SEC Petition Evaluation Report

Petition SEC-00252 

Report Rev Number: 0

Report Submittal Date: July 31, 2019

Subject Expert(s): Timothy Kirkham, Chris Miles

Site Expert(s): N/A

Petition Administrative Summary

Petition Under Evaluation

Petition Number: SEC-00252

Petition Type: 83.14

Petition A Receipt Date: May 1, 2019

DOE/AWE Facility Name: West Valley Demonstration Project

Petition Class

NIOSH-Proposed Class Definition: All Atomic Weapons employees who worked at the West Valley Demonstration 

Project in West Valley, New York, from January 1, 1969 through December 31, 

1973, 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 in the 

Special Exposure Cohort.

Related Petition Summary Information

SEC Petition Tracking Number(s): N/A

Petition Type: N/A

DOE/AWE Facility Name: N/A

Petition Status: N/A

Related Evaluation Report Information 

Report Title: N/A

DOE/AWE Facility Name: N/A

ORAU Preparation and Review

ORAU Lead Technical Evaluator: Timothy Kirkham

ORAU Peer Review Completed By: Daniel Stempfley
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DCAS Review and Approval

Peer Review Completed By:

[Signature on File]

Christine Corwin

July 31, 2019

SEC Petition Evaluation Reviewed By:

[Signature on File]

Timothy D. Taulbee

July 31, 2019

SEC Petition Evaluation Approved By:

[Signature on File]

Grady Calhoun 

July 31, 2019
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Evaluation Report Summary: SEC-00252, West Valley Demonstration Project

The National Institute for Occupational Safety and Health (NIOSH) prepared this evaluation report in 

response to a petition to add a class of workers at West Valley Demonstration Project (WVDP) to the 

Special Exposure Cohort (SEC). The Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended, (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, describe the process for adding new classes 

to the SEC. 

NIOSH-Proposed Class Definition 

All Atomic Weapons employees who worked at the West Valley Demonstration Project in West 

Valley, New York, from January 1, 1969 through December 31, 1973, 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. 

Feasibility of Dose Reconstruction Findings 

NIOSH lacks sufficient information, which includes biological monitoring, air monitoring 

information, or process monitoring information, to allow it to estimate with sufficient accuracy the 

potential internal exposures to uranium and mixed fission products to which the proposed class may 

have been subjected. NIOSH finds that it is not applicable to reconstruct occupational medical dose 

for West Valley Demonstration Project employees because medical X-ray procedures were performed 

at an offsite, non-EEOICPA-covered facility.

This evaluation responds to a petition based on NIOSH determining that internal radiation exposures 

could not be reconstructed for a dose reconstruction referred to NIOSH by the Department of Labor 

(DOL). The feasibility of external dose reconstruction is not addressed in this evaluation. 

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 

thorium-232 (Th-232), uranium-233 (U-233), uranium-235 (U-235), neptunium-237 (Np-237), 

uranium-238 (U-238), plutonium-238 (Pu-238), plutonium-239 (Pu-239), plutonium-240 (Pu240), plutonium-241 (Pu-241), americium-241 (Am-241), curium-244 (Cm-244), and mixed 

fission and activation products. The modes of exposure were inhalation and ingestion during fuel 

reprocessing activities.

• NIOSH has determined that the sparse uranium bioassay data available for 1969 through 1973 are 

inadequate for WVDP claimants. Mixed fission product bioassay data are likewise inadequate for 

1972 and 1973. Therefore, NIOSH cannot estimate internal doses from uranium and mixed 

fission products with sufficient accuracy for these radionuclides for this period. 
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• 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 

WVDP during the period from January 1, 1969 through December 31, 1973, but who do not qualify 

for inclusion in the SEC, may be performed using these data as appropriate.

The operational period from January 1, 1966 through December 31, 1968, was not included in this 

SEC recommendation because NIOSH has significantly more internal dosimetry data available to 

assess intakes for this period than for the January 1, 1969 through December 31, 1973 period. NIOSH 

is continuing to evaluate the quality and sufficiency of the 1966 through 1968 data.

Health Endangerment Determination

The NIOSH evaluation did not identify any evidence that would establish that the class was exposed 

to radiation during a discrete incident likely to have involved exceptionally high-level exposures, such 

as nuclear criticality incidents or other events involving similarly high levels of exposures. However, 

the evidence reviewed in this evaluation indicates that some employees in the class may have 

accumulated chronic radiation exposures through intakes of radioactive materials and from direct 

exposure to radioactive materials. Therefore, 42 C.F.R. § 83.13(c)(3)(ii) requires NIOSH to specify

that health may have been endangered for those employees 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.
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Table of Contents

Evaluation Report Summary: SEC-00252, West Valley Demonstration Project .................................... 4

Table of Contents .................................................................................................................................... 6

1.0 Purpose and Scope ....................................................................................................................... 8

2.0 Introduction ................................................................................................................................. 8

3.0 NIOSH-Proposed Class Definition and Petition Basis................................................................ 9

4.0 Radiological Operations Relevant to the Proposed Class ........................................................... 9

4.1 Operations Description ..................................................................................................... 10

4.2 Radiation Exposure Potential from Operations ................................................................ 11

4.2.1 Internal Exposure Potential .................................................................................. 12

4.2.2 External Exposure Potential ................................................................................. 12

4.3 Time Period Associated with Radiological Operations .................................................... 12

4.4 Site Locations Associated with Radiological Operations ................................................ 13

4.5 Job Descriptions Affected by Radiological Operations ................................................... 13

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

5.1 Data Capture Efforts and Sources Reviewed ................................................................... 14

5.2 Previous Dose Reconstructions ........................................................................................ 14

5.3 Employee Interviews ........................................................................................................ 15

5.4 Internal Monitoring Data .................................................................................................. 16

5.5 External Monitoring Data ................................................................................................. 18

5.6 Workplace Monitoring Data ............................................................................................. 18

5.7 Radiological Source Term Data ....................................................................................... 19

6.0 Feasibility of Dose Reconstruction for the Proposed Class ...................................................... 20

6.1 Feasibility of Estimating Internal Exposures ................................................................... 20

6.2 Feasibility of Estimating External Exposures .................................................................. 22

6.3 Class Parameters Associated with Infeasibility ................................................................ 23

7.0 Summary of Feasibility Findings for Petition SEC-00252 ........................................................ 23

8.0 Evaluation of Health Endangerment for Petition SEC-00252 ................................................... 24

9.0 NIOSH-Proposed Class for Petition SEC-00252 ...................................................................... 24

10.0 Evaluation of Second Similar Class .......................................................................................... 25

11.0 References ................................................................................................................................. 27

Attachment One: Data Capture Synopsis .............................................................................................. 31

Tables 

Table 5-1: No. of WVDP Claims Submitted Under the Dose Reconstruction Rule ............................. 14

Table 5-2: Special Bioassay Sample Requirements Following Possible Uptake of Pu, U, or MFP ..... 16

Table 5-3: No. of Available Bioassay Results for January 1, 1966 through December 31, 1973 ......... 18

Table A1-1: Summary of Holdings in the SRDB for West Valley Demonstration Project .................. 31

Table A1-2: Database Searches for West Valley Demonstration Project ............................................. 38
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SEC Petition Evaluation Report for SEC-00252

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: 

Timothy Kirkham; 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 employees who worked at the WVDP

facility during a specified time. It provides information and analysis 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, with the exception of the employee whose dose reconstruction could not be completed, and 

whose claim consequently led to this petition evaluation. The finding in this report is not the final 

determination as to whether or not the proposed class will be added to the SEC. This report will be 

considered by the Advisory Board on Radiation and Worker Health (the Board) and by the Secretary 

of Health and Human Services (HHS). The Secretary of HHS will make final decisions concerning 

whether or not to add one or more classes to the SEC in response to the petition addressed by this 

report.

This evaluation, in which NIOSH provides its findings both on the feasibility of estimating radiation 

doses of members of this class with sufficient accuracy and on health endangerment, was conducted in 

accordance with the requirements of EEOICPA and 42 C.F.R. § 83.14. 

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 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 proposed class of employees through NIOSH dose 

reconstructions.1

 

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 on the NIOSH Radiation Dose Reconstruction Program page.
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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 petitioners and the 

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

report, together with the petition, comments of the petitioner(s) and such other information as the 

Board considers appropriate, 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 final decision process, the 

petitioner(s) may seek a review of certain types of final decisions issued by the Secretary of HHS.

2

3.0 NIOSH-Proposed Class Definition and Petition Basis

The NIOSH-proposed class includes all Atomic Weapons employees who worked at the West Valley 

Demonstration Project in West Valley, New York, from January 1, 1969 through December 31, 1973, 

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. During this period, employees at 

this facility were involved in fuel reprocessing.

The evaluation responds to Petition SEC-00252 which was submitted by an EEOICPA claimant 

whose dose reconstruction could not be completed by NIOSH due to a lack of sufficient dosimetryrelated information. NIOSH’s determination that it is unable to complete a dose reconstruction for an 

EEOICPA claimant is a qualified basis for submitting an SEC petition pursuant to 42 C.F.R. § 

83.9(b). 

4.0 Radiological Operations Relevant to the Proposed Class 

The following subsections summarize the radiological operations at WVDP and the information 

available to NIOSH to characterize particular processes and radioactive source materials. Using

available sources, NIOSH has attempted to gather process and source descriptions, information 

regarding the identity and quantities of radionuclides of concern, and information describing processes 

through which the radiation exposures of concern may have occurred and the physical environment in 

which they may have occurred. The information included within this evaluation report is meant only 

to be a summary of the available information. 

 

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

available on the NIOSH Radiation Dose Reconstruction Program page.
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4.1 Operations Description

WVDP was located in Ashford, New York, in Cattaraugus County, approximately 35 miles south of 

Buffalo, New York, on a 3,345-acre site. The site was originally purchased by the state of New York 

in 1959 and was leased from New York State in 1962 by Nuclear Fuel Services, Inc. (NFS)

(Michalczak, 2004).

On May 27, 1965, WVDP (formerly referred to as the NFS West Valley facility) was granted a license 

to receive and store spent nuclear fuel (AEC, 1966, PDF p. 99), and on April 19, 1966, was granted a 

license to reprocess spent fuel. The site operated as a private, spent nuclear-fuel reprocessing center 

from 1966 through 1972 using the Plutonium Uranium Extraction (PUREX) process. In addition, a

single Thorium Extraction (THOREX) campaign took place between November 15, 1968, and 

January 20, 1969, for the Indian Point Plant (Birchler, 1970). On November 15, 1967, NFS and the 

New York State Atomic and Space Development Authority (NYSASDA) applied for a construction

permit for neptunium extraction for startup in 1970 (AEC, 1968). Fuel assemblies continued to be 

shipped to WVDP through 1972. In 1972, fuel reprocessing was halted to increase reprocessing 

capacity and upgrade the facility to meet new regulatory requirements.

Throughout its operational history, WVDP received both commercial and government spent fuels, 

with roughly 60 percent of the fuel and 33 percent of the plutonium coming from Department of 

Energy (DOE) reactors. The facility had remote-handling capabilities with a design capacity of 300 

tons of fuel per year. As a spent-fuel processing facility, WVDP did not receive recycled uranium. It 

did, however, reprocess and recover approximately 620 metric tons of recycled uranium. The 

recovered uranium was shipped to the Feed Materials Production Center in Fernald, Ohio, for 

conversion into metal and intermediate uranium compounds (DOE, 2000b, PDF p. 5).

For the period of this evaluation, January 1, 1969 through December 31, 1973, the WVDP workforce 

consisted of approximately 200-300 employees. By July 1973, NFS was down from 187 to about 65 

permanent employees (Inspection, 1973a, PDF p. 411; Inspection, 1973b, PDF p. 453).

Fuel Reprocessing Activities

Fuel reprocessing operations using the PUREX process took place from 1966 through 1972. The 

PUREX process was utilized for recovering uranium and plutonium. This process included storing

spent fuel assemblies; chopping the assembly rods; dissolving the uranium, plutonium, and 

radioactive products in acid; separating and storing the radioactive wastes; and separating uranium 

nitrate from plutonium nitrate. The plant was designed to facilitate the remote handling of spent 

reactor fuel and to separate and recover the uranium and plutonium. Fission products were separated 

from the product material and processed as liquid-waste materials.

The PUREX process utilized pulsed solvent-extraction columns with a counter-current flow of tributyl 

phosphate and kerosene. This organic solvent would pick up the plutonium and uranium nitrates, 

while the fission products would remain and were removed in the aqueous phase. The recovered 

materials were extracted and concentrated together in the organic solvent and then purified by 

chemical scrubbing with dilute, nitric acid. Two further cycles of solvent extraction and scrubbing 

each resulted in separate, concentrated, and purified aqueous solutions of plutonium nitrate and 

uranium nitrate (DOE, 2000a, PDF p. 53).
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From 1966 to 1972, WVDP handled and reprocessed a total of 630 tons of spent fuel from nine 

different reactors during 28 campaigns. Fuels processed included light-water reactor fuels (from both 

boiling- and pressurized-water reactors), fuels from Atomic Energy Commission (AEC)-owned 

reactors (such as the Hanford N Reactor), and a uranium-thorium fuel cycle core from the Indian Point 

1 Reactor. Plutonium and uranium recovered from irradiated fuels were delivered as nitrates. The 

recovered uranium was sent to the Feed Materials Production Center in Ohio and the plutonium was 

sent to either the Hanford site in Washington or later to the offsite NYSASDA Plutonium Storage 

Facility. In general, AEC plutonium was sent to Hanford, and utility-owned plutonium was retained 

by the utilities, sold to industry, or sold to NFS so that it could be resold later for plutonium-recycle 

processes. NFS and NYSASDA entered into a plutonium storage agreement on May 3, 1971, in 

which NYSASDA would store plutonium at its Plutonium Storage Facility, located approximately 

2,200 meters south-southeast of the NFS site (NYSASDA and NFS, 1971).

Following a THOREX processing campaign for the Indian Point Plant, which took place from 

November 15, 1968 through January 20, 1969, the processing system was thoroughly flushed in order 

to reduce the amount of highly-enriched uranium in its systems. Thorium-fuel processing required 

significant changes to the recovery process in order to account for the high levels of thorium, U-235, 

and U-233 present. The fuel also contained Pu-239. The high concentrations of fissile species 

required the use of boron in the dissolving process. A number of systems normally used in processing 

(e.g., wash systems, silica beds) were not used due to criticality concerns. High Pu-238 activity 

required resin beds to be regenerated more frequently than usual. By 1970, the plant had processed 

spent fuel with burnups as high as 30,000 MWd/MTU (Runion, 1970).

The last fuel reprocessing campaign at WVDP was completed in November 1971 (Nelson, 1973a). 

The last plutonium scrap-recovery operation took place in March 1972 (Inspection, 1973b, PDF p. 

453). Afterward, WVDP was in a shutdown condition, with operations limited to fuel receipt and 

storage and decontamination activities. Per the AEC, decontamination activities were significantly 

reduced after May 1973 (Nelson, 1973b).

4.2 Radiation Exposure Potential from Operations

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

WVDP class under evaluation. Descriptions of facility-specific radiological operations are presented 

in more detail in Section 4.4.

Fuel segmentation operations at WVDP resulted in substantial quantities of high-specific-activity 

airborne particulate matter, resulting in significant operational difficulties associated with the plant 

ventilation systems and airflow issues. This, coupled with other unforeseen circumstances involving 

radioactivity in systems where it was not anticipated, or at unanticipated levels, meant radiological 

conditions encumbered operations at WVDP from the outset. Routine maintenance activities had to 

be performed in high-dose-rate environments. Dose rates in normally-occupied areas were high, and 

radiological contamination from maintenance activities and spills was also substantial plant-wide. 

High background levels compromised the effectiveness of contamination control measurements

(ORAUT-TKBS-0057).
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4.2.1 Internal Exposure Potential 

The potential for intakes of radioactive materials resulting from fuel reprocessing activities existed at 

the WVDP throughout the AWE time period. An AEC letter dated March 16, 1972, states: 

“...criteria and objectives for the protection of plant personnel have not been fully realized. You 

have failed to maintain effective containment of radioactive material to areas within the process 

equipment, cells and plant systems and your program for protecting your workers through the use 

of masks and other protective equipment has not been completely adequate in that NFS records 

and reports show that during the years 1966 through 1971, 36 individuals (in 13 separate 

incidents) have been exposed during their work, to excessive concentrations of radioactive 

materials which resulted in the uptake of such materials in the body through inhalation or 

ingestion. In addition, our inspectors have observed, and plant records show, that radioactive 

contamination also exists outside plant buildings in areas of the plant environs. Furthermore, from 

inspection of these data and from the observations by our inspectors, it appears that there has been 

no significant improvement in exposure controls or radiological safety conditions during the 

operating history of your plant” (Low, 1972, PDF p. 185). 

Sources of internal radiation dose for members of the evaluated class included exposures to U-233, 

Np-237, Pu-238, Pu-239, Pu-240, Pu-241, Am-241, Cm-244, and mixed fission and activation 

products (WVDP, 2005; Michalczak, 2004).

4.2.2 External Exposure Potential 

The potential for external radiation doses from exposure to beta, photon, and neutron radiation from 

various radioactive materials also existed at the WVDP site. This evaluation, however, responds to a 

petition based on NIOSH determining that internal radiation exposures could not be reconstructed for 

a dose reconstruction referred to NIOSH by DOL. HHS considers this determination to be sufficient, 

without further consideration of external exposure potential, to determine that it is not feasible to 

estimate the levels of radiation doses of individual members of the class with sufficient accuracy. 

Consequently, it is not necessary for NIOSH to fully evaluate the feasibility of reconstructing external 

radiation exposures for the class of employees covered by this report. Therefore, details regarding 

external dose are not addressed in this document. 

4.3 Time Period Associated with Radiological Operations

Although this evaluation is specific to the period from January 1, 1969 through December 31, 1973, 

per the DOE Office of Health, Safety and Security, the time period associated with AWE operations at 

WVDP is from January 1, 1966 through December 31, 1973. NIOSH has discovered no additional 

data to support more specific dates for the start and stop of AWE operations. Therefore, AWE work 

at WVDP is assumed to have started on January 1, 1966, and to have continued through December 31, 

1973, which encompasses NIOSH’s proposed class time period. The early operational period from 

January 1, 1966 through December 31, 1968, was not included in this evaluation because NIOSH 

believes it may have sufficient internal dosimetry data available for this period to support individual 

dose reconstructions. NIOSH is continuing to evaluate the period from 1966 through 1968.
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4.4 Site Locations Associated with Radiological Operations

WVDP’s Reprocessing Plant consisted of a complex of cells with the various supporting and 

operating areas grouped around them. The plant was arranged in a U-shape, with the Fuel Receiving 

and Storage (FRS) Facility on one end and the Product Removal Facilities on the other. The 

mechanical and chemical processing cells were in the middle (Runion, 1970). Most areas of the 

Reprocessing Plant fell into one of three categories: shielded cells, operating aisles, and unshielded 

rooms (WVDP, 2005). The cells consisted of reinforced concrete walls several feet thick. The rest of 

the plant was constructed out of cinderblock. Chemical operations were directed from the Control 

Room, while mechanical operations were directed from operating aisles adjacent to viewing windows

in the hot cells (Runion, 1970).

NIOSH has concluded that the available documentation does not indicate any definite boundaries 

between radiological and non-radiological areas for the period being evaluated. Furthermore, NIOSH 

has determined that the site-specific and claimant-specific data available for the time period covered 

in this evaluation are insufficient to allow NIOSH to characterize employee movements across the 

WVDP site. NIOSH is therefore unable to define individual employee exposure scenarios based on 

specific work locations within the WVDP site during the period under evaluation.

4.5 Job Descriptions Affected by Radiological Operations

NIOSH has determined that the site-specific and claimant-specific data available for WVDP for the 

time period under evaluation are insufficient to allow NIOSH to determine that any specific work 

group was not potentially exposed to radioactive material releases or possible subsequent 

contamination. NIOSH has insufficient information associating job titles and/or job assignments with 

specific radiological operations or conditions. Without such information, NIOSH is unable to define 

potential radiation exposure conditions based on employee job descriptions.

5.0 Summary of Available Monitoring Data for the Proposed Class

The primary data used for determining internal exposures are derived from personal monitoring data, 

such as urinalyses, fecal samples, and whole-body counting results. If these are unavailable, the air 

monitoring data from breathing zone and general area monitoring are used to estimate the potential 

internal exposure. If personal monitoring and breathing zone area monitoring 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 to the cancer site. 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 the potential 

exposure.

A more detailed discussion of the information required for dose reconstruction can be found in 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, and OCAS-IG-002, Internal 

Dose Reconstruction Implementation Guideline. These documents are available at: 

http://www.cdc.gov/niosh/ocas/ocasdose.html.
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5.1 Data Capture Efforts and Sources Reviewed 

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

regarding WVDP. The database search included the DOE Noncompliance Tracking System, the DOE 

Occurrence Reporting and Processing system, the Defense Technical Information Center, the DOE 

Legacy Management Considered Sites database, the DOE Office of Scientific and Technical 

Information (OSTI) SciTech Connect database, and the Hanford Declassified Document Retrieval 

System. In addition to general Internet searches, the NIOSH Internet search included OSTI OpenNet 

Advanced searches, Nuclear Regulatory Commission (NRC) Agency-wide Documents Access and 

Management (ADAMS) web searches, and the DOE-National Nuclear Security AdministrationNevada Site Office-search. Attachment One contains a summary of WVDP 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. NIOSH also conducted major physical data captures at the WVDP site, the Nuclear 

Regulatory Commission Public Document Room, and the Lee’s Summit, Missouri Federal Records 

Center where 7,781 documents were captured. 

5.2 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. Table 5-1 summarizes the results of this review. (NOCTS data available as of July 19, 

2019) 

Table 5-1: No. of WVDP Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 150

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

(January 1, 1969 through December 31, 1973) 35

Total number of claims submitted for energy employees who started their employment during the period 

under evaluation (January 1, 1969 through December 31, 1973) 12

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).

33

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

evaluated class definition 24

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

evaluated class definition 33

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

records could be obtained for the employee. As indicated in Table 5-1, of the total number of claims 
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submitted for energy employees who worked within the time period under this evaluation, 24 (69%) 

contain internal monitoring data and 33 (94%) contain external monitoring data.

5.3 Employee Interviews

This evaluation was initiated because the internal dosimetry data provided by DOE was found to be 

incomplete. Employee interviews for the specific purpose of supporting this evaluation were not 

considered likely to produce new information that would change the feasibility findings for the period 

under evaluation. Therefore, NIOSH did not conduct interviews for this SEC-00252 evaluation. 
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5.4 Internal Monitoring Data

In vivo and in vitro bioassay data were utilized to varying degrees at WVDP during the operational 

period. Assays utilized have included chest counts, whole-body counts, urine, and fecal analysis. 

Targeted radionuclides have included Am-241, Pu-239/240, mixed fission products (MFP), activation 

and corrosion products (Monitoring, 1967–1975, PDF p. 2104), and uranium. From 1966 to 

September 1972, a chest counter was used for ad hoc onsite screening and a phoswich counter at 

NYU-Rochester was used for post-incident follow-up counts for transuranic radionuclides.

In 1967, NFS appears to have used a bioassay program focused on estimating intakes of plutonium. If 

potential intakes occurred at a Mechanical Processing Area, the plutonium was assumed to be in an 

insoluble metal or oxide form. This plutonium, which would most likely appear in fecal samples, was 

assumed to have been accompanied by fission products. Nasal smears analyzed for fission products 

were believed to be more sensitive indicators of plutonium intakes than fecal samples. The bioassay 

program in these areas included nasal smears for fission products and chest counting using a 3-inch by 

3-inch Na I detector. Depending on the nasal smear and chest count results, fecal samples would also 

be obtained and/or whole-body counting would be used to estimate intakes. If plutonium intakes were 

suspected in a Chemical Processing Area, the plutonium was assumed to be in a soluble nitrate form 

and urinalyses were used to assess intakes (Runion, 1967, PDF p. 29). 

Table 5-2 shows the levels (in disintegrations per minute [DPM]) at which special bioassay samples 

were required circa early 1968 for plutonium, uranium, and MFP (WVDP, 1968, PDF pp. 34-36). 

Table 5-2: Special Bioassay Sample Requirements Following Possible Uptake of Pu, U, or MFP

Evidence of 

Exposure

Action Point for 

Plutonium

Action Point for 

Uranium

Action Point for 

MFP Action Taken

Activity in nasal 

passages 50 dpm alpha 500 dpm alpha 500 dpm beta Collect 2 consecutive urine samples

Activity in nasal 

passages 500 dpm alpha 5,000 dpm alpha 5,000 dpm beta Collect 5 consecutive urine samples

Skin contamination 50,000 dpm 

alpha

100,000 dpm 

alpha

500,000 dpm 

beta Collect 2 consecutive urine samples

An inspection conducted by the AEC in 1974 found that the WVDP nasal smear action limits of 50 

dpm alpha and 5,000 dpm beta were not technically justified and were inappropriate. The report 

indicated that the derivation of the site’s nasal action limits were not based upon the limits prescribed 

by 10 C.F.R. § 20.103, but were set to equal an inhaled activity which would give a 1% body burden 

of Pu-239 and Sr/Y-90. The inspection report states that if the same calculation had been 

appropriately based upon exposures equivalent to 40 MPC hours of Pu-239 and Sr-Y-90, the nasal 

action levels would be significantly less (i.e., 5.6 dpm alpha and 2,800 dpm beta, respectively) 

(O’Reilly, 1975). 

The inspection report cited an example of an employee with a nasal smear showing 16 dpm alpha and 

9,000 dpm beta. The employee was required to submit a urine sample and was whole-body counted. 

The raw data for the whole-body count was located but the evaluation interpreting the data wasn’t 

documented, although the site maintained at the time that the count did not indicate significant 

exposure to airborne MFP. The urine sample was not sent to the vendor for analysis until nearly three
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months after it was submitted. In the meantime, the employee continued to perform radiological 

work. The inspector not only found the nasal smear action level to be inappropriate, but also found no 

basis for using the nasal smear results for purposes of evaluating the extent of an exposure as opposed 

to using it only as an indicator of potential exposure (O’Reilly, 1975). 

NIOSH has access to some bioassay results beginning in January 1967 and going past December 1973 

(Monitoring, 1967–1973). Results show urine data analyzed for total plutonium (Total Pu) and MFP 

for 1967, and beginning in October 1967, the results show Total Pu and MFP in fecal results 

(continuing until 1970). Then in January 1970, fecal results for Pu-239 and Total Pu are presented, as 

well as MFP in urine. These data continue into August 1972 when Pu-239 and Pu-240 results are 

found for urine samples. The urine samples for Pu-239, Pu-240, and Total Pu continue into 1973, 

along with some fecal sample results with the same analyses. In March 1973, there are results for 

Am-241 in urine. NIOSH found evidence of the ability to perform thorium bioassay, but no results 

for thorium were located. 

Event-driven conditions requiring a bioassay sample were listed as (Clark, 1968, PDF p. 95): 

• a positive nose blow is detected, 

• work is completed in areas with alpha contamination above 500,000 dpm/100 cm2

, 

• loss of air supply in areas with smearable contamination above 500 dpm alpha/100 cm2 or 50,000 

dpm beta/100 cm2 , and/or 

• facial contamination above 50 cpm alpha or 100 cpm beta/probe area is detected.

A Safety and Industrial Relations monthly report from [Month redacted] 1969 includes an example of 

a lack of control of airborne activity. The report indicates that on [Month/day redacted], ten 

employees and three visitors were exposed to airborne activity in the [Location redacted]. Initial chest 

counts on these individuals showed lung burdens to 50%. However, a recount 12 days later showed 

that the lungs had cleared the radioactivity (Keely, 1969, PDF p. 499). 

NIOSH located many delinquent notices that placed workers on work restriction due to the workers

not submitting a required bioassay; some workers were restricted over several weeks due to continued 

violations. One notice dated [Month/day redacted], 1971, contained sixteen worker names, [Number 

redacted] of whom had been delinquent more than once, and [Number redacted] of those were 

delinquent by eight months (Wilcox, 1971); thus, indicating an inadequate bioassay program. There is 

some indication that notices were issued lifting work restrictions, but NIOSH has not located a 

comprehensive list tracking work restrictions or the release from work restrictions.

Correspondence regarding a yearly report for 1970 implies that urinalyses for radionuclides other than 

mixed fission and activation products were performed onsite, and that counts were often lost “due to 

electrical storms.” Sample counting began in April 1970. The reported results show that 

approximately 10% of the counts were lost. The 1970 onsite counting included samples collected in 

1969 since they lost three months of counting due to a labor strike. WVDP personnel counted 393 

urine samples in house, shipped out approximately 150 samples for urinalysis for MFP, and shipped 

out approximately 200 fecal samples (Kester, 1971, PDF p. 1378).
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Table 5-3 shows the number of various bioassay data results that NIOSH obtained through its data 

capture efforts for the period from January 1, 1966 through December 31, 1973. 

Table 5-3: No. of Available Bioassay Results for January 1, 1966 through December 31, 1973

Year Urine

Plutonium

Fecal

Plutonium

Urine

Uranium

Urine

MFP

Fecal

MFP

Total

In Vitro

Whole 

Body 

Count

Chest 

Count

1966 2 0 0 2 0 4 2 0 

1967 782 106 46 225 1 1160 160 0 

1968 527 68 89 221 1 906 128 2 

1969 1 21 5 56 10 93 120 8 

1970 1 178 1 75 2 257 165 0 

1971 2 193 1 104 28 328 11 11

1972 116 61 1 45 1 224 4 11

1973 249 11 1 1 1 263 0 0 

Sources: Monitoring, 1965-1967, PDF p. 163; Monitoring, 1966–1973, PDF pp. 26, 89; Monitoring, 1967–1975, PDF pp. 

1798–2041 and 2065–2177

As noted in Table 5-3, NIOSH’s evaluation of the available bioassay data indicated a marked decrease 

in the number of plutonium and uranium bioassay samples starting in 1969 with a significant, 

sustained decrease in the uranium urine bioassays (Monitoring, 1966-1973). A discussion of the 

bioassay program in a WVDP letter dated June 28, 1968, indicates that the supplier of bioassay 

services, Isotopes, Inc., was providing poor quality work in identifying positive routine samples. 

WVDP chose to change suppliers to Eberline Instrument Corporation at that time. The letter also 

denotes cost cutting efforts including discontinuing annual MFP analysis, decreasing plutonium 

routine analyses from quarterly to annually (because of the increased sensitivity of the Eberline 

analyses), and a possible increase in special sampling (Keely, 1968). The decrease in routine 

sampling as discussed in this letter is corroborated in the NIOSH data analysis presented in Table 5-3. 

5.5 External Monitoring Data

As stated in Section 4.2.2, this evaluation responds to a petition based on NIOSH determining that 

internal radiation exposures could not be reconstructed for a dose reconstruction referred to NIOSH by 

the DOL. External dose reconstruction is not addressed in this evaluation. 

5.6 Workplace Monitoring Data

NIOSH could not locate breathing zone air sample data. NIOSH has access to air sample data sheets 

indicating results from March 1970 in the General Purpose Cell Room and from 1973 in the 

Analytical Aisle (via Continuous Air Monitor). This same dataset also includes copies of logbook 

pages with gross alpha and gross beta results from routine (daily and weekly) air monitoring from 

1966 through 1974 (Monitoring, 1966–1974). 
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NIOSH has access to Radiation Contamination status reports for August 1965 through December 

1967 (Monitoring, 1965–1967). These reports indicate that relatively high contamination levels were 

common in many areas, with both alpha- and beta-smearable levels often exceeding several hundred 

thousand dpm/100 cm2, and even exceeding several million dpm/100 cm2 in some areas. The reports 

appear to highlight the most heavily contaminated areas. Detailed air concentration levels are not 

provided, although in some instances particularly high levels are described in terms of mrads/hr by 

direct sample measurement with a survey meter. These reports group areas and rooms into specified 

zones, depending on their contamination status. For example, “Zone III” areas are defined as having 

contamination levels ranging from 50 to 500 dpm/100 cm2 alpha or 500 to 5000 dpm/100cm2 beta. 

Rooms and areas designated as airborne contamination areas are also listed on these reports. Entry 

into airborne contamination areas required supplied respiratory protection. Airborne contamination 

areas are defined as areas where airborne contamination levels exceed the MPC (maximum 

permissible concentration), 2 x 10-12 μCi/cc for long-lived alpha, based on Pu-239, and 1 x 10-9 μCi/cc 

for long-lived beta, based on mixed fission products.

NIOSH has access to logbook pages that list alpha- and beta-contamination smear and dose-rate 

results from 1972 through 1974 by room location (Monitoring, 1972–1974, PDF pp. 26–119). These 

logbook pages document routine contamination and dose rate surveys from July 1973 through October 

1974 in various areas. Some areas were surveyed weekly, some monthly, and others quarterly. The 

units associated with these smear results are unspecified, but are likely dpm/100 cm2. The radiation 

level results are in units of mR/hr.

5.7 Radiological Source Term Data

The WVDP facility, with a design capacity to process 300 tons of spent fuel per year, reprocessed and 

recovered approximately 620 metric tons of recycled uranium. While NIOSH has access to the 

primary radionuclides that were present and workers worked with at WVDP, specific information that 

would support a source term exposure evaluation for the WVDP workers is limited.

Available nuclide mix information for product streams show that the plutonium produced at WVDP 

was, in general, approximately 75% Pu-239 by weight. In terms of alpha activity, the data show that, 

in general, the dominant nuclide was Pu-238 (Shipping, 1969–1970; Monitoring, 1967–1975, PDF pp. 

2020–2037). This is consistent with the reactor-grade plutonium that was being separated.

From November 15, 1968, through January 20, 1969, the Reprocessing Plant ran a THOREX fuel 

cycle to reprocess thorium-uranium fuel from Indian Point Unit 1 (an offsite nuclear plant). Thus

during this time period, in addition to the other nuclides normally encountered, workers would have 

encountered thorium, thorium decay products, and U-233 during work activities in the Reprocessing 

Plant. There was also higher-than-usual amounts of U-235 and Pu-238 present during this campaign 

(Birchler, 1970).

Beta contamination at WVDP would have included a mixture of fission and activation products 

representative of irradiated nuclear fuel. The nuclides present would have included H-3, Co-58, Co60, Sr/Y-90, Zr/Nb-95, Tc-99, Ru/Rh-106, Sb-125, Cs-134, Cs-137, Ce-141, and Ce-144. In 1966, 

the principal gamma emitters in the FRS pool water were found to be Co-58, Co-60, and Cs-137 

(Loud, 1966). In May 1972, isotopic measurements of FRS pool water included concentration data 

for Cs-134, Cs-137, Ru/Rh-106, Ce/Pr-144, and Sb-125 (Jaroszeski, 1972). Ruthenium was a large 
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contributor to the radioactivity in the acid recovery system (NFS, 1973–1976, PDF p. 98). 

Technetium-99 was prominent in the Uranium Product Cell (WVDP, 2005).

6.0 Feasibility of Dose Reconstruction for the Proposed Class 

42 C.F.R. § 83.14(b) states that HHS will consider a NIOSH determination that there was insufficient 

information to complete a dose reconstruction, as indicated in this present case, to be sufficient,

without further consideration, to conclude that it is not feasible to estimate the levels of radiation 

doses of individual members of the class with sufficient accuracy.

In the case of a petition submitted to NIOSH under 42 C.F.R. § 83.9(b), NIOSH has already 

determined that a dose reconstruction cannot be completed for an employee at the DOE or AWE 

facility. This determination by NIOSH provides the basis for the petition by the affected claimant. 

Per § 83.14(a), the NIOSH-proposed class defines those employees who, based on completed 

research, are similarly affected and for whom, as a class, dose reconstruction is similarly not feasible. 

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility for 

whom NIOSH believes that dose reconstruction is similarly infeasible, but for whom additional 

research and analysis is required. If so identified, NIOSH would address this second class in a 

separate SEC evaluation rather than delay consideration of the claim currently under evaluation (see 

Section 10). This would allow NIOSH, the Board, and HHS to complete, without delay, their 

consideration of the class that includes a claimant for whom NIOSH has already determined a dose 

reconstruction cannot be completed, and whose only possible remedy under EEOICPA is the addition 

of a class of employees to the SEC.

This section of the report summarizes research findings by which NIOSH determined that it lacked 

sufficient information to complete the relevant dose reconstruction and on which basis it has defined 

the class of employees for which dose reconstruction is not feasible. NIOSH’s determination relies on 

the same statutory and regulatory criteria that govern consideration of all SEC petitions.

6.1 Feasibility of Estimating Internal Exposures

NIOSH has evaluated the available employee and workplace monitoring data and source-term 

information and has determined that there are insufficient data for estimating internal exposures, as 

described below.

Some in vitro and in vivo bioassay data are available for workers at WVDP during the evaluated AWE 

period, as presented in Section 5.4. These data, from chest counts, whole-body counts, and urine and 

fecal analyses, included results for intakes of Pu-239, Pu-240, total Pu, Am-241, total U, and MFP, 

including Cs-137, Ru-103/106, Zr/Nb-95, Zn-65, Co-60, and Co-58. The available data, however, are 

likely to be incomplete. Table 5-1 indicates that there were 24 claims for which internal dosimetry 

records were obtained for the identified years in the evaluated class definition. DOE provided internal 

dosimetry data for only 12 of those 24 claims and NIOSH found additional internal dosimetry data, 

both in vivo and in vitro, for 10 of those 12. For the remaining 12 claims, claims for which DOE was 

unable to provide any internal dosimetry data, all of the in vivo and in vitro bioassay data were 

obtained via NIOSH data capture efforts.
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It is evident that DOE has not provided all internal dosimetry data for all claimants, given the fact that 

NIOSH has found additional data, beyond that provided by DOE, for most of the claimants to date. 

For other claims, DOE has provided data that NIOSH did not find in its data capture efforts. This 

leads NIOSH to conclude that neither set of data, DOE provided or NIOSH data capture, includes all 

bioassay data. Furthermore, NIOSH has no basis to conclude that the combination of both sets of data

include all bioassay data. Given this potential for missing bioassay data, NIOSH has concluded that 

the data are insufficient for estimating all internal exposures.

Table 6-1 provides a summary of the plutonium, uranium, and mixed fission product bioassay 

analyses available from the combined urine, fecal, and whole-body count data. 

Table 6-1: Summary of Bioassay Analyses by Major Radionuclide and Year

Year Total Pua

Analyses

Total Ub

Analyses

Total MFPc

Analyses

1966 2 0 4

1967 888 46 386

1968 595 89 250

1969 22 5 186

1970 179 1 242

1971 195 1 143

1972 177 1 50

1973 260 1 2

a) Urine and fecal combined

b) Only urinalysis is available

c) Urine, fecal, and whole-body count total

Considering the small workforce of approximately 200-300 workers, the development of a co-worker 

model for some radionuclides for some years may be feasible. In particular, the large quantity of data 

in 1967 and 1968 suggests that a co-worker model may be feasible for those years. NIOSH is 

evaluating this possibility. A co-worker model for plutonium in 1969 might be feasible. It would 

depend on whether the stability of the workforce would enable interpolation from the co-worker 

model results for 1968 and 1970. However, as shown in Table 6-1, the inadequate bioassay 

information for uranium from 1969 through 1973, coupled with the inadequate bioassay information 

for mixed fission products in 1972 and 1973, would make a co-worker model for all radionuclides 

across the 1969 to 1973 time period infeasible. As indicated previously, NIOSH is still evaluating the 

1966 to 1968 time period. Although data in 1966 are limited, reprocessing operations do not appear to 

have started until the latter portion of the year; therefore, the absence of bioassay may or may not be 

an issue for co-worker model development. 

The radiological source term included relatively large quantities of various radioactive materials that 

posed significant risk for intakes. It is evident from logbook entries and associated data that air 

monitoring was used to identify airborne contamination areas. There are also some air sample results 

from the General Purpose Cell Room in March 1970, and there are some Continuous Air Monitor 

(CAM) results from the Analytical Aisle in 1973. Air concentration data can be used to bound 

internal exposures when there are low-to-moderate concentrations. In order to perform maintenance, 

entry into high-airborne radioactive areas requiring respiratory protection was not uncommon at the 

West Valley Demonstration Project. The use of respiratory protection in high-airborne concentration 

areas greatly complicates dose reconstruction, and nasal smears and/or bioassay is relied upon to 

assess potential intakes. Previous discussions concerning nasal-smear action levels indicate that the 

site used much higher action levels than would currently be required. As a result, there could have 
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been unmonitored intakes for which the site did not take any follow-up action to assess potential 

internal exposures. As a result of this practice, personal bioassay or use of bioassay co-worker models 

would be the only sufficient methods for accurately assessing internal exposures. The use of air 

concentration data to bound intakes for all workers for all radionuclides in all areas for the period 

from January 1, 1969 through December 31, 1973 is not considered sufficiently accurate when 

considering high-airborne concentration levels while respiratory protection may or may not have been 

used. 

Surface contamination results, as presented in Section 5.6 of this report, indicate that relatively high 

contamination levels were common in many areas throughout the operational period. The 

contamination levels, both alpha and beta, were quite variable depending upon location, with 

smearable contamination ranging from virtually non-contaminated to several million dpm/100 cm2. 

NIOSH finds it infeasible to determine the times that workers may have spent in the various different 

areas and also finds it unreasonable to assume that workers spent all of their time in the most heavily 

contaminated areas. Furthermore, since the available data are gross alpha and gross beta, NIOSH 

would need to make assumptions regarding the isotopic composition of these results in order to 

reconstruct doses. Due to the large uncertainties regarding isotopic composition of the contamination 

and worker occupancy in the various areas, NIOSH finds it infeasible to estimate worker intakes with 

sufficient accuracy using these data. The data that are available do support NIOSH’s position that 

there was significant potential for intakes.

NIOSH does not have access to sufficient employee monitoring, workplace monitoring, or source 

term data to estimate potential internal exposures to uranium and mixed fission products during the 

period of AWE operations. Consequently, NIOSH finds that it is not feasible to estimate, with 

sufficient accuracy, the internal exposures to uranium or mixed fission products and the resulting 

doses for the class of employees under evaluation.

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

period from January 1, 1969 through December 31, 1973, 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 West Valley Demonstration Project during the period from January 1, 1969 through 

December 31, 1973, but who do not qualify for inclusion in the SEC, may be performed using these 

data as appropriate.

6.2 Feasibility of Estimating External Exposures

This evaluation responds to a petition based on NIOSH determining that internal radiation exposures 

could not be reconstructed for a dose reconstruction referred to NIOSH by DOL. As noted previously, 

HHS will consider this determination to be sufficient without further consideration to determine that it 

is not feasible to estimate the levels of radiation doses of individual members of the class with 

sufficient accuracy. Consequently, it is not necessary for NIOSH to fully evaluate the feasibility of 

reconstructing external radiation exposures for the class of employees covered by this report. 
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NIOSH intends to use any available external monitoring data that may become available for an 

individual claim (that can be interpreted using existing NIOSH dose reconstruction processes or 

procedures). Dose reconstructions for individuals employed at WVDP during the period from January 

1, 1969 through December 31, 1973, but who do not qualify for inclusion in the SEC, may be 

performed using these data as appropriate.

6.3 Class Parameters Associated with Infeasibility

The time period associated with AWE operations at WVDP is January 1, 1966 through December 31, 

1973. Through the course of ongoing dose reconstruction and data capture efforts, NIOSH has 

determined that it is unable to estimate, with sufficient accuracy, the total internal dose for WVDP 

employees for the time period from January 1, 1969 through December 1973. Therefore, NIOSH 

recommends that the NIOSH-proposed class include the period from January 1, 1969 through 

December 31, 1973.

Based on the information available to NIOSH, it cannot associate WVDP personnel with specific 

buildings. There were no barriers between the buildings, and certain personnel, such as maintenance

personnel, may have worked in more than one building. NIOSH is unable to define individual 

employee exposure scenarios based on specific work locations within the WVDP. Therefore, NIOSH 

recommends that the proposed class definition include all areas of WVDP during the specified timeperiod.

NIOSH has also found insufficient documentation associating job titles and/or job assignments with 

specific radiological operations or conditions. Without this information, NIOSH is unable to define 

the proposed SEC class based on job descriptions. NIOSH therefore recommends that the proposed 

class include personnel having worked in any area of WVDP and include all job descriptions.

7.0 Summary of Feasibility Findings for Petition SEC-00252

This report evaluates the feasibility for completing dose reconstructions for employees at WVDP from 

January 1, 1969 through December 31, 1973. NIOSH determined that members of this class may 

have received radiation exposures through intakes of Th-232, U-233, U-235, Np-237, U-238, Pu-238, 

Pu-239, Pu-240, Pu-241, Am-241, Cm-244, and mixed fission and activation products. NIOSH lacks 

sufficient information, such as internal dose monitoring, air monitoring, source term, and 

contamination monitoring data, which would allow it to estimate the potential cumulative internal 

exposures to which the proposed class may have been exposed.

NIOSH has documented herein that it cannot complete the dose reconstructions related to this petition. 

The basis of this finding demonstrates that NIOSH does not have access to sufficient information to 

estimate either the maximum radiation dose incurred by any member of the class or to estimate such 

radiation doses more precisely than a maximum dose estimate.

NIOSH finds that it is not feasible to estimate, with sufficient accuracy, the internal radiation doses 

received by members of the proposed class of employees from January 1, 1969 through December 31, 

1973. The time period for the recommended class is the latter portion of the AWE period, as defined 

in the DOE Covered Facility Database. NIOSH will continue to evaluate dose reconstruction 

feasibilities for the 1966 to 1968 operating period and the post-1973 residual radiation period at 

WVDP.
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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 

WVDP during the period from January 1, 1969 through December 31, 1973, 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-00252

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by EEOICPA and 42 C.F.R. § 83.14(b) and § 83.13(c)(3). Pursuant to these requirements, if 

it is not feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH 

must determine that there is a reasonable likelihood that such radiation doses may have endangered 

the health of members of the class. The regulations require 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 employees 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.

NIOSH has determined that members of the class were not exposed to radiation during a discrete 

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

criticality incidents. However, the evidence reviewed in this evaluation indicates that some 

employees in the class may have accumulated chronic internal and external radiation exposures from

Th-232, U-233, U-235, Np-237, U-238, Pu-238, Pu-239, Pu-240, Pu-241, Am-241, Cm-244, and 

mixed fission and activation products. Consequently, NIOSH is specifying that health was 

endangered for those employees 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.

9.0 NIOSH-Proposed Class for Petition SEC-00252

The evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. This class includes all Atomic Weapons employees who worked at the West 

Valley Demonstration Project in West Valley, New York, from January 1, 1969 through December 

31, 1973, 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.
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10.0 Evaluation of Second Similar Class

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility, 

similar to the class defined in Section 9.0, for whom NIOSH believes that dose reconstruction may not 

be feasible, and for whom additional research and analyses is required. If a second class is identified, 

it would require additional research and analyses. Such a class would be addressed in a separate SEC 

evaluation rather than delay consideration of the current claim. At this time, NIOSH has not identified 

a second similar class of employees at WVDP for whom dose reconstruction may not be feasible.
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11.0 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; DCAS website

AEC, 1966, Annual Report to Congress on the Atomic Energy Commission for 1965; United States 

Atomic Energy Commission (AEC); January 1966; SRDB Ref ID: 36190 

AEC, 1968, Annual Report to Congress on the Atomic Energy Commission for 1967; United States 

Atomic Energy Commission (AEC); January 1968; SRDB Ref ID: 40951 

Birchler, 1970, Plant Cleanout Between Processing of a Thorium Fuel and a Low Enriched Uranium 

Fuel, correspondence to J. R. Clark; J. E. Birchler; December16, 1970; SRDB Ref ID: 26331, PDF p. 

33 

Clark, 1968, Compliance with AEC Letter of December 28, 1968, correspondence to Dr. E. D. North 

(includes attachments); J. R. Clark; April 8, 1968; SRDB Ref ID: 24455, PDF pp. 87–101 

DOE, 2000a, Recycled Uranium Project Report, Final; DOE Ohio Field Office (DOE); May 15, 2000; 

SRDB Ref ID: 3644 

DOE, 2000b, Appendix E of the Recycled Uranium Project Report; DOE Ohio Field Office (DOE); 

May 15, 2000; SRDB Ref ID: 93457 

Inspection, 1973a, Routine, Unannounced Inspection; reporting inspector was W. W. Kinney; 

inspection conducted July 24–27, 1973; SRDB Ref ID: 24455, PDF pp. 405–420 

Inspection, 1973b, Routine, Announced Health Physics Inspection; reporting inspector was J. O. 

Lubenau; inspection conducted October 29–31, 1973; SRDB Ref ID: 24455, PDF pp. 451–474 

Jaroszeski, 1972, Identification of Fission Products in FRS Pool Water, correspondence to M. J. Jump 

(includes pool activity results); R. A. Jaroszeski; May 11, 1972; SRDB Ref ID: 24437, PDF pp. 2021–

2022 

Keely, 1968, Bioassay Sampling Program, correspondence to W. G. Urbon; R. B. Keely; June 28, 

1968; SRDB Ref ID: 24432, PDF p. 200 
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Keely, 1969, Safety and Industrial Relations Monthly Report for [Month redacted] 1969, 

correspondence to J. P. Duckworth; R. B. Keely; December 4, 1969; SRDB Ref ID: 24432, PDF p. 

499 

Kester, 1971, Yearly Report from Bioassay Technician, correspondence to D. P. Wilcox; Richard T. 

Kester; February 22, 1971; SRDB Ref ID: 24437, PDF pp. 1378–1379 

Loud, 1966, Radiation—Contamination Status Report, February 1966, correspondence to W. H. 

Lewis; G. C. Loud; March 7, 1966; SRDB Ref ID: 24419, PDF pp. 210–214 

Low, 1972, Inspection Conducted in November 1971 (with enclosures), correspondence to R. Miller; 

Lawrence Low; March 16, 1972; SRDB Ref ID: 24455, PDF pp. 176–188 

Michalczak, 2004, Characterization Management Plan for the Facility Characterization Project, Rev. 

3; L. M. Michalczak; January 16, 2004; SRDB Ref ID: 91177 

Monitoring, 1965-1967, Radiation Contamination Status Reports for 1965 through 1967; most written 

by T. K. Wenstrand; SRDB Ref ID: 24419 

Monitoring, 1966-1973, Bioassay Results for Dates of Collection between 1966 and 1973; SRDB Ref 

ID: 24458 

Monitoring, 1966-1974, Nuclear Fuel Services, Inc. Air Sample Data Sheets and Air Sample Logs for 

Various Dates from 1966-1974; SRDB Ref ID: 24415 

Monitoring, 1967–1975, Correspondence with Monitoring Results for 1967 through 1975; multiple 

authors; multiple dates between 1967 and 1975; SRDB Ref ID: 24404 

Monitoring, 1972-1974, Daily Activities Log with Smears and Air Sample Results for 1972 through 

1974; SRDB Ref ID: 24410 

Nelson, 1973a, Response to Noncompliance Corrections (includes attachments), correspondence to R. 

N. Miller; Paul R. Nelson; February 5, 1973; SRDB Ref ID: 24455, PDF pp. 316–339 

Nelson, 1973b, Reference to Inspection Conducted on October 29–31, 1973, correspondence to R. N. 

Miller; December 7, 1973; SRDB Ref ID: 24455, PDF pp. 446–450 

NFS, 1973–1976, Safety Analysis Report NFS’ Reprocessing Plant, West Valley, New York, contains 

revision pages from various years; Nuclear Fuel Services, Inc. (NFS); Volume 1 dated 1973, but 

contains revision pages with various dates into 1976; SRDB Ref ID: 27086 

NYSASDA and NFS, 1971, Plutonium Storage Agreement between New York State Atomic and Space 

Development Authority and Nuclear Fuel Services, Inc.; May 3, 1971; SRDB Ref ID: 28316, PDF pp. 

203–238 

ORAUT-TKBS-0057, Site Profile for the West Valley Demonstration Project, Rev. 00 PC-1; ORAU 

Team Dose Reconstruction Project for NIOSH; effective August 17, 2007; SRDB Ref ID: 34371 
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O’Reilly, 1975, Reference to Inspection Nos. 50- 201/74-10 and 70-959/74-02 (with enclosures), 

correspondence to R. W. Deuster; James O’Reilly; January 15, 1975; SRDB Ref ID: 24456, PDF pp. 

65-81 

Runion, 1967, Response to August 1967 Letter, correspondence to Lawrence Low; T. C. Runion; 

September 18, 1967; SRDB Ref ID: 24455, PDF pp. 27–29 

Runion, 1970, Statement before the Joint Committee on Atomic Energy, Part II, Hearings on the 

Environmental Effects of Producing Electric Power; T. C. Runion, President of Nuclear Fuel 

Services; February 25, 1970; SRDB Ref ID: 30228 

Shipping, 1969–1970, Plutonium Shipping and Analytical Data Records for 1969–1970; Nuclear Fuel 

Services, Inc.; May 30, 1969 through July 31, 1979; SRDB Ref ID: 29119 

Wilcox, 1971, Delinquent Bioassay Samples, correspondence; D. P. Willcox; [Month redacted] 3, 

1971; SRDB Ref ID: 24437, PDF pp. 1129–1130 

WVDP, 1968, Special Bioassay Samples Following Possible Uptake of Uranium, Plutonium, and 

Mixed Fission Products; assuming the author is West Valley Demonstration Project (WVDP); 

correspondence related to this is dated May 23, 1968; SRDB Ref ID: 24457, PDF pp. 27–36 

WVDP, 2005, WVDP Decommissioning Plan, Appendix C, Rev. 0, Draft 2; West Valley 

Demonstration Project (WVDP); no date, but last survey report referenced is April 26, 2005; SRDB 

Ref ID: 30280
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Attachment One: Data Capture Synopsis

Table A1-1: Summary of Holdings in the SRDB for West Valley Demonstration Project

Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into 

SRDB

Primary Site / Company Name: West 

Valley Demonstration Project

Alternate Site Names: Western New York 

Nuclear Service Center; Western New 

York Fuels Service Center

Physical Size of the Site: The DOE is 

responsible for 152 acres of the 3,338 acre 

site. Major structures in the area of DOE 

responsibility include the Main Plant 

Process Building, the Vitrification Facility, 

four underground storage tanks, and four 

wastewater treatment lagoons. The entire 

site is owned by the New York State 

Energy Research and Development 

Authority.

Site Population: In 1967, 209 workers were 

monitored for radiation exposure. In 1971, 

1,153 workers were monitored for radiation 

exposure. In 1988 660 workers were 

monitored for radiation exposure.

Environmental reports, NRC license changes, WVDP internal dosimetry programmatic documents and 

reviews, air sampling results, radiological survey results, dosimetry procedures, occurrence reports, radiation 

dosimetry reports, log books, bioassay investigations, waste treatment reports, area monitoring results, 

periodic radiation protection reports, contamination area logs, periodic operational reports, ALARA 

performance reports, analyses of container contents, RWPs, effluent monitoring, analyses of waste streams, 

transuranic waste assays, safety analysis reports, hazard classifications of waste containers, radiological dose 

performance reports, scheduling of whole-body counts, internal dosimetry quality assurance reports, offsite 

bioassay laboratory contract requirements, spent fuel reprocessing campaign requirements, respirator 

issuance and control, shipping cask evaluations, nuclear material inventories, a plutonium inhalation 

incident, production and handling of uranium hexafluoride, removal of transuranic contaminants from 

recycled uranium hexafluoride, removal of ruthenium from calciner off-gas, fuel rod shipments, neutrongamma detection, material transfers, periodic status reports, aerial radiological surveys, WVDP radiological 

manual, WVDP external dosimetry programmatic documents, design and construction of treatment systems, 

volatile radioiodine effluent controls, dose trending analyses, a radiological compliance review, trip reports, 

and the 1995 offsite radiation investigation.

03/14/2019 817

State Contacted: New York State Energy 

Research and Development Authority 

(NYSERDA)

The ORAU Team selected 267 documents from NYSERDA's response to the ORAU Team's New York 

Freedom of Information Law request. NYSERDA staff estimate that pulling and reviewing the requested 

documents may not be complete until August 2019.

OPEN 1

Albany Research Center Reference to an ALARA report submitted by WVDP in 2002. 03/22/2013 1

Ames Laboratory An optical special nuclear material assay quarterly report and occupational radiation exposure history 

records.

01/28/2016 2

Brookhaven National Laboratory Cesium-137 concentrations in deer meat, Brookhaven annual reports with spent fuel shipments to West 

Valley, and the shipment of phantoms to West Valley.

02/18/2009 5

Cincinnati Public Library A 1991 environmental regulatory guide. 04/24/2006 1

Colorado Mesa University A literature survey on the environmental effects of tritium. 11/18/2010 1

Curtiss-Wright, Cheswick, PA Shipment records. 05/04/2009 2
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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into 

SRDB

Department of Labor / Paragon Environmental impact statements, the status of New York sites, an aerial survey, Public Law 96-368, and 

information on low-level mixed waste.

01/23/2012 10

DOE Environmental Management 

Consolidated Business Center (EMCBC) -

Cincinnati

Personnel exposure information cards, the 1981 annual report to Congress, notification that the Brookhaven 

Area Office is responsible for radiological emergency assistance, 1999-2014 dosimetry data, and the 1998 

Bioassay Enforcement Moratorium internal assessment. 

02/18/2019 11

DOE EMCBC - Cincinnati / Lee's Summit 

Federal Records Center

The characterization of sealed rooms for RCRA issues. 02/15/2007 1

DOE Germantown Site summaries and DOE records search procedures. 03/07/2011 4

DOE Legacy Management - Grand 

Junction Office

An enriched uranium report, a decontamination report, environmental reports, the draft environmental 

impact statement, hazardous waste rankings, and FUSRAP reports.

03/11/2011 17

DOE Legacy Management - Morgantown 

Office

Periodic processing reports, recycled uranium reports, environmental reports, urinalysis reports, air sampling 

reports, and lapel sampling reports.

04/07/2016 74

DOE Legacy Management - MoundView 

Office (Fernald Holdings, includes Fernald 

Legal Database)

Analyses of material transfers to Fernald, trip reports, the analysis and impact of plutonium in recycled 

uranium, and a report on neptunium in recycled uranium.

04/17/2008 91

DOE Oak Ridge Operations Office An article on radiation conspiracies and a study of uranium-233. 07/09/2012 2

DOE Office of Scientific and Technical 

Information (OSTI)

Radioactive waste reports, personnel exposure from a hydro fracturing experiment, and a waste treatment 

study.

07/02/2015 4

Oak Ridge Gaseous Diffusion Plant (K-25) Baseline monitoring for transferees to ETTP from West Valley. 07/15/2014 6

Federal Records Center (FRC) - Atlanta An Oak Ridge Operations Office trip report. 03/17/2004 1

Federal Records Center (FRC) - Dayton Information from a decontamination services vendor. 06/02/2014 1

Federal Records Center (FRC) - Kansas 

City

Documentation that Argonne National Laboratory-East was commissioned to perform a West Valley waste 

burial study and some complex-wide observation from the Kansas City Plant Tiger Team findings.

10/07/2013 2
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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into 

SRDB

Federal Records Center (FRC) - Lee's 

Summit

Environmental reports, in vitro monitoring results, procedures, and reports, in vivo monitoring results, 

radiological control procedures, and reports, radiation dose rate maps, periodic operations reports, ALARA 

performance reports, decontamination reports, container qualification reports, waste form qualification 

reports, personnel radiation exposure reports, the 1988 assessment of the WVDP radiological records 

system, external exposure reports, daily badge transmittal reports, badged worker rosters, Bioassay.DAT 

exposure data, specific job cumulative dose data, weekly direct reading dosimeter records, area monitoring 

data, in vivo counter maintenance and calibration, radiation work permits, special dose evaluations, 

extremity exposure reports, ALARA budgets, ALARA review checklists, air sample results, specific job 

dose estimates, dosimetry logbooks, routine and job-specific radiation and contamination surveys, Radiation 

Control Program performance indicators, occurrence reports, NRC monitoring, DOELAP results and reports, 

lagoon contents radiological analyses, effluent discharge information, radiological controls manual, 

individual radiation exposure histories, safety analyses, safety evaluations, shielding requirements, 

radiological waste analyses, stabilization of plutonium extraction waste, waste disposition reports, air 

sampler and CAM logbooks, IRTS logbooks, X-ray survey, criticality safety evaluations, personnel 

contamination reports, groundwater reports, nuclear material accountability, closure engineering reports, 

contaminated soil management, EPA studies and evaluations, dosimetry intercomparisons, analytical 

intercomparisons, assessments and responses, neutron dose rates, lapel sample logbooks, operational safety 

requirements, WVDP emergency plan, hazard classifications, a photon streaming report, RCRA facility 

investigations, incident critique minutes, evaluations of sources of radionuclide emissions, ALARA 

committee minutes, options for handling transuranic materials, training records, line management selfassessments, equipment and tooling for decontamination jobs, and Tiger Team environmental closeout. 

06/13/2016 7,781

Hanford Hanford reports on reprocessing, material transfers to and from West Valley, material balance reports, and a 

proposal for cesium-137 recovery. 

09/23/2014 14

Idaho National Laboratory Monthly environmental reports, bioassay reports, independent measurements program data summaries, 

waste management reports, operational reports, individual radiation dose reports, the bioassay records 

system, and the bioassay data entry guide.

08/27/2018 77

Idaho National Laboratory Electronic 

Document Management System (EDMS)

An internal dose assessment methodology, key word search results, Human Radiation Experiment records, 

and mention of West Valley as a waste disposal site.

06/28/2017 5

Interlibrary Loan Radioactive waste discharges, a site description, and DOE's 1981 request for proposal to operate West 

Valley.

08/24/2018 3

Internet - Defense Technical Information 

Center (DTIC)

An occupational dose reduction bibliography, Defense Nuclear Facilities Safety Board annual reports to 

Congress, radioactive waste classification for disposal, transportation reports, weapons grade plutonium 

dispositioning, the toxicological profile for plutonium, and Nevada Test Site waste acceptance criteria.

03/22/2019 12

Internet - DOE The DOE guide for good practices at plutonium facilities and a 2015 aerial radiological survey. 07/17/2018 2

Internet - DOE Hanford Declassified 

Document Retrieval System (DDRS)

Material transfers (primarily plutonium) between Hanford and West Valley. 10/27/2008 29
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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into 

SRDB

Internet - DOE Legacy Management 

Considered Sites

The West Valley record of decision, volume 1 of the final environmental impact statement, a site history, an 

official visit, cleanup plans, a review of DOE radioactive waste management, occupational radiation 

exposure annual reports, and a former worker medical screening report.

06/02/2017 19

Internet - DOE National Nuclear Security 

Administration (NNSA) 

The final Nevada Test Site environmental impact statement for shipping radioactive waste to the site. 04/14/2016 1

Internet - DOE Noncompliance Tracking 

System (NTS)

Personnel contamination, clothing contamination, area contamination, external exposure limit exceedances, 

unworn dosimetry, and unplanned exposures reports. 

03/15/2019 23

Internet - DOE Occurrence Reporting 

Processing System (ORPS)

Personnel contamination, clothing contamination, area contamination, and contamination discovery reports. 03/18/2019 22

Internet - DOE Office of Scientific and 

Technical Information (OSTI)

A 1997 radiation safety report, the development of internal dosimetry derived investigation levels, the 

characterization of the head-end cells, annual occupational exposure reports, environmental aspects of 

plutonium bibliography, bibliographies of nuclear safety literature, plutonium uptake cases, radioactive 

waste reports, potential fuel reprocessing safety issues, nuclear facility safety related issues in 1971, and 

tritium control technology.

04/24/2019 25

Internet - DOE OpenNet A United States Transuranium Registry report, plutonium recovery at West Valley, transportation of 

radioactive materials, INL independent measurements at West Valley, a brief discussion of the hydro 

fracturing experiment, transfers of plutonium between West Valley and Hanford, a symposium on 

population exposures, and receipt at Hanford of contaminated shipping casks from West Valley.

04/16/2019 47

Internet - DOE OSTI Energy Citations Transportation reports, nuclear waste generation reports, decommissioning bibliographies, the draft site 

treatment plan, chemical safety, and a waste treatment review.

05/07/2013 19

Internet - DOE OSTI Information Bridge A site history, annual spent fuel inventories, waste vitrification reports, waste generation and pollution 

prevention reports, transportation of radioactive waste, nuclear facility decommissioning bibliographies, 

transuranic contaminated waste information, spent fuel management issues, plutonium control and 

disposition alternatives, the disposition of mixed low-level waste, and transuranic and low-level boxed waste 

assay technology.

07/31/2013 54

Internet - DOE OSTI SciTech Connect Decontamination and decommissioning reports, high-level waste reports, waste management alternatives, 

plutonium oxide dissolution issues, spent fuel transportation, aerial radiological survey, environmental 

reports, seismic analyses, cleanup progress reports, design of high-level waste treatment systems, tests and 

characteristics of vitrification glass, waste form qualification experience, environmental assessments, waste 

management meetings, waste form analyses, waste canister design and qualification, melter testing, 

groundwater flow and transport modeling, the feed preparation code, vitrification facility design, periodic 

vitrification reports, nuclear waste treatment periodic reports, New York State low-level waste reports, a 

melter inspection report, tank wall corrosion studies, spent fuel rod consolidation, the phase 1 final status 

survey plan, evaluations of off-gas system technologies, reactor spent fuel discharges, tank waste 

remediation system reports, 2012 occupational radiation exposure summary, an airborne radioactive effluent 

investigation, the correlation of laboratory testing and actual operations, and the removal of high-level waste 

from storage tanks. 

07/19/2018 424
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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into 

SRDB

Internet - DOE OSTI SciTech Connect / 

Lee's Summit FRC

The environmental assessment for low-level and mixed waste treatment. 11/20/2014 1

Internet - Energy Employees Claimant 

Assistance Project (EECAP)

No relevant documents identified. 03/26/2019 0

Internet - Google Annual occupational radiation exposure reports, environmental reports, status of the decommissioning 

reports, waste shipments to and from Nevada Test Site, high-level waste management, U.S. spent fuel 

inventories, annual reports to Congress, waste generation and pollution prevention reports, measuring and 

reporting effluents, annual transuranic waste inventories, guidance for low-level and mixed waste handling, 

annual Defense Nuclear Facility Safety Board reports, general employee training, decontamination reports, 

individual project environmental checklists, vitrification lessons learned, public meetings, spent nuclear fuel 

shipments, tank corrosion mitigation, vitrification progress and completion, independent reviews of 

environmental impact statements, groundwater treatment, site treatment plans, tank waste removal, 

characteristics of potential repository wastes, environmental sampling plans, radioactive waste classification, 

and minutes of an Advisory Board on Radiation and Worker Health meeting.

04/09/2019 288

Internet - Health Physics Journal The Health Physics challenges of fuel reprocessing. 02/15/2007 1

Internet - Idaho National Laboratory A brief statement on the progress of a TLD test. 08/01/2016 1

Internet - International Journal of 

Occupational and Environmental Hygiene

No relevant documents identified. 03/26/2019 0

Internet - National Academies Press (NAP) Waste management and retrieval reports, a plutonium disposition report, and an environmental management 

report.

06/24/2015 9

Internet - National Institute for 

Occupational Safety and Health (NIOSH)

Periodic reports on residual radioactive and beryllium contamination at covered facilities, and the Advisory 

Board on Radiation and Worker Health review of the NIOSH WVDP site profile revision 1.

04/22/2019 4

Internet - National Service Center for 

Environmental Publications (NEPIS), US 

EPA

Environmental radiation protection, environmental radionuclide studies, ingestion dose pathways, and a 

report on the low-level radioactive waste burial site. 

12/17/2014 6

Internet - NRC Agencywide Document 

Access and Management (ADAMS) 

U.S. spent fuel inventories, FUSRAP site reviews, environmental radiation in New York State reports, DOE 

spent fuel management programs, DOE request to place low-level waste at Nevada Test Site, 

decommissioning program annual reports, characterization and decommissioning plans, safety analysis 

reports, NRC site visit reports, audits, periodic operational reports, WVDP quality assurance program, 

Hanford and Yucca Mountain high-level waste handling plans, NRC observations and responses, draft and 

final environmental impact statements, reviews of waste treatment plans, safety evaluation reports, highlevel waste profiles, summary plutonium and uranium recovery report, technical evaluation reports, dose 

modeling, and mitigation of contaminated groundwater. 

08/30/2018 337

Internet - Oak Ridge National Library Periodic division reports, solvent stability in nuclear fuel reprocessing, and methods for decladding light 

water reactor fuel.

11/21/2016 7

Internet / SC&A Technical specifications of the West Valley NRC license. 06/05/2006 1
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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into 

SRDB

Internet - US Army Corps of Engineers 

(USACE)

No relevant documents identified. 04/17/2019 0

Internet - US Transuranium and Uranium 

Registries

No relevant documents identified. 04/16/2019 0

Kansas City Plant Radioactive waste management and site treatment plans. 03/04/2015 2

Lawrence Livermore National Laboratory A Radiation Safety Program records list. 10/01/2015 1

Lewiston Public Library Documentation of the transfer of Lake Ontario Ordnance Works residues to West Valley. 03/31/2009 1

Marriott Hotel - Buffalo NY An advocacy newsletter referring to the proposed placement of radioactive waste at West Valley. 04/18/2005 1

Massachusetts Department of Public Health A statement on the similarities of the Nuclear Metals, Inc. and West Valley financial situations. 04/12/2012 2

Mel Chew & Associates Recycled uranium reports. 12/14/2014 14

Missouri Department of Natural Resources Plutonium working group reports. 10/01/2008 3

Mound Radiation exposure reports and personnel contamination incidents. 03/26/2007 9

Mound Museum Mound employee newsletters. 05/18/2010 2

National Archives and Records 

Administration (NARA) - Atlanta

An Oak Ridge Operations Office health review and results of the DOE indoor radon study. 08/09/2004 2

National Archives and Records 

Administration (NARA) - College Park

A 1974 trip report to Battelle Pacific Northwest Laboratory. 04/16/2010 1

National Archives and Records 

Administration (NARA) - Kansas City

High-level waste reports, decontamination reports, a radiation shielding analysis, waste management plans, 

transuranic waste reports, environmental reports, field measurements, and periodic reports.

07/12/2016 46

National Archives and Records 

Administration (NARA) - Seattle

1969 environmental TLD records and incident reports. 12/17/2014 4

National Institute for Occupational Safety 

and Health (NIOSH)

Annual reports to Congress, recycled uranium, a claimant communication, and worker outreach agendas, 

sign-in sheets, presentations, and minutes.

11/22/2017 26

NIOSH OCAS Claims Tracking System 

(NOCTS)

The 1981 history of site decontamination. 05/02/2017 1

NIOSH / SC&A The DOE Ohio Field Office recycled uranium project report. 08/14/2003 1

Nevada Test Site The final NTS environmental impact statement with quantities of West Valley radioactive waste shipped to 

the site.

10/01/2003 1

New York Department of Environmental 

Conservation

A uranium mill tailings report. 03/05/2007 1

Nuclear Fuel Services, Erwin, TN The rationale behind spent fuel reprocessing and a summary of spent fuel receipts and reprocessing. 03/23/2006 5

Nuclear Regulatory Commission Public 

Document Room

NRC licenses SNM-124, CSF-1 with correspondence and supporting documentation, high-level waste 

reviews with comments, review of the long-term waste management plan, review of the transuranic waste 

certification plan, safety analysis reports, the WVDP project plan, environmental monitoring reports, trip 

reports, review of site closure documents, offsite dose limits, periodic operational reports, material control 

and accountability, the waste form qualification review, audits, safety evaluation reports, environmental 

assessments for waste classes, certificates of compliance, and geologic and hydrologic research.

04/24/2018 246
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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into 

SRDB

Nuclear Regulatory Commission Public 

Document Room / Lee's Summit FRC

A vitrification progress report, radiological parameters for the assessment of project activities, an 

environmental monitoring report, and a project plan progress report.

12/17/2014 4

Oak Ridge Associated Universities 

(ORAU)

A nuclear weapons databook, environmental radiation in New York in 1972, and the 1967-1981 West Valley 

radiation exposure database in spreadsheet and pdf formats.

07/18/2018 4

Oak Ridge Institute for Science and 

Education (ORISE)

Chelation DTPA data for DOE employees. 08/06/2009 3

Oak Ridge Library for Dose 

Reconstruction

A review of public health data around nuclear facilities and gaseous effluent control technology. 04/05/2011 2

Oak Ridge National Laboratory (ORNL) A computer program for calculating neutron production in high-level waste. 11/29/2004 1

ORAU Team Technical basis documents, excerpts from claim files, and documented communications. 06/16/2017 15

Paducah Gaseous Diffusion Plant Radiation exposure summaries and Health Physics audits. 12/03/2008 10

Personal Files - Jack Selby Annual DOE radiation exposure reports. 10/11/2006 6

Richland Library A process building closure engineering report. 10/01/2018 1

Savannah River Site A compliance assessment, material transfer receipts, and a 1997 Price-Anderson annual report. 08/23/2017 3

S. Cohen & Associates (SC&A) 2010 records search results, plutonium, actinide, and uranium analysis procedures, West Valley Nuclear 

Services Company and West Valley Environmental Services policy and procedures, controlled documents, 

radiological assessment of environmental releases manual, several revisions of the internal dosimetry 

program manual and TBD, dissolver criticality studies, Nuclear Fuel Services surveys, spent fuel 

reprocessing plant operation, 1969 safety and health manual, potential exposures from radiation streaming, 

unusual occurrence reports, radiation protection periodic reports, review of the WVDP internal dosimetry 

program, review of radiation work permits for bioassay requirements, bioassay records, reviews of the 

bioassay program, DOELAP reviews, AEC license SNM-857, environmental monitoring reports, safety 

analyses, periodic health and safety reports, fuel processing campaigns, uranium-232 content in irradiated 

uranium, and radiation contamination status reports. 

07/18/2014 541

SC&A / INL The preparation of uranium-233 oxide for the breeder reactor program, a radioactive waste management 

plan, and environmental information.

06/24/2010 3

SC&A / Internet - DOE OpenNet A historical plutonium report. 10/28/2014 1

SC&A / Lee's Summit FRC The review of the WVDP bioassay and internal dosimetry program, a 1989 whole-body dosimeter study, and 

calibration source data for the in vivo counter.

02/11/2016 3

SC&A / Pinellas Plant The 1993 waste generation and minimization report. 06/24/2010 1

SC&A / Santa Susana Field Laboratory A trip report to Argonne National Laboratory. 06/24/2010 1

SC&A / West Valley Demonstration 

Project

Uranium and tritium analytical procedures, validation of indirect bioassay data, stack air effluent monitoring, 

entry into and exit from contamination areas, waste stream characterization, Radiological Procedures RC-1 -

RC-74, Radiological Control ADM Procedures RC-ADM-1 - RC-ADM-42, Radiological Control DOS 

Procedures RC-DOS-1 - RC-DOS 18, RC-DOS-20 - RC-DOS-55, RC-IOC Procedures RC-IOC-1 - RCIOC-62, RC-EMRG-1, RC-RPO-301, RC-RPL-7, and RIR-403 Procedures RIR-403-001, RIR-403-003 -

RIR-403-011, RIR-403-013 to RIR-403-024, RIR-403-026 - RIR-403-038.

05/06/2011 441
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38 of 40

Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into 

SRDB

SC&A / West Valley Demonstration 

Project / Lee's Summit FRC

In vivo counting procedures, gamma and neutron dose rate evaluations, air sampling guidelines and action 

levels, skin dose assessment, TLD element correction factors, performing in situ soil measurements, 

operating and calibration instructions for a liquid monitoring system, and a quarterly area radiation monitors 

alarm check. 

05/06/2011 15

Southern Illinois University The 1964 minerals yearbook. 10/29/2008 1

University of Rochester Shipments of radioactive waste to West Valley. 08/20/2008 1

Unknown Historical summaries and information, material transfers, the 1995 DOE occupational exposure report, 

various correspondence, and mixed waste disposal.

11/12/2004 22

Unknown / SC&A Results of the DOE indoor radon study. 10/09/2003 1

West Valley Demonstration Project / Lee's 

Summit FRC

Environmental reports, ambient air concentrations, bioassay reports and procedures, decontamination 

reports, an operational event, a facilities utilization plan, and lessons learned.

11/17/2010 14

West Valley Demonstration Project / NRC 

Public Document Room

A 1983 summary environmental monitoring report. 06/05/2006 1

West Valley Demonstration Project / 

SC&A

In vivo counting procedures, in vitro counting procedures, airborne radioactivity sampling procedure, spread 

of contamination, environmental results, internal dosimetry programmatic documents, area dosimetry, an 

unusual occurrence report, and periodic radiological reports.

11/17/2010 29

TOTAL N/A N/A 11,759

Table A1-2: Database Searches for West Valley Demonstration Project

Database/Source Keywords No. of Hits

No. 

Uploaded 

into SRDB

Defense Technical Information Center (DTIC)

http://www.dtic.mil/dtic/

COMPLETED 03/22/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

464 1

DOE Hanford Declassified Document Retrieval 

System (DDRS) and Public Reading Room

http://reading-room.labworks.org/Catalog/Search.aspx

COMPLETED 04/05/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

0 0

DOE Legacy Management Considered Sites

https://www.lm.doe.gov/Considered_Sites/Summary/

COMPLETED 04/18/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

238 14
SEC-00252 07-31-2019 West Valley Demonstration Project

39 of 40

Database/Source Keywords No. of Hits

No. 

Uploaded 

into SRDB

DOE National Nuclear Security Administration 

(NNSA) - Nevada Site Office

https://nnsa.energy.gov/library

COMPLETED 03/28/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

1,233 0

DOE OpenNet

http://www.osti.gov/opennet/advanced-search.jsp

COMPLETED 04/16/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

132 78

DOE OSTI SciTech Connect (now OSTI.GOV/Search)

https://www.osti.gov/search/

COMPLETED 04/10/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

190,382 577

Energy Employees Claimant Assistance Project 

(EECAP)

http://www.eecap.org

COMPLETED 03/26/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

0 0

Google

http://www.google.com

COMPLETED 04/24/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

7,173,638 178

Health Physics Journal

http://journals.lww.com/healthphysics/pages/default.aspx

COMPLETED 03/26/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

27 0

International Journal of Occupational and 

Environmental Health 

https://tandfonline.com/search/advanced

COMPLETED 03/26/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

1 0

National Academies Press

http://www.nap.edu/

COMPLETED 04/16/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

29,272 9

National Service Center for Environmental 

Publications (NEPIS)

http://nepis.epa.gov/

COMPLETED 04/18/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

19,368 12

NRC ADAMS Reading Room

https://adams.nrc.gov/wba/

COMPLETED 04/16/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

2,632 334

United States Army Corps of Engineers (USACE)

http://www.usace.army.mil/

COMPLETED 04/17/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

1,000 1
SEC-00252 07-31-2019 West Valley Demonstration Project

40 of 40

Database/Source Keywords No. of Hits

No. 

Uploaded 

into SRDB

U.S. Transuranium & Uranium Registries 

http://www.ustur.wsu.edu/

COMPLETED 04/16/2019

Database search terms are available in the Excel file called “West Valley Demonstration Project 

(WVDP) Rev 00 (83.14), 05-13-19.”

0 0