REVIEW AND CRITIQUE OF THE DRAFT NIOSH SITE PROFILE 

DOCUMENT FOR LOS ALAMOS NATIONAL LABORATORY 

Submitted to the NIOSH Office of Compensation, Analysis and Support 

September 19, 2005 

Ken Silver, D.Sc., S.M. 

Assistant Professor of Environmental Health 

East Tennessee State University 

Johnson City, TN 37614 

silver@etsu.edu
TABLE OF CONTENTS 

Executive Summary i 

Introduction 1 

 SEC 2 

 Other workers 2 

Dose Reconstruction 3 

 Background 4 

 The Site Profile Process 5 

 Access to Information at LANL 5 

 Information Access for EEOICPA Claims 8 

Four Key Issues 10 

Section 1. Completeness and Fidelity of the Site Profiler’s Retrieval and Use of

Information Already in the Public Domain 11 

 Relationship to the LAHDRA Project 11 

 Omissions and Errors 11 

 Monthly Health Division Progress Reports After 1960 are Publicly Available 11 

 Post-1964 Ambiguity 14 

 1991 DOE Tiger Team Report Not Considered 15 

 Universe of Citable Sources 15 

 “Is” versus “Ought” 16 

 Role of Quality Programs 17 

 Technical Issues 18 

 1. Radiation Dosimetry: CAM Alarms 18 

 TA-55 Glove Box 18 

 TA-50 Paint Crew 20 

 2. Internal Dosimetry: Bioassay Program 21 

 3. Variation in Health Physics Programs 23 

 Standard Operating Procedures 24 

 4. Other Tiger Team Findings 25 

 Workers’ Recollections 26 

Other Important Publicly Available Documents Not Cited in Site Profile 27 

 Nyhan Report 27 

 History Associates “...Guide to Record Series...” 28 

 “Human Radiation Experiments: The Department of Energy...” 29 

 Apparent Inconsistencies Between Sections of the Site Profile 29 
 CMR Hot Cells 29 

 “...OWR Facility is not a source of radioiodine” 30 

Section 2. LANL’s Furnishing of Access to Information Not Yet in the Public 31 

Domain 

 Incidents, Accidents and Occurrences 31 

 Background 31 

 Analysis of Selected Years 32 

 Occurrences in Other Years 34 

 Use of Occurrence Reports in Dose Reconstruction 35 

 Conclusions 36 

 Addenda 36 

Occurrences Reports Can Supplement Bioassay Data 36 

Beyond Occurrence Reports: RCT Log Books 37 

Section 3. Ability of Worker and Community Organizations to Independently Evaluate 

How Primary Sources of Information Have Been Analyzed and Interpreted in the Site 

Profile Document 39 

 Introduction 40 

 Analysis of the Accessibility of Information Sources Cited in the Site Profile 40 

 Methods 40 

Results 41 

 Example: Population Dose 42 

 Caveats 43 

 Conclusions 44 

Conclusions 45 

References 50 

Tables

Figures

Appendices

A. Transfer request form 

B. Monitoring sheet for Room 401 hot cells at DP West, July 1969 

C. Surrogate Incident Report (LA POWS) 

D. Recommended Formatting Changes 

E. Author’s Biosketch 
i

EXECUTIVE SUMMARY 

Introduction 

 The Energy Employees Occupational Illness Compensation Program Act 

(EEOICPA) is a federal entitlement program with two sets of claims criteria for 

radiation-related cancer. One set of criteria applies to members of the Special Exposure 

Cohort (SEC). All other claims for radiation-related cancer are subject to the highly 

detailed scientific methodologies of dose reconstruction and the probability of causation. 

 

Gaseous diffusion plant workers and workers on three underground nuclear tests 

in Alaska prior to 1974 were written into the SEC in the original EEOICPA law. The 

current status of petitions to add new groups of workers to the SEC is summarized in 

Table 1. 

Dose Reconstruction 

 To carry out its duties to perform dose reconstruction, NIOSH has contracted with 

Oak Ridge Associated Universities (ORAU) for the services of health physicists. A 

series of guidance documents, called “site profiles,” is being prepared. Each site profile 

is intended to describe the technical details of how radiation doses were measured at 

DOE sites where claims are undergoing dose reconstruction. 

 The site profile document owes its existence to EEOICPA which, in turn, resulted 

from a sociopolitical process. Previously, many occupational health concerns at LANL 

were muted by the DOE-LANL “culture of secrecy.” EEOICPA passed in 2000 with 

New Mexico political leaders at the helm. 

 Individual workers, government agencies and researchers with legitimate claims 

to exposure- and health-related information have long encountered resistance from 

LANL. “Frontstage” explanations for information access restrictions at LANL generally 

involve national security concerns. Lab managers’ “backstage” concerns, documented in 

internal memoranda, have included avoidance of lawsuits and public embarrassment. 

Four Key Issues 

This EEOICPA context for the use of pertinent information in dose reconstruction 

and claims adjudication raises the following issues for the site profile process: 

1. Completeness and fidelity of the site profiler’s retrieval and use of information 

already in the public domain 

2. LANL’s furnishing of access to information not yet in the public domain 

3. Ability of worker and community organizations to independently evaluate how 

cited sources of information have been analyzed and interpreted in the site profile 

document 

4. Verification and assurance for individual claimants that no pertinent sources of 

information have been overlooked in performing dose reconstructions, as a matter 

of fairness 
ii

This report analyzes the site profile document in the light of the first three issues. 

Issue #4 can best be addressed by comparing the administrative records of dose 

reconstructions in rejected claims to pertinent information available elsewhere. As this 

report was being finalized, the release of the administrative record for such a claim was 

pending. (It was under review by the NIOSH FOIA Office). Thus, this author intends to 

address Issue #4 outside the scope of this report. 

Section 1. Completeness and fidelity of the site profiler’s retrieval and use of 

information already in the public domain 

The site profile document incorrectly states that H-Division Monthly Progress 

Reports are not available after October 1960. On the contrary, numerous such reports 

have been in the public domain for more than a decade. Ambiguity exists as to whether 

H-Division Monthly Progress Reports were issued after 1964. The possibility of a 

“curious hiatus” in public availability of reports during the late 1960’s and 1970’s, due to 

secrecy or environmentally provocative information, merits consideration. Monthly or 

quarterly reports were issued by LANL group H-1 throughout the 1960’s and 1970’s. 

Transfer request (TR) forms indicate the contents of some monthly reports in the 1960’s 

include “Secret” material or “Conf. R.D.” (confidential research and development). 

The site profile document willfully fails to consider the landmark Tiger Team 

Report on LANL (1991). A large proportion of the cited sources in the site profile 

document are technical reports issued by LANL. The technical reports emphasize 

recommended procedures for measuring doses. By willfully ignoring the Tiger Team 

report, the site profile document has, quite dangerously, repackaged the “ought” of 

LANL technical reports into a purported profile of what “is” (or was). 

Failure to consider the Tiger Team report and other critical depictions of worker 

health and safety at LANL leads to idealized presentations of several technical issues in 

the site profile document. These issues include: radiation doses resulting from numerous 

problems with continuous air monitoring (CAM) alarms; serious deficiencies with the 

bioassay program for internal dosimetry; and variation in health physics programs 

among groups at LANL. Several additional issues cited by the Tiger Team report are 

listed on pages 25-6 of this report but not discussed in depth here due to resource 

limitations. 

At the June 18 meeting in Espanola, the issue of censoring of radiation badge data 

was raised at least three times. Specific events were described. In a subsequent 

interview, a glove box worker described the widespread practice of wearing dosimetry 

badges underneath a lead apron. 

The site profile document does not cite several other important publicly available 

documents. Apparent inconsistencies between sections of the site profile document are 

noted. 
iii

Section 2. LANL’s Furnishing of Access to Information Not Yet in the Public 

Domain 

 Two tables (2-4 and 5-22) in the site profile document list incidents that resulted 

in worker exposure to radiation. However, NIOSH and ORAU do not appear to have yet 

made comprehensive use of a voluminous Occurrence Reports Collection (ORC) located 

at TA-35 under the custodianship of John Voltin and William Inkret. 

 Based on this author’s first-hand experience in the ORC at TA-35, it is apparent 

that Tables 2-4 and 5-22 of the site profile document do not take account of numerous 

worker contamination episodes. A lower bound estimate of 64 net additional occurrences 

involving worker radiation contamination is derived for the years 1970-1980, 1985 and 

1990 alone (Table 2), using this author’s research notes taken when he had access to the 

ORC at TA-35 from 1996 to 1998. Extrapolation of this lower bound estimate to the 

entire period of 1944 to 1991 translates into more than 230 occurrences involving worker 

radiation contamination for which documentation would be available if NIOSH and 

ORAU were to thoroughly utilize the ORC at TA-35. Illustrative examples of incidents 

documented in this collection but not included in the site profile document are listed in 

Table 3. In addition, Table 4 presents a similar list for years other than the 13 years noted 

above, drawing upon multiple sources including the LAHDRA repository at UNM’s 

Zimmerman Library and the files of the Joint Committee on Atomic Energy in 

Washington, D.C.. 

 It cannot be assumed that occurrence reports were added to the medical records of 

individual workers. A comprehensive search and retrieval of the ORC at TA-35 should 

be performed by NIOSH and ORAU. Occurrence reports could be used to improve 

EEOICPA dose reconstructions in several ways. A truly “claimant friendly” dose 

reconstruction process would leave no stone unturned in locating documentation of such 

incidents. The ORC at TA-35 also holds the potential for a portion of LANL dose 

reconstructions to be based on primary documentation. Use of primary documentation 

could serve as a quality check on dose reconstructions performed with internal dosimetry 

data which, according to Chapter 5 of the site profile document, LANL has provided in a 

piecemeal fashion, and only after long delays and re-formatting. 

Participants in the June 18 meeting in Espanola, and in subsequent discussions, 

emphasized the vitally important information contained in another record series: the 

daily log books of RCTs. 

Section 3. Ability of worker and community organizations to independently evaluate

how cited sources of information have been analyzed and interpreted in the site 

profile document 

 Access to the complete docket of agency criteria documents, memoranda, and 

technical reports is the sine qua non of good public interest science. To evaluate whether 

the NIOSH site profile process at LANL is amenable to a public interest science 

approach, the public availability of all 254 sources cited in the site profile document was 

analyzed. At LANL the public computer terminals were used to search the following 
iv

online sources to determine the public availability of cited sources in the site profile 

document: 

1. LANL Library’s online catalogue (http://library.lanl.gov/) 

2. Energy Citations Database (http://www.osti.gov/energycitations/) 

3. DOE’s Opennet database (https://www.osti.gov/opennet/) 

4. CDC-ChemRisk LAHDRA database 

(http://www2.cdc.gov/nceh/radiation/LANL/default.htm) 

Seventy-eight (30.7%) of the 254 cited sources in the site profile are not available 

to the public using the open literature, ECDB, Opennet, or CDC-ChemRisk. For the 

17.7% of documents which are available in the LAHDRA repository at UNM 

Zimmerman Library, photocopying charges and travel costs are entailed. Similarly, 

NTIS’s page and shipping costs for the 6.3% of documents not available elsewhere are 

non-trivial. Thus, in effect, one-third to one-half (i.e., 30.7% + 17.7% + 6.3% = 54.7%) 

of the basis for the NIOSH site profile document cannot be scrutinized using a public 

interest science approach. 

 One of the cited sources, an internal LANL document that is not publicly 

available, sharply contradicts the official public record of workers’ collective doses at 

LANL established by the annual report series “Radiation Exposures for DOE and DOE 

Contractor Employees.” The numbers reported by the site profile do not agree with 

DOE’s annual report for either the total number of persons monitored (which includes 

visitors) or the number of UC plus Zia employees monitored. The population dose 

(person-rems) in the site profile is systematically lower than the population dose reported 

in DOE’s annual report for UC plus Zia employees. 

Conclusions 

 The “ought” of LANL technical reports and standard operating procedures has 

been repackaged for NIOSH into a purported profile of what “is” (or was). A desultory 

approach to utilizing the Occurrence Reports Collection at TA-35 is unconscionable in 

light of the large number of contamination incidents documented in the collection. 

Especially grievous are newly proffered but never published retrospective 

numbers from LANL for the total persons monitored and population dose (person-rems) 

which differ markedly from the official public record. This reinforces an impression 

gained by some workers over the course of their careers at LANL that “the books are 

cooked.” 

 Little has changed for LANL workers and families, despite passage of EEOICPA. 

The Lab’s “official line” continues to prevail. “Cold war heroes” have been told 

repeatedly that the information needed to reconstruct their radiation doses will soon be 

forthcoming. Meanwhile, claimants are dying. At the beginning of the twenty-first 

century a federal public health agency should not be providing the kind of leadership 

which leaves citizens thinking that inexorable death is the likeliest outcome. 
v

The term “investigatory surrender” is coined as an analogy to “regulatory 

capture.” In its current form, the site profile document represents investigatory surrender 

because it is captive to the Lab’s idealized version of “ought”; an audience of Lab 

managers will be assuaged that recommended dosimetry procedures were routinely 

followed. 

 A series of questions is posed to focus NIOSH actions at LANL. Interminable, 

obsequious investigation is a roadblock to fulfilling the objectives of EEOICPA for 

LANL workers and families. 
1

INTRODUCTION

 The Energy Employees Occupational Illness Compensation Program Act 

(EEOICPA) is a federal entitlement program intended to provide “efficient, uniform and 

adequate” compensation for occupational illnesses incurred by workers in government 

owned, contractor operated (GOCO) nuclear weapons plants and research facilities. 1

The word “entitlement” does not mean that all GOCO employees unconditionally receive 

payments. Rather, it denotes the direct spending mechanism adopted by Congress when 

EEOICPA was passed and signed into law in October 2000.2, 3 Funds for “entitlement” 

programs are set aside in special trust funds, managed by the U.S. Department of 

Treasury, so as to avoid the risky situation of payments to eligible beneficiaries hinging 

on Congressional appropriations annually (which posed problems for uranium miners and 

“downwinders” seeking compensation under the Radiation Exposure Compensation Act 

[RECA] in the 1990’s). Colloquially, “entitlements” exist for those who not capable of 

“self-reliance,” such as the elderly, infirm, disabled, etc.. Another example of an 

occupational illness compensation program paid for with “entitlement” spending is the 

federal program which provides benefits for coal miners suffering from black lung, 

enacted in 1977.

Every entitlement program has claims criteria. U.S. Department of Labor 

regulations under EEOICPA repeatedly use the terms “determination of entitlement”4

 and 

“claims for entitlement.”5

 EEOICPA’s criteria depend upon the specific illness claimed. 

If radiation-related cancer is claimed, then there are two sets of criteria which apply. One 

set of criteria applies to members of the special exposure cohort (SEC), or their survivors, 

who have filed a claim for any of 22 kinds of specified cancer. All other claims for 
2

radiation-related cancer are subject to the second set of criteria which are based upon the 

highly detailed scientific methodologies of dose reconstruction and the probability of 

causation.

SEC. In the legislative debates which led to EEOICPA’s passage, the labor union 

(PACE) which represents workers at the three gaseous diffusion plants (Paducah, 

Portsmouth, Oak Ridge) presented extensive evidence of how the federal government and 

contractors intentionally withheld from workers information about exposure to energetic 

internal emitters such as NP237 and Pu239 and failed to measure internal doses until the 

late 1980’s.6, 7 The Washington Post gave the story wide coverage. 8, 9 As a result, 

gaseous diffusion plant (GDP) workers were written into the original EEOICPA law 

passed in 2000 as the first members of the SEC. Also, workers on three underground 

nuclear tests on Amchitka Island, Alaska prior to 1974 were written into the SEC. 

 The law created a petition process for adding more groups of workers to the SEC 

if “it is not feasible to estimate with sufficient accuracy the radiation dose they received.” 

1

 On December 11, 2000 President Clinton issued Executive Order 13179 which directed 

NIOSH to develop regulations for a petition process by which groups of workers can be 

added to the SEC.10 NIOSH issued these regulations in final form in May 2002.11 The 

law also specified that the Advisory Board on Radiation and Worker Health will “advise” 

the President and make recommendations in response to petitions, in addition to advising 

NIOSH on dose reconstruction procedures. Groups of workers already in, or petitioning 

for inclusion in, the SEC are summarized in Table 1. 

Other Workers. Claims for radiation-related cancer in workers who are not members of 

the SEC, or SEC members with a non-listed cancer, must undergo a two-step process of: 
3

1. dose reconstruction 

2. probability of causation determination 

to receive EEOICPA entitlement benefits. The reconstructed dose is inputted to the 

“IREP” model (Interactive Radioepidemiological Program). For 33 kinds of cancer IREP 

calculates the percent probability that a given dose of radiation caused the cancer.

Because there is a great deal of uncertainty in such a calculation, IREP also provides an 

“error bar” (or “confidence interval”) around the calculated probability of causation. 

Congress specified in EEOICPA that the upper 99% confidence internal around the 

probability of causation would be used. This was intended to be “claimant friendly,” 

resulting in more decisions to award compensation than if the probability of causation 

were used.

Senator Jeff Bingaman explained in the Congressional Record: 

For example, for a given worker with a particular cancer and radiation exposure 

history, the PC may be 0.38 with 99% confidence interval of 0.21 to 0.55. This 

means that it is 38% likely that this worker’s cancer was caused by this radiation 

dose, and we can say with 99% confidence that this estimate is between 21% and 

55%. Since the upper bound, 55%, is greater than 50%, this person’s cancer 

would be considered to be at least as likely as not to have been caused by 

exposure to radiation, and the person would be eligible for benefits... 12

A minor point of clarification to Senator Bingaman’s remarks is in order: compensation 

is awarded if the upper bound is equal to or greater than 50%. 

DOSE RECONSTRUCTION 

 The remainder of this report focuses on dose reconstruction, a key criterion used 

to determine the eligibility of radiation-related cancer claimants for EEOICPA 

entitlement benefits. 
4

Background. To carry out its duties to perform dose reconstruction, NIOSH has 

contracted with Oak Ridge Associated Universities (ORAU) for the services of health 

physicists. A series of guidance documents, called “site profiles,” is being prepared. 

Each site profile is intended to describe the technical details of how radiation doses were 

measured at DOE sites where claims are undergoing dose reconstruction. The standard 

site profile format consists of six chapters:

1. Introduction 

2. Site Description 

3. Occupational Medical Dose (i.e., x-rays by medical staff) 

4. Occupational Environmental Dose (i.e., ambient exposures on-site) 

5. Occupational Internal Dose 

6. Occupational External Dose 

 An ORAU-affiliated health physicist assigned to reconstruct a worker’s dose will 

refer to the site profile(s) for the site(s) where the worker was exposed to radiation. The 

site profile will give health physicists (hereinafter “dose reconstructionists”) insight into 

monitoring methods, record-keeping procedures, facility operations, etc.. Conflict of 

interest rules limit the degree to which a dose reconstructionist may work on DOE sites 

where s/he has had a financial or employment relationship with the contractor. So the 

site profiles will serve as a principal source of information for dose reconstructionists 

who have not previously performed extensive work at that DOE site. 

 Pursuant to EEOICPA and Executive Order 13179 the ABRWH has a prominent 

role in overseeing the dose reconstruction activities of NIOSH and, by extension, ORAU 

and its affiliated dose reconstructionists. The Board has engaged the services of a 
5

scientific consulting firm (Sanford Cohen & Associates) to audit selected dose 

reconstructions and review key work products, including site profiles. 

The Site Profile Process 

It is important to distinguish between process and content. The site profile 

document owes its existence to EEOICPA which, in turn, resulted from a sociopolitical 

process. Many LANL families’ occupational health concerns were first brought to the 

attention of high level government officials and the general public in meetings held in 

late 1999 and early 2000.13, 14 Previously, many of these concerns were muted by the 

DOE-LANL “culture of secrecy.” EEOICPA passed in October 2000 with Senator Jeff 

Bingaman as the lead sponsor and former northern New Mexico Congressman Bill 

Richardson (then Energy Secretary, now Governor) as the principal proponent. Public 

participation soon shifted to the DOL claims process and to the formal federal advisory 

committee process in which the ABRWH operates.

15 EEOICPA issues have also been 

aired in recent sessions of the New Mexico state legislature. 16

Access to Information at LANL. Access to information about exposures is a 

fundamental process issue, one which is never far from discussions of LANL 

occupational and environmental health concerns among New Mexicans. Access to 

information sets the parameters of any fact-based discussion of LANL health issues.

Individual workers, government agencies and researchers with legitimate claims to 

exposure- and health-related information have long encountered resistance from LANL. 

x In the 1970’s the attorney representing William Van Buskirk in a state workers’ 

compensation claim for berylliosis had to resort to a subpoena delivered to LANL 
6

by the Bernalillo County sheriff in order to obtain his client’s chest x-rays from 

the Lab.14

x In the mid-1990’s the widow of a LANL radiation worker who had died of 

leukemia complained to the state health department that the Lab was claiming that 

her husband’s medical records were “classified.”17

x A steamfitter who volunteered to clean up after the criticality accident which 

killed Cecil Kelley in 1959 was dismayed to find no documentation of this 

incident, or several other very “hot” jobs he performed over the course of his 40 

year career at LANL, when he sought his official medical records upon 

retirement. (Meeting Transcript, pp. 21-2) 

x In 2002 the adult children of a machinist who had died of a progressive lung 

disease prior to 1993 found it necessary to apply considerable pressure through 

the formal appeals process of the Espanola Resource Center in order to obtain 

complete medical records from LANL. This tactic made the difference between 

initial denial of their EEOICPA Subtitle B claim for CBD and the ultimate award 

on appeal – but only after the complete medical file was in-hand.18

x To this day, despite repeated requests made since the passage of EEOICPA, a 

former LANL plutonium glove box worker has been unable to obtain his finger 

ring dosimetry data. A supervisory lab scientist confirmed that the 

documentation does exist.19

Workers and families are not alone. Government agencies and researchers have 

also encountered marked resistance from LANL in attempting to access relevant health 

and environmental data. LANL information management practices and policies have 
7

stymied the New Mexico Attorney General’s office20 highly qualified academicians 

carrying out research with grants from NIOSH,21 and others.22 The LANL Archives 

spurned efforts in the mid-1990’s by the DOE headquarters history staff to make public a 

finding aid to the archives. The federal Centers for Disease Control’s Los Alamos 

Historical Documents and Assessment (LAHDRA) project, the most comprehensive and 

highly sanctioned effort ever to retrieve documentation pertinent to radiation exposures at 

LANL, encountered no less than 20 obstacles to accessing information at the Lab.23, 24

In 2004, a Congressionally mandated report issued by NIOSH found LANL to be 

among a handful of DOE sites “not consistently providing adequate responses to data 

requests for dose reconstruction.”25

 Environmental sociologists distinguish between the “backstage” and “frontstage” 

behavior of institutions.26 Frontstage behavior is intended for public view. Institutional 

actors portray the polluting facility in the best light possible. Backstage behavior consists 

of candid internal deliberations by managers and workers. This distinction is helpful in 

analyzing LANL information policies. “Frontstage” explanations for information access 

restrictions at LANL generally involve national security concerns.24 Less frequently 

cited in public are concerns over whether certain records are “owned” by the contractor 

or by the DOE.27 For example, a former worker at the June 18, 2005 meeting in Espanola 

organized by ATL recounted how records documenting the contents of waste barrels 

from DP West, buried at Area G, are maintained by a consulting firm (Benchmark). 

When asked to provide access to the records, the firm replied that are “owned by the 

Lab” (Meeting Transcript, p. 15). Another ground cited by LANL for limiting access to 
8

records is the lack of specific funding (or “cost code”) to pay for staff members’ time in 

assisting outside researchers. 

 Occasionally, official memoranda become publicly available which describe the 

“backstage” concerns of Lab management over public access to information. In 1946 Dr. 

J. Robert Oppenheimer instructed subordinates to create special security classification for 

any health-related information; one of the subordinates wrote that its purpose was to 

“safeguard the project against being sued by people claiming to have been damaged.” 

Two years later AEC officials balked at disseminating to affected Los Alamos chemists 

the results of an occupational health study which showed hematological abnormalities 

after handling radiolanthanum and related fission products.28 How long a special security 

classification for health information remained in existence de jure at the Lab is difficult 

to ascertain, but its de facto influence appears to have been long-lasting. More recently, 

waste managers at LANL issued memoranda admonishing workers to maintain tight 

control of documents which might cause the Lab public embarrassment. These memos 

invoke the terms “sensitive” and “official use only” to justify restricting public 

dissemination of waste-related information. National security is not cited.29, 30

 Perhaps the most detailed glimpse into the “backstage” concerns of Lab managers 

is provided in a series of depositions obtained in the discovery phase of a tort lawsuit 

(brain cancer in the community) against LANL in the early 1990’s. The details are 

beyond the scope of this report. 

Information Access for EEOICPA Claims. Under EEOICPA and implementing 

regulations, claimants are not required to gather information on past exposures. Rather, 
9

NIOSH is supposed to obtain the information needed for dose reconstruction from DOE 

and its contractors. An individual claimant may request copies of the documents (the 

“administrative record”) used in the dose reconstruction. Claimants may also provide 

supplemental information. Due in part to long-standing restrictive information practices 

and policies at LANL, few individual claimants are likely to have relevant documentation 

in their personal possession. However, worker and community-based organizations, such 

as the Los Alamos Project for Worker Safety and El Rio Arriba Environmental Health 

Association, have used their extensive collections of documents and familiarity with 

public collections (e.g., reading rooms, online data bases, etc.) to provide technical 

assistance to claimants.31, 32
10

FOUR KEY ISSUES 

 This EEOICPA context for the use of pertinent information in dose reconstruction 

and claims adjudication raises the following issues for the site profile process: 

1. Completeness and fidelity of the site profiler’s retrieval and use of information 

already in the public domain 

2. LANL’s furnishing of access to information not yet in the public domain 

3. Ability of worker and community organizations to independently evaluate how 

cited sources of information have been analyzed and interpreted in the site profile 

document 

4. Verification and assurance for individual claimants that no pertinent sources of 

information have been overlooked in performing dose reconstructions, as a matter 

of fairness 

The site profile document is analyzed and discussed in the light of issues #1-3 in the 

following sections of this report. 

 Issue #4 can best be addressed by comparing the administrative records of dose 

reconstructions in rejected claims to other pertinent sources of information. As this 

report was being finalized, the release of the administrative record for such a claim was 

pending (under review by the NIOSH FOIA Office). This author hopes to address issue 

#4 outside the scope of this report.
11

Section 1. 

Completeness and Fidelity of the Site Profiler’s Retrieval and Use of Information 

Already in the Public Domain 

Relationship to the LAHDRA Project. The site profiler is well qualified to access 

publicly available information on historical exposures at LANL, having served on the 

technical team of the Los Alamos Historical Documents Retrieval and Assessment 

Project (LAHDRA). Although mainly focused on off-site environmental emissions, 

LAHDRA is the most comprehensive effort ever to retrieve documentation pertinent to 

radiation exposures at LANL. LAHDRA documents constitute one of the largest 

collections of publicly available information. The assets of LAHDRA are most evident 

in Chapter 2 of the site profile, a nearly comprehensive historical overview of LANL 

technical areas, activities and radionuclides. Chapter 4, “Occupational Environmental 

Dose,” also relies heavily on LAHDRA disclosures. 

Omissions and Errors. Noted below are two types of errors of omission in the site 

profile: 

x Omission of information already made publicly available by LAHDRA; and 

x Omission of other highly pertinent information that is already in the public 

domain. 

In addition, contradictory information presented within different sections of the site 

profile is noted. 

Monthly Health Division Progress Reports After 1960 are Publicly Available

 The following statement appears on page 48 of Chapter 2 of the site profile 

document: 
12

“The Health Group (later Division) produced over 150 Progress Reports. The 

reports were produced on a monthly basis; - the oldest is dated November 1943, 

and the most recent report was published in October 1960.” 

The date of October 1960 as the “most recent” H-Division Progress Report is highly 

erroneous.

 This is a very serious error. At any DOE site, the progress reports of healthrelated groups provide a narrative account of the principal problems and exposures with 

which health physicists, industrial hygienists and other occupational and environmental 

health specialists were grappling.33 Mention of a problem or exposure in these narrative 

reports is a clue to the existence of further documentation, such as monitoring data and 

occurrence reports.

 LAHDRA’s most recent report affirms the value of H-Division Monthly Progress 

reports (pp. 16-17) and confirms the availability of monthly issues after 1960. (The site 

profiler’s photo appears on page 18).23 Monthly issues in this report series after 1960 are 

publicly available from several sources. Indeed, some have been in the public domain for 

more than a decade. 

a. LAHDRA Collection. A simple search of CDC’s online data base yields 38 

monthly and one quarterly H-Division Progress Reports issued after 1960. The latest 

monthly report is September 1964; the quarterly is from the fourth quarter of 1969. 

b. Human Studies Project Team (HSPT) Notebooks. The 31 volumes of historical 

documents pertaining to human radiation experiments, which were released to the public 

by LANL in 1994, contain numerous H-Division Monthly Progress reports after 1960.

Indeed, the monthly issues released by LAHDRA (“a,” above) closely match the 
13

monthly issues released by the HSPT. Neither source contains the following monthly 

issues:

(for the month ending) 

October 1963 

February 1964 

April 1964 

June 1964 

October 1964 

November 1964 

December 1964 

The occupational and environmental health significance of these omissions may include 

exposure to fission products present in large quantities in spent fuel elements from the 

Rover nuclear rocket program which were handled in the hot cells at CMR Building (TA3) in this time frame. Other documentation made available by LAHDRA evinces concern 

among Health Division personnel about I-132 in June 1964. Moreover, spent fuel from 

the Kiwi NRX rocket test would have reached CMR Building in about October 1964. 

c. Opennet. Selected H-Division Monthly Progress Reports for the time period of 

1961-1963 have long been publicly available from the DOE’s Opennet data base. 

Additional monthly issues may be stored in hard copy format at DOE’s Coordination and 

Information Center in North Las Vegas, Nevada,34 based on this author’s (K.S.) prior 

experience using this repository. 

d. Advisory Committee on Human Radiation Experiments (ACHRE). In the fall of 

1994, this author (K.S.) photocopied LANL H-Division Monthly Progress Reports in the 

public documents room of ACHRE, a presidential advisory committee, in Washington, 

D.C.. A compilation of excerpts from these reports -- which was widely distributed to 
14

citizens, tribal governments, and organizations in northern New Mexico in November 

1994 -- contained numerous entries from monthly reports after 1960. 

 ACHRE’s charter has lapsed, but a finding aid to its documents is maintained 

online by the National Security Archive at George Washington University 

(http://www.gwu.edu/~nsarchiv/radiation/). ACHRE’s document collection was 

transmitted to the National Archives, a federal agency. 

Post-1964 Ambiguity. Ambiguity exists as to whether H-Division Monthly Progress 

Reports were issued after 1964. LAHDRA’s most recent report asserts this series was 

“discontinued in September 1964 in favor of quarterly reports,” yet also states that there 

are “some additional reports issued in the early 1980’s.” To further complicate the 

picture, at a November 2001 public meeting, a project member cited a Lab memo which 

admits the issuance of H-Division Monthly Progress Reports as late as 1967.

The possibility of a “curious hiatus” in public availability of reports during the 

late 1960’s and 1970’s, due to secrecy or environmentally provocative information, 

merits consideration. 

 Former LANL workers verbally dispute the assertion that the monthly reports 

ceased in 1964; however none have furnished documentary evidence to support their 

position. One possible explanation is that the division-level report ceased, but grouplevel reports continued. As shown in Appendix A of this report it is quite clear that 

“Monthly Progress Reports” were issued by LANL group H-1, the “Health Physics” 

group after 1964. This is made plain by official “TR” forms (“transfer request”), used by 

LANL managers to designate long-term storage locations for records. A collection of 
15

transfer request forms detailing the locations of many historical health-related records 

was made publicly available in the LANL-UC Reading Room in Los Alamos in 1998. 

The site profile document does not explicitly cite “H-1 Monthly Progress 

Reports” in the late 1960’s or early 1970’s. The transfer request forms (Appendix A) 

indicate that the contents of some monthly reports in the 1960’s include “Secret” material 

or “Conf. R.D.” (confidential research and development). Group H-1 was the LANL unit 

with primary technical responsibility for controlling worker exposure to radiation. The 

failure of the site profile document to consider the “H-1 Monthly Progress Report” in the 

late 1960’s and early 1970’s series is a serious omission. The fact that monthly reports 

later than 1964 exist – at least those issued by group H-1 -- has been in the public domain 

since 1998.

Since February 1999 this author (K.S.) has been urging CDC and its LAHDRA 

contractor to make public as many H-Division Progress reports as possible.35, 36

1991 DOE Tiger Team Report Not Considered

 At the June 18, 2005 meeting in Espanola, New Mexico on the LANL site profile, 

organized by ATL International, the site profiler acknowledged that he owns (or has 

available at work) a copy of the 1991 DOE Tiger Team report on LANL. He made this 

statement in response to this author’s (K.S.) criticism that the site profile document did 

not cite the Tiger Team report. Former workers quoted directly from the Tiger Team 

report37 and submitted annotated excerpts into the formal record of the meeting. 

Universe of Citable Sources. This raises the question of “What process is used to define 

the universe of citable sources?” Clearly, the Tiger Team report was sanctioned at the 

highest levels of the U.S. Department of Energy. It was not issued by a fringe 
16

organization. The engineers and scientists on the Tiger Team were selected for their 

impressive credentials.38, 39 They were not a group of “Lab bashers.”

 Willful failure to include this landmark report in the universe of citable sources is 

so grievous that it raises questions about motive and intended audience for the site profile 

document. As described in Section 3 (below), a large proportion of the cited sources are 

technical reports issued by LANL, many of which are not readily available to the public.

Few of these LANL technical reports have been subjected to external review or 

independent criticism. These technical reports emphasize recommended procedures for 

measuring radiation doses. 

“Is” versus “Ought.” It is helpful to invoke the classic distinction between what “is”

and “ought” to be. It’s the difference between depiction and espousal. LANL technical 

reports and standard operating procedures describe how radiation doses “ought” to be 

measured. Recommended procedures are delineated. An institutional espousal that 

these procedures should be followed is plain. In contrast, the Tiger Team was the most 

systematic effort ever to depict what “is” (or was) the situation for worker and health and 

safety at LANL. 

 By willfully ignoring the Tiger Team report, the site profile document has, quite 

dangerously, repackaged the “ought” of LANL technical reports into a purported profile 

of what “is” (or was). An audience of lab technical managers reading the site profile 

document will be pleased to find no difference between their recommended technical 

procedures and past dosimetry practices. This legerdemain depends upon the exclusion 

of not just the Tiger Team report but all other external, critical depictions of what “is” (or 

was) the situation for worker health and safety at LANL. Moreover, the fact that many of 
17

the cited LANL technical reports are inaccessible (see Section 3) makes it impossible for 

citizens’ or workers’ organizations to mount an incisive challenge to management’s 

idealized picture of “ought,” which the site profile now proffers as reality. The worker’s 

depiction of what “is” (or was) the situation with radiation dosimetry at LANL gets 

shunted to a meeting or two. 

Role of Quality Programs. Organizations address the gap between “ought” and “is” by 

means of quality assurance and quality control programs. An internal auditing function is 

commonly used to provide assurance that written policies are actually being followed. 

 Deficiencies in quality assurance were among the principal shortcomings found at 

LANL by the Tiger Team. At the highest levels of the Lab, the Quality Operations 

Office (QOO) was found to suffer from an “organizational conflict of interest” (p. 5-16), 

due to its accountability to the same Associate Director as the divisions it audited. 

Further, the Tiger Team cited QOO’s inability to perform audits unless requested and 

funded by the organization to be audited (p. 4-262).

 Health and safety audits were found to be lacking in comprehensiveness and 

consistency (p. 4-774). Comprehensive records on occupational radiation exposures were 

not readily available (p. 4-190). The Tiger Team could find: 

“..no Health and Safety Division assurance that accurate monitoring of either 

external or internal exposures is accomplished using current procedures and 

policies or that DOE 5480.11 monitoring requirements are satisfied.” 

In sum, at the time of the Tiger Team report in 1991 -- and presumably in the years 

preceding – there was a large gap between the “ought” and “is” of worker protection at 

LANL. This gap was not well characterized by audits. 
18

Technical Issues. Failure to consider the Tiger Team report and other critical depictions 

of worker health and safety at LANL leads to idealized presentations of several technical 

issues in the site profile document. If left unchallenged, the site profile will lead dose 

reconstructionists to make assumptions which are not “claimant friendly.” More LANL 

claims will be denied than if the facts contained in the Tiger Team report and other 

critical sources had been incorporated into the site profile.

1. Radiation Dosimetry: CAM Alarms. Chapter 4 (“Internal Occupational Dose”) 

includes a discussion of continuous air monitor (CAM) alarms. Citing a report by LANL 

scientists, the site profile considers the issue of the suboptimal location of CAM alarms: 

 “When a worker causes the release and is at or near the release point, the worker 

could be exposed to intakes that did not trigger alarms ... [T]he possibility exists

that workers could be exposed to intakes that did not trigger alarms.” [emphasis 

added]

However, the site profile does not consider numerous other mechanisms cited by the 

Tiger Team which cast serious doubt on the efficacy of CAM alarms in protecting LANL 

workers. (See box, p. 20). In light of this litany of deficiencies recognized by the Tiger 

Team in 1991, the site profile’s conclusion that “the possibility exists” of worker 

exposure prior to a CAM alarm is quite weak. On the contrary, there is a strong 

likelihood that such overexposures occurred. 

 Two recent incidents illustrate the ongoing failure of CAM alarms to protect 

workers from internal emitters at LANL. Although both incidents are well-documented 

in publicly available, authoritative sources of information, neither is considered in the site 

profile document. 

TA-55 Glove Box. According to a March 2003 report by the DOE Inspector General, a 
19

Tiger Team Observations About CAM Alarms and Related Radiation Monitoring 

Devices at LANL 

“lack of LANL capability to calibrate and test high-range instruments used for emergency 

warning and evacuation” (p. 2-6) 

“Calibration and response checking of fixed instrument and tritium monitors does not 

reflect the same level of attention and commitment given to portable instrumentation.” (p. 

4-174)

“The check sources used to response check fixed instrumentation are disks of depleted 

uranium attached to each detector. The sources have not been characterized, are not 

documented, and emit at an unmeasured rate.” (p. 4-184) 

“There are no procedures to ensure that failed radiation protection equipment at 

accelerators are promptly removed from operation and evaluated to determine the impact 

of the failure.” (p. 4-185) 

“Fixed and portable radiation survey instruments are not calibrated annually or source 

checked in compliance with Los Alamos National Laboratory procedures and ANSI N 

323-1978...” (p. 4-185) 

“Tritium detectors in laboratories and on stack monitors are not source checked.” 

“With the exception of the WET Facility, documented studies of airflow in the workplace 

were not available to identify the airflow patterns and problem areas.” (p. 4-384) 

“Tritium air monitors do not have a uniform alarm setpoint, and no written justification 

was available for the alarm setpoints that were chosen.” (p. 4-384) 

“Tritium room air monitors were purchased at TA-41 Building 4 by operations personnel 

without support from calibrations staff or calibration and testing at the calibration 

facility.” (p. 4-390) 

“Facility monitor alarms points...are not always set at a uniform level. The setpoint may 

vary from monitor to monitor even in the same building.” (p. 4-394) 

“The setpoint on the tritium monitor at the IBF was reset by operations staff without 

ES&H review or approval.” (p. 4-463)
20

 contamination episode in February 2001 involving Pu-238 at TA-55 was worsened when 

the Lead Technician attempted to shut off the monitoring device which had initially 

warned of contamination: 

“The Lead Technician attempted to reset the monitoring device, but could not 

reach the reset button. The Lead Technician took a notebook with his 

contaminated hand, thereby spreading the contamination onto the notebook, and 

hit the reset switch. He handed the notebook back to another team member, 

whose hand then also became contaminated.” 40

It is noteworthy that members of the “team” handling plutonium at TA-55 assist each 

other in hitting the reset button when monitoring devices sound. Indeed, a former TA-55 

glove box worker who was last employed in 1996 confirms that operator intervention in 

resetting CAM alarms was commonplace, with the routine complicity of line managers.19

TA-50 Paint Crew. A March 3, 2005 incident is described in Energy Daily, one day 

after it was discussed at a May 5 Congressional hearing.41 Several construction trades 

workers received internal doses while cleaning up contaminated paint chips in a vault 

containing a leaking radioactive waste tank at TA-50. Contrary to standard operating 

procedures (what “ought” to happen) safety technicians failed to put a CAM into the 

vault. No alarm warned the workers of airborne dust contaminated with plutonium. 

 Clearly, problems with CAM alarms at LANL are long-standing and far more 

complex and serious than the site profile’s narrow discussion of suboptimal placement of 

devices would suggest. The issue of suboptimal placement alarms was studied by LANL 

scientists; the site profile dutifully discusses the issue. Many other issues involving the 

failure of CAM alarms have been identified by the Tiger Team, the DOE Inspector 

General, and the U.S. Congress. The site profile document completely ignores these 

sources of information. 
21

 In addition, at the June 18 meeting in Espanola organized by ATL International, a 

former worker at TA-54 (Area G) mentioned how monitoring devices called “sniffers” 

were turned off, thus avoiding detection of tritium (Meeting Transcript, p. 16). Further, a 

separate interview and follow-up discussions were held with a former lab services 

inspector, whose job entailed walking through numerous facilities like CMR Building. 

He remembers being told to turn off any hand and foot monitors that were alarming. The 

same instructions applied to CAM alarms that were sounding.19, 42

2. Internal Dosimetry: Bioassay Program

 The aforementioned section of the site profile document on the problem of 

suboptimal placement of CAM alarms continues: 

“However, after 1970 when the bioassay programs were well-established, the 

majority of workers with the potential for monitored and unmonitored intakes are 

expected to have participated in a bioassay program.” [emphasis added] 

Here again, the Tiger Team report tells a very different story. The Tiger Team’s review 

of LANL’s internal dosimetry program in 1991 is devastating. 

 DOE orders required contractors to identify workers for participation in a 

bioassay program. An Employee Health Physics Checklist (HS form 2-1A) was to be 

completed for each employee potentially exposed to radioactive materials. Radiation 

Protection Technicians were supposed to review work operations to evaluate who should 

participate in the bioassay program. 

 Instead, the Tiger team found a “low priority” was given to the requirement that 

radiation protection technicians review operations (p. 4-783). For example, at the firing 

sites (including TA-36 and TA-15) “LANL personnel are not evaluated for inclusion in 
22

the bioassay program” (p. 4-183). Furthermore: “Not all personnel at the plutonium and 

depleted uranium facilities are evaluated for participation in the bioassay program” (p. 4-

183). Similarly, despite an employee’s potential exposure to “substantial quantities of 

tritium contamination (i.e., oxide and organic bound)” at the Ion Beam Facility: “The 

facility does not provide proper controls and protection or require bioassay analyses for 

potentially exposed personnel” (p. 4-385). 

In sum, at the time of the Tiger Team report in 1991 LANL did not have an 

adequate internal dosimetry program for four of the major categories of exposed workers:

firing site workers, and workers potentially exposed to tritium, plutonium and depleted 

uranium. An underlying reason may have been that three separate organizations were 

involved in staffing the bioassay program, resulting in an effort that “lacks clear 

organization, defined responsibilities and authorities” (p. 4-783).

 Given this state of affairs, it is not surprising that refinements such as particle-size 

distribution and solubility studies had not been conducted for areas where workers were 

potentially exposed to airborne plutonium and uranium (p. 4-785). It is also unsurprising 

that documented procedures and administrative requirements for evaluating exposures to 

“unusual” radioactive materials were non-existent (p. 4-775). 

 Even when workers were properly enrolled in internal dosimetry programs line 

managers had “not accepted responsibility for conducting the chain-of-custody program” 

to ensure the integrity of bioassay samples against tampering, neglect and delay (p. 4-

388). This posed a threat to the chain-of-custody program because: 

“In several instances radiation protection technicians are not permanently located 

in the building where bioassay samples are to be left, making it difficult to 

conduct an effective program” (p. 4-388) 
23

And, although radiation protection technicians were trained in the chain-of-custody 

requirements “a few do not properly conduct the program.” The report gives actual 

examples of samples that had been misplaced for months, mislabeled, never sealed, 

and/or lacked complete paperwork (p. 4-388, 4-784). (Indeed, at the June 18, 2005 

meeting in Espanola organized by ATL International, a former worker described how 

urine samples sat for a month before being picked up for analysis [Meeting transcript, p. 

13]).

 Entirely consistent with these above deficiencies, the Tiger Team also found that 

the Lab did not have an internal audit program “to ensure quality radiochemistry 

measurements on bioassay samples” (p. 4-784). 

The site profile document’s contention that “bioassay programs were wellestablished” after 1970 and that “the majority of workers with the potential for monitored 

and unmonitored intakes are expected to have participated” is wishful thinking. It results 

from a willful failure to consult the Tiger Team report and amounts to a simplistic, 

idealized portrayal of the LANL bioassay program. 

3. Variation in Health Physics Programs

In an organization as large and complex as LANL, sweeping generalizations – 

such as the reliability of CAM alarms or the coverage of the bioassay program – are 

inherently suspect. Indeed, the Tiger Team noted marked variation in radiation 

protection programs among the various groups and divisions of the Lab: 

“Radiological protection programs vary considerably from group-to-group and 

division-to-division within the Laboratory, even though the requirements and 

conditions are similar” [p. 4-22]. 
24

Line managers’ review of radiation protection standards and practices within their groups 

was found to be “informal and inconsistent and is not in compliance with Chapter XVI of 

DOE 5480.19” [p. 4-176]. 

Standard Operating Procedures. The site profile’s reliance upon the Lab’s written 

Standard Operating Procedures is an obvious example of the blurring of the line between 

“is” and “ought.” Written SOPs are a technical community’s formal expression of how 

tasks “ought” to be performed. However, the reliability of the Lab’s written SOPs as a 

basis for historical dose reconstructions is cast in doubt by findings of the Tiger Team. 

Missing from the Lab’s internal audit program (required by a DOE order) was a system 

for: 

“... review of standard operating procedures for correctness, approval by Health 

and Safety Division, or to determine whether standard operating procedures are 

current” [p. 4-378]. 

Furthermore: 

“A few safety and radiation protection officers reported that they did not need to 

seek approval from the Health and Safety Division for changes in standard 

operating procedures, etc. In addition, they did not need to accept 

recommendations from Health and Safety Division.” [p. 4-376] 

Thus, written Lab SOPs which may appear to have been generally applicable were, in 

fact, subject to unilateral change by field technicians, with no systematic oversight or 

review.

 The ability of today’s EEOICPA dose reconstructionists to utilize Lab SOPs is 

further undermined by the fact that SOPs and radiation work permits were not included in 

the occupational exposure record system, a clear violation of ANSI Standard N13.6. The 

Tiger Team reported: 
25

“LANL standard operating procedures are not being routed to the Health Physics 

Policy and Programs Group for inclusion in occupational exposure records” [p. 4-

396]

Had such a system been followed, today’s dose reconstructionists might at least know 

where to begin in deciding whether a given Lab SOP is pertinent to a specific cancer 

claim. Data collected in interviews could then fill the gap between “ought” and “is” (or 

was).

In light of the above deficiencies identified by the Tiger Team in 1991, dose 

reconstructionists cannot assume that: 

x a written SOP didn’t simply undergo unilateral revision in the hands of a 

field technician; nor 

x the revised SOP was reviewed and approved by health physicists. 

Fundamentally, one cannot assume that SOPs which happen to be contemporaneous with 

the worker’s employment history actually describe how the radiation monitoring tasks 

were performed. 

4. Other Tiger Team Findings. The three volumes of the Tiger Team report on LANL 

contain many additional findings which seriously cast in doubt the ability of EEOICPA 

dose reconstructionists to rely on the LANL technical reports, SOPs and other 

publications which form so much of the basis of the site profile document. Resource 

limitations prohibit an in-depth discussion of each of these issues. They include: 

x based on numerous deficiencies, a lack of accreditation for the Lab’s external 

radiation personnel dosimetry program; 

x lack of extremity dosimeters for large groups of exposed workers; 

x dubious gamma-to-neutron ratios for extremity doses; 
26

x inadequate programs for tracking of and protection from the many radioactive sources 

and x-ray units around the Lab; 

x inadequate radiological protection programs for the Lab’s accelerator workers; 

x inadequate training and management of radiation protection technicians; and 

x lack of calibration of fixed and portable instruments. 

Workers’ Recollections

 At the June 18 meeting in Espanola organized by ATL International, the difficult 

but all-too-familiar subject of censoring of radiation badge readings was raised at least 

three times. 

 A long-time employee who carried an ionization chamber recalled: “I was around 

radiation sources... [A]nd my film badge always showed up zero, but in my ionization 

chamber it always showed up something else.” Another former worker recalled a cleanup operation in which pencil dosimeters taped to his wrists measured high levels of 

external radiation. As was customary, an RCT noted the readings in a log book as the 

worker exited the hot zone. However, the worker’s dosimetry badge data came back later 

with “zero” exposure. 42

 A former Radiation Control Technician (RCT) described operations at two 

facilities (TA-3 and TA-55) involving intensive handling of radioactive materials where 

he and other RCTs expected dose rates to be elevated. “But when the RCTs got their 

reports, the exposure rates were very low,” he recalled. Furthermore, a former RCT 

described having been instructed not to turn in filter counts for stacks at CMR Building if 
27

the count was over a certain level. He was instructed “to just dispose of it in the trash 

can.”

 A specific event was described by a former worker in which “the Lab hired 

summer students to purge the medical records” of Zia employees. It is unclear whether 

dose records were purged, but the former worker thinks probably so. According to this 

former worker, the purpose was to shield the Lab from potential liability related to a 

change in the maintenance contractor from Zia to another company. 

 Even more fundamental than censored dosimeter readings is the practice of 

workers wearing their film badges underneath their lead aprons. A former plutonium 

glove box worker described this as “common practice” while doing “hot work, especially 

gamma” at CMR Building, DP West and TA-55. Americium, Pu-242 and the changing of 

hot equipment were jobs in which this practice was common, through the mid-1990’s. In 

one specific incident, the worker’s pen dosimeter read “greater than 10R.” In several 

other incidents it exceeded 1R. Yet in all of these cases the worker’s film badge was 

underneath the lead apron where the recorded dose would turn out to be much lower. 42

Other Important Publicly Available Documents Not Cited in Site Profile 

Nyhan Report. In September 1990, Dr. Jack Nyhan of LANL’s Environmental Science 

Group produced a draft report on past activities associated with contamination at TA21.43 This report documents the use of small incinerators called “salamanders” in the 

1960’s and 1970’s to burn organic solvents and oils contaminated with transuranics and 

fission products. This activity is not mentioned in the site profile document’s description 

of work at TA-21.
28

History Associates “...Guide to Records Series...”. Due to the information access 

issues described above, public confidence in the dose reconstruction process depends on 

the degree to which NIOSH gains access to relevant record series at LANL. Certain 

record series have long been known to exist, but have proven inaccessible to workers and 

families. 

 The most systematic compilation of such records series, published by History 

Associates in 1995, is entitled “Los Alamos National Laboratory: A Guide to Records 

Series Supporting Epidemiologic Studies Conducted for the Department of Energy.” 44

Among the record series described in this compilation which are not explicitly mentioned 

in the site profile document are: 

x “Source Records, 1978-1990” (for Wiggs et al study45)

x Zia Company Employee Mortality and Occupational Exposure Analysis 

Reports, 1991

x Plutonium body burden records, 1977-1992 

x Exposure Rates Analysis Record, 1977 

x Zia Company , External Exposure reports, 1984, 1986-1990 (for Galke et 

al study46)

The great difficulties experienced by NIOSH-funded researchers during the 

1990’s in gaining access to LANL record series21 augers badly for the agency’s ability to 

access records for EEOICPA. However, there is now a larger, better-informed public 

constituency to support NIOSH access to LANL records. The site profile process is an 

opportunity to make more citizens aware of the specific LANL record series that may be 

helpful in assessing health risks. By excluding the History Associates report, the site 

profile document misses an opportunity to build informed public participation.

Moreover, it raises the question of whether the pertinent record series have been 

accessed. 
29

“Human Radiation Experiments: The Department of Energy Roadmap...” Table 5-

22 of the site profile document lists the “Radioiodine Experiments: In the late 1950’s...,” 

asserting that 19 subjects received doses of either I-125 or I-131. In 1995 DOE published 

a report which lists eight radioiodine experiments at LANL, the last in “about 1963.” 47

As shown in Table 3, the total number of experimental subjects exceeds 100; however, it 

is unclear whether individuals were enrolled in more than one study. The potentially 

large number of experimental subjects should be cited in the site profile document. 

LANL employees were among the research subjects. 

Apparent Inconsistencies Between Sections of the Site Profile 

CMR Hot Cells. Throughout the 1960’s a major activity at LANL with serious potential 

for worker exposure to radioactive materials took place in the hot cells at CMR Building 

(TA-3). Fuel elements from test nuclear reactors of various kinds were subjected to postmortem studies. Large inventories of fission products, along with irradiated Pu and U, 

were handled. The site profile document does not consistently portray the nature and 

magnitude of this activity. An accurate, consistent portrayal is essential due to the great 

potential for worker exposure to radioactive materials. 

 Chapter 2 misses several opportunities to describe these operations (e.g., Table 2-

1; Section 2.3 Description of Site Activities and Processes; Section 2.3.10.7 Project 

Rover). Chapter 5 states “Radioiodine and noble gases are released from facilities 

performing fission product chemistry [Wing 9, CMR (TA-3) and TA-48]...” This comes 

closer to describing hot cell operations, but use of the term “fission product chemistry” 

does not convey the large inventories present. A further mention of the CMR hot cells is 

made in Chapter 6, but the context is neutron doses so only U and Pu are mentioned. 
30

 The implications of this oversight become clear on p. 96 of Chapter 5 where it is 

stated:

“...interviews with current and past LANL personnel involved with bioassay 

indicate that fission products were not considered a significant source term for 

intake among LANL workers.” 

A complete portrayal of activities in the CMR hot cells in the 1960’s would cast serious 

doubt on this assumption. Research and analysis on the hot cells at DP West and TA-48 

would deepen these doubts. For example, Appendix B shows several monitoring sheets 

(obtained by this author [K.S.] under the Freedom of Information Act in 1996) for the hot 

cells in Room 401 of DP West in July 1969. Alongside the unusually high counts is the 

notation “These Figures Should Not Be Recorded...”

 Regrettably, the parsimonious description of the CMR hot cells is all too 

consistent with the site profile document’s serious errors of omission regarding HDivision Progress Reports (see above). Some data on environmental releases from the 

hot cells at CMR in the 1960’s and 1970’s are available in the LAHDRA repository at 

UNM. Health Division Progress Reports from the mid- to late-1960’s (Appendix A) are 

likely to prove revealing, if they are ever made public. In this light, the fragmentary 

descriptions of these operations in various chapters of the site profile are quite curious.

“...OWR Facility is not a source of radioiodine.” This declarative statement appears 

on p. 30 of Chapter 5. Yet Table 2-1 lists I-131 as one of the radionuclides released from 

TA-2. Data contained in the LAHDRA repository at UNM, along with the most recent 

LAHDRA report,23 show that OWR was a source of I-131. 
31

Section 2. LANL’s Furnishing of Access to Information Not Yet in the Public 

Domain

Incidents, Accidents and Occurrences. A principal shortcoming of the site profile 

document is an incomplete listing of incidents, accidents and occurrences involving 

worker contamination. Table 2-4 (pp. 50-1) lists 54 “accidents and incidents” covering 

the time period of 1943 to 1996. The criteria for inclusion in Table 2-4 are: “either 

reported to DOE or the subject of a Los Alamos report, or that involved criticality events 

with or without exposure.” The documentary sources of information from which these 

incidents and accidents were drawn include H-Division Reports, Lab technical reports, a 

widely available AEC compilation published in 1975, and a LANL technical report 

reviewing criticality accidents published in 2000. 

 A second table (Table 5-22) contains 45 entries of “Reported Exposure Incidents 

and Results” from 1944 to 1983. The sources of information for the list in Table 5-22 are 

primarily Health Division reports. 

Background. From 1996 to 1998 this author (K.S.) had access to a LANL Occurrence 

Reports Collection maintained in a non-classified vault at TA-35 under the custodianship 

of William Inkret and John Voltin of ESH-12. The focus of the research was 

environmental releases from LANL during the 1970’s. To determine the proportion of all 

reported occurrences which involved environmental releases of radioactive materials, 

cursory notes were also taken on all “worker-only” occurrences between 1970 and 1980.

In addition, for a grant proposal to NIOSH in collaboration with colleagues at the 

University of New Mexico, this author also took cursory notes on occurrences in 1985 

and 1990. Finally, in investigating thyroid cancer in Los Alamos County, notes were also 
32

taken on environmental releases potentially involving fission products in the mid- to late1960’s.

The Occurrence Reports Collection at TA-35 is a paper collection, organized 

chronologically in binders labeled by year. Its contents span the period of the Lab’s 

founding in the early 1940’s during the Manhattan Project to the early 1990’s. In 1991, 

the DOE’s electronic occurrence reporting system became operational and the paper 

collection lapsed.

Most, if not all, of the reports in the ORC at TA-35 were prepared by Los Alamos 

managers to comply with regulations and administrative orders issued by the AEC and its 

successor agencies for the reporting of occurrences. Most reports are about five pages in 

length. A standard reporting form, adapted from a form in use at Hanford, was 

introduced in 1972, but it did not gain uniform use thereafter. Many reports are in the 

form of internal memos, usually from group leaders, with attached sampling results and 

official correspondence. In the early 1970’s the Group Leader of H-1 (Health Physics) 

urged his subordinates to “investigate all contamination incidents in detail,” regardless of 

whether they met the formal AEC reporting requirements.48 This policy affirms the 

impression that the ORC at TA-35 includes a large number of “off-normal” incidents. 

On fewer than five occasions in the 1970’s were full-scale investigations of a particular 

“Type A” occurrence conducted. These resulted in final reports longer than 100 pages.

Analysis of Selected Years. Based on this author’s first-hand experience in the ORC at 

TA-35, it is apparent that Tables 2-4 and 5-22 of the site profile document do not take 

account of numerous worker contamination episodes. Here, a lower bound estimate is 

developed for the additional occurrences likely involving worker radiation contamination 
33

which might be obtained if NIOSH and ORAU were to thoroughly utilize the ORC at 

TA-35. A thorough search and retrieval of this collection would bring to light many 

additional worker radiation contamination episodes. 

 This analysis is limited to the following years: 

1970 to 1980 

1985

1990

because these are the only years’ occurrences on which this author took notes when in the 

vault at TA-35. In each of these years, the number of occurrences known to have 

involved radioactive materials is shown in column 5 of Table 3. This excludes a 

relatively small number of traumatic injuries and fatalities, “near misses” involving 

physical dangers (e.g., lock-out), breeches of security fences, and incidents involving 

non-radioactive substances.

 Occurrences which involved radioactive materials and are likely to have resulted 

in worker contamination are tallied in column 6 of Table 3. Included among these 

incidents are nose swipes, elevated air sampling results, contamination of personal 

articles and effects, and/or reports with descriptors such as “significant.” Incidents 

involving depleted uranium are also included. Table 4 gives illustrative examples of the 

kinds of incidents that are tallied in column 6 of Table 3. 

The numbers in column 6 of Table 3 are likely to be underestimates for two 

reasons. First, this author’s notes are cursory when it comes to the details of “workeronly” contamination incidents. Second, the numbers in column 6 exclude incidents for 

which this author’s notes indicate only that a “spill” had occurred in the work area. In 
34

some “spills” surface counts were on the order of 105 cpm. Modern exposure modeling 

techniques might yield significant doses which influence IREP calculations under 

EEOICPA.

The difference between the number of occurrences provided by the site profile 

(Table 3, column 4) and those in the ORC likely involving worker radiation 

contamination (Table 3, column 6), is shown in column 7 of Table 3. This represents a 

lower bound estimate of the additional occurrences which might be obtained for just the 

13 years analyzed if NIOSH and ORAU were to thoroughly utilize the ORC at TA-35. 

A rate of 64 additional occurrences in a 13 year period is roughly five per year.

Extrapolated to the other 34 years of operation from 1944 to 1991 this translates into 170 

more occurrences involving worker contamination with radioactive materials which 

could be utilized in dose reconstructions if the ORC at TA-35 were to be thoroughly 

utilized. All told, at least 230 new occurrences would be obtained from this paper 

collection between 1944 and 1991. 

Occurrences in Other Years. Table 5 of this report shows 35 occurrences which are not 

listed in Table 2-4 or Table 5-22 of the site profile document. The occurrences in Table 5 

were obtained from the following sources: 

A. Occurrence Reports Collection at TA-35 (author’s notes) 

B. Files of the Joint Committee on Atomic Energy in the National Archives in 

Washington, D.C. 

C. LAHDRA repository at UNM-Albuquerque’s Zimmerman Library 

D. Author’s June 2003 Freedom of Information Act request for the entire ORC at 

TA-35 (only the first 250 pages were provided, covering 1944-1950) 

In no way does Table 5 purport to be comprehensive. Rather, it is intended to give the 

reader a qualitative appreciation of the large number and wide variety of contamination 
35

incidents. LANL routinely documented many such incidents. But the Lab’s historical 

documentation is not currently being tapped for dose reconstructions under EEOICPA. 

Use of Occurrence Reports in Dose Reconstruction. It cannot be assumed that copies 

of occurrence reports were routinely added to individuals’ medical records. Numerous 

workers and survivors have voiced frustration upon reviewing their supposedly 

“complete” medical records from LANL, only to find key pieces of documentation 

missing – occurrence reports, finger ring dosimetry data, internal biosassay results, etc..

Importantly, the reports in the ORC at TA-35 contain individual identifiers such as 

names, Z-numbers, and group affiliation (e.g., Zia, MP Division, etc.). These reports 

could be used to improve the quality of dose reconstructions in several ways. First, and 

most obvious, the listing of an individual’s Z-number in an occurrence report is 

conclusive evidence of the worker’s presence at an incident where a dose was likely 

incurred, a dose which may not be documented elsewhere. In particular, this applies to 

internal radiation doses received in contamination incidents taking place before the 

bioassay program was fully implemented. According to the Tiger Team report (see 

Section 1) the bioassay program was not fully implemented as late as 1991. 

Second, in cases where the interviewee describes an incident but is unable to 

provide precise dates, the ORC at TA-35 should be mined in pursuit of contemporaneous 

documentation. For example, an individualized docket notebook was compiled for an 

EEOICPA leukemia claimant32 using the “Surrogate Incident Report” form in Appendix 

C. Its purpose was to alert dose reconstructionists to the possible availability of 

documentation for incidents which the worker recalled from memory. Third, exposures 

resulting from incidents which were never documented, but are described in sufficient 
36

detail by interviewees, could be quantitatively modeled using similar incidents 

documented in the ORC at TA-35. 

Conclusions. A comprehensive search and retrieval of the ORC at TA-35 should be 

performed by NIOSH and ORAU. Names and Z-numbers should be extracted, indexed, 

and linked to the primary occurrence reports. Until this valuable source of information is 

accessed and utilized systematically in the performance of dose reconstructions, LANL 

claimants cannot have confidence that their individualized dose reconstructions are truly 

“claimant friendly.” Involvement in an occurrence was a significant and often stressful 

event in a worker’s career at the Lab. Some were life-threatening. A truly “claimant 

friendly” dose reconstruction process would leave no stone unturned in locating 

documentation of such incidents. 

Addenda.

Occurrence Reports Can Supplement Bioassay Data that Are Missing or Suspect.

Chapter 5 (p. 11) of the site profile document on internal dosimetry states: 

“At the time of this technical basis document, LANL had submitted bioassay data 

for only a few individuals. Only summary dose reports have been submitted for 

all claims. The submitted bioassay results were for plutonium only and in an 

interim format excerpted from the current database. The format of these results is 

not the final format expected for the data. All descriptive information provided in 

this document is based on speculation of the final format of the data that will 

eventually be supplied.” [emphasis added] 

A worker or public interest scientist experienced in seeking data from DOE contractors 

would draw the following logical inferences. First, LANL has not provided bioassay data 

on a timely basis, despite the public finding in NIOSH’s 2004 report to Congress that the 
37

lab was “not consistently providing adequate responses to data requests for dose 

reconstruction.”25 Second, the data submitted are no longer in the form of primary 

documentation, having been entered into a LANL database and reformatted. Third, the 

format in which some data have been provided is a further impediment to NIOSH’s 

ability to perform dose reconstructions. Fourth, NIOSH can’t be sure the agency will 

receive the necessary information – hence, the rest of Chapter 5 is “based on 

speculation.” 

This further underscores the importance of NIOSH and ORAU thoroughly 

utilizing the ORC at TA-35. Many occurrence reports include primary documentation of 

bioassays on contaminated workers. The public will have little confidence in dose 

reconstructions based on data that has been extensively re-worked – with its release long 

delayed – by LANL. A portion of the dose reconstructions should be audited to ascertain 

whether reliance on primary documentation yields probability of causation intervals that 

are systematically different from those obtained when data reformatted by LANL is used. 

Beyond Occurrence Reports: RCT Log Books. Participants at the June 18 meeting in 

Espanola organized by ATL International, as well as subsequent interviewees, 

emphasized the vitally important information contained in another record series: the 

daily “log books” of radiation control technicians (RCTs; also known as “health physics 

technicians”). 

“Many incidents were not reported up the chain of command,” a former worker 

explained, “nor would they be found in any incident reports. The only record would be a 

note in the daily RCT log book.”49
38

In addition, “On many clean-ups only the RCT wore a film badge. Whatever 

reading they received was considered to be the same for everyone involved.”42 This 

common approach to monitoring clean-up workers was obviously flawed. Every spill 

had “hot spots,” resulting in variation in worker exposure. RCTs were typically the least 

exposed since their job did not involve hands-on clean-up tasks. Use of the RCT’s badge 

reading as a proxy for all workers on the clean-up job casts doubt on doses recorded in all 

secondary sources of data. This underscores the importance of accessing the RCT log 

books.
39

Section 3.

Ability of worker and community organizations to independently evaluate how 

primary sources of information have been analyzed and interpreted in the site 

profile document 

Introduction. A sociopolitical process involving workers’ and citizens’ organizations in 

New Mexico, and across the United States, led to passage of EEOICPA in 2000. 13, 14, 50-52

These organizations have continued to provide leadership on EEOICPA implementation 

and technical assistance to selected individual claimants. This author (K.S.) was 

involved in developing the formal comments of the Los Alamos Project on Worker 

Safety on the NIOSH dose reconstruction rule, as well as several related legislative, 

regulatory and technical assistance initiatives. 

 These activities fall within the ambit of public interest science, which the 

Association for Science in the Public Interest defines as: 

“[R]esearch carried out primarily to advance the public good. Key characteristics 

distinguishing public interest science from other science include the following:

* The primary beneficiary is society as a whole, future generations, or a specific 

‘public’ unable to carry out research on its own behalf;

* Research outcomes are freely available, that is, not patented, proprietary, or 

requiring proprietary means to access;

* Research outcomes are developed in consultation or collaboration with 

members of the public; and 

* Any assumptions or values underlying or providing a context for the research 

are made explicit.” 53

Many citizens form their opinions about health risk issues on the basis of positions taken 

by organizations they trust.54 Public interest and citizens’ organizations employ or 

collaborate with scientists who independently review and critique the basis for the actions 
40

of government agencies. Access to the complete docket of agency criteria documents, 

memoranda, and technical reports is the sine qua non of good public interest science. 

Analysis of the Accessibility of Information Sources Cited in the Site Profile.

Department of Energy facilities have long been inhospitable venues for the practice of 

public interest science, due to policies restricting the public availability of documents 

which form the basis for agency decisions. In addition to bona fide classification for 

national security reasons, there are several less clear-cut reasons why documents may be 

unavailable to the public: 

x documents “born classified” in the era of the Atomic Energy Commission 

55, 56

x “unclassified controlled nuclear information” (UCNI) 

x “sensitive” information57

x “official use only” 

x re-reviews of documents previously available to the public58

x unexplained restrictions 

To evaluate whether the NIOSH site profile process at LANL is amenable to a 

public interest science approach, the public availability of all 254 sources cited in the site 

profile document was analyzed. 

Methods. Between July 26 and August 8, 2005 three visits were made to the 

Oppenheimer Study Center (the main library at LANL), and one visit to the Zimmerman 

Library at the University of New Mexico (which serves as a repository for LAHDRA 

documents). At LANL the public computer terminals were used to search the following 
41

online sources to determine the public availability of cited sources in the site profile 

document: 

1. LANL Library’s online catalogue (http://library.lanl.gov/) 

2. Energy Citations Database (http://www.osti.gov/energycitations/) 

3. DOE’s Opennet database (https://www.osti.gov/opennet/) 

4. CDC-ChemRisk LAHDRA database 

(http://www2.cdc.gov/nceh/radiation/LANL/default.htm) 

The visit to UNM’s Zimmerman Library was necessary to resolve ambiguity over the 

availability of specific Health Division Progress Reports which are cited in Chapter 5 of 

the site profile document. 

Results. Journal articles, published conference proceedings, DOE orders and published 

books account for the 35.0% (N=89) of cited sources which are available in the open 

literature (Table 6).

 Although cited LANL technical reports (“LA-“) usually had entries in the LANL 

Library’s online catalogue, they were almost uniformly inaccessible to the public. They 

are maintained at the Oppenheimer Study Center in one or more of the following formats: 

x PDF file “Access restricted to selected government agencies” 

x Microfiche collection 

x Technical reports collection 

Only LANL technical staff have access to these materials at the Oppenheimer Study 

Center. An exception was one item found on the open shelves of the Library. 

 DOE’s Opennet and the CDC-ChemRisk database were both created in response 

to public and worker health concerns at DOE facilities. Together, these databases could 
42

be relied upon to provide 27.1% (N=69) of the cited sources not available in the open 

literature.

 DOE’s Energy Citations Database (ECDB) had just two (0.8%) of the cited 

sources as full-text (PDF) documents available for download to the public. According to 

ECDB 16 (6.3%) of the cited sources not otherwise available can supposedly be 

purchased from the National Technical Information Service (NTIS). However, the NTIS 

web site’s search function (http://www.ntis.gov/search/advanced.asp) is not amenable to 

documents published prior to 1990. Older LANL technical reports would therefore 

require that a customized query regarding availability be submitted to the NTIS technical 

staff. Moreover, a fee will be charged for each report. 

 Finally, 78 (30.7%) of the 254 cited sources in the site profile are not available to 

the public using the open literature, ECDB, Opennet, or CDC-ChemRisk. Among these 

items are: 

x LANL Photodosimetry Evaluation Book (“the Bible”) 

x Inkret’s numerous technical reports on dosimetry practices (1998-1999) 

x LANL Health Physics checklist (2004) 

x Lawrence’s numerous dosimetry reports (1967, 1984, 1990, 1992) 

Example: Population Dose. One of the 78 cited sources which is not publicly available 

has ramifications far beyond the site profile process. In Chapter 6 (“...External Dose”) 

the following cited source: 

LANL 2004. Annual worker deep, neutron, shallow and collective dose values 

supplied by LANL for 1944 through part of 2004. July 26 and July 29, 2004 [NB: 

no “LA-“ number]
43

is not publicly available. Yet it sharply contradicts the public record of workers’ 

collective doses at LANL, established by the report series “Radiation Exposures for DOE 

and DOE Contractor Employees” which has been issued annually for over 30 years.

 This author (K.S.) had on file data from selected years’ DOE reports. Total 

numbers of employees (EEs) of UC and Zia, as well as visitors who were monitored, are 

provided. As shown in Figure 1, the numbers used by the site profile based on LANL 

(2004) do not agree with either the total number of persons monitored (includes visitors) 

or the number of UC plus Zia employees monitored (“EEs only”) in the annual DOE 

report, except in 1975. 

 Further, Figure 2 shows the percent discrepancy between the population doses in 

the two sources of information. The annual population doses reported in LANL (2004) is 

systematically lower than that for reported in the annual DOE report for UC plus Zia 

employees (except 1987-9). Person-rems, a basic metric of population dose, has long 

been used by public health decision-makers in assessing and prioritizing concerns among 

nuclear facilities. For the site profile document to sharply contradict this public record 

without a word of explanation is naive. One possibility is that the Lab’s numbers were 

developed subsequent to the alleged “purging” of Zia employees’ dose records (Meeting 

Transcript, p. 27). 

Caveats. More than 30 university and public libraries in the United States were part of 

the AEC depository system for technical reports.59 These libraries received microfiche 

copies of many LANL technical reports. Under DOE, many of these libraries have 

continued to receive microfiche versions of technical reports from major facilities like 

LANL. It is theoretically possible that some of the 78 cited sources which are otherwise 
44

unavailable could be found on microfiche at selected AEC depository librarires.

However, this author’s (K.S.) experience at the Massachusetts Institute of Technology 

and UNM’s Centennial Library revealed the AEC depository collections to be incomplete 

and poorly maintained. Harvard’s AEC depository collection could not be located by 

library staff in response to this author’s persistent inquiries in 1996.

 It is unlikely that there is a single university library anywhere in the United States 

where a public interest scientist would be able to retrieve all of the “LA-“ technical 

reports in order to critically review how the cited sources were actually interpreted by the 

author of the site profile. 

Conclusions. Despite the seminal role of citizens’ and workers’ organizations in 

successfully advocating for adoption and implementation of EEOICPA 13, 14, 31, 60, these 

organizations cannot now undertake a meaningful public interest science approach to the 

NIOSH site profile process at LANL. Thirty percent of the documents cited in the site 

profile are not available to the public. Moreover, for the 17.7% of documents which are 

available at UNM Zimmerman Library, photocopying charges and travel costs are 

entailed. NTIS’s page and shipping costs for the 6.3% of documents not available 

elsewhere are non-trivial. Thus, in effect, one-third to one-half (i.e., 30.7% + 17.7% + 

6.3% = 54.7%) of the basis for the NIOSH site profile document cannot be scrutinized 

using a public interest science approach on behalf of the very organizations that 

advocated for EEOICPA’s passage. 
45

CONCLUSIONS 

 The sociopolitical process which led to EEOICPA’s passage in 2000 has entered a 

phase dominated by technical and administrative specialists in dose reconstruction and 

claims processing. The site profile process provides a public window into the interaction 

between federal agencies and LANL over access to information on past radiation 

exposures. Problems with access to information for dose reconstructions at LANL were 

not unanticipated, in light of past controversies between LANL and others with legitimate 

claims to health- and exposure-related data. 

However, this author (K.S.) never anticipated the legerdemain by which the 

“ought” of LANL technical reports and SOPs would be repackaged for NIOSH into a 

purported profile of what “is” (or was). The site profile document disregards 

independent, critical analyses of worker safety and health at LANL, even those from 

highly-sanctioned, reputable sources like the Tiger Team and the DOE Inspector 

General’s Office. 

 A desultory approach to utilizing the voluminous Occurrence Reports Collection 

at TA-35 is unconscionable. Numerous contamination incidents which are not likely to 

be documented in claimants’ medical records are readily accessible at TA-35 to 

researchers and contractors. National security is not the issue. This author (K.S.) has 

never held a security clearance, but was allowed to use the collection from 1996 to 1998 

with a badge provided by the DOE Area Office. Unlike some other record collections at 

LANL which have been exhaustively searched by the LAHDRA project team, the ORC 

at TA-35 contains no extraneous information. Under a conservative estimate presented in 

Section 2 of this report, more than 230 occurrence reports of radioactive contamination of 
46

LANL workers prior to 1991 could be obtained by a thorough search and retrieval of the 

ORC at TA-35. The ORC at TA-35 also holds the potential for basing LANL dose 

reconstructions on primary documentation. This would provide a quality check on dose 

reconstructions performed with dosimetry data which LANL has only provided only after 

long delays and re-formatting. 

 Especially grievous are newly proffered but never published retrospective 

numbers from LANL for the total persons monitored and population dose (person-rems). 

Until now, the official record has been an annual report which DOE has published for 

more than 30 years. The site profile document furnishes the Lab’s new numbers without 

even citing the DOE report series. The Lab’s numbers are from a cited source with no 

“LA-“ report number. The Lab’s numbers for annual person-rems are systematically 

lower. This reinforces an impression gained by some workers over the course of their 

careers at LANL that “the books are cooked” (Meeting Transcript, p. 27). 

The fact that the site profile document cannot be scrutinized using a public 

interest science approach exposes a fundamental lack of public openness in the dose 

reconstruction process. The site profile process is associated with the Advisory Board on 

Radiation and Worker Health, a federal advisory committee. The public interest science 

movement has grown up on the terrain of federal advisory committees where scientists 

advise federal decision-makers on issues of public importance.61, 62 Although the draft 

site profile document is available on the Internet, one-third to one-half of the 254 cited 

sources are unavailable to the public. These cited sources are not classified documents. 

They have nothing to do with weapons design, but everything to do with radiation 

workers’ health. 
47

 Little has changed for LANL workers and families, despite passage of EEOICPA 

with New Mexico political leaders at the helm. The Lab’s “official line” continues to 

prevail, due to health agencies’ and contractors’ willful disregard of information that 

deviates. Having failed to aggressively pursue one of the most germaine sources of 

documentary information (the ORC at TA-35), a contractor now seeks to enlist former 

workers to voluntarily attend meetings for the purpose of eliciting largely anecdotal

information (Meeting Transcript, p. 19). And Chapter 5 of the site profile document is 

based almost entirely on “speculation” that data will be forthcoming. 

 “The cavalry is coming. The cavalry is coming,” a local leader in Hurricane 

Katrina was told by federal officials, as rising flood waters inexorably drowned residents 

of a nursing home. Analogously, the “Cold War heroes” of Los Alamos have been told 

repeatedly that the information needed to reconstruct their radiation doses will soon be 

forthcoming. This author (K.S.) expects rebuttals to this report to emphasize “new 

developments since June 2005,” in which the Lab is showing signs of “turning over a 

new leaf,” etc.. But, with past experience as a guide,23, 24 in about 18 months no one will 

be surprised to learn that NIOSH is still not getting the information needed to reconstruct 

doses. One thing is certain. More LANL cancer claimants will be dead, along with their 

families’ faith in the government program for which they campaigned. At the beginning 

of the twenty-first century a federal public health agency should not be providing the kind 

of leadership which leaves citizens thinking that inexorable death is the likeliest outcome. 

The term “regulatory capture” describes a process whereby government regulators 

come to be dominated by the industries they are supposed to regulate. NIOSH is not a 

regulatory agency; it has an investigatory role under EEOICPA. So a more appropriate 
48

term might be “investigatory surrender.” In its current form, the site profile document 

represents investigatory surrender because it is captive to the Lab’s idealized version of 

“ought”; an audience of Lab managers will be assuaged that recommended dosimetry 

procedures were routinely followed. 

x Will NIOSH and ORAU incorporate into the site profile document insights and 

facts contained in widely available reports which critically evaluate radiation 

worker safety and health practices at LANL? 

x Will NIOSH and ORAU aggressively pursue occurrence reports at TA-35? 

x Will NIOSH and ORAU seek to resolve discrepancies between the official public 

record of DOE annual reports and the Lab’s newly proffered but never published 

retrospective numbers of the total persons monitored and population dose? Is the 

discrepancy related to the alleged “purging” of Zia workers’ records? (Meeting 

Transcript, pp. 9-10) 

x Will resources be made available for organizations that advocated for EEOICPA 

to participate on the terms of public interest science? 

x Above all, how long will “speculation” as to the future availability of data be 

allowed to continue before NIOSH determines that doses cannot be 

reconstructed? 

Overt surrender might be the most claimant-friendly outcome. A statement by 

NIOSH that it cannot obtain timely information needed for dose reconstruction would 

provide a basis for including LANL workers in the SEC. As a first step, NIOSH should 

regularly present data to the Advisory Board on Radiation and Worker Health on LANL 
49

claims for which doses could not be reconstructed, showing the technical areas and eras 

of employment. On-the-record updates on access issues at LANL are also needed. 

Interminable, obsequious investigation is a roadblock to fulfilling the objectives 

of EEOICPA for LANL workers and families. Conceiving of the site profile document 

as “a living, breathing document” (Meeting Transcript, p. 19) is morally akin to playing 

an endless audio loop of the sound effects of approaching hoof beats. The sham cavalry 

never arrives to help the citizens. Because new information is always “just around the 

bend” as it were, those of us who are mulling petitions for including LANL workers in 

the SEC must give pause. This would-be SEC petitioner (K.S.) does not relish the public 

humiliation of basing a well-honed petition on the current version of the site profile 

document only to have “newly released” information materialize in defense of the Lab’s 

past dosimetry practices. 

Governments have long been able to force “official” versions of history onto 

society, even when evidence to the contrary is abundant and widely available.63 As one 

who counts among his most esteemed colleagues and teachers many NIOSH staff and 

grantees -- and well remembers how NIOSH scientists lent a willing ear to LANL 

workers’ concerns in 1998 and 1999 -- it is this author’s heartfelt wish that NIOSH not be 

complicitous in such a grave injustice. 
50

REFERENCES 

1. House of Representatives. Enactment of Provisions of H.R. 5408, The Floyd D. 

Spence National Defense Authorization Act for Fiscal Year 2001; Conference 

Report to Accompany H.R. 4205. Washington, D.C.; 2000. 

2. House Report on the Floyd D. Spence National Defense Authorization Act. 

Congressional Record. October 6 2000;146:H9451-H9453. 

3. Levin C. Remarks on the National Defense Authorization Act for 2000. 

Congressional Record. October 12 2000;146:S10373. 

4. U.S. Department of Labor. 20 CFR Parts 1 and 30. Performance of Functions 

Under this Chapter; Claims for Compensation Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000, as Amended. Federal

Register. December 26 2002;67(102):78874-78910. 

5. U.S. Department of Labor. 20 CFR Parts 1 and 30 Performance of Functions; 

Claims for Compensation Under the Energy Employees Occupational Illness 

Compensation Program Act; Interim Rule. Federal Register. June 8 

2005;70(109):33590-33639.

6. Fuller D. Statement before the Subcommittee of the Committee on 

Appropriations, United States Senate. Paducah Gaseous Diffusion Plant.

Washington, D.C.: GPO; 1999:15-28. 

7. U.S. Senate Committee on Governmental Affairs. Department of Energy's 

Management of Health and Safety Issues at it Gaseous Diffusion Plants in Oak 

Ridge, Tennessee, Piketon, Ohio. Committee on Governmental Affairs. Second 

ed. Washington, D.C.: Government Printing Office; 2000:461. 

8. Warrick J. In Harm's Way, And in the Dark; Workers Exposed to Plutonium at 

U.S. Plant. Washington Post. August 8, 1999;A: A01. 

9. Warrick J. Study Finds More Hazards at Paducah; Discord Greets Draft Report 

on Uranium Workers' Radiation Exposure. Washington Post. October 5, 2000;A: 

A03.

10. Clinton WJ. Executive Order 13179; Providing Compensation to America's 

Nuclear Weapons Workers. Federal Register. December 11 2000;65(238):77487-

77490.

11. National Institute for Occupational Safety and Health. Methods for Radiation 

Dose Reconstruction Under the Energy Employees Occupational Illness 

Compensation Program Act of 2000; Final Rule. Federal Register. May 2 

2002;67(85):22314-22336.

12. The Floyd D. Spence National Defense Authorization Act for fiscal year 2001.

Conference report. Congressional Record. 2000;146:S10376-S10378.

13. Silver K. DOE illness compensation: on the ground in northern New Mexico. 

Perspectives on Nuclear Weapons and Community Health. October 2001:4-6. 

14. Public Hearing - Injured LANL workers. Dr. David Michaels, Senator Jeff 

Bingaman, Congressman Tom Udall. Espanola, NM; 2000:186+. 

15. Public Meeting. Advisory Board on Radiation and Worker Health. Denver, CO: 

NIOSH; 2002. 

16. Ruiz R. Energy Employees Occupational Illness Compensation; 2003. 

17. Burkhardt M. Personal communication. To Silver K., Santa Fe, NM; 1997. 
51

18. Martinez L. Personal communication. To Silver K., Espanola, NM; 2003. 

19. Schofield P. Interview with Silver K. Albuquerque, NM; 2005. 

20. McKee J. AG pressures Lab on pollution data. Albuquerque Journal. April 6, 

2001: 1. 

21. Advisory Committee on Energy-Related Epidemiologic Research. Summary of 

the Eighth Meeting. Santa Fe, New Mexico April 18-19, 1996

22. Davenport K. Health advocate sues Energy Department. Santa Fe New Mexican.

February 6, 2001: B1. 

23. Widner T, Shonka J, Flack S, et al. Interim Report of the Los Alamos Historical 

Document Retrieval and Assessment (LAHDRA) Project. Version 3B ed. San 

Francisco, CA: ChemRisk; 2004. 

24. McKee J. Team seeks access to Lab records; Fed researchers appeal LANL 

restrictions in pollution study. Albuquerque Journal. November 28, 2001;Journal 

North.

25. National Institute for Occupational Safety and Health. Report to Congress:

Report on Access to Information for Performance of Radiation Dose 

Reconstruction. Washington, D.C.: U.S. Department of Health and Human 

Services; May 5 2004. 

26. Stearns LB. Environmental politics in the United States and Japan: Self-interest, 

ideology, power and institutional isomorphism. Paper presented at: American 

Sociological Association, 1994. 

27. O'Toole T. American Public Health Association Meeting. Personal 

communication. To: Silver K. Meeting of the American Public Health 

Association, New York; November, 1996. 

28. Advisory Committee on Human Radiation Experiments. Final Report.

Washington, D.C.: Government Printing Office; 1995. 

29. Harper J. Fridays. Memo to Radioactive Waste Section. Los Alamos, NM: Los 

Alamos National Laboratory, HSE-7; 1990. 

30. Drypolcher A. Waste management documents and information. Memo to 

Employees. Los Alamos, NM: Los Alamos National Laboratory; 1992. 

31. Meeting on the Energy Employees Occupational Illness Compensation Program. 

Senator Jeff Bingaman, Congressman Tom Udall, Assistant Energy Secretary Bev 

Cook. Espanola, NM; 2002:73. 

32. Los Alamos Project on Worker Safety. Personal Exposure and Health Docket for 

Jonathan Garcia. Espanola, NM 2002. 

33. Voilleque PG. Estimating source terms for radionuclides released to the 

environment. Presentation at: Calculating and Understanding Risk from 

Radionuclides Released to the Environment; April 28, 1997; Santa Fe, NM. 

34. Church BW. Selection from Elements of Controversy: The Atomic Energy 

Commission and radiation Safety in Nuclear Weapons Testing, 1947-1974: 

Origins of the project. The Public Historian. Winter 1996;18(1):15-16. 

35. Renard P. Personal communication. To Silver K., Espanola, NM; 1999. 

36. Silver K. These Figures Should Not Be Recorded. Santa Fe, NM: Concerned 

Citizens for Nuclear Safety; 1999. 
52

37. U.S. Department of Energy, Environment, Safety and Health. Tiger Team 

Assessment of the Los Alamos National Laboratory. Washington, D.C.: US DOE; 

November 1991. 

38. Anon. Bulletin of the Atomic Scientists. July/August 1991;47(6):5. 

39. Marshall E. Tiger teams draw researchers' snarls. Science. April 19 

1991;252(5004):366-368.

40. Office of Inspector General. Inspection Report: Allegations Concerning the 

Reporting of a Radiological Incident at the Los Alamos National Laboratory.

Washington, D.C.: U.S. Department of Energy; March 2003. DOE/IG-0591. 

41. Lobsenz G. Leaky tank never inspected; Exposure incident reveals new safety 

breakdowns at Los Alamos. Energy Daily. May 6 2005;33(86):1-2. 

42. Schofield P. Personal communication. To: Silver K., Albuquerque, NM; 2005. 

43. Nyhan JW. RCRA Facility Investigation Task; SWMU Descriptions and 

Identifications of Data Needs: TA-21 Surface Units Aggregate at Los Alamos, 

NM. Los Alamos, New Mexico: Environmental Science Group; September 1990. 

44. History Associates. Los Alamos National Laboratory: A Guide to Records Series 

Supporting Epidemiologic Studies Conducted for the Department of Energy.

Rockville, MD: U.S. Department of Energy, Office of Epidemiology and Health 

Surveillance; October 12 1995. 

45. Wiggs LD, Johnson ER, Cox-DeVore CA, Voelz GL. Mortality through 1990 

among white male workers at the Los Alamos National Laboratory: considering 

exposures to plutonium and external ionizing radiation. Health Physics. 

December 1994;67(6):557-586. 

46. Galke WA, Johnson ER, Tietjen GL. Mortality in an ethnically diverse radiation 

exposed occupational cohort [unpublished draft]. Los Alamos, NM: Los Alamos 

Scientific Laboratory; November 24 1992. 

47. U.S. Department of Energy,. Human Radiation Experiments: The Department of 

Energy Roadmap to the Story and the Records. Washington, D.C.: U.S. 

Department of Energy; February 1995. DOE/EH-0445. 

48. Meyer DD. Follow-up on Minor Occurrences. In: "Distribution", ed. Los Alamos, 

New Mexico: Los Alamos Scientific Laboratory; 1972. 

49. Trimmer L. Personal communication. To: Silver K., Santa Fe, NM; 2005. 

50. Alvarez R. Aid for nuclear workers. The Nation. October 9 2000;271(10):7. 

51. Alvarez R. Making it work; compensation for nuclear workers. Bulletin of the 

Atomic Scientists. July 2001;57(4):54-60. 

52. Udall M. Bill to compensate poisoned nuclear workers. Congressional Record - 

Extensions of Remarks. September 14 2000;146:E1489-1490. 

53. Association for Science in the Public Interest. Definition of public interest 

science. Available at: www.public-science.org/id9_m.htm. Accessed August 18, 

2005.

54. Tesh SN. Citizen experts in environmental risk. Policy Sciences. 1999;32:39-58.

55. Hewlett RG. 'Born classified' in the AEC: A historian's view. The Bulletin of the 

Atomic Scientists. December 1981:20-27. 

56. Green HP. 'Born classified' in the AEC: A legal perspective. The Bulletin of the 

Atomic Scientists. December 1981:28-31. 
53

57. Silver K. Access to environmental information [letter]. Environmental Health 

Perspectives. February 2004;112(8):A458. 

58. Costner B. Access denied. The Bulletin of the Atomic Scientists. March-April 

2002;58(2):58.

59. Bonilla CF. Appendix I. Availability of AEC Documents. Nuclear Engineering.

New York: McGraw-Hill; 1957:813-814. 

60. Silver K. Playing with Fire on a Remote Plateau: The Coming of Genetic 

Susceptibility Testing of Workers at Los Alamos National Laboratory [DRAFT].

Boston: JSI Center for Environmental Health Studies; December 5 2001. 

61. Primack J, von Hippel F. Advice and Dissent: Scientists in the Political Arena.

New York, NY: Basic Books; 1974. 

62. von Hippel F, Primack J. Public interest science. Science. September 29 

1972;177:1166-1171.

63. Ruosso H. The Vichy Syndrome: History and Memory in France Since 1944.

Cambridge, MA: Harvard University Press; 1991. 
Tables and Figures 
TABLE 1. SPECIAL EXPOSURE COHORT 

Group Basis for Inclusion Minimum Employment Era Additio

MEMBERSGaseous Diffusion Plants (Oak Ridge, Paducah, Portsmouth) 

EEOICPA statute (2000) 250 days before 

2/1/92 

were or could ha

Amchitka (Long Shot, Milrow or Cannikin tests) 

EEOICPA statute (2000) None before 

1/1/74 

exposed to radia

Mallinckrodt Chemical Works, Destrehan St. Facility (St. Louis, MO) 

petition granted 250 days 1942-1948 

Iowa Ordnance Plant, Line 1 

petition granted 250 days 3/49-12/74 

Y-12 Plant Uranium enrichment, Building 9201-5, Beta Building 

petition granted 250 days 1944-1947 
UNDER REVIEW

National Bureau of Standards, Radioactivity Lab, Building #2 (Washington, D.C.) 

1943-1952 

OTHER PETITIONS “QUALIFIED FOR EVALUATION”

Era Workers 

Rocky Flats 1952-2005 All workers represented 

by Steelworkers Union 

Y-12 Eastman lab equipment cleaning 

work 

Pacific Proving Ground 7/1-8/31/58 Operation Hardtack 
UNSUCCESSFUL PETITIONS (“NOT QUALIFYING FOR EVALUATION”)

LANL – withdrawn by petitioner Multiple Facilities Nationwide – petitioner status could not be determined Oak Ridge K-25 – already included Paducah - uncelar 
TABLE 2. Radioiodine Experiments at LANL (excerpted from DOE’s 1995 report, “Human Radiation 

Experiments: The Department of Energy Roadmap...”) 

Experiment’s 

Serial Designation 

Number of 

Subjects 

Route of 

Administration 

Subjects 

LANL-7 17 oral Normal of ill male or female, ages 10-57 LANL-9 26 oral Adults: 17 females, 10 males. Children: 3 

girls, 3 boys 

LANL-10 4 Skin 2 employees LANL-11 28 Injection 10 normal, 18 liver disease LANL-14 unspecified LANL-19 8 Adults LANL-20 2 Female LANL-23 “in about 1963” 

19 I-125, I-131 

Total: 104+ 
TABLE 3. Lower Bound Estimate (last column) of the Number of Additional 

Occurrences Likely Involving Worker Radiation Contamination (for selected years) 

Obtainable by a Thorough Search of the Occurrence Reports Collection at TA-35 

(ESH-12) 

 Site Profile Document Silver’s Research Notes from 

ORC at TA-35 (1996-8) 

Year Table 

2-4 

Table 5-22 Sum Radioactive 

Materials 

Involved 

Likely Worker 

Radiation 

Contamination 

Net 

Additional 

Occurrences

1970 2 0 2 25 4 2 

1971 1 1 2 19 6 4 

1972 1 2* 3 34 12 9 

1973 0 2* 2 69 13 11 

1974 0 0 0 30 10 10 

1975 1 0 1 31 ? ? 

1976 0 0 0 50 10 10 

1977 2 10 14 57 14 0 

1978 0 2 2 30 11 9 

1979 2 1 3 44 6 3 

1980 0 3 3 33 5 2 

1985 0 0 0 37 1 1 

1990 0 0 0 30 3 3 

 

Totals: 32 489 95 64 

*Table 5-22 lists a total of four incidents in 1972-3. For compatibility with the analysis performed here, it 

was assumed that two incidents occurred in each year. 

? Author’s notes on “worker-only” occurrences in 1975 were too cursory to allow an estimate 
TABLE 4. Illustrative examples of incidents documented in the Occurrence Reports Collection (TA-35, E

involved worker contamination with radioactive materials (1970-1980, 1985, 1990) 

Date Tech Area/Location Description 

January 5, 1970 52 five workers counted for I-131 exposure July 31, 1971 SD-6 Worker’s high badge readings November 2, 1972 TA-21, DPW Finger rings, one >25 rem/Q4; Pu-238 through non-

December 5, 1972 TA-15, Phermex Three people > 1.0 rem October 11, 1972 TA-21, 21-213 Worker sprayed with Pu-239 September 14, 1973 TA-21, 401W hot cells 110 mR gamma November 15, 1974 TA-33, Building 86, Room 9 Tritium to room, worker 3.43 rem May 8, 1974 TA-53 Three badges 5 to 10R February 27, 1974 TA-53, A-2 target Dermatitis January 30, 1974 TA-33, Building 86 3 rem in first quarter, tritium May 18, 1976 TA-53, MPF1, D125 C-11 lungs due to air plenum April 26, 1976 TA-21, Building 5, Room 500A Pu-239, U-235, operator highly contaminated February 4, 1976 TA-3, CMR Fire inspector contaminated May 31, 1977 TA-21, Building 5, Room 500 9.81 rem badge March 9, 1978 TA-21, Building 4, Room 401W 35 rem badge Co-60 August 12, 1978 TA-53, Area B, BR Neutron exposures January 15, 1979 TA-3, Building 16, Neutron Room 128 mR to badge; Pu-238 source misplaced September 12, 1985 TA-55, PF4 Room 429 Pu-239, some “significant,” metal prep line April 1, 1990 TA-55, PF4 High worker badge readings May 30, 1990 TA-53, MPF3 Isotope production workers 
TABLE 5. Selected occurrences not reported in site profile document 

Date Tech Area Description 

March 8, 1945 1 Po source resulted in "extremely high hand counts" due to poor packaging of shipm

September 26, 1945 1 fire in contaminated pit; smoke "contaminated badly"; urinalysis 

November 28, 1945 1 Po source contaminated Gamma Building, Room 76 

March 29, 1946 1 two plumbers exposed to Po source in W Building 

May 3, 1946 1 chemical explosion spread Pu contamination in Building D 

June 1, 1946 21 nose counts and second hand account of accident by Dean Meyer 

July 11, 1946 1 Pu metal turnings caught fire in room D-317, "very high contamination"; nose countJuly 19, 1946 1 hand wound in chemical operator 8,000 c/m 

December 19, 1946 21 hand wound from Po-contaminated glassware 265.7 c/m 

October 1, 1947 21 pipefitters contaminated; nose counts 

November 7, 1947 21 radioactive solution sprayed in faces of two operators; nose counts 

November 12, 1947 21 hand wound 900 c/m 

July 20, 1948 1 Pu-249 solution spilled in Building D; two workers contaminated 

September 14, 1948 1 worker contaminated in cleaning operation; nose counts 

November 14, 1949 unk Pu-249 thumb contamination to 20K c/m 

March 10, 1950 K-Site worker contaminated; elevated urine counts March 25, 1950 1 hand would cleaning glassware in Building D; to 1,500 c/m 

July 5, 1950 10 member of decontamination crew overexposed to gamma radiation 

July 24, 1950 R-Site 

two accelerator workers "showed a gamma exposure so high as to be essentially uEastman Type K film" 

August 11, 1950 2 Omega site worker exposed: 1.6 r gamma body badge; 5.0 r gamma wrist 

October 3, 1950 21 

"extreme contamination" of worker opening tape sealed can of Pu; prompts investig

incident involving three more workers 
January 15, 1960 3 

"a glass bottle containing a plutonium solution ruptured violently," resulting in elevatcounts in three chemists; room counts 

October 7, 1960 TX-NM tritium container leaked en route from TX to LASL, contaminating three couriers 

January 11, 1963 33 

"exposure problem at TA-33." Destruction of memo March 30, 1972 by C. Buckland "confidential RD" 

April 22, 1964 21 

explosion and fire in rag incinerator damaged filters. spread to adjoining hood; U-2counts 

February 16, 1965 33 release to atmosphere; refers to March 4, 1965 classified memo 

April 15, 1966 

P-9 

accelerator 1,200 Ci tritium released 

October 26, 1967 3 650 Ci tritium released 

February 7, 1968 3 300 Ci tritium released 

October 28, 1968 21 Room 500 DP West contaminated incident 

March 3, 1969 21 chemical fire during leaching of U-235 filter 

June 26, 1969 21 explosion in incinerator burning U-235 metal turnings; dust in Room 313 

July 30, 1969 21 

CMB 11 worker with elevated nose counts upon opening a can containing Pu metaruptured plastic bag 

September 22, 1969 21 Pm-147 contamination of open glove box; room counts 

Sources: A: ORC at TA-35 B: JCAE at National Archives C: LAHDRA D: FOIA June 2003 
TABLE 6. Analysis of the Availability of Sources Cited in the LANL Site Profile 

Available from... 

Chapter No. of 

citations* 

Open 

Literature 

DOE’s 

OpenNet 

CDC 

Chem

Risk 

Library 

or online 

full text 

NTIS Not Available 

2 42 10 2 19 1 6 3 3 29 16 3 10 4 21 11 12 5 106 30 17 15 46 6 62 23 5 4 1 10 19 

Totals 254 89 24 45 2 16 78 

% 35.0% 9.4% 17.7% 0.8% 6.3% 30.7% *Corrected for citations which appear in multiple chapters 
Figure 1. Number of Persons Monitored for External Radiation

("Radiation Exposures for DOE..." annual report vs. Site Profile's LANL [2004] cited 

0

2000400060008000

10000120001400016000

1974

1975

1976

1977

1978

1979

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

# of Persons Monitored 
Figure 2. Percent Discrepancy Between Reported Person-Rems: 

Site Profile's LANL (2004) Relative to "Radiation Exposures for DOE...

-60.0%-50.0%-40.0%-30.0%-20.0%-10.0%

0.0%

10.0%

1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 19