, in the form of film badges, provide external 

photon/gamma dose information for the personnel working during the operational period at Nuclear 

Metals, Inc. These data can be used to reconstruct dose for members of the class under evaluation. 

While external dosimetry data are not available for all members of the class under evaluation, 

monitoring data do exist for some Nuclear Metals employees within the class being evaluated. As 

discussed in this evaluation, the available personnel monitoring data include data that represent the 

maximally-exposed work group and work scenario during the Nuclear Metals, Inc. operational period. 

NIOSH believes that external monitoring data obtained from workers associated with the production 

activities can be used to likely bound external exposures to all members of the class under evaluation. 

Therefore, NIOSH has concluded that the available personnel monitoring data and information for 

Nuclear Metals, Inc. support its ability to likely bound the photon dose for the class under evaluation. 

Beta

The available personnel external monitoring data, in the form of film badges assigned to workers over 

the operational period, were used to evaluate not only whole-body photon doses, but also workplace 

beta doses. As discussed in this evaluation, the available personnel monitoring data include data that 

represent the maximally-exposed work group and work scenario over the Nuclear Metals, Inc.

operational period. These data are likely sufficient to support bounding beta particle dose for 

members of the class under evaluation, as described in Section 7.3.3.1. 

Neutron 

A routine external monitoring program for neutron exposure did not exist at Nuclear Metals, Inc. 

Rather, the site emphasized administrative and engineering controls to prevent a criticality accident. 

An indium foil (for indication of a neutron exposure from such an accident) was included with worker 

film badges (Fire Prevention, unspecified, pdf p. 4). 

Because a routine monitoring program for neutrons did not exist, NIOSH evaluated several possible 

methods to bound neutron doses. A suggested approach that employs ORAUT-OTIB-0024 is 

provided in Section 7.3.3.1. 

7.3.1.2 Area Monitoring Data

NIOSH identified records addressing the conduct of routine site radiation and contamination surveys 

in both clear and contaminated areas of the Nuclear Metals plant. Surveys were required per the 

plant’s Health Physics Manual and licensing requirements (Inspection Report, Jul1970; NMI, 1960; 

Monitoring, 1979-1982; AEC, 1973). NIOSH does not intend to use these data as the primary source 

of information for the purpose of bounding external dose. However, these data can be used to 

supplement the personnel external dosimetry data and to corroborate the defined bounding approaches 

for the class under evaluation. 
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7.3.2 Nuclear Metals, Inc. Occupational X-Ray Examinations 

NIOSH has indications that Nuclear Metals Inc. employees received on-site annual physical exams 

that included a chest X-ray (Monitoring, 1955-1966, pdf p. 57). These radiographs were taken using a 

Picker X-ray machine and consisted of two views (presumably a lateral view and an anterior-posterior 

view) acquired with exposure times of one-tenth and one-twentieth of a second (Monitoring, 1955-

1966, pdf pp. 60-62). Information presented to NIOSH during worker outreach meetings with 

previous site employees additionally indicated that medical X-ray examinations were also performed 

at local medical facilities. NIOSH has no further data regarding when medical X-ray examinations 

may have been performed on-site versus off-site. Due to the known performance of on-site medical 

X-ray examinations, per ORAUT-OTIB-0079, Guidance on Assigning Occupational X-ray Dose 

Under EEOICPA for X-rays Administered Off Site, NIOSH has determined that it is applicable to 

reconstruct occupational medical X-ray exposures for Nuclear Metals, Inc. workers during the period 

from October 29, 1958 through December 31, 1983. 

Although NIOSH has not located specific parameters associated with these occupational medical 

X-rays (i.e., specific information on the X-ray devices), default values of entrance kerma, developed 

for the three most commonly-used occupational medical diagnostic procedures, are available in 

ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related X-Ray Procedures. These 

values can be used to support bounding the medical X-ray dose for the time period under evaluation. 

These default values are maxima or upper limit values developed from review of patient doses as 

reported in the literature, machine characteristics, and knowledge of X-ray procedures used during 

different time periods. These default values can be used in lieu of actual measurement data or 

entrance kerma derived from technique factors to bound the occupational X-ray exposures for Nuclear 

Metals, Inc. NIOSH believes this methodology supports its ability to bound occupational medical Xray doses (reconstruct the medical X-ray dose with sufficient accuracy) for the class under evaluation. 

Therefore, NIOSH concludes that it is likely feasible to reconstruct occupational medical dose for 

Nuclear Metals, Inc. workers with sufficient accuracy.

7.3.3 Methods for Bounding External Dose at Nuclear Metals, Inc.

There is an established protocol for assessing external exposure when performing dose reconstructions 

(these protocol steps are discussed in the following subsections): 

• Photon Dose 

• Beta Dose

• Neutron Dose 

• Medical X-ray Dose (as applicable per Section 7.3.2) 

7.3.3.1 Methods for Bounding Operational Period External Dose

Photon Dose 

Photon doses can be reconstructed using available film badge summary reports for all years associated 

with the evaluated period. At times, badging extended to all site employees whether in process or 

non-process areas (NMI, 1960, pdf p. 7; Fire Prevention, unspecified, pdf p. 4). At other times, 

badges were only issued to uranium process workers (NMI, 1959, pdf p. 7). Reconstruction of 
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unmonitored photon doses can likely be accomplished using co-worker data distributions and the 

bounding assumptions and applicable protocols specified in various complex-wide Technical 

Information Bulletins.

Beta Dose

Exposures to beta radiation were routinely recorded during the evaluated period as a component of the 

external dosimetry (i.e., film badging) program. NIOSH has not identified any data related to the 

description of the extremity badges.

Estimation of extremity dose would be necessary only if warranted by the specific parameters of an 

individual case. Sufficient dosimetry information exists to likely estimate external doses from this 

radiation type.

Neutron Dose 

Because a routine monitoring program for neutrons did not exist, NIOSH evaluated several possible 

methods to bound potential neutron doses. These methods included consideration of spontaneous 

fission, uranium compound source terms and quantities used at the site, enrichment levels, neutron 

yields from alpha-neutron and spontaneous fission reactions, worker stay times under different 

exposure scenarios, and neutron-to-photon ratios. Due to its low production rate, spontaneous fission 

can be eliminated as a viable dose contributor (Battelle-TBD-6000). 

Because of the alpha-neutron reaction from alpha interactions with light elements, very low neutron 

radiation exposures to unmonitored workers may have occurred in buildings that processed uranium. 

NIOSH has considered the potential source of neutrons resulting from alpha-neutron reactions and 

determined that in the cases where NIOSH needs to apply unmonitored neutron dose for members of 

the class, it can apply the methods approved in ORAUT-OTIB-0024 to support bounding the neutron 

dose. The applicability of this method will be assessed on a case-by-case basis for individual dose 

reconstructions. 

Medical X-ray Dose 

Nuclear Metals, Inc. employees were required to have chest X-rays annually as part of their routine 

physical examination. Although NIOSH has not located specific parameters associated with these 

occupational medical X-rays, default values of entrance kerma, developed for the three most 

commonly-used occupational medical diagnostic procedures are available in ORAUT-OTIB-0006. 

These values can be used to support bounding the medical X-ray dose for the time period under 

evaluation. 

7.3.4 External Dose Reconstruction Feasibility Conclusion 

Due to the availability of external personal monitoring data throughout the period under evaluation, 

NIOSH considers reconstruction of external radiation dose to be likely feasible for the Nuclear 

Metals, Inc. worker class for the period from October 29, 1958 through December 31, 1983. Such 

reconstruction can be accomplished using co-worker data distributions and the bounding assumptions 

and applicable protocols specified in various complex-wide Technical Information Bulletins. NIOSH 

also considers reconstruction of medical X-ray dose to be likely feasible.
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7.4 Evaluation of Petition Basis for SEC-00195

The following evaluates the assertions made on behalf of petition SEC-00195 for Nuclear Metals, Inc. 

Lack of Monitoring 

Issue: The petitioner provided affidavits and supporting documents describing unmonitored uranium 

airborne and external exposures. 

Response: NIOSH has reviewed the affidavits and supporting documents and has noted that there 

were many fires and explosions that subjected the workers to airborne uranium and were not 

monitored. The supporting documents and AEC inspections substantiate this claim. In addition, 

NIOSH has not identified any monitoring data for thorium. Therefore, as presented in Section 7.2 

above, NIOSH has concluded the available data are insufficient to bound the total internal dose for the 

period from October 29, 1958 through December 31, 1979. NIOSH is reserving its full assessment of 

available post-1979 data and will continue to evaluate the feasibility of sufficiently accurate dose 

reconstruction for the period from January 1, 1980 through December 31, 1983. 

7.5 Summary of Feasibility Findings for Petition SEC-00195

This report evaluates the feasibility for completing dose reconstructions for employees at Nuclear 

Metals, Inc. from January 1, 1958 through December 31, 1983. NIOSH found that the available 

monitoring records, process descriptions and source term data available are not sufficient to complete 

dose reconstructions for the evaluated class of employees for the period from October 29, 1958 

through December 31, 1979. 

Table 7-1 summarizes the results of the feasibility findings at Nuclear Metals, Inc. for each exposure 

source during the evaluated AWE time period from October 29, 1958 through December 31, 1983. 

As previously stated, the DOL has determined that the period from January 1, 1958 through October 

28, 1958 is not included in the covered AWE designation for the Nuclear Metals, Inc., Concord 

facility (DOL, 2012). 
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Table 7-1: Summary of Feasibility Findings for SEC-00195

October 29, 1958 through December 31, 1983

Source of Exposure Reconstruction Feasible Reconstruction Not 

Feasible

Reserved for Further 

NIOSH Evaluation

Internal1 X

(October 29, 1958 through 

December 31, 1979)

X

(January 1, 1980 through 

December 31, 1983)

- Natural and Depleted Uranium X2

(October 29, 1958 through 

December 31, 1979)

X

(January 1, 1980 through 

December 31, 1983)

- Enriched Uranium X

(October 29, 1958 through 

December 31, 1979)

X

(January 1, 1980 through 

December 31, 1983)

- Uranium Progeny X

(October 29, 1958 through 

December 31, 1979)

X

(January 1, 1980 through 

December 31, 1983)

- Thorium X

(October 29, 1958 through 

December 31, 1979)

X

(January 1, 1980 through 

December 31, 1983)

- Thorium Progeny X

(October 29, 1958 through 

December 31, 1979)

X

(January 1, 1980 through 

December 31, 1983)

External X3

- Gamma X

- Beta X

- Neutron X

- Occupational Medical X-ray X

Notes:

1 Internal dosimetry data are insufficient to determine the internal doses for the recommended SEC period, October 29, 

1958 through December 31, 1979. However, an evaluation beyond December 31, 1979 is continuing due to further 

NIOSH assessment of information gained during recent data capture efforts.

2 NIOSH found that it may be feasible to reconstruct internal doses from natural and depleted uranium for employees 

during the recommended SEC period from October 29, 1958 through December 31, 1979 using available claimant and site 

monitoring data, and information in established procedures such as Site Profiles for Atomic Weapons Employers that 

Worked Uranium Metals, Battelle-TBD-6000.

3 External monitoring data available to NIOSH consist of film badge and thermoluminescent dosimeter results covering the 

entire operational period under evaluation. NIOSH has determined that reconstruction of external doses, including 

occupational medical doses, is likely feasible for the period from October 29, 1958 through December 31, 1983.

As of August 7, 2012, a total of 19 claims have been submitted to NIOSH for individuals who worked 

at Nuclear Metals, Inc. during the period under evaluation in this report. Dose reconstructions have 

been completed for 16 individuals (~84%). 

Although NIOSH found that it is not possible to completely reconstruct radiation doses for the 

proposed class, NIOSH intends to use any internal and external monitoring data that may become 

available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed at 
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Nuclear Metals, Inc. during the period from October 29, 1958 through December 31, 1979, but who 

do not qualify for inclusion in the SEC, may be performed using these data as appropriate. 

8.0 Evaluation of Health Endangerment for Petition SEC-00195

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

Based on the sum of information available from available resources, NIOSH’s evaluation determined 

that it is not feasible to estimate radiation dose with sufficient accuracy for members of the NIOSHevaluated class for the time period from October 29, 1958 through December 31, 1979. Therefore, the 

resulting NIOSH-proposed SEC class must include a minimum required employment period as a basis 

for specifying that health was endangered for this time period. NIOSH is continuing to evaluate the 

period from January 1, 1980 through December 31, 1983. 

9.0 Class Conclusion for Petition SEC-00195

Based on its full research of the class under evaluation, NIOSH has defined a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class to be added to the SEC includes all Atomic Weapons Employees who worked at the

facility owned by Nuclear Metals Inc. (or a subsequent owner) in West Concord, Massachusetts 

during the period from October 29, 1958 through December 31, 1979, for a number of work days 

aggregating at least 250 work days, occurring either solely under this employment or in combination 

with work days within the parameters established for one or more other classes of employees included 

in the Special Exposure Cohort. NIOSH is continuing to research Nuclear Metals, Inc. activities and 

further analyze information gained during recent data capture efforts for the post-1979 period; 

subsequently NIOSH has reserved the period from January 1, 1980 through December 31, 1983 

pending further evaluation.

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00195. In addition, NIOSH reviewed its NOCTS dose reconstruction 
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database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 

standards of performance in determining the feasibility or infeasibility of reconstructing dose for the 

class under evaluation. 
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10.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p. 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended

ACI, 1994, Decommissioning Cost Estimate; Applied Consultants, Inc. (ACI); May 13, 1994; SRDB 

Ref ID: 106126 

AEC, 1969, Compliance Issues in Response of Inspection of September 3-4, 1969; Atomic Energy 

Commission (AEC); September 18, 1969; SRDB Ref ID: 107823 

AEC, 1973, AEC Violations Identified from Inspection on March 21, 1973; Atomic Energy 

Commission (AEC); May 15, 1973; SRDB Ref ID: 107746 

Affidavit, 1970-1983, Affidavit Describing Unmonitored Radioactive Material Exposures During 

Employment from 1977 through 1983; SRDB Ref ID: 110491 

Affidavits, 2011, Group of Seven Affidavits from Employees of Nuclear Metals, Inc. West Concord; 

received on October 20, 2011; July 6, 2010; DSA Ref ID: 115107 

AMCCOM, 2000, Final Report: Kinetic Energy Penetrator Long Term Strategy Study (Abridged); 

AMCCOM Task Group; July 24, 1990; SRDB Ref ID: 105874 

Battelle-TBD-6000, Site Profiles for Atomic Weapons Employers that Worked Uranium Metals, Rev. 

1; Division of Compensation Analysis and Support; June 17, 2011; SRDB Ref ID: 101251 

Cardarelli, post-1996, Health Hazard Evaluation Report 96-0198-2651 Portsmouth Gaseous Diffusion 

Plant Piketon, Ohio; John Cardarelli; document date not specified, site visits conducted November 

1996 and February 1997; SRDB Ref ID: 10913 

DCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 1, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; April 15, 2011; 

SRDB Ref ID: 94768 

DOE, 2010, Facility List for Hood Building; Department of Energy website; web page last updated 

August 10, 2010; SRDB Ref ID: 116969 

DOL, 2012, DOL Response to NIOSH on the NMI SEC Class Definition, correspondence to DCAS; 

Department of Labor (DOL); August 23, 2012; SRDB Ref ID: 117700 
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Fire Prevention, unspecified, Fire Prevention, appears to be a portion of a document; unspecified 

author; unspecified date; SRDB Ref ID: 24982, pdf pp. 2-11 

Furnace Explosion, unspecified date; Furnace Explosion Video, provided as support for petition; DSA 

Ref ID: 116322 

Henderson, 1991, Evaluation of Radiation Exposure in Metal Preparation Depleted Uranium Process 

Areas; M. D. Henderson; May 1991; SRDB Ref ID: 8538 

Incident, 1981, Incident Report and Monitoring Results for Incident in April 1981; SRDB Ref ID: 

107796 

Incident, 1982a, Incident Report and Related Documents for a Uranium Fire on June 18, 1982; 

incident on June 18, 1982; SRDB Ref ID: 26841 

Incident, 1982b, Incident Report and Related Documents for a Vent Fire on the CAF Lines on July 28, 

1982; incident on July 28, 1982; SRDB Ref ID: 26847 

Incident, 1981-1984, Unusual Occurrences and Incident Reports for 1981 through 1984; various 

dates throughout 1981 through 1984; SRDB Ref ID: 25124 

Incident, 1996, Preliminary Notification of Vent Fire on February 21, 1996; incident February 21, 

1996; SRDB Ref ID: 107741 & 107983 

Inspection Report, Jul1968, Inspection Report with Backup Notes for Inspection Conducted July 30, 

1968; inspector was W. G. Browne; August 23, 1968; SRDB Ref ID: 105839 

Inspection Report, Dec1969, Inspection Report for Inspection Conducted December 2-3, 1969; 

inspector was R. H. Smith; January 6, 1970; SRDB Ref ID: 105852 

Inspection Report, Jul1970, Inspection Report and Notes of Inspection Conducted July 15-16, 1970; 

inspector was R. H. Smith; SRDB Ref ID: 107851 & 109544 

Inspection Report, May1971, Inspection Report and Backup Notes for Inspection Conducted May 13-

14, 1971; inspector was R. H. Smith; June 11, 1971; SRDB Ref ID: 105866 

Inspection Report, Jul-Aug1972, Inspection Report and Field Notes for Inspection Conducted July 31, 

1972 through August 1, 1972; inspector was H. W. Crocker; SRDB Ref ID: 105867 

Inspection Report, Mar1973, Inspection Report and Findings of Inspection Conducted March 14-16, 

1973; reporting inspector was Phillip C. Jerman; April 20, 1973; SRDB Ref ID: 105870 

Inspection Report, Dec1973-Jan1974, Inspection Report of Inspections Conducted December 27-28, 

1973 and January 8-9, 1974; inspection performed by Phillip C. Jerman; February 15, 1974; SRDB 

Ref ID: 105296 & 106825 

Inspection Report, May1974, Inspection Report and Findings of Inspection Conducted May 30-31, 

1974; reporting inspector was Phillip C. Jerman; SRDB Ref ID: 105872 

Inspection Report, Dec1981, Report of Inspection Conducted on December 16, 1981; December 16, 

1981; SRDB Ref ID: 112179 
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Inspection Report, Jan1983, Report of Inspection Conducted January 4-5, 1983; Frank R. Archibald 

and Leonard D. Pagnotto; SRDB Ref ID: 112178 

Inspection Report, Aug1983, Inspection Report for Inspection Conducted August 9-10, 1983; SRDB 

Ref ID: 112167 

Knapp, 1974, Telephone Conversation Regarding Whole-Body Counting, memo to the files; Peter J. 

Knapp; telephone conversation on January 9, 1974; SRDB Ref ID: 109472 

Levin, 1978, Bioassay and Air Sampling Program Review; Samuel Levin; November 30, 1978; SRDB 

Ref ID: 24998 

Loewenstein, 1954, Report on Explosion of Extruded Thorium Metal, correspondence to J. T. Morris; 

P. Lowenstein; December 2, 1954; SRDB Ref ID: 95613 & 17000 

MACTEC, 2004, Health and Safety Plan Nuclear Metals Superfund Site Remedial 

Investigation/Feasibility Study Concord, Massachusetts; MACTEC Engineering and Consulting, Inc.; 

September 29, 2004; SRDB Ref ID: 105264 

MIT, 1963, Hood Building Demolition Press Release; Office of Public Relations at MIT; February 4, 

1963; SRDB Ref ID: 51121, pdf pp. 3-4 

Monitoring, 1955-1959, Urinalysis Data for 1955-1959; Nuclear Metals, Inc. Health and Safety 

Department; various dates from 1955 through 1959; SRDB Ref ID: 24978 

Monitoring, 1955-1964, Urine Sample Results for 1955 through 1964; Atomic Energy Commission 

Health and Safety Division; various dates from 1955 through 1964; SRDB Ref ID: 10512 

Monitoring, 1955-1966, Facility Visit Reports on Bioassay Data, Film Badge Data, X-Ray 

Information, and Various Radiation Correspondence for 1955 through 1966; various authors; various 

dates from 1955 through 1966; SRDB Ref ID: 25090 

Monitoring, 1957-1958, Film Badge Exposure Results for 1957 through 1958; various dates from 

1957 through 1958; SRDB Ref ID: 25034 

Monitoring, 1958-1959, Film Badge Data Reports for 1958 through 1959; Controls for Radiation; 

various dates from 1958 through 1959; SRDB Ref ID: 25035 

Monitoring, 1959-1982, Bioassay Data for 1959 through 1982; various dates from 1959 through 

1982; SRDB Ref ID: 26863 

Monitoring, 1960-1961, Beta, Gamma, and X-ray Film Badge Reports for 1960 through 1961; various 

dates from 1960 through 1961; SRDB Ref ID: 28468 

Monitoring, 1960-1969, Health and Safety Department Medical Sample Results for 1960-1969; 

Nuclear Metals Health and Safety Department; various dates from 1960 through 1969; SRDB Ref ID: 

29172 

Monitoring, 1961-1962, Film Badge Radiation Exposure Reports for 1961 through 1962; various 

dates from 1961 through 1962; SRDB Ref ID: 25038 
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Monitoring, 1963-1965a, Film Badge Exposure Reports for 1963 through 1965; various dates from 

1963 through 1965; SRDB Ref ID: 25037 

Monitoring, 1963-1965b, Film Badge Exposure Reports for 1963 through 1965; various dates from 

1963 through 1965; SRDB Ref ID: 29184 

Monitoring, 1966-1967, Film Badge Exposure Reports for 1966 through 1967; various dates from 

1966 through 1967; SRDB Ref ID: 25045 

Monitoring, 1968, Exposure Reports for 1968; Gardray Film Badge Service; various dates throughout 

1968; SRDB Ref ID: 28465 

Monitoring, 1968-1969, Radiation Dosimetry Reports for 1968 through 1969; various dates from 

1968 through 1969; SRDB Ref ID: 25040 

Monitoring, 1970-1971, Urine Sample Results for 1970 through 1971; Nuclear Metals Health and 

Safety Department; various dates from March 1970 through November 1971; SRDB Ref ID: 28439 

Monitoring, 1970-1972, Film Badge Reports for 1970 through 1972; Landauer; various dates from 

1970 through 1972; SRDB Ref ID: 25046 

Monitoring, 1973-1977, Uranium Urine Analysis Data for 1973 through 1977; Nuclear Metals Health 

and Safety Department; various dates between 1973 and 1977; SRDB Ref ID: 25057 

Monitoring, 1973-1980, Film Badge Results for 1973 through 1980; various dates from 1973 through 

1980; SRDB Ref ID: 25054 

Monitoring, Feb1974, Whole-Body Counts Contamination Monitoring; write up of February 18, 1974 

telephone call from a licensee management representative; SRDB Ref ID: 110464

Monitoring, 1974-1977, Urine Analysis Results for 1974 through 1977; various dates from 1974 

through 1977; SRDB Ref ID: 28440 

Monitoring, May1976-Oct1977, Radiation Dosimetry Reports for May 1976 through October 1977; 

Landauer; various dates from May 1976 through October 1977; SRDB Ref ID: 113279 

Monitoring, Dec1976-1977, Radiation Dosimetry Reports for December 1976 through December 

1977; Landauer; various dates from December 1976 through December 1977; SRDB Ref ID: 113268 

Monitoring, 1977, Film Badge Date for 1977; Landauer; various dates throughout 1977; SRDB Ref 

ID: 25072 

Monitoring, 1978, Urine Analysis Results for May 1978 through December 1978; various dates from 

May 1978 through December 1978; SRDB Ref ID: 29195 

Monitoring, 1979a, Urine Analysis Results for 1979; various dates throughout 1979; SRDB Ref ID: 

28442 

Monitoring, 1979b, Claimant Dosimetry File with Results from 1956 through 1985; selected pages 

with 1979 results; SRDB Ref ID: 25049, pdf pp. 6-12 
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Monitoring, 1979c, Film Badge Reports for 1979; Landauer; various dates throughout 1979; SRDB 

Ref ID: 25055 

Monitoring, 1979d, Film Badge Reports for 1979; Landauer; various dates throughout 1979; SRDB 

Ref ID: 25058 

Monitoring, 1979-1982, Radiation Surveys for 1979, 1981, and 1982; surveys conducted October 

1979, July 28, 1981, and February 3-4, 1982; SRDB Ref ID: 24996 

Monitoring, Jan-Apr1980, Personnel Exposure Reports for January 1980 through April 1980; 

Landauer; various dates from January 1980 through April 1980; SRDB Ref ID: 113198 

Monitoring, 1980a, Radiation Dosimetry Reports for 1980; Landauer; various dates throughout 1980; 

SRDB Ref ID: 29132 

Monitoring, 1980b, Urinalysis Results for 1980; various dates throughout 1980; SRDB Ref ID: 29174 

Monitoring, 1980-1983, Various Breathing Zone Air Sample Records from Various Locations; various 

dates from 1980 through 1983; SRDB Ref IDs: 26864, 26867, 28484, 28486-28488, 28490-28491, 

29135, 29137-29138, 29214, 113136-113138, 113154, 113156-113157, 113159-113164, 113169 -

113170, 113173, 113176, 113180, 113183, 113186, 113189, 113196, 113207, 113236, 113239, 

113241-113242, 113247, 113249, and 113353-113354 

Monitoring, Jun-Dec1981, Air Sample Records for June 1981 through December 1981; various dates 

from June 1981 through December 1981; SRDB Ref ID: 25085 

Monitoring, Oct-Dec1981, Air Sample Records for October 1981 through December 1981; various 

dates from October 1981 through December 1981; SRDB Ref ID: 28484 

Monitoring, 1981a, Urinalysis Results for 1981; various dates throughout 1981; SRDB Ref ID: 29175 

Monitoring, 1981b, Evaluation of Bioassay Data/Urinalysis Results for 1981; various dates 

throughout 1981; SRDB Ref ID: 107973 

Monitoring, 1981c, Radiation Dosimetry Reports for 1981; various dates throughout 1981; SRDB Ref 

ID: 28481 

Monitoring, 1981d, Radiation Dosimetry Reports TLD Including Rings; Landauer; various dates 

throughout 1981; SRDB Ref ID: 28483 

Monitoring, Jan-Jun1982, Radiation Dosimetry Reports for January 1982 through June 1982; 

Landauer; various dates from January 1982 through June 1982; SRDB Ref ID: 28584 

Monitoring, Jul-Dec1982, Radiation Dosimetry Reports for July 1982 through December 1982; 

Landauer; various dates from July 1982 through December 1982; SRDB Ref ID: 28582 

Monitoring, 1982, Radiochemistry and Health Physics Urinalysis Results for 1982; Bolton & 

Galanek, Inc.; various dates throughout 1982; SRDB Ref ID: 28443 

Monitoring, 1982-1983, Lung Counting Procedures and Results for 1982 through 1983; various dates 

from 1982 through 1983; SRDB Ref ID: 25116 
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Monitoring, 1982-1985, Lung Count Data for 1982 through 1985; various dates from 1982 through 

1985; SRDB Ref ID: 25063 

Monitoring, Jan-Jun1983, Radiation Dosimetry Reports for January 1983 through June 1983; 

Landauer; various dates from January 1983 through June 1983; SRDB Ref ID: 29151 

Monitoring, Jul-Dec1983, Radiation Dosimetry Reports for July 1983 through December 1983; 

Landauer; various dates from July 1983 through December 1983; SRDB Ref ID: 29154 

Monitoring, 1983a, Bioassay Data Results for 1983; Bolton & Galanek, Inc.; various dates throughout 

1983; SRDB Ref ID: 25074 

Monitoring, 1983b, NRC Correspondence on Internal Exposure Results for 1983, RWP, and ALARA 

Program; various dates throughout 1983; SRDB Ref ID: 25112 

NMI, 1959, Occupational Exposure to Airborne Beryllium and Uranium, HASL-68; Nuclear Metals, 

Inc. (NMI), Field Services Branch; July 21, 1959; SRDB Ref ID: 10505 

NMI, 1960, Occupational Exposure to Airborne Beryllium and Uranium: Safety and Fire Protection, 

HASL-97; Nuclear Metals, Inc. (NMI); September 28, 1960; SRDB Ref ID: 10497 

NMI, 1981, Nuclear Metals, Inc. Renewal Application for Nuclear Regulatory Commission License 

SMB-179; November 1981; SRDB Ref ID: 25115 

NSWC, 1997, 1997 Tri-Service Conference on Corrosion; conference organized by Naval Surface 

Warfare Center (NSWC); conference held from November 17-21, 1997; SRDB Ref ID: 106125 

ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures, Rev. 03 PC-1; ORAU Team Dose Reconstruction Project for NIOSH; effective 

December 21, 2005; SRDB Ref ID: 20220 

ORAUT-OTIB-0024, Estimation of Neutron Dose Rates from Alpha-Neutron Reactions in Uranium 

and Thorium Compounds, Rev. 00; ORAU Team Dose Reconstruction Project for NIOSH; effective 

April 7, 2005; SRDB Ref ID: 19445 

ORAUT-OTIB-0079, Guidance on Assigning Occupational X-ray Dose Under EEOICPA for X-rays 

Administered Off Site, Rev. 00; ORAU Team Dose Reconstruction Project for NIOSH; effective 

January 1, 2011; SRDB Ref ID: 89563

ORAUT-TKBS-0015-6, Portsmouth Gaseous Diffusion Plant – Occupational External Dose, Rev. 01 

PC-1; ORAU Team Dose Reconstruction Project for NIOSH; effective August 20, 2007; SRDB Ref 

ID: 34469 

ORNL, 1996, Site Summary Document for Nuclear Metals, Inc.; Oak Ridge National Laboratory 

(ORNL); approved August 13, 1996; SRDB Ref ID: 106833 

Personal Communication, 2012a, Documented Communication with a Plant Engineer; Telephone 

Interview by ORAU Team; March 5, 2012, 10:00 AM EST; SRDB Ref ID: 111249 

Personal Communication, 2012b, Documented Communication with a Plant Engineer; Telephone 

Interview by ORAU Team; March 8, 2012, 3:30 PM EST; SRDB Ref ID: 111248
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Personal Communication, 2012c, Documented Communication with a Plant Manager; Telephone 

Interview by ORAU Team; March 8, 2012, 10:00 AM EST; SRDB Ref ID: 111247

Personal Communication, 2012d, Documented Communication with a Machine Operator; Telephone 

Interview by ORAU/NIOSH Team; March 7, 2012, 2:00 PM EST; SRDB Ref ID: 111246 

Personal Communication, 2012e, Documented Communication with a REP Machine Operator; 

Telephone Interview by ORAU Team; March 27, 2012, 12:00 PM EST; SRDB Ref ID: 114279

Personal Communication, 2012f, Documented Communication with a Senior Health Physicist; 

Telephone Interview by ORAU Team; April 17, 2012, 2:00 PM EST; SRDB Ref ID: 114280

Personal Communication, 2012g, Documented Communication with a Health Physics Technician; 

Telephone Interview by ORAU Team; March 27, 2012, 9:00 AM EST; SRDB Ref ID: 114281

Personal Communication, 2012h, Documented Communication with a Foundry Worker; Telephone 

Interview by ORAU Team; March 26, 2012, 11:00 AM EST; SRDB Ref ID: 114282 

Production Order, 1960, Production Orders for Shipment of 3% Enriched Uranium Scrap to Nuclear 

Metals, Inc.; orders dated March 3, 1960 and December 6, 1960; SRDB Ref ID: 93116, pdf pp. 2-3 

Progress Report, Jul-Dec1952, Health Physics Progress Report for July 1, 1952 through December 

31, 1952; E. G. Struxness; February 8, 1954; SRDB Ref ID: 8602, pdf pp. 86-109

Quinn, 2001, Beryllium and Uranium Work Performed by Nuclear Metals, Inc., correspondence to 

Roger Anders; Robert E. Quinn; October 11, 2001; SRDB Ref ID: 10485, pdf pp. 102-103 

Rad Handbook, 1970, Radiological Health Handbook, Revised Edition; compiled and edited by the 

Bureau of Radiological Health and the Training Institute Environmental Control Administration; 

revised January 1970; SRDB Ref ID: 75017 

Rad Handbook, 1998, Handbook of Health Physics and Radiological Health, 3rd Edition; editors 

include Bernard Schleien, Lester Slaback, and Brian Kent; 1998; SRDB Ref ID: 22737 

Rocco, 1983, Environmental Survey of Nuclear Metals, Inc., Final Report; B. B. Rocco; February 

1983; SRDB Ref ID: 25126 

Supporting Doc, 1974-2006, Appendix A NRC/AEC Reports and Excerpts; various documents and 

reports with dates ranging from 1974 through 2006; DSA Ref ID: 115098 

Thorium, 2012, Notes Regarding Thorium Work in Concord, hand written notes; notes provided by 

[Name Redacted]; collected May 24, 2012; SRDB Ref ID: 114724 

Thorium Shipments, 1952-1985, FMPC Thorium Campaigns and Shipment Lists for 1952-1985; 

shipments from 1952 through 1985; SRDB Ref ID: 41375 pdf pp. 104-124 

Thorium Receipts, 1959-1962, Receipts of Thorium at Colonie Interim Storage Site; dates ranging 

from 1959 through 1962; SRDB Ref ID: 45268 

Uranium Shipments, Oct1960, Uranium Shipment to Nuclear Metals October 1960; shipment from 

Atlas Steels Limited; October 4, 1960; SRDB Ref ID: 101273 
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Uranium Shipments, Dec1960, Uranium Shipment from Nuclear Metals to Atlas Steels Limited 

December 1960; December 1960; SRDB Ref ID: 101269 
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Attachment One: Data Capture Synopsis

Table A1-1: Data Capture Synopsis for Nuclear Metals, Inc.

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Primary Site / Company Name: Nuclear Metals, Inc.; BE 

1954-1986; AWE 1958-1990; Residual Radiation 1991-

October 2009 

Alternate Site Names: 

Starmet, Inc.

Whittaker Corp. Nuclear Metals Division

NMI

Physical Size of the Site: 46.4 Acres

Site Population: Apparent peak of 650 (1984/85)

Aerial radiological survey, air sample data, ALARA control 

information, personnel radiological exposure, area dosimetry, area 

radiation surveys, urinalyses sample results, bioassay and air sampling 

program procedure, breathing zone and area air sample records, 

fluorometry laboratory procedures, company history, depleted uranium 

processing, dissolution rates of uranium from air samples, chest x-rays, 

environmental survey, GAU-8 program, in vivo counting for Nuclear 

Metals, Inc, incident reports, license documentation, NMI Views 

volumes, NRC inspection reports, proposed action levels for uranium 

urinalysis, radiological work permit system, safety precautions for 

depleted uranium powder production, site visit reports, summary of air 

emissions, summary of perimeter and off-site uranium air 

concentrations and calculated lung doses, thorium work in Concord, and 

TLD badge program information.

06/06/2012 305

State Contacted: MA Department of Public Health, 

Radiation Control Program [Phone no. redacted]

Airborne emissions report, ambient air monitoring data, personnel 

radiological exposure information, calculation of uranium inventory, 

drum excavation work plan, depleted uranium inventory, environmental 

survey, floor plans and site map showing location of drains and utilities, 

holding basin decommissioning project site specific health and safety 

plan, incident notifications, inspection reports, radiation dosimetry 

report, license amendments and other documentation, Massachusetts 

Environmental Radiation Laboratory sample procedure and radiation 

control program inspection report, site photographs, update to holding 

basin release abatement measure project, radioactive materials 

inventory, radiological survey data, registration of ionizing radiation 

sources, health and safety plan, disposal of industrial wastes, routing of 

radioactive waste shipments, time line of events, town of Concord air 

monitoring data, USEPA National Air and Radiation Environmental 

Laboratory thorium analyses, uranium emissions summary, ventilation 

information and air data at plant boundary, and waste disposal practices 

and shipments.

04/12/2012 84

Battelle Memorial Institute, King Avenue Report on explosion of extruded thorium. 04/14/2011 1

Claimant Provided Licensing and product information and employee work history. 07/05/2012 2
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Table A1-1: Data Capture Synopsis for Nuclear Metals, Inc.

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Concord, MA Public Library Description of bioassay program, use of asbestos, survey frequency, air 

sample data and uranium inventory.

10/06/2008 7

Concord, MA Town Hall Beryllium monitoring, exposure investigation, personnel intake 

evaluations, personnel dosimetry reports, and personnel rosters and 

photographs.

10/07/2008 35

Department of Labor / Paragon Uranium requests and thorium slugs from extruded rod. 01/23/2012 3

DOE Germantown Site description and beryllium related material. 09/11/2002 3

DOE Legacy Management - Grand Junction Office Report to Congress excerpt, research in support of Savannah River, 

material receipts, waste classification, thorium procurement, and 

uranium shipment documentation.

08/25/2011 25

DOE Legacy Management - Morgantown Special Nuclear Material accountability station symbols, Fernald 

agreements, production orders, ALARA program development and 

division highlight reports.

03/02/2011 7

DOE Legacy Management - MoundView (Fernald 

Holdings, includes Fernald Legal Database)

Weekly progress report, thorium receipts and campaigns, actinium 

inventory, tritium release, and a report on normal uranium scrap 

materials.

09/08/2008 6

DOE Office of Scientific and Technical Information 

(OSTI)

Thorium receipts, zirconium cladding of uranium, and a trip report. 03/26/2012 3

Federal Record Center (FRC) - Boston Urine sample collection data, breathing zone air samples, radiation 

dosimetry reports, general area air sample results, personnel termination 

exposure records, and quality control information.

05/30/2012 389

Hagley Museum and Library Trip reports and research programs in support of Savannah River. 10/28/2010 2

Hanford Monthly processing and operations reports. NOTE: Cannot submit 

requested documents from search results until funding issues at Hanford 

are resolved.

OPEN 13

HASL - EML Thorium sampling and storage. 03/08/2005 1

Interlibrary Loan M.I.T. beginnings, "The Legacy of Nuclear Metals, Inc." 05/15/2008 1

Internet - Defense Technical Information Center (DTIC) Nuclear Metals site history, feasibility of recycling penetrators, 

filtration of molten depleted uranium, depleted uranium reclamation 

report, machining depleted uranium, techniques for cleaning depleted 

uranium derbys, dies for extrusion of complex shapes of steel and 

refractory alloys, disposal of depleted uranium, compatibility studies of 

molten uranium and thorium alloys, and development of high strength 

columbium and tantalum alloy tubing progress report.

02/04/2012 37

Internet - DOE Comprehensive Epidemiologic Data 

Resource (CEDR)

No relevant documents identified. 07/09/2012 0
SEC-00195 08-30-2012 Nuclear Metals, Inc.

73 of 78 

Table A1-1: Data Capture Synopsis for Nuclear Metals, Inc.

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Internet - DOE Hanford Declassified Document Retrieval 

System (DDRS)

Monthly processing and operations reports. 10/24/2008 11

Internet - DOE Legacy Management Considered Sites Considered sites listing. 03/15/2012 1

Internet - DOE National Nuclear Security Administration 

(NNSA) - Nevada Site Office

No relevant documents identified. 03/20/2012 0

Internet - DOE OpenNet No relevant documents identified. 03/20/2012 0

Internet - DOE OSTI Energy Citations Progress reports, report on low exposure irradiation of enriched sevenrod cluster in KER loop, extrusion program summary report, and 

thorium 1.4 wt percent uranium-235 metal fuel tubes fabrication.

04/03/2012 8

Internet - DOE OSTI Information Bridge Departmental monthly reports, decommissioning management plan, 

grain refinement of case uranium by heat, trip reports, evaluation of 

thorium - uranium alloys, irradiation of uranium 2% zirconium fuel 

tube, effects of irradiation, Mound Laboratory monthly report, stockpile 

management quarterly report, and heavy water moderated power 

reactors progress reports.

03/15/2012 56

Internet - DOE OSTI Information Bridge / SC&A Preparation and characterization of uranium oxides. 03/15/2012 1

Internet - Environmental Protection Agency Waste site cleanup and reuse and removal of contaminated buildings. 03/24/2012 2

Internet - Google Criticality safety inspections, depleted uranium technical brief, drum 

excavation, engineering evaluation and cost analysis for disposition of 

structures and contents, enriched uranium liquid sludge transfer, 

environmental assessments, evaluation of zircaloy clad tubes, 

evaluation of tantalum bimetallic tubing fabrication, groundwater and 

surface water sampling and analysis, holding basin characterization, 

licensing documentation, monthly and bi-annual monitoring data, 

decommissioning plan for the holding basin, process for removing 

uranium and other metals from wastes, processing and applications of 

depleted uranium alloy products, production of high-value fluoride gas 

from uranium tetrafluoride, radiation exposure information, radiological 

incidents, radiological surveys, safeguards inspection, scope of work 

Nuclear Metals, Inc. Superfund site, site characterization report, 

uranium contamination at Nuclear Metals plant, and whole body counts 

contamination monitoring.

06/24/2012 257

Internet - Health Physics Journal No relevant documents identified. 07/09/2012 0

Internet - Journal of Occupational and Environmental 

Hygiene

No relevant documents identified. 07/09/2012 0

Internet - National Academies Press (NAP) No relevant documents identified. 03/20/2012 0
SEC-00195 08-30-2012 Nuclear Metals, Inc.

74 of 78 

Table A1-1: Data Capture Synopsis for Nuclear Metals, Inc.

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Internet - NIOSH Report on residual radioactive beryllium contamination. 01/25/2007 1

Internet - NRC Agencywide Document Access and 

Management (ADAMS) 

Amendments to vendor reported dosimetry, decommissioning cost 

estimate, evaluation of bioassay data, examination and analysis of three 

fired depleted uranium penetrators, exclusion boundaries fissile material 

storage, feasibility reports, guidelines for transferring solid depleted 

uranium product, holding basin remediation plan, incident reports 

including notification and corrective actions, inspection reports, 

notifications and violations, license amendment and termination 

documentation, material status report, ORNL site summary, placarding 

of shipment violation, notification of banning radioactive waste 

shipments, radiological safety inspection, record of shipment forms, 

requirements for uranium conversion and deconversion facilities, 

holding basin characterization report, site decommissioning 

management plan, skin dose report, Starmet Corporation fact sheet, 

decommissioning program annual report, urinalysis data, zero power 

experiments with U-235 enriched thoria and thorium metal lattices.

08/23/2012 158

Internet - USACE/FUSRAP No relevant documents identified. 03/20/2012 0

Internet - US Transuranium and Uranium Registries No relevant documents identified. 03/20/2012 0

Iron Mountain Survey of control over source and special nuclear materials. 09/11/2006 1

Massachusetts Department of Environmental Protection Remediation photographs, documented communication, extrusion, 

groundwater contamination investigation, and consequences of using 

depleted uranium.

06/14/2012 9

National Archives and Records Administration (NARA) -

Atlanta

Thorium explosion and a proposal for work on solid duel liquid metal 

cooled aircraft propulsion reactor.

05/20/2008 2

National Institute for Occupational Safety and Health 

(NIOSH)

History of USAEC and the establishment of EEOICPA. 12/12/2011 2

New South Associates The 300/M area fuel and target fabrication. 08/08/2009 1
SEC-00195 08-30-2012 Nuclear Metals, Inc.

75 of 78 

Table A1-1: Data Capture Synopsis for Nuclear Metals, Inc.

Data Capture Information General Description of Documents Captured Date 

Completed

Uploaded

To SRDB

Nuclear Regulatory Commission Public Document Room Soil monitoring program and soil analyses, potential airborne releases, 

certificate of disposition of materials, disposal of low level waste at 

Envirocare of Utah, dose rate evaluations for exposure to copper metal 

contaminated with depleted uranium, environmental summary report, 

extrapolation chamber measurements, ground water report, site 

historical information brochure, license application, amendment, 

renewal and termination documentation, minimum requirements for 

entrance into restricted areas, air sampling program documentation, 

annual lung counting program, notice of violation and proposed 

imposition of civil penalties, pre-construction radiological assessment 

and decontamination of a depleted uranium waste handling site, 

regulatory operations routine inspection, request for approval to use the 

Clive, Utah repository, transportation violations, and a trip report.

05/21/2012 119

ORAU Team Documented communications. 04/17/2012 14

R. S. Landauer NOTE: Request submitted to Landauer by NIOSH; awaiting response. OPEN NA

Sandia National Laboratories, New Mexico / SC&A Radiological surveys. 09/15/2010 3

Savannah River Site Classified reports received for 1957, dosimetry visitors cards, extrusion 

of electrolytic thorium, monthly progress report, radiation survey 

logsheets, symposium on high temperature fuel processing, and thorium 

metal requirements.

06/06/2012 25

Science Applications International Corp (SAIC) Radiation exposure summary. 09/02/2004 3

Southern Illinois University Nuclear fuels and materials development and an off-site extrusion 

program summary.

11/08/2008 2

Unknown Air, stack, water, and urine samples, building contamination, employee 

radiological summary, occupational exposure record, breathing zone air 

samples, and occupational exposure to airborne beryllium and uranium.

06/08/2009 20

TOTAL 1,620

Table A1-2: Databases searched for Nuclear Metals, Inc.

Database/Source Keywords / Phrases Hits Selected
SEC-00195 08-30-2012 Nuclear Metals, Inc.

76 of 78 

Table A1-2: Databases searched for Nuclear Metals, Inc.

Database/Source Keywords / Phrases Hits Selected

NOTE: Database search terms employed for each of the databases listed below are available 

in the Excel file called “Nuclear Metals Rev 00, (83.13) 07-25-12”

Defense Technical Information Center (DTIC)

https://www.dtic.mil/

COMPLETED 11/08/2012

See Note above 1,479 23

DOE CEDR

http://cedr.lbl.gov/

COMPLETED 07/09/2012

See Note above 0 0

DOE Hanford DDRS

http://www2.hanford.gov/declass/

COMPLETED 03/20/2012

See Note above 0 0

DOE Legacy Management Considered Sites

http://csd.lm.doe.gov/

COMPLETED 03/20/2012

See Note above 6 2

DOE NNSA - Nevada Site Office

www.nv.doe.gov/main/search.htm

COMPLETED 03/20/2012

See Note above 18 0

DOE OpenNet

http://www.osti.gov/opennet/advancedsearch.jsp

COMPLETED 03/20/2012

See Note above 224 11

DOE OSTI Energy Citations

http://www.osti.gov/energycitations/

COMPLETED 03/20/2012 

See Note above 2,385 7

DOE OSTI Information Bridge

http://www.osti.gov/bridge/advancedsearch.jsp

COMPLETED 03/20/2012

See Note above 1,644 18

Google

http://www.google.com

COMPLETED 03/31/2012

See Note above 22,494,928 497

HP Journal

http://journals.lww.com/health-physics/pages/default.aspx 

COMPLETED 07/09/2012

See Note above 4 0
SEC-00195 08-30-2012 Nuclear Metals, Inc.

77 of 78 

Table A1-2: Databases searched for Nuclear Metals, Inc.

Database/Source Keywords / Phrases Hits Selected

Journal of Occupational and Environmental Health 

http://www.ijoeh.com/index.php/ijoeh

COMPLETED 07/09/2012

See Note above 0 0

National Academies Press

http://www.nap.edu/

COMPLETED 03/20/2012

See Note above 5,879 0

NRC ADAMS Reading Room

http://www.nrc.gov/reading-rm/adams/web-based.html

COMPLETED 03/20/2012

See Note above 807 107

USACE/FUSRAP

http://www.lrb.usace.army.mil/fusrap/

COMPLETED 03/20/2012

See Note above 4 4

U.S. Transuranium & Uranium Registries 

http://www.ustur.wsu.edu/

COMPLETED 03/20/2012

See Note above 0 0

Table A1-3: DTIC Documents Requested for Nuclear Metals, Inc.

Document Number Document Title Requested

Date

Received

Date

NA Extrusion of DU Penetrator Alloys Using the Canned Billet Technique 11/14/2011

NA Investment Casting of Uranium Alloy Penetrators 11/14/2011

NA An Investigation of (1) Stabilizing the Carbon Content of Investment 

Cast Performs for Phalanx Penetrators (2) Dual-Hardness Phalanx 

Penetrators

11/11/2011 NA - Request 

denied

NA Fundamental and Applied Research and Development in Metallurgy 11/11/2011 11/22/2011 -

Not relevant

NA

REF ID: 105845

Reclamation/Recycle of Depleted Uranium and Heavy Metal Alloy 

Residue for Soils

11/11/2011 12/19/2011

NMI-9709.13

REF ID: 105847

Development of Processing Techniques for the Extrusion of Metal 

Powders dated December 1967

11/08/2011 12/16/2011

ARCCD-CR-87006

REF ID: 104924

Filtration of Molten Depleted Uranium dated June 24, 1987 11/08/2011 11/28/2011
SEC-00195 08-30-2012 Nuclear Metals, Inc.

78 of 78 

Table A1-3: DTIC Documents Requested for Nuclear Metals, Inc.

Document Number Document Title Requested

Date

Received

Date

ARLCD-CR-83018

REF ID: 104927

M774 Machine Chip Recycling 11/08/2011 11/28/2011

AFATL-TR-82-49

REF ID: 104926

Depleted Uranium Test Range Fragment Reclamation dated July 1982 11/08/2011 11/28/2011

ARCCD-CR-86010 

REF ID: 104929

Recycle Process for Depleted Uranium Machining Chips by Vacuum 

Induction Remelt dated May 1987

11/08/2011 11/28/2011

ARCCD-CR-86008 

REF ID: 104930

Atmosphere Assisted Machining of Depleted Uranium (DU) 

Penetration dated May 1987

11/08/2011 11/28/2011

ARCCD-CR-87004

REF ID: 104932

Established Techniques for Cleaning Depleted Uranium Derby in Lieu 

of Nitric Acid Pickling dated May 1987

11/08/2011 11/28/2011

Table A1-4: Interlibrary Loan Documents Requested for Nuclear Metals, Inc.

Document Number Document Title Requested

Date

Received

Date

NA Proceedings of the High Density Alloy Penetrator Materials 

Conference, April 1977

11/28/2011