Los Alamos National Laboratory

(SEC-00109)

LaVon B. Rutherford, CHP

Special Exposure Cohort Health Physics Team Leader

Division of Compensation Analysis and Support

Advisory Board on Radiation and Worker Health (ABRWH)

Santa Fe, New Mexico 

November 30, 2016

Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health
Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

Petition timeline

Special Exposure Cohort (SEC) petition received April 3, 2008

Qualified for evaluation May 29, 2008

NIOSH evaluated “All service support workers from January 1, 1976 

through December 31, 2005”

Evaluation Report (ER) actions

 Revision 0 approved January 1, 2009

 Revision 1 approved August 15, 2012
Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

Resulting action

The Secretary of the Department of Health and Human Services 

(DHHS) added the following class to the Special Exposure Cohort (SEC)

“All employees of the Department of Energy, its predecessor 

agencies, and their contractors and subcontractors who worked at 

the Los Alamos National Laboratory (LANL) in Los Alamos, New 

Mexico from January 1, 1976, through December 31, 1995, for a 

number of work days aggregating at least 250 work days, occurring 

either solely under this employment or in combination with work 

days within the parameters established for one or more other 

classes of employees in the Special Exposure Cohort.”
Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

1975 through 1995 SEC class bases

 Identified infeasibility included the inability to bound unmonitored

intakes of exotic alpha emitters, fission products, activation products,

tritium (STCs), Sr/Y-90, Th-230 and Th-232

 End date of December 31, 1995, for the class based on the

presumption that LANL would have been in full compliance with 10

CFR 835, Occupational Radiation Protection at the time

NIOSH committed to evaluate post-1995 issues
Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

Occupational Radiation Protection1

 Requires internal dosimetry programs (including routine bioassay

programs) for Radiological workers who, under typical conditions, are

likely to receive a committed effective dose equivalent of 0.1 rem

(0.001 Sv) or more from all occupational radionuclide intakes in a year

 Given this requirement, in the absence of individual internal

dosimetry data, intakes would be unlikely to have resulted in greater

than 0.1 rem CEDE and the infeasibility to reconstruct dose would not

exist

1 10 CFR 835
Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

Progress reports on ER Addendum

 Since ER Rev. 1, NIOSH received more information, documents, and 

procedures about the post-1995 use of exotic radionuclides

 Work with these radionuclides (especially after 1995) has been 

sporadic and there are correspondingly few bioassay data

1 10 CFR 835
Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

Progress report on ER addendum – cont.

 NIOSH, Sanford Cohen & and Associates, and the Oak Ridge

Associated University Team went to LANL in November 2015

 Met LANL Health Physics (HP), including Managers, Dosimetrists, and

field personnel to better understand how compliance with

Occupational Radiation Protection under 10 CFR 835 was achieved

 New documents were captured including RWPs, respirator use, air

sampling, radiation surveys, HP checklists, routine monitoring

instructions, and external exposure data
 

Progress report on ER addendum – cont.
 

 During November 2015 site visit, LANL provided information and 

documents specific to 

• Special Tritium Compounds 

• 10 CFR 835 RPP 

• And their Dosimetry Matrices program 

 Spring 2016 NIOSH began considering the dose reconstruction 

implications of compliance with 10 CFR 835 for unmonitored workers 

 Unlikely to have received exposures exceeding 40 DAC-hrs per year 

Department of Health and Human Services 

Centers for Disease Control and Prevention 

National Institute for Occupational Safety and Health 
Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

Progress report on ER addendum – cont.

 NIOSH is reviewing compliance with 10 CFR 835

• Review assessments – focusing on findings, response, and 

corrective action

• Review Nonconformance Tracking System (NTS) for 10 CFR 835 

violations, site response, and corrective action

• Review Occurrence Reporting System (ORPS)
Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

Progress report on ER addendum – cont.

Questions when Reviewing Findings

1) (SEC Perspective) Do the findings identify unmonitored exposures 

that may prevent reconstructing exposures to a defined class of 

workers?

2) (DR Perspective) Do the findings identify a programmatic flaw 

that would suggest the unmonitored workers could have received 

exposures in excess of 40 DAC-hrs per year?
Department of Health and Human Services

Centers for Disease Control and Prevention

National Institute for Occupational Safety and Health

Path forward for addendum

 NIOSH has reviewed available assessments

 Recently NIOSH, SC&A, and ORAUT gained access to the NTS system

LANL – nonconformance reports have been reviewed and selected by 

NIOSH/ORAUT team. They are being downloaded and loaded to the SRDB

 DOE is working on access to ORPS

 After review of all the assessments and reports the addendum can be 

completed

 The current project schedule has the Addendum being completed by 

late February 2017