SEC Petition Evaluation Report
 

Petition SEC-00109 

Report Rev #: 0 Report Submittal Date: January 22, 2009 

Subject Expert(s): Chris Miles, John Fix, Don Stewart, Ray Clark, Rowena Argall, Robert Burns, 

Elizabeth Brackett 

Site Expert(s): N/A 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition 

Qualification Date 

DOE/AWE Facility Name 

SEC-00109 83.13 May 29, 2008 Los Alamos National Laboratory (LANL) 

Petitioner Class Definition 

Service Support Workers (which includes, but is not limited to, security guards, firefighters, laborers, 

custodians, carpenters, plumbers, electricians, pipefitters, sheet metal workers, ironworkers, welders, 

maintenance workers, truck drivers, delivery persons, rad technicians, and area work coordinators) who worked 

in any operational Technical Areas with a history of radioactive material use at the Los Alamos National 

Laboratory from January 1, 1976 through December 31, 2005. 

Class Evaluated by NIOSH 

Service Support Workers (which includes, but is not limited to, security guards, firefighters, laborers, 

custodians, carpenters, plumbers, electricians, pipefitters, sheet metal workers, ironworkers, welders, 

maintenance workers, truck drivers, delivery persons, rad technicians, and area work coordinators) who worked 

in any operational Technical Areas with a history of radioactive material use at the Los Alamos National 

Laboratory from January 1, 1976 through December 31, 2005. 

NIOSH-Proposed Class(es) to be Added to the SEC 

None 

Related Petition Summary Information 

SEC Petition Tracking #(s) Petition Type DOE/AWE Facility Name Petition Status 

None 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

SEC Petition Evaluation Report, SEC-00051 LANL 

SEC Petition Evaluation Report, SEC-00061 LANL 
SEC-00109 01-22-09 FINAL LANL
 

ORAU Lead Technical Evaluator: Chris Miles ORAU Review Completed By: Dan Stempfley 

Peer Review Completed By: [Signature on file] 

Gregory Macievic 

1/22/2009 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 

J. W. Neton 

1/22/2009 

Date 

SEC Evaluation Approved By: [Signature on file] 

Larry Elliott 

1/22/2009 

Date 

2 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Evaluation Report Summary: SEC-00109 

Los Alamos National Laboratory (LANL) 

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as 

Members of the Special Exposure Cohort under the Energy Employees Occupational Illness 

Compensation Program Act of 2000. 

Petitioner-Requested Class Definition 

Petition SEC-00109, qualified on May 29, 2008, requested that NIOSH consider the following class: 

Service Support Workers (which includes, but is not limited to, security guards, firefighters, laborers, 

custodians, carpenters, plumbers, electricians, pipefitters, sheet metal workers, ironworkers, welders, 

maintenance workers, truck drivers, delivery persons, rad technicians, and area work coordinators) 

who worked in any operational Technical Areas with a history of radioactive material use at the Los 

Alamos National Laboratory from January 1, 1976 through December 31, 2005. 

Class Evaluated by NIOSH 

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

the following class: Service Support Workers (which includes, but is not limited to, security guards, 

firefighters, laborers, custodians, carpenters, plumbers, electricians, pipefitters, sheet metal workers, 

ironworkers, welders, maintenance workers, truck drivers, delivery persons, rad technicians, and area 

work coordinators) who worked in any operational Technical Areas with a history of radioactive 

material use at the Los Alamos National Laboratory from January 1, 1976 through December 31, 

2005. 

NIOSH-Proposed Class(es) to be Added to the SEC 

Based on its full research of the class under evaluation, NIOSH has obtained numerous documents 

containing monitoring results as well as LANL process and source information. LANL has provided 

monitoring data summaries from its employee exposure records databases, and site personnel have 

been interviewed. Employee-specific information provided through the EEOICPA claims process and 

Technical Basis Documents written by NIOSH have also been available for this evaluation. Based on 

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

it cannot estimate radiation doses with sufficient accuracy. 

3 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Feasibility of Dose Reconstruction 

Per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it has access to sufficient 

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

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

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

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

document or estimate the maximum internal and external potential exposure to members of the 

proposed class under plausible circumstances during the specified period. 

Health Endangerment Determination 

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is not required 

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

the proposed class. 

4 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Table of Contents 

Evaluation Report Summary: SEC-00109 Los Alamos National Laboratory (LANL) .......................... 3 

1.0 Purpose and Scope.......................................................................................................................... 9 

2.0 Introduction .................................................................................................................................... 9 

3.0 SEC-00109 Site Name Class Definitions ..................................................................................... 10 

3.1 Petitioner-Requested Class Definition and Basis ................................................................ 10 

3.2 Class Evaluated by NIOSH ................................................................................................. 12
 

3.3 NIOSH-Proposed Class(es) to be Added to the SEC .......................................................... 12 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ........................................................... 13 

4.1 Site Profile Technical Basis Documents (TBDs) ................................................................ 13 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures ..................................... 14 

4.3 Facility Employees and Experts .......................................................................................... 14 

4.4 Previous Dose Reconstructions ........................................................................................... 15 

4.5 NIOSH Site Research Database .......................................................................................... 15 

4.6 Other Technical Sources...................................................................................................... 16 

4.7 Documentation and/or Affidavits Provided by Petitioners ................................................. 17 

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 18 

5.1 LANL Plant and Process Descriptions ................................................................................ 18 

5.2 Radiological Exposure Sources from LANL Operations .................................................... 19 

5.2.1 Internal Radiological Exposure Sources from LANL Operations .......................... 19 

5.2.1.1 Plutonium ................................................................................................. 20 

5.2.1.2 Hydrogen-3 (Tritium) ............................................................................... 20 

5.2.1.3 Uranium.................................................................................................... 20 

5.2.1.4 Mixed Fission and Activation Products ................................................... 20 

5.2.1.5 Strontium-90/Yttrium-90.......................................................................... 20 

5.2.1.6 Thorium-230 ............................................................................................. 20 

5.2.1.7 Thorium-232 ............................................................................................. 20 

5.2.1.8 Americium-241......................................................................................... 20 

5.2.1.9 Neptunium-237 ......................................................................................... 20 

5.2.1.10 Actinium-227............................................................................................ 20 

5.2.1.11 Protactinium-231 ...................................................................................... 20 

5.2.1.12 Curium-244............................................................................................... 20 

5.2.2 External Radiological Exposure Sources from LANL Operations ......................... 20 

5.2.2.1 Photon....................................................................................................... 20 

5.2.2.2 Beta........................................................................................................... 20 

5.2.2.3 Neutron ..................................................................................................... 20 

5.2.3 Incidents .................................................................................................................. 20 

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 20 

6.1 Available LANL Internal Monitoring Data......................................................................... 20 

6.2 Available LANL External Monitoring Data........................................................................ 20 

5 of 77 
SEC-00109 01-22-09 FINAL LANL
 

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 20 

7.1 Pedigree of LANL Data....................................................................................................... 20 

7.1.1 Internal Monitoring Data Pedigree Review............................................................. 20 

7.1.2 External Monitoring Data Pedigree Review............................................................ 20 

7.2 Evaluation of Bounding Internal Radiation Doses at LANL .............................................. 20 

7.2.1 Evaluation of Bounding Process-Related Internal Doses........................................ 20 

7.2.1.1 Urinalysis Information and Available Data.............................................. 20 

7.2.1.2 Lung and Whole Body Counting Information and Available Data.......... 20 

7.2.1.3 Other Types of Intake Monitoring............................................................ 20 

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses........................... 20 

7.2.3 Methods for Bounding Internal Dose at LANL ...................................................... 20 

7.2.3.1 Methods for Bounding Operational Period Internal Dose........................ 20 

Application of Co-Worker Data for Internal Dose Reconstruction......................... 20 

7.2.3.2 Bounding Methods by Radionuclide ........................................................ 20 

7.2.3.3 Methods for Bounding Ambient Environmental Internal Dose ............... 20 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion ............................................. 20 

7.3 Evaluation of Bounding External Radiation Doses at LANL ............................................. 20 

7.3.1 Evaluation of Bounding Process-Related External Doses....................................... 20 

7.3.2 Evaluation of Bounding Ambient Environmental External Doses.......................... 20 

7.3.3 LANL Occupational X-Ray Examinations ............................................................. 20 

7.3.5 External Dose Reconstruction Feasibility Conclusion ............................................ 20 

7.4 Evaluation of Petition Basis for SEC-00109 ....................................................................... 20 

7.4.1 Cerro Grande Fire.................................................................................................... 20 

7.4.2 Sigma Americium Contamination Incident ............................................................. 20 

7.4.3 Neptunium Special Hazards .................................................................................... 20 

7.4.4 LANL 7776 TLDS and Neutron Correction Factors............................................... 20 

7.4.5 LANL Contamination Surveys, Postings, and Control ........................................... 20 

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the Evaluation ...... 20 

7.6 Summary of Feasibility Findings for Petition SEC-00109.................................................. 20 

8.0 Evaluation of Health Endangerment for Petition SEC-00109...................................................... 20 

9.0 NIOSH-Proposed Class for Petition SEC-00109 ......................................................................... 20 

10.0 References .................................................................................................................................... 20 

Attachment 1: Documentation Provided by Petitioner.......................................................................... 20 

6 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Tables 

4-1: No. of LANL Claims Submitted Under the Dose Reconstruction Rule ........................................ 15 

5-1: Potential Contributors to LANL Internal Dose and Their Primary Modes of Decay .................... 20 

6-1: Number of Records in the LANL in vivo Database ...................................................................... 20 

6-2: Number of LANL Urinalysis Samples, 1976-2004 ....................................................................... 20 

6-3: Dose Data Types Recorded Over Time ......................................................................................... 20 

6-4: Annual External Radiation Doses (1976-2005) ............................................................................. 20
 

6-5: LANL Recorded Gamma Dose > 50 mrem ................................................................................... 20 

6-6: LANL Recorded Shallow Dose > 50 mrem ................................................................................... 20 

6-7: LANL Recorded Neutron Dose > 50 mrem ................................................................................... 20 

7-1: Zia Employee Access to Plutonium Areas..................................................................................... 20 

7-2: Summary of Feasibility Findings for SEC-00109.......................................................................... 20 

7 of 77 
SEC-00109 01-22-09 FINAL LANL
 

This page intentionally left blank 

8 of 77 
 

 

 

SEC-00109 01-22-09 FINAL LANL
 

SEC Petition Evaluation Report for SEC-00109
 

1.0 Purpose and Scope 

This report evaluates the feasibility of reconstructing doses for Service Support Workers (which 

includes, but is not limited to, security guards, firefighters, laborers, custodians, carpenters, plumbers, 

electricians, pipefitters, sheet metal workers, ironworkers, welders, maintenance workers, truck 

drivers, delivery persons, rad technicians, and area work coordinators) who worked in any operational 

Technical Areas with a history of radioactive material use at the Los Alamos National Laboratory 

from January 1, 1976 through December 31, 2005. It provides information and analyses germane to 

considering a petition for adding a class of employees to the congressionally-created SEC. 

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

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

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

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83, 

and the guidance contained in the Office of Compensation Analysis and Support’s (OCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004. 

2.0 Introduction 

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

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

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

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

reconstructions.1 

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

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

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

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

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

estimate of the maximum radiation dose. 

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

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

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

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

members of a class when it has been established that the class may have been exposed to radiation 

during a discrete incident likely to have involved levels of exposure similarly high to those occurring 

1

 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 

9 of 77 
 

 

 

SEC-00109 01-22-09 FINAL LANL
 

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

who were employed for at least 250 aggregated work days within the parameters established for the 

class or in combination with work days within the parameters established for other SEC classes 

(excluding aggregate work day requirements). 

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

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

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

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

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.2 

3.0 SEC-00109 Site Name Class Definitions 

The following subsections address the evolution of the class definition for SEC-00109, Los Alamos 

National Laboratory (LANL). When a petition is submitted by a claimant, the requested class 

definition is evaluated as submitted. If the available site information and data justify a change in the 

petitioner’s class definition, NIOSH will specify a modified class to be fully evaluated. After a 

complete analysis, NIOSH will determine whether to propose a class for addition to the SEC and will 

specify that proposed class definition. 

3.1 Petitioner-Requested Class Definition and Basis 

Petition SEC-00109, qualified on May 29, 2008, requested that NIOSH consider the following class 

for addition to the SEC: Service Support Workers (which includes, but is not limited to, security 

guards, firefighters, laborers, custodians, carpenters, plumbers, electricians, pipefitters, sheet metal 

workers, ironworkers, welders, maintenance workers, truck drivers, delivery persons, rad technicians, 

and area work coordinators) who worked in any operational Technical Areas with a history of 

radioactive material use at the Los Alamos National Laboratory from January 1, 1976 through 

December 31, 2005. 

2 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas. 

10 of 77 
SEC-00109 01-22-09 FINAL LANL
 

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

accurate dose reconstruction over time is impossible for the LANL workers in question. NIOSH 

deemed the following information and affidavit statements sufficient to qualify SEC-00109 for 

evaluation: 

In the narrative attached to the petition, the petitioner points out that, when evaluating LANL 

petition SEC-00051 (covering 1943 through 1975), NIOSH determined “that the available 

monitoring records, process descriptions, and source-term data are not sufficient to complete dose 

reconstructions for the proposed class of employees, at a minimum, through December 31, 1975.” 

The petitioner asserts that the evaluation report (ER) indicates that data are insufficient for dose 

reconstruction after 1975. The petitioner provided a large amount of documentation to support this 

assertion (a listing is provided in Attachment 1). In the SEC-00051 ER, NIOSH did note that “the 

potential for monitored and unmonitored intakes has existed throughout the history of the site.” 

NIOSH also recognized that potential dose reconstruction issues may exist for the post-1975 

period (e.g., internal dose assessment for mixed fission products). On this basis, NIOSH 

determined that this current petition (SEC-00109) qualifies for further evaluation. The petitioner 

also reported on a meeting of the Advisory Board in which NIOSH staff stated that there are “still 

issues on the table after 1975” and that “evaluation of the mixed fission products and a few of the 

other issues past 1975” would continue in order to determine if additional years need to be added 

to the SEC class. (Petition, 2008) 

The petitioner also provided ten affidavits (listed in Section 4.7). A number of these affidavits 

asserted that Service Support Workers with inadequate or no PPE were routinely assigned to areas 

in which workers were using full PPE. They also asserted that these Service Support Workers had 

little or no participation in the LANL urine sampling or whole-body counting program. Because 

this petition qualified for further evaluation based on the issues discussed in the preceding 

paragraph, these affidavit statements will be considered during the evaluation. 

Based on its LANL research and data capture efforts, NIOSH determined that it has access to chest 

counts, whole-body counts, bioassay results, urinalysis results, external dosimetry data, and air 

monitoring data for LANL workers during the time period under evaluation. However, NIOSH also 

acknowledged that certain issues raised during the research for SEC-00051 remain unresolved, in 

particular the assessment of dose from mixed fission products. NIOSH concluded that there is 

sufficient documentation to support, for at least part of the proposed time period, the petition basis 

that radiation exposures and radiation doses were not adequately monitored at LANL, either through 

personal monitoring or area monitoring. The information and statements provided by the petitioner 

qualified the petition for further consideration by NIOSH, the Board, and HHS. The details of the 

petition basis are addressed in Section 7.4. 

11 of 77 
SEC-00109 01-22-09 FINAL LANL
 

3.2 Class Evaluated by NIOSH 

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

defined the following class for further evaluation: Service Support Workers (which includes, but is not 

limited to, security guards, firefighters, laborers, custodians, carpenters, plumbers, electricians, 

pipefitters, sheet metal workers, ironworkers, welders, maintenance workers, truck drivers, delivery 

persons, rad technicians, and area work coordinators) who worked in any operational Technical Areas 

with a history of radioactive material use at the Los Alamos National Laboratory from January 1, 

1976 through December 31, 2005. 

3.3 NIOSH-Proposed Class(es) to be Added to the SEC 

Based on its research, NIOSH has obtained numerous documents containing monitoring results as 

well as LANL process and source information. LANL has provided monitoring data summaries from 

its employee exposure records databases, and site personnel have been consulted. Employee-specific 

information provided through the EEOICPA claims process and Technical Basis Documents written 

by NIOSH have also been available for this evaluation. 

NIOSH also addressed certain unresolved issues raised during the research for SEC-00051, in 

particular the assessment of dose from mixed fission products. In the SEC-00051 evaluation, NIOSH 

noted that whole-body counting started about 1970. The evaluation also stated that “...some 

radionuclide maximum intakes possibly could be inferred from the chest counting data. However, at 

the time of this report, an analysis of this technique has not been performed.” 

Furthermore, at the time of the SEC-00051 report, NOSH lacked the information or methods to 

support bounding at least some of the internal doses for the more “exotic” radionuclides. The term 

“exotics” is used to include everything other than U-234/235/238, Pu-238/239, tritium, Am-241, and 

Cs-137. This would include Sr-90, Th-232, Cm-244, Ac-227, Pa-231, Np-237, and others. This 

resulted in a recommendation to add a class to the SEC. Because SEC-00051 had the “gray” area for 

reconstructing internal dose from 1970-75, the decision was to recommend the class to 1975 (the 

petitioner’s proposed end date), continue the review and evaluation efforts for the post-1975 time 

period, and report to the Board on the findings. 

Since the SEC-00051 presentation, SEC-00109 was filed for the post-1975 period. With the 

subsequent capture of additional LANL documents and data, NIOSH believes that it has sufficient 

information to support bounding all internal doses for the SEC-00109 class, including the exotics that 

were the limiting factors in SEC-00051. SEC-00109 research resulted in information that clarifies the 

1970-75 “gray” area, with the conclusion that available dose information now provides much stronger 

support for the ability to reconstruct internal dose for the 1970-75 period with sufficient accuracy. 

However, because a decision had already been made for the 1970-75 time period (per SEC-00051), 

further consideration of the reconstruction of that dose is irrelevant to the SEC-00109 evaluation. 

Based on its analysis of the available resources, NIOSH found no part of the class under evaluation for 

which it cannot estimate radiation doses with sufficient accuracy. 

12 of 77 
SEC-00109 01-22-09 FINAL LANL
 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class 

NIOSH identified and reviewed numerous data sources to find information relevant to determining the 

feasibility of dose reconstruction for the class of employees under evaluation. This included 

determining the availability of information on personal monitoring, area monitoring, industrial 

processes, and radiation source materials. The following subsections summarize the data sources 

identified and reviewed by NIOSH. 

4.1 Site Profile Technical Basis Documents (TBDs) 

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

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

dosimetry data for monitored and unmonitored workers, and to supplement, or substitute for, 

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

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

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

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

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

LANL operations or related topics/operations at other sites: 

•	 TBD for the Los Alamos National Laboratory – Introduction, ORAUT-TKBS-0010-1; Rev. 01; 

October 1, 2007; SRDB Ref ID: 35193 

•	 TBD for the Los Alamos National Laboratory – Site Description, ORAUT-TKBS-0010-2; Rev. 

00; May 7, 2004; SRDB Ref ID: 19561 

•	 TBD for the Los Alamos National Laboratory – Occupational Medical Dose, ORAUT-TKBS0010-3; Rev. 00; December 29, 2004; SRDB Ref ID: 19562 

•	 TBD for the Los Alamos National Laboratory – Occupational Environmental Dose, ORAUTTKBS-0010-4; Rev. 00; October 8, 2004; SRDB Ref ID: 19564 

•	 TBD for the Los Alamos National Laboratory – Occupational Internal Dose, ORAUT-TKBS0010-5; Rev. 00; December 21, 2004; SRDB Ref ID: 19565 

•	 TBD for the Los Alamos National Laboratory – Occupational External Dose, ORAUT-TKBS0010-6; Rev. 01; May 30, 2007; SRDB Ref ID: 32018 

13 of 77 
SEC-00109 01-22-09 FINAL LANL
 

4.2 ORAU Technical Information Bulletins (OTIBs) and Procedures 

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

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

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

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

reviewed the following OTIBs as part of its evaluation: 

•	 OTIB: Analysis of Coworker Bioassay Data for Internal Dose Assignment, ORAUT-OTIB-0019, 

Rev. 01; October 7, 2005; SRDB Ref ID: 19438 

•	 OTIB: Fission and Activation Product Assignment for Internal Dose-Related Gross Beta and 

Gross Gamma Analyses, ORAUT-OTIB-0054, Rev. 00 PC-1, November 19, 2007;SRDB Ref ID: 

36235 

•	 OTIB: Internal Dosimetry Coworker Data for Los Alamos National Laboratory, ORAUT-OTIB0062, draft; SRDB Ref ID: Not currently available in the SRDB 

•	 OTIB: Los Alamos National Laboratory Bioassay Data Project Final Report; ORAUT-OTIB0063, draft; SRDB Ref ID: Not currently available in the SRDB 

•	 PROC: Occupational Onsite Ambient Dose Reconstruction for DOE Sites, ORAUT-PROC-0060, 

Rev. 01; June 28, 2006; SRDB Ref ID: 29986 

•	 PROC: Occupational X-Ray Dose Reconstruction for DOE Sites, ORAUT-PROC-0061, Rev. 02; 

January2, 2008; SRDB Ref ID: 39338 

4.3 Facility Employees and Experts 

NIOSH talked with current LANL technical staff concerning additional data capture that was 

subsequently performed: 

•	 Conference call: ORAU Team and NIOSH with LANL Radiation Protection Division Personnel; 

August 7, 2008; SRDB Ref ID: 55742 

•	 Conference call: ORAU Team and NIOSH with LANL Radiation Protection Division Personnel; 

August 28, 2008; SRDB Ref ID: 55741 

•	 Conference call: ORAU Team and NIOSH with LANL Radiation Protection Division Personnel; 

September 9, 2008; SRDB Ref ID: 55744 

14 of 77 
SEC-00109 01-22-09 FINAL LANL
 

4.4 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH OCAS Claims Tracking System (NOCTS) to locate EEOICPA-related 

dose reconstructions that might provide information relevant to the petition evaluation. Table 4-1 

summarizes the results of this review. (NOCTS data available as of December 29, 2008) 

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

Description Totals 

Total number of claims submitted for dose reconstruction 629 

Total number of claims submitted for energy employees who meet the definition criteria for the class 

under evaluation (January 1, 1976 through December 31, 2005). 331 

Number of dose reconstructions completed for energy employees who meet the definition criteria for 

the class under evaluation (i.e., the number of such claims completed by NIOSH and submitted to the 

Department of Labor for final approval). 161 

Number of claims for which internal dosimetry records were obtained for the identified years in the 

evaluated class definition 244 

Number of claims for which external dosimetry records were obtained for the identified years in the 

evaluated class definition 308 

NIOSH reviewed each claim to determine whether internal and/or external personal monitoring 

records could be obtained for the employee. As indicated in Table 4-1, NIOSH has been able to 

obtain monitoring data for many of the claims that meet the proposed class definition. Of the total 

number of claims submitted for energy employees who meet the class under evaluation, 244 (74%) 

contain internal monitoring data and 308 (93%) contain external monitoring data. 

The telephone interviews conducted with individual LANL claimants for dose reconstruction purposes 

provided additional detailed information regarding work locations, hours worked, incidents, and 

hazards encountered. The interviews also identified conditions for which there would have been 

potential for either internal or external exposures. 

4.5 NIOSH Site Research Database 

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

evaluation of the proposed class. Two thousand one hundred six (2106) documents in this database 

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

petition. The documents include historical background on external and internal dosimetry programs 

and evaluations, monitoring reports, annual environmental reports, reviews and assessments of LANL, 

evaluations of specific buildings, site surveys, and facility and process descriptions. 

15 of 77 
SEC-00109 01-22-09 FINAL LANL
 

4.6 Other Technical Sources 

NIOSH reviewed the following technical sources in support of the evaluation of the proposed class: 

•	 Tritium Calculations with IMBA, OCAS-TIB-002, Office of Compensation Analysis and Support, 

Technical Information Bulletin, April 22, 2003; SRBD Ref ID: 22407 

•	 Overview of Los Alamos National Laboratory - 1997, LA-UR-97-4765; LANL Environment, 

Safety, and Health Division; 1998; SRDB Ref ID: 27224 

•	 Internal Dosimetry and Dose Assessment at Los Alamos National Laboratory, Inkret, W. C., 

LANL; 1993; SRDB Ref ID: 14522 

•	 Air Monitoring and Its Evolution at the LASL Plutonium Facility, LA-4076; LASL; 1969; SRDB 

Ref ID: 27223 

•	 History of LANL’s Bioassay Program from Inception to 1993, LA-UR-05-1942; Clark, M. J.; 

LANL; 2005; SRDB Ref ID: 17157 

•	 Brief History of Biological Monitoring and Dose Assessment for Tritium at Los Alamos, LANL, 

1987; SRDB Ref ID: 14512 

•	 Compendium of Reports on Various Nuclides, Work Groups and Operations, Circa 1945, LASL; 

1946; SRDB Ref ID: 14878 

•	 Evaluation of Polonium-210 Exposure for Termination Reports, LANL, 1979. SRDB Ref ID: 

14519 

•	 Interim Report of the Los Alamos Historical Document Retrieval and Assessment (LAHDRA) 

Project, ChemRisk et al.; Version 3B; July 27, 2004; SRDB RefID: 27260 

•	 Evaluation of Continuous Air Monitor Placement in a Plutonium Facility, J. J. Whicker, J. C. 

Rodgers, C. I. Fairchild, R. C. Scripsick, and R. C. Lopez; Health Physics, Volume 72, pp. 734– 

743; 1997; SRDB Ref ID: 13095 

•	 Relationship of Air Sample Measurements to Internal Dose: A Review, J. J. Whicker; Health 

Physics Society Midyear Topical Meeting; 2004; SRDB Ref ID: 13096 

•	 In Vivo Assessment of Whole Body Radioisotope Burdens at the Los Alamos National Laboratory, 

D. G. Vasilik and I. C. Aikin; LA-9858-MS, Los Alamos National Laboratory; 1983: SRDB Ref 

ID: 925 

•	 Internal memorandum, Health Protection of Maintenance Personnel Working in Contaminated 

Areas, J. F. Tribby; Los Alamos Scientific Laboratory; May 14, 1946; SRDB Ref ID: 27980 

•	 Los Alamos National Laboratory (LANL) Bioassay Data Project Final Report, J. M. O’Brien; 

Shonka, Inc.; Atlanta, Georgia; June, 2006; SRDB Ref ID: 49287 

16 of 77 
SEC-00109 01-22-09 FINAL LANL
 

•	 Identifying Uranium Intakes from Bioassay Data in the Presence of Environmental Background, 

T. T. Little, G. Miller, and R. Guilmette; Proceedings of the 49th Annual Radiobioassay & 

Radiochemical Measurements Conference; 2003; http://www.bioassay.org/2003; SRDB Ref ID: 

12939
 

•	 Health Physics Checklist, http://eshdb.lanl.gov/~esh12/new_eshdb/Matrices, accessed April 30, 

2004; SRDB Ref ID: 12969 

•	 Tiger Team Assessment of the Los Alamos National Laboratory, U.S. Department of Energy; 

November 1991; SRDB Ref ID: 23620 

•	 E-mail correspondence, LANL Lab Notebooks, J. Buddenbaum; ENSR|AECOM; Westford, 

Massachusetts; September 1, 2006; SRDB Ref ID: 27995 

•	 Conference Call Minutes, Final, J. Buddenbaum; ENSR|AECOM; Westford, Massachusetts; 

February 13, 2006; SRDB Ref ID: 27992
 

•	 Los Alamos National Laboratory Radiological Dose Assessment – Tritium Internal Dosimetry, W. 

C. Inkret, D. Lewis, G. Miller, and M. E. Schillaci; LA-UR-99-838; Los Alamos National 

Laboratory; 1999; SRDB Ref ID: 12899 

•	 Los Alamos National Laboratory Radiological Dose Assessment – Tritium Internal Dosimetry and 

Bioassay Programs, Inkret, W. C., D. Lewis, T. T. Little, G. Miller, and M. E. Schillaci, 

LA-UR-99-832; Los Alamos National Laboratory; 1998; SRDB Ref ID: 13485 

•	 Los Alamos National Laboratory Radiological Dose Assessment – Americium Internal Dosimetry 

and Bioassay Program, W. C. Inkret, D. Lewis, G. Miller, and M. E. Schillaci; LA-UR-99-836; 

Los Alamos National Laboratory; 1998; SRDB Ref ID: 13488 

4.7 Documentation and/or Affidavits Provided by Petitioners 

In qualifying and evaluating the petition, NIOSH reviewed a large number of documents submitted by 

the petitioners. These documents are in the file of supporting documents submitted with the 

SEC-00109 Petition (OSA Ref ID: 105765); the document titles and/or descriptions are listed in 

Attachment 1. This same file also contains the following ten affidavits from workers or survivors: 

•	 Affidavit from D&D Laborer, February 13, 2008; pdf pp. 213-214 

•	 Affidavit from Security Officer, March 24, 2008; pdf pp. 173-175 

•	 Affidavit from Assembly Technician, April 12, 2005; pdf pp. 204-208 

•	 Affidavit from Laborer (unspecified), June 6, 2006; pdf pp. 211-212 

•	 Affidavit from Survivor of Uncle who worked as Chemical Plant Operator, Prototype Machinist, 

and Plant Engineering Technician; February 28, 2007; pdf pp. 215-216 

17 of 77 
SEC-00109 01-22-09 FINAL LANL
 

•	 Affidavit from Engineer-Operator, March 18, 2008; pdf pp. 186-199 

•	 Affidavit from Electrician, June 21, 2006; pdf p. 176 

•	 Affidavit from Custodial Worker, February 12, 2008; pdf pp. 209-210 

•	 Affidavit from current staff member of the Office of Nuclear Worker Advocacy (State of New 

Mexico) and former LANL administrative worker; also documenting work history of deceased 

father who worked as a Truck Driver; March 21, 2008; pdf pp. 177-181 

•	 Affidavit from Radiation Technician, April 12, 2005; pdf pp. 200-203 

5.0 Radiological Operations Relevant to the Class Evaluated by 

NIOSH 

The following subsections summarize both radiological operations at the LANL from January 1, 1976 

through December 31, 2005 and the information available to NIOSH to characterize particular 

processes and radioactive source materials. From available sources NIOSH has gathered process and 

source descriptions, information regarding radionuclides of concern, and information describing 

processes through which radiation exposures may have occurred and the physical environment in 

which they may have occurred. The information included within this evaluation report is intended 

only to be a summary of the available information. 

5.1 LANL Plant and Process Descriptions 

ATTRIBUTION: Section 5.1 was completed by Chris Miles, Quantaflux, LLC. These conclusions 

were peer-reviewed by the individuals listed on the cover page. The rationales for all conclusions in 

this document are explained in the associated text. 

NOTE: The LANL Evaluation Report for Petition SEC-00051 (covering 1943 through 1975) provides 

a detailed historical description of the LANL site. Additional information can also be found in the 

Site Description TBD of the Site Profile, ORAUT-TKBS-0010-2. The following discussion focuses 

on the time period currently under evaluation (1976 through 2005). 

Nuclear weapons-related activities have been the primary function of LANL since the laboratory was 

established in 1943. Since that time until 2006, including the entire period covered by this evaluation, 

the laboratory was managed by the University of California. Work with radioactive materials in the 

very early years involved primarily plutonium, enriched uranium, and fission products. Since those 

early years through the present time, the site has been performing a variety of activities involving a 

wide array of radioactive materials, nuclear reactors, accelerators, and other machines that generate 

ionizing radiation. 

18 of 77 
SEC-00109 01-22-09 FINAL LANL
 

To accomplish its mission, LANL was divided into a number of physically separate Technical Areas 

(TAs) which spread in time over a relatively large area. These TAs and locations, along with their 

significant radiation sources, are briefly described in Table 5-1 of the Evaluation Report for Petition 

SEC-00051. 

The LANL site’s main functional areas include: 

• Weapons Development and Testing 

• Critical Assemblies, Reactors, and Reactor Development 

• Accelerators, X-ray Equipment, and Radiography Sources 

• Biomedical Research 

• Project Sherwood and Fusion Research 

• Waste Treatment and Disposal 

Overviews of each of these functional areas are presented in Section 5.2 of the SEC-00051 Evaluation 

Report. More detailed information on TAs and functional areas is also available in ORAUT-TKBS0010-2. 

5.2 Radiological Exposure Sources from LANL Operations 

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

LANL class under evaluation. 

5.2.1 Internal Radiological Exposure Sources from LANL Operations 

ATTRIBUTION: Section 5.2.1 and its related subsections were completed by Chris Miles, Quantaflux, 

LLC. These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

In the SEC-00051 Petition Evaluation Report, data deficiencies for mixed fission and mixed activation 

products, Am-241 (separated from plutonium), Th-232, Th-230, Ac-227, Pa-231, Np-237, and 

Cm-244 were identified for the 1970 through 1975 time period. NIOSH subsequently recognized that 

these internal dose reconstruction issues may also exist for the post-1975 period. On this basis, 

NIOSH determined that this current petition (SEC-00109) qualified for evaluation. Potential intakes of 

these “exotic” radionuclides are therefore a focus of this evaluation report. The primary exposure 

sources (tritium, uranium, and plutonium) are also included for completeness and because, as will be 

seen later in this report, intakes of the primary sources can sometimes be used to bound intakes of the 

exotic radionuclides. 

Many of the radioactive source materials handled at LANL were alpha-particle emitters. Although 

alpha particles do not present an external exposure hazard, prevention of internal exposures to alphaemitters was recognized from the onset of site operations as the most significant radiological hazard 

protection challenge. 

There were also a variety of beta and beta-gamma-emitting radionuclides that represented potential 

internal dose hazards at LANL. Table 5-1 provides a summary of radionuclides that are recognized as 

potentially contributing to internal dose to LANL workers. This list is not all-inclusive, but it includes 

all of the more significant sources of internal radiation dose. Radionuclides that emit both alpha and 

19 of 77 
 

 

 

 

SEC-00109 01-22-09 FINAL LANL
 

beta(-gamma) are simply listed as alpha-emitters, since the alpha emission will be the predominant 

component of the internal dose. Likewise, beta-gamma emitters are simply listed as beta emitters. 

Specific TAs where various radionuclides may have been present are provided in Table 5-1 of the 

SEC-00051 Evaluation Report. 

Table 5-1: Potential Contributors to LANL Internal Dose and Their 

Primary Modes of Decay 

Radionuclide Primary Mode of Decay 

H-3 Beta 

Sr-90/Y-90 Beta 

Mixed Fission Products (MFP) Beta 

Mixed Activation Products (MAP) Beta 

Ac-227 Alpha (progeny) 

Th-230 Alpha 

Th-232 Alpha 

Pa-231 Alpha 

uranium Alpha 

Np-237 Alpha 

plutonium Alpha 

Am-241 Alpha 

Cm-244 Alpha 

5.2.1.1 Plutonium 

Freshly-separated weapons-grade plutonium is comprised of nominally 93% by weight Pu-239, 6% 

Pu-240, and less than 1% (combined) of Pu-238, Pu-241, and Pu-242. With time, Am-241 begins to 

“grow in” to the mix as Pu-241 decays. Kilogram quantities of weapons-grade plutonium have been 

handled at LANL throughout its history. 

Beginning in 1968, heat sources (radioisotope thermoelectric generators) containing primarily Pu-238 

were developed at LANL for space electric-power applications and for powering artificial organs. 

Such programs involving the use of Pu-238 have been on-going for the duration of this evaluation 

period. 

5.2.1.2 Hydrogen-3 (Tritium) 

Tritium is a primary component of thermonuclear weapons and was used extensively at LANL 

throughout the time period under evaluation. Megacurie quantities of H-3 have been handled at 

LANL. Tritium at LANL has taken several forms, including water (HTO), organically-bound tritium 

(OBT), metal tritide (MT), and gaseous hydrogen (T2 or HT). Gaseous tritium could have been 

contained as a pressurized gas or adsorbed onto various metals (e.g., uranium or palladium). 

5.2.1.3 Uranium 

Depleted and natural uranium compounds were commonly used in kilogram quantities at LANL. 

Enriched uranium and U-233 were used in critical assemblies. The U-233 contained U-232 as an 

unavoidable contaminant. 

20 of 77 
SEC-00109 01-22-09 FINAL LANL
 

5.2.1.4 Mixed Fission and Activation Products 

Mixed fission and products (MFP) and mixed activation products (MAP) are generally beta and/or 

gamma-emitters. MFP is common in reactor areas. MFP includes Cs-137, Sr-90, radioactive noble 

gases, and others. MAP is common in accelerator and reactor areas. MAP includes C-11, N-13, O15, Ar-41, Be-7, Na-22, Na-24, Co-58, Co-57, Mn-54, Mn-52, V-48, and others. 

5.2.1.5 Strontium-90/Yttrium-90 

Sr-90/Y-90 is a common component of MFP. It is also listed separately here because it is a residual 

contaminant from the radioactive lanthanum (RaLa) program, in which case it could be present in 

some areas in the absence of other mixed fission products. The RaLa program ended in 1963 (Bayo, 

1963). Residual Sr-90 contamination from the RaLa program was still present in some areas after 

1975. H-1 Health Physics Quarterly Progress Reports for October-December 1979 and JanuaryMarch 1980 discuss decommissioning activities at Ten Site involving an estimated 0.021 Ci of Sr-90 

in 260 m3

 of waste debris (Quarterly, 1979; Quarterly, 1980). A Radiological Work Permit from 1995 

addresses an asbestos removal operation involving Sr-90 contamination (RWP, 1995). 

5.2.1.6 Thorium-230 

In the 1950s, an effort was underway within the AEC complex to build a production capacity for 

Th-230 (also called “ionium”) as a potential heat source. It appears that LANL may have had some 

involvement with this effort since there were a number of bioassays conducted for Th-230 in the year 

1958. There is no evidence of its use since that time. 

5.2.1.7 Thorium-232 

According to the LANL Occupational Internal Dose TBD, casting, machining, and powder metallurgy 

were conducted with Th-232 at LANL (ORAUT-TKBS-0010-5). There is evidence of operations 

involving Th-232 beginning in the mid-1940s (Steele, 1998; SCA-TR-TASK1-0011). There are also 

indications that operations involving Th-232 continued into later years, as evidenced from an Office 

Memorandum from H-1 Division, dated October 29, 1976, titled Health Physics Aspects of Thorium. 

(Buckland, 1976). This memo compares Th-232 with depleted uranium with respect to specific 

activities. It also compares Th-232 to Pu-238 from an internal dose perspective, pointing out the 

tremendous difference between Th-232 and Pu-238 in terms of specific activity. Special Work 

Permits (SWPs) for Radiation Work from 1992 discuss operations involving Th-232 contamination 

(SWP, 1992). 

5.2.1.8 Americium-241 

As mentioned in Section 5.2.1.1, Am-241 is a component that is always present in aged 

weapons-grade plutonium. There is also evidence that operations involving purified Am-241 took 

place at LANL during the time period under evaluation (post-1975). For example, a 1982 

memorandum that discusses the criteria for routine Am-241 urine sampling states: “However, in the 

plutonium recovery process Am-241 concentrates in the residues (which contain little plutonium) such 

that the weight percent of Am-241 is much larger than initial values. These high Am-241 content 

residues may be recycled for more efficient plutonium recovery, further processed to recover the 

21 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Am-241 specifically, or prepared for recoverable storage. Personnel involved in these operations 

would be americium workers.” (Criteria, 1982). 

5.2.1.9 Neptunium-237 

Neptunium-237 was not a commonly-used radionuclide at LANL. There is, however, evidence of 

periodic operations involving Np-237 prior to 1975 and continuing to at least 2002. Approximately 

seven kg of Np-237 metal were used for a criticality experiment conducted in 2002 (Mosteller, 2003). 

A TA-55 “Radiological and Hazardous Work Permit,” dated August 30, 1994, addresses radiological 

issues for work involving Np-237 contamination (TA-55 RWP). The SEC-00109 petitioner also 

describes use of 100-gram quantities of neptunium powders (Neptunium, 2005). 

5.2.1.10 Actinium-227 

There is no indication that Ac-227 was frequently used post-1975. LANL research operations with 

Ac-227 were focused on its possible use as a “substitute” radionuclide to replace Po-210, which had a 

short half-life (DOE, 1993). The “substitute material” program was cancelled in 1955 (DOE, 1993). 

For the time period under evaluation (post-1975), only residual material would have formed a 

potential for a presumptive exposure. For example, decommissioning and decontamination of Filter 

Building 153 in 1978 (Harper, 1981) is likely to have resulted in potential exposures to Ac-227. 

5.2.1.11 Protactinium-231 

In a survey conducted by the Mound site in 1970, LANL projected its future needs for Pa-231 for the 

years 1979, 1980, and 1981, as 0.1 g, 30.1 g, and 11.0 g, respectively (Eppley, 1979). Another Mound 

site reference states that the semi-works operated at Mound from 1974 through 1979, and that during 

this time, 0.890 g of Pa-231 were produced (DOE, 1993). The end of Pa-231 processing in the 

semi-works precludes delivery of the material to LANL after 1979. Although NIOSH has been unable 

to find specific evidence of Pa-231 use at LANL, the topic is included in this section because it was 

identified in the SEC-00051 Evaluation Report as being a radionuclide for which internal dose 

reconstruction issues may exist after 1975. 

5.2.1.12 Curium-244 

There is evidence that operations involving Cm-244 took place at LANL in the 1950s (and perhaps 

into the 1960s). In an external “Radiation Exposure Follow-up” report, dated 1985, there is mention 

of a weld encapsulation operation of highly-radioactive materials, including Cm-244 (Follow-up, 

1985). 

A special dose assessment for Cm-244 was performed in 2003 because an individual’s security badge 

triggered an alarm and was found to be contaminated with Cm-244 (Little, 2003). The source of the 

contamination was one of many uncharacterized items that site personnel had packed into a cooler and 

shipped to TA-59 for pre-disposal characterization. These were legacy items that had been placed 

inside two stainless steel boxes and stored inside a shielded pit in the hot cell area of TA-48. TA-48 

personnel were engaged in an effort to identify and dispose of unnecessary material so that the hazard 

category of the facility could be reduced. Quoting the Occurrence Report (ORPS, 2003), these items 

had been stored for “tens of years (at least one sample was dated 1970’s). The owner (as indicated by 

22 of 77 
SEC-00109 01-22-09 FINAL LANL
 

labeling on the boxes) has been retired from the laboratory for some time. When contacted by TA-48 

personnel, he did not remember what might be in the boxes.” Through a series of administrative 

oversights, the individual’s badge, smock, and radiological van became contaminated by Cm-244 

when she repackaged items in the van. The presence of this legacy material supports the notion that 

operations involving Cm-244 took place at some point during the site’s history. 

5.2.2 External Radiological Exposure Sources from LANL Operations 

ATTRIBUTION: Section 5.2.2 and its related subsections were completed by Chris Miles, Quantaflux, 

LLC. These conclusions were peer-reviewed by the individuals listed on the cover page. The 

rationales for all conclusions in this document are explained in the associated text. 

Given the broad scope of activities involving ionizing radiation at LANL, workers were potentially 

exposed to external photon, beta and/or neutron radiation from a variety of sources. Potential sources 

included numerous radioactive materials, nuclear reactors, particle accelerators, and miscellaneous Xray-generating equipment. 

5.2.2.1 Photon 

Many LANL radiological operations involved gamma and X-ray photon radiation fields. Potential 

photon exposure sources to workers would have been associated with the following: 

•	 Gamma-emitting fission and/or activation products resulting from reactor and accelerator 

operations. 

•	 Uranium and associated decay progeny. 

•	 Bremsstrahlung radiation from various beta-emitting radionuclides. 

•	 X-ray-generating machines. 

•	 Plutonium and associated decay progeny 

•	 Calibration sources of americium, thorium, radium, cobalt, cesium, and other miscellaneous 

radionuclides. 

5.2.2.2 Beta 

LANL facilities during the period under evaluation involved diverse activities with an extensive beta 

particle-emitting source term. Beta radiation over a broad range of energies could have been 

encountered from: certain plutonium isotopes; uranium progeny; thorium progeny; tritium; activation 

and fission products from reactor and accelerator operations; and other radionuclides such as those 

used as calibration sources. 

Whether a beta source is considered an internal hazard or both an internal and external hazard depends 

on the maximum energy of the beta emission continuum for a given radionuclide, the shielding 

employed, and the use of protective clothing. Higher-energy beta emitters present both an external 

23 of 77 
SEC-00109 01-22-09 FINAL LANL
 

hazard (to the skin) and an internal hazard. In many cases, beta-emitting radionuclides also emit 

characteristic photons. 

5.2.2.3 Neutron 

There were several sources of potential neutron radiation exposure associated with LANL operations. 

Neutron exposures could have resulted from LANL weapons development operations, 

neutron-generating sources, criticality experiments, and operating reactors and accelerators. The 

source of the neutron emissions from these activities and potential worker exposure would have been 

associated with the following: 

•	 Spontaneous fission 

•	 Alpha-neutron (α,n) reactions particularly with low-atomic-number elements 

•	 Operating reactors 

•	 Criticality experiments with plutonium or enriched uranium 

•	 Accelerators 

•	 Neutron-generating sources, either via the α,n reaction (PuBe, RaBe, PoBe) or via spontaneous 

fission sources (Cf-252) 

The broad scope of LANL neutron-generating activities resulted in a correspondingly extensive 

neutron energy spectrum. The spectrum ranged from the thermal energy region of 0.025 eV through 

the fission spectrum of 0.1 to 6.0 MeV (predominant energy of 0.7 to 1.0 MeV), and included 

high-energy, accelerator-produced neutrons up to 20 MeV. Estimated neutron energy spectra for 

various LANL operations are in SEC-00051, Table 5-4. More detailed information is available in 

ORAUT-TKBS-0010-6. 

5.2.3 Incidents 

ATTRIBUTION: Section 5.3 was completed by Chris Miles, Quantaflux, LLC. These conclusions 

were peer-reviewed by the individuals listed on the cover page. The rationales for all conclusions in 

this document are explained in the associated text. 

After researching the historical monitoring programs and their records disposition, the LANL staff has 

provided the following accounting of incident-related records that are available: 

Hardcopy Historical Incident Files (1944 – 1991), including: 

•	 Miscellaneous event-related and monitoring records 

•	 Type A/B/C investigation reports (also available through DOE/HSS) 

•	 Radiation Occurrence Reports (RORs) (1974 – 1991) 

- Record inventory summaries for each year 

- Datatrieve entry forms for each ROR 

- Datatrieve printouts 

- Details of events and personnel involved 

- Indications whether special bioassay was performed 

•	 Radiological Incident Reports related to significant ROR events 

24 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Radiological Incident Reports (RIRs) / Radiation Protection Observations (RPOs): 

•	 Includes details of events and personnel involved 

•	 Name changed to RPO in 2005 

•	 Hardcopy for 1989-2000 in LANL archives 

•	 Hardcopy RIRs archived in: 

- Late 1980s to early 1990s: FRC (Denver) 

- Late 1980s to early 1990s: NSSB (LANL, accessible) 

- Mid 1990s-2000: TA-35 (LANL, inaccessible – in transit to NSSB 

- 2001-present: database, TA-59 

ORPS Reports (1990-present): 

•	 DOE-maintained database includes details of events, but no personal information 

Hardcopy Dose Assessment Reports (1998-present): 

•	 Includes methods, data, and results of special dose assessments 

Hardcopy Personnel Radiological Files (1944-present): 

•	 Includes any dose-related information incremental to routine dosimetry 

Electronic Bioassay Data Repository (1944-present): 

•	 Includes all bioassay results (routine, special, in vitro, in vivo) 

Internal Dosimetry Database (1944-present): 

•	 Includes bioassay and dose assessment results from Pu-238, Pu-239, Am-241, and H-3 intakes 

Personnel Dose Records (1944-present): 

•	 Internal doses for applicable individuals 

There was an attempt to comprehensively review LANL incidents in the past. In 1999, the Centers for 

Disease Control and Prevention (CDC) began the Los Alamos Historical Document Retrieval and 

Assessment (LAHDRA) project. The purpose of the LAHDRA project was to identify information 

available concerning past releases of radionuclides and chemicals at the LANL site. Millions of 

documents were reviewed; however, issues regarding access to classified information prevented 

access to all files. As a result, a large but still partial chronology of incidents was compiled. The 

following incidents are examples of incident types that occurred during the time period under 

evaluation. These incidents are drawn from Appendix L of the 2007 Interim Report of CDC’s 

LAHDRA Project (LAHDRA, 2007). 

•	 January 1, 1976: Air release – Approximately 3271 Ci of tritium was released into the 

environment. 

•	 July 15, 1976: Air Release – Tritium release of 22,000 Ci from TA-3-34. 

•	 January 1, 1977: Air Release – Approximately 6417 Ci of tritium was released into the 

environment. 

•	 October 6, 1977: Air Release – Tritium release of 33, 800 Ci from TA-33-86. 

25 of 77 
SEC-00109 01-22-09 FINAL LANL
 

•	 November 11, 1977: Fire – At the TA-54 Burial Pit, seven bales of suspect low-level radioactive 

contaminated combustible waste auto-ignited. 

•	 May 4, 1979: Air Release – Tritium release of approximately 3000 Ci from SM-34. 

•	 August 22, 1979 – Air Release – Approximately 200 grams of UF-6 was released at Building 23 

TA-18 Parajito Site. 

•	 February, 1981: Contamination Events – A total of eleven minor radiation accidents were reported 

internally. 

•	 October 14, 1981: Contamination Event – Plutonium contamination incident at TA-3, SM-29. 

•	 November, 1981: Contamination Events – A total of ten minor radiation releases were reported 

internally. 

•	 November 2, 1982: Liquid Release – Approximately 50-100 liters of waste liquid escaped from a 

tank vent at TA-21-257, contaminating the roof, walls, and surrounding area with plutonium, 

americium, and uranium. 

•	 June 1, 1983: Air Release - High airborne plutonium levels were detected in Room 429 at TA-55 

Building PF-4. 

•	 February 17, 1984: Fire – Filter bags were ignited in the TA-50 Building 1 ventilation exhaust 

plenum. 

•	 September 12, 1985: Fire – A fire in a glove box at TA55-4-429 resulted in high airborne activity 

and area contamination. 

•	 October 30, 1986: Air Release – An estimated 633 Ci of tritium were released at TA-33, mostly in 

the form of tritiated water. 

•	 February 27, 1990: Liquid Release – Cooling water overflowed into the exhaust system of 

TA-55-4. 

•	 March 1, 2000: Air Release - Eight workers at TA-55 were exposed to airborne plutonium. 

•	 May, 2000: Fire – A wild fire was ignited that ultimately burned nearly 50,000 acres in and around 

Los Alamos. This incident was cited by the petitioner (see Section 7.4.1) 

•	 July, 2005: Contamination Event - Am-241 contamination occurred at the Sigma Facility due to 

repeated handling of highly-contaminated components with no radiological controls in place. This 

incident was cited by the petitioner (see Section 7.4.1) 

26 of 77 
SEC-00109 01-22-09 FINAL LANL
 

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH 

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

monitoring data for the LANL class under evaluation. 

6.1 Available LANL Internal Monitoring Data 

ATTRIBUTION: Section 6.1 was completed by Chris Miles, Quantaflux, LLC; and Rowena Argall, 

MJW Corporation. These conclusions were peer-reviewed by the individuals listed on the cover page. 

The rationales for all conclusions in this document are explained in the associated text. 

In vivo counting equipment and techniques were developed in the late 1950s and have been in routine 

use for measuring X-ray and gamma-ray-emitting radionuclides since June 1969 (Internal Dosimetry, 

2007). There are indications that some of the counts recorded between 1955 (program onset) and the 

1960s were performed for program development rather than actual suspected intakes. NIOSH has 

been unable to locate any records of these early in vivo measurements. A detailed discussion of the 

early years of in vivo counting is provided in the ER for petition SEC-00051. 

In 1970, an in vivo counter capable of measuring four separate regions of the body began operation 

(Vasilik, 1983). Twin Phoswich (CsI and NaI) detectors were placed over the lungs. The two layers 

of the detector were capable of simultaneously, yet separately, monitoring chest burdens for 10- to 

250-keV photons (NaI), and 200- to 2,000-keV photons (CsI) for a qualitative assessment of a variety 

of fission and activation nuclides. A planar High Purity Germanium (HPGe) detector monitored the 

region between 10 and 250 keV with excellent energy resolution and could be positioned over the 

liver or thyroid as needed. Finally, an HPGe (previously a GeLi) detector was positioned under the 

prone subject. This detector was primarily for whole-body assessment. This system could both 

identify radionuclides and quantify the body burden. Pu-239 and Am-241 were a routine part of the in 

vivo analysis library for all individuals receiving lung counts. In recent years, U-235 and Th-234 (as 

U-238) were added to the routine library. Other nuclides would be identified at their corresponding 

MDA levels if they appeared in the gamma spectrum. MDAs for whole-body counting and lung 

counting by historical period are provided in Tables 5-17 and 5-19 in ORAUT-TKBS-0010-5. 

27 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Table 6-1 summarizes the records in the in vivo database for the post-1975 period, including 

non-positive results. 

Table 6-1: Number of Records in the LANL in vivo Database 

Analyte Number of Records 

(1976 forward) 

Am-241 40,966 

As-72 12 

Be-7 963 

Bi-214 12 

Br-76 61 

Br-77 64 

C-11/N-13 1,461 

Cd-109 81 

Ce-141 61 

Cf-249 14 

Cm-244 1 

Co-56 7 

Co-57 18 

Co-57/Co-58 2 

Co-58 7 

Co-60 211 

Cr-51 7 

Cs-134 189 

Cs-137 440 

Cu-64 7 

Cu-67 8 

Eu-152 507 

Fe-59 8 

“Fission Prods” 1 

Ge-67/Ga-67 1 

Ge-68/Ga-68 2 

Hf-173 4 

Hg-195m 61 

Hg-197 85 

Hg-197m 61 

Hg-203 73 

I-125 314 

I-131 12 

I-132 2 

“Mixed Activation Products” 0 

“Mixed Fission Products” 0 

Mn-54 928 

Na-22 1,321 

Na-24 25 

Nd-147 61 

Os-185 61 

P-32 0 

Pb-212 2 

Pu-238 6 

Pu-239 40,100 

Ra-226 0 

Rb-83 62 

28 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Table 6-1: Number of Records in the LANL in vivo Database 

Analyte Number of Records 

(1976 forward) 

Rb-84 61 

Sb-124 61 

Sc-46 18 

Se-72/As-72 1 

Se-75 72 

Sm-145 61 

Ta-179 69 

Te-132 1 

Th-234 2,971 

Tl-201 61 

Tl-202 62 

“Tungsten” 2 

U-235 2,974 

U-237 8 

U-238 127 

“Unidentified” 2 

V-48 9 

Zn-65 10 

Zr-95 4 

Zr-95/Nb-95 7 

Table 6-2 below shows that bioassay results are available for the development of co-worker studies 

for use in dose reconstructions. Data values for H-3, U-235, and U-238 for Jan-Jun 91 are absent 

from the static data subsets the ORAU Team derived from the LANL bioassay database. There 

appears to have been a change in record-keeping practices during that period with a modern database 

coming on line in mid-1991. In addition, there was a shift in analytical technique from Uranium 

Neutron Activation Analysis (UNAA) to Radiometric Alpha Spectroscopy (RAS). 

Although not readily available for the purpose of generating the table below, data for the year 2005 do 

exist at LANL and have been requested. Details regarding the various analyses used and the 

associated minimum detectable activities are presented in the Technical Basis Document for the Los 

Alamos National Laboratory - Occupational Internal Dose (ORAUT-TKBS-0010-5). 

29 of 77 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SEC-00109 01-22-09 FINAL LANL
 

Table 6-2: Number of LANL Urinalysis Samples, 1976-2004 

Year Am-241 H-3 Pu-238 Pu-239 Pu-240 U* U-234 U-235 U-238 

1976 963 2714 2757 1738 

1977 815 3043 3070 1780 

1978 756 2434 2441 2653 

1979 1390 2703 2713 2724 

1980 1589 2689 2711 2951 

1981 1282 3297 3328 2972 

1982 1063 2192 2211 1874 

1983 930 1998 1990 1342 

1984 1361 2172 2170 1189 

1985 1566 2086 2087 925 

1986 1492 1983 1983 822 

1987 1666 1973 1970 768 

1988 1611 1931 1927 954 

1989 1870 2197 2201 272*** 604*** 

1990 2197 2218 2219 394*** 953*** 

Jan-Jun 91 1256 1256 

Jul-Dec 91 30 1247 1099 1099 538 538 538 

1992 38 2307 2254 2254 1360 1360 1360 

1993 28 1974 2584 2584 1431 1431 1431 

1994 47 1691 2390 2390 1602 1602 1602 

1995 57 1955 1991 1991 1651 1651 1651 

1996 12 1647 1937 1948 1026 1026 1026 

1997 85 1681 1928 2434 138** 825 825 825 

1998 122 1691 2343 2668 117 829 829 829 

1999 123 1673 2085 2455 62 740 740 740 

2000 114 1623 2299 2565 67 905 905 905 

2001 133 1471 2092 2771 186 1272 1272 1272 

2002 142 1406 2206 3292 213 748 748 748 

2003 107 1427 2342 3949 1189 772 772 772 

2004 161 1260 2147 3772 1625 1109 1109 1109 

* Reported uranium samples for 1976-1988 are for non-isotopic-specific urinalysis. 

** The introduction of TIMS analysis in 1997 made the separation of Pu-240 possible. 

*** 1989 through June 1991 comprises a transition period to a new analytical technique for uranium. The uranium
 

results for U-235 and U-238 for 1989 and 1990 correspond to EU and DU. 

30 of 77 
SEC-00109 01-22-09 FINAL LANL
 

6.2 Available LANL External Monitoring Data 

ATTRIBUTION: Section 6.2 was completed by Chris Miles, Quantaflux, LLC; and Bob Burns, NGTS, 

Inc. These conclusions were peer-reviewed by the individuals listed on the cover page. The rationales 

for all conclusions in this document are explained in the associated text. 

NOTE: The following discussion focuses on the time period for the class under evaluation (1976 

through 2005). For a historical summary of the LANL external monitoring program as it developed 

from the onset of operations in 1943, see the LANL Occupational External Dose TBD (ORAUTTKBS-0010-6). That document discusses the evolution of dosimetric technology, analytical 

techniques, MDAs, calibration procedures, and methods for estimating missed dose. 

Historically, LANL had an extensive radiation safety monitoring program using portable radiation 

instruments, contamination surveys, zone controls, and personnel dosimeters for measuring exposure 

in the workplace. This program was conducted directly by, or under the guidance of, a speciallytrained group of radiation monitors or radiation protection technologists. The relevant types of 

personnel dosimetry technology in use during the time period under evaluation are listed below. 

•	 The Cycolac film badge was adopted in 1962 and used until 1978. The multi-element Cycolac 

used several filters and two film packets: a DuPont 543 packet that contained DuPont 502 dental 

film and an Eastman Kodak Type B packet that contained an NTA fast neutron film. In addition, 

it contained indium, gold, and sulfur foils for accident dosimetry. The Cycolac badge was 

improved relative to earlier LANL dosimeters and was considered to have the advantages of 

relative gamma and X-ray energy independence (within 30%) from about 30 keV to 1,400 keV, 

the ability to evaluate thermal neutrons in the presence of X- and gamma radiations below 400 

keV, and improved directional independence. 

•	 Beginning in 1978, LANL began conversion to the Model 7776 thermoluminescent dosimeter 

(TLD). The TLD had cadmium (for use in neutron radiation fields) and non-cadmium versions. It 

incorporated copper, Cycolac plastic, and cadmium filters and used three TLD-700 chips (one 

covered with copper, one with thin Cycolac plastic, and the third with thicker plastic) and one 

TLD-600 chip (enriched in 6Li). In the cadmium badge, the third TLD-700 chip and the TLD-600 

chip were shielded by cadmium pockets, as opposed to plastic covers in the non-cadmium badge. 

The changeover from film dosimeters to TLDs as the dosimeter of record was completed on 

January 1, 1980. The Model 7776 dosimeter was not designed to meet the DOELAP performance 

criteria for those categories involving low-energy beta particles or mixtures of beta and 

low-energy photons (Hoffman, 1999, pdf p. 4). 

Neutron dose determination with the Model 7776 dosimeter relied on the use of site- and 

operation-specific neutron correction factors (NCFs) to improve accuracy of the assigned neutron 

dose. TLD albedo dosimeters are sensitive to intermediate and lower-energy neutrons that other 

dosimetry methods could not detect, but their net neutron signal was highly energy-dependent and 

required the use of workplace-specific NCFs to convert the response to dose. NCFs could vary by 

more than an order of magnitude. As a consequence, NCFs that were assigned had conservative 

values; therefore, neutron doses were typically overestimated by factors of two to three 

(Blackstock, 1978). A detachable holder for NTA film was included in the Model 7776 TLD 

badge design to improve fast neutron measurement (Mallett, 1990). 

31 of 77 
 

 

 

 

 

 

 

 

 

 

 

 

SEC-00109 01-22-09 FINAL LANL
 

•	 In 1995, LANL began using the Model 8823 TLD and a Track-Etch Dosimeter (TED or PN3), 

that is sensitive only to neutron radiation and employed for special field conditions. The Model 

8823 is an improved TLD design that contains two TLD cards containing a total of 8 TLD 

sensitive elements. The TED component contains three dosimetry-grade CR-39 track-etch plastic 

foils (Hoffman, 1999, pdf p. 30). The foils are placed in a hemispherically-shaped ABS plastic 

case on the sides of a triangular polystyrene pyramid to minimize angular dependence of the TED. 

(Hoffman, 1999, pdf p. 30). The Model 8823 became the dosimeter of record for LANL on April 

1, 1998. It satisfies DOELAP performance criteria in all categories and continues in use until the 

present. 

Due to historical changes in dosimetric technology and analytical methodology, workers exposures 

have been recorded in different data types. Table 6-3 summarizes the dose data types that have been 

recorded in LANL worker exposure records over time. Interpretations of these data types for dose 

reconstruction are detailed in ORAUT-TKBS-0010-6, Attachment A. 

Table 6-3: Dose Data Types Recorded Over Time 

Period Dose Data Types Recorded in Personnel Exposure Records 

1960–1979 Gamma dose (rem) 

Beta dose (rad) 

Thermal neutron dose (rem) 

Fast neutron dose (rem) 

1980–1997 "Non-penetrating Rad" 

"Penetrating-rem" 

"Neutron-rem" 

"Total-rem" 

1998–present Beta shallow DE (mrem) 

Beta eye DE (mrem) 

Gamma shallow DE (mrem) 

Gamma deep DE (mrem) 

Gamma eye DE (mrem) 

Neutron deep DE (mrem) 

Total shallow DE (mrem) 

Total deep DE (mrem) 

Total eye DE (mrem) 

Total deep neutron DE (mrem) 

Sources: LASL, 1977; LASL, 1979; LANL, 1986; LANL, 1989; LANL, 1996; LANL, 

2001; LANL, 2003 

32 of 77 
SEC-00109 01-22-09 FINAL LANL
 

LANL has always implemented a policy of monitoring individuals with the highest potential for 

exposure. When monitoring for external radiation exposures began in 1943, PICs were assigned to “a 

few persons thought to have the highest potential for receiving exposures at or above the ‘tolerance’ 

limit” (LANL, 1986, 10/6/81 Questionnaire). By 1945, when film badges were in use by a number of 

LANL groups, only workers with the “higher exposure potentials” were issued dosimeter badges 

(LANL, 1986, 10/6/81 Questionnaire). As of 1960, film badges were worn by about half of 

University of California employees, all of the Security Force, and 75% of Zia employees (LASL, 

1969). Between 1943 and late 1981, the number of persons monitored for external exposures 

increased from less than 100/yr to more than 5,000/yr, but personnel monitoring for external radiation 

still had not been extended to all LANL workers (LANL, 1996). In the 1970s, LANL initiated an 

Employee Health Physics Checklist (LANL, 2004a). This checklist allowed the evaluation of each 

individual for potential internal and external exposure. Individuals were placed on the appropriate 

monitoring schedule based on this checklist. During the first quarter of 1976, 50 such checklists were 

completed, as evidenced by the Group H-1 Health Physics Quarterly Progress Report, January – 

March, 1976 (Quarterly, 1976). The checklist is still used and was computerized in 1998 as the 

Dosimetry Enrollment System. 

Table 6-4 lists the reported numbers of workers monitored by LANL from 1976 to 2003 along with 

total and average doses calculated from those data (LANL, 2004b). Estimates of the total number of 

workers employed at LANL each year are also presented. The estimated number of LANL workers 

for each year was obtained from a number of LANL sources; these values are quite uncertain for some 

years. Consequently, for some years the number of total workers supplied by LANL is smaller than 

the number of people who received dosimeters. Sources of workforce data for Table 6-4 included 

staff from LANL Human Resources - Workforce Data & Analysis, and Los Alamos publication 

LASL-77-25. The major source of uncertainty appears to stem from variability in the worker types 

included in the worker count each year. Worker categories include full-time regular, part-time, 

limited-term, students, subcontractors, and visitors. More recent data have worker type information 

recorded, but older data might not. 

In Table 6-4, “Average total dose” for each year is calculated as the total dose (person-rem) divided 

by the number of workers monitored (i.e., Column 2 divided by Column 3). The data have not been 

corrected for potential missed doses. 

33 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Table 6-4: Annual External Radiation Doses (1976-2005) 

Year Total Dose* 

(person-rem) 

No. of Workers Average Total 

Monitored Total Dose (rem) 

1976 393.26 5,254 6,224 0.07 

1977 432.81 5,624 6,519 0.08 

1978 364.53 7,045 7,162 0.05 

1979 320.88 7,549 7,398 0.04 

1980 375.54 7,638 5,317 0.05 

1981 588.55 7,966 8,028 0.07 

1982 672.83 7,997 7,639 0.08 

1983 673.33 8,144 7,912 0.08 

1984 798.77 8,622 8,467 0.09 

1985 715.19 9,487 9,025 0.08 

1986 531.67 9,612 9,265 0.06 

1987 400.48 9,202 9,075 0.04 

1988 391.98 9,469 9,128 0.04 

1989 326.93 10,605 9,665 0.03 

1990 228.85 10,796 10,806 0.02 

1991 163.25 11,284 11,037 0.01 

1992 132.49 11,560 11,377 0.01 

1993 141.81 11,772 11,371 0.01 

1994 178.44 11,783 11,386 0.02 

1995 234.93 12,448 11,382 0.02 

1996 188.70 10,958 11,603 0.02 

1997 182.02 10,860 12,146 0.02 

1998 158.21 11,167 12,829 0.01 

1999 128.89 11,212 13,294 0.01 

2000 87.45 10,456 12,987 0.01 

2001 114.28 10,443 13,284 0.01 

2002 160.06 10,871 14,332 0.01 

2003 218.83 10,660 10,015 0.02 

2004 113.29 10,192 13,652 0.01 

2005 149.06 10,826 13,194 0.01 

* Total Dose = deep dose + neutron dose 

** Annual dose summaries are available for all years after 2005. 

Tables 6-5, 6-6, and 6-7 below summarize the mean and maximum doses values for LANL workers 

with reported gamma, shallow, and neutron doses > 50 mrem for the years 1976 through 2004 

(partial). These data can be used to estimate unmonitored doses and to bound dose for the class. They 

can also be used to estimate reasonable values of unrecorded doses for which no records exist. The 

data upon which these tables are based do not include the potential missed dose. 

34 of 77 
Year 

SEC-00109 01-22-09 FINAL LANL
 

Table 6-5: LANL Recorded Gamma Dose > 50 mrem 

No. of Workers w/Reported Dose (mrem) 

Gamma Dose > 50 mrem Mean Maximum 

1976 952 358 3,290 

1977 921 422 4,460 

1978 938 333 3,680 

1979 779 270 1,870 

1980 666 269 1,850 

1981 832 271 2,400 

1982 821 325 2,270 

1983 1,017 296 2,160 

1984 1,513 232 2,470 

1985 733 354 1,880 

1986 527 321 1,710 

1987 420 314 2,740 

1988 428 297 1,710 

1989 436 256 1,470 

1990 340 241 2,280 

1991 298 187 1,860 

1992 221 138 565 

1993 224 140 946 

1994 215 147 689 

1995 193 126 285 

1996 267 174 600 

1997 327 200 1,210 

1998 313 192 1,090 

1999 253 158 641 

2000 215 120 596 

2001 281 169 2,130 

2002 380 186 1,370 

2003 453 250 2,350 

2004 282 155 1,230 

2005 339 157 1,266 

* Parameters can be obtained for all years after 2005. 

35 of 77 
Year 

SEC-00109 01-22-09 FINAL LANL
 

Table 6-6: LANL Recorded Shallow Dose > 50 mrem 

No. of Workers w/Reported Dose (mrem) 

Shallow Dose > 50 mrem Mean Maximum 

1976 1,231 411 3,920 

1977 1,211 476 5,470 

1978 1,183 387 3,990 

1979 1,036 283 2,330 

1980 1,087 228 2,350 

1981 1,275 253 2,930 

1982 1,191 302 2,810 

1983 1,414 274 2,750 

1984 2,269 205 2,840 

1985 1,299 263 1,970 

1986 651 303 1,820 

1987 501 314 8,890 

1988 497 290 1,820 

1989 518 249 1,470 

1990 431 237 2,550 

1991 398 188 2,042 

1992 323 144 630 

1993 349 141 962 

1994 343 143 734 

1995 345 182 657 

1996 335 174 618 

1997 466 186 1,342 

1998 390 190 1,126 

1999 311 162 1,572 

2000 250 130 611 

2001 353 165 2,133 

2002 470 179 1,381 

2003 548 236 2,352 

2004 332 156 1,230 

2005 383 164 1,291 

* Parameters can be obtained for all years after 2005. 

36 of 77 
Year 

SEC-00109 01-22-09 FINAL LANL
 

Table 6-7: LANL Recorded Neutron Dose > 50 mrem 

No. of Workers w/Reported Dose (mrem) 

Neutron Dose > 50 mrem Mean Maximum 

1976 221 118 800 

1977 162 160 990 

1978 221 125 1,370 

1979 418 198 1,380 

1980 659 242 3,390 

1981 723 415 3,970 

1982 691 519 3,700 

1983 586 555 3,790 

1984 692 517 3,930 

1985 779 538 3,390 

1986 648 524 2,920 

1987 616 409 2,270 

1988 604 408 2,450 

1989 602 326 1,510 

1990 519 249 1,690 

1991 369 248 1,523 

1992 386 212 1,569 

1993 408 217 1,651 

1994 465 248 1,515 

1995 592 265 1,705 

1996 562 206 1,465 

1997 412 206 1,374 

1998 354 198 1,370 

1999 333 207 1,451 

2000 258 158 831 

2001 272 177 1,474 

2002 331 196 1,731 

2003 411 190 1,564 

2004 314 146 842 

2005 382 165 1,584 

* Parameters can be obtained for all years after 2005. 

Details regarding the various analyses used and the associated minimum detectable activities are 

presented in the Technical Basis Document for the Los Alamos National Laboratory - Occupational 

External Dose (ORAUT-TKBS-0010-6). 

37 of 77 
SEC-00109 01-22-09 FINAL LANL
 

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH 

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

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

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

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

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

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

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

reconstructions. 

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

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

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

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

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

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

exposures experienced by groups or individual members of the class as summarized in Section 7.6. 

This approach is discussed in OCAS’s SEC Petition Evaluation Internal Procedures which are 

available at http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation 

Report examine: 

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

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

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

• The bases for petition SEC-00109 as submitted by the petitioner. (Section 7.4) 

7.1 Pedigree of LANL Data 

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

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

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

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

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

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

feasibility evaluation presupposes that data pedigree issues have been settled. 

38 of 77 
SEC-00109 01-22-09 FINAL LANL
 

7.1.1 Internal Monitoring Data Pedigree Review 

ATTRIBUTION: Section 7.1.1 was completed by Bob Burns, NGTS, Inc. These conclusions were 

peer-reviewed by the individuals listed on the cover page. The rationales for all conclusions in this 

document are explained in the associated text. 

Beginning in 2004, LANL and NIOSH representatives began a collaborative effort to retrieve and 

evaluate LANL’s historical bioassay data and capture it in an active database for on-going use. The 

master database is hosted and maintained by LANL. The ORAU Team has three static subsets of this 

database on its network: in vivo data for the period 1960-2004, in vitro data prior to 1991, and in vitro 

data for 1991-2004. These subsets result from queries of the master database designed to provide data 

for use in individual dose reconstructions and co-worker studies. The queries were performed in 

2004, but subsequent data are available from the master database. These datasets provide a readilyavailable source of bioassay results for the radionuclides considered the principal sources of internal 

radiation dose prior to, and during, the class period under evaluation. 

Based on a reconnaissance of the various databases and datasets that existed at LANL, it was decided 

to create the master bioassay database by modifying LANL’s existing Bioassay Enrollment, 

Scheduling, and Tracking (BEST) system, which already contained bioassay data from 1990 to the 

present. Modification and adaptation of the BEST system was an iterative process carried out in 

parallel with the retrieval and evaluation of historical bioassay data. Beyond the data already in the 

BEST system, the additional data incorporated into the database were derived from three principal 

sources: 

•	 In vivo data from existing and historical databases 

•	 In vitro data for americium and plutonium from a standalone database 

•	 In vitro data for tritium, uranium, and polonium (TUPo) extracted from an obsolete electronic 

archive format 

Table 6-1 presents the in vivo analytes present in the database for the period 1976-2004; Table 6-2 

presents the same information for urinalyses. There are no records for bioassay for polonium in the 

database after 1965. 

Because the in vivo data and later in vitro data had primarily been recorded electronically (and 

automatically), validation of the historical information incorporated into the database focused on the 

earlier in vitro records (i.e., TUPo data). The electronically-archived TUPo data had been entered 

from laboratory notebooks, which were the formal records for such information prior to about 1980. 

Thus, the fraction of the in vitro data obtained from lab notebooks was relatively small for the time 

period under evaluation in this report (1976-2005). Most of the in vitro data for the period were 

obtained (recorded) automatically. The LANL bioassay master database provides a readily-available 

set of bioassay results for the radionuclides considered the principal sources of internal radiation dose 

for the class period under evaluation. 

39 of 77 
SEC-00109 01-22-09 FINAL LANL
 

7.1.2 External Monitoring Data Pedigree Review 

ATTRIBUTION: Section 7.1.2 was completed by Bob Burns, NGTS, Inc. These conclusions were 

peer-reviewed by the individuals listed on the cover page. The rationales for all conclusions in this 

document are explained in the associated text. 

NIOSH has found that LANL’s policies for the collection and maintenance of employee external 

radiation monitoring data are sufficient to provide estimates of employee gamma, beta, and neutron 

dose. Radiological instrument and dosimeter measurement methods used for external exposures made 

during the evaluated timeframe were consistent with prevailing industry standards. With the 

exception of neutron exposure data obtained from NTA film (see Section 7.3), the data obtained from 

the evaluated class timeframe are sufficient in quality and quantity to be used to evaluate external 

doses. Section 7.3.4 describes a method to bound potential neutron exposures. 

Records of radiation doses to individual workers from personnel dosimeters worn by workers and 

co-workers are available for LANL operations beginning in 1943. Doses from these dosimeters were 

recorded at the time of measurement and routinely reviewed by operations and radiation safety 

personnel for compliance with radiation control limits. Administrative practices are described in the 

Photodosimetry Evaluation Book (LASL 1959a, 1969, and 1977a, 1979; LANL 1986, 1989, 1996, 

2001, and 2003) and LANL technical reports. Detailed information for each worker is in the NIOSH 

claim documentation. The claim documentation provides specific information to be evaluated on the 

recorded dose of record. There do not appear to have been significant administrative practices that 

jeopardized the integrity of the dose of record (ORAUT-TKBS-0010-6). Furthermore, data recording 

became more automated with time. 

7.2 Evaluation of Bounding Internal Radiation Doses at LANL 

ATTRIBUTION: Section 7.2 and its related subsections were completed by Chris Miles, Quantaflux, 

LLC; Rowena Argall, MJW Corporation; and Elizabeth Brackett, MJW Corporation. These 

conclusions were peer-reviewed by the individuals listed on the cover page. The rationales for all 

conclusions in this document are explained in the associated text. 

The principal sources of internal radiation doses for members of the class under evaluation were the 

variety of site processes and incidents involving plutonium, americium, tritium, and uranium 

(ORAUT-TKBS-0010-5). The following subsections address the ability to bound internal doses, 

methods for bounding doses, and the feasibility of internal dose reconstruction. 

7.2.1 Evaluation of Bounding Process-Related Internal Doses 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal doses of members of the class under evaluation. 

The primary sources of internal radiation doses for members of the proposed class were inhalation of 

plutonium isotopes, tritium, uranium isotopes, and mixed fission and activation products (MFP/MAP). 

The LANL internal dosimetry database contains bioassay data for U-234/235/238, Pu-238/239, 

tritium, Po-210, and Cs-137. Uranium, plutonium, and tritium were the primary contributors to the 

collective internal dose at LANL during the time period under evaluation. Po-210, widely used during 

the 1940s and 1950s, was not a significant nuclide for this time period. Am-241 was also a significant 

40 of 77 
SEC-00109 01-22-09 FINAL LANL
 

source of internal dose, primarily due to its association with weapons-grade plutonium, although it 

was not always associated with plutonium. There is an abundance of bioassay data for Am-241. Data 

for Cs-137 are available due to ease of detection using gamma spectroscopy systems. For the purpose 

of this discussion, the term “exotics” is used to include everything other than U-234/235/238, 

Pu-238/239, tritium, Am-241, and Cs-137 (i.e., radionuclides for which there are limited or no internal 

dosimetry data). This would include Sr-90, Th-232, Cm-244, Ac-227, Pa-231, Np-237, and others. 

Although not primary contributors to the collective dose at LANL, it is possible that for some 

individuals, one or more of these exotic radionuclides were the primary source of internal dose. 

LANL clearly possessed capabilities to conduct bioassay measurements for these exotic radionuclides 

(LANL, 2008); however, specific data for such measurements are very sparse and generally 

unavailable. 

Multiple data capture efforts have taken place to support this evaluation. These efforts have included 

trips to LANL as well as the National Archives in Denver. It is clear from these efforts that 

comprehensive health physics programs were in effect at LANL during the 1976-2005 time period. 

Hundreds of boxes of health physics records have been found pertaining to this time period. Records 

include: exposure reports, air monitoring reports, radiation incident reports, radiation work permits, 

special operating procedures, radioactive material handling, stack air monitoring, contamination 

surveys, nasal smears, whole body counting, urinalysis reports, CAM reports, ALARA reports, and 

employee checklists (Records, 2008) 

These health physics records indicate that exotic radionuclides were handled, controlled, and 

monitored in a similar manner as the primary nuclides. For example, many alpha-emitting exotics 

were handled in a manner similar to handling plutonium: using glove-boxes, monitoring airborne 

concentrations, using personal protective equipment (PPE) such as respirators, performing surface 

contamination surveys, and covering jobs with radiation protection technicians. Although the vast 

majority of these documents were associated with the primary radionuclides, several documents 

pertaining to exotics were located. Some examples are listed below: 

•	 A Special Work Permit (SWP) for Radiation Work, dated July 31,1992, addressed an operation 

described as “disconnect thoria duct, stack, and fan.” Th-232 is identified as the radiological 

hazard associated with this operation. The PPE called for included double anti-contamination suits 

(anti-Cs) with taped openings and a full-face respirator. It also called for nose wipes and stated 

that urine samples were required, as requested (SWP, 1992). 

•	 An SWP, dated July 28, 1992, addressed an operation described as “remove service connections, 

wiring, and plumbing for Th contaminated hood.” Th-232 and U-238 are identified as the 

radiological hazards associated with this operation. The PPE called for included anti-Cs with taped 

openings and a full-face respirator, as requested. It also called for nose wipes (SWP, 1992). 

•	 A Radiological and Hazardous Work Permit, dated August 30, 1994, addresses work involving 

Np-237 contamination. It calls for a continuous air monitor (CAM) to be used, with “settings 

changed to threshold 4.15, and window 1.5.” It also required Level 1 PPE with full-face respirator 

and continuous health physics tech (HPT) coverage (TA-55 RWP). 

•	 LANL report entitled, The Decommissioning of TA-21-153, Ac-227 Contaminated Old Filter 

Building, dated November 1981, includes a discussion about health physics controls used for this 

operation. The work was performed by experienced radiation workers who had received formal 

41 of 77 
SEC-00109 01-22-09 FINAL LANL
 

health physics training. Decommissioning work was not permitted without the presence of a 

health physics surveyor. All workers participated in a full-face respirator, fitting, testing, and 

training program. Air samplers and continuous air monitors (CAMs) were used with the 

maximum air concentration detected being 2.5 dis/s/m3 . All workers wore gamma and neutron 

film badges (TA-21-153, 1981). 

•	 Radiological Safety Procedures in P-Division, dated January 1977, contain a set of procedures 

prepared by the Radiation Safety Committee which describe various health physics practices 

designed to minimize exposure to radioactive materials (P-Division, 1977). 

•	 A memorandum, Standard Operating Procedures for the Handling of Actinide Elements, dated 

October 15, 1973 and reviewed and updated on April 20, 1976, states: “All manipulations of 

americium or curium are carried out in enclosed gloved-boxes or vacuum systems, maintained at a 

negative pressure with respect to laboratory air. Neoprene gloves, a minimum of 10-gauge 

thickness and tested for leaks before use are installed on these boxes. In addition, the operator 

uses surgeon’s gloves. Protective clothing and a full face mask respirator are supplied. 

Respirators are used whenever material from a ‘hot’ gloved-box is transferred out, or between 

boxes.” (SOPs, 1973). 

•	 An office memorandum entitled Radiation Protection Procedures, dated September 17, 1976, lists 

40 Standard Operating Procedures that pertain to radiation protection that were reviewed and 

found to be adequate and up-to-date (SOPs, 1976). 

The above is small sampling from hundreds of boxes of health physics-related records that are 

archived at LANL. 

NOTE: The LANL Evaluation Report for Petition SEC-00051 (covering 1943 through 1975) has a 

detailed description of the monitoring methods employed since the creation of the site. The following 

discussion focuses on the time period of the class currently under evaluation (1976 through 2005). 

In the 1970s, LANL initiated an Employee Health Physics Checklist. This checklist allowed the 

evaluation of each individual for potential internal and external exposure, the purpose being the 

identification of those individuals with significant potential for radiation exposure. Individuals were 

placed on a monitoring schedule based on this checklist. The checklist is still used and was 

computerized in 1998 as the Dosimetry Enrollment System (Checklist, 1985; Checklist, 1990; 

Checklist, 2000). Sampling protocols for various radionuclides are discussed in the LANL Internal 

Dose TBD (ORAUT-TKBS-0010-5). 

7.2.1.1 Urinalysis Information and Available Data 

Excreta bioassay methods for determining internal exposures were developed in late 1944 for 

plutonium (fully implemented in April 1945); for uranium and americium in 1949; and tritium in 

1950. Methodologies for interpreting these resulting bioassay data over the years are presented in the 

LANL Internal Dose TBD. Although the number of monitored individuals increased over the years, 

not all individuals working at LANL were monitored. The Employee Health Physics Checklist was 

used to ensure that workers with the highest exposure potential were monitored. These checklists 

were completed for LANL employees, contractor employees, students, and visitors (Checklist, 1977). 

Workers involved in radiological incidents were also often monitored, as evidenced by the historical 

42 of 77 
 

 

 

SEC-00109 01-22-09 FINAL LANL
 

incident files maintained by LANL (see Section 5.2.3 for a summary of the incident-related records 

that are available). Nasal swipes and wound counts have also been used extensively at LANL to 

identify the need for bioassay. 

Plutonium 

The largest intakes at LANL have involved isotopes of plutonium. Current and historical bioassay 

results are stored with the plutonium results in the LANL bioassay database. There are over 70,000 

urine sample results for Pu-239 and over 60,000 results for Pu-238 in the LANL database, from 1976 

through 2005. The optimum source of data to estimate doses to unmonitored workers is co-worker 

data analyzed per ORAUT-OTIB-0019. This analysis has been performed and documented in 

ORAUT-OTIB-0062 (draft). In 1997, the TIMS analysis (which could separate Pu-239 and Pu-240) 

became available. There are over 3500 urine sample results for Pu-240, beginning in 1997. 

Many of the Service Support Workers, as defined in the petitioner-proposed class definition, were Zia 

Company employees. The Zia Company was the service workers’ contractor for many years. Zia 

employees participated in a plutonium bioassay program that required annual urine samples. In 1976, 

a program was used for Zia employees that restricted access to plutonium areas if participation in the 

plutonium bioassay program was not recorded within 425 calendar days. 

Table 7-1 contains a list of criteria and exempt job categories (LASL, 1978a). In more recent years, 

other service contractors have participated in site activities and would be subject to these criteria. 

Table 7-1: Zia Employee Access to Plutonium Areas 

Area Urine Sample 

Within 425 

Days of Entry 

Exempt 

Job requiring respiratory protection X 

Modifications or repairs on dry boxes or other highly contaminated equipment. X 

Replacement of plutonium-contaminated filters at all sites. X 

Janitorial (long-term) work in plutonium operation areas X 

Long-term operations (weeks) in areas of low levels of plutonium contamination (>1,000 

dpm-60 cm2

 and <10,000 dpm-60 cm2) 

X 

Decontamination of plutonium spills with >10,000 dpm-60 cm2

 X 

Work in burial pits at TA-54 when personnel contamination potential is moderate to high X 

Short-term jobs (2-3 d) when sizable quantities of plutonium (grams of Pu-238 or kilograms 

of Pu-239) are present in dry boxes (even when work is being done outside dry box) 

X 

Supervisory personnel (base urine sample on record) X 

Short-term jobs (2-3 d) in areas of CMR Building, Ten Site, TA-50, TA-55, TA-54, TA-18, 

TA-48, or TA-21, where there is little plutonium contamination (<1,000 dpm-60 cm2

) 

X 

Jobs in other minimum exposure potential areas when respiratory protection is not required 

and possibility of plutonium contamination is minimal. 

X 

43 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Americium 

At LANL, Am-241 is usually encountered as a trace contaminant in plutonium; however, there is 

potential for exposure to pure Am-241, as seen in the 2005 Am-241 contamination incident discussed 

by the petitioner. The americium bioassay program began in 1954, although a procedure for 

determining Am-241 in urine was in development in 1948. Also, laboratory notebook pages dated 

1950 through 1957 list approximately 950 urinalyses for Am-241; many of these results were 

pre-1954 (Kirkham, 2006). Current and historical bioassay results are stored with the plutonium 

results in the Los Alamos Bioassay Data Repository database. There are over 1200 urine sample 

results for Am-241 in the LANL database, from 1991 through 2005. 

Tritium 

Tritium was encountered in several forms: tritiated water (HTO), tritiated gas (HT), organically-bound 

tritium (OBT), and metal tritide (MT). Each form has unique characteristics. From 1950 until the 

present, an average of 100 individuals per year has been monitored for tritium intakes at LANL. The 

form generally encountered was HTO. There are no records of tritium monitoring prior to 1950. 

Urinalysis for tritium began on January 1, 1950; data are available in the Los Alamos Bioassay Data 

Repository database. There are over 40,000 urine sample results for tritium in the LANL database, 

from 1976 through 2005. The tritium bioassay data were sufficient to derive a co-worker model to 

estimate tritium doses after 1950 (ORAUT-OTIB-62, draft). 

Uranium 

Monitoring for uranium consisted of routine urinalysis, starting in 1949, for employees identified as 

being at risk for exposure (ORAUT-TKBS-0010-5, Table 5A-14, Routine Sampling Procedure). 

Nasal swipes with more than 50 cpm indicated the need for follow-up bioassay. Internal monitoring 

data are available in the Los Alamos Bioassay Data Repository database and doses due to intakes of 

uranium can be reconstructed for the period after 1949. There are over 40,000 urine sample results for 

uranium in the LANL database, from 1976 through 2005. The co-worker data were sufficient to 

derive intake estimates for unmonitored workers for uranium after January 1, 1950 (ORAUT-OTIB62, draft). 

Strontium-90 

Records of routine or special Sr-90 urinalyses are very sparse for the post-1975 time period. 

Conversations in 2004 with current bioassay personnel indicate that possibly 200 Sr-90 analyses have 

been performed throughout the history of the site. In 1979, four urine samples were analyzed in 

association with a decommissioning operation at Ten Site, in an area that had been contaminated with 

Sr-90 due to the RaLa program prior to 1963 (Quarterly, 1980). Results are also available for three 

Sr-90 analyses performed in 1997 (Targeted Sr-90). 

44 of 77 
SEC-00109 01-22-09 FINAL LANL
 

7.2.1.2 Lung and Whole Body Counting Information and Available Data 

In vivo counting equipment and techniques were developed in the late 1950s and have been in routine 

use for measuring X-ray and gamma-ray-emitting radionuclides at LANL since 1970. Descriptions of 

the counting equipment in use over the years at LANL are included in the LANL Internal Dose TBD 

(ORAUT-TKBS-0010-5). 

Prior to the recent consolidation efforts by LANL and NIOSH (see Section 7.1.1 and ORAUT-OTIB0063, draft), in vivo counting data from 1960-2003 were maintained in a legacy system called 

“OMNIS7”. Table 6-1 summarizes the numbers of in vivo records, by analyte, that are available in the 

LANL database during the post-1975 time period. Methodologies for interpreting these resulting 

bioassay data over the years are are presented in the LANL Internal Dose TBD (ORAUT-TKBS0010-5). Validation of these data sources is described in Section 7.1.1. 

7.2.1.3 Other Types of Intake Monitoring 

Wound Counts 

In August 1959, the H-6 Group acquired a probe to be used to monitor wounds contaminated with 

plutonium. This probe was capable of detecting soft plutonium X-rays. The sensitivity of this probe 

was 1 × 10-9 Ci of plutonium unshielded. This was equivalent to detection of one-tenth of a 

permissible body burden of plutonium embedded in tissue to a depth of 1 cm (LASL 1959a). In 1977, 

a new NaI detector (12 mm x 2 mm) was being evaluated. This produced an MDA of 0.07 nCi based 

on weapons-grade plutonium (LASL 1977c). No other information on instrumentation or sensitivities 

is available (ORAUT-TKBS-0010-5). 

Wound counting was used primarily as a tool for surgeons to locate plutonium in the wound, and 

results were not used to calculate internal dose. Wound monitoring continues to be performed. In 

most cases, intake and dose will not be assessed directly from the wound count but rather from the 

resultant in vitro (urine and fecal samples) bioassay data. Follow-up studies of wounds found that, in 

the majority of incidents, plutonium does not readily migrate away from the wound site. Wound 

count results are added to a worker’s case file, and although they are not used specifically to 

reconstruct dose, may indicate that a potential uptake occurred that should be accounted for during 

dose reconstruction. 

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses 

An ambient air-monitoring program at LANL began as early as 1954. Historical results of the 

AIRNET monitoring network through 2000 are available on the LANL website (LANL, 2003); annual 

environmental surveillance reports summarize yearly results. Emissions data are also available. 

These data are described in detail in ORAUT-TKBS-0010-4 and are used to evaluate airborne 

environmental intakes for application to individual dose reconstructions. Table 4-31 in ORAUTTKBS-0010-4 provides site-wide maximum ambient intakes for the entire class period under 

evaluation. Although available post-1975 data enable dose reconstruction, in this evaluation, workers 

are assumed to be maximally exposed to conditions that potentially existed in operational areas. 

Ambient environmental dose is bounded by the assignment of this operations-related dose. 

45 of 77 
 

SEC-00109 01-22-09 FINAL LANL
 

7.2.3 Methods for Bounding Internal Dose at LANL 

7.2.3.1 Methods for Bounding Operational Period Internal Dose 

Application of Available Bioassay Data for Monitored Workers 

Intakes to monitored workers may be estimated using the available in vitro and/or in vivo data for the 

specific radionuclides that were analyzed. These intake estimates may then be used to bound organ 

doses from those radionuclides, for those monitored individuals, using the methodologies described in 

the LANL Internal Dose TBD (ORAUT-TKBS-0010-5). 

Application of Co-Worker Data for Internal Dose Reconstruction 

A draft technical information bulletin (ORAUT-OTIB-0062, draft) has been developed for dose 

reconstruction, for unmonitored individuals, using co-worker data for Pu-239, Pu-238, uranium, 

tritium, and Cs-137. The intake rates provided in the OTIB cover the class period under evaluation: 

In Section 7.2.1, it was demonstrated through various health physics records that exotic radionuclides 

were handled, controlled, and monitored in a similar manner as the primary nuclides. The applicable 

guidelines for controlling airborne concentrations and surface contamination levels for all radioactive 

materials are defined in units of activity (e.g., μCi/m3

 and dpm/100cm2). The guidelines for many of 

the exotic alpha-emitters were the same as, or more restrictive than, the guidelines established for 

Pu-238 and Pu-239. For this reason, in the absence of specific internal dosimetry data, it is possible to 

bound intakes of many of the exotic alpha-emitting radionuclides using co-worker data for Pu-238 

and/or Pu-239. Co-worker data for LANL are given in draft ORAUT-OTIB-0062. Daily intake rates 

for Pu-239 taken from ORAUT-OTIB-0062, in units of pCi/d, may be assigned separately for each 

alpha-emitting exotic radionuclide that would have required similar controls: Ac-227, Pa-231, 

Np-237, and Th-230. To process an individual claim, on a case-by-case basis, the nuclide that results 

in the highest dose to the organ of interest for the energy employee could be used as the bounding 

intake. Since the properties of Cm-244 are more similar to Pu-238, daily intake rates for Pu-238 could 

be used for Cm-244. Since the radiological properties and health physics controls for natural thorium 

are comparable to uranium, co-worker data for uranium could similarly be used to bound intakes of 

natural thorium. 

Incidents 

Incidents often resulted in requests for special bioassays (see Section 5.2.3 for a summary of the 

incident-related records that will be available for data capture by NIOSH in early 2009).). In such 

cases, these bioassay results may be used to support bounding intake estimates for the exposure 

situations/conditions associated with the incidents. 

46 of 77 
SEC-00109 01-22-09 FINAL LANL
 

7.2.3.2 Bounding Methods by Radionuclide 

Plutonium 

The LANL bioassay programs for plutonium were extensive. Monitored worker intakes were 

determined by chest counting and through urine bioassay. These data are readily available to bound 

dose from plutonium isotopes for monitored workers. 

Unmonitored worker intakes may be bound using monitored co-worker data. Internal dosimetry coworker data for LANL are presented in ORAUT-OTIB-0062 (draft). 

Hydrogen-3 (Tritium) 

The tritium bioassay program at LANL was extensive. Monitored worker doses were determined 

through urine bioassay. These data are readily available to bound tritium dose to monitored workers. 

Unmonitored worker intakes may be bound using monitored co-worker data. Unmonitored worker 

intakes may be bound using monitored co-worker data. Internal dosimetry co-worker data for LANL 

are presented in ORAUT-OTIB-0062 (draft). 

Exposures to tritiated water and/or vapor (HTO) and gaseous tritium (HT) were the most prevalent 

forms of tritium exposure at LANL. Organically bound tritium (OBT) would have been encountered 

only in locations where biological research with labeled compounds was conducted. Exposures to the 

stable metal tritide (SMT) form of tritium may have been encountered as the result of the storage of 

tritium adsorbed on rare metals. Exposure to these compounds is a specialized circumstance (Inkret, 

1999b). On a case-by-case basis, intakes of OBT and SMT compounds may be bounded using the 

methodologies outlined in ORAUT-OTIB-0066. 

Uranium 

The LANL bioassay programs for uranium were extensive. Monitored worker intakes were 

determined by chest counting and through urine bioassay. These data are readily available to bound 

dose to uranium isotopes for monitored workers. 

Internal dosimetry co-worker data for LANL are presented in ORAUT-OTIB-0062 (draft). 

Mixed Fission and Activation Products 

By 1976, in vivo counting methods were well-established and available for bounding intakes of MFP 

and MAP. ORAUT-OTIB-0054 discusses MFAP ratios and the calculation of intakes based on a 

single nuclide (e.g., Cs-137 co-worker data). For unmonitored workers, Cs-137 co-worker data are 

available in the draft co-worker study ORAUT-OTIB-0062. For bounding intakes to unmonitored 

workers, Cs-137 co-worker data in the draft co-worker study (ORAUT-OTIB-0062) may be used. 

47 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Strontium-90/Yttrium-90 

Sr-90/Y-90 is often associated with other mixed fission products. In such cases, bounding intakes 

may be estimated by assessing intakes of Cs-137, another fission product with a similar fission yield 

and similar physical half-life as Sr-90. Intakes of Cs-137 can be readily determined by in vivo 

counting. Intakes of Sr-90/Y-90 for workers exposed to MFP who were monitored for Cs-137 can 

therefore be estimated from Cs-137 intake assessments (assuming that the Sr-90/Y-90 is a component 

of MFP). The details of this method are described in ORAUT-OTIB-0054. 

Urine bioassay methods for Sr-90/Y-90 were well-established by 1976. Due to a lack of necessity, 

routine Sr-90/Y-90 bioassay was uncommon. As described previously, the only activity at LANL 

known to have involved Sr-90 contamination (other than as a component of MFP) was the RaLa 

program. Although this program ended in 1963, residual Sr-90 contamination remained in specific 

associated areas long after the program ended. The available health physics records provide 

information supporting that operations in affected areas were sufficiently controlled from a 

radiological exposure control perspective. After the RaLa program ended, NIOSH found no 

indication of work that could result in significant exposures (or disturbance of the residual Sr-90 

contamination) until the commencement of decommissioning activities at the associated locations. 

The decommissioning operation at Ten Site during the late 1979 and early 1980 time period involved 

hundreds of air tests, continuous air monitoring (CAM) during all operations, hundreds of routine and 

special air tests, hundreds of nose swipes and four urine bioassay samples (Quarterly, 1979). RWPs 

from the 1990s are available for the decommissioning work conducted in TA-35 where Sr-90 

contamination was known to have been present (RWP, 1995). These operations were conducted by 

trained radiation workers and involved the use of CAMs, other air monitoring, radiological technician 

coverage, level 1 PPE, nasal swipes, etc. Workers with significant potential for Sr-90 intakes during 

these decommissioning activities would have been monitored via urine bioassay; the resulting data 

would be included in their personnel records. 

Following a NIOSH request, LANL staff has provided evidence of targeted urine bioassay for Sr-90 

involving three workers performed in 1997 (Targeted Sr-90, 1997). 

Thorium-230 

NIOSH has not found any evidence of work with separated Th-230 at LANL since the late 1950s. 

Urine bioassay methods for Th-230 were established in the 1950s, as there were a number of 

bioassays conducted for Th-230 in 1958 (ORAUT-TKBS-0010-5). In the absence of bioassay data, 

intakes of Th-230 from residual contamination could be bound using co-worker data for Pu-239, as 

described earlier in this section. 

Thorium-232 

There is evidence of small-scale operations involving Th-232 extending into the 1990s (DOE, 1991). 

Due to a lack of necessity, routine Th-232 bioassays were uncommon; however, LANL maintained 

the ability to perform targeted bioassay for the duration of the evaluation period (post-1975). 

Targeted dosimetry was indicated for an international traveler in 1999 (Targeted Th-232, 2000). 

LANL maintains a DOELAP-accredited in vitro bioassay program for Th-230 and Th-232. In the 

absence of bioassay data, Th-232 intakes could be bound using co-worker data approach for uranium, 

as described earlier in this section. 

48 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Americium-241 

For intakes of Am-241 as a component of weapons-grade plutonium, plutonium bioassay data may be 

used to bound intakes of Am-241. Since 1970, LANL has maintained in vivo capability for Am-241. 

These data are readily available to bound intakes of Am-241 for monitored workers. Although 

bioassay data for Am-241 are abundant, unmonitored intakes could be bound using co-worker data 

approach for Pu-239, as described earlier in this section. 

Neptunium-237 

Neptunium-237 was not a commonly-used radionuclide at LANL. There is, however, evidence of 

periodic operations involving its use prior to 1975 and continuing to at least 2002. Although LANL 

maintains the ready ability for targeted in vitro measurements (LANL, 2008), bioassay data are 

generally unavailable. In the absence of bioassay data, intakes of Np-237 could be bound using 

co-worker data approach for Pu-239, as described earlier in this section. 

Actinium-227 

Actinium is unlikely to have been a significant radiological hazard in the post-1975 period at LANL. 

The available literature suggests that work with this radionuclide was substantially complete by 1955 

(DOE, 1993). Residues of this material may exist in waste streams, including filter buildings and 

environmental disposal sites. 

Potential doses to affected workers from the 1978 decontamination and decommissioning of the Old 

Filter Building, TA-21-153 may be bounded using job-coverage data from the decommissioning 

report (Harper, 1981) when a realistic exposure scenario can be inferred from case-specific 

information. During this decommissioning project, workers wore respiratory protection, air 

monitoring was conducted throughout the project (air monitoring data are available), and the 

maximally exposed individuals received bioassay via whole-body counting. No measureable intakes 

were found (Harper, 1981). This is an example of “targeted dosimetry” as described by current LANL 

Radiation Protection Division staff (LANL, 2008). In the absence of bioassay data, intakes of Ac-227 

could be bound using co-worker data approach for Pu-239, as described earlier in this section. 

Protactinium-231 

No LANL workers are on a routine Pa-231 bioassay program, although LANL has the ability to detect 

this nuclide through targeted in vivo measurements (LANL, 2008). In the absence of bioassay data, 

intakes of Pa-231 could be bound using co-worker data approach for Pu-239, as described earlier in 

this section. 

Curium-244 

LANL has the ability to detect Cm-244 through targeted in vitro measurements, if warranted, with 

sample analysis conducted at Oak Ridge (LANL, 2008). An example case of targeted bioassay was 

provided by LANL for a presumptive intake occurring in 2003 (Little, 2003b). In the absence of 

bioassay data, intakes of Cm-244 could be bound using co-worker data for Pu-238, as described 

earlier in this section. 

49 of 77 
SEC-00109 01-22-09 FINAL LANL
 

7.2.3.3 Methods for Bounding Ambient Environmental Internal Dose 

The LANL Environmental Occupational Dose TBD lists relevant monitoring or other data pertinent to 

estimating environmental internal dose (ORAUT-TKBS-0010-4). Although available post-1975 data 

enable dose reconstruction, in this evaluation, workers are assumed to be maximally exposed to 

conditions that potentially existed in operational areas. Ambient environmental dose is bounded by 

the assignment of this operations-related dose. 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion 

This evaluation concludes that internal dose reconstruction for members of the proposed class is 

feasible, based on: (1) using in vitro and in vivo bioassay data for monitored workers; and (2) using 

co-worker data to bound intakes to unmonitored workers, based on the co-worker study described in 

ORAUT-OTIB-62 (draft) and as described within this section of this evaluation report. 

7.3 Evaluation of Bounding External Radiation Doses at LANL 

ATTRIBUTION: Section 7.3 and its related subsections were completed by Bob Burns, NGTS, Inc.; 

and John Fix, Dade Moeller & Associates. These conclusions were peer-reviewed by the individuals 

listed on the cover page. The rationales for all conclusions in this document are explained in the 

associated text. 

The principal source of external radiation exposure for members of the class under evaluation was 

photon radiation, with the expectation that members of the class may have been exposed to beta and 

neutron radiation associated with: nuclear weapon development; reactor and accelerator operations; 

criticality experimentation; handling of radioactive materials in production or research activities; 

radiation-producing devices; or radioactive waste facilities or handling operations. For some workers, 

neutron radiation accounted for a large fraction of the occupational external radiation dose. The 

principal sources of neutron dose over the time period under evaluation were accelerator and 

plutonium-handling operations. 

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

and the feasibility of external dose reconstruction. 

7.3.1 Evaluation of Bounding Process-Related External Doses 

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related external doses of members of the class under evaluation. 

LANL historical documentation shows knowledge of potential workplace external radiation hazards, 

applicable radiation exposure guidelines, methods of limiting worker exposure, and an on-going 

pursuit of improved radiation instrumentation and dosimetry capabilities. Table 6-2 of the LANL 

External Dose TBD shows monitoring for a substantial fraction of the total workers for all years after 

1945 and certainly over the time period under evaluation (1976 through 2005) (ORAUT-TKBS-0010­

6). The values for 1976 through 2005 are shown in Table 6-4 of this evaluation. The dosimeters 

employed were state-of-the-art and included design features to provide sensitivity in the workplace 

radiation environments encountered by LANL workers. LANL made efforts to characterize the 

response of its personnel dosimeters to workplace radiation fields. For the period 1976 through 1979, 

50 of 77 
SEC-00109 01-22-09 FINAL LANL
 

the dosimeter of record for beta, gamma, and thermal-to-intermediate-energy neutron dose was the 

multi-element “Cycolac” film badge. In 1978, some workers began receiving thermoluminescent 

dosimeters (TLDs) which incorporated a new and improved technology. TLDs have been the 

dosimeter of record since 1980. For fast-neutron monitoring, NTA film was used in conjunction with 

the Cycolac film or TLD personnel dosimeters until 1995, when it was replaced with track-etch 

dosimeters (TEDs). 

LANL has recorded gamma (penetrating), beta (non-penetrating), and neutron dose (or dose 

equivalent) for monitored workers over the time period under evaluation. Prior to 1980, fast and 

thermal neutron dose were recorded separately; total neutron dose (i.e., that from all neutron energies) 

has been recorded thereafter (ORAUT-TKBS-0010-6). 

Data from LANL dosimetry systems and workplace instrument measurements such as multi-sphere 

and rem-meter workplace measurements of neutron dose and spectra, and recent LANL Rotating 

Neutron Spectrometer workplace measurements provide a basis for determining an upper-bound 

neutron dose for the corresponding periods of dosimeter use (ORAUT-TKBS-0010-6). 

Photon 

The personnel dosimeters assigned to LANL workers over the time period under evaluation were 

capable of measuring photon doses in the workplace with sufficient accuracy to permit the calculation 

of bounding photon doses. The majority of workers were routinely monitored with state-of-the-art 

dosimeters and the measured photon doses are considered to be reasonably accurate based on 

laboratory-measured response characteristics of these dosimeters, and complete based on the worker 

dose records (ORAUT-TKBS-0010-6). These data have been used in several health effect studies of 

LANL workers. Potential missed dose is assigned using OCAS-IG-001 guidance. The Occupational 

External Dose TBD includes documentation of measures taken by LANL staff to characterize the 

response of their personnel dosimeters to the low-energy photon fields associated with plutoniumhandling operations (ORAUT-TKBS-0010-6, Section 6.2.3.4). 

Table A-2 in the External Dose TBD gives gamma dose rate statistics for LANL dosimeter results 

(gamma dose ≥ 50 mrem) for all years of operation through 2003 and into 2004. These data include 

the mean, maximum., median, and 95th percentile values, and the corresponding geometric standard 

deviation. If these data are adjusted for missed dose and uncertainty, as applicable, they represent a 

reasonable means of bounding photon dose for all members of the class under evaluation. The 

External Dose TBD contains sufficient information with which to adjust the Table A-2 data for missed 

dose and uncertainty (ORAUT-TKBS-0010-6). 

Beta 

Beta in association with photon radiation monitoring instrumentation was commonly used to evaluate 

workplace beta radiation fields. The personnel dosimeters assigned to LANL workers during the time 

period under evaluation had the capability to measure doses from significant beta radiation sources. 

Non-penetrating, beta, or shallow (depending upon terminology used at different times) doses were 

routinely recorded along with the photon dose. These data provide information to permit the 

calculation of bounding doses for members of the class. LANL shallow doses were based on uranium 

calibration (ORAUT-TKBS-0010-6). Mixed photon and beta radiation fields typically result in 

substantial overestimation of the shallow dose. Lower-energy beta radiation was not generally a 

51 of 77 
SEC-00109 01-22-09 FINAL LANL
 

significant source of dose at LANL (ORAUT-TKBS-0010-6). There is sufficient LANL 

documentation to allow bounding of beta dose for members of the class under evaluation. 

Neutron 

Neutron radiation monitoring instrumentation was commonly used to evaluate workplace neutron 

radiation fields. Prior to 1980, the NTA personnel neutron dosimeter was used to measure and record 

personnel neutron dose. Since NTA film-based dosimeters do not respond to neutrons with energies 

less than approximately 500 keV, the use of neutron-to-photon dose ratios is necessary to bound 

neutron dose prior to 1980 (ORAUT-TKBS-0010-6). After 1980, recorded neutron doses are 

considered to be sufficiently accurate based on a combination of albedo TLD (for low- and 

intermediate-energy neutrons) and NTA film (for high-energy neutrons). 

Characterization of workplace neutron spectra at LANL showed that the neutron energies associated 

with plutonium-handling operations were consistent with those from well-moderated sources. 

Measurements performed in plutonium processing areas in 1978 indicated an average neutron energy 

of 200 keV. Neutron spectrometry data collected in these areas in 1993 showed that approximately 

90% of the neutron flux was from neutrons having energy of 1.2 MeV or less. Characterization of 

neutron spectra at TA-53 showed neutron energy spectra could vary widely, and included areas where 

the dominant contribution to neutron dose equivalent came from neutrons having energy greater than 

10 MeV. These measurements included evaluation of NTA and TLD measured neutron doses. 

(ORAUT-TKBS-0010-6). 

The External Dose TBD contains sufficient information to allow bounding of neutron dose using, as 

necessary, neutron-to-photon dose ratios in LANL areas where personnel neutron exposures occurred. 

It also contains sufficient information to allow assessment of missed dose and uncertainties associated 

with reported neutron dose after 1979, as well as reported neutron dose for the entire time period 

under evaluation. The combination of bounding neutron-to-photon dose ratios and the photon (i.e., 

gamma) dose information given in Table A-2 of ORAUT-TKBS-0010-6 therefore provides a means 

for bounding neutron dose for all members of the class for the period prior to 1980 when NTA film 

was still the principal means of neutron monitoring. The same approach could be extended to the 

post-1979 period; alternatively, an approach akin to that described above for bounding photon 

exposures could be used. Either way, sufficient information is available to allow bounding of neutron 

dose for all members of the class for the entire time period under evaluation. 

7.3.2 Evaluation of Bounding Ambient Environmental External Doses 

LANL had a comprehensive program for monitoring ambient radiation exposure within its boundaries 

and in the surrounding area. This program and the data it generated are described in detail in 

ORAUT-TKBS-0010-4, which provides a thorough evaluation of ambient environmental dose as 

applicable to performing individual dose reconstructions. Table 4-25 in ORAUT-TKBS-0010-4 

provides site-wide maximum ambient dose data for the entire class period under evaluation. This 

information should be sufficient to allow bounding of ambient environmental external dose for all 

members of the class. 

52 of 77 
 

SEC-00109 01-22-09 FINAL LANL
 

7.3.3 LANL Occupational X-Ray Examinations 

The information given in the Occupational Medical Dose TBD is sufficient to allow bounding of 

radiation dose associated with occupationally-related X-ray examinations received by members of the 

class under evaluation. The examination protocols and equipment used during the relevant time 

period are documented sufficiently to allow assessments of organ dose that may be considered 

bounding (ORAUT-TKBS-0010-3). 

7.3.5 External Dose Reconstruction Feasibility Conclusion 

During the period of this evaluation, the majority of LANL workers were monitored as illustrated in 

Table 6-4. Information describing workplace radiation fields at LANL, performance of personnel 

dosimetry systems in those fields, and the monitoring data produced by LANL’s personnel dosimetry 

program have been reviewed as they pertain to bounding of radiation dose from external sources of 

photon, beta, and neutron radiation for members of the class under evaluation. Information describing 

dose from ambient sources of radiation and from occupationally-related X-ray examinations have also 

been reviewed. The available information has been found adequate to allow bounding of external 

radiation doses with sufficient accuracy for members of the class under evaluation. 

7.4 Evaluation of Petition Basis for SEC-00109 

ATTRIBUTION: Section 7.4 and its related subsections were completed by Ray Clark, Oak Ridge 

Assiciated Universities (ORAU); and Chris Miles, Quantaflux, LLC. These conclusions were peerreviewed by the individuals listed on the cover page. The rationales for all conclusions in this 

document are explained in the associated text. 

The following subsections evaluate the assertions made on behalf of petition SEC-00109 for the 

LANL site. 

7.4.1 Cerro Grande Fire 

SEC-00109: The petitioner identified the “Cerro Grande Fire” in 2000 as an unmonitored, unrecorded, 

or inadequately monitored exposure incident. 

A study performed soon after the Cerro Grande fire included two dose calculations: (1) the 

hypothetical maximally-exposed firemen or volunteer who was working actively in the Los Alamos 

area throughout the worst of the burn duration; and (2) the maximally-exposed member of the public 

outside Los Alamos. Those calculations are updated in Updated Calculations of the Inhalation Dose 

from the Cerro Grande Fire Based on Final Air Data (Cerro Grande, 2001). In addition, a third 

calculation is added: a fireman or other worker in the vicinity of AIRNET (LANL’s ambient air 

monitoring network) Station #23 in Mortandad Canyon where elevated levels of LANL-derived 

airborne uranium occurred during the peak of the fire. The incident information was reviewed by 

NIOSH and these data can be used to bound the dose for any Service Support Worker who might 

have been exposed during the fire. 

53 of 77 
 

 

 

SEC-00109 01-22-09 FINAL LANL
 

7.4.2 Sigma Americium Contamination Incident 

SEC-00109: The petitioner identified the “Sigma Americium Contamination Incident” in 2005 as an 

unmonitored, unrecorded, or inadequately monitored exposure incident. 

The Type B Accident Investigation report on the July 14, 2005 americium contamination accident at 

the LANL Sigma Facility states that the maximum dose to Worker 1 (the maximally-exposed 

individual) was 500 mrem CEDE. Based on this assessment and its review by NIOSH, a maximum 

intake may be estimated, which could then be used to bound the dose for service workers 

(Investigation, 2006). 

7.4.3 Neptunium Special Hazards 

SEC-00109: The process hazards analysis, HCPs, and work instructions for actinide fuels work do 

not adequately define or analyze the special hazards posed by the use of 100-gram quantities of 

neptunium powders by NMT-11 workers. 

NIOSH recognizes that there was a potential for unmonitored intakes of Np-237 at LANL. A 

methodology for bounding intakes of Np-237 to unmonitored workers is described in Section 7.2.3 of 

this report. 

7.4.4 LANL 7776 TLDS and Neutron Correction Factors 

SEC-00109: “NCFs can vary by more than an order of magnitude at LANL facilities.” Considering 

that Support Service workers could work at several facilities during a day, dose reconstruction using 

the data from the LANL 7776 type TLD cannot be done. 

Area-specific neutron correction factors (NCFs) are used at LANL to improve the accuracy of the 

neutron dose based on workplace instrument measurements (ORAUT-TKBS-0010-6). If workers 

frequented multiple facilities, or if the facilities frequented are unknown, NIOSH can bound neutron 

doses by applying the highest NCF for any of the buildings the worker may have entered. 

7.4.5 LANL Contamination Surveys, Postings, and Control 

SEC-00109: The Tiger Team Assessment Report (submitted by the petitioner) made a number of 

observations about the LANL site that are pertinent to the potential for unmonitored intakes (DOE, 

1991). In summary, the report observed that: (1) radiation surveys sometimes did not conform to 

LANL policies and documented schedules; (2) contamination control programs did not ensure 

complete control of the spread of contamination; (3) there were instances in which barriers had been 

removed or signage was inappropriate or missing; (4) posting was inconsistent throughout the site; (5) 

the frequency of surveys mandated by procedures was not consistently followed; (6) signs and labels 

throughout the plutonium and uranium facilities did not indicate radiological conditions, were not 

accurate, or had other problems that could lead to unsafe practices; (7) documentation of smear 

surveys was not consistently performed; (8) the use of open-front hoods led to an increased frequency 

of radioactive material contamination incidents; (9) cracked glovebox gloves were observed; (10) 

removable and fixed surface contamination limits for tritium and pure gamma-emitting nuclides were 

not in compliance with DOE Order 5480.11; (11) calibration and response-checking of fixed 

instruments and tritium monitors did not reflect the same level of attention and commitment given to 

54 of 77 
SEC-00109 01-22-09 FINAL LANL
 

portable instrumentation; (12) out-of-calibration instruments, such as glovebox hand and foot 

monitors and tritium monitors, were not placed out of service; (13) placement of air monitoring 

instruments at the DU sites was not based on studies of flow patterns; (14) facility air monitor alarm 

points, used per DOE Order 5480.11 to warn workers that airborne radioactive material contamination 

levels had exceeded an action level, were not always set at a uniform level, with the set points varying 

from monitor to monitor even in the same building; and (15) training programs had not been 

established to ensure that routine dose rate and contamination surveys were conducted in a consistent 

manner. 

None of the numerous Tiger Team findings and observations pertains to the adequacy of the internal 

or external personnel monitoring programs; therefore, they do not compromise NIOSH’s ability to 

conduct dose reconstruction with sufficient accuracy. Dose reconstructions for LANL employees are 

based upon internal and external monitoring data. These data are also employed in co-worker studies 

to estimate unmonitored worker intakes. 

7.5 Other Potential SEC Issues Relevant to the Petition Identified During the 

Evaluation 

ATTRIBUTION: Section 7.5 was completed by Ray Clark, Oak Ridge Associated Universities 

(ORAU); and Chris Miles, Quantaflux. LLC. These conclusions were peer-reviewed by the 

individuals listed on the cover page. The rationales for all conclusions in this document are explained 

in the associated text. 

During the feasibility evaluation for SEC-00109, a number of issues were identified in the LANL ER 

for Petition SEC-00051 that needed further analysis and resolution. The issues and their current status 

are: 

•	 ISSUE: SEC-00051, Sect. 7.2.1.1: There are no data available that permit internal dose 

contributions from Sr-90 to be reconstructed with sufficient accuracy. 

RESPONSE: During the time period covered by the SEC-00051 evaluation (at least until about 

1970), in vivo counting was not effectively used at LANL to monitor for mixed fission products, 

of which Sr-90 is most commonly associated. Also, prior to the termination of the RaLa program, 

the potential for exposure to Sr-90 was much greater and controls were much less robust. 

Methods for bounding intakes to Sr-90 during the post-1975 period are described in Section 

7.2.3.2. 

55 of 77 
SEC-00109 01-22-09 FINAL LANL
 

•	 ISSUE: SEC-00051, Section 7.2.1.1: After 1970, with the onset of chest counting and improved 

analytical capabilities, LANL possessed the ability to monitor for all ROCs with the exception of 

Ac-227, Cm-244, and Pa-231. Ac-227 and Pa-231 possibly could be quantified by the chest count 

procedure. However, no information has been found that would indicate an attempt at this 

process or that any such data are available. Inventory records to establish the significance of the 

source term of these “exotic” radionuclides is limited. Most available information is limited to 

waste activity reports. 

Few bioassay data are available for Ac-227, Cm-244, or Pa-231. Health physics records are 

available for the post-1975 time period which indicate that controls and protective measures 

applied when these nuclides were being used were similar to the controls applied when working 

with plutonium. A methodology to bound intakes of these nuclides by unmonitored workers using 

plutonium co-worker data is described in Section 7.2.3 of this report. 

•	 ISSUE: SEC-00051, Section 7.2.1.2: Data for Pu-238, Pu-239, Am-241, and Cs-137 are 

available. Few data for other radionuclides are available prior to the 1980s when the use of 

germanium detectors became more common. 

A significant amount of additional data has been captured from LANL since the SEC-00051 

Evaluation Report was written. Using these additional data, methodologies for bounding intakes 

to unmonitored LANL workers of the less-frequently-encountered radionuclides have been 

developed. These are described in Section 7.2.3 of this report. 

56 of 77 
 

 

 

SEC-00109 01-22-09 FINAL LANL
 

7.6 Summary of Feasibility Findings for Petition SEC-00109 

This report evaluates the feasibility for completing dose reconstructions for employees at LANL from 

January 1, 1976 through December 31, 2005. NIOSH found that the available monitoring records, 

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

the evaluated class of employees. 

Table 7-2 summarizes the results of the feasibility findings at LANL for each exposure source during 

the time period January 1, 1976 through December 31, 2005. 

Table 7-2: Summary of Feasibility Findings for SEC-00109 

January 1, 1976 through December 31, 2005 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal1

 X 

 - Pu X 

 - H-3 X 

 - U X 

 - MFP and MAP X 

 - Sr-90/Y-90 X 

 - Th-230 and Th-232 X

 - Am-241 X 

 - Np-237 X

 - Ac-227 X 

 - Pa-231 X

 - Cm-244 X 

External X

 - Gamma X 

 - Beta X 

 - Neutron X 

 - Occupational Medical X-ray X 

1

 Internal includes an evaluation of urinalysis (in vitro), airborne dust, and lung/whole body count (in vivo) data 

As of December 29, 2008, a total of 331 claims have been submitted to NIOSH for individuals who 

worked at LANL and are covered by the class definition evaluated in this report. Dose 

reconstructions have been completed for 161 individuals (~49%). 

57 of 77 
SEC-00109 01-22-09 FINAL LANL
 

8.0 Evaluation of Health Endangerment for Petition SEC-00109 

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

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

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

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

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

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

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

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

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

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

NIOSH has obtained numerous documents containing monitoring results as well as LANL process 

and source information. LANL has provided monitoring data summaries from its employee exposure 

records databases. NIOSH’s evaluation determined that it is feasible to estimate radiation dose for 

members of the proposed class with sufficient accuracy based on the sum of information available 

from available resources. Modification of the class definition regarding health endangerment and 

minimum required employment periods, therefore, is not required. 

9.0 NIOSH-Proposed Class for Petition SEC-00109 

Based on its research, NIOSH accepted the NIOSH-evaluated class to define a single class of 

employees for which NIOSH can estimate radiation doses with sufficient accuracy. The NIOSHproposed class includes Service Support Workers (which includes, but is not limited to, security 

guards, firefighters, laborers, custodians, carpenters, plumbers, electricians, pipefitters, sheet metal 

workers, ironworkers, welders, maintenance workers, truck drivers, delivery persons, rad technicians, 

and area work coordinators) who worked in any operational Technical Areas with a history of 

radioactive material use at the Los Alamos National Laboratory from January 1, 1976 through 

December 31, 2005. 

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

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

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00109. In addition, NIOSH reviewed its NOCTS dose reconstruction 

database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 

58 of 77 
SEC-00109 01-22-09 FINAL LANL
 

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

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

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

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

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

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

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

standards of performance in determining that it would be feasible to reconstruct the dose for the class 

proposed in this petition. 

59 of 77 
SEC-00109 01-22-09 FINAL LANL
 

This page intentionally left blank 

60 of 77 
SEC-00109 01-22-09 FINAL LANL
 

10.0 References 

10 C.F.R. pt. 835, App. C, Occupational Radiation Protection, Appendix C: Derived Air 

Concentrations (DAC) for Controlling Radiation Exposure to Workers at DOE Facilities, accessed 

via the Internet on August 27, 2008; http://www.hss.energy.gov/HealthSafety/WSHP/Radiation/ 

10cfr835/finalfedregjune82007.pdf 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended; available on OCAS website: www.cdc.gov/niosh/ocas/ 

DOE Order 5480.11, Radiation Protection for Occupational Workers, U.S. Department of Energy, 

December 21, 1988; SRDB Ref ID: 8073 

LASL-77-25, Welcome to Los Alamos, capsule summary of LASL site; Los Alamos Scientific 

Laboratory; 1977; SRDB Ref ID: 54586 

OCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 0, 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; September 23, 

2004; SRDB Ref ID: 32022 

OCAS-TIB-002, Tritium Calculations with IMBA, Office of Compensation Analysis and Support, 

Technical Information Bulletin, April 22, 2003; SRBD Ref ID: 22407 

ORAUT-OTIB-0019, Analysis of Coworker Bioassay Data for Internal Dose Assignment, Rev. 01; 

October 7, 2005; SRDB Ref ID: 19438 

ORAUT-OTIB-0054, Fission and Activation Product Assignment for Internal Dose-Related Gross 

Beta and Gross Gamma Analyses, Rev. 00, November 19, 2007; SRDB Ref ID: 36235 

ORAUT-OTIB-0062, draft, Internal Dosimetry Coworker Data for Los Alamos National Laboratory; 

SRDB Ref ID: Not currently available in the SRDB 

ORAUT-OTIB-0063, draft, Los Alamos National Laboratory Bioassay Data Project Final Report; 

SRDB Ref ID: Not currently available in the SRDB 

61 of 77 
SEC-00109 01-22-09 FINAL LANL
 

ORAUT-OTIB-0066, Calculation of Dose from Intakes of Special Tritium Compounds, Rev. 00, April 

26, 2007; SRDB Ref ID: 31421 

ORAUT-PROC-0060, Occupational Onsite Ambient Dose Reconstruction for DOE Sites, Rev. 01; 

June 28, 2006; SRDB Ref ID: 29986 

ORAUT-PROC-0061, Occupational X-Ray Dose Reconstruction for DOE Sites, Rev. 02; January2, 

2008; SRDB Ref ID: 39338 

ORAUT-TKBS-0010-1, Technical Basis Document for the Los Alamos National Laboratory – 

Introduction, Rev. 01; October 1, 2007; SRDB Ref ID: 35193 

ORAUT-TKBS-0010-2, Technical Basis Document for the Los Alamos National Laboratory – Site 

Description, Rev. 00; May 7, 2004; SRDB Ref ID: 19561 

ORAUT-TKBS-0010-3, Technical Basis Document for the Los Alamos National Laboratory – 

Occupational Medical Dose, Rev. 00; December 29, 2004; SRDB Ref ID: 19562 

ORAUT-TKBS-0010-4, Technical Basis Document for the Los Alamos National Laboratory – 

Occupational Environmental Dose, Rev. 00; October 8, 2004; SRDB Ref ID: 19564 

ORAUT-TKBS-0010-5, Technical Basis Document for the Los Alamos National Laboratory – 

Occupational Internal Dose, Rev. 00; December 21, 2004; SRDB Ref ID: 19565 

ORAUT-TKBS-0010-6, Technical Basis Document for the Los Alamos National Laboratory – 

Occupational External Dose, Rev. 01; May 30, 2007; SRDB Ref ID: 32018 

SEC-00051, 2007, SEC Petition Evaluation Report, Petition SEC-00051, T. Vitkus, T. Adler, R. 

Clark, D. Mantooth, C. Barton, V. Shockley, R. Kathren; August 7, 2006; SRDB Ref ID: 41108, pdf. 

pp. 76 

SCA-TR-TASK1-0011, 2006, Los Alamos National Laboratory Site Profile Review, S. Cohen & 

Associates, Saliant Inc., August 2006; SRDB Ref ID: 46217 

Asprey, 1964, Protactinium Fluorides, the New Class, MPaF6, L. B. Asprey and R. A. Penneman; 

Science 145, no. 3635, p. 934, August 28, 1964 

Bayo, 1963, Letter from N. E. Bradbury to C. C. Campbell; LANL; July 18, 1963; SRDB Ref ID: 885 

Bayo, date unknown, Estimates of Materials at the Bayo Canyon Firing Sites; author unknown; date 

unknown; Los Alamos Scientific Laboratory; SRDB Ref ID: 7895 

Blackstock, 1978, Neutron Response of a New Albedo-Neutron Dosimeter, University of California, 

Los Alamos Scientific Laboratory, A. W. Blackstock, J. R. Cortez, G. J. Littlejohn, E. Storm, January 

17-19, 1978; SRDB Ref ID: 27246 

62 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Buckland, 1976, Health Physics Aspects of Thorium, office memorandum from C. Buckland (Leader, 

H-1 General & Materials Monitoring) to Tom Larson (Alt. Group Leader, WX-2, MS-920); Los 

Alamos Scientific Laboratory; October 29, 1976; SRDB Ref ID: 54382 

Buddenbaum, 2006a, E-mail correspondence: LANL Lab Notebooks, J. Buddenbaum; 

ENSR|AECOM; Westford, Massachusetts; September 1, 2006; SRDB Ref ID: 27995 

Buddenbaum, 2006b, Conference Call Minutes, Final, J. Buddenbaum; ENSR|AECOM; Westford, 

Massachusetts; February 13, 2006; SRDB Ref ID: 27992 

Cerro Grande, 2001, Updated Calculations of the Inhalation Dose from the Cerro Grande Fire Based 

on Final Air Data; LA-UR-01-1132; February, 2001; SRDB Ref ID: 46247 

Checklist, 1977, Employee Health Physics Check List; Los Alamos National Laboratory; various dates 

in 1977; SRDB Ref ID: 54392 

Checklist, 1985, Employee Health Physics Checklist, Los Alamos National Laboratory, HS Form 

Number 3-1A (6/84); April 9, 1985; SRDB Ref ID: 54543 

Checklist, 1990, Employee Health Physics Checklist, Los Alamos National Laboratory, HS Form 

Number 3-1A (9/86); April 12, 1990; SRDB Ref ID: 51438 

Checklist, 2000, Health Physics Checklist, Version 2000 10 18 v1 release, Los Alamos National 

Laboratory; SRDB Ref ID: 12969 

Conference A, 2008: ORAU Team and NIOSH with LANL Radiation Protection Division Personnel; 

August 7, 2008; SRDB Ref ID: 55742 

Conference B, 2008: ORAU Team and NIOSH with LANL Radiation Protection Division Personnel; 

August 28, 2008; SRDB Ref ID: 55741 

Conference C, 2008: ORAU Team and NIOSH with LANL Radiation Protection Division Personnel; 

September 9, 2008; SRDB Ref ID: 55744 

Criteria, 1982, 1982 Criteria for Routine Am-241 Urine Sampling, J. N. P. Lawrence; June 24, 1982; 

SRDB Ref ID: 51533, pdf. pp 20-21 

DOE, 1990, Results of DOE Indoor Radon Study, August 1990, Vol. 1, DOE, August 1990; SRDB 

Ref ID: 13191 

DOE, 1991, Tiger Team Assessment of the Los Alamos National Laboratory, U.S. Department of 

Energy; November 1991; SRDB Ref ID: 23620 

DOE, 1993, Operable Unit 9 Site Scoping Report, Volume 7, Waste Management, U.S. Department of 

Energy; Environmental Restoration Program; February 1993; SRDB Ref ID: 11877 

63 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Dummer, date unknown, Quarterly Progress Report April - June, 1978, J. E. Dummer, Los Alamos 

Scientific Laboratory, date unknown; SRDB Ref ID: 40679 

Ennis, M., 2003, Historical Minimum Detectable Activities for LANL’s In Vivo Measurements 

Laboratory, LA-UR-03-7702, Los Alamos National Laboratory; SRDB Ref ID: 27304 

Eppley, 1979, Reported Needs for the Radioactive Isotopes Uranium-234, Protactinium-231, 

Thorium-230, and Thorium-229, R. E. Eppley and R. E. Vallee; MLM-ML-77-46-0003; Monsanto 

Research Corporation, Mound Laboratory; June 1, 1979; SRDB Ref ID: 25195 

Farr, 1953, Crystal Structure of Actinium Metal and Actinium Hydride, J. D. Farr, A. I. Giorgi, and M. 

G. Bowman; LA-1545, Los Alamos National Laboratory, April 1953; SRDB Ref ID: 970 

Follow-up, 1985, Radiation Exposure Follow-up, Los Alamos National Laboratory, November 1985; 

SRDB Ref ID: 54280, pdf p. 3 

Harper, 1981, The Decommissioning of TA-21-153, 227Ac Contaminated Old Filter Building, J. R. 

Harper and R. Garde; LA-9047-MS; Los Alamos National Laboratory; November 1981; SRDB Ref 

ID: 929 

Hoffman, 1999, The LANL Model 8823 Whole-Body TLD and Associated Dose Algorithm, J. M. 

Hoffman and M. W. Mallett; Los Alamos National Laboratory; Radiation Protection Journal; Vol. 77, 

No. 5 suppl, November 1999; OSA Ref ID: 105765 

Inkret, 1998a, Los Alamos National Laboratory Radiological Dose Assessment – Tritium Internal 

Dosimetry and Bioassay Programs, Inkret, W. C., D. Lewis, T. T. Little, G. Miller, and M. E. 

Schillaci, LA-UR-99-832, Los Alamos National Laboratory 1998; SRDB Ref ID: 13485 

Inkret, 1998b, Los Alamos National Laboratory Radiological Dose Assessment – Americium Internal 

Dosimetry and Bioassay Program, W. C. Inkret, D. Lewis, G. Miller, and M. E. Schillaci; 

LA-UR-99-836; Los Alamos National Laboratory; 1998; SRDB Ref ID: 13488 

Inkret, 1999a, Los Alamos National Laboratory Radiological Dose Assessment – Tritium Internal 

Dosimetry, W. C. Inkret, D. Lewis, G. Miller, and M. E. Schillaci; LA-UR-99-838; Los Alamos 

National Laboratory; 1999; SRDB Ref ID: 12899 

Inkret, 1999b, Internal Dosimetry for Inhalation of Hafnium Tritide Aerosols, W. C. Inkret, M. E. 

Schillaci, Y. S. Cheng, D. W. Efurd, T. T. Little, G. Miller, J. A. Musgrave, J. R. Werner; Los Alamos 

National Laboratory; LA-UR-98-4818; August 10, 1999; SRDB Ref ID: 12906 

Inspection of Environment, 2005, Inspection of Environment, Safety, and Health Programs at the Los 

Alamos National Laboratory, Office of Independent Oversight, Office of Security and Safety 

Performance Assurance, Office of the Secretary of Energy, November 2005; OSA ID: 106015 pdf pp. 

Internal Dosimetry, 2007, Internal Dosimetry Question, P. Hoover, Los Alamos National Laboratory; 

January 3, 2007; SRDB Ref ID: 28600 

64 of 77 

993 
SEC-00109 01-22-09 FINAL LANL
 

Investigation, 2006, Type B Investigation of the Am-241 Contamination Accident at the Sigma 

Facility, LANL, July 14, 2005, Doug Minnema; National Nuclear Security Administration; May, 3, 

2006; SRDB Ref ID: 46117 

Jette, 1949a, CMR Division Progress Report July 20, 1949 – August 20, 1949, E. R. Jette; LAMS-945, 

Los Alamos National Laboratory; 1949; SRDB Ref ID: 41103 

Jette, 1949b, CMR Division Progress Report August 20, 1949 – September 20, 1949, E. R. Jette; 

LAMS-957, Los Alamos National Laboratory; 1949; SRDB Ref ID: 41104 

Kirby, 1959, The Radiochemistry of Protactinium, H. W. Kirby; U.S. Energy Commission Report 

NAS-NS 3016; Subcommittee on Radiochemistry, National Academy of Sciences, National Research 

Council; Washington, D.C.; December 1959; SRDB Ref ID: 41602 

Kirkham, 2006, Urine Bioassay Data Indicating Americium Bioassay Analysis (1954-1957), raw data 

logs captured by T. Kirkham; Los Alamos National Laboratory; various dates; SRDB Ref ID: 27951 

Langham, 1952, Toxicology of Actinium Equilibrium Mixture, W. Langham and J. Storer; LA-1372; 

Los Alamos National Laboratory; February 20, 1952; SRDB Ref ID: 974 

LANL, 1986, Photodosimetry Evaluation Book, Volume IV, Los Alamos National Laboratory; 1986; 

SRDB Ref ID: 8206 and 8209 

LANL, 1989, Photodosimetry Evaluation Book, Volume VI, Los Alamos National Laboratory; 1989; 

SRDB Ref ID: 27288 

LANL, 1996, Photodosimetry Evaluation Book, Volume VII, Los Alamos National Laboratory; 1996; 

SRDB Ref ID: 27273 

LANL, 2001, Photodosimetry Evaluation Book, Volume VIII, Los Alamos National Laboratory; 2001; 

SRDB Ref ID: 27292 

LANL, 2003, Photodosimetry Evaluation Book, Volume IX, Los Alamos National Laboratory, 2003; 

SRDB Ref ID: 27301 

LANL, 2004a, Health Physics Checklist, http://eshdb.lanl.gov/~esh12/new_eshdb/Matrices, accessed 

April 30, 2004; SRDB Ref ID: 12969 

LANL, 2004b, Notes Regarding the LANL Dosimetry Data Obtained During 2004, Los Alamos 

National Laboratory; 2004; SRDB Ref ID: 27261 

LANL, 2008, LANL Response to NIOSH Request Regarding SEC Petition [SEC-00109], Paul Hoover, 

Radiation Protection Division, Los Alamos National Laboratory; September 2, 2008; SRDB Ref ID: 

LASL, 1959a Photodosimetry Evaluation Book “Bible,” Volume I, Procedures 1944-1959; Los 

Alamos Scientific Laboratory; 1959; SRDB Ref ID: 8181 and 8266 

65 of 77 

55136 
SEC-00109 01-22-09 FINAL LANL
 

LASL, 1959b, H-Division Progress Report, August 20 - September 20, 1959, T. L. Shipman; Los 

Alamos Scientific Laboratory; HSPT-REL-94-912; SRDB Ref ID: 12914 

LASL, 1969, Photodosimetry Evaluation Book “Bible,” Volume II, Procedures 1960-1969; Los 

Alamos Scientific Laboratory; 1969; SRDB Ref ID: 8173 

LASL, 1977a, Photodosimetry Evaluation Book, "Bible" Volume III, Procedures, 1970-1977, Los 

Alamos Scientific Laboratory; SRDB Ref ID: 8176 and 8192 

LASL, 1977b, Quarterly Progress Report, July – September 1977, J. E. Dummer; Los Alamos 

Scientific Laboratory; Group H-1 Health Physics; SRDB Ref ID: 27314 

LASL, 1977c, Quarterly Progress Report, October – December 1977, J. E. Dummer; Los Alamos 

Scientific Laboratory; Group H-1 Health Physics; SRDB Ref ID: 27317 

LASL, 1978, Quarterly Progress Report, April – June 1978, Group H-1, Health Physics; Los Alamos 

Scientific Laboratory; 1978; SRDB Ref ID: 40697 

LASL, 1979, Photodosimetry Evaluation Book, Volume V, Los Alamos Scientific Laboratory; 1979; 

SRDB Ref ID: 2727 

List, 2008, Internet site: Complete List of All U.S. Nuclear Weapons, 

http://nuclearweaponarchive.org/Usa/Weapons/Allbombs.html, compiled from various cited reference 

sources 

Little, 2003a, Identifying Uranium Intakes from Bioassay Data in the Presence of Environmental 

Background, T. T. Little, G. Miller, and R. Guilmette; Proceedings of the 49th Annual Radiobioassay 

& Radiochemical Measurements Conference; 2003; http://www.bioassay.org/2003; SRDB Ref ID: 

12939 

Little, 2003b, Special Dose Assessment, T. Little, G. Miller, and R. Guilmette, July 2, 2003; SRDB 

Ref ID: 55135 

Mallett, 1990, High-Energy Neutron Dosimetry at the Clinton P. Anderson Meson Physics Facility, 

LA-11740-MS, University of California, Los Alamos National Laboratory; M. W. Mallett, D.G. 

Vasilik, G. J. Littlejohn, J. R. Cortez; January 1990; SRDB Ref ID: 912 

Mosteller, 2003, Creation of a Simplified Benchmark Model for the Neptunium Sphere Experiment, R. 

D. Mosteller and D. J. Loaiza; Los Alamos National Laboratory; ANS/ENS 2003 Winter Meeting; 

New Orleans, LA; November 16-23, 2003; SRDB Ref ID: 49288 

Mound, 1995, Technical Manual, Mound Site Radionuclides by Location, Issue 1, MD-22153, July 

26, 1995; SRDB Ref ID: 3240 

Neptunium, 2005, Inspection of Environment, Safety, and Health Programs at the Los Alamos 

National Laboratory; Office of Independent Oversight, Office of Security and Safety Performance 

Assurance, Office of the Secretary of Energy; November 2005: OSA Ref ID: 106015, pdf. p. 993 

66 of 77 
SEC-00109 01-22-09 FINAL LANL
 

NUREG-1400, Air Sampling in the Workplace, Final Report, Division of Regulatory Applications, 

Office of Nuclear Regulatory Research, United States Nuclear Regulatory Commission; September 

1993; SRDB Ref ID: 20129 

O’Brien, 2006, Los Alamos National Laboratory (LANL) Bioassay Data Project Final Report, J. M. 

O’Brien; Shonka, Inc.; Atlanta, Georgia; June, 2006; SRDB Ref ID: 49287 

ORPS, 2003, Curium 244 Detected on Employee’s DOE Badge, Badge Transported Off-site, 

Improper Shipment of Radioactive Material, ORPS Number DP-ALO-LA-LANL-ESHSUPT-2003­

0001, Los Alamos National Laboratory; March 6, 2003; SRDB Ref ID: 57071 

P-Division, 1977, Radiological Safety Procedures in P-Division, W. E. Stein, Radiation Safety 

Committee, Los Alamos National Laboratory; January 1977; SRDB Ref ID: 54253 

Penneman, 1960, The Radiochemistry of Americium and Curium, R. A. Penneman and T. K. Keenan; 

NAS-NS-3006, National Academy of Sciences, National Research Council, University of California; 

January 31, 1960; SRDB Ref ID: 41106 

Petition, 2008, SEC Petition and narrative attachment submitted for SEC-00109; OSA Ref ID: 

105760, pdf pp. 11-12 

Processes, Author Unknown, Processes and Characteristics of Major Isotopes Handled at Mound, No 

author, no publication date. SRDB Ref ID: 12328 

Quarterly, 1976, Quarterly Progress Report January – March 1976, J. E. Dummer, Group H-1 Health 

Physics; no issue date; SRDB Ref ID: 44681 

Quarterly, 1979, Quarterly Progress Report October – December 1979, J. E. Dummer, Group H-1 

Health Physics, January 16, 1980; SRDB Ref ID: 40709 

Quarterly,1980, Quarterly Progress Report January – March 1980, J. E. Dummer, Group H-1 Health 

Physics, April 14, 1980; SRDB Ref ID: 40710 

Records, 2008, LANL Radiological Incident-related Records, Radiation Protection Division, Los 

Alamos National Laboratory; December 1, 2008; SRDB Ref ID: 55649 

RWP, 1995, Radiological Work Permit, author unknown, 1995; SRDB Ref ID: 51749 

Smith, 1979, Superconducting Properties of Protactinium, J. L. Smith, J. C. Spirlet, and W. Muller; 

Science, 205, 188-190, July 13, 1979 

SOPs, 1973, office memorandum, Standard Operating Procedures for the Handling of Actinide 

Elements, R. A. Penneman and L. B. Asprey, Los Alamos Scientific Laboratory, October 15, 1973; 

SRDB Ref ID: 54127 

67 of 77 
SEC-00109 01-22-09 FINAL LANL
 

SOPs, 1976, office memorandum, Radiation Protection Procedures, from J. E. Dummer to J. Aragon; 

Los Alamos Scientific Laboratory; September 17, 1976; SRDB Ref ID: 54264 

Steele, 1998, CMR Basis for Interim Operations, Steele, C. and J. E. O’Neil, Los Alamos National 

Laboratory; August 27, 1998; LAP (Los Alamos Project), 1944a. Progress Report Number Twelve of 

the Experimental Physics Division of the Los Alamos Project, LAM-48. January 1, 1944; 

http://www.doeal.gov/laso/SWEIS/LANLDocuments/279%20LANL%202004%20Cont%20Waste%2 

0Gen.pdf 

SWP, 1992, Special Work Permit Radiation Work: Disconnect Thoria Duct, Stack, and Fan, Noel 

Calkins, Los Alamos National Laboratory; July 31, 1992; SRDB Ref ID: 52172, pdf pp. 33-45 

TA-21-153, 1981, The Decommissioning of TA-21-153, Ac-227 Contaminated Old Filter Building, J. 

R. Harper, R. Garde; Los Alamos National Laboratory; November 1981; SRDB Ref ID: 929 

TA-55 RWP, 1994, TA-55 Radiological and Hazardous Work Permit, Sammi Owens, Los Alamos 

National Laboratory; August 30, 1994; SRDB Ref ID: 52396 

Targeted Sr-90, 1997, LANL Bioassay Results for Targeted Sr-90 Dosimetry, Los Alamos National 

Laboratory; 1997; SRDB Ref ID: 55137 

Targeted Th-232, 2000, Whole Body/Chest Count Dosimetry Report, Los Alamos National 

Laboratory; February 23, 2000; SRDB Ref ID: 55138 

Tribby, 1946, Internal memorandum, Health Protection of Maintenance Personnel Working in 

Contaminated Areas, J. F. Tribby; Los Alamos Scientific Laboratory; May 14, 1946; SRDB Ref ID: 

27980 

Tyree, 1974, Single Scintillation Crystal Versus Phoswich Detectors for In Vivo Low-Energy Photon 

Detection, W. H. Tyree, Dow Chemical, January 7, 1974; SRDB Ref ID: 24382 

Tyree, 1975, Operating Parameters and Limitations of a Germanium-Lithium Drifted Detector System 

for the In Vivo Measurement of Americium-241, W. H. Tyree, R. B. Falk, R. W. Liskey, Dow 

Chemical, February 3, 1975; SRDB Ref ID: 24380 

Vasilik, 1983, In Vivo Assessment of Whole Body Radioisotope Burdens at the Los Alamos National 

Laboratory, D. G. Vasilik and I. C. Aikin; LA-9858-MS, Los Alamos National Laboratory; 1983: 

SRDB Ref ID: 925 

Whicker, 1997, Evaluation of Continuous Air Monitor Placement in a Plutonium Facility, J. J. 

Whicker, J. C. Rodgers, C. I. Fairchild, R. C. Scripsick, and R. C. Lopez; Health Physics, Volume 72, 

pp. 734–743; 1997; SRDB Ref ID: 13095 

68 of 77 
 

SEC-00109 01-22-09 FINAL LANL
 

Whicker, 2004, Relationship of Air Sample Measurements to Internal Dose: A Review, J. J. Whicker; 

Health Physics Society Midyear Topical Meeting; 2004; SRDB Ref ID: 13096 

Wing 9, 1999, Wing 9 Hot Cells Support Work Involving Highly Radioactive Materials, Actinide 

Research Quarterly, 1st quarter 1999; Nuclear Material and Technology; Los Alamos National 

Laboratory; 1999; http://www.fas.org/sgp/othergov/doe/lanl/orgs/nmt/99spring.pdf. 

Wingfield, 1974, memorandum: Inventory of Quantities and Locations of Radioactivity in the 

Environment On and Near AEC Sites, from E. E. Wingfield (AEC) to R. Taschek (LASL), Los 

Alamos National Laboratory; February 19, 1974; SRDB Ref ID: 12978 

69 of 77 
SEC-00109 01-22-09 FINAL LANL
 

This page intentionally left blank 

70 of 77 
SEC-00109 01-22-09 FINAL LANL
 

Attachment 1: Documentation Provided by Petitioner 

In qualifying and evaluating the petition, NIOSH reviewed the following documents submitted by the 

petitioner (SEC-00109 Petition: OSA Ref ID 105760): 

•	 Type B Investigation of the Am-241 Contamination Accident at the Sigma Facility, LANL; July 

14, 2005; Doug Minnema, PhD, CHP 

•	 Office Memorandum: Tritium Leak at TA-35-1; August 4, 1980; John Ahlquist 

•	 Informal Investigation Report: Kiva I UF6 Release Bldg 23, TA-18 on August 22, 1979; R. E. 

Malenfant, A. M. Valentine 

•	 LANL SEC Petition, 1943-1975 

•	 DOE/IG-0591 Allegations Concerning the Reporting of a Radiological Incident at the Los Alamos 

National Laboratory 

•	 Stack Parameters Annual Review, 1984 

•	 The Los Alamos National Laboratory's Air Emissions Monitoring Program: A Quick Look 

Technical Review (9/9/91); Ray Waller, Charles Keller, and Sumner Barr 

•	 Resource Conservation and Recovery Act (RCRA) Permit Containing All Changes Since 1995; 

September 27, 2004; Jack Ellvinger 

•	 Aspects of Dispersion following an Explosive Release (2004); D. M. Deaves, C. R. Hebden 

•	 Improving the Accuracy of Dispersion Models; Richard H. Schulze 

•	 The Physics and Mechanisms of Primary Blast Injury; James H. Stubmiller, Yancy Y. Phillips III, 

and Donald R. Richmond 

•	 Blast Loading and Blast Effects on Structures - An Overview (2007); T. Ngo, P. Mendis, A. 

Gupta, and J. Ramsay 

•	 Guidelines for the Inclusion of Low Wind Speed Conditions into Risk Assessments (2000); I.G. 

Lines, J. H. Daycock, and D. M. Deaves 

•	 Workbook on the Dispersion of Dense Gases (1988); R. E. Britter, J. McQuaid 

•	 Considering the Feasibility of Developing a Simple Methodology to Assess Dispersion in 

Low/Zero Windspeeds (1998); I. G. Lines, D. M. Deaves 

•	 Tiger Team Report 1 

71 of 77 
SEC-00109 01-22-09 FINAL LANL
 

•	 Tiger Team Report 2 

•	 Security and Other Issues Related to Out-Processing of Employees at Los Alamos National 

Laboratory; DOE/IG-0677 (2005) 

•	 Fire maps 

•	 Comments on the 2002 Risk Assessment Corporation analysis of risks from the 2000 Cerro 

Grande fire at Los Alamos National Laboratory (2005); Abel Russ 

•	 Effects of the Cerro Grande Fire (Smoke and Fallout Ash) on Soil Chemical Properties; LA13769-MS 

•	 Radiological and Nonradiological Effects after the Cerro Grande Fire; LA-1391 

•	 Updated Calculation of the Inhalation Dose from the Cerro Grande Fire; LA-UR-01-1132 

•	 The Cerro Grande Fire, Los Alamos, New Mexico; LA-UR-01-1630 

•	 Lessons Learned From the Cerro Grande (Los Alamos) Fire; GAO/T-RCED-00-273 

•	 Summary Report: Analysis of Exposure and Risks to the Public from Radionuclides and 

Chemicals Released by the Cerro Grande Fire at Los Alamos (2002); S. Shawn Mohler, et al. 

•	 Memo: Some Quality Assurance Issues Regarding Input Data For Unmonitored Sources Dose 

Estimation Date; September 1, 2002; Arjun Makhijani 

•	 Memo: Some issues for the ITAT review regarding unmonitored sources during the third CAA 

audit; July 11, 2002; Arjun Makhijani 

•	 DOE/EIS-0380D, June 2006 Draft, Site Wide Environmental Impact Statement for Continued 

Operation of Los Alamos National Laboratory; Los Alamos, New Mexico 

•	 LA-14341-ENV, Environmental Surveillance 2006 

•	 Long-Term Risk from Actinides in the Environment: Modes of Mobility (2000); David D. 

Breshears, et al. 

•	 LANL Hazardous Waste Permit Fact Sheet Attachment listing new SWMUs and AOCs 

•	 Increased Wind Erosion from Forest Wildfire: Implications for Contaminant-Related Risks 

(2006); Jeffrey J. Whicker, John E. Pinder III, and David D. Breshears 

•	 LA-13839-MS, U.S. Department of Energy Report 2000; LANL Radionuclide Air Emissions 

(Parts 1, 2, and 4); Keith Jacobson 

•	 LA-UR-00-3471, Special Edition of the SWEIS Yearbook: Wildfire 2000 

72 of 77 
SEC-00109 01-22-09 FINAL LANL
 

•	 LA-UR-04-0195, Unplanned Airborne Releases at Los Alamos National Laboratory: A 

Comparison between Observations and Model Predictions (2004); Scot Johnson 

•	 New Mexico's Right to Know: The Impacts of Los Alamos National Laboratory Operations on 

Public Health and the Environment (2003); Bernd Franke, Catherine M. Richards, Steve Wing, 

and David Richardson 

•	 Final Report, Independent Technical Audit of Los Alamos National Laboratory for Compliance 

with the Clean Air Act, 40 CFR 61, Subpart H in 2001; DOJ File Number: 90-5-1749A; Case 

Name: CCNS v DOE October 2002 (Independent Technical Audit for 2001) 

•	 LANL Environmental Surveillance 2000 

•	 In-Place Testing Summary (1991); John P. Ortiz, Douglas Barney 

•	 Dispersion Near Buildings; Application of Simple Modeling (1997); I. G. Lines, D. M. Deaves 

•	 Citizens Monitoring and Technical Assessment - June 2007 Analysis of Radiochemical 

Contaminants in Los Alamos Region Biota and Environmental Materials at the Perimeter of the 

Los Alamos National Laboratory; Marco Kaltofen (PE), Tom Carpenter 

•	 Better Oversight Needed for Safety and Health, Activities at DOE's Nuclear Facilities; EMD-81­

108 (1981) 

•	 Nuclear Health and Safety Efforts to Strengthen DOE's Health and Epidemiology Program; 

GAO/RCED-91-67 (1991) 

•	 GAO/RCED-98-197, Uncertain Progress in Implementing Reforms (1998) 

•	 Need for Improved Responsiveness to Problems at DOE Sites; GAO/RCED-90-101 

•	 DOE's Safety and Health Oversight Program at Nuclear Facilities Could Be Strengthened; 

GAO/RCED-84-50 (1993) 

•	 Better Planning Needed to Correct Records Management Problems, GAO/RCED-92-88 (1992) 

•	 Corrective Actions on Tiger Teams' Findings Progressing Slower Than Planned; GAO/RCED-93­

66 (1993) 

•	 Protecting Workers and the Public Continues to Challenge; DOE GAO/T-RCED-94-283 (1994) 

•	 Handbook on Atmospheric Diffusion (1982); Steven R. Hanna, Gary A. Briggs, and Rayford P. 

Hosker, Jr. 

•	 General and Specific Characteristics for Model: HOTSPOT 

73 of 77 
 

SEC-00109 01-22-09 FINAL LANL
 

•	 Feasibility study of Modeling Particle Deposition onto a Person using Computational Fluid 

Dynamics (2006); N. Gobreau, D. Mark, and A. Garrard 

•	 Audit Report on "The Department's Reporting of Occupational Injuries and Illnesses”; DOE/IG0648 (2004) 

•	 Characterization Wells at Los Alamos National Laboratory; DOE/IG-0703 (2005) 

•	 A Guide to Radiological Accident Considerations for Siting and Design of DOE Nonreactor 

Nuclear Facilities; J. C. Elder, et al. 

•	 LA-13235-T, Compliance Program for 40 C.F.R. 61, Subpart H at Los Alamos National 

Laboratory (1997); Eric A. McNamara 

•	 Brief Climatology for Los Alamos, N. M.; UNL, 1999 

•	 Los Alamos Cancer Rate Study: Phase I Cancer Incidence in Los Alamos County, 1970- 1990 

Final Report (1993); William F. Athas, PhD; Charles R. Key, MD, PhD 

•	 LAMS-202, Explosives (1945); G.M. Kistiakowski 

•	 Death Rate Report for New Mexico by County, death years through 2002 

•	 LA-UR-97-4765, Overview of Los Alamos National Laboratory - 1997 

•	 LASL-77-36, Laboratory Activities Description of Work Done At MSL By Division, Department, 

and Group (1977) 

•	 LA-UR-00-1168, Siting of Environmental Direct-Penetrating-Radiation Dosimeters; Michael W. 

McNaughton, David H. Kraig, and Joseph C. Lochamy 

•	 LA-UR-00-3091, Performance Evaluation of LANL Environmental Radiological Air Monitoring 

Inlets at High Wind Velocities Associated with Re-suspension; John Rodgers, Piotr Wasiolek, Jeff 

Whicker, Craig Eberhart, Keith Saxton, and David Chandler 

•	 Long Term Tracer Study at Los Alamos, New Mexico; Part I: Wind, Turbulence, and Tracer 

Patterns (1994); Brent M. Bowen 

•	 Long Term Tracer Study at Los Alamos, New Mexico; Part II: Evaluation and Comparison of 

Several Methods to Determine Dispersion Coefficients; Brent M. Bowen 

•	 New Mexico Air Quality Bureau Dispersion Modeling Guidelines (2003) 

•	 Mixing Heights, Wind Speeds, and Potential for Urban Air Pollution Throughout the Contiguous 

United States (1972); George C. Holzworth 

74 of 77 
 

SEC-00109 01-22-09 FINAL LANL
 

•	 Los Alamos National Laboratory Radiological Facility List; PS-OAB-403, Rev. 1 (2002); George 

F. Nolan 

•	 DOE/DP-0137, Plutonium - The First 50 Years (1996); United States Plutonium Production, 

Acquisition, and Utilization from 1944 through 1994 (1996) 

•	 The Effect of Stack Height, Stack Location and Rooftop Structures on Air Intake Contamination: 

A Laboratory and Full-Scale Study (2004); Ted Stathopoulos, Louis Lazure, Patrick Saathoff, and 

Amit Gupta 

•	 Source Term Modeling of Releases within Building Complexes (2003); A. Scaperdas and C. R. 

Hebden 

•	 LA-UR-98-4539, Emergency Responders' "Rules-of-Thumb" for Air Toxics Releases in Urban 

Environments (1998); Michael J. Brown 

•	 SCA-TR-TASK1-0011, Los Alamos National Laboratory Site Profile Review (2006); Joseph 

Fitzgerald 

•	 Investigation of Excess Thyroid Cancer Incidence in Los Alamos County Final Report (1996); 

William F. Athas 

•	 Dangerous Discrepancies: Missing Weapons Plutonium in Los Alamos National Laboratory 

Waste Accounts (2006); Arjun Makhijani and Brice Smith, 

•	 LANL-04M, Satellite Image of Los Alamos 

•	 Draft Report, Independent Technical Audit of Los Alamos National Laboratory for Compliance 

with the Clean Air Act, 40 CFR 61, Subpart H in 2001; DOJ File Number: 90-5-1749A; Case 

Name: CCNS v DOE October 2002 (CCNS Comments) 

•	 Final Report, Independent Technical Audit of Los Alamos National Laboratory for Compliance 

with the Clean Air Act, 40 CFR 61, Subpart H in 2001; DOJ File Number: 90-5-1749A; Case 

Name: CCNS v DOE October 2002 (IEER Comments) 

•	 Monitoring Report of the Institute for Energy and Environmental Research on the First 

Independent Technical Audit of the Los Alamos National Laboratory's Compliance Status with 

Respect to the Clean Air Act II; April 2000; Arjun Makhijani and Bernd Franke 

•	 Final Report of the Institute for Energy and Environmental Research on the Second Clean Air Act 

Audit of Los Alamos National Laboratory by the Independent Technical Audit Team; December 

13, 2000; Arjun Makhijani and Bernd Franke 

•	 Report of the Monitoring Team of the Institute for Energy and Environmental Research on the 

[Third] Independent Audit of Los Alamos National Laboratory for Compliance With the Clean Air 

Act, 40 CFR 61, Subpart H in 2001 to Concerned Citizens for Nuclear Safety; December 18, 

2002; Arjun Makhijani, Ph.D.; Bernd Franke 

75 of 77 
SEC-00109 01-22-09 FINAL LANL
 

•	 LANL Comments on the RAC Audit Draft Report 

•	 LANL ES&H Self Assessment LANL SWElS, 1999 

•	 Aerodynamic Properties of Urban Areas Derived from Analysis of Surface Form (1999); C. S. B. 

Grimmond and T. R. Oke 

•	 Application of Atmospheric Transport Models for Complex Terrain (1984); David S. King and 

Susan S. Bunker 

•	 Atmospheric Transport Models for Complex Terrain (1984); C. G. Davis, S. S. Bunker, and J. P. 

Mutschlecner 

•	 Diffusion in a Canyon within Rough Mountainous Terrain (April 1975); G. E. Start, C. R. 

Dickerson, and L. L. Wendall 

•	 Dispersion in Complex Terrain: A Summary of the AMS Workshop; Bruce A. Egan and Francis 

Schierrneier 

•	 Dispersion Parameters over Forested Terrain (1988); R. T. Pinker and J. Z. Holland 

•	 Earth's Atmosphere, Wikipedia 

•	 Meteorology, Wikipedia 

•	 Influence of External Meteorology on Nocturnal Valley Drainage Winds (1988); Sumner Barr and 

Montie M. Orgill 

•	 Harmonization in the Preprocessing of Meteorological Data for Atmospheric Dispersion Models 

(COST 710); Bernard Fisher and David Thomson 

•	 Nocturnal Wind Direction Shear and Its Potential Impact on Pollutant Transport (2000); Brent M. 

Bowen, Jeffrey A. Baars, and Gregory L. Stone 

•	 Potential Temperature Analysis for Mountainous Terrain (1972); Owen P. Cramer 

•	 On Pressure-Driven Wind in Deep Forests (1989); Joshua Z. Holland 

•	 Surface Delays for Gases Dispersing in the Atmosphere (2001); John D. Wilson, Thomas K. 

Flesch, and Real D'Arnours 

•	 Tributary, Valley and Sidewall Air Flow Interactions in a Deep Valley (1989); William F. Porch, 

Richard B. Fritz, Richard L. Coulter, and Paul H. Gudikson 

•	 Two-Zone Convective Scaling of Diffusion in Complex Terrain (1994); C.E. Skupniewicz 

76 of 77 
SEC-00109 01-22-09 FINAL LANL
 

•	 U.S. Standard Atmosphere, 1976 

•	 Price-Anderson letters that detail violations by LANL of the Price-Anderson Act, as amended. 

•	 Special Environmental Analysis: Cerro Grande Fire 

•	 Rad-NESHAPs Project Records: Quality Assurance Review of Dose Factors Calculated from 

Nuclear Decay Data for S-38 

•	 Rad-NESHAPs Project Records: Quality Assurance Review of Dose Factors Calculated from 

Nuclear Decay Data for S-37 

•	 Rad-NESHAPs Project Records: Quality Assurance Review of Dose Factors Calculated from 

Nuclear Decay Data for S-35 

•	 Rad-NESHAPs Project Records: Quality Assurance Review of Dose Factors Calculated from 

Nuclear Decay Data for Au-192 

77 of 77