Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 1 of 61

NIOSH Response to SC&A’s Review of 

the SEC-00109 LANL Addendum, with 

Revised References Section and Appendix

Response Paper

National Institute for Occupational

Safety and Health 

October 23, 2018

Chris Miles 

Oak Ridge Associated Universities Team

Reviewed by LaVon Rutherford 

Division of Compensation Analysis and Support

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 2 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

SUMMARY

In the SEC-00109 Evaluation Report Addendum, NIOSH relied heavily on a presumption of 

compliance with 10 CFR Part 835 to conclude that unmonitored workers were unlikely to have 

received intakes of radioactive materials that would have resulted in 100 mrem CEDE per 

year. NIOSH concurs with SC&A’s assessment (SC&A, 2017) that compliance with the 10 CFR 

835 milestone may not be sufficient for demonstrating actual implementation of the 

corresponding radiation monitoring program requirements. NIOSH also concurs that reliance on 

oversight findings may not be sufficient for validating that LANL had fully implemented 10 CFR 

Part 835. Since the issuance of SC&A’s review, NIOSH has compared the available bioassay 

data for monitored LANL workers to the 100 mrem CEDE monitoring threshold and found that 

monitored workers were unlikely to receive 100 mrem CEDE intakes. Also, in response to 

SC&A’s concerns, NIOSH re-emphasizes the significance of LANL’s field monitoring 

programs, which were intended to ensure that unmonitored individuals were unlikely to receive 

intakes of 100 mrem CEDE. These two topics are discussed herein under “NIOSH: Review 

Completed That Supports the Assumption That Unmonitored Worker Intakes Were Not Likely to 

Have Exceeded 100 mrem CEDE.” In conclusion, NIOSH finds that the weight of the evidence 

supports the assumption that unmonitored LANL workers were unlikely to have received intakes 

greater than 100 mrem CEDE per year. For purposes of dose reconstruction for unmonitored 

LANL workers during the 10 CFR 835 era, the assignment of 100 mrem CEDE intakes appears 

to be claimant favorable.

BACKGROUND

On May 4, 2017, SC&A was tasked with reviewing the Addendum to Los Alamos National 

Laboratory (SEC-00109) Special Exposure Cohort Evaluation Report, issued April 24, 2017 

(NIOSH, 2017). This ER Addendum addresses “post-1995 unmonitored intakes of the 

radionuclides for which dose reconstruction limitations were identified in Rev. 1 of the 

SEC-00109 ER,” with the evaluated class remaining the same as in Rev. 1 (NIOSH, 2012) but 

with the start year changed from 1976 to 1996 (NIOSH, 2017). Thus, the evaluated class

defined in the Addendum is: 

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 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 3 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Alamos National Laboratory from January 1, 1996 through December 31, 2005. 

(NIOSH, 2017, PDF p. 4) 

In the Los Alamos National Laboratory (SEC-00109) Special Exposure Cohort Evaluation 

Report, Rev. 1, issued August 13, 2012 (NIOSH, 2012), the National Institute for Occupational 

Safety and Health (NIOSH) selected the class end date of December 31, 1995, based on a 

presumption of full compliance with the U.S. Department of Energy’s (DOE’s) newlypromulgated 10 CFR Part 835, “Occupational Radiation Protection,” which took effect on 

January 1, 1996. In particular, NIOSH refers to 10 CFR 835.402, “Individual Monitoring,” and 

10 CFR 835.702, “Individual Monitoring Records.” 

10 CFR 835.402 states: 

(c) For the purpose of monitoring individual exposures to internal radiation, internal 

dosimetry programs (including routine bioassay programs) shall be conducted for: (1) 

Radiological workers who, under typical conditions, are likely to receive a committed 

effective dose equivalent of 0.1 rem (0.001 sievert) [100 mrem] or more from all 

occupational radionuclide intakes in a year” (10 CFR 835.402). 

10 CFR 835.702 states: 

(a) Records shall be maintained to document doses received by all individuals for whom 

monitoring was required pursuant to §835.402 and doses received during planned special 

exposures, accidents, and emergency conditions (10 CFR 835.702). 

With full compliance, NIOSH assumes that all DOE work sites, including LANL, would have 

satisfied the monitoring requirements contained in the rule, thereby resolving any limitations that 

make dose reconstruction infeasible prior to that date. For LANL, these limitations included the 

“inability to bound unmonitored intakes of exotic alpha-emitters, fission products, and activation 

products” (NIOSH, 2017, PDF p. 3). Furthermore, with full compliance, NIOSH assumes that 

individual monitoring records would have been maintained and would be available for dose 

reconstruction. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 4 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

PURPOSE AND SCOPE

This white paper serves two functions. It is: 

1. NIOSH’s response to SC&A’s assessment of the LANL ER Addendum and their resulting 

conclusions; and 

2. An expansion of NIOSH’s original rationale with a focus on the field monitoring programs 

and existing bioassay data.

In its review, SC&A viewed the application of the 10 CFR 835 presumptive criterion (for LANL 

and other DOE sites) from two vantage points: 

1. Is the use of 10 CFR Part 835 promulgation a valid basis for presumptive relief from the dose 

reconstruction limitations defined in preceding SEC classes for a site such as LANL?

2. Assuming January 1, 1996 as a reasonable milestone for internal dosimetry program 

progress, what metrics can be applied to confirm or validate that substantive implementation 

of 10 CFR Part 835 was achieved?

This white paper addresses the above two SC&A discussions in turn. NIOSH then expands its 

original rationale in light of those discussions followed by its conclusion. Appendix A contains a 

summary of petitioner issues with their corresponding resolutions.

SC&A: REVIEW OF THE USE OF 10 CFR 835 PRESUMPTIVE CRITERION

In its review, SC&A noted that prior to January 1, 1996, an SEC class was defined for 

1976-1995 with dose reconstruction limitations identified for “exotic alpha-emitters, fission 

products, and activation products” (NIOSH, 2017). These limitations derived from inadequate 

monitoring records, process descriptions, and source-term data to complete internal dose 

reconstructions with sufficient accuracy (ABRWH, 2012a). 

Based on a presumption of compliance with DOE’s then newly-promulgated occupational 

radiation safety rule, 10 CFR Part 835, NIOSH found that dose reconstruction became feasible 

by the rule’s effective date, January 1, 1996. This presumption was based on two key 

provisions of the rule: 

1. Internal dosimetry programs shall be conducted “...for radiological workers who, under 

typical conditions, are likely to receive a committed effective dose equivalent of 0.1 rem 

(0.001 sievert) [100 mrem] or more from all occupational intakes in a year” (10 CFR 

835.402) 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 5 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

2. “...records shall be maintained to document doses received by all individuals for whom 

monitoring was required pursuant to §835.402 and doses received during planned special 

exposures, accidents, and emergency conditions.” (10 CFR 835.702) 

NIOSH’S presumption also relied on other advancements, including LANL’s response to the 

1990 Tiger Team findings and the 1992 development of a Technical Basis Standard for Internal 

Dosimetry.

 

SC&A concluded that NIOSH’s presumption derives from an enforcement milestone, 

beginning in 1996, that would hold LANL accountable for monitoring all workers with a 

likelihood of receiving 100 millirem (mrem) of internal exposure in a year and maintaining 

corresponding records, thereby encompassing those potentially exposed to exotics, mixed 

activation products (MAPs), and mixed fission products (MFPs). This presumption, in turn, 

served as the basis for NIOSH’s conclusion that: 

 “...given the presumption of compliance, the absence of internal dosimetry records 

indicates that unmonitored workers were deemed unlikely to have received intakes 

resulting in a CEDE 0.1 rem or more from all occupational radionuclide intakes in a year” 

(NIOSH, 2017). 

Given NIOSH’s presumptions, SC&A responded with arguments in support of the following 

conclusions: 

1. ...Program compliance with 10 CFR Part 835, while necessary under DOE’s PriceAnderson regulatory framework, is not sufficient for demonstrating that actual radiation 

program practice is adequate. ... 

...Reliance on oversight findings based on non-compliances or incidents is likewise 

necessary, but not sufficient, for validating that LANL or any DOE contractor had 

implemented 10 CFR Part 835 in a complete and substantive manner. 

2. In summary, while 10 CFR Part 835 provides a clear regulatory milestone with the 

Department’s first enforcement mechanism, it was one of several policy milestones for 

DOE’s occupational RPP, with the basic provisions being first defined in DOE’s 1989 

Order 5480.11. By itself, this regulatory milestone does not necessarily guarantee 

conformance with program requirements and expectations for individual monitoring, no 

more than did Order 5480.11 and the Radiological Control Manual before it. If anything, 

core requirements for and change to how DOE internal dosimetry programs were 

implemented did not come until the internal dosimetry technical standard of 10 CFR Part 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 6 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

835 was coupled with an accreditation requirement (for overall dosimetry program 

functionality) under DOELAP in the 1998 amendments to the rule, which required all sites 

to achieve accreditation by January 1, 2002. 

NIOSH Response:

1. NIOSH concurs with SC&A’s assessment that program compliance may not be sufficient 

for demonstrating implementation of the radiation monitoring program. NIOSH also 

concurs that reliance on oversight findings may not be sufficient for validating that LANL 

had fully implemented 10 CFR Part 835. This appears particularly evident in the multiple 

pertinent findings identified in Noncompliance Report NC ID 484, as SC&A points out later 

in its memorandum. 

Although the focus of the SEC-00109 LANL Addendum is compliance with 10 CFR 835, 

NIOSH does not rely solely on 10 CFR 835 compliance for the conclusion that unmonitored 

workers were unlikely to have received intakes resulting in greater than 100 mrem CEDE. 

The field monitoring and contamination control programs at LANL were well-established 

and formalized by January 1, 1996. A description of these programs, along with a summary 

of associated data available to NIOSH, was included in Section 6.1.1 of the SEC-00109 ER 

Addendum; for the reader’s convenience, this section is reproduced herein under “NIOSH: 

Review Completed That Supports the Assumption That Unmonitored Worker Intakes Were 

Not Likely to Have Exceeded 100 mrem CEDE.” NIOSH also has a substantial amount of 

actual internal dosimetry data for LANL workers. These data show that, for the common 

radionuclides (tritium, uranium, and plutonium), intakes for monitored workers during the 

1996-2005 time period were generally less than 100 mrem CEDE. NIOSH has not found 

any evidence suggesting that the case would be otherwise for unmonitored workers, or that 

intakes of exotic radionuclides would have been higher. A summary of available internal 

dosimetry data and an associated discussion are presented herein under “NIOSH: Review 

Completed That Supports the Assumption That Unmonitored Worker Intakes Were Not 

Likely to Have Exceeded 100 mrem CEDE.” 

2. NIOSH believes that the 10 CFR 835 era represents a paradigm shift in DOE operations. 

Earlier precursors, like DOE Order 5480.11 and the Radiological Control Manual, were 

guidelines and contractual obligations for the contractor. As of January 1, 1996, there was a 

legal requirement, violations of which were subject to criminal and civil penalties under 

Price-Anderson enforcement. 

Although 10 CFR 835 contains a lot of nuances and implementation guides that may have 

come out too late to impact RPP development by January 1, 1996, the important question is 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 7 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

not overall implementation and compliance with 100 percent of 10 CFR 835, but rather, 

whether there was a program in place ensuring that unmonitored workers were unlikely to 

receive intakes resulting in 100 mrem CEDE. This is a very narrow but important subset of 

10 CFR 835. Although there were some bioassay deficiencies identified in LANL audits,

NIOSH does not find that those issues preclude assigning two percent of the occupational 

exposure limit for workers as a bounding limit for workers who were not monitored. 

NIOSH does not agree that DOELAP accreditation is relevant for full compliance with 

835.402 and 835.702. DOELAP is not a dosimetry standard; it is a performance standard 

tied to ANSI 13.30, Performance Criteria for Radiobioassay. It has nothing to do with the 

100 mrem monitoring requirement; it has to do with how well a laboratory measures an 

analyte in a bioassay sample.

SC&A: REVIEW OF 10 CFR 835 AND INTERNAL DOSIMETRY PROGRAM 

IMPLEMENTATION

In the second part of its review of the LANL ER Addendum, SC&A evaluated NIOSH’s 

presumption that full 10 CFR 835 compliance equated to an occupational radiation 

program operating in 1996–2005 that demonstrably resolves the dose reconstruction 

limitations previously identified for the site. Toward this end, SC&A asked three question 

ns and provided their conclusions (summarized below). 

Q1: Was the LANL occupational radiation program that was deemed compliant with 

10 CFR 835 fully defined, evaluated, and independently reviewed and certified 

prior to January 1, 1996? 

SC&A concludes that both LANL and DOE followed a deliberate review and verification 

process for validating compliance with 10 CFR Part 835 prior to final enactment on 

January 1, 1996. However, it is apparent that uniform acceptance criteria (i.e., 

implementation guidance) were not available in time for use in the field and that wide 

latitude was apparently given to LANL and other DOE sites to interpret how 10 CFR 

Part 835 was to be applied to occupational RPPs. Therefore, that compliance review, at 

the time, may not have been adequate to validate the conformity of existing LANL 

dosimetry programs to corresponding dosimetry requirements in the rule.

NIOSH Response:

NIOSH concurs with SC&A’s assessment that compliance review, at the time, may not 

have been adequate to validate total conformity of existing LANL dosimetry programs to 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 8 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

corresponding dosimetry requirements in 10 CFR 835. However, NIOSH does not find 

that the potential lack of complete conformity precludes assigning two percent of the 

occupational exposure limit for workers as a bounding limit for workers who were not 

monitored. Again, existing data for monitored workers during this time period indicate that 

monitored workers were unlikely to receive intakes resulting in 100 mrem CEDE. NIOSH 

believes that the unmonitored worker population would have had a lower potential for 

exposure than the monitored population. This issue is discussed in more depth herein 

under “NIOSH: Review Completed That Supports the Assumption That Unmonitored 

Worker Intakes Were Not Likely to Have Exceeded 100 mrem CEDE.” 

Q2: Is there any evidence of site-specific or general non-conformances with 10 CFR 

835 that would have substantive implications for dose reconstruction within the 

LANL occupational RPP following the effective implementation of the rule on 

January 1, 1996? 

SC&A’s review scope went beyond site-specific findings to include more general 10 CFR 

835 non-conformance issues stemming from experiences at other DOE sites that may have 

implications for LANL.

SC&A reviewed LANL self-assessments, DOE and DNFSB oversight reviews, nonconformance reports from the DOE Office of Enforcement, and contractor and DOE 

reporting systems, such as the DOE ORPS and DOE NTS. Non-conformance Report NC 

ID 484 was specifically identified as having substantive implications for dose 

reconstruction: 

Noncompliance report NC ID 484 was based on an assessment of the LANL internal dose 

evaluation program conducted by representatives from Savannah River Site (SRS), MJW 

Corporation, LANL’s Radiation Protection Services Group (ESH-12), and Quality 

Assurance Group (ESH-14) on March 22–25, 1999. The assessment had 10 

noncompliance findings, summarized as follows (DOE/NTS 2017), the first three of 

which impaired LANL’s ability to monitor individuals “likely to receive a committed 

effective dose equivalent of 0.1 rem (0.001 sievert) or more from all occupational 

radionuclide intakes in a year” (10 CFR 835.402(c)(1)). 

The three findings that SC&A identified as particularly problematic are:

1. Some workers and their supervisors are not accurately completing the 

“health physics checklist” (utilized for enrolling workers into dosimetry 

programs) to the extent that these checklists may not identify those 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 9 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

radionuclides actually handled by the worker. Thus, some workers are not 

being assigned to the appropriate routine bioassay program in accordance 

with site requirements. [835.402(c)(1)] 

2. Some radiological workers are not complying with specific RWPs that require 

them to participate in a bioassay program. As an example, two out of five 

workers who performed work under a specific RWP did not participate in the 

bioassay program in accordance with requirements of the RWP. 

[835.402(c)(1)] 

3. Johnson Controls of Northern New Mexico (JCNNM), the principle 

[sic] subcontractor to Los Alamos National Laboratory, may not be 

enrolling all workers who are potentially exposed to radionuclides into 

the appropriate bioassay program in accordance with site 

requirements. [835.402(c)(1)]

SC&A noted the subsequent corrective actions were undertaken and closed by 2000. In 

SC&A’s view, the above non-compliances and subsequent corrective actions are important 

to the LANL bioassay program, quite apart from 10 CFR 835 compliance, and evince 

likely longstanding implementation issues with that program: 

SC&A concludes that the 1999 LANL noncompliance notwithstanding (which derived 

from an independent review with outside reviewers), solely relying on the lack of Notices 

of Violation (NOVs) and other recorded non-conformances as a benchmark of effective 

RPP implementation is questionable. Key provisions of 10 CFR Part 835, e.g., 

application of the 100 mrem criterion under 835.402(c)(1), do not lend themselves easily 

to assessment and verification by external compliance reviews, incident occurrences, or 

procedure reviews. Traditional validation and verification sampling for adequacy and 

completeness, and interviews with workers and radiation protection personnel, have 

proven effective in the past to establish the status of program implementation. 

NIOSH Response:

NIOSH concurs with SC&A’s assessment that solely relying on the lack of Notices of 

Violation (NOVs) and other recorded non-conformances as a benchmark of effective RPP 

implementation is questionable. This appears particularly evident in the 1999 independent 

review (Assessment, 1999) that resulted in the pertinent findings identified in Noncompliance Report NC ID 484 (Non-conformance, 1999). 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 10 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Although the focus of the SEC-00109 LANL ER Addendum is compliance with 10 CFR 

835, NIOSH does not rely solely on 10 CFR 835 compliance for the conclusion that 

unmonitored workers were unlikely to have received intakes resulting in greater than 100 

mrem CEDE. LANL’s field monitoring programs were designed and implemented for the 

purpose of ensuring that unmonitored individuals were unlikely to receive intakes of 100 

mrem CEDE. Also, as mentioned previously, NIOSH has a substantial amount of internal 

dosimetry data for LANL workers. These data show that intakes for monitored workers 

during the 1996-2005 time period were generally less than 100 mrem CEDE and NIOSH 

believes that intakes for unmonitored workers would likely be even lower. Discussions 

regarding LANL’s field monitoring programs and available bioassay data for monitored 

LANL workers are included herein under “NIOSH: Review Completed That Supports the 

Assumption That Unmonitored Worker Intakes Were Not Likely to Have Exceeded 100 

mrem CEDE.”

Q3: Are there any LANL occupational protection program or internal dosimetry 

program implementation issues identified after January 1, 1996 that may hamper 

or preclude dose reconstruction? These would include concerns identified in the 

ER, including neptunium and special tritium compounds. 

SC&A originally raised concerns about exotic alpha-emitters, fission products, and 

activation products in its 2010 focused review of the LANL evaluation report (SC&A 

2010). That review noted that as far back as in its 2006 site profile review, SC&A had 

found that “inadequate consideration was given to potential exposure and missed dose 

from radionuclides other than the ‘well documented’ ones cited in the TBD (e.g., 

plutonium, polonium, tritium, etc.)” (SC&A 2010, page 8). This was borne out in terms of 

LANL practice from interviews with LANL staff and other experts; a summary of findings 

from those interviews is provided below (SC&A 2010): 

• It is fairly well recognized that most DOE facilities, such as LANL, Rocky 

Flats Plant (RFP), etc., had the capability to detect, identify, and quantify 

MFP/MAP in workers beginning in the early 1970s. However, it is not as 

certain (or as well documented) that it was standard practice to actually 

analyze and record the activity from these radionuclides in the worker’sfile.

• MFP/MAP activities appear to have been investigated in certain situations, 

but it has not been documented that it was performed on a routine basis at 

LANL.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 11 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

• Prior to 1998, LANL primarily relied upon the Phoswich detectors for in-vivo 

(whole-body or lung-counting) measurements. An in-vivo count spectrum was 

typically not analyzed for fission or activation product radionuclides, unless a 

peak associated with a certain nuclide was visible in the spectrum, or LANL 

knew or suspected that an exposure had occurred. When that peak was 

identified, the nuclide was added to the radionuclide library, and the spectrum 

as converted to activity and reported in the record. Identification of a peak 

could be subjective at times and not directly correlated to MDA [minimum 

detectable activity] or critical levels, especially with the broad peaks that 

appeared in the photon spectra, because of the low resolution of these 

scintillation-type detectors.

• Phoswich detectors were unable to resolve peaks for exotic and MFP or MAP 

radionuclides, particularly those that emitted low-energy photons. 

• To overcome the detector’s inability to resolve peaks, LANL set up regions of 

interest for the photon spectra, and used control groups of non-nuclear 

workers to estimate body and room background contributions, and to 

statistically determine net counts above background and identify peaks of 

interest.

• After germanium detectors became available, if a known or suspected 

exposure had occurred, then measurements were repeated with highresolution germanium detectors to verify and identify the presence of a 

radionuclide if the peak was determined not to be one of the primary 

radionuclides. If detected, the radionuclide was added to the analysis library 

and confirmed as a positive identification that needed a dose assessment. In 

most of the cases, in-vitro bioassay samples were also collected.

• There is a higher likelihood that peaks could have been missed when the 

germanium detectors were not in operation or had not yet been installed (i.e., 

before 1998). 

• A programmatic assessment of the internal dosimetry program by DOE in 

2001 found that thorium-232 and the short-lived MAP radionuclides 

generated at the Los Alamos Neutron Science Center (LANSCE), although 

required for routine internal dosimetry evaluation, were not included in the 

in-vivo program library (DOE, 2001[a]). The absence of this routine 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 12 of 61

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

monitoring capability as late as 2001 brings into question the ability of the 

LANL program to detect these and other exotics on a routine basis as a 

matter of practice (vs. technical capability). As DOE noted in its finding, 

“Without this information, the in-vivo laboratory cannot identify monitoring 

strategies or ensure adequate energy calibrations;” and that “interviews with 

the in-vivo staff indicated that they were not aware of the need for this

capability.” 

SC&A contends that these and related concerns likely contributed to the lack of 

monitoring records for MFPs and MAPs. 

In discussing the oversight finding that Th-232 and MAPs generated at LANSCE were 

not included in the in-vivo program library, SC&A closed with the following statement: 

This may not have been of great consequence after the introduction of more sensitive 

germanium detectors in 1998, but it clearly may have hampered in vivo monitoring for 

these radionuclides before that time when Phoswich detectors were being relied upon.

The section concluded with the following statement: 

SC&A concludes that there is no evidence that the internal dosimetry and monitoring 

shortfalls cited in deliberations that led to the recommendation by the Advisory Board to 

define an SEC class for 1976–1995 (ABRWH 2012b) have been resolved for the time 

period after 1995.

NIOSH Response:

NIOSH does not share many of the concerns identified by SC&A in this section. It 

appears that SC&A was not aware of the extensive use of high-resolution germanium 

detectors for in-vivo counting at LANL throughout the period evaluated in the SEC-00109 

ER Addendum. Germanium detectors had been widely used at LANL for in-vivo

measurements since the mid-1970s, long before the period under evaluation in the 

addendum. The configuration of the lung-counting system is illustrated in the 1984 

LANL document LA-9979-MS, In Vivo Assessment of Lung Burdens at the Los Alamos 

National Laboratory (LANL, 1984). Although it is true that Phoswich detectors were 

used as late as 1998, they were used in conjunction with germanium detectors and not 

exclusively relied upon.

NIOSH acknowledges that there were very few bioassay or other internal dose assessments 

for exotic radionuclides. This is true for the entire period of LANL operations. This was 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 13 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

the primary driver for NIOSH’s recommendation to extend the LANL SEC through 1995 

in Rev. 1 of the SEC-00109 ER. The ER Addendum presents a methodology for

performing dose reconstructions for exotic radionuclides for LANL workers in the absence 

of bioassay during the 10 CFR 835 era. Based on the available information that NIOSH 

has collected regarding LANL operations, use of exotic radionuclides at LANL was 

relatively rare, not nearly as prevalent as the use of the primary radionuclides (plutonium, 

uranium, and tritium), for which there is an abundance of bioassay data. As pointed out in 

SC&A’s memorandum, LANL noted that its internal dosimetry monitoring programs are 

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

workers likely to receive 100 mrem annually from internal exposure (LANL 2013). LANL 

further notes: 

LANL has an in vivo monitoring program established for fission products and activation 

products, and has historically used in vivo monitoring for these radionuclides. A spectral 

analysis of each count was performed by the in vivo staff. During this review, all peaks 

were identified and quantified. [LANL 2013, page 3] 

Regarding the 2001 DOE oversight finding concerning LANL’s capability to monitor for 

MAPs generated at LANSCE, NIOSH does not share SC&A’s concern. LANL has used 

germanium detectors extensively for body counts for LANSCE workers beginning in 

March 1979. A summary of the bioassay data available to NIOSH is presented in the 

LANL Bioassay Repository Database (ORAUT-OTIB-0063). This database includes 

106,950 in-vivo records. The vast majority of these are counts for Am-241 (41%) and 

Pu-239 (41%). The next largest contributors to the total number of in-vivo records are 

U-235 and Th-234 (5% each). The bulk of the remaining 7000+ records is primarily 

comprised of fission and activation product radionuclides for LANSCE employees that 

were acquired via germanium detectors. The in-vivo records in the LANL bioassay 

database specify 81 different analytes. A summary of the in-vivo counting records from 

1969 through 2005 are listed below. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 14 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Analytes Listed for In-Vivo Counting Records in the ORAU Team’s Database

Analyte Total Records 

for 1969-2005

Records with Count 

Dates from 1969-1995

Records with Count 

Dates from 1996-2005

Am-241 40796 28712 12084

As-72 3 3 0 

Ba-140 0 0 0 

Be-7 819 690 129

Bi-213 14 0 14

Bi-214 6 6 0 

Br-76 12 11 1 

Br-77 17 16 1 

C-11/N-13 1308 758 550

Cd-109 19 18 1 

Ce-141 8 7 1 

Cf-249 9 9 0 

Cm-244 1 0 1 

Co-56 1 1 0 

Co-57 8 8 0 

Co-57/Co-58 1 1 0 

Co-58 6 6 0 

Co-60 73 43 30

Cr-51 1 1 0 

Cs-134 127 127 0 

Cs-137 436 353 83

Cu-64 1 1 0 

Cu-67 1 1 0 

Eu-152 451 27 424

Fe-59 1 1 0 

Fission prods 1 1 0 

Gd-146 0 0 0 

Gd-153 0 0 0 

Ge-67/Ga-67 1 1 0 

Ge-68/Ga-68 5 5 0 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 15 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Analyte Total Records 

for 1969-2005

Records with Count 

Dates from 1969-1995

Records with Count 

Dates from 1996-2005

Hf-173 3 0 3

Hf-175 5 0 5

Hg-195M 8 7 1

Hg-197 40 39 1

Hg-197M 8 7 1

Hg-203 25 24 1

I-123 2 2 0

I-125 159 159 0

I-131 13 13 0

I-132 1 1 0

La-140 0 0 0

Lu-172 0 0 0

Lu-173 0 0 0

Mn-54 773 649 124

Na-22 1178 636 542

Na-24 6 6 0

Nb-95 0 0 0

Nd-147 8 7 1

Os-185 11 10 1

P-32 2 2 0

Pb-212 15 1 14

Pb-214 14 0 14

Pu-238 109 109 0

Pu-238/Pu-239 2 2 0

Pu-239 39848 27863 11985

Ra-226 4 3 1

Rb-83 13 12 1

Rb-84 11 10 1

Sb-124 11 10 1

Sc-46 8 8 0

Se-72/As-72 1 1 0
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 16 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Analyte Total Records 

for 1969-2005

Records with Count 

Dates from 1969-1995

Records with Count 

Dates from 1996-2005

Se-75 32 31 1 

Sm-145 8 7 1 

Ta-179 9 8 1 

Ta-182 0 0 0 

Te-132 1 1 0 

Th-234 2567 0 2567

Tl-201 11 10 1 

Tl-202 14 13 1 

Tungsten 1 1 0 

U-235 2572 1 2571

U-237 7 7 0 

U-238 3 2 1 

Unidentified 2 2 0 

V-48 4 4 0 

Yb-169 0 0 0 

Zn-65 11 11 0 

Zr-95 1 1 0 

Zr-95/Nb-95 3 3 0 

The SC&A memorandum also expressed concern about the 2001 DOE oversight finding 

regarding LANL’s ability to monitor for Th-232. In response to NIOSH requests for 

information to demonstrate LANL’s capability to monitor for various radionuclides

(including Th-232), LANL indicated that there are no workers on a routine thorium 

bioassay program because it is not warranted (i.e., workers are unlikely to receive thorium 

intakes resulting in greater than 100 mrem CEDE). LANL also provided an example of 

“targeted” in vivo Th-232 bioassay for an international traveler in 1999 (Th-232 Bioassay, 

1999). This whole-body count result from March 1999 clearly demonstrates LANL’s 

capability to monitor for Th-232 using in-vivo methods prior to the 2001 DOE oversight 

finding. NIOSH concludes that this capability was likely present for the duration of the 

period under evaluation (1996-2005). 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 17 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Special Tritium Compounds and Neptunium

For special tritium compounds (STCs), SC&A agreed with NIOSH’s assessment that 

LANL was aware of their presence in the late 1990s and took measures to communicate 

appropriate dose assessment considerations within the LANL health physics program and 

to DOE. The potential for significant exposure was deemed small and handled on a 

case-by-case basis. The capability for NIOSH to bound intakes of STCs exists, if found 

necessary, and methods are available (e.g., ORAUT-OTIB-0066) by which dose 

reconstruction can be performed. 

For neptunium, SC&A did not necessarily agree with NIOSH’s conclusion that the RPP 

inadequacies found by the DOE Office of Independent Oversight (LANL Inspection, 

2005) “do not indicate that unmonitored intakes occurred” (NIOSH, 2017). SC&A found 

premature any conclusion regarding potential exposure from, and monitoring for, 

neptunium founded on findings from one facility and a particular oversight investigation, 

without ascertaining site-wide inventories and the full scope of operations that may have 

handled neptunium. 

NIOSH Response:

NIOSH has fully evaluated the neptunium operations of concern to the petitioner. This 

evaluation was summarized in the ER Addendum (NIOSH, 2017). The possibility that 

there may have been other neptunium operations of which NIOSH is unaware cannot be 

dismissed. However, given LANL’s awareness of this issue and its limited case-by-case

exposure potential, NIOSH maintains that intakes resulting in 100 mrem CEDE would 

likely be bounding for any such operation. 

NIOSH: REVIEW COMPLETED THAT SUPPORTS THE ASSUMPTION THAT 

UNMONITORED WORKER INTAKES WERE NOT LIKELY TO HAVE EXCEEDED 

100 MREM CEDE 

In response to SC&A’s concerns, NIOSH re-emphasizes the significance of LANL’s 

field monitoring programs, which were intended to ensure that unmonitored individuals 

were unlikely to receive intakes of 100 mrem CEDE. Also, since the issuance of 

SC&A’s review, NIOSH has compared the available bioassay data for monitored 

LANL workers to the 100 mrem CEDE monitoring threshold and found that monitored 

workers were unlikely to receive 100 mrem CEDE intakes. These two topics are 

discussed below.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 18 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

LANL Field Monitoring and Contamination Control Programs 

The field monitoring and contamination control programs at LANL were wellestablished and formalized by January 1, 1996. A description of these programs, along 

with a summary of associated data available to NIOSH, was included in Section 6.1.1 

of the SEC-00109 ER Addendum (NIOSH, 2017). For the reader’s convenience, this 

section is reproduced below. 

ER Addendum, Section 6.1.1: Field Monitoring Program and Associated Data 

By January 1, 1996, the health physics field monitoring and contamination control programs 

at LANL were well established and formalized, with over 60 procedures addressing various 

aspects of radiological protection (LANL Procedures, 1996), as well as an established 

process for tracking and notifying staff of revisions (Procedure Revisions, 1996). These 

procedures cover program administration, exposure and contamination control, monitoring, 

instrumentation, protective equipment, emergency response, and the As Low As Reasonably 

Achievable (ALARA) program. 

In addition to site-wide procedures, area-specific procedures and instructions were also in 

effect. For example, the stated purpose of the ESH-1/TA-55 Radiation Monitoring 

Instructions is “to provide survey frequencies which are to be used by the ESH-1 

Radiological Control Technicians (RCTs) and Health Protection Technicians (HPTs) in 

assisting the NMT Division in the implementation of the radiological control program at TA55” (TA-55 Instructions, 2000). This document defines the routine monitoring tasks of the 

RCTs assigned to TA-55 and delineates responsibilities. Routine surveys are described with 

survey frequencies ranging from daily to annually. These instructions also specify types of 

routine external radiation surveys, as well as air monitoring and TA-55 Technical Safety 

Requirements (TSRs), which include annual CAM system calibration, monthly performance 

tests, and daily operability checks. 

NIOSH has obtained hundreds of radiological protection documents from LANL for the time 

period under evaluation. Examples include: 

• Radiological Work Permits requiring contamination surveys and air monitoring (RWPs, 

1997; RWPs, 2003) 

• Monthly contamination surveys (Monthly Surveys, 1998; Monthly Surveys, 1999) 

• Area-specific contamination surveys (TA-3 Survey Results, 1999; TA-18 Survey Results, 

1997) 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 19 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

• Quarterly contamination survey summaries (Quarterly Summaries, 1999; Quarterly 

Summaries, 2003) 

• Area-specific monitoring data quarterly reviews (CMR Quarterly Review, 1996; TA-55 

Quarterly Review, 1995-1996) 

• Air sample analysis data (Air Data, 1996-1997; Air Data, 2001) 

• Air sampling/monitoring technical evaluations (Air Sampling Evaluation, 2001a; Air 

Sampling Evaluation, 2001b) 

• Airborne radioactivity investigation reports (Airborne Radioactivity, 2001; Airborne 

Radioactivity, 2002) 

• Task-specific radiological protection assessments/checklists (ESH-1 Checklist, 2001; Rad 

Protection Checklist, 1995)

• Standard operating procedures (SOP) tracking (SOP Matrices, 1996; SOP Revisions, 

1996) 

[End ER Addendum, Section 6.1.1] 

During multiple data capture efforts, NIOSH found many boxes of LANL RWP records. 

Although it did not attempt to capture or review each and every one of these records, NIOSH did 

capture what it feels is a representative sample. Consequently, the NIOSH database contains 

several hundred LANL RWPs for the 1996-2005 time period, consisting of thousands of pages of 

records. Much of the focus during these data capture efforts was on finding RWPs that involved 

non-routine radionuclides (i.e., other than plutonium, uranium, and tritium), although many 

RWPs involving these more common nuclides were also collected. 

Some general statements can be made regarding the LANL RWPs issued during the time period 

under evaluation: 

• Most of these RWPs required pre-job and/or post-job contamination surveys, and the 

associated smear records are included in the captured documentation.

• Most of them specified PPE to be worn. 

• Many of them specified respiratory protection. 

• Most of them required at least some RCT coverage and included stop work or hold points 

that would invoke re-evaluation. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 20 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

• Most of the work was conducted in areas where continuous air monitors (CAMs) were in 

operation. 

• Many of the RWPs required other job-specific air monitoring or breathing-zone air 

monitoring, and the associated monitoring records are included in the captured 

documentation. 

• Several of them required nasal smears to be taken.

In general, bioassay requirements were not routinely specified on RWPs. The RWPs appear to 

have been designed to minimize the likelihood of intakes via engineering controls, PPE, and 

respiratory protection. The RWPs were also designed to detect material release via air 

monitoring and smear surveys. Elevated surface or airborne contamination would trigger an 

assessment for the need for bioassay.

Occurrence Report No. DP-ALO-LA-LANL-TA55-2002-0003 describes an event in TA-55 in 

2002 that resulted in airborne release of radioactive material and internal exposure to employees 

(ORPS, 2002). The operation was performed under RWP 02-55-319-7 (not available in the 

NIOSH database). The description provided in the occurrence report (reproduced below) clearly 

shows a scenario whereby field indicators, including a CAM alarm, personnel contamination 

surveys, and nasal smears led to bioassay assessments.

MANAGEMENT SYNOPSIS: On [redacted] 2002, at approximately [redacted] hours, at 

Technical Area 55, [redacted], two employees were detected with contamination in their 

nasal passages, as indicated by nasal swipes, one of whom also had skin contamination, after 

evacuating [redacted] after a Continuous Air Monitor (CAM) alarmed indicating airborne 

contamination. All contamination was alpha. The first employee (E1), from[redacted], had 

skin and hair contamination up to 5,000 disintegrations per minute (dpm) and nasal smear 

readings of 1,389/No Detectable Activity (NDA) dpm. The second employee (E2), from 

[redacted], had no skin contamination but nasal smear readings of 32/92 dpm. E2 had been 

working approximately 5-10 feet from E1. Thirteen employees were in the room at the time 

of the CAM alarm. No other personnel contamination was detected. E1 and E2 were placed 

on prompt bioassay on [redacted] 2002. Field indicators were evaluated to determine 

appropriate special bioassay requirements for all other employees present in [redacted] at 

the time of the release. Based on the pattern of the release, as indicated by FAS filter 

analysis, additional employees were placed on special bioassay. A total of seven employees 

were placed on bioassay. The preliminary results of the bioassays were received on

[redacted] 2002. The preliminary estimates indicated 50-year Committed Effective Dose 

Equivalent (CEDE) ranging from 2 mrem to 14 mrem. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 21 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

In a 1998 Occurrence Report, ALO-LA-LANL-CMR-1998-0041, from the CMR facility, the 

description (reproduced below) shows another scenario in which field monitoring led to bioassay 

assessment (ORPS, 1998). This operation was performed under RWP Number 98-3-29-2114-

285 (not available in the NIOSH database). 

MANAGEMENT SYNOPSIS: On [redacted] 1998, at [redacted], Chemistry and Metallurgy 

Research (CMR) facility management was notified that alpha activity measuring up to 

56,000 disintegrations per minute/100 square centimeters (cm[2]) had been detected on a 

[redacted] employee's personal clothing. The [redacted] employee had been removing 

legacy items from a chemical fume hood in [redacted] of the CMR facility. The principal 

contaminant was subsequently determined to be americium-241. 

Radiological control technicians (RCTs) assisted the [redacted] employee with changing into 

clean clothing. The contaminated clothing will be properly discarded. The [redacted] 

employee submitted nasal smears; results were 36/0 dpm-alpha. Based on the nasal smear 

results, the employee was placed on a special bioassay program and restricted from working 

in radiologically controlled areas pending preliminary bioassay results and radiation dose 

assessment. 

Available Bioassay Data for Monitored LANL Workers 

Radiation dosimetry monitoring requirements for LANL workers were well-established prior to 

the implementation of 10 CFR 835. The 1991 LANL Environment, Safety, and Health Manual 

indicates the need for bioassay monitoring of personnel in order to demonstrate compliance with 

radiation protection standards (ES&H Manual, 1991). That document includes action levels for 

worker monitoring that required routine bioassay for workers with the potential to receive “0.1 

rem annual effective dose equivalent from internal sources” or “5 rem annual dose equivalent to 

any organ or tissue from internal sources.” LANL’s 1994 Radiation Dosimetry Monitoring 

Laboratory Standard (LANL Dosimetry, 1994) specifies bioassay monitoring requirements. It 

includes operations that would trigger bioassay and determinations based on quantities and forms 

of radioactive materials at risk. A table presented in that document indicates that any positive in 

vivo whole-body count will require an assessment of intake. The table shows the recommended 

counting interval necessary to detect 2% of an ALI for 26 different gamma-emitting 

radionuclides. Routine contamination survey and air monitoring programs were in place to 

ensure that personnel monitoring was appropriate for the various areas, and boundaries were 

established so that unmonitored personnel would not likely receive 100 mrem CEDE. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 22 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NIOSH reviewed the DOE Occurrence Reporting System for LANL 10 CFR 835 violations, site 

responses, and corrective actions. A total of 159 documents were accessed (ORPS Reports, 

1993-2015). NIOSH also reviewed the DOE Non-conformance Tracking System for LANL 

10 C.F.R. pt. 835 violations, site responses, and corrective actions. A total of 384 documents 

were captured (NTS List, 2016). As a consequence of the field monitoring programs, workers 

were often required to undergo bioassay. This was clearly evident from the numerous ORPS 

reports reviewed by NIOSH.

A class of LANL workers has been added to the Special Exposure Cohort due to a lack of 

available bioassay data for “exotic” radionuclides. This class includes all workers from the 

beginning of site operations in 1942 through 1995. This lack of bioassay data for “exotic” 

radionuclides has continued to persist to the present time. LANL has contended that bioassay 

data for exotic radionuclides are scarce because it is and has been unwarranted, especially during 

the 10 CFR 835 era. It is deemed unwarranted, according to LANL health physics professionals, 

because workers are unlikely to have received intakes resulting in 100 mrem CEDE from these 

radionuclides in any given year; therefore, workers were not required to have been monitored for 

them. 

In the SEC-00109 LANL ER Addendum, NIOSH proposed a method for assigning bounding 

intakes of these exotic radionuclides for LANL workers in the absence of bioassay data. The 

method proposed was to assign annual intakes for these radionuclides that would have resulted in 

100 mrem CEDE. The primary basis for this proposed method was the legal requirements set 

forth in 10 CFR 835 that went into effect on January 1, 1996. 

In SC&A’s review of the SEC-00109 LANL ER Addendum, SC&A pointed out multiple issues 

regarding LANL’s technical ability to monitor for various radionuclides and examples of 

oversight findings where perhaps workers should have been monitored for internal dose 

according to the 10 CFR 835 rule, but apparently were not. NIOSH shares some of the concerns

from the oversight findings, as discussed above in this document. In light of these concerns, the 

primary question still remains. Is the assignment of 100 mrem CEDE intakes for unmonitored 

workers likely to be bounding? 

In an attempt to help answer this question, NIOSH believes it useful to take a look at the primary 

LANL radionuclides, tritium, plutonium isotopes, and uranium isotopes - radionuclides for 

which bioassay data are abundant. There are over 450,000 LANL urinalysis records available to 

NIOSH for the period 1945 through 2008. These include data for plutonium, polonium, 

uranium, and tritium. In addition, there are over 100,000 in-vivo records. These data are 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 23 of 61

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

presented and evaluated in the Internal Dosimetry Coworker Data for Los Alamos National 

Laboratory (ORAUT-OTIB-0062). 

The following six tables, reproduced from ORAUT-OTIB-0062, give intake values to be used in 

dose reconstruction for unmonitored LANL workers for any given year. The values are based on 

the available co-worker bioassay data, and represent 50th percentile exposures. For tritium, the 

actual annual dose equivalent (mrem) is provided. For isotopes of plutonium and uranium, 

intake rates in units of picocurie per day (pCi/d) are provided. 

Note: A feature worth noting in these tables is that intake rates have trended lower over the 

years at LANL. Post-1995 intakes for monitored workers can be seen to be relatively low 

in comparison to intakes during LANL’s earlier years. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 24 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Table 5-1 from ORAUT-OTIB-0062: Tritium Annual Doses (mrem) and GSDs

Year Dose GSD

1950 33 7.2

1951 36 5.9

1952 25 4.2

1953 26 6.7

1954 16 6.2

1955 43 6.5

1956 33 6.9

1957 35 6.9

1958 26 5.7

1959 22 5.5

1960 27 5.2

1961 20 4.7

1962 17 4.7

1963 18 3.7

1964 17 3.5

1965 18 3.5

1966 19 4.2

1967 23 6.0

1968 16 4.6

1969 21 5.0

1970 25 7.0

1971 16 4.9

1972 14 5.4

1973 16 5.3

1974 25 6.7

1975 19 6.2

1976 13 4.1

1977 20 5.5

1978 20 5.2

1979 12 4.9
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 25 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Year Dose GSD

1980 15 4.1

1981 17 4.1

1982 21 4.5

1983 18 4.8

1984 16 3.4

1985 18 3.3

1986 21 3.8

1987 17 4.3

1988 7 4.4

1989 7 3.5

1990 6 3.2

1991 2 3.0

1992 5 3.5

1993 6 3.4

1994 3 3.0

1995 5 3.0

1996 5 3.0

1997 4 3.0

1998 7 3.0

1999 4 3.0

2000 9 4.1

2001 6 3.0

2002 6 3.5

2003 5 3.3

2004 3 3.0

2005 3 3.0

2006 4 3.0

2007 4 3.0

2008 6 3.3
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 26 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Table 5-2 from ORAUT-OTIB-0062: Plutonium-238 Intake Rates (pCi/d)

Start End Type M 50th 

Percentile Type M GSD Type S 50th Percentile Type S GSD

1/1/1968 12/31/1971 1.8 5.63 43 5.74

1/1/1972 12/31/1972 14. 3.13 765 3.13

1/1/1973 12/31/1974 2.0 4.31 72 4.17

1/1/1975 12/31/1977 0.67 3.59 5.2 8.47

1/1/1978 12/31/1981 0.32 7.56 5.2 8.47

1/1/1982 12/31/1988 0.084 8.73 1.8 8.47

1/1/1989 12/31/1993 0.44 4.31 9.7 4.17

1/1/1994 12/31/2008 0.048 6.82 0.72 6.58

Table 5-3 from ORAUT-OTIB-0062: Plutonium-239 Type M Intake Rates (pCi/d)

Start End Type M 50th 

Percentile Type M GSD

1/1/1944 12/31/1945 248 5.05

1/1/1946 12/31/1946 95 6.24

1/1/1947 12/31/1953 10 5.16

1/1/1954 12/31/1954 3.1 17.2

1/1/1955 12/31/1956 3.1 12.4

1/1/1957 12/31/1966 0.38 12.4

1/1/1967 12/31/1972 3.3 4.81

1/1/1973 12/31/1975 1.5 6.21

1/1/1976 12/31/1993 0.16 6.83

1/1/1994 12/31/2008 0.013 12.2
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 27 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Columns 1-4 from Table 5-4 from ORAUT-OTIB-0062:Pu-239 

Type S and Super S Systemic Intake Rates (pCi/d)

Start End 50th 

Percentile GSD

1/1/1944 12/31/1945 8,651 a 5.05

1/1/1946 12/31/1946 5,125 a 6.24

1/1/1947 12/31/1953 200 a 4.87

1/1/1954 12/31/1954 88a 11.12

1/1/1955 12/31/1956 88a 15.3

1/1/1957 12/31/1966 6.3a 11.91

1/1/1967 12/31/1972 73a 4.62

1/1/1973 12/31/1975 41 a 6.34

1/1/1976 12/31/1993 2.3 a 6.34

1/1/1994 12/31/2008 0.14 a 12.8

a. Urinalysis-based intake rates.

Columns 5-8 from Table 5-4 from ORAUT-OTIB-0062: Pu-239 

Type S and Super S Non-Systemic Intake Rates (pCi/d)

Start End 50th 

Percentile GSD

1/1/1944 12/31/1945 8,651a 5.05

1/1/1946 12/31/1946 5,125a 6.24

1/1/1947 12/31/1953 200a 4.87

1/1/1954 12/31/1954 88a 11.12

1/1/1955 12/31/1956 88a 15.3

1/1/1957 12/31/1966 6.3a 11.91

1/1/1967 12/31/1968 73a 4.62

1/1/1969 12/31/1971 27.66b 4.50

1/1/1972 12/31/1974 29.43b 4.50

1/1/1975 12/31/1975 505.4b 3.00

1/1/1976 12/31/1977 96.07b 3.90

1/1/1978 12/31/1979 19.55b 6.24

1/1/1980 12/31/1993 2.3a 6.34

1/1/1994 12/31/2008 0.14a 12.8

a. Urinalysis-based intake rates.

b. Lung count-based intake rates. 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 28 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Table 5-7 from ORAUT-OTIB-0062: Uranium Intake Rates (pCi/d)

Start End Type F 50th P 

Percentile

Type F 

GSD

Type M 50th 

Percentile

Type M 

GSD

Type S 50th 

Percentile

Type S 

GSD

1/1/1947 12/31/1949 21.3a 3.36 88.7a 3.36 1,520a 3.24

1/1/1950 12/31/1955 21.3 3.36 88.7 3.36 1,520 3.24

1/1/1956 12/31/1957 5.36 3.36 16.0 3.36 656 3.24

1/1/1958 12/31/1965 1.98 4.81 7.95 4.90 141 4.71

1/1/1966 12/31/1973 0.909 6.84 3.53 7.03 59.3 6.59

1/1/1974 12/31/1982 0.227 11.31 1.03 10.6 19.7 9.27

1/1/1983 12/31/1989 1.53 4.81 6.29 4.90 105 4.44

1/1/1990 12/31/2000 0.201 4.03 0.756 4.06 11.0 4.57

1/1/2001 12/31/2001 1.019 3.00 4.70 3.00 92.0 3.00

1/1/2002 12/31/2008 0.201 4.03 0.756 4.06 11.0 4.57

a. Intakes for 1947 through 1949 are based on the 1950 through 1955 intakes.

The SEC-00109 LANL ER Addendum proposed annual intakes of 2% SALI as bounding intake 

quantities for unmonitored workers with access to controlled areas. Those proposed annual 

intake quantities were presented in units of becquerel (Bq) (see ER Addendum Table 7-1). For 

ease of comparison to the values presented in ORAUT-OTIB-0062, the units for the primary 

radionuclides, those for which bioassay data are abundant, have been converted to pCi/d in the 

table below. 

Conversion of LANL ER Addendum Annual Intake Values (Bq) to Daily Intake Values (pCi/d)

Radionuclide Lung Clearance 

Class

Annual Intake Quantity, 

2% SALI (Bq) 

(from ER Addendum)

Daily Intake Quantity, 

2% SALI (pCi/d)

U-234 D 1.36 x 103 100

U-234 W 4.69 x 102 35

U-234 Y 3.88 x 101 2.9

Pu-238 W 9.43 x 100 0.70

Pu-238 Y 1.28 x 101 0.95

Pu-239 W 8.62 x 100 0.64

Pu-239 Y 1.20 x 101 0.89

An intake value for tritium was not included in the above table because the values given, 

ORAUT-OTIB-0062, Table 5-1, are already in units of mrem per year, which may be compared 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 29 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

directly to the 100 mrem CEDE proposed intake quantity. Table 5-1 from ORAUT-OTIB-0062 

shows annual tritium doses gradually trending lower from 1950 through 1988, at which time they 

stabilized and remained relatively low. The 50th percentile annual doses for the applicable 

period, 1996-2005, based on actual bioassay data, range from 3 to 9 mrem per year. Assignment 

of 100 mrem per year for unmonitored workers potentially exposed to tritium appears to be 

bounding. 

For U-234, Pu-238, and Pu-239, the comparisons are not as straightforward. For these, intake 

quantities proposed in the ER Addendum for lung clearance classes D, W, and Y are compared 

to the 50th percentile intake rates presented in ORAUT-OTIB-0062 for lung clearance types F, 

M, and S, respectively. 

The following table shows a side-by-side comparison of ORAUT-OTIB-0062 uranium intakes to 

ER Addendum-proposed uranium intake rates, for the applicable time period. 

Comparison of ORAUT-OTIB-0062 vs. ER Addendum Uranium Intake Rates (pCi/d)

Time Period OTIB-0062

Type F

ER Add.

Class D

OTIB-0062

Type M

ER Add.

Class W

OTIB-0062 

Type S

ER Add.

Class Y

1996-2000 0.201 100 0.756 35 11.0 2.9

2001 1.019 100 4.70 35 92.0 2.9

2002-2005 0.201 100 0.756 35 11.0 2.9

A comparison of the OTIB-0062 Type F uranium intake rates to those proposed in the ER 

Addendum for Class D U-234 suggests that the ER Addendum intake rates are bounding. The 

same is true when comparing OTIB-0062 Type M intakes to Addendum Class W. This is not the 

case when comparing OTIB-0062 Type S to ER Addendum Class Y. It is important to keep in 

mind, however, the method by which the OTIB-0062 values were derived for Type S uranium. 

These values were produced from urine bioassay results. The underlying assumption is that the 

uranium found in the urine resulted from intakes of 100% pure Type S (highly-insoluble) 

material. In this case, a small amount of uranium in urine corresponds to a relatively large 

intake. It is also important to keep in mind here that no dose reconstruction infeasibilities have 

been identified for uranium intakes at LANL. For the case of uranium, bioassay data are 

available for monitored workers and ORAUT-OTIB-0062 (not necessarily 2% SALI) could be 

used to assign intakes for unmonitored workers with potential for exposure. This is also the case 

for tritium and plutonium intakes discussed in this section. The purpose for presenting these data 

and making these comparisons here is simply to show how intakes derived from actual bioassay 

results for the primary radionuclides would compare to 2% SALI intakes for these nuclides. Use 

of the 2% SALI (or 100 mrem CEDE) intake assumption would only be necessary for 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 30 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

radionuclides for which dose reconstruction infeasibilities have been identified in Los Alamos 

National Laboratory (SEC-00109) Special Exposure Cohort Evaluation Report, Rev. 1, issued 

August 13, 2012 (NIOSH, 2012). 

The OTIB-0062 50th percentile intake rates for Pu-238 for the 1996-2005 period are 0.048 and 

0.72 pCi/d for lung clearance Type M and S, respectively. The ER Addendum values for Class 

W and Y are 0.70 and 0.95. By this comparison, the proposed ER Addendum intake rates would 

appear to be bounding.

For Pu-239, the OTIB-0062 50th percentile intake rates for the 1996-2005 period are 0.013 pCi/d 

for Type M material and 0.14 pCi/d for Type S and Super S. The ER Addendum values for 

Class W and Y are 0.64 and 0.89. By this comparison, the proposed ER Addendum intake rates 

would appear to be bounding for Pu-239.

CONCLUSION

NIOSH agrees with many of the issues identified by SC&A in its review of the LANL ER 

Addendum. Specifically, NIOSH agrees that LANL may not have been in full compliance with 

all aspects of 10 CFR 835 during the entire period under evaluation (1996-2005). NIOSH further 

acknowledges the possibility that some workers who should have been monitored according to 

procedure, may not have been. 

NIOSH does not share many of SC&A’s technical concerns. Specifically, NIOSH did not 

identify any significant technical shortfalls with regard to LANL’s in-vivo program during the 

period of this evaluation. During the 10 CFR 835 era, the LANL in-vivo operation was equipped 

with state-of-the-art counting equipment and was staffed with competent professionals. As 

evidenced by available in-vivo measurement results, LANL used high-resolution germanium 

detectors throughout the entire evaluation period to monitor for fission and activation products 

for workers at the LANSCE facility and throughout the laboratory.

The field monitoring and contamination control programs at LANL were well-established and 

formalized by January 1, 1996. These programs, which were intended to ensure that 

unmonitored individuals were unlikely to receive intakes of 100 mrem CEDE, were in place and 

being implemented during the period of this evaluation.

Based upon its review of existing bioassay results, NIOSH finds that workers who were 

monitored for the primary radionuclides (uranium, plutonium, and tritium) were unlikely to have 

received intakes exceeding 2% of the SALI (or intakes that would have resulted in 100 mrem 

CEDE). NIOSH also believes that intakes to the unmonitored population would have been lower 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 31 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

than that of the monitored population. NIOSH therefore concludes that unmonitored workers 

were unlikely to have received intakes of 2% of the SALI, and the assignment of 2% SALI 

intakes for unmonitored workers with access to controlled areas is bounding. NIOSH further 

finds no reason to believe that intakes of exotic radionuclides by unmonitored workers would be 

substantially different. In summary, NIOSH concludes that the weight of the evidence supports 

assignment of 2% SALI intakes for unmonitored workers, as proposed in the ER Addendum, is 

sufficiently bounding and claimant favorable.
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 32 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

REFERENCES

10 CFR 835, Occupational Radiation Protection, U.S. Department of Energy; SRDB Ref ID: 

173742 

ABRWH, 2007, Transcript: Advisory Board on Radiation and Worker Health, 46th Meeting, 

May 3, 2007; Westminster, Colorado; SRDB Ref ID: 174240, PDF pp. 274, 302-304

ABRWH, 2010a, Transcript: Advisory Board on Radiation and Worker Health, Los Alamos 

National Laboratory Work Group, April 29, 2010; SRDB Ref ID: 174236

ABRWH, 2010b, Transcript: Advisory Board on Radiation and Worker Health, Los Alamos 

National Laboratory Work Group, November 3, 2010; SRDB Ref ID: 174242

ABRWH, 2011, Transcript: Advisory Board on Radiation and Worker Health, Los Alamos 

National Laboratory Work Group, May 2, 2011; SRDB Ref ID: 174239

ABRWH, 2012a, Transcript: Advisory Board on Radiation and Worker Health, 86th Meeting, 

September 18, 2012; Denver, Colorado; SRDB Ref ID: 173738 

ABRWH, 2012b, Letter from James M. Melius, Chairman, ABRWH, to Kathleen Sebelius, 

Secretary of Health and Human Services. October 31, 2012; SRDB Ref ID: 169470 

ABRWH, 2012c, Transcript: Advisory Board on Radiation and Worker Health, Los Alamos 

National Laboratory Work Group, May 14, 2012; SRDB Ref ID: 174241

ABRWH, 2017, Transcript: Advisory Board on Radiation and Worker Health, Los Alamos 

National Laboratory Work Group, August 15, 2017; SRDB Ref ID: 174238

Assessment, 1999, Assessment of the Los Alamos National Laboratory Internal Dose Evaluation 

Program, E. M. Brackett (MJW Corp.) and T. R. La Bone (Westinghouse Savannah River Co.); 

April 1, 1999; SRDB Ref ID: 168446, PDF pp. 132-138 

CAP88-PC, 1992, Clean Air Act Assessment Package – 1988 Synopsis Report Non-radon 

Population Assessment, June 14, 1992; SRDB Ref ID: 70298

CDC, 2010, Final Report of the Los Alamos Historical Document Retrieval and Assessment 

(LAHDRA) Project, prepared for the Centers for Disease Control and Prevention (CDC) National 

Center for Environmental Health Division of Environmental Hazards and Health Effects 

Radiation Studies Branch, November 2010; SRDB Ref ID: 137540

Cerro Grande, 2001, Updated Calculation of the Inhalation Dose from the Cerro Grande Fire 

Based on Final Air Data, LA-UR-01-1132, D.H. Kraig, et al, Los Alamos National 

Laboratory; February 2001; SRDB Ref ID: 46247
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 33 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Cerro Grande, 2011, Revision to Cerro Grande White Paper, Rev. 1, Oak Ridge Associated 

Universities, April 4, 2011; SRDB Ref ID 174281

DOE, 1988, Radiation Protection for Occupational Workers, DOE Order 5480.11, U.S. 

Department of Energy, Washington, DC. December 21, 1988; SRDB Ref ID: 8073 

DOE, 1995, Dual Axis Radiographic Hydrodynamic Test Facility Final Environmental Impact 

Statement, Volume 1: Chapters 1-6 & Appendixes A-K, DOE/EIS-0228, U.S. Department of 

Energy, Albuquerque Operations Office, Los Alamos Area Office, Albuquerque, New Mexico; 

August 1995; SRDB Ref ID: 61709 

DOE, 1999, Site-Wide Environmental Impact Statement for Continued Operation of the Los 

Alamos National Laboratory, Los Alamos, New Mexico, Volume I-Main Report, DOE/EIS-0238, 

U.S. Department of Energy, Albuquerque Operations Office, Albuquerque, New Mexico; 

January 1999; SRDB Ref ID: 13468 

DOE, 2001a, Programmatic Assessment of the Internal Dosimetry Program at Los Alamos 

National Laboratory, 200-RP-1, U.S. Department of Energy, Los Alamos Area Office, Office of 

Facility Operations; July 5, 2001; SRDB Ref ID: 83663 

DOE, 2001b, Conduct of Operations Requirements for DOE Facilities, Change 2, DOE Order 

5480.19, U.S. Department of Energy, Washington, D.C., October 23, 2001; SRDB Ref ID: 

174235 

DOE/NTS, 2017, Department of Energy Noncompliance Report, Main Information, NTS-ALOLA-LANL-1999-0004, Internal Dose Evaluation Program, viewed on the Noncompliance 

Tracking System on July 5, 2017; SRDB Ref ID: 164555 

ES&H Manual, 1991, Environment, Safety, and Health Manual, Administrative Requirements: 

AR 3-6, Personnel Radiation Dosimetry; Los Alamos National; February 1991; SRDB Ref ID: 

51526 

GAO, 1990, Need for Improved Responsiveness to Problems at DOE Sites, GAO/RCED-90-101, 

United States General Accounting Office; March 1990; SRDB Ref ID: 46148, PDF p. 20

GAO, 1993, Corrective Actions on Tiger Teams’ Findings Progressing Slower than Planned,

GAO/RCED-93-66, United States General Accounting Office; March 1993; SRDB Ref ID: 

46172, PDF p. 5

GAO, 2000, Lessons Learned from the Cerro Grande (Los Alamos) Fire and Actions Needed to 

Reduce Fire Risks, GAO/T-RCED-00-273, United States General Accounting Office; August 14, 

2000; SRDB Ref ID: 46252
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 34 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

LAMPF, 1975, An Assessment of Los Alamos Meson Physics Facility (LAMPF) Liquid 

Radioactive Waste Generation and Disposal Alternatives, Los Alamos Scientific Laboratory; 

July, 1975; SRDB Ref ID: 73423

LAMPF, 1983, Major Dose Contributors at LAMPF, HD-83-42, memo to R. Miller (U.S. 

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Laboratory); March 21, 1983; SRDB Ref ID: 73389

LANL, 1984, In Vivo Assessment of Lung Burdens at the Los Alamos National Laboratory, LA9979-MS; Los Alamos National Laboratory; April 1984; SRDB Ref ID: 12960 

LANL, 1988, Accelerator Health Protection Quarterly Progress Report, First Quarter-1988, 

Los Alamos National Laboratory; April 14, 1988; SRDB Ref ID: 45486

LANL, 1991a, The Los Alamos National Laboratory’s Air Emissions Monitoring Program: A 

Quick-Look Technical Review; Ray Waller, Charles Keller, and Sumner Barr (Institute for 

Geophysics and Planetary Physics); September 12, 1991; SRDB Ref ID: 46108, PDF pp. 8-14

LANL, 1991b, Los Alamos National Laboratory ES&H Self-Assessment Report, LA-12200-MS; 

Finding/AX.2-1, August 1991; SRDB Ref ID: 174244 PDF pp. 108, 141

LANL, 1994, Environmental Surveillance at Los Alamos during 1992, LA-12764-ENV; Los 

Alamos National Laboratory, Environmental Management Division, Environmental Protection 

Group, Los Alamos, NM; July 1994; SRDB Ref ID: 47048 

LANL, 2013, Response to NIOSH Questions for LANL Staff Regarding 10 CFR 835 

Implementation and Unresolved Issues, RP2-HPM-13:002, Los Alamos National Laboratory, 

Radiation Protection Division, Los Alamos, NM; March 19, 2013; SRDB Ref ID: 166130 

LANL Dosimetry, 1994, Laboratory Standard: Radiation Dosimetry Monitoring, LS107-11.0 

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133601

LANL Dosimetry, 1999, The LANL Model 8823 Whole-Body TLD and Associated Dose 

Algorithm, ESH4-PDO-TBD-02, R1 (LA-UR-99-2327); Los Alamos National Laboratory 

Personnel Dosimetry Operations Team, ESH4; 1999; SRDB Ref ID: 27256

LANL Health Physics, 2012, LANL Health Physics Procedures and Source Terms, written and 

submitted by SEC-00109 LANL Petitioner; April 2012; SRDB Ref ID: 174282, PDF p. 5

LANL Inspection, 2005, Inspection of Environment, Safety, and Health Programs at the Los 

Alamos National Laboratory, U.S. Department of Energy, Office of Security and Safety 

Performance Assurance, Office of Independent Oversight; November 2005; SRDB Ref ID: 

123968
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 35 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

NCRP, 1987, Use of Bioassay Procedures for Assessment of Internal Radionuclide Deposition, 

Report No. 87, National Council on Radiation Protection and Measurements; February 28, 1987; 

SRDB Ref ID: 167664

NIOSH, 2007, SEC Petition Evaluation Report for Petition SEC-00051, Los Alamos National 

Laboratory, Revision Addendum-2, National Institute for Occupational Safety and Health 

(NIOSH); June 5, 2007; SRDB Ref ID: 41108, PDF pp. 74, 110

NIOSH, 2009, SEC Petition Evaluation Report for Petition SEC-00109, Los Alamos National 

Laboratory, Rev. 0, National Institute for Occupational Safety and Health (NIOSH); January 22, 

2009; SRDB Ref ID: 79895

NIOSH, 2012, SEC Petition Evaluation Report for Petition SEC-00109, Los Alamos National 

Laboratory, Rev. 1, National Institute for Occupational Safety and Health (NIOSH); August 13, 

2012; SRDB Ref ID: 165232 

NIOSH, 2017, Addendum to Los Alamos National Laboratory (SEC-00109) Special Exposure 

Cohort Evaluation Report, National Institute for Occupational Safety and Health, (NIOSH). 

April 24, 2017; SRDB Ref ID: 173741 

NNSA, 2005, Type B Investigation of the Am-241 Contamination Accident at the Sigma Facility, 

LANL, July 14, 2005, Doug Minnema (National Nuclear Security Administration); July 14, 2005; 

SRDB Ref ID: 46117

Non-conformance, 1999, Noncompliance Report NC ID 484: Internal Dose Evaluation 

Program, NTS-ALO-LA-LANL-LANL-1999-0004; Los Alamos National Laboratory; March 

1999; SRDB Ref ID: 164555 

NRC, 1995, Radiation Dose Reconstruction for Epidemiologic Uses, National Research Council; 

SRDB Ref ID: 174249 

NTS List, 2016, LANL-Associated Documents Potentially Related to 10 CFR 835 Compliance 

Accessed for the DOE Nonconformance Tracking System (NTS), Oak Ridge Associated 

Universities; November 11, 2016; SRDB Ref ID: 165178 

ORAUT-OTIB-0062, Internal Dosimetry Coworker Data for Los Alamos National Laboratory, 

Rev. 00, Oak Ridge Associated Universities; October 15, 2009; SRDB Ref ID: 75028 

ORAUT-OTIB-0063, Los Alamos National Laboratory Bioassay Repository Database, Rev. 00, 

Oak Ridge Associated Universities; August 24, 2009; SRDB Ref ID: 73101 

ORAUT-OTIB-0066, Calculation of Dose from Intakes of Special Tritium Compounds, Rev. 00, 

Oak Ridge Associated Universities; April 26, 2007; SRDB Ref ID: 31421 
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 36 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

ORAUT-TKBS-0010-4, Technical Basis Document for the Los Alamos National LaboratoryOccupational Environmental Dose, Revision 01, Oak Ridge Associated Universities; March 26, 

2010; SRDB Ref ID: 80164

ORAUT-TKBS-0010-6, Technical Basis Document for the Los Alamos National LaboratoryOccupational External Dose, Revision 03, Oak Ridge Associated Universities; March 21, 2013; 

SRDB Ref ID: 123074

ORPS, 1998, LANL Occurrence Report:Americium-241 Contamination Detected on the 

Personal Clothing of [redacted] Employee Working in [redacted] of the CMR Facility; ALOLA-LANL-CMR-1998-0041; Los Alamos National Laboratory; [redacted], 1998; SRDB Ref ID: 

168453, PDF pp. 220-225 (Contains UCNI and OUO) 

ORPS, 2002, LANL Occurrence Report: Employees with Potential Uptake, One with Skin 

Contamination, After Airborne Release at Technical Area 55, [redacted]; DP-ALO-LA-LANLTA55-2002-0003; Los Alamos National Laboratory; [redacted], 2002; SRDB Ref ID: 164536, 

PDF pp. 18-26 

ORPS Reports, 1993-2015, LANL-Associated Documents Potentially Related to 10 CFR 835 

Compliance Accessed from the DOE Occurrence Reporting System (ORPS) for the Years 1993-

2015, Oak Ridge Associated Universities; accessed from U.S. Department of Energy in 2017; 

SRDB Ref ID: 165346 (1993); SRDB Ref ID:165347 (1994-2006); SRDB Ref ID: 165348 

(2007-2015)

PNOV, 2007, Preliminary Notice of Violation and Proposed Civil Penalty of $1,100,000 

(Waived by Statute), EA-2006-05, U.S. Department of Energy, National Nuclear Security 

Administration; February 16, 2007; SRDB Ref ID: 46407 

SC&A, 2006, Los Alamos National Laboratory Site Profile Review, SCA-TR-Task1-0011, 

Revision 0, S. Cohen & Associates, Vienna, Virginia and Saliant, Inc., Jefferson, Maryland, 

August, 2006; SRDB Ref ID: 46217

SC&A, 2010, SC&A’s Review of NIOSH’s Evaluation Report for Los Alamos National 

Laboratory Special Exposure Cohort Petition SEC-00109: Preliminary Issues – Availability of 

Bioassay Records and Adequacy of In-vivo Dosimetry, SCA-TR-SEC2010-0004, Revision 0, 

SC&A, Inc., Vienna, Virginia. April 8, 2010; SRDB Ref ID: 173739 

SC&A, 2017, Review of SEC Petition Evaluation Report Addendum (SEC-00109) for Los 

Alamos National Laboratory, SC&A, Inc.; July 27, 2017; SRDB Ref ID: 173740 

SEC-00109 LANL Petitioner, 2008, SEC-00109 Petition Attached Narrative, LANL Support 

Services Workers, SEC Petition, 1976-2005, SRDB Ref ID: 46103
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 37 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

Th-232 Bioassay, 1999, LANL Whole Body/Chest Count Dosimetry Report, Los Alamos National 

Laboratory; March 1999; SRDB Ref ID: 55138 

Tiger Team, 1991, Tiger Team Assessment of the Los Alamos National Laboratory, Washington, 

DC 20585, U.S. Department of Energy: Environment, Safety, and Health; November 1991; 

SRDB Ref ID: 23620

U.S. District Court Order, 1996. Memorandum Opinion and Order, Concerned Citizens for 

Nuclear Safety, Inc. and Patrick Jerome Chavez v. U.S. DOE and Siegfried S. Hecker, No. CIV 

94-1039 M, U.S. District Court for the District of New Mexico, Albuquerque, New Mexico;

April 2, 1996; SRDB Ref ID: 174243, PDF pp. 10-18
Response Paper NIOSH Response to SC&A’s Review of the 

SEC-00109 LANL Addendum, with Revised 

References Section and Appendix

October 23, 2018

Page 38 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution. 

APPENDIX A: SEC-00109 LANL PETITIONER ISSUES AND RESOLUTIONS

This appendix provides a compilation of all the issues identified by the SEC-00109 

LANL petitioner along with their corresponding resolutions. The SEC-00109 

petitioner has, over the course of several years, identified an extensive array of 

concerns. These concerns involve monitoring, dosimetry, bioassay, data sufficiency, 

data integrity, site characteristics, exotic radionuclides, dose modeling, sites policies, 

and the role and attendant risks of Support Service Workers. 

Documentation Provided by Petitioner

When the petitioner filed his Form B petition in 2008, he provided a 68-page written 

narrative that discusses in detail a wide range of issues (SEC-00109 LANL Petitioner, 

2008). He also provided hundreds of references in a CD, consisting primarily of siteproduced and third-party documentation in support of his concerns. The following 

table is not an attempt to summarize all pertinent supporting documentation provided 

by the petitioner. It only identifies supporting documentation that was specifically 

provided or referenced in the forum from which the issue was identified. A complete 

listing of the documentation provided by the petitioner and reviewed by NIOSH in 

qualifying and evaluating the petition was presented in the SEC Petition Evaluation 

Report for Petition SEC-00109 (NIOSH, 2009).

Subsequent to the original submission, the petitioner physically attended, or called in 

to, meetings of the Advisory Board Work Group on LANL that were held on: 

• April 29, 2010; 

• November 3, 2010; 

• May 2, 2011; 

• May 14, 2012; 

• September 11, 2012; and 

• August 15, 2017. 

During these sessions, the petitioner identified additional concerns or elaborated on 

previous issues. Following a page-by-page review of the original narrative and the 

Work Group meeting transcripts, NIOSH has compiled the petitioner’s issues in the 

following table. NIOSH then assessed whether each issue has been addressed in the 

appropriate manner in some document or venue. The issues are presented in the 

chronological order in which they were raised, beginning with the original narrative 

and going through the six meeting transcripts. 
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 39 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

SEC-00109 LANL Petitioner Issues

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

1 Multiple documented 

admissions by NIOSH that 

there are still unresolved 

issues at the site after 1975

SEC-00109 Petition 

Attached Narrative

(SEC-00109 LANL 

Petitioner, 2008), 

PDF pp. 3-4, 43

Received

04-03-08

SEC-00051, PDF pp. 74, 110 (NIOSH, 2007)

May 3, 2007 Board meeting, PDF pp. 274, 302-

304 (ABRWH, 2007) 

NIOSH concurred with the petitioner. SEC 

Petition Evaluation Report for Petition 

SEC-00109, Rev. 1 (NIOSH, 2012), 

recommended expanding the SEC class 

through 1995. 

2 Poor monitoring or lack of 

monitoring of the support 

service workers

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 4, 36-38

Received 

04-03-08

SEC-00051, PDF pp. 74, 110 (NIOSH, 2007)

LANL’s Air Emissions Monitoring Program, pp. 

8-14 (LANL, 1991a)

NIOSH concurred with the petitioner. SEC 

Petition Evaluation Report for Petition 

SEC-00109, Rev. 1 (NIOSH, 2012), 

recommended expanding the SEC class 

through 1995.

3 Dosimetry deficiencies SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 5 

Received 

04-03-08

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH concurred with the petitioner. SEC 

Petition Evaluation Report for Petition 

SEC-00109, Rev. 1 (NIOSH, 2012), 

recommended expanding the SEC class 

through 1995.

4 Bioassay deficiencies SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 5 

Received 

04-03-08

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH concurred with the petitioner. SEC 

Petition Evaluation Report for Petition 

SEC-00109, Rev. 1 (NIOSH, 2012), 

recommended expanding the SEC class 

through 1995.

5 Insufficient data and poor 

methodology for 

reconstructing 

environmental dose

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 5 

Received 

04-03-08

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH concurred with the petitioner. SEC 

Petition Evaluation Report for Petition 

SEC-00109, Rev. 1 (NIOSH, 2012), 

recommended expanding the SEC class 

through 1995.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 40 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

6 The site is very large (8.6 

M sq. ft. in about 2000 

structures), which makes 

analysis a challenge

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 5 

Received 

04-03-08

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH acknowledges that LANL is a large 

site. This fact, however, would not likely 

affect the ability to reconstruct dose for 

monitored workers.

7 LANL is topographically 

complex, which makes site 

meteorology highly 

variable

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 8 

Received 

04-03-08

Radiation Dose Reconstruction for Epidemiologic 

Uses (NRC, 1995)

Environmental Surveillance at Los Alamos 

during 1992 (LANL, 1994)

NIOSH acknowledges that LANL is 

topographically complex. This fact, 

however, would not likely affect the ability 

to reconstruct dose for monitored workers.

8 LANL climate and terrain 

make radionuclide 

dispersion highly variable

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 8, 18

Received 

04-03-08

Radiation Dose Reconstruction for Epidemiologic 

Uses (NRC, 1995)

Environmental Surveillance at Los Alamos 

during 1992 (LANL, 1994)

NIOSH agrees. This issue affects the 

accuracy of dispersion modeling; however 

does not affect the ability to reconstruct 

worker intakes based upon workplace 

sampling. 

9 The LANL Site Profile

(ORAUT-TKBS-0010-4)

assumes that outdoor 

explosives testing is an area 

source. The column of 

entrainment should be 

considered a point source, 

which should be modeled 

differently.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 16, 20-21

Received 

04-03-08

Dual Axis Radiographic Hydrodynamic Test

Facility Final Environmental Impact Statement, 

Volume 1 (DOE, 1995)

The Occupational Environmental Dose 

volume of the Site Profile, ORAUT-TKBS0010-4, mentions “...area sources (such as 

contaminated soil)...” (PDF p. 50). This is 

the only mention of area sources in the 

profile. Worker intake estimates do not 

rely upon plume dispersion models. 

Environmental intake estimates in outdoor 

explosives testing areas are based on air 

monitoring data. Post-1995, workers likely 

to receive intakes resulting in 100 mrem 

CEDE should have been monitored. (Note: 

The LANL Site Profile was revised in 

2010.)
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 41 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

10 Buildings influence 

dispersion

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 16

Received 

04-03-08

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

Worker intake estimates do not rely on 

plume-dispersion models. Environmental 

intake estimates in outdoor areas are based 

on air monitoring data. Post-1995, workers 

likely to receive intakes resulting in 100 

mrem CEDE should have been monitored.

11 The CAP-88 Model 

(CAP88-PC, 1992) has 

limitations that affect 

accuracy when applied to 

LANL. 

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 26-28 

Received 

04-03-08

Clean Air Act Assessment Package – 1988

Synopsis Report Non-radon Population 

Assessment (CAP88-PC, 1992) 

Radiation Dose Reconstruction for Epidemiologic 

Uses (NRC, 1995)

Site-Wide Environmental Impact Statement for 

Continued Operation of the Los Alamos National 

Laboratory (DOE, 1999)

Worker intake estimates do not rely on 

plume-dispersion models. Environmental 

intake estimates in outdoor areas are based 

on air monitoring data. Post-1995, workers 

likely to receive intakes resulting in 100 

mrem CEDE should have been monitored. 

(Note: The LANL Site Profile was revised 

in 2010. There is no mention of the CAP88 Model in the current version.) 

12 Few AIRNET samplers are 

placed in locations that 

would determine employee 

exposures. They are 

located to estimate off-site 

exposure.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 30 

Received 

04-03-08

Los Alamos National Laboratory Site Profile 

Review (SC&A, 2006)

The cited SC&A review of the 2004 Site 

Profile was completed in 2006. The 2010 

revised LANL Site Profile (ORAUTTKBS-0010-4) addressed this issue.

13 In the DOE environmental 

surveys of all its sites, 

LANL was the 4th highest 

in problems with 59.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 31 

Received 

04-03-08

Need for Improved Responsiveness to Problems 

at DOE Sites (GAO, 1990)

NIOSH does not disagree that there were 

environmental problems at LANL, as 

identified in the cited report. However, 

these problems would not affect NIOSH’s 

ability to reconstruct worker doses that are 

based on monitoring data.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 42 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

14 There were a number of 

findings by the Tiger Team

(Tiger Team, 1991) that 

relate to monitoring, dose, 

and missed dose.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 32

Received 

04-03-08

Corrective Actions on Tiger Team Findings 

Progressing Slower than Planned, p. 5 (GAO, 

1993)

This issue was addressed in SEC Petition 

Evaluation Report for Petition SEC-00109, 

Rev. 0 (NIOSH, 2009), and in SEC Petition 

Evaluation Report for Petition SEC-00109, 

Rev. 1 (NIOSH, 2012). 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 (Tiger 

Team, 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;

(continued on next page)
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 43 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

14 (continued) (continued) (continued) (continued) (continued) 

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 (DOE, 1988);

11. calibration and response-checking of

fixed instruments and tritium monitors

did not reflect the same level of attention

and commitment given to 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

(continued on next page)
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 44 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

14 (continued) (continued) (continued) (continued) (continued) 

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 dose 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 on internal and 

external dose monitoring data. These data 

are also employed in co-worker studies to 

estimate unmonitored worker intakes.

15 The LANL ES&H SelfAssessment (LANL, 

1991b) identified problems 

with stack monitoring and 

LANL lost a Clean Air Act 

lawsuit as a result.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 33

Received 

04-03-08

Los Alamos National Laboratory ES&H SelfAssessment Report (LANL, 1991b)NIOSH does not disagree that there were 

stack-monitoring problems at LANL, as 

identified in the cited 1991 ES&H SelfAssessment report. However, these 

problems would not affect NIOSH’s ability 

to reconstruct worker doses using 

methodologies that do not rely on stack 

monitoring.

16 The EPA found that LANL 

was not in compliance in 

regard to identifying 

emission sources, 

installation of stacks, and 

stack monitoring.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 34

Received 

04-03-08

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH does not disagree that there were 

stack-monitoring problems at LANL. 

However, these problems would not affect 

NIOSH’s ability to reconstruct worker 

doses using methodologies that do not rely 

on stack monitoring.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 45 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

17 An EPA audit the following 

year found continuing 

violations. 31 of 33 

radionuclide-emitting 

stacks were out of 

compliance. LANL was 

fined and had to submit 3 

independent audits of its air 

quality.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 34-35

Received 

04-03-08

Memorandum Opinion and Order, Concerned 

Citizens for Nuclear Safety, Inc and Patrick 

Jerome Chavez v. U.S. DOE and Siegfried S. 

Hecker, p. 8 (U.S. District Court Order, 1996)

See response to Issue 16.

18 The main resources for the 

dosing tables in ORAUTTKBS-0010-4 were the 

CDC’s LAHDRA report

(CDC, 2010) and the 

LANL Environmental 

Surveillance Report

(LANL, 1994), both of 

which only address 

airborne concentrations that 

would affect people offsite.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 39

Received 

04-03-08

ORAUT-TKBS-0010-4 

SEC-00051 ER, PDF p. 81 (NIOSH, 2007)

This issue is from the 2004 Site Profile. 

The profile was revised in 2010. Section 

4.2.1.1 of ORAUT-TKBS-0010-4 (03-26-

10) states: For earlier years (1943 to

1970), the effluent releases in this

document rely on data from the Centers for

Disease Control and Prevention Los

Alamos Historical Document Retrieval and

Assessment (LAHDRA) project, including

unpublished data; however, these data

were determined to be insufficient for

reconstruction of environmental internal

doses.

19 Prior to the Clean Air Act 

in 1969, LANL did not 

maintain effluent data.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 42

Received 

04-03-08

Final Report of the Los Alamos Historical

Document Retrieval and Assessment (LAHDRA) 

Project (CDC, 2010) 

The SEC-00109 evaluation addressed the 

years 1976-2005. This pre-1969 issue is 

not relevant. 
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 46 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

20 Current policies and 

procedures do not ensure 

compliance with DOE 

Order 5480.19 (DOE, 

2001b). 

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 45

Received 

04-03-08

Los Alamos National Laboratory ES&H 

Self- Assessment Report (LANL, 1991b) 

This 1991 Self-Assessment identified 

compliance issues with DOE Order 

5480.19, “Conduct of Operations 

Requirements for DOE Facilities,” (DOE, 

2001b). NIOSH also found issues 

associated with written operating 

procedures. Expansion of the SEC class 

through 1995 was recommended in the 

SEC-00109 ER, Rev. 1 (NIOSH, 2012). 

Radiation protection and monitoring 

procedures improved by 1996, with the 

implementation of 10 C.F.R. 835.

21 LANL does not have a 

clearly articulated policy 

with standards for 

procedure development, 

document control, and 

records management.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF p. 46

Received 

04-03-08

Los Alamos National Laboratory ES&H 

Self- Assessment Report (LANL, 1991b) 

This 1991 Self-Assessment identified 

compliance issues with DOE Order 

5480.19, “Conduct of Operations 

Requirements for DOE Facilities,” (DOE, 

2001b). NIOSH also found issues 

associated with procedures and records 

management. Expansion of the SEC class 

through 1995 was recommended in the 

SEC-00109 ER, Rev. 1 (NIOSH, 2012). 

Radiation protection and records 

management procedures improved by 1996, 

with the implementation of 10 C.F.R. 835.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 47 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

22 There is a lack of data for 

the Cerro Grande Fire for a 

variety of reasons. Security 

guards were not provided 

with any breathing 

apparatus throughout the 

three weeks of the fire and 

evacuation and return and 

they worked 16 hrs/day 7 

days/wk.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 47-55

Received 

04-03-08

Lessons Learned from the Cerro Grande (Los 

Alamos) Fire and Actions Needed to Reduce Fire 

Risks (GAO, 2000)

Radiation Dose Reconstruction for 

Epidemiologic Uses (NRC, 1995)

Updated Calculation of the Inhalation Dose from 

the Cerro Grande Fire Based on Final Air Data 

(Cerro Grande, 2001)

SEC-00109 ER, Rev. 0 (NIOSH, 2009), 

and SEC-00109 ER, Rev. 1 (NIOSH, 

2012), address the Cerro Grande Fire in 

Section 7.4.1. 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.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 48 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

23 Support service workers 

were not monitored or 

adequately monitored 

during and after the Sigma 

Americium Contamination 

Incident.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 55-57

Received 

04-03-08

Type B Investigation of the Am-241

Contamination Accident at the Sigma Facility

(NNSA, 2005)

Use of Bioassay Procedures for Assessment of 

Internal Radionuclide Deposition (NCRP, 1987) 

SEC-00051 LANL ER, PDF pp. 67, 78 (NIOSH,

2007)

SEC-00109 ER, Rev. 0 (NIOSH, 2009), 

and SEC-00109 ER, Rev. 1 (NIOSH, 

2012), address the Sigma American 

Contamination Incident in Section 7.4.2. 

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.

24 In-vitro bioassay samples 

were not handled properly. 

They were stored in an 

unrefrigerated cabinet and 

analyzed once a week.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 57-58

Received 

04-03-08

Use of Bioassay Procedures for Assessment of 

Internal Radionuclide Deposition (NCRP, 1987) 

NIOSH has not identified sample-handling 

issues that would invalidate bioassay 

results. 

25 The LANL bioassay 

program was insufficient 

because support service 

workers were not routinely 

monitored and the records 

are inadequate or 

incomplete.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 58-60

Received 

04-03-08

SEC-00051 LANL ER, PDF pp. 67, 78 (NIOSH, 

2007)

NIOSH concurred with the petitioner. 

SEC-00109 ER, Rev. 1 (NIOSH, 2012), 

recommended expanding the SEC class 

through 1995. Post-1995, workers likely to 

receive intakes resulting in 100 mrem 

CEDE should have been monitored. 
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 49 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

26 Because support service 

workers could work at 

several facilities in a day, 

and because NCFs varied 

by more than an order of 

magnitude across LANL 

facilities, data from the 

LANL 7776 type TLD 

cannot be used for DRs for 

these workers.

SEC-00109 Petition 

Attached Narrative 

(SEC-00109 LANL 

Petitioner, 2008),

PDF pp. 60-61

Received

04-03-08

The LANL Model 8823 Whole-Body TLD and 

Associated Dose Algorithm (LANL Dosimetry, 

1999)

This issue was addressed in SEC-00109 

ER, Rev. 0 (NIOSH, 2009) and SEC-00109 

ER, Rev. 1 (NIOSH, 2012), in Section 

7.4.4. 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. 

27 Regarding the validity of 

coworker data, I have 

concerns about the firing 

sites. There were 

explosions involving 

exotics. What workers are 

you using to represent the 

people who were there and 

who cleaned up? All site 

workers?

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 240-242

(ABRWH, 2010a)

April 29, 

2010

No additional supporting documents were

specifically provided or referenced in the cited 

Forum.

The coworker models were derived from 

bioassay results from all monitored workers 

at LANL, not just glovebox workers.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 50 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

28 Are the electronic data 

present to validate who was 

in an area and when?

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 242-244

(ABRWH, 2010a)

April 29, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH does not rely on electronic data to 

determine who is in various LANL areas. 

NIOSH acknowledges that many workers 

frequented multiple unknown areas. For 

this reason, the SEC class definition in 

SEC-00109 ER, Rev. 1 (NIOSH, 2012), 

includes all workers. In the SEC-00109 ER 

Addendum (NIOSH, 2017), NIOSH 

concluded that unmonitored workers were 

unlikely to have received intakes that 

would have resulted in 100 mrem CEDE.

29 What about the checklist 

that workers fill out 

annually that is part of the 

occupational health 

program? It asks what 

radionuclides a worker is 

exposed to. If workers 

don’t know, they will 

generally say No. Does 

this checklist determine 

who is identified for 

monitoring and the 

bioassay program?

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 244-249

(ABRWH, 2010a)

April 29, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

In the SEC-00109 ER Addendum (NIOSH, 

2017), NIOSH concluded that the LANL 

programs for identifying individuals for 

bioassay during the post-1995 era were 

effective. NIOSH further concluded that 

unmonitored workers were unlikely to have 

received intakes that would have resulted in 

100 mrem CEDE.

This issue was identified by SC&A in their 

review of the LANL ER Addendum

(SC&A, 2017). This was one of the issues 

identified in the noncompliance report NC 

ID 484 (Non-conformance, 1999). 

30 I still don’t feel all the 

source terms 

environmentally have been 

identified and examined. I 

related them in my report. I 

don’t feel they were 

addressed in the ER.

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 249-250

(ABRWH, 2010a) 

April 29, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

In the SEC-00109 ER Addendum (NIOSH, 

2017), NIOSH concluded that unmonitored 

workers were unlikely to have received 

intakes that would have resulted in 100 

mrem CEDE. This determination includes 

contributions from environmental 

contamination source terms.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 51 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

31 The New Mexico 

Environment Dept. and 

LANL are supposed to 

issue a joint report 

concerning contamination 

at the lab. They have 

determined that the DO 

need a federal investigation 

where it is compensable to 

surrounding lands.

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

p. 249 (ABRWH,

2010a)

April 29, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

In the SEC-00109 ER Addendum (NIOSH, 

2017), NIOSH concluded that unmonitored 

workers were unlikely to have received 

intakes that would have resulted in 100 

mrem CEDE. This determination includes 

contributions from environmental 

contamination source terms.

32 Talking about LANSCE 

and the activation product 

issues, in my petition, there 

is a discrepancy between 

that and I believe the latest 

update to the environmental 

exposures in the TBD 

because basically they say 

the winds going to TA-72 

are three percent. And in 

the petition, I provide 

documentation that says the 

winds going towards TA-72 

are 26 percent.

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 250-251

(ABRWH, 2010a)

April 29, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

In the SEC-00109 ER Addendum (NIOSH, 

2017), NIOSH concluded that unmonitored 

workers were unlikely to have received 

intakes that would have resulted in 100 

mrem CEDE. This determination includes 

contributions from environmental 

contamination source terms. 
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 52 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

33 LANL cited one air 

monitor in Mortandad 

Canyon they would use to 

determine dose for 

firefighter, guards, and 

other people on site. The 

RAC report stated that air 

monitors were shut off for 3 

days during the fire. 

Particulate matter 

overwhelmed the filters so 

that accuracy was changed 

by an order of magnitude.

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 252-255

(ABRWH, 2010a)

April 29, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum. 

See response to Issue 22.

The report referenced in response to Issue 

22, Updated Calculations of the Inhalation 

Dose from the Cerro Grande Fire Based on 

Final Air Data (Cerro Grande, 2001), 

concluded that the maximally-exposed 

individual from this fire received an intake 

resulting in a CEDE of only a fraction of a 

mrem. It is unlikely that unmonitored 

workers received intakes in excess of 100 

mrem CEDE. 

34 Worker records that did not 

record locations where 

people worked. They just 

recorded pay code and 

hours worked. Only in the 

last few years, were work 

locations recorded.

Transcript from the 

Board meeting of 

April 29, 2010, PDF 

pp. 257-258

(ABRWH, 2010a)

April 29, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH recognizes that claimants’ specific 

work locations are often unknown. For this 

reason, the SEC class definition in 

SEC-00109 ER, Rev. 1 (NIOSH, 2012), 

includes all workers and all areas. In the 

SEC-00109 ER Addendum (NIOSH, 

2017), NIOSH concluded that unmonitored 

workers were unlikely to have received 

intakes that would have resulted in 100 

mrem CEDE.

35 It was revealed in the Clean 

Air Act lawsuit that there 

were several buildings with 

unmonitored stacks. Were 

there exotics in these 

buildings?

Transcript from the 

Board meeting of 

Nov. 3, 2010, PDF 

pp. 133-134

(ABRWH, 2010b)

Nov. 3, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH does not disagree that there were 

stack monitoring problems at LANL. 

However, these problems would not affect 

NIOSH’s ability to reconstruct worker 

doses using methodologies that do not rely 

on stack monitoring.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 53 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

36 The episodic nature of the 

release of exotics through 

unmonitored stacks.

Transcript from the 

Board meeting of 

Nov. 3, 2010, PDF 

pp. 165-166

(ABRWH, 2010b)

Nov. 3, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

See response to Issue 35.

37 A guy inside a building has 

a glovebox and negative 

pressure. Where is 

contamination going? Out 

an unmonitored stack to a 

guy who is mowing the 

lawn.

Transcript from the 

Board meeting of 

Nov. 3, 2010, PDF 

pp. 168-169

(ABRWH, 2010b)

Nov. 3, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

Intakes by a person mowing the lawn 

would be accounted for by using 

methodologies given in the Site Profile for 

assigning environmental dose (ORAUTTKBS-0010-4). 

38 How do you place service 

workers at the firing sites 

before and after explosions 

(e.g., during clean-up)? 

There are problems with 

the badging process in 

making that determination.

Transcript from the 

Board meeting of 

Nov. 3, 2010, PDF 

pp. 292-297

(ABRWH, 2010b)

Nov. 3, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH will use personal monitoring data 

when available to assign worker doses and 

intakes. NIOSH does not rely on 

knowledge of worker location during and 

after explosives tests. In the SEC-00109 

ER Addendum (NIOSH, 2017), NIOSH 

concluded that unmonitored workers were 

unlikely to have received intakes that 

would have resulted in 100 mrem CEDE.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 54 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

39 There is a question about 

the reliability of 

Occupational Health and 

Health Physics checklists. 

The OH checklist is selfreporting. The HP 

checklist is informing in 

regard to whether bioassay 

will be required. Are these 

considered administrative 

controls? Are we relying 

on these to determine 

where people worked and 

when?

Transcript from the 

Board meeting of 

Nov. 3, 2010, PDF 

pp. 299-310, 338-341

(ABRWH, 2010b)

Nov. 3, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

The Board conversation seems to say that 

NIOSH is NOT using these documents to 

make these determinations.

NIOSH does not rely on the HP checklists 

to determine when and where individuals 

worked. The checklists are used, in part, 

by LANL HP professionals to ensure that 

workers are placed on the appropriate 

personnel monitoring programs.

Concerns regarding the effectiveness of the 

HP checklists for identifying appropriate 

bioassay programs for workers were raised 

by SC&A in their review of the LANL ER 

Addendum (SC&A, 2017). This was one 

of the issues identified in the noncompliance report NC ID 484 (Nonconformance, 1999). 

40 There are a number of sites 

that are uncharacterized. 

They don’t know what’s in 

them. There is exposure 

potential there, at least for 

service workers.

Transcript from the 

Board meeting of 

Nov. 3, 2010, PDF 

pp. 315-319

(ABRWH, 2010b)

Nov. 3, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

For monitored workers at uncharacterized 

sites, NIOSH would use those monitoring 

results to assign doses and intakes. In the 

SEC-00109 ER Addendum (NIOSH, 

2017), NIOSH concluded that unmonitored 

workers were unlikely to have received 

intakes that would have resulted in 100 

mrem CEDE.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 55 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

41 The National Academy of 

Sciences report says there 

is no mass balance for 

LANL. That raise the 

question: Have you 

captured the entire source 

term and potential exposure 

to workers?

Transcript from the 

Board meeting of 

Nov. 3, 2010, PDF p. 

315 (ABRWH, 

2010b)

Nov. 3, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

Accurate knowledge of source terms can 

sometimes be helpful to bound potential 

intakes in the absence of monitoring data. 

For LANL, NIOSH relies on monitoring 

data to assign intakes, but also recognizes 

that some workers were not monitored. In 

the SEC-00109 ER Addendum (NIOSH, 

2017), NIOSH concluded that unmonitored 

workers were unlikely to have received 

intakes that would have resulted in 100 

mrem CEDE.

42 Cerro Grande fire 

discussion and Don 

Stewart’s white paper 

being developed (Cerro 

Grande, 2011). 

Transcript from the 

Board meeting of 

Nov. 3, 2010, PDF 

pp. 321-333

(ABRWH, 2010b)

Nov. 3, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

See response to Issue 22.

43 The Tiger Team findings 

(Tiger Team, 1991) are 

programmatic. They call 

into question the reliability 

of the data for what you 

intend to use the data for. 

Transcript from the 

Board meeting of 

Nov. 3, 2010, PDF 

pp. 336-344

(ABRWH, 2010b)

Nov. 3, 

2010

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

This issue was addressed in SEC-00109 

ER, Rev. 0 (NIOSH, 2009). See response 

to Issue 14.

44 Are uncharacterized areas 

(e.g., waste disposal sites) 

covered under 

environmental? There is a 

listing of sites that require 

further investigation to 

determine if the pose a 

threat. The petitioner lists 

many examples.

Transcript from the 

Board meeting of 

May 2, 2011, PDF 

pp. 286-293

(ABRWH, 2011)

May 2, 

2011

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

For monitored workers in uncharacterized 

areas, NIOSH would use those monitoring 

results to assign doses and intakes. In the 

SEC-00109 ER Addendum (NIOSH, 

2017), NIOSH concluded that unmonitored 

workers were unlikely to have received 

intakes that would have resulted in 100 

mrem CEDE.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 56 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

45 As a result of the Clean Air 

Act lawsuit, they had an 

audit team that determined 

that a lack of 

documentation regarding 

inventories precluded a 

thorough evaluation 

regarding the quality and 

completeness of the 1996 

inventory. Also, they 

questioned the historical 

data on release and stack 

monitoring. Additional 

issue recited.

Transcript from the 

Board meeting of 

May 2, 2011, PDF 

pp. 293-298

(ABRWH, 2011)

May 2, 

2011

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

This issue is unlikely to impact NIOSH’s 

ability to reconstruct dose to workers. 

NIOSH utilizes personnel monitoring data 

for dose reconstruction at LANL, not 

inventories or stack monitoring data. In the 

SEC-00109 ER Addendum (NIOSH, 

2017), NIOSH concluded that unmonitored 

workers were unlikely to have received 

intakes that would have resulted in 100 

mrem CEDE.

46 In discussions with the 

petitioner, the firefighters 

maintain they had no 

bioassay samples taken 

during or after the Cerro 

Grande fire.

Transcript from the 

Board meeting of 

May 2, 2011, PDF 

pp. 310-315

(ABRWH, 2011)

May 2, 

2011

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

See response to Issue 22.

47 The issue of the size of the 

in vivo datasets in regard to 

exotics. There is a lot for 

U, Pu, and Am, but not for 

exotics. Are the datasets 

representative for exotics in 

terms of DR?

Transcript from the 

Board meeting of 

May 2, 2011, PDF 

pp. 318-322

(ABRWH, 2011)

May 2, 

2011

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH concurred with this issue in 

SEC-00109 ER, Rev. 1 (NIOSH, 2012), 

when it recommended an SEC class 

through 1995. In the SEC-00109 ER 

Addendum (NIOSH, 2017), NIOSH 

concluded that unmonitored workers were 

unlikely to have received intakes from 

exotic radionuclides that would have 

resulted in 100 mrem CEDE.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 57 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

48 The issue of RWPs and 

SWPs and whether they are 

always used and properly 

used when they are used. 

What about service workers 

who are not on an RWP?

Transcript from the 

Board meeting of 

May 14, 2012, PDF 

pp. 137-150

(ABRWH, 2012c) 

May 14, 

2012

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH concurred with this issue in 

SEC-00109 ER, Rev. 1 (NIOSH, 2012), 

when it recommended an SEC class 

through 1995. In the SEC-00109 ER 

Addendum (NIOSH, 2017), NIOSH 

concluded that unmonitored workers were 

unlikely to have received intakes from 

exotic radionuclides that would have 

resulted in 100 mrem CEDE.

Concern regarding the effectiveness of 

RWPs for identifying appropriate bioassay 

programs for workers was raised by SC&A 

in their review of the LANL ER Addendum

(SC&A, 2017). This was one of the issues 

identified in the noncompliance report NC 

ID 484 (Non-conformance, 1999). 

49 The measurement 

techniques for Pu don’t 

translate for Np. A wideranging discussion 

revolving around 

unmonitored workers.

Transcript from the 

Board meeting of 

May 14, 2012, PDF 

pp. 207-221

(ABRWH, 2012c) 

May 14, 

2012

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

This issue was addressed in a six-page 

response in the SEC-00109 ER Addendum 

(NIOSH, 2017).
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 58 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

50 In the 2008 report by DOE 

HSS (LANL Health 

Physics, 2012), they said 

that at the institutional 

level, methods used to 

enroll workers in the 

bioassay program have not 

been adequate to ensure 

that workers are monitored 

for correct isotopes and at 

the required frequencies. 

Question about NIOSH’s 

programmatic argument.

Transcript from the 

Board meeting of 

May 14, 2012, PDF 

pp. 244-246

(ABRWH, 2012c) 

May 14, 

2012

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

Concern regarding the effectiveness of the 

methods used to enroll workers in the 

appropriate bioassay programs was raised 

by SC&A in their review of the LANL ER 

Addendum (SC&A, 2017). This was one 

of the issues identified in the 

noncompliance report NC ID 484 (Nonconformance, 1999). 

51 At what point do you 

establish that the hole is too 

big and it seems you are not 

looking for these (exotic) 

radionuclides to begin with. 

If you are not looking for 

them, how do you establish 

a dose?

Transcript from the 

Board meeting of 

May 14, 2012, PDF 

pp. 249-252

(ABRWH, 2012c) 

May 14, 

2012

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

NIOSH concurred with this issue in 

SEC-00109 ER, Rev. 1 (NIOSH, 2012), 

when it recommended an SEC class 

through 1995. In the SEC-00109 ER 

Addendum (NIOSH, 2017), NIOSH 

concluded that unmonitored workers were 

unlikely to have received intakes from 

exotic radionuclides that would have 

resulted in 100 mrem CEDE.

52 Re the response doc: How 

is the co-worker model 

going to fly for the firing 

sites when the model deals 

with glovebox workers and 

the firing sites are open 

areas with resuspension 

issues? 

Transcript from the 

Board meeting of 

May 14, 2012, PDF 

pp. 286-292

(ABRWH, 2012c) 

May 14, 

2012

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

The co-worker models were derived from 

bioassay results from all monitored workers 

at LANL, not just glovebox workers.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 59 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

53 More discussion of Cerro 

Grande.

Transcript from the 

Board meeting of 

May 14, 2012, PDF 

pp. 293-297

(ABRWH, 2012c) 

May 14, 

2012

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

See response to Issue 22.

54 No issues discussed by 

petitioner during this 

meeting.

Transcript from the 

Board meeting of 

Sept. 11, 2012

(ABRWH, 2012a)

Sept. 11, 

2012

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

No issue, no resolution.
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 60 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

55 Concern about spallation 

products from the 

accelerator.

Transcript from the 

Board meeting of 

Aug. 15, 2017, PDF 

p. 87 (ABRWH, 

2017)

Aug. 15, 

2017

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

A 1975 assessment identifies spallation

products in LAMPF waste water (LAMPF, 

1975). It lists C-10, O-14, O-15, N-13, 

C-11, Be-7, and H-3 as spallation products. 

A 1983 memo discusses public doses from 

LAMPF (LAMPF, 1983). C-11, N-13, and 

O-15 are identified as the major dose 

contributors. 

A health protection quarterly progress 

report for Q1 1988 summarizes the 1987 

Area A stack releases (LANL, 1988), as 

follows:

The total quantity of gaseous radioactivity 

released to the atmosphere from the Area A 

stack during the 1987 operating period was

150,000 Curies. The composition of this 

gaseous effluent was as follows:

In addition, approximately 13 Curies of 

tritium [H-3] as water vapor was released 

in 1987.

(continued on next page)
Response Paper NIOSH Response to SC&A’s Review of the SEC-00109 LANL Addendum,

with Revised References Section and Appendix

October 23, 2018

Page 61 of 61

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Issue Petitioner Issue Forum Date Supporting Document(s) Provided or 

Referenced by Petitioner Resolution

55 (continued) (continued) (continued) (continued) (continued)

For dose reconstruction purposes, NIOSH 

has numerous bioassay results for 

LANSCE that include assay for Be-7, 

C-11/N-13, and several other activation 

products (as shown in Table 4-1 in this 

white paper).

Given the short half-lives of the spallation 

products (listed above), NIOSH considers 

that these products were unlikely to have 

been significant contributors to worker 

doses.

56 Question about Np. Was it 

only in TA-55 or were there 

other areas? If so, was 100 

grams the maximum?

Transcript from the 

Board meeting of 

Aug. 15, 2017, PDF 

p. 87 (ABRWH, 

2017)

Aug. 15, 

2017

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

The neptunium issue was addressed in the 

SEC-0009 Addendum (NIOSH, 2017). 

This specific issue was also raised by 

SC&A in their Review of SEC Petition 

Evaluation Report Addendum (SEC-00109) 

for Los Alamos National Laboratory

(SC&A, 2017).

57 The catalog for the in vivo 

measurements is very 

limited or non-existent so 

you don’t have the ability 

to determine if someone 

was exposed to an exotic as 

opposed to a common 

ROC.

Transcript from the 

Board meeting of 

Aug. 15, 2017, PDF 

p. 88 (ABRWH, 

2017)

Aug. 15, 

2017

No additional supporting documents were 

specifically provided or referenced in the cited 

Forum.

Post-1995, LANL has maintained the 

technical capability to identify specific 

radionuclides in bioassay analyses for 

monitored workers. In the SEC-00109 ER 

Addendum (NIOSH, 2017), NIOSH 

concluded that unmonitored workers were 

unlikely to have received intakes from 

exotic radionuclides that would have 

resulted in 100 mrem CEDE.