SC&A’s Review of NIOSH’s SEC-00253 

Petition Evaluation Report for the 

Reduction Pilot Plant, Huntington, WV

Ron Buchanan, PhD, CHP

Advisory Board on Radiation and Worker Health, URAWE 

Work Group

February 17, 2022
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SC&A’s review of the evaluation report

 On September 2, 2020, SC&A was tasked with a review of 

NIOSH’s ER for SEC-00253 for this focused group of workers 

and time period.

 SC&A’s review cleared U.S. Department of Energy 

classification review in March 2021 and was delivered 

April 2, 2021 (SC&A, 2021).

 NIOSH issued a response to SC&A’s review in a memo dated 

April 29, 2021 (NIOSH, 2021).
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SC&A’s review approach

 SC&A reviewed the 77 claimant records in the NIOSH DCAS 

Claims Tracking System (NOCTS) files associated with RPP to 

identify any information relevant to dose reconstruction (DR) 

feasibility for security personnel during the period from 

June 7, 1976, to November 26, 1978.

 SC&A found that a total of 44 claimants worked a portion or all 

of 1976 through 1978 at RPP.
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SC&A’s review results

 SC&A did not identify any information that would impact the 

feasibility of DR during the SEC-00253 period for security 

guards.

 However, given that a key facet of the proposed DR process 

includes the exposure time, it is important to assure that 

estimates of time spent during relevant activities are properly 

characterized and bounded. 

– “Exposure time” = time spent inside the facility where residual 

contamination was present.
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Observation 1: Suggest further refinement of 

exposure time

 CATI information indicated that exposure time may be longer:

– Original estimate was 15 minutes per day

– Claimant A had to check all 7 floors and the perimeter

– Claimant B estimated it took 30 minutes per day

 SC&A recommended that it may be beneficial for NIOSH to attempt 

to contact and interview security guards or other workers with 

specific knowledge of the surveillance activities to assure an 

accurate or (in the absence of specific occupational time) a 

bounding estimate of the time required to walk through the facility.

 Assumptions about exposure time should not preclude DR feasibility 

and can be considered site profile issues.
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NIOSH’s response to observation 1: Exposure 

time

 NIOSH’s April 2021 revised estimate of time spent in the facility 

was 52 minutes per day, 6 days per week, for 250 days per 

year (260 hours per year).

– Estimated 5 minutes per floor (based on original ER assumptions of 

time spent walking the building floor footprint with stops) multiplied by 

7 floors.

– Accounted for the physical dimensions of the lot at a walking rate of 

4.4 feet per minute for the perimeter check (4.4 feet per second may 

have been intended).

 Increase in exposure time by a factor of approximately 3.
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NIOSH’s response to observation 1: Dose rate

 NIOSH (2021) used a maximum dose rate of 0.035 mrem/hour 

to complete the ER in a timely manner.

 NIOSH will evaluate all dose rate data.

 Site profile (NIOSH, 2018) will be revised to consider various 

dose rates.

 Site profile will be revised to add the standby period: 

May 1, 1963, through November 26, 1978.
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NIOSH’s response to observation 1: Overall 

annual dose

 The overall annual doses may be lower even when using the 

increased exposure time because of the lower dose rates 

obtained by considering all the available dose data.
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SC&A’s evaluation of NIOSH’s response to 

observation 1

 SC&A concurs with NIOSH’s reevaluation of the potential 

exposure time and finds it reasonable.

 SC&A concurs with NIOSH using the maximum dose rate to 

facilitate completion of the ER.

 SC&A finds it is appropriate to consider all applicable dose rate 

data in the revised site profile.

 SC&A recommends the time component be designated in 

abeyance pending review of the revised site profile (it may be 

important to review the revised dose rate approach).
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Observation 2: Ingestion intake not addressed 

for SEC period

 Tables 3 and 4 of the site profile give ingestion intake values 

for production workers and administrative personnel during the 

operational and decontamination and decommissioning 

periods (NIOSH, 2018, pp. 13–14). 

 However, the ER does not address potential ingestion intakes 

for the SEC period (though doses may be small).
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NIOSH’s response to observation 2

 Ingestion dose for the security guards can be estimated based 

on contamination levels. 

 The ER used the bounding alpha contamination value of 

19 dpm/100 cm2 to estimate inhalation intakes. 

 That value is applied to a 10E-4 m2/hour ingestion coefficient 

from NUREG/CR-5512 (NRC, 1992) to derive a 

0.19 disintegrations per hour alpha ingestion rate for the 

security guards.

 Details for assigning ingestion intakes will be included in the 

revised site profile.
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SC&A’s evaluation of NIOSH’s response to 

observation 2

 SC&A concurs with NIOSH’s recommendations to address 

ingestion intakes.

 SC&A recommends this observation be designated 

in abeyance pending review of the revised site profile.
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Summary of site profiles issues

Observation 1: Exposure time

 SC&A concurs with NIOSH’s 

reevaluation of the potential 

exposure time and all applicable 

dose rate data.

 SC&A recommends this 

observation remain in abeyance 

pending review of the revised site 

profile.

 SC&A recommends review of the 

revised site profile’s approach to 

dose rate.

Observation 2: Ingestion intake

 SC&A concurs with NIOSH’s 

recommendations to address 

ingestion intakes. 

 SC&A recommends this 

observation be designated 

in abeyance pending review of 

the revised site profile.
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Conclusions

 SC&A concurs with NIOSH that upper bounds can be 

established for internal intakes and external exposures.

 SC&A concurs that DR is feasible for security personnel during 

the SEC-00253 period. 
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Questions?
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References

National Institute for Occupational Safety and Health. (2018). Technical basis 

document for the Huntington Pilot Plant, Huntington, West Virginia (DCAS-TKBS- 0004, rev. 02). https://www.cdc.gov/niosh/ocas/pdfs/tbd/huntpp-r2-508.pdf

National Institute for Occupational Safety and Health. (2021, April 29). Reduction 

Pilot Plant SEC evaluation report review [Memorandum]. 

https://www.cdc.gov/niosh/ocas/pdfs/dps/dc-rppsec253-042921-508.pdf

SC&A, Inc. (2021). SC&A’s Review of NIOSH SEC-00253 petition evaluation report 

for the Reduction Pilot Plant, Huntington, WV” (SCA-TR-2021-SEC003, rev. 0). 

https://www.cdc.gov/niosh/ocas/pdfs/abrwh/scarpts/sca-rppsec253-r0-508.pdf

U.S. Nuclear Regulatory Commission (NRC). (1992). Residual radioactive 

contamination from decommissioning: Technical basis for translating contamination 

levels to annual total effective dose equivalent (NUREG/CR-5512, PNNL-7994, 

Vol. 1). SRDB Ref. ID 23558