SEC Petition Evaluation Report
 

Petition SEC-00080 

Report Rev #:0 Report Submittal Date: _8-31-07 

Subject Expert(s): James K. Alexander and Timothy J. Vitkus 

Site Expert(s): NA 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition B 

Qualification Date 

DOE/AWE Facility Name 

SEC-00080 83.13 May 7, 2007 NUMEC Apollo 

Petitioner Class Definition 

All employees in all locations at the Nuclear Materials and Equipment Corporation (NUMEC) facility located in Apollo, 

Pennsylvania, from 1957 through 1983. 

Proposed Class Definition 

All Atomic Weapons Employer (AWE) employees who were monitored, or should have been monitored, for exposure to 

ionizing radiation while working at the NUMEC Plant in Apollo, Pennsylvania for a number of work days aggregating at 

least 250 work days from January 1, 1957 through December 31, 1983, or in combination with the work days within the 

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

Related Petition Summary Information 

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

SEC00047 83.13 NUMEC-Apollo Merged with SEC00080 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

None NA 

OCAS Lead Technical Evaluator: [Signature on file] 09/14/2007 

Lara Hughes Date 

Peer Review Completed By: [Signature on file] 

LaVon Rutherford 

09/14/2007 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 

J. W. Neton 

09/14/2007 

Date 

SEC Evaluation Approved By: [Signature on file] 

Larry J. Elliott 

09/14/2007 

Date 
SEC-00080 08-31-07 NUMEC Apollo 

This page intentionally left blank 

2 of 23 
 

SEC-00080 08-31-07 NUMEC Apollo 

Evaluation Report Summary: SEC-00080, NUMEC Apollo 

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) as defined 

by 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-00080 qualified on May 7, 2007, requested that NIOSH consider the following class: All 

employees in all locations at the Nuclear Materials and Equipment Corporation (NUMEC) facility 

located in Apollo, Pennsylvania, from 1957 through 1983. 

NIOSH-Proposed Class Definition 

The NIOSH-proposed class includes all Atomic Weapons Employer (AWE) employees who were 

monitored, or should have been monitored, for exposure to ionizing radiation while working at the 

NUMEC Plant in Apollo, Pennsylvania for a number of work days aggregating at least 250 work days 

from January 1, 1957 through December 31, 1983, or in combination with the work days within the 

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

Feasibility of Dose Reconstruction 

Pursuant to 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 incurred by any member 

of the class; or (2) estimate radiation doses more precisely than a maximum dose estimate. Available 

data resources do not allow estimating the maximum internal and external potential exposure to 

members of the proposed class under plausible circumstances during the plant’s operational period. 

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 their 

employment or in combination with work days within the parameters established for other SEC 

classes (excluding aggregate work day requirements). 

3 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

This page intentionally left blank 

4 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

Table of Contents 

Evaluation Report Summary: SEC-00080, NUMEC Apollo .................................................................. 3 

1.0 Purpose and Scope.......................................................................................................................... 7 

2.0 Introduction .................................................................................................................................... 7 

3.0 Petitioner-Requested Class/Basis ................................................................................................... 8 

4.0 Data Sources Evaluated by NIOSH................................................................................................ 9 

4.1 Site Profile ............................................................................................................................. 9 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures ....................................... 9 

4.3 Facility Employees and Experts .......................................................................................... 10 

4.4 Previous Dose Reconstructions ........................................................................................... 10 

4.5 NIOSH Site Research Database .......................................................................................... 11 

5.0 Radiological Operations Relevant to the Proposed Class ............................................................ 11 

5.1 NUMEC Apollo Plant and Process Descriptions ............................................................... 11 

5.2 Radiological Exposure Sources from NUMEC Apollo Site Operations ............................. 13 

6.0 Summary of Available Monitoring Data for the Proposed Class ................................................. 13 

7.0 Feasibility of Dose Reconstruction for the Proposed Class ......................................................... 14 

7.1 Pedigree of NUMEC Apollo Site Data ............................................................................... 14 

7.2 Internal Radiation Doses at NUMEC Apollo...................................................................... 15 

7.3 External Radiation Doses at NUMEC Apollo..................................................................... 16 

7.4 Summary of Feasibility Findings for Petition SEC-00080.................................................. 18 

8.0 Evaluation of Health Endangerment for Petition SEC-00080...................................................... 19 

9.0 NIOSH-Proposed Class for Petition SEC-00080 ......................................................................... 20 

10.0 References .................................................................................................................................... 22 

Tables 

Table 4-1: Number of NUMEC Apollo Claims Submitted Under the Dose Reconstruction Rule ....... 10 

Table 7-2: Summary of Feasibility Findings for SEC-00080 ............................................................... 18 

5 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

This page intentionally left blank 

6 of 23 
 

 

 

SEC-00080 08-31-07 NUMEC Apollo 

SEC Petition Evaluation Report for SEC-00080
 

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

the data presented in this evaluation were made by the OCAS Lead Technical Evaluator: Lara 

Hughes, NIOSH OCAS. These conclusions were peer-reviewed by the individuals listed on the cover 

page. 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 in all areas 

at the NUMEC Plant in Apollo, Pennsylvania during the period from January 1, 1957 through 

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

for adding a class of employees to the congressionally-created SEC. 

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 Office of Compensation Analysis and Support’s (OCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004. 

2.0 Introduction 

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

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.1 

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 

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, NIOSH must also then determine whether or not 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 

1

 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. 

7 of 23 
 

 

 

SEC-00080 08-31-07 NUMEC Apollo 

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 other 

SEC classes (excluding aggregate work day requirements). 

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 to 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.2 

3.0 Petitioner-Requested Class/Basis 

Two petitions associated with the NUMEC Apollo site requested that NIOSH consider classes for 

addition to the SEC: 

•	 Petition SEC-00047, qualified on January 11, 2007, requested that NIOSH consider the 

following class: All office employees who worked at the NUMEC Apollo, Pennsylvania, 

facility from January 1, 1957 through December 31, 1983. 

•	 Petition SEC-00080, qualified on May 7, 2007, requested that NIOSH consider the following 

class for addition to the SEC: All employees in all locations at the NUMEC Apollo site, from 

1957 through 1983. 

NIOSH merged the two petitions for the purpose of this evaluation because the class requested in 

SEC00047 is encompassed by the class requested in SEC00080. Therefore, all references to 

SEC00080 in this report cover SEC00047 as well, unless otherwise indicated. 

The petitioners provided information and documentation in support of their belief that accurate dose 

reconstruction for all NUMEC workers is not possible. In addition, NIOSH identified several SEC 

related issues that supported the qualification of this petition for evaluation. NIOSH deemed the 

following information sufficient to qualify SEC00080 for evaluation: 

2 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. 

8 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

•	 During the qualification review process and the early stages of the evaluation process, NIOSH 

identified an apparent lack of dosimetry data for the early operational periods at NUMEC 

Apollo (1957 through 1959). 

•	 NIOSH has learned during the qualification review process that the company “Controls for 

Environmental Pollution” (CEP) has been implicated in data falsification and that its bioassay 

analyses provided to NUMEC cannot therefore be considered reliable. 

NIOSH modified the petitioner’s proposed class to be consistent with language used in SEC class 

definitions. The class for this report is defined as: all Atomic Weapons Employer (AWE) employees 

who were monitored, or should have been monitored, for exposure to ionizing radiation while 

working at the NUMEC Plant in Apollo, Pennsylvania, for a number of work days aggregating at least 

250 work days from January 1, 1957 through December 31, 1983, or in combination with the work 

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

Exposure Cohort. 

4.0 Data Sources Evaluated by NIOSH 

NIOSH sought to identify and evaluate all potential information resources considered relevant to 

determining the feasibility of dose reconstruction for the class of employees proposed for this petition. 

This included determining the availability of information on personal monitoring, area monitoring, 

industrial processes, and radioactive source materials. 

4.1 Site Profile 

A Site Profile typically provides specific information derived from available 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. Site Profiles are also typically used in evaluating SEC 

petitions. 

A Site Profile has not yet been prepared for the NUMEC Apollo site for several reasons, including 

security classification issues. 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures 

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. An ORAU 

Procedure provides specific requirements and guidance regarding EEOICPA project-level activities, 

including preparation of dose reconstructions at particular sites or categories of sites. 

Currently, no site-specific or operations-specific OTIBs or ORAU Procedures have been developed 

that can either address NUMEC-Apollo dose reconstruction issues or be effectively used to evaluate 

dose potential for the NUMEC Apollo site employees. 

9 of 23 
 

SEC-00080 08-31-07 NUMEC Apollo 

4.3 Facility Employees and Experts 

Interviews were performed with several former workers at the NUMEC Apollo site, several of whom 

shared their knowledge regarding processes and the radiological control situation in the plant, as well 

as the occurrence of small-scale incidents. The information gained in these interviews was largely 

confirmed by reports available from other information sources, such as the NIOSH Site Research Data 

Base (SRDB). 

4.4 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH OCAS Claims Tracking System (NOCTS) to locate EEOICPA-related 

dose reconstructions that might provide information relevant to this petition evaluation. Table 4-1 

summarizes the results of this review for the period January 1, 1957 through December 31, 1983. 

Table 4-1: Number of NUMEC Apollo Claims Submitted Under the Dose Reconstruction Rule 

(January 1, 1957 through December 31, 1983) 

Description Totals 

Total number of claims submitted for dose reconstruction 133 

Total number of claims submitted for energy employees who meet the proposed class definition criteria 133 

Number of dose reconstructions completed for energy employees who meet the proposed class definition 

criteria 53 

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

class definition 92 

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

class definition 43 

There were 133 claims filed for former employees at the NUMEC Apollo site and dose 

reconstructions have been completed for 53 claimants (~ 40%). Of those, 38 claims were completed 

in 2007 and they used either the available monitoring data (24 had internal dosimetry information and 

11 had external dosimetry information) or a more generic approach, as discussed below. Fifteen 

claims were completed in 2005 before the majority of the currently available dosimetry information 

became available to NIOSH in early 2007. Those 15 cases involved circumstances that allowed for the 

use of either an overestimating or underestimating dose reconstruction methodology. These methods 

make use of relatively limited and case-specific information that are not necessarily sufficient to 

demonstrate feasibility of estimating radiation doses for a class of employees, which may include 

individuals for whom these methods are inappropriate. NIOSH has reviewed the overestimating 

techniques employed in the completed dose reconstructions. The overestimating techniques do not 

support dose reconstruction for all cancers as required by the SEC rule. 

10 of 23 
 

SEC-00080 08-31-07 NUMEC Apollo 

4.5 NIOSH Site Research Database 

The NIOSH Site Research Database (SRDB) currently contains 989 documents pertaining to the 

NUMEC sites (Apollo and Parks). The majority of the available information consists of personnel and 

area monitoring records, health and safety reports, incident reports, correspondence between NUMEC 

and AEC/NRC and decommissioning records. All documents have been carefully reviewed to obtain 

information on monitoring data and process information at NUMEC and the information has been 

assessed to determine the feasibility of reconstructing doses for the class of employees. At this point 

what the available documentation in the SRDB lacks are 1) detailed process information regarding the 

thorium operations, 2) process descriptions regarding the production of Po-Be and Ra-Be sources, 3) 

internal monitoring data for the 1957-1960 time period, and 4) information regarding the use of 

plutonium compounds at NUMEC Apollo. 

5.0 Radiological Operations Relevant to the Proposed Class 

All operations conducted at the NUMEC Apollo site involving radioactive materials during the entire 

history of the plant’s operations are considered relevant to the proposed class. 

5.1 NUMEC Apollo Plant and Process Descriptions 

The NUMEC Apollo Nuclear Fuel Facility was located in the town of Apollo, 33 miles northeast of 

Pittsburgh, in Armstrong County, Pennsylvania. The plant is located in a small industrial area across 

from a largely residential area, bordered by the main street (U.S. Route 66, Warren Avenue) and the 

Kiskiminetas River. The facility consisted of one main bay, the East Bay, and three smaller attached 

bays, known as the West Bay, the Box Shop and the Annex. They were bordered on the north, south 

and west by a metals processing facility not affiliated with NUMEC. The parking lot area contained a 

laundry building and the Small Block Building. The laundry building began operations in 1960, 

during which articles of protective clothing used at nuclear power plants and nuclear fuel 

manufacturing facilities were washed, dried, and packaged for return shipping. In March 1965, the 

NUMEC laundry building license was amended to permit the decontamination of control rod drive 

mechanisms owned by the U.S. Navy. The Small Block building was used for storage of process 

equipment. The NUMEC office building was located outside the plant area across the main street 

facing the NUMEC Apollo plant and also supported the NUMEC facility in Parks Township (BWXT, 

1997, Fogel, 1992) 

The NUMEC Apollo Nuclear Fuel Facility was first licensed by AEC in July 1957, it operated under 

AEC and NRC license SNM 145. The plant started operations in 1957 with the small scale 

production of high and low enriched uranium fuel. Between 1958 and 1983 the Apollo facility 

produced low enriched uranium (LEU) dioxide fuel for use in commercial nuclear power reactors. The 

process consisted of the conversion of uranium hexafluoride (UF6) to uranium dioxide (UO2). In 1963 

an additional production line was added to produce high enriched uranium (HEU) fuel for US Naval 

propulsion reactors. From 1958 through the 1960’s, NUMEC started processing unirradiated enriched 

uranium scrap under license from the U. S. Atomic Energy Commission (AEC, 1958). In 1961 the 

AEC issued a license to NUMEC to produce Plutonium-Beryllium sources (AEC, 1961). Other 

smaller operations consisted of analytical laboratories, UO2 pellet production and research and 

development into coating techniques for uranium microspheres (BWXT, 1997). HEU operations at 

11 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

NUMEC Apollo were discontinued in 1978, and LEU and all other processing operations involving 

radioactive materials had ceased by the end of 1983. By October 1984, all of the chemical conversion 

process equipment had been decontaminated and removed either to allowable scrap sales outlets or to 

licensed radioactive waste disposal sites. A decommissioning plan for the idle plant site, which was 

submitted to the NRC in 1991, was subsequently approved and implemented. The facility’s license 

was formally terminated on April 14, 1997 (Fogel, 1992). 

The following is a summary list and the associated time frames of the operations documented for the 

NUMEC Apollo facility: 

• HEU production: 1957-1978 

• LEU production: 1957-1984 

• HEU and LEU scarp recovery: 1958 – 1960’s 

• Po-Be neutron source production: started in 1961 

• UO2 pellet production: started in 1961 

• Research and Development for coating of uranium microspheres: start in 1961 

• Thorium operations: started in 1963 

• Laundry operations: 1959 - 1984 

Some of the smaller research and experimental operations at NUMEC Apollo are not very well 

documented. NUMEC operated a plutonium production facility nearby in Parks Township, PA, both 

plants shared management, administration and health and safety operations, and workers sometimes 

were transferred between the two facilities. Since the main office building in Apollo supported both 

facilities, most available documents are labeled as pertaining to “Apollo” and it is impossible to 

determine to which site a given document refers. Thus, for some of the smaller processes, it is not 

possible to tell at which site they were performed, given the current amount of information available. 

In late 1964 and early 1965, NUMEC was contracted by Bettis Atomic Power Laboratory to produce 

thorium oxide (ThO2) pellets to be used for nuclear fuel. During this operation, an unknown amount 

of ThO2 was processed at NUMEC. A rough outline of the planned production process is available in 

form of correspondence between NUMEC and the AEC Oak Ridge operations office (Forscher, 

1963), as well as some of the air sampling that was done to monitor the air contamination during the 

processes. There are 87 general air samples, 19 process samples and 11 breathing zone samples 

available from the thorium production operations in 1964 and early 1965. The extent and duration of 

the thorium operations at NUMEC is unknown at this point. The available process description is not 

sufficiently detailed to use source term information to permit addressing the thorium exposure in dose 

reconstructions. 

The NUMEC facility at Parks Township handled all plutonium processing and the available 

documentation does not indicate that major amounts of plutonium were handled at the Apollo plant. 

However, NUMEC Apollo was licensed to handle significant amounts of plutonium mostly in coated 

or encapsulated form. The laundry operations at the Apollo site most likely had plutonium residues 

resulting from the handling of the work clothing from both NUMEC facilities. There is insufficient 

information to permit the construction of a source term model for plutonium at the NUMEC Apollo 

plant. 

12 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

5.2 Radiological Exposure Sources from NUMEC Apollo Site Operations 

Based on reviews of documents identified in section 4.0, and from evaluations of the available 

dosimetry data, NIOSH has concluded that workers at NUMEC Apollo had the potential for 

radiological internal exposures (from radioactive materials including uranium, thorium, plutonium and 

polonium) and external exposures (from beta-gamma and neutron radiation) during the performance 

of work at the site. 

Uncontrolled stack releases from the Apollo plant could have caused the exposure of on-site personnel 

to elevated ambient levels of radioactive dust. Based on an assessment of stack releases in 1966 by 

NUMEC Health Physicist Roger Caldwell, the 124 stacks of the NUMEC uranium facility frequently 

exceed permissible levels of 234U due to filter leakage and poor filter seals. He also pointed out that 

the stack geometry was highly unfavorable to dispersion and facilitated downwash of the released 

particles due to insufficient stack height, rain hats and building wake effects. This resulted in little offsite contamination, but may have posed an exposure potential for on-site workers (Caldwell, 1967). 

Stack monitoring was taking place at a rate of only a few stack samples per day, which resulted in 

most stack effluents going largely unmonitored. Only a very limited amount of these stack sample 

results are available to NIOSH. 

6.0 Summary of Available Monitoring Data for the Proposed Class 

The data primarily used for determining internal exposures are personal monitoring data such as urine 

and fecal bioassay and whole body counting results. If these are unavailable, breathing zone air 

monitoring data are used to estimate the potential internal exposure. If breathing zone air monitoring 

data are unavailable, internal exposures can sometimes be estimated using more general area 

monitoring, process information, and information characterizing and quantifying the source term. 

This same hierarchy is used for determining the external exposures. Personal monitoring data from 

film badges or thermoluminescent dosimeters (TLDs) are the primary data used to determine such 

external exposures. If there are no personal monitoring data, exposure rate surveys, process 

knowledge, and source term modeling can sometimes be used to reconstruct potential exposure. 

Personal monitoring data are available through the NRC for monitored individuals that worked at 

NUMEC Apollo from 1960 to the end of the decommissioning phase. Data capture efforts have 

included formal requests to the former site operator Babcock and Wilcox (BWXT) and the NRC and 

all site-specific documents identified from these efforts are available on the SRDB or the OCAS SEC 

Application (OSA). 

Bioassay data from urinalysis are available from December 1960 through 1976 for workers at the 

NUMEC Apollo plant. Initial sample analysis was provided by the AEC Health and Safety Laboratory 

(HASL). Starting in 1961 NUMEC employed several different commercial contractors for urine 

bioassay analyses. Fecal bioassay for uranium is available from 1966-1976. Urine and fecal bioassay 

data for the period when CEP served as the bioassay contractor (1976-1993) is excluded from this 

summary as discussed in section 7.1. NUMEC Apollo personnel were also evaluated by whole body 

counting (WBC) from 1968-1985. NUMEC initially used the services from the Helgeson mobile body 

counter and later had a contract with the University of Pittsburgh to perform the WBCs. Employees at 

13 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

the uranium facility were monitored for 235U, employees at the plutonium facility received monitoring 

for 239Pu/241Am. 

 External dosimetry data for NUMEC employees are available from 1961-1983. It appears that 

external dosimetry was mainly used for area monitoring and that personal external monitoring was 

available only to a small number of employees who had external exposure potential. 

Several reports by the HASL contain the earliest uranium air monitoring data from samples collected 

in 1960 (AEC, 1960a, 1960b). NUMEC specific air sampling data sheets are available starting in 1961 

in the form of general air samples (1961-1968) and breathing zone monitoring for uranium dust which 

is available from 1961-1982. Air sample results for thorium are available for parts of 1964 and 1965 

and consist of 87 general air and 11 breathing zone samples. No additional monitoring results for 

thorium have been located. 

7.0 Feasibility of Dose Reconstruction for the Proposed Class 

The feasibility determination for the proposed class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, radiation doses 

can be estimated with sufficient accuracy if NIOSH can establish 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 sufficient information to estimate the 

radiation doses of members of the class more precisely than an estimate of the maximum radiation 

dose. If NIOSH has access to sufficient information for either case, NIOSH would then determine 

that it is feasible to conduct dose reconstructions. 

In determining the feasibility of dose reconstructions, NIOSH typically evaluates whether current or 

completed NIOSH dose reconstructions succeed in estimating the potential radiation exposure of the 

class with sufficient accuracy. If it finds that this is not the case, NIOSH then systematically evaluates 

all other available types of monitoring data, process and source or source term data, which then 

together or individually might allow NIOSH to arrive either at a maximum or more precise dose 

estimate that members of the class might have incurred. This approach is discussed in the OCAS SEC 

Petition Evaluation Internal Procedures which are available at http://www.cdc.gov/niosh/ocas. 

7.1 Pedigree of NUMEC Apollo Site Data 

Evaluation of the feasibility of dose begins with an evaluation of the pedigree of the available data and 

information. An analysis of data pedigree addresses the background, history, and origin of the data. It 

requires consideration of data collection, management, dosimetry methodologies and their changes 

over time; primary versus secondary data sources and whether they match; and whether data are 

internally consistent. All these issues allow the researcher to come to a conclusion about the data’s 

quality, credibility, reliability, representativeness, sufficiency and suitability to be used for dose 

reconstruction. The feasibility evaluation is performed after all data pedigree issues have been settled. 

Initial occupational exposure surveys to radioactive dust at NUMEC Apollo were reported in the AEC 

Health and Safety Laboratory (HASL) surveys performed between 1959 and 1961. Initial urine 

14 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

bioassay samples (12/1960) are also available directly from sample analyses by HASL. Starting in 

1961, bioassay and external (TLD) monitoring was performed by external contractors, and dosimetry 

information on NUMEC is available in the form of data sheets provided by the contractors. The sheets 

indicate the company that performed the analyses and the name of the employee providing the sample. 

Air sampling in form of general area monitoring, fixed and lapel breathing zone sampling was done 

by NUMEC health and safety personnel, and the results recorded on log sheets indicating sample 

location, instrumentation used, count time and any additional comments regarding the sampling 

process. Sheets are typically signed by the sample collector and the health and safety technician 

performing the analysis. 

Secondary exposure data for NUMEC personnel are available in form of exposure summary sheets 

sent to each employee upon termination. The summaries list all the external and internal dose results 

that were collected during the employment period. NUMEC also had a contract with the University of 

Pittsburgh for whole body counts (WBC) on employees. The WBC data is largely available in form of 

secondary data –in summary documents provided from the contractor and in the form of letters sent to 

NUMEC employees to inform them of the results. 

Upon careful evaluation of the data pedigree, only a single major data pedigree issue was discovered 

during the analysis of available data. The contractor “Controls for Environmental Pollution” (CEP) 

was used by NUMEC to analyze urine and fecal bioassay samples from 1976-1993. Available 

information indicates that CEP was the sole contractor used for this period at NUMEC. In 1994, CEP 

had come under suspicion of data falsification for analyses performed for Sandia National 

Laboratories (Sandia) from 1992-1994. The allegations were serious enough that federal authorities 

executed a search warrant for the records at CEP and NRC and DOE issued press releases to their 

licensees that the accuracy of the data provided by CEP was questionable. Even though the NUMEC 

period almost completely predates these events; there is no indication for what time period the CEP 

data can be considered reliable and it is not clear what actions were taken by NUMEC in response to 

these allegations. A 1994 press release by the NRC to its licensees states that the events related to 

CEP give reason to question the sample results received from the company. 

7.2 Internal Radiation Doses at NUMEC Apollo 

Based on the review of documents from the resources identified in section 4.0, from evaluations of 

available claimant dosimetry data, and other information deficiency considerations; NIOSH has 

concluded that information pertaining to internal dosimetry is inadequate to ensure sufficiently 

accurate internal exposures can be reconstructed for the NUMEC Apollo operations. Specifically: 

•	 Internal monitoring data from 1957 through 1959 do not appear to exist, and exposure 

modeling using back extrapolation of co-worker data would likely be inconclusive. 

Although several data capture initiatives for NUMEC Apollo have been completed, NIOSH has 

been unable to find any evidence that internal monitoring data exist for the 1957 through 1959 

time period, which were the first few years of AWE operations at the site. 

As a possible means to offset this data gap, NIOSH evaluated using a co-worker model to develop 

dose estimates based on a “back-extrapolation” approach. However, to ensure that the co-worker 

15 of 23 
 

SEC-00080 08-31-07 NUMEC Apollo 

model could properly bound actual internal exposures during the unmonitored period, NIOSH 

would need to have detailed process information that would support an assumption that work 

activities conducted during 1957, 1958, and 1959 were substantively similar to the operations 

conducted in later years for which exposure data are available. Indications are that activities in 

1957 -1959 involved start up operations or pilot activities and small scale processing. Based on 

NIOSH’s evaluation of startup or pilot activities at other facilities, the assumption that operations 

were similar and exposures were similar or less is not always true. NIOSH has found, based on 

lessons learned from pilot activities, engineering controls are added to reduce exposure potential to 

the production force. Therefore, NIOSH has concluded that it is not feasible to determine a 

bounding dose estimate for the internal exposures for this time period. 

•	 Information providing an adequate description of the thorium operations at NUMEC Apollo 

is not available. 

During the data capture phase, NIOSH identified some air sampling data for thorium. The 

samples dated from the 1964 and 1965 and consisted of 87 general area samples, 19 process 

samples and 11 breathing zone samples. NIOSH has information suggesting that NUMEC 

fabricated ThO2 pellets for the Bettis Atomic Power Laboratory, and that this activity probably 

began in late 1963 or early 1964. The process for this fabrication work is generally described in 

correspondence with AEC (Forscher, 1963); but NIOSH has been unable to find detailed process 

descriptions or information concerning the overall scope of the thorium work, i.e. when actual 

operations stopped and if the operations were decontaminated and decommissioned and whether 

all thorium was removed from the site. It is NIOSH’s assessment that the limited information on 

the period of operation, the small number of breathing zone samples, and the lack of detailed 

information describing the work processes would make it impossible to establish accurate 

bounding conditions for potential exposures associated with the NUMEC Apollo thorium work. 

•	 Bioassay data provided by the company “Controls for Environmental Pollution” (CEP) is 

not suitable for use 

CEP had come under suspicion of data falsification in 1994 after bioassay data provided to Sandia 

were found to be questionable. In November 1994, both DOE and the NRC advised contractors 

and/or licensees to seriously question the accuracy of any analytical results provided by CEP 

(NRC, 1994). 

The seriousness of the Sandia events calls into question the reliability of CEP’s analytical services 

for other nuclear facilities, including those it provided to NUMEC Apollo from 1976 to 1993. 

NIOSH is not aware of any documentation that would limit the time period during which CEP’s 

analytical processes were considered to be flawed, or show that only the early 1990s data provided 

to Sandia should be considered suspect. Therefore, unless documentation can be located to 

support a different conclusion, NIOSH has concluded that it must consider all CEP data provided 

to NUMEC Apollo to be suspect, and should not use these data to support dose reconstructions, 

SEC evaluations, or the development of co-worker models. Since CEP was the major bioassay 

contractor for NUMEC from 1976 to 1993, this creates a large gap in the monitoring data 

available for dose reconstruction. 

16 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

To offset this data gap, NIOSH ruled out using a co-worker model to develop dose estimates based 

on a bioassay data prior to the CEP period, because a co-worker model could properly bound 

actual internal exposures only if the process activities were substantively similar to the years for 

which exposure data are available. This cannot be considered a valid assumption given the fact 

that the first major decommissioning operations started at NUMEC in 1978 with the disassembly 

of the HEU processing operations and that the exposure scenarios that are encountered during 

decommissioning operations are different compared to production operations,. Therefore NIOSH 

has concluded that it has insufficient data to establish an accurate bounding estimate for internal 

doses from uranium from 1976-1983. 

•	 No monitoring data, process description, or source term data exist for plutonium or 

concerning the fabrication of Ra-Be and Po-Be neutron sources at NUMEC Apollo. 

Historical documentation indicates that NUMEC fabricated Ra-Be and Po-Be neutron sources and 

was also licensed to handle plutonium at the Apollo site. Additionally the laundry building was 

handling all the work clothing from the plutonium processing facility, which resulted in plutonium 

exposure potential for the workers handling the laundry. However, to date NIOSH has not been 

able to find any detailed process descriptions for these operations, any source term data, any 

personnel or area monitoring data specifically associated with these processes, or any records 

establishing the exact time period these operations took place. Therefore NIOSH has concluded 

that it has insufficient data to establish an accurate bounding estimate for doses resulting from 

these operations. 

•	 Potential elevated ambient radiation levels from stack releases of the Apollo plant are not 

well documented. 

A report authored by NUMEC health physicist Roger Caldwell in 1967 highlighted some 

problems related to the stack releases from the Apollo plant. There were 124 filtered stacks on the 

roof of the plant, and whereas sampling was frequent, it was done on a rather small scale, and it is 

possible that many releases would have gone undetected. Caldwell pointed out that there was a 

problem with leakage of particulate material through the stack filters, mainly consisting of 234U. In 

addition, the geometry of the stacks (insufficient height, rain hats, and building wake effects) 

resulted in insufficient dispersion of stack releases and downwash, which could have caused 

elevated dust exposures to on-site workers. Only very limited stack monitoring data are available 

for the operations in the early 1960’s and it is not possible to reconstruct the release scenario based 

on limited process information for uranium and thorium operations. 

Although NIOSH has concluded in this evaluation that there is a lack of sufficient data to permit 

estimating and/or reconstructing NUMEC Apollo internal doses with sufficient accuracy, NIOSH 

does intend to use any available non-CEP internal data that may be included in an individual’s file 

(and that can be interpreted using existing NIOSH dose reconstruction processes or procedures) to 

support a partial internal dose reconstruction for non-presumptive cancers and/or cases that have less 

than 250 working-days of employment. 

7.3 External Radiation Doses at NUMEC Apollo 

17 of 23 
 

 

SEC-00080 08-31-07 NUMEC Apollo 

Based on its review of documents from the resources identified in section 4.0, from evaluations of 

available claimant dosimetry data, and other information deficiency considerations, NIOSH has 

concluded that information pertaining to external dosimetry is inadequate to ensure that sufficiently 

accurate external exposures can be reconstructed for the NUMEC Apollo operations. Specifically: 

•	 Information is lacking to adequately characterize the Radium-Beryllium and PoloniumBeryllium neutron source fabrication operations conducted at NUMEC Apollo. 

Historical documentation indicates that NUMEC fabricated Ra-Be and Po-Be neutron sources. 

However, NIOSH was unable to find any detailed process descriptions for these operations, any 

source term data, any personnel or area monitoring data specifically associated with these 

processes, nor records establishing the exact time period these operations took place. Therefore 

NIOSH has concluded that it has insufficient data to establish an accurate bounding estimate for 

doses resulting from these operations. 

Although NIOSH has determined in this evaluation that there is a lack of sufficient data to permit 

estimating and/or reconstructing NUMEC Apollo external doses with sufficient accuracy, NIOSH 

does intend to use any available external data that may be included in an individual’s file (and that can 

be interpreted using existing NIOSH dose reconstruction processes or procedures) to support a partial 

external dose reconstruction for non-presumptive cancers and/or cases that have less than 250 

working-days of employment. NIOSH also concluded that medical X-rays that were performed as a 

condition of employment for NUMEC Apollo personnel can be reconstructed for all members of the 

class using claimant favorable assumptions as well as the applicable protocols in the complex-wide 

Technical Information Bulletin, Dose Reconstructions from Occupationally Related Diagnostic X-Ray 

Procedures (ORAUT-OTIB-0006). 

7.4 Summary of Feasibility Findings for Petition SEC-00080 

This report evaluates the feasibility for completing dose reconstructions for employees at the NUMEC 

Apollo site from January 1957 through December 1983. Table 7-2 summarizes the results of the 

feasibility findings at NUMEC Apollo for each exposure source during the time period from January 

1957 through December 1983. 

Table 7-2: Summary of Feasibility Findings for SEC-00080 

January 1957 through December 1983 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal X1

 - Uranium X2

 - Other Radionuclides X1 

External X3

 - Gamma X3

 - Beta X3

 - Neutron X3

 - Occupational Medical x-ray X3 

Notes: 

18 of 23 
 

SEC-00080 08-31-07 NUMEC Apollo 

1 With the exception of any available non-CEP internal data that may be included in an individual’s file (and 

that can be interpreted using existing NIOSH dose reconstruction processes or procedures) – for the 

purpose of completing a partial internal dose reconstruction for non-presumptive cancers and/or cases that 

have less than 250 working days of employment. 2 For the time period where uranium bioassay data is available (1960-1976) 

3 With the exception of any available external data that may be included in an individual’s file (and that can be 

interpreted using existing NIOSH dose reconstruction processes or procedures), and medical X-rays that were 

performed as a condition of employment for NUMEC Apollo personnel – for the purpose of completing a partial 

external dose reconstruction for non-presumptive cancers and/or cases that have less than 250 working days of 

employment. 

8.0 Evaluation of Health Endangerment for Petition SEC-00080 

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 apparent complete lack of dosimetry data for some periods of operation, uncertainty 

about the exact nature and duration of some NUMEC Apollo processes, and the compromised 

integrity of the CEP bioassay data, NIOSH has concluded that it is not feasible to estimate radiation 

dose for members of the proposed class with sufficient accuracy based on the sum of information from 

available resources. 

This NIOSH evaluation did not identify any evidence from the petitioner or from other resources that 

would establish that the class was exposed to radiation during a discrete incident or similar conditions 

resulting from the failure of radiation exposure controls likely to have produced levels of exposure 

similarly high to those occurring during nuclear criticality incidents. NIOSH is not aware of any 

report of such an occurrence at the facility during this period. NIOSH finds that the primary radiation 

exposure hazards to employees resulted from chronic exposures from inhalation and ingestion of 

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

Consequently, NIOSH is specifying that health may have been endangered for those workers covered 

by this evaluation who were employed for a number of work days aggregating at least 250 work days 

within the parameters established for this class or in combination with work days within the 

parameters established for one or more other classes of employees in the SEC. A modification of the 

class definition regarding health endangerment and minimum required employment periods was not 

required. 

19 of 23 
 

SEC-00080 08-31-07 NUMEC Apollo 

9.0 NIOSH-Proposed Class for Petition SEC-00080 

Based on its research, NIOSH accepted the petitioner-requested class to define a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. 

The NIOSH-proposed class includes all Atomic Weapons Employer (AWE) employees who were 

monitored, or should have been monitored, for exposure to ionizing radiation while working at the 

NUMEC Plant in Apollo, Pennsylvania for a number of work days aggregating at least 250 work days 

from January 1, 1957 through December 31, 1983, or in combination with the work days within the 

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

The class is proposed because: 

•	 No bioassay data exist for the 1957-1959 time period at NUMEC Apollo and exposure scenarios 

for workers involved in the NUMEC start up operations cannot be reconstructed, 

•	 Detailed descriptions for process and duration of the thorium operations are lacking and potential 

exposure scenarios for those workers cannot be reconstructed, 

•	 Bioassay sample analyses performed by CEP cannot be considered technically valid and cannot be 

used to estimate doses, 

•	 Detailed descriptions of operations involving plutonium or the production of the Ra-Be and PoBe neutron sources are not available and potential exposure scenarios cannot be reconstructed, 

•	 No data exists on stack emissions from uranium and thorium operations, and potential exposures 

to elevated air dust resulting from these emissions cannot be reconstructed. 

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 that it would not be feasible to reconstruct the dose for the 

class proposed in this petition. 

20 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

This page intentionally left blank. 

21 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

10.0 References
 

42 C.F.R. 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. 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. 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 

Babcock & Wilcox, (BWXT NESI), 1997, Final Technical Report, Apollo Decommissioning Project, 

Apollo, Pennsylvania; DOE/EW/40017-T6, Rev. 0; SRDB Ref ID: 31243 

Caldwell, R. D., Crosby, R. F., ca. 1967, Environmental Monitoring near a Multi-Stack Uranium 

Plant; available on http://bidug.pnl.gov/rdc.htm, accessed 09/06/2007; SRDB Ref ID: 18293 

Fogel, 1992, Apollo Nuclear Fuel Facility Decontamination and Decommissioning Project; 

correspondence to Ms. Phyllis Morgan; D. M. Fogel; February 17, 1992; SRDB Ref ID: 19965 

Forscher, F., 1963, Feasibility Report # 47 for BAPL; correspondence to C. A. Keller (AEC); F. 

Forscher; October 22, 1963, December 27, 1963; SRDB Ref ID: 11965 

ORAUT-OTIB-0006, Dose Reconstruction from Occupationally Related Diagnostic X-Ray 

Procedures, Oak Ridge Associated Universities, Dec. 21, 2005, SRDB REF ID: 19422 

U.S. Atomic Energy Commission (AEC), 1960, Health and Safety Laboratory, Nuclear Materials and 

Equipment Corporation, Apollo, Pennsylvania, Occupational Exposure to Radioactive Dust; Safety 

and Fire Protection, HASL-92; New York Operations Office, August 24, 1960; SRDB Ref ID: 10460 

U.S. Atomic Energy Commission (AEC), 1960, Health and Safety Laboratory, Nuclear Materials and 

Equipment Corporation, Apollo, Pennsylvania, Occupational Exposure to Radioactive Dust; Safety 

and Fire Protection, HASL-103; New York Operations Office, November 8, 1960; SRDB Ref ID: 

10478 

U.S. Atomic Energy Commission (AEC), 1961, Major Activities in the Atomic Energy Programs, 

Jan.-Dec. 1961. United States Government Printing Office, Jan. 1962 

U.S. Atomic Energy Commission (AEC), Atomic Industrial Progress and 2nd World conference, Jul.-

Dec. 1958, United States Government Printing Office, Jan. 1959 

22 of 23 
SEC-00080 08-31-07 NUMEC Apollo 

United States Nuclear Regulatory Commission (NRC), 1994, Accuracy of bioassay and environmental 

sampling results; Office of Nuclear Materials Safety and Safeguards, NRC information notice 94-81 

23 of 23