Page 1 of 51

DOE Review Release 12/27/2021

Assessment of Los Alamos National 

Laboratory Plutonium Bioassay Programs 

1996 to 2001

ORAUT-RPRT-0102 Rev. 00

Effective Date: 12/02/2021

Supersedes: None

Subject Expert(s): Thomas R. LaBone, Nancy M. Chalmers, and Elizabeth M. Brackett

Document Owner 

Approval: Signature on File

Thomas R. LaBone, Document Owner

Approval Date: 11/01/2021

Concurrence: Signature on File

Pat McCloskey, Objective 4 Manager

Concurrence Date: 10/28/2021

Concurrence: Vickie S. Short Signature on File for

Kate Kimpan, Project Director

Concurrence Date: 11/01/2021

Approval: Signature on File

Timothy D. Taulbee, Associate Director for Science

Approval Date: 12/02/2021

FOR DOCUMENTS MARKED AS A TOTAL REWRITE, REVISION, OR PAGE CHANGE, REPLACE THE PRIOR 

REVISION AND DISCARD / DESTROY ALL COPIES OF THE PRIOR REVISION.

New Total Rewrite Revision Page Change
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 2 of 51

PUBLICATION RECORD

EFFECTIVE 

DATE

REVISION 

NUMBER DESCRIPTION

12/02/2021 00 New report to assess the adequacy of Los Alamos National 

Laboratory bioassay results for the construction of a 

co-exposure model. Incorporates formal internal and NIOSH review 

comments. Training not required. Initiated by Michael S. Kubiak and 

authored by Thomas R. LaBone.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 3 of 51

TABLE OF CONTENTS

SECTION TITLE PAGE

Acronyms and Abbreviations ............................................................................................................... 6

1.0 Introduction .............................................................................................................................. 7

2.0 Co-Exposure Models................................................................................................................ 7

3.0 Study Design............................................................................................................................ 9

4.0 Regulatory Compliance Versus Co-Exposure Modeling ......................................................... 10

5.0 Description of Study............................................................................................................... 11

5.1 Health Physics Checklist Dataset ............................................................................... 11

5.2 Bioassay Enrollment, Scheduling, and Tracking Dataset............................................ 12

5.3 In Vitro Bioassay Dataset ........................................................................................... 13

5.4 In Vivo Bioassay Dataset............................................................................................ 14

5.5 External Dose Dataset................................................................................................ 15

5.6 Radiological Work Permits Dataset ............................................................................ 15

5.6.1 Summary of Radiological Work Permits by Technical Area .......................... 16

6.0 Analysis of Data ..................................................................................................................... 17

7.0 Comparison of Bioassay Enrollment, Scheduling, and Tracking and the In Vitro Dataset....... 18

8.0 Definition of Groups ............................................................................................................... 22

9.0 Comparison of Health Physics Checklist and Bioassay Enrollment, Scheduling, and 

Tracking................................................................................................................................. 22

10.0 Compliance with Radiological Work Permit Monitoring Requirements.................................... 23

11.0 Plutonium Results for Johnson Controls, Environmental Safety and Health, Nuclear 

Materials Technology, and Other ........................................................................................... 27

12.0 Summary and Conclusions .................................................................................................... 29

References ........................................................................................................................................ 30

ATTACHMENT A DATA FOR BAR CHARTS.............................................................................. 32

ATTACHMENT B GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK 

PERMITS........................................................................................................ 35
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LIST OF TABLES

TABLE TITLE PAGE

5-1 RWPs issued by TA and the year in which the RWP expired ................................................. 17

7-1 Reasons for sample kits requested through BEST not being submitted ................................. 19

7-2 Requests for in vitro samples for plutonium analysis by company.......................................... 20

10-1 Summary of statistics for monitoring of RWP work................................................................. 26

A-1 Data for Figure 5-1, HPCs submitted per year that were adds for plutonium during the 

study period ...........................................................................................................................33

A-2 Data for Figure 5-2, Sample requests in BEST for plutonium analysis per year...................... 33

A-3 Data for Figure 5-3, Plutonium in vitro bioassay samples submitted by workers in each 

year of the study ....................................................................................................................33

A-4 Data for Figure 5-4, Plutonium/americium chest counts performed and workers in each 

year of the study ....................................................................................................................33

A-5 Data for Figure 7-1, Plutonium samples requested through BEST and received for all 

workers ..................................................................................................................................33

A-6 Data for Figure 7-2, Samples requested from JC workers through BEST that were 

received and analyzed for plutonium...................................................................................... 33

A-7 Data for Figure 7-3, Samples requested from KSL workers through BEST that were 

received and analyzed for plutonium...................................................................................... 33

A-8 Data for Figure 7-4, Samples requested from LANL workers through BEST that were 

received and analyzed for plutonium...................................................................................... 33

A-9 Data for Figure 9-1, HPC adds per group............................................................................... 34

A-10 Data for Figure 10-1, Plutonium samples from workers who signed an acknowledgment 

sheet on an RWP that had a PAL requirement....................................................................... 34

A-11 Data for Figure 10-2, Workers in each of the groups who signed RWP acknowledgment 

forms in each year..................................................................................................................34

A-12 Data for Figure 10-3, RWP acknowledgments signed by workers in each group by year ....... 34

A-13 Data for Figure 10-4, Histogram of the frequencies of workgroup monitoring percentages 

for 2,252 RWPs......................................................................................................................34

B-1 Data for Figure B-1, Work performed by JC that was properly monitored (Sampled).............. 36

B-2 Data for Figure B-2, JC workers who were properly monitored (Sampled) ............................. 37

B-3 Data for Figure B-3, Work performed by Other that was properly monitored (Sampled)......... 38

B-4 Data for Figure B-4, Other workers who were properly monitored (Sampled)......................... 39

B-5 Data for Figure B-5, Work performed by ESH that was properly monitored (Sampled)........... 40

B-6 Data for Figure B-6, ESH workers who were properly monitored (Sampled) .......................... 41

B-7 Data for Figure B-7, Work performed by NMT that was properly monitored (Sampled) .......... 42

B-8 Data for Figure B-8, NMT workers who were properly monitored (Sampled).......................... 43

B-9 Data for Figure B-9, Work performed by JC that was properly monitored (Sampled).............. 44

B-10 Data for Figure B-10, JC workers who were properly monitored during the study period 

(Sampled) ..............................................................................................................................45

B-11 Data for Figure B-11, Work performed by Other that was properly monitored (Sampled)....... 46

B-12 Data for Figure B-12, Other workers who were properly monitored (Sampled)....................... 47

B-13 Data for Figure B-13, Work performed by ESH that was properly monitored (Sampled)......... 48

B-14 Data for Figure B-14, ESH workers who were properly monitored (Sampled) ........................ 49

B-15 Data for Figure B-15, Work performed by NMT that was properly monitored (Sampled) ........ 50

B-16 Data for Figure B-16, NMT workers who were properly monitored (Sampled)........................ 51
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LIST OF FIGURES

FIGURE TITLE PAGE

2-1 Co-exposure models where the study population is used directly and where it is sampled....... 8

5-1 HPCs submitted per year that were adds for plutonium.......................................................... 12

5-2 Sample requests in BEST for plutonium analysis per year ..................................................... 13

5-3 Plutonium in vitro bioassay samples submitted by workers in each year of the study............. 14

5-4 Plutonium/americium chest counts performed and the number of workers in each year of 

the study ................................................................................................................................15

6-1 Relationship between datasets analyzed in this report ........................................................... 18

7-1 Plutonium samples requested through BEST and received for all workers............................. 19

7-2 Samples requested from JC workers through BEST that were received and analyzed for 

plutonium ...............................................................................................................................20

7-3 Samples requested from KSL workers through BEST that were received and analyzed 

for plutonium ..........................................................................................................................21

7-4 Samples requested from LANL workers through BEST that were received and analyzed 

for plutonium ..........................................................................................................................21

9-1 HPC adds per group ..............................................................................................................23

10-1 Plutonium samples from workers who signed an acknowledgment sheet on an RWP that 

had a PAL requirement .......................................................................................................... 24

10-2 Workers in each of the groups who signed RWP acknowledgment forms in each year.......... 25

10-3 RWP acknowledgments signed by workers in each group by year......................................... 25

10-4 Histogram of the frequencies of workgroup monitoring percentages for 2,252 RWPs ............ 27

11-1 Comparison of 238Pu in the urine of JC, ESH, and NMT workers who submitted samples 

in the study period..................................................................................................................28

11-2 Comparison of 239Pu in the urine of JC, ESH, and NMT workers who submitted samples ...... 28

B-1 Work performed by JC that was properly monitored (Sampled).............................................. 36

B-2 JC workers who were properly monitored (Sampled) ............................................................. 37

B-3 Work performed by Other that was properly monitored (Sampled)......................................... 38

B-4 Other workers who were properly monitored (Sampled)......................................................... 39

B-5 Work performed by ESH that was properly monitored (Sampled)........................................... 40

B-6 ESH workers who were properly monitored (Sampled) .......................................................... 41

B-7 Work performed by NMT that was properly monitored (Sampled) .......................................... 42

B-8 NMT workers who were properly monitored (Sampled).......................................................... 43

B-9 Work performed by JC that was properly monitored (Sampled).............................................. 44

B-10 JC workers who were properly monitored (Sampled) ............................................................. 45

B-11 Work performed by Other that was properly monitored (Sampled)......................................... 46

B-12 Other workers who were properly monitored (Sampled)......................................................... 47

B-13 Work performed by ESH that was properly monitored (Sampled)........................................... 48

B-14 ESH workers who were properly monitored (Sampled) .......................................................... 49

B-15 Work performed by NMT that was properly monitored (Sampled) .......................................... 50

B-16 NMT workers who were properly monitored (Sampled).......................................................... 51
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ACRONYMS AND ABBREVIATIONS 

BEST Bioassay Enrollment, Scheduling, and Tracking

C.F.R. Code of Federal Regulations

DCAS Division of Compensation Analysis and Support

DOE U.S. Department of Energy

DU depleted uranium

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000

ESH Environmental Safety and Health

HPC Health Physics Checklist

JC Johnson Controls

LANL Los Alamos National Laboratory

mrem millirem

NIOSH National Institute for Occupational Safety and Health

NMT Nuclear Materials Technology

ORAU Oak Ridge Associated Universities

ORAUT Oak Ridge Associated Universities Team

PAL plutonium access list

q-q quantile-quantile

RAS radiometric alpha spectrometry

RWP radiological work permit

SRDB Ref ID Site Research Database Reference Identification (number)

TA Technical Area

§ section or sections
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1.0 INTRODUCTION

The 1999 audit of the Los Alamos National Laboratory (LANL) bioassay program listed several 

deficiencies in the bioassay program that were of regulatory significance [Brackett and LaBone 1999, 

p. 4]. Most relevant to this discussion is Finding 1: “Radiation workers are not consistently placed on 

the appropriate routine bioassay program.” This finding was supported by the following observations: 

• Out of [redacted] individuals who signed the acknowledgment sheet for a [redacted] RWP that 

required [redacted] bioassay, [redacted] had not submitted a sample since 1994 and 

[redacted] had never submitted a sample; and

• Johnson Controls workers did not consistently submit HP Checklist forms to enroll in routine 

bioassay programs by admission of Johnson Controls management. 

The findings of this audit prompted the Advisory Board on Radiation Worker Health (ABRWH) to ask 

[SC&A 2017, Board Review System 2019]:

Do the 1999 LANL findings regarding bioassay program deficiencies imply data 

inadequacy and incompleteness significant enough to impair dose reconstruction?

This is a difficult question to answer because it is not clear how to quantify the degree to which a dose 

reconstruction is impaired by bioassay program deficiencies or the point at which it becomes 

excessive. However, we can reply “no” to the question if the bioassay data are adequate for 

development of a co-exposure model because the co-exposure model can be used to perform the 

dose reconstruction for an individual in the absence of bioassay data. Therefore, the question 

becomes, 

Do the indicated bioassay program deficiencies imply data inadequacy and 

incompleteness significant enough to impair development of a co-exposure model?

It is important to note that operational monitoring programs frequently have deficiencies of some sort, 

but the impact of these deficiencies can be difficult to quantify objectively. One might point to 

regulations as defining objective standards for deficiencies, but in Section 4.0 we make the argument 

that our ability to construct a co-exposure model is not directly related to regulatory deficiencies in the 

monitoring program. 

In the absence of objective standards we have taken the approach of assembling data that indicates

who was monitored for plutonium, when they were monitored, and what results were obtained. Then, 

based on decades of collective experience in constructing co-exposure models, we decide if the 

preponderance of evidence supports the conclusion that we can indeed construct a bounding coexposure model. This study design is discussed in more detail in Section 3.0, and the data used are 

described in Section 5.0 along with their summary statistics. Details of the analysis are given in 

Sections 6.0 to 11.0, with final conclusions given in Section 12.0. However, before proceeding it is 

essential to precisely define what a co-exposure model is, how it works, and what conditions would 

lead us to conclude that we cannot construct the model.

2.0 CO-EXPOSURE MODELS

It will be beneficial to describe in detail how co-exposure models work using the terminology of 

epidemiology. The goal of a co-exposure study, as used in the Energy Employees Occupational 

Illness Compensation Program Act (EEOICPA) program, is to estimate the probability distribution of 

external doses or internal intakes to a “target population” [Coggon et al. 2009]. In internal dose coexposure models the target population consists of all workers exposed to a given radioactive material 
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 8 of 51

in a given year during the course of work (Exposed Workers in Figure 2-1). All members of the target 

population who were monitored are referred to as the “study population” (Monitored-Exposed in 

Figure 2-1). The distribution of intakes in the study population is referred to as a “co-exposure model,” 

and it can be used to estimate the distribution of intakes in the target population. The co-exposure 

model is then used to estimate intakes to exposed workers who were unmonitored (UnmonitoredExposed in Figure 2-1). In the event the entire study population is not available, the co-exposure 

model is constructed from the “study sample” (right flowchart in Figure 2-1). Ideally, the study sample 

would be selected from the study population by random sampling, but other methods can be used 

when random sampling is not possible. 

Figure 2-1. Co-exposure models where the study population is used directly (left) and where it is 

sampled (right).

If workers in the target population were monitored at random and the study sample (if used) was 

selected at random, a representative (unbiased) co-exposure model is obtained. If the monitoring of 

the workers in the target population was not random, a bounding (biased high) co-exposure model 

can still be generated if a significant portion of the most highly exposed workers in the target 

population were monitored. It is worth noting that monitoring programs at radiological facilities tend to 

focus on the most highly exposed workers, i.e., random monitoring programs are not used. Such 

programs inherently tend to generate bioassay data that results in biased-high co-exposure models. 

Three conclusions can be drawn:

1. All of the workers in the target population do not have to be monitored to construct a 

co-exposure model (in fact, if all the workers were monitored there would be no need for a 

co-exposure model).

2. If the co-exposure model is generated from the study population, a bounding model can be 

generated as long as a significant portion of the most highly exposed workers in the target 

population are monitored. Note that all of those workers do not need to have been monitored, 

just a significant portion of them.

3. If the co-exposure model is generated from a study sample, a bounding model can be 

generated as long as the previous condition holds and the study sample is not missing a 

significant portion of the most highly exposed workers from the study population.
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In summary, a representative or bounding co-exposure model can be constructed unless a significant 

portion of the most highly exposed workers were not monitored or do not appear in the study sample.

3.0 STUDY DESIGN

How does one demonstrate that an adequate portion of the most highly exposed workers were 

monitored? The program deficiency cited in the 1999 audit that appears to be the primary concern of 

the ABRWH [National Institute for Occupational Safety and Health (NIOSH) 2017, 2019a] is workers 

who were not placed on the appropriate bioassay programs as specified in LANL procedures. 

Bioassay programs for plutonium are specifically addressed because plutonium posed the greatest 

radiological hazard to workers at LANL during the study period (1996 to 2001). Therefore, a focused 

evaluation of the plutonium monitoring program at LANL during the study period provides the best 

picture of the monitoring programs LANL could implement. The ABRWH question can then be stated 

as: 

Were workers who needed to be monitored for plutonium identified and placed on an 

appropriate bioassay program?

Did these workers submit urine samples for analysis in a timely fashion after their work 

with plutonium?

The answers to these questions are important as applied to the most highly exposed plutonium 

workers at LANL because the ABRWH original question can now be expressed in terms of two 

specific questions that can be answered by examining the records of the LANL plutonium monitoring 

program. The period of interest is January 1, 1996, to December 31, 2001 (the study period for this 

document), which runs from the beginning of the 10 Code of Federal Regulations (C.F.R.) Part 835 

era to the implementation of electronic radiological work permits (RWPs) at LANL. 10 C.F.R. 835, 

1993. During the study period, LANL had bioassay monitoring program policies, procedures, 

equipment, and personnel in place to determine exposure potential for workers, enroll them in the 

monitoring program, prepare and analyze the samples, and assess the sample results. Therefore, 

NIOSH presumes LANL had the wherewithal to monitor the most highly exposed plutonium workers 

and, therefore, data would be available from a significant proportion of the most highly exposed 

plutonium workers during the study period. Note that this is only one aspect of “data completeness” as 

discussed in Criteria for the Evaluation and Use of Co-Exposure Datasets [NIOSH 2020], but it is the 

aspect of primary relevance in this discussion.

Therefore, the next step is to analyze all available data in a search for evidence to the contrary (i.e., 

evidence that the plutonium bioassay data cannot be used to create a representative or bounding 

co-exposure model because a significant portion of the most highly exposed workers were not 

monitored). In short, it is not necessary to prove that the bioassay program was adequate; adequacy 

is presumed and evidence that it is inadequate for the construction of a co-exposure model must be 

sought. 

Before proceeding to a more detailed discussion of the study and conclusions drawn from it, the 

relationship between regulatory compliance and generating co-exposure models must be discussed. 
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4.0 REGULATORY COMPLIANCE VERSUS CO-EXPOSURE MODELING

The 1999 audit was intended to assess whether LANL was in compliance1

1 In this document the word compliance used by itself usually means “the act or process of complying to a desire, 

demand, proposal, or regimen or to coercion.” For example, if a worker did not submit a urine sample when required to 

do so by LANL procedures he is not in compliance with the bioassay program and the procedures that govern it. If those 

procedures are linked to DOE regulations so that the procedures implement a regulation, then he is not in regulatory 

compliance, or equivalently, not in compliance with the regulations.

with the regulations 

promulgated in 10 C.F.R. Part 835. 10 C.F.R. 835, 1993. These regulations established criteria for 

limiting dose to workers and for acceptable design and implementation of internal dosimetry programs 

that were used to demonstrate compliance with these dose limits. The regulations were implemented 

in LANL policy statements and procedures. During audits like the one in 1999 any instance of LANL 

not following its procedures is of concern because it could indicate potential regulatory 

noncompliance. Because compliance with regulations helps to minimize and limit dose received by 

individuals, even one instance of noncompliance is of interest to the regulator and the site.

Dose reconstruction is concerned with making a reasonable estimate of the radiation doses received 

by an individual. To obtain a reasonable estimate of radiation exposure based on a co-exposure 

model, it need only be based on a representative (or bounding) sample of the workers performing 

radiological work (Section 2.0). In fact, regulatory compliance with participation in a bioassay program 

is neither necessary nor sufficient to construct a co-exposure model from the data from that program. 

To further illustrate, consider three scenarios: 

1. The health physicists running the radiological protection program determine that it is unlikely 

under typical conditions that any workers will be exposed to radioactive materials that would 

deliver a dose in excess of 100 mrem committed effective dose equivalent in a year. According 

to 10 C.F.R. § 835.402(c)(1) no workers are placed on a bioassay program. 10 C.F.R. 835, 

1993. The monitoring program is in compliance with the regulations but a co-exposure model 

cannot be constructed because there are no bioassay data.

2. Based on anticipated work, a worker is placed on an annual plutonium urine bioassay 

program. At the end of the year the worker had not performed any of the planned work, and in 

fact had never entered a regulated area. Consequently, no sample was required and none 

submitted. The monitoring program might not be in compliance with the regulations 

(depending on how procedures were worded), but the delinquent sample has no effect on the 

ability to construct a co-exposure model because the worker was not a member of the target 

population and did not submit a sample. 

3. A worker was involved in an event with a high potential for exposure to significant levels of 

radioactive material. For some reason, no samples were collected from the worker. According 

to 10 C.F.R. § 835.402(d), the monitoring program is not in compliance with the regulations. 

10 C.F.R. 835, 1993. However, this noncompliance has negligible effect on the ability to 

construct a co-exposure model. Careful study of Section 2.0 explains why this does not affect

the ability to construct a co-exposure model (i.e., a significant portion of the most highly 

exposed workers are monitored). 

Thus, compliance with the regulations in place at the time the radiological work was performed is not 

required in order to perform a dose reconstruction or develop a co-exposure model.

2

2 This conclusion was echoed by Dr. Ziemer at the April 15, 2021 meeting of the Advisory Board on Radiation and Worker 

Health [NIOSH 2021, p. 84].
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5.0 DESCRIPTION OF STUDY

The approach used in this study was to assemble and analyze all the relevant available data about 

the plutonium monitoring program at LANL during the 1996 to 2001 study period. The question then 

becomes: do the data provide a “preponderance of evidence” that an unacceptably large portion of 

the most highly exposed workers either were not monitored or are missing from the study sample? 

The six datasets that are relevant to this analysis are:

• Health Physics Checklist (HPC); 

• Bioassay Enrollment, Scheduling, and Tracking (BEST); 

• Plutonium in vitro bioassay; 

• Plutonium in vivo bioassay; 

• External dose; and

• RWPs that required monitoring for plutonium and the associated acknowledgment forms.

These datasets are discussed in the following sections, which provide summary statistics for each. 

Detailed analyses for the HPC are in ORAUT [2021b], and those for the other five datasets are in 

ORAUT [2021a]. More detailed analyses of the datasets are described starting in Section 6.0. 

5.1 HEALTH PHYSICS CHECKLIST DATASET

The HPC is a paper form that a worker, the manager, and a representative from Environmental Safety 

and Health (ESH) filled in to make changes in the worker’s in vitro, in vivo, and external dose 

monitoring programs. HPCs are of interest because they are how workers got enrolled in bioassay 

programs.

HPCs from 1985 to 2002 were collected by the ORAU Team during nine targeted visits between 

May 20, 2019, and December 4, 2019, to LANL and Federal Records Centers in Dayton and Denver. 

A Site Research Database (SRDB) query for “health physics checklist” in the title and with a date 

retrieved between May 20, 2019, and December 4, 2019, returned 43 references. Not all 43 of these 

documents were entered into the HPC database because the focus of the HPC effort shifted to just 

the checklists from the study period (January 1, 1996 to December 31, 2001). The HPC dataset called 

“LANL HPC from targeted visits_2021_03_05.csv” contains 32 of the 43 SRDB documents. The 

dataset underwent a quality assurance test and had a transcription error rate of less than 5% (see 

ORAUT [2021a]).

In this discussion, HPC “adds” refers to HPC forms that requested a worker be added to a monitoring 

program that required an in vitro sample to be collected (e.g., an annual routine bioassay program or 

a termination bioassay program). Only HPC adds are of interest, not requests for a worker to be 

removed from a monitoring program (which does not require a sample). During the study period, 

1,856 HPC adds were requested. The breakdown of HPC adds per year during the study period is 

shown in Figure 5-1. Of note is the relatively low number of adds in 2001, which appears to be the 

result of the HPC system being replaced by the electronic Dosimetry Evaluation System in that year 

(i.e., HPC paper forms were phased out in 2001). 
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Figure 5-1. HPCs submitted per year that were adds for plutonium. See 

Table A-1. 

5.2 BIOASSAY ENROLLMENT, SCHEDULING, AND TRACKING DATASET

BEST is a system that was used to manage bioassay program enrollments, which included adding 

and removing workers from routine, baseline, termination, and special monitoring programs. In this 

discussion enrollments that placed workers on bioassay programs are referred to as adds (which are

different from adds in HPCs), which always had an associated sample request that is referred to as an 

Enroll Request. Sample requests not associated with adds were for routine (e.g., annual) samples, 

which are referred to as Non-enroll Requests. Figure 5-2 provides summaries of Enroll and Non-enroll 

Requests. The total number of sample requests for plutonium made through BEST in a given year is 

the sum of the Enroll and Non-enroll Requests in that year. For example, a total of 1,496 + 516 = 

2,012 requests were made in 1996, and these sums are given in Figure 7-1. Bioassay sample kits 

were issued, tracked, and logged in BEST. Information extracted from the BEST database was 

provided electronically to the ORAU Team in 2020 [U.S. Department of Energy (DOE) 2021]. During 

the study period there were 13,895 requests for plutonium samples (which were for Enroll Requests 

and Non-enroll Requests) for 3,384 workers.
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Figure 5-2. Sample requests in BEST for plutonium analysis per year. See 

Table A-2.

5.3 IN VITRO BIOASSAY DATASET 

Creation of the in vitro bioassay dataset is detailed in ORAUT-OTIB-0063, Los Alamos National 

Laboratory Bioassay Repository Database [NIOSH 2009]. The file “LANL IN VITRO DATA FEB 2009 

5-26-20.csv” was extracted from the Access database named “LANL_invitro_dataset_feb2009.mdb”

located in the O:\DOE Site Images\LANL\030157133 - LANL In Vitro Dataset February 2009 folder on 

the ORAU Team network. There were 12,666 plutonium urine and fecal bioassay samples collected 

for plutonium analysis3

3 By radiometric alpha spectrometry (RAS) and thermal ionization mass spectrometry.

from 3,219 workers during the study period. Note that these 12,666 bioassay 

results are the data that would be used for a co-exposure model for plutonium in urine at LANL. The 

year-by-year breakdown of the number of workers and samples they submitted is shown in 

Figure 5-3. The number of samples requested through BEST in a given year (Figure 5-2) for analysis 

for plutonium was greater than the number of samples received in a given year (Figure 5-3), which is 

discussed further in Section 7.0. 
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Figure 5-3. Plutonium in vitro bioassay samples submitted by workers in each 

year of the study. Note that these are all plutonium samples from all workers.

See Table A-3. 

5.4 IN VIVO BIOASSAY DATASET

Creation of the in vivo bioassay dataset is detailed in ORAUT-OTIB-0063, Los Alamos National 

Laboratory Bioassay Repository Database [NIOSH 2009]. The file “LANL in vivo 

TBL_NIOSH_REPORT_2005_11_09 5-26-20.csv” was extracted from the Access database named 

“2007_10_08-LANL_IN_VIVO_DATA-Access2003.mdb” located in the O:\DOE Site 

Images\LANL\030157132 - LANL In Vivo Data October 8, 2007 folder on the ORAU Team server. 

There are 6,817 plutonium/americium chest counts from 3,282 workers during the study period. The 

year-by-year breakdown of chest counts is shown in Figure 5-4. The number of workers monitored by 

chest counting and in vitro bioassay is essentially constant over the study period. Approximately 80% 

of the workers monitored for plutonium by in vitro bioassay also were monitored by chest counting.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 15 of 51

Figure 5-4. Plutonium/americium chest counts performed and the number of 

workers in each year of the study. See Table A-4.

5.5 EXTERNAL DOSE DATASET 

The external dose records of LANL workers provide a comprehensive list of individuals (name and 

employee number) who performed radiological work at LANL. The external dosimetry records were 

used to help identify individuals who were missing employee numbers in other datasets and as an aid 

in the entry of those datasets. The external dose data consists of the 3.4 million records in the Access 

dataset located in the O:\DOE Site Images\LANL\030086614 - LANL External Whole-Body and 

Extremity Dosimetry Results folder.

4

4 Dump to comma-separated values file format provided by Joe Guido on August 14, 2020.

There were approximately 11,000 workers at LANL who were 

monitored for external dose each year during the study period. 

5.6 RADIOLOGICAL WORK PERMITS DATASET

RWPs and acknowledgment sheets were transcribed by the ORAU Team from the documents that 

were captured during the nine targeted visits (between May 20, 2019, and December 4, 2019) to 

LANL and Federal Records Centers in Dayton and Denver. Notable RWPs were targeted for capture, 

where a “notable” RWP is defined as an RWP that: 

• Occurred within the study period (January 1, 1996, to December 31, 2001); 

• Required urinalysis as noted on the RWP by having “Special Urinalysis” or “Pu Access List” 

checked or contained other equivalent terminology or notation indicating urinalysis was 

required; and

• Contained an associated roster (acknowledgment sheet) with names of personnel 

acknowledging the RWP.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 16 of 51

An SRDB query for “notable RWP” in the title and with a date retrieved between May 20, 2019, and 

December 4, 2019, returned 316 references. These documents constitute the RWP dataset called 

“LANL RWP from targeted visits_2021_03_11.csv.” The RWP dataset underwent a quality assurance 

test and had a transcription error rate of less than 5% (see ORAUT [2021a]).

RWPs were used to control work with a high potential for exposures to radiation. All other radiological 

work was performed according to Safe Operating Procedures. RWPs with plutonium access list (PAL) 

checked required that a person be on a plutonium monitoring program before performing work under 

the RWP. PALs were generated monthly and mailed as a memorandum to designated field contacts 

[Archuleta 2020]. Workers signed an acknowledgment sheet during the prejob briefing, which was 

required before working under the RWP. The signature on the acknowledgment sheet indicated that 

the worker understood the monitoring requirements of the RWP [DOE 1998]. Note that a worker could 

have signed an acknowledgment sheet and never performed work under that RWP; it is not a sign-in 

sheet. During the study period there are 19,568 records in the RWP dataset, where each record is the 

signature of one worker on the acknowledgment sheet of a particular RWP that had a PAL 

requirement. Overall, there are signatures from 1,942 workers.

5.6.1 Summary of Radiological Work Permits by Technical Area

The breakdown by year and Technical Area (TA) of RWPs with PAL requirements is given in 

Table 5-1. Areas mentioned in these RWPs [ORAUT 2004] are: 

• TA-3 Core Area (a.k.a. South Mesa Site): 238Pu, 239Pu, 235U, 238U, depleted uranium (DU), 

natural uranium, 210Po.

• TA-18 Pajarito Laboratory: 235U, 239Pu, 240Pu, 233U, mixed fission products, 131I, polonium. 

• TA-21 DP Site (a.k.a. DP Mesa): 239Pu, 238Pu, 240Pu, 241Pu, 241Am, 235U, 238U, 210Po, 227Ac, 3H.

• TA-35 Ten Site: 3H, 90Sr, 140Ba, 140La, 235U, DU, 237Np, plutonium, polonium, cobalt, volatile 

fission products. 

• TA-48 Radiochemistry Site: uranium, transuranic, mixed activation products, mixed fission 

products. 

• TA-49 Frijoles Mesa Site: 3H, plutonium, uranium.

• TA-50 Waste Management Site: all radionuclides.

• TA-54 Waste Disposal Site: all radionuclides. 

• TA-55 Plutonium Facility Site: 239Pu, 3H.

Note that all RWPs with PAL checked that have any date (signed, effective, or expired) in the study 

period are included in this table. Year is the year in which the RWP expired. This table shows that a 

reasonable number of RWPs were obtained for the primary plutonium facilities at LANL.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 17 of 51

Table 5-1. RWPs issued by TA and the year in which the RWP expired. 

TA 1996 1997 1998 1999 2000 2001 2002 Totals

3 172 139 151 189 36 66 6 759

18 0 0 0 0 1 0 0 1

21 1 4 3 1 1 1 0 11

35 1 0 0 0 0 0 0 1

48 0 0 2 2 0 0 0 4

49 0 0 5 0 0 0 0 5

50 2 42 26 34 27 20 0 151

54 3 32 42 4 0 0 3 84

55 218 230 20 239 238 287 4 1,236

Totals 397 447 249 469 303 374 13 2,252

6.0 ANALYSIS OF DATA

The LANL datasets are interrelated as shown in Figure 6-1. Analysis of the HPC -> BEST -> INVITRO branch should indicate if a worker placed on a plutonium bioassay program submitted samples 

for analysis. The following questions can be asked and answers offered based on the information in 

those three datasets:

• If a sample was requested through BEST was it received and analyzed?

– Compare sample requests in BEST to results reported in the in vitro bioassay database. 

• Were samples in the in vitro bioassay dataset requested through BEST?

– Compare results in the in vitro database to BEST to see if they were requested through 

BEST. 

• Was a worker entered into BEST if requested to do so via an HPC?

– Compare transactions initiated by HPCs to information that was uploaded into BEST.

Ideally, that analysis would answer most of the questions about whether a plutonium co-exposure 

model could be generated from the plutonium bioassay data. However, there is a known problem of 

HPCs not being submitted consistently. Analysis of the HPC -> BEST -> IN-VITRO branch cannot

indicate anything if the HPC was never submitted. To address this issue, the ORAU Team analyzed 

the RWP -> ACKNOWLEDGMENT SHEET -> IN-VITRO/IN-VIVO branch, which can show if a worker 

who did work with potential for exposure to plutonium was monitored for plutonium. Note that this 

analysis is independent of whether a worker submitted an HPC. In other words, if an individual 

performed radiological work that required monitoring for plutonium and was properly monitored, the 

HPC paperwork is irrelevant. The questions are:

• Were workers who signed an RWP acknowledgment sheet with a PAL requirement monitored 

in a timely fashion?

– Identify workers who signed an acknowledgment sheet that were monitored during an

RWP-approved work period or after that RWP period (see Section 10.0 for details).

– Identify workers who were eventually monitored after the end of the post-RWP monitoring 

window (see Section 10.0 for details).

• What fraction of workers who signed the acknowledgment sheet for a given RWP was

monitored?
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 18 of 51

– Examine the fraction of workers in a workgroup (all workers who signed a given 

acknowledgment form) who were monitored.

• What were the relative exposures of different groups to plutonium?

– Compare 238Pu and 239

Pu excretion rates for the different groups.

Figure 6-1. Relationship between datasets 

analyzed in this report. It is believed that the 

plutonium access list (PAL) was generated 

from BEST and was used to verify workers 

signing the acknowledgment sheet (Ack 

Sheet) were on a Pu bioassay program. 

7.0 COMPARISON OF BIOASSAY ENROLLMENT, SCHEDULING, AND TRACKING AND THE 

IN VITRO DATASET

Overall, out of 13,895 requests made through BEST for samples to be analyzed for plutonium, 11,914 

(85.7%) were fulfilled. All requests from BEST were tracked and most were accounted for with 

reasons being given for why sample requests were not fulfilled (Table 7-1). Of the 1,981 samples not 

received, 1,613 have legitimate reasons for not being received. Note that INACTIVATED FOR 

MIGRATION refers to sample requests that were canceled to migrate BEST to a new database, and 

that NO CHARGE means that no charge code was provided to pay for the analysis.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 19 of 51

Table 7-1. Reasons for sample kits 

requested through BEST not being 

submitted.

Reason Number

Travel 1

Vacation 1

Label/seal problems 4

Holiday break 5

Change of station 6

Sick leave 10

None given 17

Extended leave of absence 25

Lost kit 37

No charge 79

Miscellaneous 94

No longer in area 115

Monitoring no longer required 175

Terminated 203

No sample submitted 351

Inactivated for migration 858

Total 1,981

The number of requests through BEST and the number of samples received from all workers by year 

is given in Figure 7-1. The company an individual works for is identified in BEST for every request, 

and a breakdown of the number of requests by company for the nine companies with more than 

100 requests (which is 90% of the requests from all 181 companies identified) is shown in Table 7-2.

Figure 7-1. Plutonium samples requested through BEST and received for all 

workers. See Table A-5. 
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 20 of 51

Table 7-2. Requests for in vitro samples for 

plutonium analysis by company (9 companies 

with more than 100 requests).

Company Number

The Plus Group 133

Kleen-Tech Building Services 155

Butler Services 156

Protection Technology Los Alamo 240

Weirich and Associates 241

Comforce Technical Services 263

JCa Northern NM 454

KSL Services 1,365

LANL 9,632

a. JC = Johnson Controls.

To provide more detail, the number of requests and samples by year is given for each of the top three 

companies (Johnson Controls [JC], KSL Services [KSL], and LANL) in Figures 7-2 to 7-4. With the 

percentage of requests that resulted in samples being received ranging from 72% for JC to 89% for 

KSL, Figures 7-2 through 7-4 show that if a sample was requested it was usually received (or LANL 

was aware that it was not received). The observed decrease in the number of requests made to and 

samples received from JC workers in 1999 to 2001 (see Figure 7-2) can be attributed to a planned 

reduction in the number of these workers being monitored [NIOSH 2019b].

Figure 7-2. Samples requested from JC workers through BEST that were 

received and analyzed for plutonium. See Table A-6. 

The reverse question, how many samples were requested through BEST, is also of interest because 

we want to confirm that BEST was the primary mechanism for requesting plutonium samples. Of the 

12,666 in vitro samples submitted for plutonium analysis, 11,852 were requested through BEST 

(93.6%). Indications are that samples lost in process due to problems like low recovery were reported 

and the kit number was removed from BEST. This could explain some of the instances where a 

plutonium result in the in vitro dataset could not be traced back to BEST. The data discussed in this 
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 21 of 51

section show that a comprehensive program was in place at LANL to request and track plutonium 

samples.

Figure 7-3. Samples requested from KSL workers through BEST that were 

received and analyzed for plutonium. See Table A-7. 

Figure 7-4. Samples requested from LANL workers through BEST that were 

received and analyzed for plutonium. See Table A-8. 
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 22 of 51

8.0 DEFINITION OF GROUPS

Analyzing the HPC and RWP datasets requires statistics describing the entire populations of workers 

who filled out an HPC or signed an RWP acknowledgment form. Statistics describing certain 

subgroups of the population are necessary as well. Specifically, four subgroups of interest were 

defined:

• JC, 

• LANL ESH, 

• LANL Nuclear Materials Technology (NMT), and

• All others (Other).

ESH, NMT, and JC were selected because workers in those groups had the most signatures on RWP 

acknowledgment sheets: 17,860 out of 19,568 signatures or 91.3% were from individuals in one of 

these three groups. In addition, ESH is considered to represent radiological control personnel, NMT is 

considered to represent operators, and JC was considered to represent maintenance workers. JC is 

also of interest because it was specifically mentioned in the 1999 audit. The basic strategy used to 

assign workers to groups was:

• Assign each person who signed the acknowledgment form to the group written on the form 

next to the signature. If the group on the acknowledgment form contained the letters “ESH” the 

person was assigned to the ESH group for that record, and likewise for “NMT” and “JC”.

• Repeat the procedure for any record not assigned to a group using the group information in 

BEST.

• Any record not assigned at this point is assigned to Other.

Note that these groupings are not the same as the BEST company groupings used in Section 7.0. 

9.0 COMPARISON OF HEALTH PHYSICS CHECKLIST AND BIOASSAY ENROLLMENT,

SCHEDULING, AND TRACKING 

There are 1,856 adds via HPCs during the study period for plutonium. The breakdown of adds by year 

and group is shown in Figure 9-1. Of note is that workers in Other made up most of the adds. This is 

not unexpected considering that: 

• Adds in the HPCs are for workers coming on bioassay programs, and

• Subcontractors like those found in Other would be expected to have a higher turnover rate 

than LANL workers.

The low number of HPC adds for JC could be due to (1) HPC adds not being submitted consistently 

for JC workers added to bioassay monitoring, which is consistent with the findings in the 1999 audit of 

the internal dosimetry program, or (2) low turnover of workers or work, meaning no adds or changes 

to current bioassay monitoring, which would contribute to the low number of HPC adds.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 23 of 51

Ideally, each of the HPC adds would be associated with an enrollment in BEST that would request a 

sample for plutonium analysis. A detailed comparison of the HPC with BEST [ORAUT 2021b] showed 

that: 

• 1,802 out of 1,856 = 97.09% of the plutonium adds in HPCs matched BEST (when only 

considering BEST), and

• 1,848 out of 1,856 = 99.57% matched when also considering samples in the in vitro dataset 

that did not have a request in BEST.

Figure 9-1. HPC adds per group. See Table A-9. 

Therefore, workers who submitted HPC add forms almost certainly were entered in the BEST system 

where samples were requested with a high probability of being received. This is quite good, but again, 

this result reveals nothing about the HPCs that were not submitted or forms that were not captured by 

the ORAU Team. These concerns will be addressed when comparing bioassay requirements of the 

RWP with the in vitro dataset.

10.0 COMPLIANCE WITH RADIOLOGICAL WORK PERMIT MONITORING REQUIREMENTS

A key part of this study is to quantify the extent to which the LANL workforce complied with the 

bioassay requirements for work involving plutonium. In particular, the focus is on work regulated by 

RWPs with a PAL requirement, which indicates that the worker needed to be on a plutonium bioassay 

program before doing work under the RWP. Workers were required to sign the RWP acknowledgment 

sheet for an RWP to indicate they understood the monitoring and personal protection equipment 

requirements of that RWP. Note that their signatures did not denote that they actually performed any 

work, only that they understood the requirements to work under that RWP. 

A summary of the number of workers, RWPs, and submitted plutonium in vitro samples is given in 

Figure 10-1. The Year of an RWP is defined to be the year in which the RWP expired. This plot gives 

an idea of how many workers were doing radiological work in each year and how many samples they 

submitted, and it indicates that there is a considerable amount of data available to analyze.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 24 of 51

Figure 10-1. Plutonium samples from workers who signed an acknowledgment 

sheet on an RWP that had a PAL requirement. See Table A-10. 

The number of workers from each group who signed an acknowledgment form in each year is given in 

Figure 10-2 and the number of RWPs acknowledgments signed by workers in each group by year is 

given in Figure 10-3. These plots show that ESH had fewer workers than NMT and JC, but their

workers signed in on a proportionally larger number of RWPs. For example, in 1996 the average ESH 

worker signed in on 9.4 RWPs whereas the average JC and NMT worker signed in on 4.6 and 

3.0 RWP, respectively. This is consistent with ESH workers moving from work location to work 

location performing radiological control functions, and it is the basis for quantifying compliance with 

bioassay programs using worker and work as metrics.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 25 of 51

Figure 10-2. Workers in each of the groups who signed RWP acknowledgment 

forms in each year. See Table A-11. 

Figure 10-3. RWP acknowledgments signed by workers in each group by year.

See Table A-12. 

Measuring compliance by work implies that if a worker signs 10 RWPs in a year (for example) and 

complies with the monitoring requirements for all of them, there are 10 instances of compliance. When 

calculating compliance with the monitoring program, using this measure puts more weight on workers 
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 26 of 51

who sign multiple RWPs in a year. To determine if workers submitted samples in a timely fashion, a 

time window for submission of the in vitro samples needs to be established. If a sample was collected 

within the window, the worker was deemed to be in compliance with the monitoring requirements of 

that RWP. Work is defined to be the combination of a specific worker and a specific RWP the worker 

acknowledged. Each record in the RWP dataset represents one instance of work. If a worker 

submitted a sample: 

• Between the effective date and the expiration date of the RWP (the active dates of the RWP), 

or

• By the end of the year after the year in which the RWP expired5

5 For example, if the RWP expired anytime in 1996, the post-RWP window goes to December 31, 1997.

(the post-RWP sampling 

window),

the worker was considered to have complied with the monitoring requirements for that work.

It is also important to examine if the worker was in compliance with the monitoring requirements for 

that year with no consideration of the number of acknowledged RWPs. There is no unique way to 

define this measure. In this report, measuring compliance by a worker is determined by checking 

compliance with any of the acknowledged RWPs that year. For example, if a worker signed 10 RWPs 

and was in compliance (in terms of work) with nine of them, then the worker was in compliance for the 

year. Using this measure puts equal weight on each worker when calculating compliance with the 

monitoring program. Other definitions of compliance can be used (e.g., using only the post-RWP 

window and requiring a worker to be in compliance with all instances of work rather than just one). 

Use of these alternative definitions does not change the conclusions of this report on the development 

of a co-exposure model for plutonium.

Another sampling window of interest considers monitoring for plutonium at any time after the postRWP window. This open window is relevant for plutonium because doses from intakes of plutonium 

can be bound by samples taken at any time after the intake.

6

6 Thermal ionization mass spec (TIMS) that was routinely used at LANL during the study period could easily bound the 

dose from weapons grade plutonium to less than 100 mrem at any time after the intake.

Sampling results in the open window 

can be used to address the concern that the most highly exposed workers were not monitored during 

the active dates of the RWP or in the post-RWP window. An overall summary of compliance with the 

RWP monitoring requirements is given in Table 10-1, and more detailed information is given in 

Attachment B. The overall compliance with the plutonium bioassay programs (when 100% compliance 

with such programs was problematic) was quite good for a large facility like LANL.

Table 10-1. Summary of statistics for monitoring of RWP work.a

Group Number of workers

Number of 

RWPs Work Worker Work(O) Worker(O)

JC 703 1,396 81.0 65.1 92.6 83.5

ESH 227 2,128 96.5 84.1 98.1 87.8

NMT 660 1,393 97.1 95.3 99.0 98.2

Other 556 579 70.6 63.3 81.4 74.5

a. Work and Worker columns refer to the percentage of work and workers, respectively, who were properly monitored as 

determined using the active RWP period and post-RWP window. Work(O) and Worker(O) columns refer to the 

percentage of work and workers, respectively, who were properly monitored as determined using the active RWP 

period, post-RWP window, and open window.

Because the acknowledgment sheets were not RWP sign-in sheets, this does not mean that all the 

workers who signed the acknowledgment sheet for a given RWP were in one place at one time. 

Nevertheless, they can be considered to constitute a workgroup. As shown in Figure 10-4, for 96.8% 

 
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 27 of 51

of the 2,252 RWPs, at least half of the workers who signed a given RWP were monitored (in the 

active RWP period or post-RWP window). This implies that it is highly likely that workers who were 

exposed to plutonium and not monitored had potentially exposed coworkers who were monitored.

Figure 10-4. Histogram of the frequencies of workgroup monitoring percentages for 2,252 RWPs. See 

Table A-13. 

11.0 PLUTONIUM RESULTS FOR JOHNSON CONTROLS, ENVIRONMENTAL SAFETY AND 

HEALTH, NUCLEAR MATERIALS TECHNOLOGY, AND OTHER

In previous sections we have established that while there is a considerable amount of data available 

on which to base a co-exposure model for plutonium at LANL, some groups have more than others. 

Therefore it is of interest to compare some measure of relative exposures of the groups to see if the 

groups with less data are more highly exposed. An approximate measure of the exposures to each of 

the four groups is the plutonium in urine analytical results for the groups. Figure 11-1 is a lognormal 

quantile-quantile (q-q) plot of the 238Pu (radiometric alpha spectrometry [RAS] only) results for the four 

groups. The data for the four groups are clearly different with NMT and ESH, the most completely 

monitored groups (see Table 10-1), being the highest.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 28 of 51

Figure 11-1. Comparison of 238Pu in the urine of JC, ESH, and NMT workers 

who submitted samples in the study period.

Figure 11-2 is a lognormal q-q plot for the combined 239Pu (RAS only) results for the four groups. The 

data for the four groups are fairly similar, with NMT and ESH being slightly higher. The relatively high 

results for JC are the result of [redacted] JC workers who had relatively high levels of 239Pu in their 

urine from what appears to have been a single event.

Figure 11-2. Comparison of 239Pu in the urine of JC, ESH, and NMT workers 

who submitted samples.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 29 of 51

12.0 SUMMARY AND CONCLUSIONS

This discussion began with the question, 

Did the regulatory deficiencies pointed out in the 1999 audit of the LANL internal 

dosimetry program imply that the data generated by that program in the 1996 to 2001 

period are unsuitable for use in generating a co-exposure model for plutonium for use in 

the EEOICPA compensation program?

The fundamental philosophy of co-exposure models was reviewed, and it was concluded that a 

bounding co-exposure model can be constructed as long as a significant portion of the most highly 

exposed workers were monitored and present in the study sample. The fact that regulatory 

deficiencies have no direct relationship with the ability to construct co-exposure models was noted. 

The premise of the study designed to answer the question was to presume that LANL had the desire 

and wherewithal to properly monitor workers who had a significant potential for exposure to plutonium 

and to look at the available data for indications that this did not occur. The following are the main 

findings from this study:

• The HPC was a paper form used to remove or add workers to monitoring programs in the 

BEST database. BEST was used to request samples and track when the sample was 

received. HPC adds were compared to the BEST dataset, and it was concluded that workers 

were put on the requested plutonium bioassay program nearly 100% of the time.

• The in vitro bioassay database contained all the plutonium analytical results reported by LANL. 

In vitro bioassay sample requests in BEST were compared to the in vitro bioassay database. It 

was concluded that the requests were fulfilled an average of about 86% of the time. 

Compliance by major companies ranged from around 72% for JC to about 89% for LANL 

employees. All samples that were not received were tracked, and most had an explanation of 

why the sample was not submitted.

• The plutonium samples in the in vitro bioassay dataset were compared to BEST and it was 

concluded that about 94% of the samples were requested through BEST.

• Workers who signed acknowledgment sheets for RWPs that required plutonium monitoring (as 

indicated by the PAL checkbox on the RWP) were compared to the in vitro and in vivo 

bioassay datasets to determine if they were in compliance with the monitoring requirements. 

Compliance was defined in a number of different ways (see Table 10-1 and the plots in 

Attachment B), but in all cases it was found that a significant portion of the most highly 

exposed workers are available for inclusion in the co-exposure model and that no workers 

from major organizations were inadequately represented in the bioassay datasets. 

• The workers who signed the acknowledgment form for a given RWP were considered to 

constitute a workgroup. Approximately 97% of the 2,252 RWP had 50% or more of the 

workers monitored.

The preponderance of evidence supports the conclusion that the plutonium bioassay data reported by 

LANL in the 1996 to 2001 study period include a significant portion of the most highly exposed 

workers and are therefore adequate to construct a co-exposure model for plutonium.
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 30 of 51

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ATTACHMENT A 

DATA FOR BAR CHARTS

LIST OF TABLES

TABLE TITLE PAGE

A-1 Data for Figure 5-1, HPCs submitted per year that were adds for plutonium during the 

study period ...........................................................................................................................33

A-2 Data for Figure 5-2, Sample requests in BEST for plutonium analysis per year...................... 33

A-3 Data for Figure 5-3, Plutonium in vitro bioassay samples submitted by workers in each 

year of the study ....................................................................................................................33

A-4 Data for Figure 5-4, Plutonium/americium chest counts performed and workers in each 

year of the study ....................................................................................................................33

A-5 Data for Figure 7-1, Plutonium samples requested through BEST and received for all 

workers ..................................................................................................................................33

A-6 Data for Figure 7-2, Samples requested from JC workers through BEST that were 

received and analyzed for plutonium...................................................................................... 33

A-7 Data for Figure 7-3, Samples requested from KSL workers through BEST that were 

received and analyzed for plutonium...................................................................................... 33

A-8 Data for Figure 7-4, Samples requested from LANL workers through BEST that were 

received and analyzed for plutonium...................................................................................... 33

A-9 Data for Figure 9-1, HPC adds per group............................................................................... 34

A-10 Data for Figure 10-1, Plutonium samples from workers who signed an acknowledgment 

sheet on an RWP that had a PAL requirement....................................................................... 34

A-11 Data for Figure 10-2, Workers in each of the groups who signed RWP acknowledgment 

forms in each year..................................................................................................................34

A-12 Data for Figure 10-3, RWP acknowledgments signed by workers in each group by year ....... 34

A-13 Data for Figure 10-4, Histogram of the frequencies of workgroup monitoring percentages 

for 2,252 RWPs......................................................................................................................34
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 33 of 51

Table A-1. Data for Figure 5-1, HPCs submitted per year 

that were adds for plutonium during the study period.

1996 1997 1998 1999 2000 2001

339 285 374 461 348 49

Table A-2. Data for Figure 5-2, Sample requests in BEST for plutonium 

analysis per year.

Type 1996 1997 1998 1999 2000 2001

Enroll 516 664 989 730 848 557

Non-enroll 1,496 1,348 1,461 1,630 1,970 1,686

Table A-3. Data for Figure 5-3, Plutonium in vitro bioassay samples 

submitted by workers in each year of the study. Note that these are all

plutonium samples from all workers.

Type 1996 1997 1998 1999 2000 2001

Samples 1,919 1,924 2,347 2,085 2,299 2,092

Workers 1,447 1,490 1,509 1,489 1,464 1,459

Table A-4. Data for Figure 5-4, Plutonium/americium chest counts 

performed and workers in each year of the study.

Type 1996 1997 1998 1999 2000 2001

Counts 1,250 1,085 1,171 1,180 1,135 996

Workers 1,150 990 1,114 1,128 1,078 962

Table A-5. Data for Figure 7-1, Plutonium samples requested 

through BEST and received for all workers.

Type 1996 1997 1998 1999 2000 2001

Requested 2,012 2,012 2,450 2,360 2,818 2,243

Received 1,827 1,857 2,230 1908 2,245 1,847

Table A-6. Data for Figure 7-2, Samples requested from JC 

workers through BEST that were received and analyzed for 

plutonium.

Type 1996 1997 1998 1999 2000 2001

Requested 128 119 98 37 43 29

Received 100 98 64 21 29 13

Table A-7. Data for Figure 7-3, Samples requested from KSL 

workers through BEST that were received and analyzed for 

plutonium.

Type 1996 1997 1998 1999 2000 2001

Requested 256 242 262 172 187 246

Received 239 226 227 142 164 215

Table A-8. Data for Figure 7-4, Samples requested from 

LANL workers through BEST that were received and 

analyzed for plutonium.

Type 1996 1997 1998 1999 2000 2001

Requested 1,212 1,200 1,650 1,712 2,207 1,651

Received 1,129 1,130 1,547 1,363 1,727 1,356
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 34 of 51

Table A-9. Data for Figure 9-1, HPC adds per group.

Type 1996 1997 1998 1999 2000 2001

JC 18 2 1 19 86 11

NMT 101 67 159 142 83 15

ESH 45 39 35 58 29 9

Other 175 177 179 242 150 14

Table A-10. Data for Figure 10-1, Plutonium samples from 

workers who signed an acknowledgment sheet on an RWP that 

had a PAL requirement.

Type 1996 1997 1998 1999 2000 2001 2002

Workers 655 812 587 833 777 835 136

RWPs 397 447 249 469 303 374 13

Samples 769 811 549 867 1,205 1,017 144

Table A-11. Data for Figure 10-2, Workers in each of the groups 

who signed RWP acknowledgment forms in each year.

Type 1996 1997 1998 1999 2000 2001 2002

JC 261 325 236 295 225 284 54

NMT 223 224 125 342 375 329 33

ESH 85 121 104 122 89 97 27

Other 110 170 147 121 115 155 23

Table A-12. Data for Figure 10-3, RWP acknowledgments signed 

by workers in each group by year.

Type 1996 1997 1998 1999 2000 2001 2002

JC 1,208 1,509 787 1,439 1,006 1,564 74

NMT 672 710 243 943 1,218 1,215 34

ESH 798 906 563 1004 941 1,215 30

Other 196 406 316 265 203 293 29

Table A-13. Data for Figure 10-4, Histogram of the frequencies of workgroup monitoring percentages 

for 2,252 RWPs.

Bin 0-10 10-20 20-30 30-40 40-50 50-60 60-70 70-80 80-90 90-100

Number 9 8 5 37 83 68 122 228 241 1451
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 35 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS

TABLE OF CONTENTS

SECTION TITLE PAGE

B.1 Active RWP Dates and Post-RWP Window............................................................................ 36

B.2 Active RWP Dates, Post-RWP Window, and Open Window................................................... 44

LIST OF TABLES

TABLE TITLE PAGE

B-1 Data for Figure B-1, Work performed by JC that was properly monitored (Sampled).............. 36

B-2 Data for Figure B-2, JC workers who were properly monitored (Sampled) ............................. 37

B-3 Data for Figure B-3, Work performed by Other that was properly monitored (Sampled)......... 38

B-4 Data for Figure B-4, Other workers who were properly monitored (Sampled)......................... 39

B-5 Data for Figure B-5, Work performed by ESH that was properly monitored (Sampled)........... 40

B-6 Data for Figure B-6, ESH workers who were properly monitored (Sampled) .......................... 41

B-7 Data for Figure B-7, Work performed by NMT that was properly monitored (Sampled) .......... 42

B-8 Data for Figure B-8, NMT workers who were properly monitored (Sampled).......................... 43

B-9 Data for Figure B-9, Work performed by JC that was properly monitored (Sampled).............. 44

B-10 Data for Figure B-10, JC workers who were properly monitored during the study period 

(Sampled) ..............................................................................................................................45

B-11 Data for Figure B-11, Work performed by Other that was properly monitored (Sampled)....... 46

B-12 Data for Figure B-12, Other workers who were properly monitored (Sampled)....................... 47

B-13 Data for Figure B-13, Work performed by ESH that was properly monitored (Sampled)......... 48

B-14 Data for Figure B-14, ESH workers who were properly monitored (Sampled) ........................ 49

B-15 Data for Figure B-15, Work performed by NMT that was properly monitored (Sampled) ........ 50

B-16 Data for Figure B-16, NMT workers who were properly monitored (Sampled)........................ 51

LIST OF FIGURES 

FIGURE TITLE PAGE

B-1 Work performed by JC that was properly monitored (Sampled).............................................. 36

B-2 JC workers who were properly monitored (Sampled) ............................................................. 37

B-3 Work performed by Other that was properly monitored (Sampled)......................................... 38

B-4 Other workers who were properly monitored (Sampled)......................................................... 39

B-5 Work performed by ESH that was properly monitored (Sampled)........................................... 40

B-6 ESH workers who were properly monitored (Sampled) .......................................................... 41

B-7 Work performed by NMT that was properly monitored (Sampled) .......................................... 42

B-8 NMT workers who were properly monitored (Sampled).......................................................... 43

B-9 Work performed by JC that was properly monitored (Sampled).............................................. 44

B-10 JC workers who were properly monitored (Sampled) ............................................................. 45

B-11 Work performed by Other that was properly monitored (Sampled)......................................... 46

B-12 Other workers who were properly monitored (Sampled)......................................................... 47

B-13 Work performed by ESH that was properly monitored (Sampled)........................................... 48

B-14 ESH workers who were properly monitored (Sampled) .......................................................... 49

B-15 Work performed by NMT that was properly monitored (Sampled) .......................................... 50

B-16 NMT workers who were properly monitored (Sampled).......................................................... 51
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 36 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

B.1 ACTIVE RWP DATES AND POST-RWP WINDOW

Table 10-1 in Section 10.0 gave a broad overview of the compliance with RWP plutonium monitoring 

programs. This section provides a more detailed breakdown of that information:

• Compliance by group (JC, ESH, NMT, and Other) by year for work and worker using the active 

RWP period and post-RWP window (Section B.1, Figures B-1 to B-8 and Tables B-1 to B-8).

• Compliance by group (JC, ESH, NMT, and Other) by year for work and worker using the active 

RWP period, post-RWP window, and open window (Section B.2, Figures B-9 to B-16 and 

Tables B-9 to B-16). 

Figure B-1. Work performed by JC that was properly monitored (Sampled). 

Table B-1. Data for Figure B-1, Work performed by JC that was properly 

monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 939 1,151 591 1,062 888 1,451 65

Not sampled 269 358 196 377 118 113 9
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 37 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-2. JC workers who were properly monitored (Sampled). 

Table B-2. Data for Figure B-2, JC workers who were properly monitored

(Sampled).

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 146 173 138 150 159 218 45

Not sampled 85 122 83 127 62 64 9
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 38 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-3. Work performed by Other that was properly monitored (Sampled). 

Table B-3. Data for Figure B-3, Work performed by Other that was 

properly monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 122 321 205 179 150 216 12

Not sampled 74 85 111 86 53 77 17
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 39 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-4. Other workers who were properly monitored (Sampled). 

Table B-4. Data for Figure B-4, Other workers who were properly 

monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 61 106 84 90 66 88 6

Not sampled 35 43 59 48 42 48 15
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 40 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-5. Work performed by ESH that was properly monitored (Sampled). 

Table B-5. Data for Figure B-5, Work performed by ESH that was properly 

monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 786 867 505 959 925 986 29

Not sampled 12 39 58 45 16 10 1
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 41 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-6. ESH workers who were properly monitored (Sampled). 

Table B-6. Data for Figure B-6, ESH workers who were properly monitored

(Sampled).

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 63 86 66 80 78 79 25

Not sampled 10 17 26 26 3 7 1
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 42 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-7. Work performed by NMT that was properly monitored (Sampled). 

Table B-7. Data for Figure B-7, Work performed by NMT that was properly 

monitored (Sampled).

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 646 702 217 904 1,196 1,193 33

Not sampled 26 8 26 39 22 22 1
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 43 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-8. NMT workers who were properly monitored (Sampled). 

Table B-8. Data for Figure B-8, NMT workers who were properly monitored

(Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 242 256 117 291 354 323 34

Not sampled 13 9 14 21 13 8 1
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 44 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

B.2 ACTIVE RWP DATES, POST-RWP WINDOW, AND OPEN WINDOW

Figure B-9. Work performed by JC that was properly monitored (Sampled). 

Table B-9. Data for Figure B-9, Work performed by JC that was properly 

monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 1,129 1,347 712 1,303 965 1,498 69

Not sampled 79 162 75 136 41 66 5
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 45 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-10. JC workers who were properly monitored (Sampled). 

Table B-10. Data for Figure B-10, JC workers who were properly monitored 

during the study period (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 192 234 188 217 190 250 49

Not sampled 39 61 33 60 31 32 5
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 46 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-11. Work performed by Other that was properly monitored (Sampled). 

Table B-11. Data for Figure B-11, Work performed by Other that was 

properly monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 142 360 226 229 175 239 20

Not sampled 54 46 90 36 28 54 9
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 47 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-12. Other workers who were properly monitored (Sampled). 

Table B-12. Data for Figure B-12, Other workers who were properly 

monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 68 119 98 106 81 105 12

Not sampled 28 30 45 32 27 31 9
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 48 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-13. Work performed by ESH that was properly monitored (Sampled). 

Table B-13. Data for Figure B-13, Work performed by ESH that was 

properly monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 789 886 539 972 936 986 29

Not sampled 9 20 24 32 5 10 1
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 49 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-14. ESH workers who were properly monitored (Sampled). 

Table B-14. Data for Figure B-14, ESH workers who were properly 

monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 66 89 75 86 78 79 25

Not sampled 7 14 17 20 3 7 1
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 50 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-15. Work performed by NMT that was properly monitored (Sampled). 

Table B-15. Data for Figure B-15, Work performed by NMT that was 

properly monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 662 706 237 927 1,206 1,213 33

Not sampled 10 4 6 16 12 2 1
Document No. ORAUT-RPRT-0102 Revision No. 00 Effective Date: 12/02/2021 Page 51 of 51

ATTACHMENT B 

GROUP-SPECIFIC COMPLIANCE WITH RADIOLOGICAL WORK PERMITS (continued)

Figure B-16. NMT workers who were properly monitored (Sampled). 

Table B-16. Data for Figure B-16, NMT workers who were properly 

monitored (Sampled). 

Type 1996 1997 1998 1999 2000 2001 2002

Sampled 253 263 125 303 358 329 34

Not sampled 2 2 6 9 9 2 1