National Institute for Occupational Safety and Health

Sandia National Laboratories - Albuquerque

SEC-00188 Addendum

Charles Nelson

Health Physicist

Advisory Board on Radiation and Worker Health (ABRWH) Work Group Meeting 

August 13, 2018
Summary of SEC-00188 Petition History

 Petition qualified (83.13) for evaluation: October 21, 2011

 Petitioner proposed class definition:

All Security Inspectors, Security Clerks, Firemen, Non-regular Recurrent Security 

Inspectors, Security Officers, Security Police Officers I, Security Police Officers II, 

Security Police Officers III, and Central Alarm System Operators that worked in 

any area at SNL-A for the period from January 1, 1963 through May 21, 2011

 NIOSH proposed the following class to be added to the SEC on February 21, 2012:

All personnel that worked in any area at Sandia National Laboratories in 

Albuquerque, New Mexico for the period from January 1, 1949 through 

December 31, 1994
Basis for 1949-1994 SEC Class

 Insufficient monitoring data and information to reconstruct internal 

dose from January 1, 1949 through December 31, 1994:

– Lack of internal monitoring program documentation

– Lack of internal monitoring data

– Lack of process information 

 External doses, including medical X-rays performed onsite as a 

condition of employment can be reconstructed
SEC-00188 Addendum

NIOSH committed to continue to evaluate and determine 

monitoring program completeness, sufficiency, and 

appropriateness for the entire SNL-A worker population for the 

January 1, 1995 through May 21, 2011 time period and 

document the results in an addendum
Data Sources Reviewed

 17 interviews with 15 people

 7 site data capture efforts since last SEC designation 

 Over 800 relevant documents captured and reviewed since last SEC designation (over 5,400 

total documents):

– Internal memos

– Radiation work permits

– Radiological surveys

– Incident reports

– Air monitoring data

– Internal dosimetry records

– Breathing Zone (BZ) monitoring

– Derived Air Concentration (DAC)-hour tracking
Data Sources Reviewed, cont.

 Fitness of monitoring program, data collection and availability, and 

program compliance

 Noncompliance Tracking System (NTS), site response, and corrective 

actions

 Occurrence Reporting and Processing System (ORPS)

 Internal assessments and procedures
NIOSH Proposed Class Extension

All employees that worked in any area at Sandia National Laboratories in 

Albuquerque, New Mexico, during the period from January 1, 1995 through 

December 31, 1996
Basis for Proposed Class Extension

 Internal monitoring program concerns

 Air monitoring data deficiencies
Internal Monitoring Program Development

 Internal monitoring had been performed on an ad hoc basis at SNL-A for 

decades prior

 Formalization of the internal monitoring program didn’t begin until 1993

 First Interim Internal Dosimetry Policy established December 1993

 Internal Dosimetry Program was undergoing continual development and 

improvements

 In 1995 -1996 work included monitoring approach changes, procedure 

development, and data collection, review and retention formalization
Internal Monitoring Program Concerns

 Documented program assessments, internal memos, and interviews 

conducted by NIOSH with SNL-A employees revealed:

– Insufficient staffing levels to meet program developmental tasks

– Lack of a fully functional internal monitoring database for efficient and 

reliable record entry, retention, and retrieval (WebDose)

• Internal Dosimetry manager stated in an internal memo and 

during an interview that there were data entry errors due to hand 

entry and a lack of adequate personnel to enter the data into the 

database
Air Monitoring Data Availability

 Internal monitoring program was transitioning from bioassay to the use 

of personal and area air monitoring 

 Available air monitoring data for the 1995-1996 period is limited to 

hard copy records that NIOSH retrieved during data capture 

 During 1995-1996 period, procedural requirements for air sampling 

records review and retention appear to have been minimal

 Personal air samples and DAC-hour results were not required to be 

routed to Internal Dosimetry for review until June 1996
Air Monitoring Data Availability, cont.

 Evidence of Individual DAC-hour tracking and accrual records are not 

available for 1995-1996

– Not procedurally required until 1997

 Personal air monitoring data is not stored in the site’s electronic 

monitoring records database (WebDose) for these years
Conclusions for 1995-1996 Dose Reconstruction 

Feasibility

 Uncertainties and concerns associated with the transitional and 

developmental nature of SNL-A’s internal monitoring program exist in 

1995 & 1996

 The site was making several improvements in the internal monitoring 

program including an increase in the use of personal and area air 

monitoring

– However, the program seemed to lack formalization in that NIOSH did 

not find adequate evidence that some key implementing procedures 

were fully in place until 1996 & 1997
Conclusions for 1995-1996 Dose Reconstruction 

Feasibility, cont.

 Air monitoring data are judged insufficient due to a lack of required, 

record retention and review procedures during January 1, 1995 through 

December 31, 1996 period

 There was a lack of a fully functional internal monitoring database for 

efficient and reliable record entry, retention, and retrieval (WebDose)

 Based on this lack of data availability and internal monitoring program 

concerns, NIOSH has determine that dose reconstruction for internal 

doses at SNL-A for the 1995-1996 period is not feasible
Claims Affected by Proposed Class Extension

 243 total claims for workers with employment in 1995 through 1996

 5 claims have internal dosimetry data

 95 claims have external dosimetry data
Feasibility Findings

SEC-00188, Addendum

(January 1, 1995 – December 31, 1996)

Source of Exposure Dose Reconstruction is

Feasible

Dose Reconstruction not

Feasible

Internal

- all radionuclides X

External

- Beta-Gamma X

- Neutron X

- Occupational Medical X-ray X
Summary of SEC-00188 Proposed Class Extension

NIOSH has determined that workplace monitoring data and documentation 

are insufficient to reconstruct internal doses from January 1, 1995 through 

December 31, 1996

NIOSH Proposed Class Extension

All employees that worked in any area at Sandia National Laboratories in 

Albuquerque, New Mexico, during the period from January 1, 1995 through 

December 31, 1996
Partial Dose Reconstructions

Although NIOSH found that it is not possible to reconstruct internal radiation 

doses for the period from January 1, 1995 to December 31, 1996, NIOSH 

intends to use any internal monitoring data that may become available for an 

individual claim
Continued SEC-00188 Analysis (1997 – 2011)

Evaluate and determine monitoring program completeness, sufficiency, and 

appropriateness for the entire SNL-A worker population for the 1997 through 

May 21, 2011 time period

 Recently identified issues in SNL-A’s monitoring records database 

(WebDose) prevent NIOSH from presenting feasibility conclusions for the 

period from January 1, 1997 through May 21, 2011, within this Addendum 

 NIOSH is analyzing an updated version of WebDose that was delivered in 

May 2018
Continued SEC-00188 Analysis (1997 – 2011), cont.

 NIOSH’s analysis is ongoing and necessary to accurately assess and present 

internal monitoring data availability and sufficiency for the remaining time 

period

 NIOSH expects to be done with the Evaluation Report addendum by the 

end of 2018