NIOSH and SC&A Reviews of Issues with 

SEC-00109 LANL Addendum

LaVon B. Rutherford, CHP

Joseph E. Fitzgerald, SC&A

Advisory Board on Radiation and Worker Health Meeting

December 12-13, 2018
Chronology

 NIOSH issued Addendum to SEC-00109 petition evaluation addressing 

1996-2011: April 24, 2017 (Class evaluated: all Service Support 

Workers for January 1, 1976 through December 31,2005) 

 SC&A was tasked with reviewing the NIOSH addendum: May 4, 2017

 SC&A issued their review of the NIOSH Addendum: July 27, 2017

 LANL work group meeting on Aug 15, 2017, followed by presentations 

by NIOSH and SC&A at Board meeting in Santa Fe, NM, on Aug 24, 2017

 NIOSH issued its response to SC&A’s review: Sept 12, 2018

 SC&A issued its response to NIOSH’s response: Nov 16, 2018

 LANL work group meeting on Nov 29, 2018
SEC-00109 Evaluation Report Addendum

 End date of December 31, 1995, for SEC-00109 class is based on the 

presumption that LANL would have been in full compliance with 10 CFR Part 

835, “Occupational Radiation Protection,” by then. 

 With full compliance, NIOSH assumes that all DOE work sites, including 

LANL, would have satisfied the monitoring requirements contained in the rule, 

thereby resolving any limitations that make dose reconstruction infeasible 

prior to that date.

 For LANL, these limitations included the “inability to bound unmonitored 

intakes of exotic alpha-emitters, fission products, and activation products.”
Summary of NIOSH and SC&A Review 

 SC&A concluded program compliance with 10 CFR 835, while necessary under 

DOE’s regulatory framework, is not sufficient for demonstrating that actual 

radiation program practice is adequate for 1996-2005 SEC evaluation years.

 NIOSH concurs that 10 CFR Part 835 “presumptive” compliance not sufficient to 

demonstrate implementation of 100 mrem/year CEDE, but additional analyses 

support weight-of-evidence conclusion that it is bounding of internal intakes.

 NIOSH finds other bases upon which bounding assumption of 100 mrem/year 

CEDE can be assumed:

 Field monitoring and contamination control programs “well-established and formalized 

by January 1, 1996” and “intended to ensure that unmonitored individuals were unlikely to 

receive intakes of 100 mrem CEDE.” 

 Bioassay data for primary radionuclides demonstrate ER Addendum intake rates are 

bounding at 2% SALI (100 mrem CEDE); “no reason to believe that intakes of exotic 

radionuclides by unmonitored workers would be substantially different.”

 NIOSH believes 10 CFR Part 835 era represents “paradigm shift in DOE operations”
Technical capabilities to monitor for MFAP

 NIOSH and SC&A agree that germanium detectors in wide use at LANL 

since 1970s and over 7,000 MFAP in-vivo records exist for LANSCE 

workers; however, SC&A emphasizes LANL did not focus on exotic 

radionuclides and bioassay data remain inadequate for coworker 

modeling after 1995.

 SC&A agrees with NIOSH that work with (and potential exposure to) 

exotics at LANL had become increasingly sporadic in 1990s

 Using gaseous MAPs from LANSCE as illustrative marker, SC&A found 

average occupational doses to have declined to well under 100 

mrem/year by mid-1990s; could NIOSH demonstrate maximum worker 

exposures to relevant exotics had likewise declined to below 100 mrem

CEDE/year after 1995?
NIOSH additional “weight-of-evidence”: LANL field 

monitoring program

Health Physics field monitoring and contamination control program: 

 Over 60 procedures addressing radiological protection – Covering 

program administration, exposure and contamination control, 

monitoring, instrumentation, protective equipment, emergency 

response, and the As Low As Reasonably Achievable (ALARA) 

program. 

 Additionally area-specific procedures and instructions existed 
LANL field monitoring program (cont’d)

 NIOSH has captured a number of field monitoring data at LANL for 

the period under evaluation including: 

– Radiological Work Permits (RWP) 

– Monthly/Quarterly Contamination Surveys 

– Area-specific contamination surveys 

– Area-specific monitoring data quarterly reviews 

– Air sample analysis data 

– Air sampling/monitoring technical evaluations 

– Airborne radioactivity investigation reports
LANL field monitoring program (cont’d)

 NIOSH attempted to review work controls established by reviewing 

RWP 

 During NIOSH’s multiple data captures, NIOSH found many boxes of 

LANL RWPs 

 NIOSH did not capture all but what we feel is a representative sample 

(several hundred) 

 NIOSH focused on finding RWPs that involved non-routine radionuclides 

 Many RWPs for common radionuclides were also collected
SC&A response to NIOSH position on LANL field 

monitoring program 

 Whether field monitoring and contamination control programs “wellestablished and formalized” belies whether they were adequately 

carried out by LANL personnel in practice.

 LANL’s self-assessment of bioassay program in 1999 found significant 

deficiencies, including those impacting LANL’s ability to monitor 

workers likely to receive 100 mrem CEDE/year – only in-depth 

validation of LANL practice during late 1990s.

 Findings that workers not providing RWP-required bioassays, and 

CTWs not being enrolled in bioassay program, raise concern over data 

adequacy and completeness for 1996–2000.

 NIOSH’s reference to “hundreds of radiological documents” points to a 

functional bioassay program, not necessarily one being adequately 

carried out “on the ground.”
NIOSH additional “weight-of-evidence:” Comparison of Monitored 

Worker Dose to 100 mrem CEDE

 LANL noted that its internal dosimetry monitoring programs are 

established on an as-needed basis and monitoring is only required for 

radiological workers likely to receive 100 mrem annually from internal 

exposure 

 LANL further notes: 

 LANL has in in-vivo monitoring program established for fission and 

activation products, and has historically used in vivo monitoring for these 

radionuclides. A spectral analysis of each count was performed by the in 

vivo staff. During this review, all peaks were identified and quantified
Comparison of Monitored Worker Dose to 100 mrem

CEDE (cont’d) 

 NIOSH reviewed the LANL Bioassay Repository Database (ORAUTOTIB-0063). The database includes 106,950 in-vivo records 

 Pu-239 and Am-241 make up 82% of the records 

 U-234 and Th-234 make up 10% of the records 

 Bulk of the remaining 7000+ records is primarily comprised of 

fission and activation product radionuclides for LANSCE employees 

that were acquired via germanium detectors
Comparison of Monitored Worker Dose to 100 mrem

CEDE (cont’d) 

Primary Radionuclides (Tritium, Plutonium, and Uranium) 

 There are over 450,000 LANL urinalysis records for 1945 through 2008 

 As previously mentioned there are over 100,000 in-vivo records 

 The data are presented and evaluated in the Internal Dosimetry 

Coworker Data for LANL(ORAUT-OTIB-0062) 

 Tables 5-1 through 5-7 of the white paper are tables taken from OTIB0062. They show for the primary radionuclides: 

 Dose for monitored workers generally goes down over time 

 Dose for monitored workers are less than 100 mrem CEDE with one 

exception
SC&A response to NIOSH Position that Intakes Can Be 

Bounded by 100 mrem/yr CEDE

 Finds no substantiation for NIOSH’s belief regarding exotic 

radionuclides; 100 mrem/year CEDE bounding for primary 

radionuclides. 

 Notes that Work Group and NIOSH agree that bioassay results for 

primary radionuclides should not be used to compare or bound 

intakes of exotics.

 Does not agree with NIOSH apparent support of LANL’s contention 

that bioassay data for exotics scarce because workers not required to 

be monitored for them; exotics monitoring was not focus.

 Bounding dose assessment lacking for exotics (LANL or NIOSH); 

long-established precedent at other EEOICPA sites for dose 

modeling based on source term or air sampling results.
A Perspective: Gaseous Mixed Activation Products 

(G/MAPs) from LANSCE and Dose Assessment

 SC&A agrees with NIOSH statement that work with (and potential exposures 

to) exotics at LANL had become increasingly sporadic, particularly after 1995.

 LANSCE/LAMPF was dominant source of airborne radionuclides at LANL from 

late 1970s to 1990s (site description TBD, 2004). Represents one key source of 

potential unmonitored G/MAPs exposure. 

 However, LANSCE airborne emissions and related estimated site boundary 

doses have steadily declined since mid-1980s to almost negligible by 1999.

 Gaussian-based dispersion modeling of occupational exposure from G/MAPs 

from LANSCE show average whole-body dose range of 0.3 to 20 mrem/year 

during 1996–2000 period (occupational environmental dose TBD, 2010).

 Decline of LANSCE emissions and corresponding estimated average worker 

whole-body dose by 1996 is significant – can maximum worker exposures be 

similarly characterized for exotics based on available source term and 

monitoring data?
Annual LANSCE Radionuclide (G/MAPs) Emissions and 

Offsite MEI, 1990–2002 (adapted from LANL 2003, 2018)
Average Occupational External Doses 

from G/MAPs released from LANSCE 

(mrem/yr) 

(excerpt from occupational env. TBD, 2010, Table 4-29)

Year Skin (mrem) Whole Body 

(mrem)

1990 190 120

1991 90 57

1992 110 71

1993 51 32

1994 79 49

1995 69 43

1996 17 11

1997 32 20

1998 12 7.7

1999 0.047 0.3

2000 1.1 0.68
Appendix A –LANL Petitioner Issues and Resolutions 

 A number of issues have been identified by the petitioner over the 

course of several years 

 The petitioner has provided a vast amount of supporting documents in 

support including: – Petition with 102 page written narrative – CD with 

a number of documents 

 The petitioner has also been very active in Advisory Board meetings 

and work group meeting 

 Appendix A identifies the petitioner issues and provides NIOSH’s 

response to those issues

 Beyond outstanding 10 CFR 835 implementation issues referenced as 

SC&A issues, SC&A had one clarifying comment re Issue #55 (status of 

MAPs dose estimation from LANSCE)
NIOSH Conclusion

 The field monitoring and contamination control programs at LANL 

were well-established and formalized by January 1, 1996 to ensure areas 

where workers were likely to exceed 100 mrem CEDE were well 

identified and controlled

 Based on review of existing bioassay results, workers monitored for the 

primary radionuclides were unlikely to have received intakes exceeding 

100 mrem CEDE 

 Based on the routine monitoring and contamination control 

established, NIOSH has no reason to believe intakes of exotic 

radionuclides for unmonitored workers would be different
SC&A Conclusions

 Lack of substantiation that 100 mrem/year CEDE bounds unmonitored 

intakes of exotics after 1995; available evidence supports only primary 

radionuclides

 Lack of follow-up to establish whether 1999 LANL findings regarding 

bioassay program deficiencies demonstrate data inadequacy and 

incompleteness significant enough to impair dose reconstruction 

 DOE enforcement moratorium in 1998 underscores “commonality” of 

serious bioassay program deficiencies across DOE sites despite 

implementation of 10 CFR Part 835 almost 3 years before; uniform site 

implementation of 100 mrem/year CEDE as basis for compliant 

bioassay monitoring should not be assumed
NIOSH Actions

 NIOSH will respond to the 1999 LANL program self-assessment 

NIOSH plans to issue a white paper that will:

 Identify the findings of the assessment

 Provide the background information driving the finding

 Corrective actions taken by the site

 How the findings affect NIOSH’s ability to reconstruct dose

 Expected Completion: March 2019

 NIOSH will draft a plan and schedule for addressing how they will 

reconstruct dose for mixed fission and activation products and other 

exotics at LANL

 Expected Completion: March 2019