SEC Petition Evaluation Report

Petition SEC-00253 

Report Rev Number: 0

Report Submittal Date: April 24, 2020

Subject Expert(s): Roger Halsey, Toshihide Ushino, Monica Harrison-Maples

Site Expert(s): N/A

Petition Administrative Summary

Petition Under Evaluation

Petition Number: SEC-00253

Petition Type: 83.13

Petition Receipt Date: June 25, 2019

Qualification Date: December 13, 2019

DOE/AWE Facility Name: Reduction Pilot Plant

Petition Class

Petitioner-Requested Class 

Definition:

All INCO security personnel who worked at any location within the Reduction 

Pilot Plant during the period from June 7, 1976 through November 26, 1978.

Class Evaluated by NIOSH: All International Nickel Company (INCO) security personnel who worked at any 

location within the Reduction Pilot Plant during the period from June 7, 1976 

through November 26, 1978.

NIOSH-Proposed Class to be Added 

to the SEC:

None

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: Roger Halsey

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

Peer Review Completed By:

[Signature on File]

Thomas P. Tomes

April 24, 2020

SEC Petition Evaluation Reviewed 

By: [Signature on File]

Timothy D. Taulbee

April 24, 2020

SEC Petition Evaluation Approved

By: [Signature on File]

Grady Calhoun 

April 24, 2020
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Evaluation Report Summary: SEC-00253, Reduction Pilot Plant

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 the Reduction Pilot Plant to the Special Exposure 

Cohort (SEC). The Energy Employees Occupational Illness Compensation Program Act of 2000, as 

amended, (EEOICPA) and 42 CFR 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.

Petitioner-Requested Class Definition

NIOSH received petition SEC-00253 on June 25, 2019 and qualified it on December 13, 2019. The 

petitioner requested that NIOSH consider the following class: All INCO security personnel who 

worked at any location within the Reduction Pilot Plant during the period from June 7, 1976 through 

November 26, 1978.

Class Evaluated by NIOSH

Based on its preliminary research, NIOSH accepted the petitioner-requested class. NIOSH evaluated 

the following class: All International Nickel Company (INCO) security personnel who worked at any 

location within the Reduction Pilot Plant during the period from June 7, 1976 through November 26, 

1978.

NIOSH Determination about the Proposed Class to be Added to the SEC

NIOSH has obtained descriptions of the plant processes, details of the preparations to place the plant 

in standby mode prior to the evaluated period, a radiological survey of the plant taken before the 

evaluated period, and surveys taken after the evaluated period that describe the radiological conditions 

at the Reduction Pilot Plant during the evaluated period. Based on its analysis of these available 

resources, NIOSH found no part of the class under evaluation for which it cannot estimate radiation 

doses with sufficient accuracy.

Feasibility of Dose Reconstruction

Per EEOICPA and 42 CFR § 83.13(c) (1), NIOSH has established that it has access to sufficient 

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

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

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

the maximum dose. Information available from the site profile and additional resources is sufficient to 

estimate the maximum internal and external potential exposure to members of the evaluated class 

under plausible circumstances during the specified period.

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

• NIOSH finds that it is feasible to reconstruct occupational medical dose for Reduction Pilot Plant

employees with sufficient accuracy during the evaluated period.
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• Principal sources of internal radiation for members of the proposed class included exposures to

low-enriched uranium and fuel-reprocessing contaminants due to resuspension by activities during 

the plant’s Standby Period.

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

the presence of low-enriched uranium and fuel-reprocessing contaminants during the plant’s 

Standby Period.

• Pursuant to 42 CFR § 83.13(c)(1), NIOSH determined that there is sufficient 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.

Health Endangerment Determination

Per EEOICPA and 42 CFR § 83.13(c)(3), a health endangerment determination is not required

because NIOSH has determined that it has sufficient information to estimate dose for the members of 

the evaluated class.
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Table of Contents

Evaluation Report Summary: SEC-00253, Reduction Pilot Plant .......................................................... 3

Table of Contents .................................................................................................................................... 5

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

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

3.0 SEC-00253, RPP Class Definitions................................................................................................ 8

3.1 Petitioner-Requested Class Definition and Basis .................................................................. 8

3.2 Class Evaluated by NIOSH ................................................................................................... 9

3.3 NIOSH Determination about the Proposed Class to be Added to the SEC ........................... 9

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class............................................................. 9

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 10

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures ..................................... 10

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

4.4 Previous Dose Reconstructions ........................................................................................... 11

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

4.6 Documentation and/or Affidavits Provided by Petitioners ................................................. 11

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 12

5.1 RPP Site and Process Descriptions ...................................................................................... 12

5.1.1 Production Period, 1951 through March 1963 ........................................................ 15

5.1.2 Standby Period, May 1, 1963 through November 26, 1978 .................................... 17

5.1.3 Demolition Period, November 27, 1978 through May 18, 1979 ............................. 19

5.2 Radiological Exposure Sources from the RPP Standby Period ........................................... 19

5.2.1 Internal Radiological Exposure Sources from the RPP Standby Period ................. 19

5.2.1.1 Enriched Uranium .................................................................................... 20

5.2.1.2 Contaminants from Reprocessed Fuel ...................................................... 20

5.2.2 External Radiological Exposure Sources from RPP Standby Period ...................... 22

5.2.2.1 Photon ....................................................................................................... 22

5.2.2.2 Beta ........................................................................................................... 22

5.2.2.3 Neutron ..................................................................................................... 22

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 22

6.1 Available RPP Internal Monitoring Data ............................................................................ 23

6.2 Available RPP External Monitoring Data ........................................................................... 24

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 25

7.1 Pedigree of RPP Data .......................................................................................................... 25

7.1.1 Internal Monitoring Data Pedigree Review ............................................................. 26

7.1.2 External Monitoring Data Pedigree Review ............................................................ 26

7.2 Evaluation of Bounding Internal Radiation Doses at the RPP ............................................ 26

7.2.1 Evaluation of Bounding Process-Related Internal Doses ........................................ 26

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses ........................... 27

7.2.3 Methods for Bounding Internal Dose at the RPP .................................................... 27

7.2.3.1 Methods for Bounding Standby Period Internal Dose ............................. 27

7.2.3.2 Methods for Bounding Ambient Environmental Internal Dose ............... 28

7.2.4 Internal Dose Reconstruction Feasibility Conclusion ............................................. 28

7.3 Evaluation of Bounding External Radiation Doses at the RPP ........................................... 28

7.3.1 Evaluation of Bounding Process-Related External Doses ....................................... 28

7.3.2 Evaluation of Bounding Ambient Environmental External Doses .......................... 29

7.3.3 RPP Occupational X-Ray Examinations ................................................................. 29
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7.3.4 Methods for Bounding External Dose at the RPP Site............................................ 29

7.3.4.1 Methods for Bounding Standby Period External Dose ............................ 29

7.3.4.2 Methods for Bounding Ambient Environmental External Doses............. 30

7.3.5 External Dose Reconstruction Feasibility Conclusion............................................ 30

7.4 Evaluation of Petition Basis for SEC-00253....................................................................... 30

7.4.1 Exposure Incidents .................................................................................................. 30

7.4.2 No Worker Monitoring............................................................................................ 31

7.4.3 Monitoring Records were Destroyed....................................................................... 31

7.5 Summary of Feasibility Findings for Petition SEC-00253.................................................. 31

8.0 Evaluation of Health Endangerment for Petition SEC-00253...................................................... 32

9.0 Class Conclusion for Petition SEC-00253 ................................................................................... 32

10.0 References .................................................................................................................................... 34

Attachment One: Data Capture Synopsis.............................................................................................. 39

Tables

Table 4-1: No. of RPP Claims Submitted Under the Dose Reconstruction Rule.................................. 11

Table 5-1: Tasks and Frequencies Proposed by INCO for the RPP Standby Period ............................ 18

Table 5-2: Default Isotopic Distributions.............................................................................................. 21

Table 5-3: Activity Ratios for Alpha-emitting Contaminants from Reprocessed Fuel......................... 21

Table 5-4: Activity Ratio for Beta-emitting Contaminant from Reprocessed Fuel .............................. 22

Table 6-1. Radiological surveys of the RPP.......................................................................................... 23

Table 6-2: Survey Results for Fixed and Removable Alpha Activity on the Residue System ............. 24

Table 7-1. Annual Inhalation Rates of Uranium and Reprocessed Fuel Contaminants........................ 28

Table 7-2: Summary of Feasibility Findings for SEC-00253 ............................................................... 32

Table A1-1: Summary of Holdings in the SRDB for the RPP, Huntington, West Virginia ................. 39

Table A1-2: Internet Database Searches for the RPP Site .................................................................... 45

Figures

Figure 5-1: Map of the RPP................................................................................................................... 13

Figure 5-2: Map Showing Location of Residue Section within the Process Building.......................... 14

Figure 5-3: Process Building, Compressor Building, and Gas Holding Tanks (left to right) ............... 14

Figure 5-4: Timeline of the RPP ........................................................................................................... 15
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SEC Petition Evaluation Report for SEC-00253

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: Roger 

Halsey, Oak Ridge Associated Universities (ORAU). 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 radiation doses for all International Nickel 

Company (INCO) security personnel who worked at any location within the Reduction Pilot Plant 

(RPP) (also referred to as Huntington Pilot Plant) during the period from June 7, 1976 through 

November 26, 1978. It provides information and analyses germane to considering a petition for 

adding a class of employees to the congressionally created SEC. 

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

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

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

be added to the SEC (see Section 2.0).

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 CFR pt. 83, and 

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

Procedures for the Evaluation of Special Exposure Cohort Petitions, DCAS-PR-004 [NIOSH 2011a]. 

2.0 Introduction 

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

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

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

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

reconstructions.1

1 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 CFR pt. 82 and 

the detailed implementation guidelines available on the NIOSH Radiation Dose Reconstruction Program webpage.

42 CFR § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH has 

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

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

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

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose.

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

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

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

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 
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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 at least 250 aggregated work days within the parameters 

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

or more other SEC classes. 

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

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

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

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

consider the NIOSH evaluation report, together with the petition, petitioner(s) comments, and other 

information the Advisory Board considers appropriate, in order to make recommendations to the 

Secretary of DHHS 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 Advisory Board, the Director of NIOSH will 

propose a decision on behalf of DHHS. The Secretary of DHHS will make the final decision, taking 

into account the NIOSH evaluation, the advice of the Advisory Board, and the proposed decision 

issued by NIOSH. As part of this decision process, petitioners may seek a review of certain types of 

final decisions issued by the Secretary of DHHS.

2

2 See 42 CFR pt. 83 for a full description of the procedures summarized here. Additional internal procedures are available 

on the NIOSH Radiation Dose Reconstruction Program webpage.

3.0 SEC-00253, RPP Class Definitions 

The following subsections address the evolution of the class definition for SEC-00253, RPP. When a 

petition is submitted, the requested-class definition is reviewed as submitted. Based on its review of 

the available site information and data, NIOSH will make a determination whether to qualify for full 

evaluation all, some, or no part of the petitioner-requested class. If some portion of the petitionerrequested class is qualified, NIOSH will specify that class along with a justification for any 

modification of the petitioner’s class. After a full evaluation of the qualified class, NIOSH will 

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

definition. 

3.1 Petitioner-Requested Class Definition and Basis

NIOSH received petition SEC-00253 on June 25, 2019 and it qualified on December 13, 2019 

[Redacted 2019]. The petitioner requested that NIOSH consider the following class: All INCO 

security personnel who worked at any location within the Reduction Pilot Plant during the period 

from June 7, 1976 through November 26, 1978. 

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

accurate dose reconstruction over time is impossible for the RPP employees in question. NIOSH 

deemed the following information sufficient to qualify SEC-00253 for evaluation: 
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• The petition was submitted on the basis that radiation exposures and radiation doses potentially 

incurred by members of the proposed class were not monitored, either through personal 

monitoring or through area monitoring. No external radiation monitoring, internal radioactivity 

monitoring, or area monitoring were performed for the workers within the class.

At the time NIOSH received the petition, the petitioner-requested class was not within the Department 

of Labor’s (DOL) covered period for the RPP. As a result of NIOSH’s request for DOL to review the 

RPP covered period, in a November 15, 2019 letter to NIOSH, DOL indicated that they were revising 

the covered period dates [DOL 2019]. DOL changed the covered period for the RPP to include “...the 

entire period from 1951 through May 18, 1979, with the period from November 27, 1978 through 

May 18, 1979 for remediation only [DOL 2019, PDF p. 3]. DOL’s revised covered period includes the 

petitioner-requested class.

NIOSH concluded that there is sufficient documentation to support the petition basis that internal and 

external radiation exposures and radiation doses were not adequately monitored at the Reduction Pilot 

Plant, either through personal monitoring or area monitoring. The information and statements

provided by the petitioner qualified the petition for further consideration by NIOSH, the Advisory

Board, and DHHS. The details of the petition basis are addressed in Section 7.4.

3.2 Class Evaluated by NIOSH

Based on its preliminary research, NIOSH accepted the petitioner-requested class. Therefore, NIOSH 

defined the following class for further evaluation: All INCO security personnel who worked at any 

location within the Reduction Pilot Plant during the period from June 7, 1976 through November 26, 

1978.

3.3 NIOSH Determination about the Proposed Class to be Added to the SEC

NIOSH has obtained descriptions of the plant processes, details of the preparations to place the plant 

in standby mode prior to the evaluated period, a radiological survey of the plant taken before the 

evaluated period, and surveys taken after the evaluated period that describe the radiological conditions 

at the RPP during the evaluated period, June 7, 1976 through November 26, 1978. Based on its 

analysis of these available resources, NIOSH found no part of the class under evaluation for which it 

cannot estimate radiation doses with sufficient accuracy.

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class

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

regarding the RPP. The database search included the DOE (Department of Energy) 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, the 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 includes a summary of the RPP documents. The summary 

specifically includes data capture details and general descriptions of the documents retrieved.
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In addition to the database and Internet searches listed above, NIOSH identified and reviewed 

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

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

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

materials. The following subsections summarize the data sources identified and reviewed by NIOSH. 

4.1 Site Profile Technical Basis Documents (TBDs) 

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

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

external dosimetry data for monitored and unmonitored employees, and to supplement, or substitute 

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

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

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

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

As part of NIOSH’s evaluation detailed herein, it examined the following TBDs for insights into RPP

operations or related topics/operations at other sites: 

• Technical Basis Document for the Huntington Pilot Plant, Huntington, West Virginia, DCASTKBS-0004, Rev. 2; effective November 5, 2018; SRDB Ref ID: 175109

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

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

• K-25 Gaseous Diffusion Plant – Occupational Internal Dose, ORAUT-TKBS-0009-5, Rev. 01 

PC-1; effective October 4, 2006; SRDB Ref ID: 30010

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures

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

guidance for preparing dose reconstructions at particular sites or categories of sites. An ORAU 

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

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

reviewed the following OTIB as part of its evaluation:

• OTIB: Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons Employer 

Facilities, ORAUT-OTIB-0070, Rev. 01; effective March 5, 2012; SRDB Ref ID: 108851

4.3 Facility Employees and Experts

To obtain more information in support of NIOSH’s evaluation of petition SEC-00253, NIOSH 

reached out to several former RPP employees, including former security personnel. However, only 

one non-security individual agreed to be interviewed. The former INCO employee confirmed that 

he/she had worked within the RPP during the Standby Period and that there was no radiological 

monitoring for that activity [ORAUT 2020].

• Documented Communication, 2020, Documented Communication SEC-00253 with [Name 

Redacted] on RPP; Telephone Interview by ORAU Team; February 18, 2020; SRDB Ref ID: 

179905
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4.4 Previous Dose Reconstructions

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

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

evaluation. Table 4-1 summarizes the results of this review. (NOCTS data available as of March 17, 

2020) 

Table 4-1: No. of RPP Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction for employment at the RPP (92 submitted, 15 

pulled by DOL)

77

Total number of dose reconstructions completed for the site (77 draft dose reconstructions completed 

with 76 final dose reconstructions submitted to DOL and 1 administratively closed).

76

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

(June 7, 1976 through November 26, 1978)

42

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

under evaluation (June 7, 1976 through November 26, 1978)

4 

Number of claims for which internal dosimetry records were obtained for the time period in the 

evaluated class definition

0 

Number of claims for which external dosimetry records were obtained for the time period in the 

evaluated class definition

0 

NIOSH has completed dose reconstructions for all cases received from DOL. However, DOL recently 

expanded the RPP’s covered period to include the Standby Period of 1963 through 1978, which was 

not previously considered covered under EEOICPA. The data in Table 4-1 do not consider dose 

reconstruction revisions that may be needed for the expanded covered period. NIOSH reviewed each 

claim to determine whether internal and/or external personal monitoring records could be obtained for 

the employee. No monitoring records were provided for any of the claimants. 

4.5 NIOSH Site Research Database

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

assessment of the evaluated class. Two hundred seventy-eight documents in this database were 

identified as pertaining to the RPP. These documents were evaluated for their relevance to this 

petition. The documents include historical background on the plant operations and processes, 

including the preparations for and activities taken during the Standby Period—the period that includes 

the class under evaluation.

4.6 Documentation and/or Affidavits Provided by Petitioners

In qualifying and evaluating the petition, NIOSH received a Form B petition with supporting 

attachments on June 25, 2019 [Redacted 2019]. The attachments consisted of: 

• Form B Appendix Continuation Page - a typewritten statement from the petitioner, a survivor of a 

worker formerly employed at INCO, that describes Exhibits A – C,
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• Exhibit A - a November 16, 2018 letter to the Department of Labor from the worker’s former 

supervisor at INCO stating that the worker had been employed at INCO,

• Exhibit B - an employment history affidavit stating that worker that had been a security guard 

employed by INCO,

• Exhibit C - a January 11, 1982 letter from INCO to DOE, Oak Ridge Operations, asking for 

clearances to be terminated and listing all remaining employees with Q and L clearances,

• Exhibit D - a January 11, 1982 internal INCO memo stating that an employee file on the INCO 

employees with clearances was to be destroyed, and

• Exhibit E - a December 14, 2018 letter to the DOL Office of Compensation from Huntington 

Alloys Corporation stating that the security force made routine checks of the RPP.

5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH

The following subsections summarize both radiological operations at the RPP and the information 

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

available sources NIOSH has gathered process and source descriptions that describe the radiological 

conditions during the evaluated period and the physical environment in which radiation exposures 

may have occurred during this period. The information included within this evaluation report is 

intended only to be a summary of the available information.

5.1 RPP Site and Process Descriptions

The RPP was located in Huntington, West Virginia, on a 3.67 acre property owned by the Atomic 

Energy Commission (AEC) and adjacent to INCO [General layout map 1958]. The RPP was 

constructed in 1951 and then operated by INCO under contract to the AEC. Q clearances were 

required for all personnel working in the RPP building and the workforce consisted of approximately 

20 to 25 employees [Hungerford 1951, PDF p. 3].

Figure 5-1 is a map of the AEC-owned property showing the two main buildings, the main Process 

Building and the Compressor Building. No contaminated materials were used in the Compressor 

Building. The Process Building was approximately 130 feet by 60 feet by 68 feet high. It was a 

structural steel building with a corrugated steel roof and siding, having five floors, with the upper four 

floors constructed with steel subway grating [Description of shutdown no date, PDF p. 9]. Materials 

were shipped to and from the facility by truck and by rail.
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Figure 5-1: Map of the RPP

Source: [Site description no date, PDF p.3]

Figure 5-2 is the section of the map in Figure 5-1 showing this building extension; it is aligned in the 

same direction as Figure 5-1 (i.e., east is toward the top of both Figure 5-1 and Figure 5-2).
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Figure 5-2: Map Showing Location of Residue Section within the Process Building

Source: [General layout map 1958, PDF p. 2]

Figure 5-3 is a photograph of the RPP buildings, with the Process Building on the far left, the 

Compressor Building in the middle, and the gas holding tanks on the far right, dated April 17, 1963. 

Figure 5-3: Process Building, Compressor Building, and Gas Holding Tanks (left to right)

Source: [Description of shutdown no date, PDF p. 40]

The RPP produced nickel-barrier material starting in 1951, entered a Standby Period beginning on 

May 1, 1963, and was demolished between November 27, 1978 and May 18, 1979. Although the time 

between May 1, 1963 and November 27, 1978, was contemporaneously called a “Standby Period” by 

INCO and DOE, it falls within the period of operations as defined by DOL. INCO was performing 
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maintenance and security within the RPP during this time under contract with DOE. DOL defined the 

covered period as the entire time between 1951 and May 18, 1979 [DOL 2019].

A timeline of these periods along with the dates that radioactivity was introduced to the site and the 

dates of the radiological surveys performed at the RPP site are shown in Figure 5-4. Although the 

class being evaluated falls with the Standby Period, the Production Period and the Demolition Period 

are described to provide the history of the radiological conditions during the Standby Period and the 

context for the radiological surveys that were performed both during the Standby Period and after the 

Demolition Period.

Figure 5-4: Timeline of the RPP

5.1.1 Production Period, 1951 through March 1963 

INCO supplied the nickel oxide, also called “sinter,” which was used as source material [Williams 

1960, PDF p.3]. The nickel was refined using the Mond process, as described below [Kirby 1961, 

PDF p. 19]. 

Nickel oxide is combined with hydrogen gas to produce nickel metal and water. 

The metal is then combined with carbon monoxide to produce nickel carbonyl gas. 

Finally, the nickel carbonyl gas is distilled to separate it from any metal contaminants such as iron 

carbonyl. It is then heated, causing it to decompose into pure nickel and carbon monoxide. 
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 A government memo from 1951 describes the process at the RPP: 

“The feed material is entered as nickel oxide, which is put into a reduction vessel, which, at 

controlled temperature in a hydrogen atmosphere, reduces the material to nickel. The nickel is 

then volatized by combining it with carbon monoxide in a pressure vessel at approximately 

300 lbs. PSI, thus forming a gaseous nickel carbonyl. This gaseous carbonyl is passed through 

a condenser to change it to a liquid status. The liquid carbonyl is then purified by selective 

distillation, removing the iron oxide and other impurities. The purified carbonyl then passes 

through the decomposer (a vertical vessel approximately 5' in diameter x 13' high) and, by 

controlled temperature, the pure carbonyl is broken down, dropping out the bottom of the 

vessel as metal powder. The metal powder then passes over screens to remove lumps, etc. 

After screening operations are completed, the metal powder is packed and ready for shipment” 

[Hungerford 1951, PDF p. 6]. 

Beginning in 1956, the RPP’s source material changed from uncontaminated nickel oxides to scrap 

barrier material supplied from the three gaseous diffusion plants: Portsmouth, Paducah, and K-25 

[Williams 1956; Excerpts from OROO no date]. The scrap barrier material included barrier that had 

been used for the isotopic separation of uranium hexafluoride and was contaminated with lowenriched uranium. Specifications for the material stated that the scrap barrier was to contain a 

minimum nickel content of 98.0% and no more than 0.0875 grams per pound of U-235 and no more 

than 500 ppm total uranium with the average content expected to be substantially less [Specifications 

for starting no date, PDF p. 2; Keller 1958a, PDF p. 2]. 

A government memo described the changes to the process when the RPP began using the 

contaminated barrier scrap as the source material:

“Since the starting material contains but a small per cent of oxide, the first step consists 

principally of activating the material with hydrogen rather than a reduction of the oxide. This 

is carried out in 4000 lb. batches in two kilns on the top level which traverse the top of the 

reactor columns on double tracks. Upon completion of the activation step the material is 

dumped through an air-tight seal into what were formerly used as reduction and activation 

reactors, but which now will be used for storage of the activated material. From this point on 

the process is basically unchanged, with the material proceeding to the reactors for conversion 

to crude carbonyl, distillation and purification of the crude carbonyl, and decomposition and 

preparation of specification grade powder” [McAlduff 1958, PDF p. 3]. 

The July 2–3, 1957, Final Report of Annual Fire Survey of Reduction Pilot Plant Huntington, West 

Virginia by Oak Ridge Operations personnel stated: 

“The plant operates continuously. There are two foremen, eight operators, and two Security 

guards on each shift. On the day shift only, this regular force is augmented by the Engineer in 

charge, Assistant Engineer in charge, one Utility Foreman and seven (7) service personnel” 

[Smith 1957, PDF p. 7].

INCO determined that during the nickel purification “virtually all of the uranium collects as a fine 

dust in the ash receivers at the bottom of the reactors" [Houser 1956, PDF p. 3]. These ash receivers 

were initially cleaned manually and on a weekly basis [Houser 1956, PDF p. 3]. 
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Modifications to the RPP in 1957 included the addition of “a vacuum system for handling 

contaminated residues including, blower with motor, separator, filters, and duct work” [Wende 1957, 

PDF p. 3]. The ash was vacuum transferred into the residue system and passed through a series of 

three filters: a cyclone filter, a metallic filter, and then a bag filter with the ash deposited into a drum. 

The drummed material was shipped to Oak Ridge, Tennessee [Travis 1980, PDF p. 2] [Smith 1979a].

In an undated, post-shutdown report listing all plant equipment, the residue system was listed as 

including the following [Description of shutdown no date, PDF p. 96]:

• U.S. Hoffman 6-stage exhauster with 40 HP motor,

• Haffco-Veyor cyclone separator,

• 1 Hoffman-Veyor bag filter,

• Dracco separator with metallic filters,

• 2-Vezin samplers with 1/2 HP motors,

• 6 Syntron electric vibrating feeders, and

• 1 Dracco discharge hopper.

In 1958, INCO was notified by Oak Ridge Operations that “minute quantities” of Pu-239, Pu-240, Pu241, U-236, Th-232, Np-237, and U-237 were present in the barrier scrap due to the fact that “a 

portion of the UF6 fed to the cascades of the diffuser plants [had] been produced from reprocessed fuel 

elements” [Sapirie 1958, PDF p. 2]. This included barrier scrap already processed at the RPP and 

future barrier scrap [Sapirie 1958].

By 1960, over 9,000,000 pounds of barrier scrap had been processed [Sapirie 1960, PDF p. 4] and a 

total of 401,181 pounds of nickel residue had been shipped to K-25 in Oak Ridge [UCC 1960, PDF p. 

33]. These residues were then shipped to the Oak Ridge Processing Company, Inc. (ORPC) to be 

smelted into ingots [UCC 1960, PDF p. 33]. ORPC was contracted to smelt metal scrap from the Oak 

Ridge facilities in order to separate uranium contamination from the metal [McLendon 1958].

5.1.2 Standby Period, May 1, 1963 through November 26, 1978

Production of the barrier material ceased at the RPP on December 11, 1962, and steps were taken to 

prepare the plant to be placed in a standby condition [Description of shutdown no date, PDF p. 6], 

with May 1, 1963, being “effective date of the beginning of the Standby Period” [Description of 

shutdown no date, PDF p. 9]. A May 3, 1962, letter from INCO to Oak Ridge Operations described 

the steps for placing the equipment in standby condition and the maintenance necessary for eventual 

restart. The procedures listed steps to remove all barrier scrap from all systems. In this letter the 

barrier scrap was described as “starting material” or S.M.

The planned steps for the Residue Section included the following [Carter 1962, PDF p. 7]:

1. Inert purge;

2. Air purge;

3. Clean completely, watching particularly for S.M.; and

4. Open to air.
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In the post shut-down report, the entire residue system was described as having been “carefully 

cleaned and lubricated” with the cloth filter bags removed [Description of shutdown no date, PDF p. 

96]. 

INCO provided Oak Ridge Operations with a list of the security and maintenance tasks along with 

their frequencies while the RPP was to be in a standby condition. Table 5-1 lists the tasks and the 

workers who performed each task, as well as the frequency. Note that this table contains all workers 

performing routine tasks within the RPP and that only the guards, as the security personnel, are 

members of the petition class.

Table 5-1: Tasks and Frequencies Proposed by INCO for the RPP Standby Period

Workers Task Frequency

Guards Check process room and compressor room Once a shift (three times a 

day)

Maintenance mechanic and helper Check that dry air system and the emergency 

inert system are functional

Once a week

Maintenance mechanic, helper, and 

craft workers

Perform maintenance as needed, lubricate 

equipment, clean and inspect equipment for 

corrosion, run equipment as needed

Monthly

Yard department Grass cutting Monthly

Responsible person from the 

Engineering Department and 

representative from paint contractor

Inspection Twice a year

Supervisor with experience during 

Production Period

Thorough inspection Yearly

Source: [Carter 1962, PDF p. 8]

A radiation survey and a security inspection of the RPP was made on January 15–16, 1975 [Smith 

1979a]. An April 1980 letter from the Director of the Safety and Environmental Control Division to 

the Director of the Research Division of Oak Ridge Operations described the radiological status of the 

RPP based on the results of the January 15-16, 1975 survey. The letter stated that with the exception 

of “the housing the residue system and the residue system itself,” the building was at a level low 

enough to comply with the unrestricted release criteria of NRC Regulatory Guide 1.86 [Travis 1980, 

PDF p. 2]. 

After determining that the RPP “no longer plays a role in either planning or back-up for future 

operations,” Oak Ridge Operations notified INCO to terminate all maintenance work needed to 

maintain operational capability as of March 4, 1975 [Anderson 1975, PDF p. 2]. The plant remained 

in standby mode until demolition began on November 27, 1978 [ORO 1977, PDF p. 4]. Although 

inspection walkthroughs may have continued after maintenance was halted, none of the inspections 

would have placed a worker inside the plant for more than two days per year. The only workers 

entering the RPP more often than that would have been security personnel.
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5.1.3 Demolition Period, November 27, 1978 through May 18, 1979 

Following the January 15–16, 1975 survey, DOE decided to dispose of the RPP. Authorization to 

proceed was received on June 10, 1977 [ORO 1977, PDF p. 4]. Demolition began on November 27, 

1978, and was completed by May 18, 1979 [ORO 1977, PDF p. 5]. Under the supervision of INCO, 

the Cleveland Wrecking Company performed the RPP demolition [Smith 1979a, PDF pp. 2–3]. For 

this effort, INCO hired several retired workers to provide health and safety supervision due to the 

presence of the nickel carbonyl [Skeletal plan for disposal no date, PDF p. 2]. 

Three specific hazards with health protection requirements were listed in a March 29, 1978, 

Specifications for Demolition document: asbestos, uranium, and nickel carbonyl [Specifications for 

demolition 1978, PDF p. 3]. Asbestos was present in the building as insulation. Uranium and nickel 

carbonyl locations were marked with white and red “X”s, respectively, based on process knowledge 

and the results of a 1975 survey. Half-face respirators were required for cutting and any dustgeneration activities involving uranium areas. Supplied-air respirators were required for nickel 

carbonyl areas or for areas marked with both uranium and nickel carbonyl [Specifications for 

demolition 1978, PDF p. 17]. All systems containing classified material were marked with at least a 

white or red “X” [Smith 1979a, PDF p. 3]. 

The decision to dispose of the demolition materials at a DOE facility was made for regulatory reasons 

rather than health protection: 

“...[A]t the time the demolition were [sic] made, there was no de minimis quantity for 

enriched uranium and the NRC Regulatory Guide 1.86 was considered inappropriate by DOE, 

Legal, for application to contamination involving enriched uranium. The decision was made in 

part for regulatory reasons rather than health protection reasons to dispose of the contaminated 

equipment at a DOE facility. Overriding considerations on this decision included the possible 

presence of classified material and possible presence of nickel carbonyl” [Travis 1980, PDF p. 

2].

There were 59 truckloads and four (4) railcar loads of scrap transported from the RPP to the classified

buria1 ground at the Portsmouth Gaseous Diffusion Plant. At the same time, 138 truckloads of clean 

scrap were removed from the RPP site. A “final site radiation survey” was conducted on May 15, 

1978, certifying that the site could be released for unrestricted use [Smith 1979, PDF pp. 2–3]. 

5.2 Radiological Exposure Sources from the RPP Standby Period

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

RPP class under evaluation. 

5.2.1 Internal Radiological Exposure Sources from the RPP Standby Period

During the Standby Period, the radiological condition of the Process Building would have remained 

static. There was no introduction of new radioactivity to the site. Any radioactivity remaining from 

earlier processing would have been inside the Process Building. The January 15–16, 1975, survey 

conducted by Oak Ridge Operations personnel confirmed that there was very little removable 

radioactivity within the Process Building and the greatest amounts of fixed radioactivity were found 

on the residue system equipment [Smith 1979]. This survey is taken to represent the conditions within 
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the RPP Process Building during the entire class period under evaluation, June 7, 1976 through 

November 26, 1978. 

5.2.1.1 Enriched Uranium 

Low-enriched uranium was present in some of the source barrier scrap used in the RPP starting in 

1956 and ending in April 1963. The average enrichment level of the uranium was planned to be 

between 1% and 2% [Armstrong 1957]. An Oak Ridge Operations internal letter stated that after 

processing over 9,000,000 pounds of the scrap barrier, the average enrichment was found to be 0.9% 

[Sapirie 1960]. Reports also stated that nickel scrap from the K-25 Plant was contaminated with 

uranium with a maximum enrichment of 4% by weight [Clark and Cottrell no date; Berger et al. 

1981].

The uranium was concentrated in the residues which were drummed and shipped to Oak Ridge, 

Tennessee, along with the final product, the nickel powder barrier material. The barrier scrap and 

residues were handled exclusively within the RPP Process Building. 

Enriched uranium within the RPP during the Standby Period may be estimated using the alphacontamination results from the January 15–16, 1975 survey and assuming the alpha activity was solely 

due to uranium. 

5.2.1.2 Contaminants from Reprocessed Fuel

In addition to uranium, radioactive contaminants from reprocessed fuel was present in the scrap 

barrier as a result of it having been used to enrich uranium obtained from reprocessed fuel. INCO was 

notified in a 1958 letter from Oak Ridge Operations of the presence of “minute quantities” of Pu-239, 

Pu-240, Pu-241, U-236, Th-232, Np-237, and U-237 contaminants present in the barrier material from 

reprocessed fuel [Sapirie 1958, PDF p. 2]. 

An estimate of contaminants from reprocessed fuel in scrap barrier material may be made following 

the methods used in DCAS-TKBS-0004. A discussion of reprocess fuel contaminants in K-25 barrier 

materials is found in the TBD, K-25 Gaseous Diffusion Plant-Occupational Internal Dose, ORAUTTKBS-0009-5. Table 5-6 from the TBD is recreated in this document as Table 5-2 with the values 

converted to dpm. This table is for low-enriched uranium and is based on a default enrichment of 2%. 

The scrap barrier material was contaminated with low-enriched uranium with a maximum enrichment 

of 4% by weight [Clark and Cottrell no date; Berger et al. 1981] and had an average enrichment of 

0.9% [Sapirie 1960].

The table is intended to provide a default isotopic distribution of reprocessed fuel contaminants when 

only total uranium results are available. In the context of RPP measurements, all alpha activity can be 

assumed to be uranium, and the amounts of contaminants from reprocessed fuel may be estimated by 

their relative activity to uranium.
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Table 5-2: Default Isotopic Distributions

Radionuclide dpm/g U

Pu-239 150,000

Am-241 150,000

U-236 2067

U-235 97,555

U-234 1,560,000

U-238 750,000

Np-237 142,000

Th-230 42,000

Tc-99 267

[ORAUT-TKBS-0009-5, PDF p. 13] 

The list of radionuclides in the 1958 letter from Oak Ridge Operations differs from the list in Table 5-

2. The list of radioisotopes in this table are taken to be a better description of the contaminants present 

from reprocessed fuel. 

All of the radionuclides in Table 5-3 are alpha emitters with the exception of Tc-99. 

The activities of the contaminants that would have been present in the contamination remaining at the 

RPP during the Standby Period may be estimated by developing ratios of their activities to the activity 

of the enriched uranium. The ratios are calculated from the data from Table 5-2 above and listed in 

Table 5-3 below. 

Table 5-3: Activity Ratios for Alpha-emitting Contaminants from Reprocessed Fuel

Radionuclide

Activity relative 

to total Enriched 

Uranium Activity

Pu-239 0.0623

Am-241 0.0623

Np-237 0.00498

Th-230 0.0174 

Tc-99 0.00011

It is assumed that all activity remained in the residues. As almost all of the uranium remained in the 

residues, these ratios may be used to estimate the amounts of these contaminants where the uranium 

concentration is known.
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5.2.2 External Radiological Exposure Sources from RPP Standby Period

During the period evaluated in this report, the radiological conditions at the RPP Process Building 

would have been static. The January 15–16, 1975, survey by Oak Ridge Operations personnel is taken 

to represent the conditions within the building during the entire Standby Period. 

5.2.2.1 Photon 

Although the low-enriched uranium and trace contaminants from fuel reprocessing do provide some 

low-energy photons, they would not have been a significant source of external exposure.

5.2.2.2 Beta

Low-enriched uranium and most of the trace contaminants from fuel reprocessing emit alpha radiation 

when they decay and are not sources of beta radiation. The only radioisotope in Table 5-3 that is a 

beta emitter is Tc-99. Table 5-4 lists the activity ratio for Tc-99 relative to the total uranium measured. 

Table 5-4: Activity Ratio for Beta-emitting Contaminant from Reprocessed Fuel

Radionuclide

Activity relative 

to total Enriched 

Uranium

Tc-99 0.00011 

5.2.2.3 Neutron 

Although low-enriched uranium was present in the barrier scrap and some of the uranium may have 

been in an oxide form, Battelle-TBD-6000 states that for uranium oxides “the neutron dose rate is 

about 0.07% of the beta/photon dose rate and need not be included in dose rate calculations. For 

uranium metal, the neutron dose rate is even less important” [NIOSH 2011b, PDF p. 25]. Because 

low-enriched uranium is the major radionuclide of concern at the RPP site, neutron exposures were 

not a significant hazard during the Standby Period. 

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH

The following subsections provide an overview of the state of the available internal and external 

monitoring data for the RPP class under evaluation.

Although no personal monitoring data have been located for INCO workers, four radiation surveys 

were performed at the RPP. One survey was done during the Standby Period prior to the class dates

evaluated in this petition, and three were done after the demolition of the RPP Process Building. The 

survey reports for all except the May 15, 1979 post-demolition survey have been found and reviewed. 

The cover letter for the May 15, 1979 survey included the statement “It is certified that as of May 15, 

1979, the site radiation level is as described and the property can be released for unrestricted use” 

[Smith 1979, PDF p. 3].
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A technical review of the “Final Site Radiation Survey,” dated May 15, 1979, resulted in 

recommendations for direct radiation levels to be measured at the ground surface and sampling for 

residual uranium in soil samples. The Oak Ridge National Laboratory (ORNL) conducted a 

preliminary survey on August 13, 1980 [Clark and Cottrell no date]. Their survey report 

recommended that a detailed formal survey be performed prior to public release of the site [Clark and 

Cottrell no date, PDF pp. 5–6]. ORAU performed the recommended surveys on November 17–19, 

1980 and December 3, 1980. Their conclusions were that the radiation levels were within guidelines 

for unrestricted release of the site [Berger et al. 1981]. 

Table 6-1. Radiological Surveys of the RPP

Survey Performed by Date(s) Performed

Radiation Survey and Security Inspection

[Smith 1979, PDF pp. 5–48] Oak Ridge Operations January 15–16, 1975

Final Site Radiation Survey

[Smith 1979, PDF pp. 3, 49–50] Oak Ridge Operations May 15, 1979

Preliminary Radiological Survey

[Clark and Cottrell no date] 

ORNL August 13, 1980

Radiological Assessment 

[Berger et al. 1981] 

ORAU November 17–19 and 

December 3, 1980

The post-demolition surveys by ORNL and ORAU identified higher gamma levels than the January 

15-16, 1975 survey by Oak Ridge Operations. The ORNL and the ORAU surveys included readings 

from both inside and outside of the buildings. Both reported gamma levels from readings made at 

contact with the surface. The ORAU report included gamma readings made at 3-feet above the 

surface.

6.1 Available RPP Internal Monitoring Data

No internal monitoring or air sampling data for radioactivity have been found for the RPP for the class 

under evaluation. NOCTS claim files have been reviewed and none contain bioassay results or air 

sampling data.

Area monitoring data from the Standby period have been found for the RPP. On January 15–16, 1975, 

a radiation survey was made of the RPP [Smith 1979, PDF p. 5]. This survey included direct alpha 

measurements made with an alpha scintillation counter. Swipes of removable alpha activity were 

made and analyzed afterward in Oak Ridge, Tennessee.

Direct alpha levels and smears were taken at 68 points on all five levels in the RPP Process Building, 

with most in the area of the residue system. The highest direct alpha measurement on the floor was 

960 dpm/100 cm2 and the highest smear from the floor was 19 dpm/100 cm2, both in the vicinity of 

the residue system. Alpha measurements and smears were also taken on 23 points on selected process 

equipment. The highest direct alpha measurement on the equipment was 3,400 dpm/100 cm2 and the 

highest smear from the equipment was 16 dpm/100 cm2, both on residue system equipment. 
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Table 6-2: Survey Results for Fixed and Removable Alpha Activity on the Residue System

Residue System 

Equipment

Survey Meter

dpm/100 cm2

Smear

dpm/100 cm2

Bag filter 3,400 10

Metallic filter 800 None Detected

Sample line Not measured 16

Sample splitter 1,200 5 

Drumming station 800 5 

6.2 Available RPP External Monitoring Data

No personal external monitoring data have been located in data capture efforts, including record 

searches at the K-25 site and at the Portsmouth site. No personnel dosimetry records have been 

identified in NOCTS records. There is no indication in the documents available to NIOSH of any 

personal dosimetry performed at the RPP. 

The January 15–16, 1975 radiation survey conducted during the Standby Period by Oak Ridge 

Operations states that gamma levels were measured by scintillation probe at 3-feet above the ground 

and contact beta-gamma levels were measured by a thin-window probe. The report states that the 

gamma levels showed “no difference from normal background, 8–10 μr/hr” [Smith 1979, PDF p. 5]. 

None of the points measured on the floors or the equipment had any detectable removable betagamma activity.

The highest beta-gamma level reported using the thin-window probe at contact was 0.25 mr/hr. The 

value was reported for three locations on process equipment: (1) the West Residue Discharge Flange 

for Reactor #2; (2) the East Residue Discharge Flange for Reactor #2; and (3) on material from Tank 

#2. The report stated that no measurements were taken at outside locations due to snow cover. 

A survey conducted on August 13, 1980, by ORNL after the demolition of the Process Building, 

reported an average of 10 μR/hr and a maximum of 45 μR/hr measured on contact with a driveway 

between the railroad tracks and the tank farm using a gamma scintillation probe [Clark and Cottrell no 

date, PDF p. 8]. The survey conducted by ORAU on November 17–19 and December 3, 1980, also 

indicated a maximum of 45 μR/hr measured in approximately the same area as the driveway as

referenced by ORNL, also measured in contact using a gamma scintillation probe [Berger et al. 1981, 

PDF p. 22]. The ORAU report included analyses of gravel that had been used as fill for the concrete 

driveway. The gravel had elevated levels of Ra-226, indicating a natural origin for the material as no 

Ra-226 was used at the RPP [Clark and Cottrell no date, PDF p. 8]. The ORAU report did say, 

however, that this pad was the location used by the demolition contractor to store contaminated 

equipment after removal from the RPP Processing Building [Berger et al. 1981, PDF p. 12]. 

The ORAU survey also measured up to 35 μR/hr in “small rooms and enclosed spaces of the change 

room, stairwell, and second floor office area” within the Compressor Building. Through sampling of 

the concrete block in the building, it was determined that the source was primarily naturally occurring 

Ra-226 [Berger et al. 1981, PDF p. 11]. 

The January 15–16, 1975 radiation survey included beta-gamma results on swipes taken at 41 points 

on the floors from all five levels; all beta-gamma swipe results were listed in the report as “None 
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Detectable” [Smith 1979, PDF pp. 13–14]. The survey report also included 16 results from 

measurements using a thin-window probe made on contact with plant equipment [Smith 1979, PDF p. 

5]. Although the purpose was to measure low-energy gamma radiation from any remaining uranium, 

the probe would have also measured any beta radiation. The results ranged from “None Detected” to a 

maximum of 0.25 mr/hr, a level found on three pieces of equipment, including the reduction kiln, 

Reactor #2, and measuring tank #2.

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH

The feasibility determination for the class of employees under evaluation in this report is governed by 

both EEOICPA and 42 CFR § 83.13(c)(1). Under that Act and rule, NIOSH must establish whether or 

not it has access to sufficient information either to estimate the maximum radiation dose for every 

type of cancer for which radiation doses are reconstructed that could have been incurred under 

plausible circumstances by any member of the class, or to estimate the radiation doses to members of 

the class more precisely than a maximum dose estimate. If NIOSH has access to sufficient information 

for either case, NIOSH would then determine that it would be feasible to conduct dose 

reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might assure that NIOSH can estimate either the maximum doses that 

members of the class might have incurred, or more precise quantities that reflect the variability of 

exposures experienced by groups or individual members of the class. This approach is discussed in 

NIOSH’s SEC Petition Evaluation Internal Procedures which are available on the NIOSH Radiation 

Dose Reconstruction Program webpage. The next four major subsections of this evaluation report 

examine:

• The sufficiency and reliability of the available data. (Section 7.1) 

• The feasibility of reconstructing internal radiation doses. (Section 7.2) 

• The feasibility of reconstructing external radiation doses. (Section 7.3) 

• The bases for petition SEC-00253 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of RPP Data

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The

feasibility evaluation presupposes that data pedigree issues have been settled. 
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7.1.1 Internal Monitoring Data Pedigree Review

NIOSH has not located any internal radiation monitoring data nor any radiation air sampling data for 

the period under evaluation (June 7, 1976 through November 26, 1978).

NIOSH has located the results of a survey conducted during the Standby Period [Smith 1979]. This 

report described the January 15–16, 1975 RPP survey and was acquired as an attachment to a 

November 14, 1979 internal Oak Ridge Operations letter [Smith 1979]. This survey report includes 

surface contamination results for removable alpha contamination on process equipment. This survey 

report appears to be primary source data and allows for resuspension analysis during the Standby 

Period of the plant history. Data pedigree evaluation is not necessary for primary source data, which is 

the only data type available for this period.

7.1.2 External Monitoring Data Pedigree Review

NIOSH has not located any external dosimetry data for the period under evaluation (June 7, 1976 

through November 26, 1978), or any documentation to indicate that personal dosimetry was 

performed at the RPP. Therefore, a data pedigree evaluation is not possible for this data type.

The January 15–16, 1975, survey by Oak Ridge Operations provides monitoring results that describe 

the radiological conditions during the Standby Period. All of the documentation available indicates 

that conditions were static within the building during the Standby Period. The survey document 

appears to be a primary source document, and as such will be used to represent the conditions at the 

facility over the period under evaluation. Therefore, a data pedigree evaluation is not necessary for 

this data type.

The November 17–19 and December 3, 1980 survey by ORAU provides monitoring results that 

describe the radiological conditions after the demolition of the Process Building. It includes 

measurements of ambient gamma levels primarily due to naturally occurring radioactivity found 

within the RPP site. The areas monitored were from materials not affected by the demolition and 

would reflect conditions prior to demolition during the Standby Period. The survey document appears 

to be a primary source document, and as such will be used to represent the conditions at the facility 

over the period under evaluation. Therefore, a data pedigree evaluation is not necessary for this data 

type.

7.2 Evaluation of Bounding Internal Radiation Doses at the RPP

The principal source of internal radiation doses for members of the class under evaluation was

contamination from low-enriched uranium, including reprocessed fuel contaminants [NIOSH 2018]. 

The following subsections address the ability to bound internal doses, methods for bounding doses, 

and the feasibility of internal dose reconstruction.

7.2.1 Evaluation of Bounding Process-Related Internal Doses

There was no known air monitoring for radioactivity at the RPP. There is no indication that bioassay 

samples were collected during the Standby Period.

A radiological survey of the RPP Process Building conducted on January 15–16, 1975, included alpha 

measurements of removable and fixed activity at a variety of points on the floors and on process 

equipment, particularly in the area of the residue handling system and its equipment [Smith 1979, 
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PDF pp. 13, 17]. This survey was conducted prior to the evaluated class period. As the site had been 

placed in a standby mode and there was no new introduction of radioactivity occurring, the survey 

results can be used to describe the radiological condition of the RPP to allow bounding of internal 

dose. 

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses

The ambient environmental dose does not need to be reconstructed because ambient dose is accounted 

for in the assignment of doses from process materials. The radiological conditions at the RPP used to 

estimate internal and external doses were measured during the Standby Period prior to the NIOSHevaluated class period and would have included the influence of both process-related materials and 

any residual materials.

7.2.3 Methods for Bounding Internal Dose at the RPP

The following subsections summarize the methods for bounding internal dose at the RPP site. 

7.2.3.1 Methods for Bounding Standby Period Internal Dose

Internal exposures may be assessed using survey results obtained during the January 15–16, 1975, 

radiological survey of the RPP. This survey predates the NIOSH-evaluated class and it is assumed that 

there was no depletion of the contamination through cleaning or other removal; cleaning was not a 

listed task charged to the government by INCO during the RPP’s Standby Period [Listing of data no 

date, PDF p. 4]. 

The highest removable alpha result, 19 dpm/100 cm2, is assumed to be uranium and assumed to apply 

uniformly to the entire floor area walked by INCO security guards. Air concentrations are estimated 

using a resuspension factor of 10-6 m-1 [ORAUT 2012] and a breathing rate of 1.2 m3 per hour [ICRP 

1994, PDF p. 107]. 

Security guards performed a walk-through of the RPP Process Building once per shift. Using a typical 

walking speed of 3 miles per hour or 4.4 feet per second, a person could walk the length of the Process 

Building in about 34 seconds. Allowing for deviations and stops, NIOSH assumed that no single 

walk-through would take more than five minutes. For estimating the length of time at the RPP, a 

factor of three is applied, giving fifteen minutes as the time that any security guard was in the RPP

Process Building, the Compressor Building, and the grounds during their walk-through. 

The time in the Process Building for any individual security guard is assumed 0.25 hours per day or 

91.3 hours per year. This provides an upper bound on the annual inhalation of total uranium as: 

19 dpm/100 cm2 * 10000 cm2/m2 * 10-6 m-1 * 1.2 m3/hr * 91.3 hr/yr = 0.208 dpm/yr 

The contaminants from reprocessed fuel may be estimated using the factors listed in Table 5-3. The 

inhalation rates per year for reprocessed-fuel contaminants are listed in Table 7-1. These may be 

applied for any year or fraction of a year the worker was at the RPP. 
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Table 7-1. Annual Inhalation Rates of Uranium and Reprocessed Fuel Contaminants

Radionuclide Annual inhalation 

(dpm/year) 

Uranium 0.209

Pu-239 0.0130

Am-241 0.0130

Np-237 0.00104

Th-230 0.00363

Tc-99 0.000023

7.2.3.2 Methods for Bounding Ambient Environmental Internal Dose 

As stated in Section 7.2.2 above, the ambient environmental dose does not need to be reconstructed 

because ambient dose is accounted for in the assignment of process-related dose in the Standby 

Period. 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion 

NIOSH has found that it is feasible to reconstruct internal dose to INCO security guards at the RPP

for the period between June 7, 1976 and November 26, 1978 using the available survey data from 

Smith [1979]. Worker dose may be estimated by using the annual inhalation values listed in Table 7-1 

for any year between 1976 and 1978. 

7.3 Evaluation of Bounding External Radiation Doses at the RPP

The principal source of external radiation doses for members of the evaluated class was to 

contamination from low-enriched uranium and processed fuel contaminants [NIOSH 2018]. 

The following subsections address the ability to bound external doses, methods for bounding doses, 

and the feasibility of external radiation dose reconstruction.

7.3.1 Evaluation of Bounding Process-Related External Doses

NIOSH is not aware of any worker monitoring for external exposure for work at the RPP. In the 

January 15–16, 1975, radiological survey, ambient gamma levels were measured with a gamma 

scintillation probe and wipes from floor locations and from equipment were counted using a thinwindow beta-gamma probe. Several locations on plant equipment were also measured directly with 

the beta-gamma probe. 

The 1975 survey report stated that the “survey results inside all the buildings using the scintillation 

gamma ratemeter showed no difference from normal background, 8-10 μr/hr” [Smith 1979, PDF p. 5]. 

None of the points measured on the floors or the equipment had any detectable removable betagamma activity.

The highest direct reading for beta-gamma was 0.25 mR/hour and was found at several locations; on 

the reduction kiln, reactor #2, and measuring tank #2. Note that these measurements were taken at 

contact with process equipment and the results did not indicate separate beta and gamma levels.
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The post-demolition ORAU survey measured 35 μR/hr within the Compressor Building and through 

sampling of the concrete block in the building, determined the source to be primarily naturally 

occurring Ra-226 [Berger et al. 1981, PDF p. 11].

The external photon exposure may be bound using the highest gamma scintillation results for 

measurements made at 3-feet above the surface at the RPP, 35 μR/hour. This was measured in the 

post-demolition survey by ORAU of the Compressor Building, and although including photons from 

natural radioactivity, encompasses all photon dose that may have come from the uranium and enriched 

fuel contaminants.

The external beta exposure may be bound using the highest beta-gamma result from the January 15–

16, 1975 survey during the Standby Period, 0.25 mR/hour. As the measurement includes exposure 

from both low-energy gamma and beta, it is bounding for beta exposure.

7.3.2 Evaluation of Bounding Ambient Environmental External Doses

The ambient environmental dose does not need to be reconstructed because ambient dose is accounted 

for in the assignment of process-related dose. The radiological conditions at the RPP used to estimate 

external doses were measured during the Standby Period and would have included the influence of 

both process-related dose and any residual materials.

7.3.3 RPP Occupational X-Ray Examinations

No information regarding medical X-rays for RPP workers were found in the available records. 

The Site Profile for the RPP [NIOSH 2018] provides instructions for assignment of annual medical Xray dose in 1951 through 1963 and 1978 through 1979. The DOL recently changed the covered period 

to be continuous from 1951 through May 18, 1979, such that the Standby Period evaluated in this 

report is covered under EEOICPA. Therefore, the methods for reconstruction of medical X-ray dose 

specified in the Site Profile also apply to the Standby Period being evaluated in this report.

7.3.4 Methods for Bounding External Dose at the RPP Site

NIOSH has an established protocol for assessing external exposure when performing dose 

reconstructions (these protocol steps are discussed in the following subsections):

• Photon Dose

• Beta Dose

• Neutron Dose

7.3.4.1 Methods for Bounding Standby Period External Dose

Photon Dose

Although the highest gamma result in the RPP radiological surveys was 45 μR/hour, this was 

measured on contact with the ground surface. The highest reading made at 3-feet above the floor was 

35 μR/hour (0.035 mR/hour). An upper-bound dose estimate may be established by using 0.035 

mR/hour. The time in the RPP for any individual security guard is assumed to be 0.25 hours per day 

or 91.3 hours per year. Using these values gives:
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0.035 mR/hour * 91.3 hours per year = 3.2 mR/year

This results in an upper-bounding estimate as it assumes that the walk-through was performed by the 

same person throughout the year, and that the person was exposed continuously to the highest ambient 

photon exposure level measured in any of the surveys conducted within the RPP, and that the 

exposure measurement which was representative of the average exposure at the RPP.

Beta Dose

An upper-bound estimate of beta dose may be established by using the highest direct beta-gamma 

results from the January 15–16, 1975, survey, 0.25 mR/hour. The beta-gamma rate was reported in 

units of exposure; it is assumed the reported mR/hour exposure rate is reasonably equivalent to 

mrad/hour beta dose rate. The time in the RPP Process Building for any individual security guard is 

assumed to be 0.25 hours per day or 91.3 hours per year. Using these values gives:

0.25 mrad/hour * 91.3 hours per year = 23 mrad/year

This is an upper-bounding estimate of the dose result as it assumes that the walk-through was 

performed by the same person throughout the year, and that the person was exposed to the highest 

beta-gamma result within the Process Building. This result also assumes that the measurement the 

dose is based on was pure beta with no gamma component.

Neutron Dose

As stated in Section 5.2.2.3 of this report, neutron dose was not a significant hazard during the 

Standby Period and does not require a bounding method.

7.3.4.2 Methods for Bounding Ambient Environmental External Doses

As stated in Section 7.3.2, the ambient environmental dose does not need to be reconstructed because 

ambient dose is accounted for in the assignment of doses from process-related materials.

7.3.5 External Dose Reconstruction Feasibility Conclusion

NIOSH has found that it is feasible to reconstruct external dose to INCO security guards at the RPP

for the period from June 7, 1976 through November 26, 1978, using the available survey data. Worker 

dose may be estimated by using an annual exposure rate of 3.2 mR per year for photon and 23 mrad

per year for beta.

7.4 Evaluation of Petition Basis for SEC-00253

The following subsections evaluate the assertions made on behalf of petition SEC-00253 for the RPP.

7.4.1 Exposure Incidents

Issue: The petition is based on one or more unmonitored, unrecorded, or inadequately monitored or 

recorded exposure incidents.

Response: In the context of qualifying a petition using the E.5 basis, 42 CFR 83.13 (c)(3)(i) refers to 

“...discrete incidents likely to have involved exceptionally high level exposures, such as nuclear 

criticality incidents or other events involving similarly high levels of exposures resulting from the 
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failure of radiation protection controls..." [Procedures for designating 2018, PDF p. 11].Statements, 

such as those provided under Section E.5 in Form B, about workers entering the RPP building without 

protective equipment do not address the basis of unmonitored, unrecorded, or inadequately monitored 

or recorded exposure incidents.

7.4.2 No Worker Monitoring

Issue: Radiation exposures and radiation doses potentially incurred by members of the proposed class 

were not monitored either through personal monitoring or through area monitoring. 

Response: NIOSH has been unable to locate area monitoring records or personal radiation records. 

However, NIOSH was able to locate a radiological survey of the RPP made prior to the evaluated 

period and surveys made after the demolition that measured alpha, beta-gamma, and gamma radiation 

levels along with INCO and government reports describing the status of the facility during this period. 

These documents provide sufficient information to allow NIOSH to establish upper bounds on worker 

exposures for the class under evaluation. 

7.4.3 Monitoring Records were Destroyed

Issue: Documents or statements provided by affidavit that indicate that radiation monitoring records 

for members of the proposed class have been lost, falsified, or destroyed; or that there is no 

information regarding monitoring, source, source term, or process from the site where the energy 

employees worked.

Response: Although evidence provided by the petitioner indicates that security records for RPP

workers were destroyed, there is no evidence that the destroyed records included radiation monitoring 

records. NIOSH has not located any radiation monitoring records for INCO workers and does not 

have evidence that any monitoring occurred. However, NIOSH was able to locate a radiological 

survey of the RPP made prior to the class period and surveys made after the demolition that measured 

alpha, beta-gamma, and gamma radiation levels along with INCO and government reports describing 

the status of the facility during this period. These documents provide sufficient information to allow 

NIOSH to establish upper bounds on worker exposures for the class under evaluation.

7.5 Summary of Feasibility Findings for Petition SEC-00253

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

from June 7, 1976 through November 26, 1978. NIOSH found that the available monitoring records, 

process descriptions, and source term data available are sufficient to complete dose reconstructions for 

the evaluated class of employees.
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Table 7-2: Summary of Feasibility Findings for SEC-00253

June 7, 1976 through November 26, 1978

Source of Exposure Reconstruction Feasible (Yes or No)

Internal (Enriched uranium) Yes

Internal (Contaminants from reprocessed fuel) Yes

External (Gamma, Beta, Neutron) Yes

External (Beta) Yes

External (Neutron) N/A

External (Occupational Medical X-ray) N/A 

8.0 Evaluation of Health Endangerment for Petition SEC-00253

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

governed by both EEOICPA and 42 CFR § 83.13(c) (3). Under these requirements, if it is not feasible

to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must also 

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

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If the 

occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those 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’s evaluation determined that it is feasible to estimate radiation dose for members of the 

NIOSH-evaluated class with sufficient accuracy based on the sum of information available from 

available resources. Therefore, a health endangerment determination is not required. 

9.0 Class Conclusion for Petition SEC-00253

Based on its full research of the class under evaluation, NIOSH found no part of said class for which it 

cannot estimate radiation doses with sufficient accuracy. This class includes all INCO security 

personnel who worked at any location within the RPP during the period from June 7, 1976 through 

November 26, 1978. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the SRDB, for information relevant to SEC00253. In addition, NIOSH reviewed its NOCTS dose reconstruction database to identify EEOICPArelated dose reconstructions that might provide information relevant to the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 
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ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 

standards of performance in determining the feasibility or infeasibility of reconstructing radiation dose 

for the class under evaluation.
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10.0 References 

Anderson RV [1975]. RPP maintenance. Letter to Manilla CE. March 5. [SRDB Ref ID: 179908] 

Answers to questions and comments on health, safety, and security [no date]. [SRDB Ref ID: 179741] 

Armstrong RC [1957]. Processing of scrap barrier material at the INCO plant, Huntington, West 

Virginia. Letter to Crosby GH. Oak Ridge, TN: Oak Ridge Operations. January 15. [SRDB Ref ID: 

19726] 

Berger JD, Kuechle CW, Riemke CF, and Weaver CF [1981]. Radiological assessment of the former 

Reduction Pilot Plant. Oak Ridge, TN: Oak Ridge Associated Universities. July 2. [SRDB Ref ID: 

179725] 

Carter JE [1962]. Shutdown, standby maintenance, and startup of Reduction Pilot Plant 

recommendations. Letter to Marsh JA. April 19. [SRDB Ref ID: 179799] 

Clark C, Cottrell WD [no date]. Preliminary radiological survey of the former Reduction Pilot Plant, 

Huntington, West Virginia. [SRDB Ref ID: 85888] 

Description of shutdown and placement in standby of Reduction Pilot Plant [no date]. [SRDB Ref ID: 

179705] 

DOL [2019]. DOL modifications of covered dates for RPP site. Letter to Calhoun G. Washington, 

DC: U.S. Department of Labor, Office of Workers’ Compensation Programs Division of Energy 

Employees Occupational Illness Compensation. November 15. [SRDB Ref ID: 180375] 

Excerpts from OROO accounting manual [no date]. [SRDB Ref ID: 18875] 

General layout map of Huntington Pilot Plant [1958]. [SRDB Ref ID: 18809] 

Guidelines for determining probability of causation under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 42 CFR Part 81 [2019]. [SRDB Ref ID: 180246] 

Houser EA [1956]. Notes on meeting with INCO at Oak Ridge. Memorandum to files. September 26. 

[SRDB Ref ID: 80294] 

Hungerford FC [1951]. Report of conference with International Nickel Company relative to the 

Huntington, WV project. Memorandum to Williams N. January 31. [SRDB Ref ID: 19713] 

ICRP [1994]. Human respiratory tract model for radiological protection. ICRP Publication 66. Ann 

ICRP 24(1-3). [SRDB Ref ID: 22732] 

Kaye SV [1980]. Radiation contamination clearance report-former Reduction Pilot Plant (RPP), 

Huntington, West Virginia March 6, 1980. Letter to Bibb WR. Oak Ridge, TN: Oak Ridge National 

Laboratory. March 6. [SRDB Ref ID: 85880] 
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Keller CA [1958a]. Estimate of maximum damage arising out of RPP activities at Huntington, West 

Virginia. Letter to Moore JR. Oak Ridge, TN: Department of Energy, Oak Ridge Operations. April 

16. [SRDB Ref ID: 80304] 

Keller CA [1958b]. Uranium urinalysis for Huntington Plant, International Nickel Company. Letter to 

Huber AP. Oak Ridge, TN: Department of Energy, Oak Ridge Operations. May 26. [SRDB Ref ID: 

18811] 

Kirby LJ [1961]. The radiochemistry of nickel. Washington, DC: Subcommittee on Radiochemistry, 

National Academy of Sciences—National Research Council. November. [SRDB Ref ID: 179906] 

Listing of data on plant and equipment in standby [no date]. [SRDB Ref ID: 19654] 

McAlduff HJ [1958]. Visit to International Nickel Company, Huntington, West Virginia on February 

26, 1958. Memorandum to Keller CA. March 5. [SRDB Ref ID: 18870] 

McLendon JD [1958]. Health physics survey of ferrous metal smelting operation. Letter to Moore 

WC. Y-12 Plant, Oak Ridge, TN: Union Carbide Nuclear Company. May 28. [SRDB Ref ID: 180258] 

Methods for conducting dose reconstruction under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 42 CFR Part 82 [2019]. [SRDB Ref ID: 180247] 

NIOSH [2011a]. Internal procedures for the evaluation of special exposure cohort petitions. DCASPR-004 Rev. 1. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease 

Control and Prevention, National Institute for Occupational Safety and Health. April 15. [SRDB Ref 

ID: 94768] 

NIOSH [2011b]. Site profiles for Atomic Weapons Employers that worked uranium metals. BattelleTBD-6000 Rev. 1. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for 

Disease Control and Prevention, National Institute for Occupational Safety and Health. June 17. 

[SRDB Ref ID: 101251] 

NIOSH [2018]. Technical basis document for the Huntington Pilot Plant, Huntington, West Virginia. 

DCAS-TKBS-0004 Rev. 02. Cincinnati, OH: U.S. Department of Health and Human Services, 

Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health. 

November 5. [SRDB Ref ID: 175109] 

ORAUT [2006]. Technical basis document for K-25 Gaseous Diffusion Plant-occupational internal 

dose. ORAUT-TKBS-0009-5 Rev. 01 PC-1. Oak Ridge, TN: Oak Ridge Associated Universities 

Team. October 4. [SRDB Ref ID: 30010] 

ORAUT [2012]. Dose reconstruction during residual radioactivity periods at Atomic Weapons 

Employer facilities. ORAUT-OTIB-0070 Rev. 01. Oak Ridge, TN: Oak Ridge Associated 

Universities Team. March 5. [SRDB Ref ID: 108851] 

ORAUT [2020]. Documented communication SEC-00253 with [name redacted] on RPP. Oak Ridge, 

TN: Oak Ridge Associated Universities Team. February 18. [SRDB Ref ID: 179905] 

ORO [1977]. Preliminary proposal for disposal of Huntington facility. Department of Energy, Oak 

Ridge Operations. September 26. [SRDB Ref ID: 179723] 
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Procedures for designating classes of employees as members of the Special Exposure Cohort under 

the Energy Employees Occupational Illness Compensation Program Act of 2000. 42 CFR Part 83 

[2018]. [SRDB Ref ID: 179160] 

Redacted [2019]. SEC-00253 petition, Form B – 83.13 with attachments. Huntington, WV. Received 

by NIOSH June 25. June 19. [SRDB Ref ID: 179907] 

Sapirie SR [1958]. Appendix C contract AT(40-1)-1092. Letter to The International Nickel Company, 

Inc. Oak Ridge, TN: Department of Energy, Oak Ridge Operations. February 28. [SRDB Ref ID: 

18869] 

Sapirie SR [1960]. Licensing requirements with regard to property which may be slightly 

contaminated with special nuclear material. Letter to Quinn GF. Oak Ridge, TN: Department of 

Energy, Oak Ridge Operations. August 29. [SRDB Ref ID: 19657] 

Site description and plot of plant [no date]. [SRDB Ref ID: 85876] 

Skeletal plan for disposal of RPP [no date]. [SRDB Ref ID: 179715] 

Smith RD [1979]. Reduction Pilot Plant (RPP) contamination clearance report (with attachments). 

Oak Ridge, TN: Department of Energy, Oak Ridge Operations. November 14. [SRDB Ref ID: 

179732] 

Smith RM [1957]. Final report of annual fire survey of Reduction Pilot Plant Huntington, West 

Virginia. July 2–3. [SRDB Ref ID: 18812] 

Specifications for demolition for the removal of the Reduction Pilot Plant [1978]. March 29. [SRDB 

Ref ID: 180218] 

Specifications for starting material [no date]. [SRDB Ref ID: 22105] 

Travis WH [1980]. Radiation contamination clearance report-former Reduction Pilot Plant (RPP), 

Huntington, West Virginia. Letter to Bibb WR. Oak Ridge, TN: Department of Energy, Oak Ridge 

Operations. April 4. [SRDB Ref ID: 85883] 

UCC [1960]. Oak Ridge Gaseous Diffusion Plant quarterly report second quarter FY1960, October 1, 

1959 through December 31, 1959. K-25 Plant, Oak Ridge, TN: Union Carbide Corporation. April 29. 

[SRDB Ref ID: 99920] 

Wende EA [1957]. Directive for modifications to Reduction Pilot Plant, Huntington, West Virginia 

subproject 224-57n-INC2. Oak Ridge, TN: Department of Energy, Oak Ridge Operations. February 

14. [SRDB Ref ID: 22000] 

Williams N [1956]. The meeting at Huntington with INCO April 19, 1956. Memorandum to files. 

April 24. [SRDB Ref ID: 80290] 

Williams N [1960]. Disposition of massive nickel. September 27. [SRDB Ref ID: 19656] 
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Attachment One: Data Capture Synopsis

Table A1-1: Summary of Holdings in the SRDB for the RPP, Huntington, West Virginia

Data Capture Information Data Capture Description Date 

Completed 

No. 

Uploaded 

into SRDB

Primary Site / Company Name: Reduction 

Pilot Plant

DOE 1951-May 18, 1979; DOE 

(Remediation) November 27, 1978- May 

18, 1979 

Alternate Site Names: RPP, Huntington 

Pilot Plant, HPP, International Nickel 

Company, INCO, Huntington Alloys

Physical Size of the Site: The site occupied 

3.67 acres. The three major buildings on 

site were the Compressor Building, Gas 

Cracking Plant, and the Main Process 

Building. 

Site Population: Demolition contract 

documents indicate that 78 persons were 

employed during the site remediation.

No relevant documents identified. 12/17/2019 0 

State Contacted: NA Since the Reduction Pilot Plant was a DOE facility the State of West Virginia was not contacted. NA 0 

Albany Research Center No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0 

Ames Laboratory No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0 

Argonne National Laboratory - East No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0 

Battelle Memorial Institute - King Avenue No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

Brookhaven National Laboratory No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0 

Colorado Mesa University, Tomlinson 

Library

No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

Department of Labor / Paragon Reduction Pilot Plant correspondence, INCO meeting notes, security reports, reports of Department of 

Labor Site Exposure Matrices roundtable meetings, the need for additional powder capacity, and an 

estimate of maximum damage from a plant accident.

04/06/2010 19
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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into SRDB

DOE Germantown Requests for nickel carbonyl detection equipment, a report of a conference with the International Nickel 

Company, a press release, contract correspondence, the 1956 agreement to process Government-owned 

nickel scrap, and Records Holding Area search procedures.

03/07/2011 10

DOE Legacy Management - Grand 

Junction Office

A site description, radiological surveys, radiation contamination clearance reports and comments, and 

elimination of the Reduction Pilot Plant from the Formerly Utilized Sites Remedial Action Program 

(FUSRAP).

08/15/2010 13

DOE Legacy Management - Morgantown 

Office

No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0

DOE Legacy Management - MoundView 

Office (Fernald Holdings, includes Fernald 

Legal Database)

No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

DOE Legacy Management - Westminster 

Office

No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

DOE Oak Ridge Operations Office -

Records Holding Task Group (RHTG)

A discussion of uranium contained in nickel scrap, change in the classification level of shipments to K-25, 

the directive to expand the Reduction Pilot Plant, and correspondence on increasing the stocks of nickel 

powder. Awaiting the release of additional documents from classification review.

OPEN 5

DOE Office of Scientific and Technical 

Information (OSTI) 

A request was submitted for a search for RPP documents in the OSTI non-publicly available holdings. OPEN 0

DOE Portsmouth/Paducah Project Office 

(PPPO)

Sample analyses, disposal of the RPP, disposal of personal property, appraisal of the RPP and its condition, 

the RPP contract and associated documents, the Cleveland Wrecking Company contract and associated 

documents, photographs of the RPP, uranium and nickel carbonyl contamination, guidelines for the 

dismantling process, costs of the RPP dismantling, disposal of contaminated equipment, RPP processing 

equipment sketches with dimensions, an RPP contamination clearance report, health protection 

requirements for the RPP dismantling, radiological assessments of the RPP, DOE officials' diary entries, 

RPP demolition staffing, demolition scrap burial at Portsmouth, radiological surveys, and questions 

concerning the health of a demolition worker.

02/20/2020 108

East Tennessee Technology Park (ETTP) 

Records Center

Page extracted from Oak Ridge Gaseous Diffusion Plant report K-1907. 06/02/2020 1

Energy Technology Engineering Center 

(ETEC)

No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Environmental Measurements Laboratory 

(EML)

No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0
SEC-00253 04-24-2020 Reduction Pilot Plant

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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into SRDB

Federal Records Center (FRC) - Atlanta No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Federal Records Center (FRC) - Chicago No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0

Federal Records Center (FRC) - Dayton No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0

Federal Records Center (FRC) - Denver No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0

Federal Records Center (FRC) - Kansas 

City

Detailed finding aid record descriptions indicate records are duplicates of records released by the DOE 

PPPO

03/06/2020 0

Federal Records Center (FRC) - Lee's 

Summit

No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0

Federal Records Center (FRC) - San Bruno No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

General Atomics No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Hagley Museum and Library No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Hanford DOE Office of Hearings and Appeals petitions for redress. 12/04/2019 1

Idaho National Laboratory No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Internet - Defense Technical Information 

Center (DTIC)

No relevant data identified. 01/17/2020 0

Internet - DOE Hanford Declassified 

Document Retrieval System (DDRS)

No relevant data identified. 07/12/2019 0

Internet - DOE Idaho Reading Room No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Internet - DOE Legacy Management 

Considered Sites

No relevant data identified. 07/12/2019 0

Internet - DOE National Nuclear Security 

Administration (NNSA) - Nevada Site 

Office

No relevant data identified. 01/17/2020 0

Internet - DOE Noncompliance Tracking 

System (NTS)

May 18, 1979 remediation completion predates NTS. 01/17/2020 0

Internet - DOE Occurrence Reporting 

Processing System (ORPS)

May 18, 1979 remediation completion predates ORPS. 01/17/2020 0

Internet - DOE OpenNet No relevant data identified. 07/22/2019 0
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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into SRDB

Internet - DOE OSTI No relevant data identified. 07/12/2019 0

Internet - DOE OSTI Information Bridge Former worker medical screening program 2010 annual report. 03/27/2012 1

Internet - Energy Employees Claimant 

Assistance Project (EECAP)

No relevant data identified. 01/17/2020 0

Internet - Google Federal Register notices concerning the Reduction Pilot Plant, The Traveler's Guide to Nuclear Weapons, 

EEOICPA bulletins, news stories, Advisory Board on Radiation and Worker Health meeting minutes, 

nuclear weapons production history, a nickel carcinogenesis report, specification for demolition and 

removal, a site exposure matrix review, a meeting between NIOSH and SC&A, SC&A reviews of the 

Reduction Pilot Plant Site Profile and NIOSH Program Evaluation Reports, denial of DOE request to 

permit salvaging of contaminated smelt alloys, site and company histories, and minutes of the 130th 

meeting of the Advisory Board on Radiation and Worker Health. 

12/19/2019 34

Internet - HathiTrust No relevant Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Internet - Health Physics Journal No relevant data identified. 01/17/2020 0

Internet - Journal of Occupational and

Environmental Hygiene

No relevant data identified. 01/17/2020 0

Internet - National Academies Press (NAP) No relevant data identified. 07/12/2020 0

Internet - National Institute for 

Occupational Safety and Health (NIOSH)

Reduction Pilot Plant Technical Basis Document. 11/30/2018 1

Internet - National Service Center for 

Environmental Publications (NSCEP), US 

EPA

No relevant data identified. 07/12/2019 0

Internet - NRC Agencywide Document 

Access and Management (ADAMS) 

Mention of the Reduction Pilot Plant in a petitioner's motion to transfer rulemaking proceedings to a 

District Court, and an NRC response to a Freedom of Information Act request.

09/28/2017 2

Internet - US Army Corps of Engineers 

(USACE)

No relevant data identified. 07/12/2019 0

Internet - US Transuranium and Uranium 

Registries

No relevant data identified. 07/12/2019 0

Lawrence Berkeley National Laboratory No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Lawrence Livermore National Laboratory No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0
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Data Capture Information Data Capture Description Date 

Completed

No. 

Uploaded 

into SRDB

Los Alamos National Laboratory No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Mound Museum No Reduction Pilot Plant documents identified in the MLM index. 03/09/2020 0

National Archives and Records 

Administration (NARA) - Atlanta

No relevant Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

National Archives and Records 

Administration (NARA) - Chicago

No Reduction Pilot Plant documents identified in the finding aid. 03/06/2020 0

National Archives and Records 

Administration (NARA) - College Park

Layout of the plant, studies of radiation hazards, fire protection surveys, trip reports, meetings with INCO 

personnel, contract documents, procurement of xenon probes, construction photographs, determination of 

nickel in urine, uranium urinalysis, plant expansion and upgrade plans, required security safeguards for 

plant expansion, and requests for approvals for plant modifications.

11/15/2005 41

National Archives and Records 

Administration (NARA) - Kansas City

The 1973 report on decontamination and decommissioning of facilities. 11/10/2004 1

National Archives and Records 

Administration (NARA) - Seattle

No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

National Institute for Occupational Safety 

and Health (NIOSH)

Specifications for nickel-containing barrier material, metallic nickel specifications, security of shipments, 

classification changes of material, estimates for an updated gamma alarm system, equipment and systems 

replacements, worker outreach meeting confirmation letters, sign-in sheets, annual reports to congress, and 

the updated EEOICPA listing for the plant.

05/04/2015 25

Nevada Test Site No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

Nuclear Regulatory Commission NonPublic HoldingsNo relevant data identified. 03/10/2020 0

Nuclear Regulatory Commission Public 

Document Room

A list of facilities that processed radioactive materials. 06/07/2007 1

Oak Ridge Library for Dose 

Reconstruction

An Oak Ridge Gaseous Diffusion Plant quarterly report for 10/01/1959 through 12/31/1959. 04/06/2011 1

Oak Ridge National Laboratory (ORNL) No relevant Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0

ORAU Team Technical basis documents and revisions, the RPP project spreadsheet communications with UF6 chemistry 

subject matter experts, a NIOSH program evaluation report, the Jessop Steel site profile mentioning the 

RPP, and guidance for assigning occupational x-ray dose.

06/16/2017 11

Paducah Gaseous Diffusion Plant Health physics and hygiene inspection reports 1959-1961. 09/13/2006 1
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Data Capture Information Data Capture Description Date 

Completed 

No. 

Uploaded 

into SRDB

Pantex No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

Radiation Exposure Information and 

Reporting System (REIRS)

No exposure records for RPP, International Nickel, or Cleveland Wrecking were located. 01/22/2020 0 

Radiation Exposure Monitoring System 

(REMS)

No exposure records for RPP, International Nickel, or Cleveland Wrecking were located. 01/22/2020 0 

Reactive Metals, Inc. No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

S. Cohen & Associates (SC&A) Audit of a Reduction Pilot Plant claim under EEOICPA. 04/04/2007 1 

Sandia National Laboratory - Albuquerque, 

New Mexico

No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

Santa Susana Field Laboratory No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

Savannah River Site No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

University of Rochester No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

University of Tennessee No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

Unknown Radiological assessments of the Reduction Pilot Plant including biological effects of nickel contamination. 09/11/2002 1 

West Valley Demonstration Project 

(WVDP)

No Reduction Pilot Plant documents identified in the finding aid. 03/09/2020 0 

TOTAL N/A N/A 278
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Table A1-2: Internet Database Searches for the RPP Site

Database/Source Keywords No. of Hits

No. 

Uploaded 

into SRDB

Defense Technical Information Center (DTIC)

COMPLETED 01/17/2020

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

111,335 0 

DOE Hanford Declassified Document Retrieval 

System (DDRS) and Public Reading Room

COMPLETED 07/12/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

0 0 

DOE Legacy Management Considered Sites

COMPLETED 07/12/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

3 3 

DOE National Nuclear Security Administration 

(NNSA) - Nevada Site Office

COMPLETED 01/17/2020

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

76,694 0 

DOE OpenNet

COMPLETED 07/22/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

12,111 0 

DOE Office of Scientific and Technical 

Information

COMPLETED 07/12/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

26 0 

Energy Employees Claimant Assistance Project 

(EECAP)

COMPLETED 01/17/2020

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

14 0 

Google

COMPLETED 07/24/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

495,641 22

Health Physics Journal

COMPLETED 01/17/2020

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

30 0 

Journal of Occupational and Environmental 

Health (Taylor Francis Group)

COMPLETED 01/17/2020

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

58 0 

National Academies Press

COMPLETED 07/12/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

6,947 0 
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Database/Source Keywords No. of Hits

No. 

Uploaded 

into SRDB

National Service Center for Environmental 

Publications (NSCEP)

COMPLETED 07/12/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

16,710 0 

NRC ADAMS Reading Room

COMPLETED 07/12/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

7 1 

United States Army Corps of Engineers 

(USACE)

COMPLETED 07/12/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

0 0 

U.S. Transuranium & Uranium Registries 

COMPLETED 07/12/2019

Database search terms and Internet URL are available in the Excel file called “Reduction Pilot Plant 

Rev 00 (83.13) 03-11-20.”

0 0