1608 SPRING HILL ROAD, SUITE 400 • VIENNA, VIRGINIA • 22182 • 703.893.6600 • FAX 703.821.8236 

February 12, 2009 

Mr. David Staudt 

Center for Disease Control and Prevention 

Acquisition and Assistance Field Branch 

Post Office Box 18070 

626 Cochrans Mill Road – B-140 

Pittsburgh, PA 15236-0295 

Re: Contract No. 200-2009-28555, Task Order 1: SCA-TR-TASK1-0022, Site Profile for Sandia 

National Laboratories in Albuquerque, New Mexico, and the Tonopah Test Range in Nevada

Dear Mr. Staudt: 

S. Cohen & Associates (SC&A, Inc.) is pleased to submit to the Advisory Board Document No. SCA-TRTASK1-0022, Site Profile for Sandia National Laboratories in Albuquerque, New Mexico, 

and the Tonopah Test Range in Nevada. This site profile has been reviewed for Privacy Act-restricted 

information and cleared with minor clarifications. The document has also been reviewed and cleared for 

public distribution by the Department of Energy (DOE). 

SC&A believes it is obligated to bring one particular issue of potential regulatory significance to the 

attention of the Advisory Board and NIOSH, with possible referral to DOE for follow-up. Finding 5.13 

of our review of the Site Profile for Sandia National Laboratory cites a concern for “inaccurate dose 

record for reactor personnel” at Sandia. This concern comes from our determination that reactor 

operators at the Sandia Pulse Reactor may have exceeded applicable annual dose limits during the time 

period from 1962 through 1982, because of non-representative external badge readings. This discrepancy 

was attributed to the inability of the torso-worn badge to adequately measure the severe radiation field 

gradient surrounding the reactor vessel during maintenance activities. SC&A found references to this 

discrepancy in its review of onsite documentation and was able to corroborate it through interviews with 

Sandia health physics personnel of that era. 

While corrective action apparently was undertaken in the early-1980s to both reduce exposure and 

improve dosimetry, it is not clear that the earlier inaccurate radiation dose records were corrected for the 

individuals and time periods in question. This is of particular significance, given that most of the 

operators involved received annual doses approaching annual limits even without such corrections. With 

correction of their dose records, many of these individuals would have exceeded their 5 rem annual limit 

repeatedly. Besides regulatory concerns, this issue will clearly have implications for dose reconstruction 

for the former workers involved. 

Should you have any questions, please contact me at 732-530-0104. 

Sincerely, 

John Mauro, PhD, CHP 

Project Manager 
cc: P. Ziemer, Board Chairperson A. Makhijani, SC&A 

Advisory Board Members H. Behling, SC&A 

T. Katz, NIOSH S. Ostrow, SC&A 

L. Elliott, NIOSH H. Chmelynski, SC&A 

J. Neton, NIOSH J. Fitzgerald, Saliant 

S. Hinnefeld, NIOSH J. Lipsztein, SC&A 

L. Homoki-Titus, NIOSH K. Robertson-DeMers, Saliant 

A. Brand, NIOSH S. Marschke, SC&A 

J. Broehm, NIOSH K. Behling, SC&A 

C. Ellison, NIOSH T. Bell, Saliant 

L. Shields, NIOSH D. Farver, SC&A 

D. Sundin, NIOSH Project File (ANIO2/001/22) 

L. Breyer, NIOSH 

1608 SPRING HILL ROAD, SUITE 400 • VIENNA, VIRGINIA • 22182 • 703.893.6600 • FAX 703.821.8236 
Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

Site Profile for Sandia National Laboratories in Albuquerque, New Mexico, 

and the Tonopah Test Range in Nevada 

Contract No. 200-2004-03805 

Task Order No. 1 

SCA-TR-TASK1-0022

Prepared by 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755

February 2009 

Disclaimer 

This document is made available in accordance with the unanimous desire of the Advisory Board on 

Radiation and Worker Health (ABRWH) to maintain all possible openness in its deliberations. However, 

the ABRWH and its contractor, SC&A, caution the reader that at the time of its release, this report is predecisional and has not been reviewed by the Board for factual accuracy or applicability within the 

requirements of 42 CFR 82. This implies that once reviewed by the ABRWH, the Board’s position may 

differ from the report’s conclusions. Thus, the reader should be cautioned that this report is for 

information only and that premature interpretations regarding its conclusions are unwarranted.
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Document No. 

SCA-TR-TASK1-0022 

Effective Date: 

Draft — February 5, 2009 

S. Cohen & Associates: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 

0 – DRAFT 

Site Profile for Sandia National Laboratories 

in Albuquerque, New Mexico, 

and the Tonopah Test Range in Nevada 

Page 1 of 80 

Task Manager: 

________________________ Date: ___________ 

Joseph Fitzgerald 

Project Manager: 

________________________ Date: ___________ 

John Mauro 

Supersedes: 

N/A 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

TABLE OF CONTENTS 

Acronyms and Abbreviations ..........................................................................................................5 

1.0 Executive Summary.............................................................................................................8 

1.1 Findings....................................................................................................................8 

1.2 Scope and Approach ..............................................................................................10 

1.3 Summary of Findings.............................................................................................11 

1.4 Opportunities for Improvement .............................................................................14 

2.0 Scope and Introduction ......................................................................................................15 

2.1 Review Scope.........................................................................................................15 

2.2 Assessment Criteria and Methods..........................................................................16 

2.2.1 Objective 1: Completeness of Data Sources.............................................17 

2.2.2 Objective 2: Technical Accuracy..............................................................17 

2.2.3 Objective 3: Adequacy of Data.................................................................17 

2.2.4 Objective 4: Consistency among Site Profiles..........................................17 

2.2.5 Objective 5: Regulatory Compliance........................................................18 

2.3 Dose Reconstruction under EEIOCPA ..................................................................18 

2.4 Report Organization...............................................................................................20 

3.0 Vertical Issues and Secondary Issues ................................................................................21 

3.1 Potential Shortcomings Exist in Completeness and Adequacy of Dosimetry 

Records ..................................................................................................................21 

3.2 Inaccurate Dose Records for Reactor Personnel....................................................26 

3.3 Site-wide Workers Not Bioassayed for Potential Internal Intakes before 

1992........................................................................................................................28 

3.4 Use of Air Monitoring Data in Dose Estimation is Problematic ...........................29 

3.5 Inadequate Treatment of Potential Radiological Exposure Sources......................32 

3.6 Lack of Guidance Provided to Support Dose Estimation for Offsite Work 

Activities................................................................................................................35 

3.7 The Maximizing and Best-Estimate Intake Parameters for Tritium may not 

be appropriate.........................................................................................................40 

3.8 Environmental Source Terms are Inadequately Characterized for use in 

Performing the Exposure Assessment for Airborne Emissions.............................43 

3.9 The Environmental External Dose Component is developed with Inadequate 

Justification and may be incomplete......................................................................45 

3.10 Criteria for Badging Workers were not defined ....................................................46 

3.11 Lack of Dosimetry Record Information.................................................................47 

3.12 Insufficient Analyses of Radiation Fields, Doses, and Uncertainties....................49 

3.13 Secondary Issues....................................................................................................53 

3.13.1 The Site Profile Table 5-24 is of very Limited Value and it is 

Uncertain why the MDA for the Whole-Body Counting in Table 5-

24 is approximately Twice as Big in 2001 as it was in 1994.....................53 
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3.13.2 The Site Profile Recommends the Use of the LANL MDA Values 

for Bioassay Analysis Performed at SNL before 1992. Better 

Justification should be Provided. ...............................................................53 

3.13.3 The TBD lacks a Discussion of Other Potential Medical X-ray 

Exposures and the Procedures needed to Maximize Medical X-ray 

Dose ...........................................................................................................53 

3.13.4 The Reference in the SNL TBD for Stout 2005 does not include the 

Backup Documentation Cited....................................................................55 

3.13.5 The TBD does not adequately describe the Approach and Data used 

in the Exposure Calculations .....................................................................55 

3.13.6 The TBD does not give Guidance on Combining the Environmental 

Intakes from Emissions at More Than One TA (i.e., Multiple TA 

Internal Exposures) and does not address Inadvertent Ingestion...............56 

3.13.7 Reliance on CATI in the Absence of Complete Records ..........................57 

4.0 Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction ........................59 

4.1 Satisfying the Five Objectives ...............................................................................59 

4.1.1 Objective 1: Completeness of Data Sources.............................................59 

4.1.2 Objective 2: Technical Accuracy..............................................................60 

4.1.3 Objective 3: Adequacy of Data.................................................................62 

4.1.4 Objective 4: Consistency among Site Profiles..........................................64 

4.1.5 Objective 5: Regulatory Compliance........................................................64 

4.2 Usability of Site Profile for Intended Purposes .....................................................64 

4.2.1 Ambiguous Dose Reconstruction Direction ..............................................64 

4.2.2 Inconsistencies and Editorial Errors in the Site Profiles............................65 

4.3 Unresolved Policy or Generic Technical Issues ....................................................66 

5.0 References..........................................................................................................................67 

Attachment 1: NIOSH Technical Documents Considered During the Review Process...............72 

Technical Support Documents...........................................................................................72 

Attachment 2: Site Expert Interview Summary............................................................................74 

Attachment 3: Key Questions and Responses for NIOSH/ORAU Regarding Site Profile 

Documents .........................................................................................................................75 
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ACRONYMS AND ABBREVIATIONS 

ACRR Annular Core Research Reactor, TA-V 

Advisory Board Advisory Board on Radiation and Worker Health 

AEC Atomic Energy Commission 

ALARA As Low as Reasonably Achievable 

AMAD Activity Median Aerodynamic Diameter 

AP Anterior Posterior 

BZA Breathing Zone Air 

CAM Continuous Air Monitor 

CATI Computer Assisted Telephone Interview 

CEDE Committed Effective Dose Equivalent 

CEP Controls for Environmental Pollution 

CFR Code of Federal Regulations 

Ci Curies 

DOE Department of Energy 

DR Dose Reconstruction or Dose Reconstructor 

dpm Disintegrations per Minute 

DU Depleted Uranium

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

ESE Entrance Skin Exposure 

GM Geometric Mean 

GSD Geometric Standard Deviation 

H-3 Tritium 

HT Tritium Gas 

HTO Tritiated Water 

IMBA Integrated Modules for Bioassay Analysis 

IREP Interactive RadioEpidemiological Program 

JTA Joint Test Assembly 

keV Kilo electron Volt 

LANL Los Alamos National Laboratory 

LASL Los Alamos Scientific Laboratory 

LAT Lateral 
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LLNL Lawrence Livermore National Laboratory 

LOD Limit of Detection 

LWDS Liquid waste disposal system 

MAP Mixed Activation Products 

MDA Minimum Detectable Activity 

MDL Minimum Detectable Dose 

MFP Mixed Fission Products 

MND Missed Neutron Dose 

MPD Missed Photon Dose 

MT Metal Tritides 

MW Megawatt 

NIOSH National Institute for Occupational Safety and Health 

NM New Mexico 

n/p Neutron-to-Photon Ratio 

NTA Eastman Kodak Nuclear Track Film Type A 

NTS Nevada Test Site 

OBT Organically Bound Tritium

OCAS Office of Compensation Analysis and Support 

ORAUT Oak Ridge Associated Universities Team

OTIB ORAU Technical Information Bulletin 

PBFA Particle Beam Fusion Accelerator 

PFG Photofluorography 

POC Probability of Causation 

PPG Pacific Proving Grounds 

R&D Research and Development 

REECo Reynolds Electrical and Engineering Company, Inc. 

rem Roentgen Equivalent Man 

SABRE Sandia Accelerator and Beam Research Experiment 

SC&A S. Cohen and Associates 

SEC Special Exposure Cohort 

SER Sandia Engineering Reactor (TA-V, circa 1957) 

SNL Sandia National Laboratories, Albuquerque, New Mexico 
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SPR Sandia Pulse Reactor (Facility), TA-V 

SRDB Ref ID Site Research Database Reference Identification (number) 

STC Special Tritium Compound 

TA Technical Area 

TBD Technical Basis Document 

TIB Technical Information Bulletin 

TLD Thermoluminescent Dosimeter 

TTR Tonopah Test Range 
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1.0 EXECUTIVE SUMMARY 

This report provides the results of an independent audit conducted by S. Cohen and Associates 

(SC&A) of the site profile for Sandia National Laboratories (SNL) developed by the National 

Institute for Occupational Safety and Health (NIOSH). This audit was conducted during the 

period December 1, 2007–August 31, 2008, in support of the Advisory Board on Radiation and 

Worker Health (Advisory Board or Board) in the latter’s statutory responsibility under the 

Energy Employees Occupational Illness Compensation Program Act of 2000 (EEOICPA) to 

conduct such reviews and advise the Secretary of Health and Human Services on the 

“completeness and adequacy” of the EEOICPA program. 

The bulk of the historic activities at SNL in New Mexico were related to the non-nuclear aspects 

of nuclear weapons design. This work included weapons design and testing, production 

engineering, stockpile maintenance, and stockpile surveillance. It also involved a spectrum of 

routine offsite activities from 1945 to the present, including operations at a number of Sandia 

Corporation sites in California, Mississippi, Nevada, and Tennessee. SNL employees also 

routinely spent time at other DOE facilities. SNL was responsible for surveillance of the 

nation’s stockpiled weapons, and accordingly, staff members were stationed at various storage 

sites to monitor, maintain, and assemble the weapons. 

It is recognized in the Oak Ridge Associated Universities Team (ORAUT) SNL technical basis 

document (TBD), ORAUT-TKBS-0037 (ORAUT 2007a), that the potential for chronic intakes 

at SNL was far less than at DOE production sites because of the nature of the tasks performed at 

SNL. Nevertheless, the potential for monitored and unmonitored intakes did exist throughout the 

history of the site. Occupational internal dose could have been received by an individual from an 

intake of radioactive material while performing tasks within buildings and structures at SNL, or 

from activities taking place outside of buildings, such as with the burial of waste or the 

monitoring of nuclear or non-nuclear tests. High external radiation fields existed at the research 

reactors and accelerators during their operations. Residual contamination existed around the 

various outdoor test ranges, where kinetic impacts, explosions, or high temperature burns were 

used to test the hardiness of warhead designs using surrogate material, such as depleted uranium. 

The SNL was operated as the Z-Division and later Albuquerque Branch of Los Alamos Scientific 

Laboratory (LASL) from 1945 until 1949. SNL was created in 1945 to perform ordnance 

engineering and assembly aspects of LASL’s design work. Nuclides with the widest historical 

and current application throughout the SNL facilities include H-3, U-238, U-234, U-235, fission 

and activation products, such as Sr-90, Cs-137, Zn-65, Co-60, Ta-182 and, to a lesser degree, 

Pu-238, Pu-239, Pu-240, Pu-241, and Am-241. In the early days, there were many similarities, 

common operations, and dosimetry practices used at both Los Alamos National Laboratory 

(LANL) and SNL. Therefore, when reviewing dose estimation procedures, it is important, to 

keep in mind the similarities in common operations performed and the radiological sources used. 

1.1 FINDINGS

SC&A finds that the existing site profile does not address inaccurate dose records for operators 

at the Sandia Pulse Reactor (SPR) resulting from under-recording of external gamma/neutron 
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dose received during shutdown maintenance activities. This under-recording resulted from 

inadequate dosimetry during the early years of SPR operation for a severe gradient of exposure 

levels experienced by personnel working close to the reactor vessel, leading to an underestimate 

of whole-body dose by at least a factor of 1.75, and likely higher, prior to installation of 

additional shielding in 1982. As annual dose levels for these operators were among the highest 

at SNL, approaching the annual limit of 5 rem in some cases, this would have significant 

implications for the accuracy of dose reconstruction. While known to SNL management at the 

time, no retroactive correction was apparently made to individual dose records. 

As the TBD acknowledges, no formal routine bioassay program existed at SNL prior to 1992, 

leading to the likelihood that workers in areas containing radioactive materials may have had the 

potential for internal exposures that would not have been monitored. With their work areas in 

many cases being unknown, a backup means of estimating dose is not apparent in the TBD. The 

instructions given for dose reconstructors in the site profile do not appear to be adequate for 

determining or quantifying the radioactive isotopes to which unmonitored or even monitored 

workers may have been exposed. Assigning potential missed dose by work location is 

particularly questionable in the absence of complete work history records. Furthermore, the 

feasibility of this approach is questionable for site-wide workers and workers involved in offsite 

activities in Nevada and other locations. In cases where work area information is not available, 

the TBD should provide further instruction. 

For tritium, it is important that the dose reconstructor chooses claimant-favorable forms of 

tritium for the dose estimation if there is a lack of process knowledge about the form that may 

have been involved with exposures. The dose to the lung from intakes of metal tritides (MTs) 

can be underestimated by orders of magnitude if it is incorrectly assumed that the dose can be 

calculated with the methods used for tritiated water (HTO). 

For external radiation dosimetry, SC& A finds that there are insufficient analyses of radiation 

fields, doses, and uncertainties in the TBD. ORAUT-TKBS-0037 (ORAUT 2007a) does not 

cover the subject of photon and neutron radiation energy fields and associated doses with related 

uncertainties as a function of work location and time periods sufficient to allow the dose 

reconstructor to accurately assign dose. For example, no relevant neutron calibration 

information is provided, nor is a clear uncertainty value provided that can be applied for neutron 

doses as a function of time. The neutron-to-photon ratio (n/p) value cited in the TBD is based on 

a relatively small number of records over an 8-year time span and would likely not be 

representative of laboratory conditions over that timeframe. 

With respect to data completeness and adequacy for internal dosimetry, SC&A finds that the 

SNL electronic database is incomplete for internal doses, and hard copy bioassay records are not 

complete in individual radiation exposure files. There is also a lack of data regarding specific 

radionuclides to which workers were potentially exposed. Additionally, the adequacy of offsite 

vendor data has been suspect at times, suggesting a need for further verification of data 

completeness and accuracy. Exposure data for workers at offsite facilities frequented by SNL 

workers (e.g., atmospheric nuclear weapons testing) may not be readily available and need to be 

addressed for the benefit of the dose reconstructor. In light of these shortcomings, the 

verification process for determining the completeness and consistency of the internal dosimetry 
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information provided electronically and in hard copy from other sites requires careful 

consideration for use in dose reconstruction. 

For external dosimetry, SC&A found that there is little treatment of the completeness or 

adequacy of external dose records, i.e., the dose information they may or may not contain; the 

different recording systems; and different recording methods/programs used after switching to 

electron data storage. 

1.2 SCOPE AND APPROACH 

SC&A’s review focused on the TBD that makes up the SNL in Albuquerque, New Mexico, and 

the Tonopah Test Range (TTR), Nevada, site profile. The TBD addresses introduction, site 

description, internal dose, external dose, occupational medical dose, and environmental 

occupational dose as they pertain to historic occupational radiation exposure to SNL workers. 

The TBD was issued in 2007. As “living” documents, TBDs are constantly being revised as new 

information, experience, or issues arise. For the SNL site profile in particular, interviews with 

NIOSH and ORAUT staff underscored their ongoing and extensive efforts to upgrade the 

existing TBD. 

SC&A’s review process included a review of the TBD and supporting documents; one onsite 

visit to conduct interviews with site experts and review documents available at the site; and an 

exchange of questions and answers between SC&A and its NIOSH and ORAUT counterparts. 

The TBD was evaluated for completeness, technical accuracy, adequacy of data, compliance 

with stated objectives, and consistency with other site profiles, as stipulated in the SC&A

Standard Operating Procedure for Performing Site Profile Reviews (SC&A 2004). A complete 

list of the SNL TBD and its supporting documents that were reviewed by SC&A is provided in 

Attachment 1. 

Issues presented in this report are sorted into the following categories, in accordance with 

SC&A’s review procedures: 

(1) Completeness of data sources 

(2) Technical accuracy 

(3) Adequacy of data 

(4) Consistency among site profiles 

(5) Regulatory compliance 

Following the introduction and a description of the criteria and methods employed to perform the 

review, the report discusses the major issues identified during our review. The issues were 

carefully reviewed with respect to the five review criteria. Several of the issues were designated 

as primary findings, because they represent key deficiencies in the TBD that need to be 

corrected, and which have the potential to substantially impact at least some dose 

reconstructions. Others have been designated “secondary findings” to both connote their 

importance for the technical adequacy and completeness of the site profile, and to indicate that 

they have been judged by SC&A to have relatively less influence on dose reconstruction or the 

ultimate significance of estimated worker doses. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

1.3 SUMMARY OF FINDINGS 

Finding 1: Potential Shortcomings Exist in Completeness and Adequacy of Dosimetry 

 Records 

Apparent shortcomings in the completeness, accuracy, and availability of radiation dose data 

should be addressed in any ongoing revision of the SNL site profile report. The SNL electronic 

database is incomplete, and hard copy bioassay records are not complete in individual radiation 

exposure files and lack data regarding specific radionuclides to which workers were potentially 

exposed. LANL was considered the primary source of bioassay prior to 1991; however, reviews 

of the LANL bioassay data in previous reviews by SC&A and by ORAUT found the LANL 

bioassay data to be incomplete or inadequate (SC&A 2006, Vitkus et al. 2007). Additionally, the 

adequacy of offsite vendor data is suspect, suggesting a need for further verification of data 

completeness and accuracy. The site profile does not fully address the significance of 

radiological incidents, how they may have contributed to worker dose, and how they would be 

addressed in dose reconstruction. In light of these shortcomings, the verification process for 

determining the completeness and consistency of the dosimetry information provided 

electronically and in hard copy requires careful consideration for use in dose reconstruction. 

Finding 2: Inaccurate Dose Record for Reactor Personnel 

The site profile does not address inaccurate dose records for SPR operators due to underrecording of external gamma/neutron dose received during shutdown maintenance activities. 

This under-recording resulted from inadequate dosimetry at the time for a severe gradient of 

exposure levels experienced by personnel working close to the reactor vessel, leading to an 

underestimate of whole-body dose by at least a factor of 1.75 and likely higher prior to 

installation of additional shielding in 1982. As annual dose levels for these operators were 

among the highest at SNL, approaching the annual limit of 5 rem in some cases, this would have 

significant implications for the accuracy of dose reconstruction. While known to SNL 

management at the time, no retroactive correction was apparently made to individual dose 

records. While some attempt was made to incorporate head dose readings in estimating wholebody dose for 1982 and forward in time, it is unclear to what extent that was done, because head 

dosimeters were not always worn by workers in later years. 

Finding 3: Site-wide Workers not Bioassayed for Potential Internal Intakes before 1992

It is of concern to SC&A that prior to 1992, when no formal routine bioassay program existed at 

SNL, workers in areas containing radioactive materials may have had the potential for internal 

exposures that would not have been monitored, and with their work areas in many cases being 

unknown, a backup means of estimating dose is not apparent in the TBD. The instructions given 

the dose reconstructors in the site profile by NIOSH/ORAUT do not appear to be adequate for 

determining or quantifying the radioactive isotopes to which unmonitored or even monitored 

workers may have been exposed. Assigning potential missed dose by work location is 

questionable, particularly in the absence of complete work history records. Furthermore, the 

feasibility of this approach is questionable for site-wide workers. In cases where work area 

information is not available, the TBD should provide further instruction. 
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However, this report is pre-decisional and has not been reviewed by the Advisory Board on Radiation and Worker 

Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Finding 4: Use of Air Monitoring Data in Dose Estimation is Problematic

Bioassay monitoring of workers was primarily dependent on the air monitoring program, as 

opposed to and in default of a routine bioassay monitoring program. With inadequate air 

sampling or no air sampling data for some years of operation, this brings into question the 

effectiveness of the special bioassay monitoring program and the use of air sampling data as a 

substitute for bioassay sampling, as stipulated in the TBD. It appears that without routine 

bioassay monitoring, dependence upon air sampling for detecting exposures to workers likely led 

to unmonitored intakes by workers over the years at SNL, or intakes that could not be measured 

or estimated accurately, due to use of area air monitoring data. Furthermore, reliance on field 

indicators to trigger special bioassay, particularly in areas where air monitoring equipment 

placement is inadequate or non-existent, is problematic. Some consideration should be given in 

the TBD to the representativeness of the sampling and the consistent use of field indicators as a 

trigger for bioassay. 

Finding 5: Inadequate Treatment of Potential Radiological Exposure Sources 

SC&A finds that further evaluation is warranted for radionuclides handled by workers at SNL to 

determine the extent of potential exposures, periods of exposure, quantities handled, and impacts 

on dose reconstruction to specific organs. Attempts should be made to evaluate archived 

bioassay data where it is available, and determine whether these data are complete and 

representative enough to develop a bounding or coworker dose. Appropriate methods for 

internal monitoring were not always available for all years of potential exposure. 

NIOSH/ORAUT should develop missed dose methodologies in the absence of monitoring data 

based on available data, technical reports, and other sources of information to ascertain potential 

exposure to non-traditional radionuclides. Additional consideration should be given to the 

exposure hazards associated with operation of accelerators, target handling, component 

activation, and byproduct radiation. 

Finding 6: Lack of Guidance Provided to Support Dose Estimation for Offsite Work 

Activities 

SNL took an active role in conducting weapons effects, ground motion, air pressure, crater 

phenomena, and other studies during the testing of weapons. SNL workers were responsible for 

the arming and firing of weapons from 1951 through 1992, and for monitoring, maintaining, and 

assembling weapons at storage sites. A recharacterization of the extent of SNL involvement in 

weapons testing and other offsite activities (e.g., research on hydrodynamic testing, treaty 

verification, and assignments to other DOE sites) should be completed. Offsite activities related 

to the weapons and components testing, surveillance, in-field retrofit and modifications, treaty 

verification, and managing storage sites and their corresponding monitoring programs have not 

been adequately addressed in the SNL TBD. This is confounded by the absence of offsite data in 

the SNL exposure files and the lack of direction to the dose reconstructors on when to request 

data from other sites. While it is understood that under EEOICPA protocols, NIOSH establishes 

work locations to enable dosimetry records to be obtained, including work at other Atomic 

Energy Commission (AEC) or Department of Energy (DOE) sites, it is not clear from the SNL, 

Nevada Test Site (NTS), or Pacific Proving Grounds (PPG) site profiles how visiting SNL 
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employees were monitored for neutron and internal radiation exposures. Internal and external 

exposure hazards during field testing require further consideration to determine if appropriate 

internal and external monitoring occurred. If adequate monitoring did not occur at these offsite 

work locations, the TBD does not provide instructions for bounding these potential exposures. A 

missed dose methodology should be included for unmonitored or inadequately monitored 

personnel who participated in weapons testing and other field activities. Where available, 

references to other site profiles are appropriate. Methodologies for activities at continental tests 

outside of Nevada require treatment in the site profile, a separate site profile, or a technical 

information bulletin (TIB). 

Finding 7: The Maximizing and Best-Estimate Intake Parameters for Tritium may not be 

Appropriate 

Bounding techniques proposed in ORAUT-OTIB-0066, Calculation of Dose from Special 

Tritium Compounds (ORAUT 2007b), cannot be effectively developed and applied without some 

basic understanding of the compounds handled and the extent to which individuals were 

exposed. From the recommendations in ORAUT-OTIB-0066, it is stated that “the selection of 

the appropriate tritium compound in an intake evaluation must usually be based on process 

knowledge of the source terms in the workplace.” It is important that the dose reconstructor 

chooses claimant-favorable forms of tritium for the dose estimation if there is a lack of process 

knowledge about the form that may have been involved with exposures. The dose to the lung 

from intakes of MTs can be underestimated by orders of magnitude if it is incorrectly assumed 

that the dose can be calculated with the methods used for HTO (ORAUT 2007b). 

Finding 8: Environmental Source Terms are Inadequately Characterized for use in 

Performing the Exposure Assessments for Airborne Exposures 

 

The environmental exposure calculations used for assessing intakes of airborne radionuclides 

provided in the SNL Environmental Dose TBD, ORAUT-TKBS-0037 (ORAUT 2007a), used 

source term data that may be inaccurate, incomplete, and not claimant favorable. There are 

periods of time that NIOSH could not find any emission or environmental monitoring data to 

calculate the actual air concentrations to which unmonitored workers could have been exposed. 

The methods that NIOSH used to assign intakes for some of these areas were not clearly 

explained and, in some cases, when the methods were explained, there is a question as to the 

validity of the assumptions used. For some areas of environmental exposure, NIOSH appears to 

have left out potentially significant radionuclides in the assessment of environmental dose. 

Finding 9: The Environmental External Dose Component is developed with Inadequate 

Justification and may be Incomplete 

The assignment of the environmental external doses from TLD data does not have a clear basis 

and is not supported with any analysis of background and onsite environmental dosimeters to 

accurately determine if there were higher levels onsite. There was no discussion detailing the 

dosimeter locations that were placed onsite and whether these were representative for estimating 

non-monitored worker dose. Assessment of possible doses from radioactive particles on skin 
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was missing, in disagreement with discussion in the Scope of the TBD (ORAUT 2007a, 

Section 1.2), which identified this as being covered in the environmental dose section. 

Finding 10: Criteria for Badging Workers are not defined

ORAUT-TKBS-0037 (ORAUT 2007a) does not provide any information concerning the criteria 

for badging workers at the SNL during the period 1949–2007. The criteria that were used to 

determine who was badged, for what type of exposure (i.e., photon, beta, and neutrons), and how 

the badging policy varied as a function of work location/facility and time needs to be addressed 

in the TBD for dose reconstruction purposes and to assist in determining if the coworker data 

presented in the TBD are valid. 

Finding 11: Lack of Dosimetry Record Information 

Throughout the Occupational External Dose section of ORAUT-TKBS-0037 (ORAUT 2007a), 

the dose data records are referred to as containing the necessary and correct dose for exposed 

workers throughout the entire period from 1949–2007. However, except for the brief statement 

on page 99 concerning the electronic files records created since 1986, there is no mention of the 

actual dose records; the dose information they may or may not contain (i.e., if neutron and 

photon components were recorded separately, or only the total penetrating dose was retained 

during certain periods as was the practice at some of the labs); the different recording systems 

(such as the change-over from handwritten to computerized records); and different recording 

methods/programs used after switching to electron data storage. 

Finding 12: Insufficient Analyses of Radiation Fields, Doses, and Uncertainties 

ORAUT-TKBS-0037 (ORAUT 2007a) does not cover the subject of photon and neutron 

radiation energy fields and associated doses with related uncertainties as a function of work 

location and time periods sufficiently to allow the dose reconstructor to accurately assign dose. 

For example, no relevant neutron calibration information is provided, nor is a clear uncertainty 

value provided that can be applied for neutron doses as a function of SNL time period. The n/p 

ratio value cited in the TBD is based on a relatively small number of records over an 8-year time 

span and would likely not be representative of laboratory conditions over that timeframe. 

1.4 OPPORTUNITIES FOR IMPROVEMENT 

(1) The Table 6-8, “Calibration and irradiations” has entries with question marks in the 

Operations columns and no entries in the Radiation type, Energy selection, keV [kilo 

electron volt], and Percentage column. 

(2) The first paragraph on page 104 uses the term “(P2/C7)” without defining these terms. 

(3) The first paragraph on page 106, which is below Table 6-11, should be located above 

Table 6-11, because it refers to the “Table 6-11 below.” 
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2.0 SCOPE AND INTRODUCTION 

The review of the Sandia National Laboratories (SNL) in Albuquerque, New Mexico and the 

Tonopah Test Range (TTR), Nevada, Site Profile was conducted during December 2007–

August 31, 2008, by a team of SC&A health physicists and technical personnel. Given the 

classified nature of some of the records for which access was needed, arrangements were made 

through the Department of Energy (DOE) for special clearances, as well as declassification 

reviews of notes taken and interviews conducted with site personnel and former workers. Two 

members of the SC&A team hold “Q” clearances that permitted unencumbered access for this 

review. 

Two team members also participated in the Nevada Test Site (NTS) site profile review 

conducted by SC&A in 2005, and are currently involved in the Special Exposure Cohort (SEC) 

petition review from which relevant issues were derived that apply to SNL personnel involved 

with nuclear testing activities at NTS and other such sites. Likewise, several members of the 

team conducted the site profile review of the Los Alamos National Laboratory (LANL) in 2006 

(SC&A 2006), and a number of dosimetry and records issues from that site have relevance to 

SNL. 

SC&A understands that site profiles are living documents, which are revised, refined, and 

supplemented with technical information bulletins (TIBs) as required to help dose reconstructors. 

Site profiles are not intended to be prescriptive or necessarily complete in terms of addressing 

every possible issue that may be relevant to a given dose reconstruction. It is recognized that 

NIOSH has data capture activities ongoing at SNL while this review is underway. Likewise, 

additional guidance documents were being issued that, while not reflected yet in the current SNL 

site profile TBDs, would serve to mitigate some of the gaps and issues raised in this report 

(where appropriate, these recent issuances have been so noted). 

2.1 REVIEW SCOPE 

Under the Energy Employees Occupational Illness Compensation Program Act (EEOICPA) of 

2000 and federal regulations defined in Title 42, Part 82, Methods for Radiation Dose 

Reconstruction Under the Energy Employees Occupational Illness Compensation Program, of 

the Code of Federal Regulations (42 CFR Part 82), the Advisory Board on Radiation and Worker 

Health (Advisory Board or Board) is mandated to conduct an independent review of the methods 

and procedures used by the National Institute for Occupational Safety and Health (NIOSH) and 

its contractors for dose reconstruction. As a contractor to the Advisory Board, S. Cohen and 

Associates (SC&A) has been charged under Task 1 to support the Advisory Board in this effort 

by independently evaluating a select number of site profiles that correspond to specific facilities 

at which energy employees worked and were exposed to ionizing radiation. 

This report provides a review of ORAUT-TKBS-0037, Site Profile for Sandia National 

Laboratories in Albuquerque, New Mexico, and the Tonopah Test Range, Nevada, Rev. 00 

(ORAUT 2007a). This document is supplemented by generic TIBs that provide additional guidance 

to the dose reconstructor. 
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Implementation guidance is also provided by so-called “workbooks,” which have been 

developed by NIOSH for selected sites to provide more definitive direction to the dose 

reconstructors on how to interpret and apply TBDs, as well as other available information. 

SC&A, in support of the Advisory Board, has critically evaluated the SNL Site technical basis 

document (TBD) as follows: 

• Determine the completeness of the information gathered by NIOSH in behalf of the site 

profile, with a view to assessing its adequacy and accuracy in supporting individual dose 

reconstructions

• Assess the technical merit of the data/information

• Assess NIOSH’s use of the data in dose reconstructions

SC&A’s review of this site profile document focuses on the quality and completeness of the data 

that characterized the facility and its operations, and the use of these data in dose reconstruction. 

The review was conducted in accordance with Standard Operating Procedure for Performing 

Site Profile Reviews (SC&A 2004), which was approved by the Advisory Board. 

The review is directed at “sampling” the site profile analyses and data for validation purposes. 

The review does not provide a rigorous quality control process, whereby actual analyses and 

calculations are duplicated or verified. The scope and depth of the review are focused on aspects 

or parameters of the site profile that would be particularly influential in deriving dose 

reconstructions, bridging uncertainties, or correcting technical inaccuracies. 

The SNL TBD serves as a site-specific guidance document used in support of dose 

reconstructions. The site profile provides the health physicists conducting dose reconstructions 

on behalf of NIOSH with consistent general information and specifications to support their 

individual dose reconstructions. This report was prepared by SC&A to provide the Advisory 

Board with an evaluation of whether and how the TBD can support dose reconstruction 

decisions. The criteria for evaluation include whether the TBD provides a basis for scientifically 

supportable dose reconstruction in a manner that is adequate, complete, efficient, and claimant 

favorable. Specifically, these criteria were viewed from the lens of whether dose reconstructions 

based on the TBD would provide for robust compensation decisions. 

The basic principle of dose reconstruction is to characterize the radiation environments to which 

workers were exposed, and determine the level of exposure the worker received in that 

environment through time. The hierarchy of data used for developing dose reconstruction 

methodologies is dosimeter readings and bioassay data, coworker data and workplace monitoring 

data, and process description information or source term data. 

2.2 ASSESSMENT CRITERIA AND METHODS 

SC&A is charged with evaluating the approach set forth in the site profile that is used in the 

individual dose reconstruction process. The document is reviewed for completeness, technical 

accuracy, adequacy of data, consistency with other site profiles, and compliance with the stated 
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objectives, as defined in SC&A 2004. This review is specific to the SNL Site Profile, supporting 

TIBs, and dose reconstruction worksheets; however, items identified in this report may be 

applied to other facilities, especially facilities with similar source terms and exposure conditions. 

The review identifies a number of issues, and discusses the degree to which the site profile 

fulfills the review objectives delineated in SC&A’s site profile review procedure. 

2.2.1 Objective 1: Completeness of Data Sources 

SC&A reviewed the site profile with respect to Objective 1, which requires SC&A to identify 

principal sources of data and information that are applicable to the development of the site 

profile. The two elements examined under this objective are (1) determining if the site profile 

made use of available data considered relevant and significant to the dose reconstruction, and 

(2) investigating whether other relevant/significant sources are available, but were not used in the 

development of the site profile. 

2.2.2 Objective 2: Technical Accuracy 

Objective 2 requires SC&A to perform a critical assessment of the methods used in the site 

profile to develop technically defensible guidance or instructions, including evaluating field 

characterization data, source term data, technical reports, standards and guidance documents, and 

literature related to processes that occurred at SNL. The goal of this objective is to analyze the 

data according to sound scientific principles, and then evaluate this information in the context of 

dose reconstruction. 

2.2.3 Objective 3: Adequacy of Data 

Objective 3 requires SC&A to determine whether the data and guidance presented in the site 

profile are sufficiently detailed and complete to conduct dose reconstruction, and whether a 

defensible approach has been developed in the absence of data. In addition, this objective 

requires SC&A to assess the credibility of the data used for dose reconstruction. The adequacy 

of the data identifies gaps in the facility data that may influence the outcome of the dose 

reconstruction process. For example, if a site did not monitor all workers exposed to neutrons 

who should have been monitored, this would be considered a gap and thus an inadequacy in the 

data. An important consideration in this aspect of our review of the site profile is the scientific 

validity and claimant favorability of the data, methods, and assumptions employed in the site 

profile to fill in data gaps. 

2.2.4 Objective 4: Consistency among Site Profiles 

Objective 4 requires SC&A to identify common elements within site profiles completed or 

reviewed to date, as appropriate. In order to accomplish this objective, the SNL TBD was 

compared to other TBDs reviewed to date. This assessment was conducted to identify areas of 

inconsistencies and determine the potential significance of any inconsistencies with regard to the 

dose reconstruction process. 
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2.2.5 Objective 5: Regulatory Compliance 

Objective 5 requires SC&A to evaluate the degree to which the site profile complies with stated 

policy and directives contained in 42 CFR Part 82. In addition, SC&A evaluated the TBDs for 

adherence to general quality assurance policies and procedures utilized for the performance of 

dose reconstructions. 

2.3 DOSE RECONSTRUCTION UNDER EEIOCPA 

In order to place the above objectives into the proper context as they pertain to the site profile, it 

is important to briefly review key elements of the dose reconstruction process, as specified in 

42 CFR Part 82. Federal regulations specify that a dose reconstruction can be broadly placed 

into one of three discrete categories. These three categories differ greatly in terms of their 

dependence on and the completeness of available dose data, as well as on the 

accuracy/uncertainty of data. 

Category 1: Least challenged by any deficiencies in available dose/monitoring data are dose 

reconstructions for which even a partial assessment [or minimized dose(s)] corresponds to a 

probability of causation (POC) value in excess of 50%, assuring compensability to the claimant. 

In some cases, such partial/incomplete dose reconstructions with a POC greater than 50% may 

involve only a limited amount of external or internal data. In extreme cases, even a total absence 

of a positive measurement may suffice for an assigned organ dose [based on limits of detection 

(LOD)] that results in a POC greater than 50%. For this reason, dose reconstructions in this 

category may only be marginally affected by incomplete/missing data or uncertainty of the 

measurements. In fact, regulatory guidelines recommend the use of a partial/incomplete dose 

reconstruction, the minimization of dose, and the exclusion of uncertainty for reasons of process 

efficiency, as long as this limited effort produces a POC of equal to or greater than 50%. 

Category 2: A second category of dose reconstruction defined by federal guidance recommends 

the use of “worst-case” assumptions. The purpose of worst-case assumptions in dose 

reconstruction is to derive maximal or highly improbable dose assignments. For example, a 

worst-case assumption may place a worker at a given work location 24 hours per day and 

365 days per year. The use of such maximized (or upper bound) values, however, is limited to 

those instances where the resultant maximized doses yield POC values below 50%, which are 

not compensated. For this second category, the dose reconstructor needs only to ensure that all 

potential internal and external exposure pathways have been considered, and that the approach is 

scientifically supportable. 

The obvious benefit of worst-case assumptions and the use of maximized doses in dose 

reconstruction is efficiency. Efficiency is achieved by the fact that maximized doses avoid the 

need for precise data and eliminates consideration for the uncertainty of the dose. Lastly, the use 

of bounding values in dose reconstruction minimizes any controversy regarding the decision not 

to compensate a claim. 

Although simplistic in design, the TBD must, at a minimum, provide information and data that 

clearly identify (1) all potential radionuclides, (2) all potential modes of exposure, and (3) upper 
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limits for each contaminant and mode of exposure to satisfy this type of a dose reconstruction. 

Thus, for external exposures, maximum dose rates must be identified in time and space that 

correspond to a worker’s employment period, work locations, and job assignment. Similarly, in 

order to maximize internal exposures, highest air concentrations and surface contaminations 

must be identified. 

Category 3: The most complex and challenging dose reconstructions consist of claims where 

the case cannot be dealt with in one of the two categories above. For instance, when a minimum 

dose estimate does not result in compensation, a next step is required to make a more complete 

estimate. Or, when a worst-case dose estimate that has assumptions that may be physically 

implausible results in a POC greater than 50%, a more refined analysis is required. A more 

refined estimate may be required either to deny or to compensate. In such dose reconstructions, 

which may be represented as a “reasonable” or “best-case” estimate, NIOSH has committed to 

resolve uncertainties in favor of the claimant. According to 42 CFR 82, NIOSH interprets 

“reasonable estimates” of radiation dose to mean the following: 

... estimates calculated using a substantial basis of fact and the application of 

science-based, logical assumptions to supplement or interpret the factual basis. 

Claimants will in no case be harmed by any level of uncertainty involved in 

their claims, since assumptions applied by NIOSH will consistently give the 

benefit of the doubt to claimants. [Emphasis added.] 

SC&A’s draft report and preliminary findings will subsequently undergo a multi-step resolution 

process. Prior to and during the resolution process, the draft report is reviewed by the DOE 

Office of Health, Safety, and Security to confirm that no classified documents or information 

have been incorporated into the report. Resolution includes a transparent review and discussion 

of draft findings with members of the Advisory Board Working Group, petitioners, claimants, 

and interested members of the public. This resolution process is intended to ensure that each 

finding is evaluated on its technical basis in a fair and impartial basis. A final report will then be 

issued to the full Advisory Board for deliberation and a final recommendation. 

All review comments apply to the Rev. 00 version of the SNL component TBD, which is the 

most recently published version. Site expert interviews were conducted with SNL workers to 

help SC&A obtain a comprehensive understanding of the radiation protection program, site 

operations, and historic exposure experience. 

Attachment 2 provides summaries of the interviews conducted by SC&A during the course of 

this review. The interviewees included staff from the SNL and were conducted by Joseph 

Fitzgerald (SC&A/Saliant Inc.) and Robert Bistline (SC&A/Saliant Inc.) from April 23–24, 

2008. 

On February 3, 2008, SC&A sent questions to NIOSH as part of its evaluation of the TBD. 

These questions are reproduced in Attachment 3, along with the written responses provided by 

NIOSH and ORAUT on March 21, 2008. Additional questions stemming from the review were 

submitted by SC&A to NIOSH on February 29, 2008, with a NIOSH/ORAUT response received 
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in the same March 21, 2008 response. These additional questions and the corresponding 

responses are also provided in Attachment 3. 

2.4 REPORT ORGANIZATION 

In accordance with directions provided by the Advisory Board and with site profile review 

procedures prepared by SC&A and approved by the Advisory Board, this report is organized into 

the following sections: 

(1) Executive Summary 

(2) Scope and Introduction 

(3) Vertical Issues and Secondary Issues 

(4) Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction 

Based on the issues raised in each of these sections, SC&A prepared a list of findings, which are 

provided in the Executive Summary. Issues are designated as findings if SC&A believes that 

they represent deficiencies in the TBD that need to be corrected, and which have the potential to 

have a substantial impact on at least some dose reconstructions. Issues can also be designated as 

Secondary Issues if they simply raise questions, which, if addressed, would further improve the 

TBD and may possibly reveal deficiencies that will need to be addressed in future revisions of 

the TBD.
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3.0 VERTICAL ISSUES AND SECONDARY ISSUES 

SC&A has developed a list of key issues regarding the Sandia National Laboratories in 

Albuquerque, New Mexico, and the Tonopah Test Range, Nevada Site Profile. These issues 

relate to each of the five objectives defined in SC&A’s review procedures (SC&A 2004). Some 

issues are related to a particular objective, while others cover several objectives. Many of the 

issues raised below are applicable to other DOE and Atomic Weapons Employer sites, and 

should be considered in the preparation and revision of other site profiles. 

3.1 POTENTIAL SHORTCOMINGS EXIST IN COMPLETENESS AND 

ADEQUACY OF DOSIMETRY RECORDS 

The completeness, accuracy, and availability of data for use in dose reconstruction and as a basis 

for the internal coworker approach should be validated to demonstrate its usefulness. Several 

potential shortcomings were noted in regard to bioassay data, incident data, and the verification 

of information from external sources. 

First, bioassay records before 1989 have been found in paper or microfiche format in the data 

archive; however, the records are limited to uranium, plutonium, and tritium bioassay, and are 

not typically located and incorporated by SNL as a part of the claimant file. Data provided to 

NIOSH for dose reconstruction are limited to summary reports, including dose information in 

some years for tritium, plutonium, and uranium. The limited hardcopy bioassay data appear 

indicative of incomplete individual exposure files and/or a limited bioassay program. 

Likewise, with respect to completeness of scope, the site profile does not fully address the 

significance of radiological incidents (onsite and offsite), how they may have contributed to 

worker dose, where information is provided in individual exposure records, and how the 

incidents should be addressed in dose reconstruction. Claimant data, relying primarily on 

summary reports, do not consistently incorporate exposures arising from onsite or offsite 

incidents. The TBD itself acknowledges offsite occupational exposures to unencapsulated 

radioactive materials, for which no bioassay data exist. Many of these situations involved 

exposure to fission and activation products that apparently were not found in the archived 

bioassay data. In addition, it is not clear that the accuracy of data from offsite sources [e.g., the 

bioassay services contractor, Controls for Environmental Pollution (CEP), and LANL] has been 

considered in the evaluation of data. 

In light of these key questions, the verification process should be reviewed to assure that internal 

dosimetry information provided to dose reconstructors is accurate, complete, and consistent. 

Where data gaps cannot be corrected, clear instructions should be provided to allow for a 

consistent and claimant-favorable approach to dose reconstruction. 

Data Completeness 

There is limited bioassay data available for SNL workers prior to 1992, when a routine 

monitoring program was implemented. The TBD indicates that archived records contain data for 

uranium, plutonium, and tritium. Analysis of the source terms indicates that individuals were 
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exposed to tritium (H-3), uranium (U-234, U-235, and U-238), fission and activation products 

(e.g., Sr-90, Cs-137, Zn-65, Co-60, Ta-182), plutonium (Pu-238, Pu-239, Pu-240, and Pu-241), 

and americium (Am-241), yet adequate bioassay data is not available for several of these 

nuclides. The bioassay data available at SNL are minimal prior to 1970, and consists primarily 

of tritium data. The TBD indicates there are few bioassay results available in the electronic 

record, and these records may be incomplete: 

There are few results of bioassay of individual SNL workers found in the electronic 

records prior to 1989. (ORAUT 2007a, pg. 61) 

Also, the potential exists that not all of the early bioassay records have been 

transferred to the current database. These early records were transferred to 

microfilm or microfiche beginning in 1967 (Argall 2007b) and a summary of the 

resultant dose (or 0.00 rem if the results were <MDA) was entered into an 

electronic database. However, this information may not have been captured in 

the current database and thus not provided with the dose records supplied by 

DOE. (ORAUT 2007a, pg. 95) 

Furthermore, the 1991 DOE “Tiger Team” assessment of SNL (DOE 1990) found several 

deficiencies regarding accuracy and completeness of personnel radiation dosimetry: 

Personnel exposure files do not contain all the radiological information related to 

personal exposures and radiation working conditions as required by DOE Order 

5480.11. 

A documented ORAUT communication regarding the availability of early SNL bioassay records 

for use in development of a coworker model indicates that “a further search of records for old 

bioassay data at this time would not be warranted” (Connell 2006). A recently retired SNL 

employee stated that SNL already searched for the pre-1992 records without success (Connell 

2006). NIOSH/ORAUT indicates in the TBD that they are conducting additional data retrieval 

efforts to obtain additional individual bioassay information: 

Recent data capture efforts at SNL have identified large volumes of bioassay data. 

These data will be used in the coworker analysis. Once this analysis is completed 

the TBD will be revised to incorporate the use of these data for claims that 

warrant an internal dose assessment but lack monitoring data in their case files 

provided by DOE. 

In light of prior decisions against further retrieval efforts, there appears to be significant doubt 

that existing data archives will resolve all concerns about the adequacy of internal dose 

information. The records in question originated prior to 1989, and retrieval can be labor 

intensive. Although the TBD indicates that data searches are performed as claims are received, 

the extent of such searches is not well defined, and it is not clearly stated that SNL is including 

archived data in the individual radiation exposure files. The internal dosimetry TBD 

acknowledges potential exposures to fission and activation products and pure americium, none of 

which are mentioned in regard to archived dosimetry records. If the archives contain dosimetry 
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records that can contribute relevant dose information to the claims evaluations, a comprehensive 

search of hardcopy monitoring data and subsequent validation of these hardcopy records against 

the electronic data should be pursued, particularly given the apparent limited internal monitoring 

conducted at SNL. Where gaps cannot be resolved from existing records, the TBD should 

address the feasibility of adequate dose reconstruction. 

Data Accuracy 

Historically, SNL relied heavily on outside vendors to provide bioassay data. Concerns about 

the accuracy and completeness of data from these support contractors have not been fully 

considered in the SNL TBD. 

The SNL TBD indicates dosimetry services were provided by LANL for some periods of time: 

Also, it is likely the bioassay records and external dosimetry records for workers 

employed by SNL prior to November 1, 1949 [Argall 2007c] when the Z-Division 

officially separated from LANL, may only be located in the LANL Bioassay 

database. (ORAUT 2007a, pg. 60) 

The TBD also states the following: 

Because of statements made during interviews with individuals currently involved with 

the bioassay program, out-sourced bioassay and a Memorandum of Understanding with 

LANL were considered to be the prime source of bioassay results for years before 1991. 

(ORAUT 2007a, pg. 60) 

The LANL Bioassay Repository database, used to provide information for LANL claimants and 

evaluated in the LANL site profile review, has been found to be incomplete (SC&A 2006). It is 

unclear whether and where Po-210 urinalysis data and other bioassay data have been fully 

incorporated into the LANL Bioassay Repository. Furthermore, verification and validation have 

only been partially completed, and may raise questions regarding the completeness and accuracy 

of internal dose estimates. 

In the evaluation report for LANL, data deficiencies were identified for particular radionuclides 

and time periods at LANL. Table 1, a recreation of Table 7-8 from the LANL petition 

evaluation report, specifies data deficiencies by period and radionuclide. 
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Table 1. Summary of LANL Data Deficiencies listed by Period and Radionuclides 

(Source: Vitkus et al. 2007) 

 

Period Radionuclides with No Reconstruction Data or Method 

1943–1949 Tritium, MPF/MAP, Am-241 (if no Pu data and pending validation of newly identified bioassay 

data), Th-232, Th-230, Ac-227, Pa-231, and Cm-244 

1950–1969 MPF/MAP (without the validation of the newly identified air monitoring data), Am-241 (if no Pu 

data or from “pure” process), Th-232, Th-230, Ac-227, Pa-231, Np-237, and Cm-244. 

1970–1975(a) MPF/MAP, Am-241 (if no Pu data or from “pure” process), Th-232, Th-230, Ac-227, Pa-231, 

Np-237, and Cm-244. 

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

time of this report, an analysis of this technique has not been performed. This technique most likely could not 

be used for Cm-244 due to the 18.7-y half-life and with only a 10% yield 14 keV x-ray. References to direct 

work with Cm end in 1975, other than burial grounds and minor residual contamination in TA-1 Building 3 and 

ML. 

If LANL was the prime source of bioassay results for the years before 1991, this could have a 

significant impact on the internal dose assessments of SNL workers. Data deficiencies during 

the 1943–1949 time period would clearly impair the ability to conduct dose reconstructions on 

SNL workers who were a part of the Z-division of LANL during this time. From 1950 to 1975, 

there are data deficiencies for mixed fission products/mixed activation products (MFP/MAP), 

which have been identified as a major contributor to internal dose at SNL. SNL housed several 

reactors and accelerators, and was heavily involved in testing that potentially resulted in 

exposures to fission and activation products. 

The SNL TBD is incomplete in its consideration of missed dose to unmonitored exposed workers 

potentially exposed to all the various MFPs and MAPs, including activation products produced 

by accelerators. Whole-body and lung counting were the primary methods for determining 

intakes of fission and activation products; however, these were performed as a result of 

suspected intakes and not as a routine monitoring program. It is noted on page 80 that SNL has 

always been a center for research, and small-scale use of various radionuclides occurred 

throughout the history of the site. Little or no documentation has been found on bioassay for 

these nuclides. Instructions given in Section 5.5.3 only hold true if the work records are 

complete and specific about the work areas to which the individuals were assigned. Certainly 

next-of-kin claimants will not be able to provide helpful information on worker locations, given 

the fact that NIOSH recognizes on page 57 that many of the exposure histories and work records 

are not specific about the work areas to which individuals were assigned. 

In addition to concerns regarding LANL bioassay data, the SNL TBD describes bioassay results 

from a commercial laboratory, CEP, that were invalidated due to inappropriate process and data 

integrity (ORAUT 2007a, pg. 59): 

The results of bioassay samples analyzed between August 1992 and April 1994 by 

a commercial laboratory were invalidated based on the results of spike samples 

and other issues surrounding the integrity of the data (Potter 1994; DOE 1994). 

No explanation is provided, however, on how the TBD will address acute uptakes that may have 

occurred during this time period. Considering the importance of bioassay data from LANL and 
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CEP, further verification of data completeness and accuracy is warranted. It would be highly 

desirable for the verification and validation process to be used and identified in the revised site 

profile. 

Incidents 

The site profile does not fully address the significance of radiological incidents, how they may 

have contributed to worker dose, and how they would be addressed in dose reconstruction (this 

issue has been addressed in other site profiles, albeit inconsistently). It is not likely that NIOSH 

has specific information on who was monitored and who was not, how samples were collected 

during such incidents, and how these samples were handled and processed, especially in the early 

days. The data provided by SNL is limited to summary data and does not appear to include any 

information on personal contamination or incidents. 

Incidents and accidents are mentioned twice in the TBD, but apparent discrepancies exist. Under 

Section 2.5, Major Site Incidents, a single incident is called out: 

A single incident of “serious overexposure” at SNL occurred in 1960.... No other 

major site incidents were ever recorded at SNL. (ORAUT 2007a, pg. 20) 

Later in the document, Table 5-32 lists 12 additional exposure incidents occurring between 1967 

and 1993 (ORAUT 2007a, pg. 95). The listing of 12 exposure incidents appears to conflict with 

the statement that there was only 1 major incident at SNL. Large gaps appear to exist for 

incidents in the early years, with the TBD listing only one incident in 1960 and no incidents prior 

to 1960 or from 1961–1966. Experience with other sites indicates that incidents were not 

routinely recorded in the early years, but were significant when they occurred. Furthermore, 

little consideration is given to episodic environmental releases. The TBD should investigate the 

existence of an incident database or other source material for radiological incidents. These data 

could be valuable in the evaluation of external, internal, and environmental dose. 

While it is clear that judgment needs to be exercised regarding what accidents and incidents need 

to be reviewed and included in site profile characterization, it is important to identify available 

information regarding key accidents and incidents and assure their availability and use by dose 

reconstructors. This is especially true when worker radiation exposure files do not contain all the 

radiological information related to personal exposure. It is also important, for the site profile to 

evaluate this accident history for its implications to dosimetry adequacy and the completeness of 

dose reconstruction data. Furthermore, the inclusion of all personnel monitoring data from 

classified incidents in individual radiation exposure files should be verified. 

Other Records Issues 

Additional data may exist for early SNL workers in the Medical Records at LANL. In a report 

on the LANL radiological records program, reference is made to radiation data in Medical 

Records: 
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Prior to January 1953, all exposures to beta and gamma radiation were reported 

to Medical Records for transposing into each individual Personnel Medical File.

(LANL 1956) 

Records found in medical files included hazard reports, whole-body and extremity dose 

information, nasal count data, personnel exposure record – airborne contamination reports, and 

incident reports. These records were not available in the corresponding radiological files 

examined. The hazard reports provide information on radiological hazards to which an 

individual was exposed during the course of their work (i.e., uranium, plutonium, polonium, 

beta, neutron x-ray, gamma, or other sources of radiation). Routine and special nasal counts 

from the 1940s reside in the medical file. Reports such as those labeled “Personnel exposure 

record – Airborne contamination” provide airborne concentration data for areas where an 

individual was assigned. These data should be requested for Z-Division workers in addition to 

occupational x-ray and incident reports from medical records provided by LANL staff. At the 

present time, the additional radiological information is not provided in the claimant package, 

underscoring the importance of verifying the completeness of information received for dose 

reconstruction. 

No references have been provided concerning the details associated with stockpile stewardship, 

weapons storage, or offsite assembly, disassembly, and retrofitting. More detail on particular 

radionuclides of concern for the SNL managed storage sites should be provided to the dose 

reconstructor. 

 

In summary, apparent shortcomings in the completeness, accuracy, and availability of radiation 

dose data should be addressed in any ongoing revision of the SNL site profile report. The SNL 

electronic database is incomplete, and hardcopy bioassay records are not complete in individual 

radiation exposure files and lack data regarding specific radionuclides to which workers were 

potentially exposed. Additionally, the adequacy of offsite vendor data is suspect, suggesting a 

need for further verification of data completeness and accuracy. Exposure data for workers at 

offsite facilities frequented by SNL workers (e.g., atmospheric nuclear weapons testing) may not 

be readily available and need to be addressed for the benefit of the dose reconstructor. In light of 

these shortcomings, the verification process for determining the completeness and consistency of 

the internal dosimetry information provided electronically, in hard copy, and from other sites 

requires careful consideration for use in dose reconstruction. 

3.2 INACCURATE DOSE RECORDS FOR REACTOR PERSONNEL 

The Sandia Pulse Reactor (SPR-1) facility was operational from October 1962 to June 1969, 

with successive reactor designs (SPR-2 and 3) becoming operational up through the present. 

External doses received by reactor operators (approximately 4–6 individuals at any given time) 

were among the highest recorded at SNL over that time period, due to elevated radiation fields 

present during shutdown maintenance periods and the proximity of personnel conducting these 

activities. A review of SNL’s “Incident/Unusually High Radiation Exposures,” by organization 
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and by year from 1979 to 1989 (SNL 1979–1989),1 showed that half or more of these high 

exposures were being received by SPR personnel. These annual doses were compiled by SNL 

management for those individuals receiving 0.5 rem or more; for SPR reactor operators, the 

range of annual external doses received for the sampled period of 1979–1989 ranged up to 

2.74 rem, with cumulative doses for some operators as high as 37.7 rem for 1989 and 20 rem for 

1988. 

In fact, the persistent high exposure level of the SPR operators was of such concern at SNL that 

steps were taken beginning in 1982 via a “SPR Dose Reduction Project” (Philbin 1982) to 

review exposure data, identify dose reduction strategies, and design a reactor maintenance shield 

for use during maintenance activities. From interviews (Attachment 2), it was also indicated that 

additional reactor workers needed to be recruited, given the “burn” rate of these high dose 

activities. An August 24, 1982, memorandum from the DOE Albuquerque field office manager 

(R. Romatowski) to the SNL Director (A. Narath) further expressed concerns over elevated 

doses at SPR, suggesting that the 5-rem annual dose limit was too often being viewed merely as 

an operational target, with “minimum annual exposure per individual [varying] from 3.5 to 

4.5 REM,” ignoring the tenets of the “as low as reasonably achievable” (ALARA) guidance 

(Romatowski 1982). 

In April 1982, a meeting was held at SNL Area V (where SPR is sited) to discuss a recently 

discovered dosimetry issue bearing on the exposures monitored at SPR (SNL 1982). An SNL 

health physicist indicated that SPR personnel performing “lower stand” maintenance activities 

during reactor shutdowns had been working in a radiation field involving a “severe gradient,” 

with the following findings: 

The dose to the head could be as much as five times as great as to the body. At 

the beginning of the quarter, only one badge was worn per person during any two 

week period. That badge was worn in various locations depending on the 

individual involved. The locations varied from the shirt collar to the pants 

pocket. During the second week of February [1982], it was found that the 

gradient existed especially when personnel performed lower stand maintenance 

on SPR III. To attempt to account for the difference, all personnel began to wear 

head badges in addition to the normal body badge. After these badges were 

processed, it became apparent that the doses to the head (and to the lens of the 

eye) were significantly larger than the whole body doses. (SNL 1982) 

From interviews with longstanding SNL health physics personnel (see Attachment 2), it was 

learned that the average ratio between doses received by the head versus the trunk in these 

maintenance activities was about 1.75 (i.e., the head received almost double the exposure of the 

trunk) after the maintenance shield (or shroud) was installed in the early 1980s. However, health 

physics personnel added that this ratio would have been much higher (than 1.75) before the 

shroud was installed. While some attempt was made to incorporate head dose readings in 

estimating whole-body dose for 1982 and forward in time, it is unclear to what extent that was 

1

 SNL (Sandia National Laboratories) 1979–1989 developed a listing of incidents/unusually high radiation 

exposures that is included in archive file box #121072. Also included are unofficial annual compilations of SNL 

employees with radiation dose equal to or in excess of 0.50 rem. 
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done, because head dosimeters were not always worn by workers in later years (i.e., not enforced 

by management). Based on the same feedback, it is apparent that no attempt was made to 

correct the pre-1982 dose records for the SPR reactor operators involved. 

The implications for dose reconstruction are clear. The SPR operators were among the highest 

exposed at SNL, with quarterly and annual doses approaching specified DOE dose limits 

(5 rem/year), with 3 rem/quarter before 1988 in a number of cases year after year. Lack of an 

adjustment for the severe exposure gradient found at the SPR of a factor of 1.75 or more would 

lead to a significant underestimation of external dose. The post-1982 dose reconstruction for 

these workers would also need to reflect some evaluation of the approach taken by SNL over that 

time period to accommodate this exposure gradient when they assigned the dose of record. The 

current version of the site profile does not acknowledge this issue or provide a means for the 

dose reconstructor to make necessary adjustments in dosimetry calculations. 

3.3 SITE-WIDE WORKERS NOT BIOASSAYED FOR POTENTIAL INTERNAL 

INTAKES BEFORE 1992 

Section 5.5 of the site profile provides the dose reconstructor instruction that when a worker does 

not have monitoring results in the DOE records, their work locations should be reviewed and 

potential for exposure determined for these locations: 

When a worker does not have monitoring results in the DOE records, their work 

locations should be reviewed. These locations should be compared to the 

radioactive materials listed for locations in previous sections. Job titles are not 

necessarily the most accurate indicator of potential for exposure. (ORAUT 

2007a, pg. 95) 

This instruction is problematic in light of the statement made earlier in the TBD: 

Many of the exposure histories and work records are not specific about the work 

areas to which individuals were assigned. However, when information about the 

work location is available, Table 5-1 can be used to determine probable nuclides. 

(ORAUT 2007a, pg. 57) 

Work area information that is either absent or inadequate makes determining whether exposures 

have occurred (and to which radioisotopes) difficult, if not impossible. Likewise, for site-wide 

workers (e.g., security guards and maintenance personnel), their routine access to a broad range 

of SNL radiological facilities and sites would make such source term assignments particularly 

problematic, if it is not feasible to identify their work locations. When specific work areas are 

not identified in the records provided by DOE, the dose reconstructor does not have a sufficient 

basis for utilizing the information in 

Table 5-1, which highlights potential radionuclides of concern by work area. The TBD has not 

presented a mechanism for assigning dose to site-wide workers in the absence of routine 

bioassay results. 
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One worker category—security inspectors or guards—illustrates the difficulty in applying the 

TBD’s work area criteria to site-wide workers. The site profile states in Section 5.1.2 (“The 

Bioassay Program”) that “security inspectors were required to participate in a routine bioassay 

program and have annual whole-body counts and urinalyses.” However, as indicated elsewhere 

in the site profile, a formal routine bioassay program did not exist at SNL prior to 1992, although 

bioassays were apparently provided to workers judged to have a potential for intake above 

administrative levels. Security guards and other support workers having site-wide access to 

radiological areas (e.g., maintenance and cleanup personnel) would have had unrestricted access 

to experimental sites and contaminated areas. From interviews with guards with tenures prior to 

1992 (see Attachment 2), it is clear that they were required to stand guard where special nuclear 

material (plutonium and enriched uranium) was being handled, and where radiological 

components containing DU and thorium were being tested. They were likewise required to 

conduct routine surveillance of all SNL facilities and areas, some of which were contaminated. 

However, from their recollection, they were never bioassayed (the only “urine samples” they 

provided were apparently for their annual physical health examinations). One guard indicated 

that he actually wore self-contained breathing apparatus at a highly contaminated site, but was 

not bioassayed afterwards. He also indicated that guards would routinely eat their lunches while 

on station in radiological areas. The facility-specific means of assigning missing dose due to 

assumed radiological source terms (as applied in the site profile) would not be feasible for such 

workers because of their site-wide access to a range of potential sources that had the potential for 

intakes. Therefore, a means of dose estimation for this cohort of workers is not evident in the 

site profile. 

Therefore, it is of concern to SC&A that prior to 1992, when no formal routine bioassay program 

existed at SNL, workers in areas containing radioactive materials may have had the potential for 

internal exposures that would not have been monitored, and with their work areas in many cases 

being unknown, a backup means of estimating dose is not apparent in the TBD. The instructions 

given the dose reconstructors in the site profile do not appear to be adequate for determining or 

quantifying the radioactive isotopes to which unmonitored or even monitored workers may have 

been exposed. Assigning potential missed dose by work location is questionable, particularly in 

the absence of complete work history records. Furthermore, the feasibility of this approach is 

questionable for site-wide workers and workers involved in offsite activities in Nevada and other 

locations. In cases where work area information is not available, the TBD should provide further 

instruction. 

3.4 USE OF AIR MONITORING DATA IN DOSE ESTIMATION IS PROBLEMATIC 

There was no formal routine bioassay monitoring program and little documentation existed 

regarding the internal dosimetry program before 1992. The site profile notes that routine 

bioassay sampling was not a general practice, and bioassay was confined to suspected intakes of 

radioactive materials or when a worker exceeded an administrative threshold. Less than 100 

individuals participated in the bioassay program each year from the beginning of the program 

through 1991. ORAUT-TKBS-0037 (ORAUT 2007a) notes that the potential for monitored and 

unmonitored intakes has existed throughout the history of the site. 
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The trigger for special sampling was based on field indicators, such as incidents, high results of 

air sampling, Continuous Air Monitor (CAM) alarms, and/or nasal swipes. In lieu of bioassay 

samples, the TBD recommends intakes be derived from airborne contamination levels (ORAUT 

2007a, Section 5.4.2): 

Intake parameters can be derived from airborne contamination levels for 

buildings with the highest exposure potential or highest intakes for various 

periods. Maximum and average airborne contamination levels for selected 

buildings are listed in Table 5-29. Examples of incidents and intakes are listed in 

Table 5-32. Average airborne contamination levels either are derived as simple 

averages or are reported as averages listed in reports. Simple averaging is 

assumed for SNL reports, but no information on the methods used to obtain these 

reported averages is available.

There are several issues associated with the use of air sampling as a means of determining 

potential internal exposures. The following statement is a well documented fact [and affirmed in 

Whicker et al. (1997) and the SNL Site Profile in the Occupational Internal Dosimetry TBD]: 

 ...selection of the location of the CAM was critical to the reliability of the 

response. The typical location of CAMs at the ventilation exhaust point of a 

room was not considered optimal. Results also suggest that when a worker 

causes the release and is at or near the release point, the worker could be 

exposed for a significant period before a radioactive cloud reaches the CAM. 

[These] ...limitations suggest that, without other interventions, the possibility 

exists that workers could be exposed to intakes that did not trigger alarms.

The TBD (pg. 93) states that CAMs were placed near the point of release where the air 

concentration would be at a maximum as a backup detection device. SC&A does not understand 

this statement. First, how can one determine in advance where a point of release is going to 

occur? Second, if the CAMs were placed at the point of release after the release incident, this 

would not necessarily represent the exposure the workers would have experienced. 

The TBD [page 91 of ORAUT-TKBS-0037 (ORAUT 2007a)] further states the following: 

Studies have shown that room air concentration is not necessarily an accurate 

predictor of intake because of the variations in respiratory conditions and 

particle dispersion within an area. Even BZA samples are not always an accurate 

predictor of the amount of intake (Whicker 2004). However, maximum and 

average airborne concentrations can be helpful in establishing boundary 

conditions for intakes or for determining which locations had potential for 

inhalation intakes. 

Whicker et al. (1997) notes that air sampling and CAMs are not dependable for predicting 

intakes because of the locations of the monitoring devices with respect to the workers and the air 

flows in work areas. Workers may be exposed for significant periods before a radioactive cloud 

reaches the CAM or air sampler, and the possibility exists that workers could be exposed to 
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intakes that did not trigger alarms. The air reaching the air sampler may not be at all 

representative of the air to which the worker was exposed. Simple averaging without 

information on the method used does not appear to maximize the intake parameter assumptions. 

The general area air sample results available to NIOSH and the dose reconstructors do not appear 

to be useful for adequately bounding the potential air concentrations that may have existed in the 

breathing zones of workers potentially exposed to uranium, plutonium, tritium, or mixed fission 

and activation products at the site. 

Section 5.4 (pg. 91) of the TBD also states the following: 

Airborne concentrations were not available for all years of operation, especially 

for fission products. The reported results often do not include the volume of air 

through the filter; therefore, it is not possible to determine the actual airborne 

concentration. 

It was noted in concern #393 (page 1,322) of the Tiger Team Report (DOE 1992a) that personnel 

were permitted to enter and work in areas with potential airborne contaminants that had not been 

monitored, as required by DOE Order 5480.11 (DOE 1988). The Tiger Team report also noted 

in concern #392 (DOE 1992a) the occurrence of incorrect readings for Remote Area Monitors, 

and in concern #391, that readings were not being taken while radiation instruments were 

removed for calibration. These Tiger Team findings and those noted in the beginning of this 

Section 5 are highly indicative of the likelihood that potential uptakes occurred during operations 

at the site, as well as at sites visited by SNL workers, that were likely not monitored and 

recorded. 

The fact that the TBD even notes that airborne concentrations are not available for all years of 

operation, especially for fission products; that air volumes through the filters are often not 

included, so airborne concentrations cannot be determined; that Remote Area Monitors indicated 

incorrect readings; and that simple averaging of airborne contamination levels was assumed, but 

no information on the methods used to obtain these averages is available makes the TBDstipulated use of air monitoring data for dose reconstruction highly questionable. 

Again, general area air results available to NIOSH and the dose reconstructors do not appear to 

be useful for adequately bounding the potential air concentrations for any of the radionuclides 

that may have existed in the breathing zones of workers/claimants. This is true for both onsite 

work activities, as well as work performed offsite in research, weapons testing, and weapons 

stockpile maintenance and surveillance conducted by SNL workers. 

Bioassay monitoring of workers was primarily dependent on the air monitoring program, as 

opposed to and in default of a routine bioassay monitoring program. With inadequate air 

sampling or no air sampling data at all, this brings into question the effectiveness of the special 

bioassay monitoring program and the use of air sampling data as a substitute for bioassay 

sampling. It certainly appears that without routine bioassay monitoring, dependence upon air 

sampling for detecting exposures to workers likely led to unmonitored intakes by workers over 

the years at SNL, or intakes that could not be measured or estimated accurately due to use of area 
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air monitoring data. Furthermore, reliance on field indicators to trigger special bioassay, 

particularly in areas where air monitoring equipment placement is inadequate or non-existent, is 

problematic. Some consideration should be given in the TBD to the representativeness of the 

sampling and the consistent use of field indicators as a trigger for bioassay. 

3.5 INADEQUATE TREATMENT OF POTENTIAL RADIOLOGICAL EXPOSURE 

SOURCES 

The predominant radionuclides encountered at SNL are tritium, uranium, and fission and 

activation products (e.g., Sr-90, Cs-137, Zn-65, Co-60, and Ta-182). Other radionuclides 

handled at SNL included plutonium (Pu-238, Pu-239, Pu-240, Pu-241), americium (Am-241), 

Tc-Mo-99, Po-210, radium, thorium (Th-228, Th-232), U-233, Cm-244, Cf-252, C-14, Na-22, 

Se-75, P-32, S-35, I-125, I-131, N-13, O-15, and other accelerator activation products. The 

quantities handled ranged from fractions of a gram to kilograms. These potential radiological 

exposure sources are identified and addressed in the site profile, but other pertinent sources are 

not. 

One such area is onsite waste disposal. Wastes disposed in pits during the early years included 

uranium (depleted, natural, and enriched), thorium, barium, enriched lithium, tritium beds, 

neutron generator tubes and targets, plutonium contaminated wastes, and plutonium 

contaminated weapons test debris from the NTS. An analysis of these waste streams from the 

standpoint of occupational radiological significance should be conducted and additional 

radionuclides of concern identified. 

Another radiological source that can be better characterized for the benefit of dose reconstructors 

is accelerators. Radiation exposure at SNL accelerators includes hazards from prompt radiation 

generated by intentional or accidental beam losses in the beam line. The principal hazards are 

photons and neutrons. Without appropriate shielding, skyshine can likewise be a problem. 

Induced activity can occur in beam-line components, cooling water for components, air (e.g., 

N-13 and O-15), shielding material, the ground, and groundwater. The possible impact from 

photo-fission also should be considered, where fissile materials are used as targets. While there 

is typically a delay period prior to entry into the accelerator area that serves to reduce potential 

exposures, entry may still involve some exposure as a function of target material, maintenance 

required, and experimental exigencies. The TBD needs to review such potential radiation 

sources and characterize their significance. 

Analysis of Available Bioassay Data 

The TBD indicates routine sampling was not a general practice, and that bioassay was performed 

in response to suspected uptakes of radioactive material or when a worker exceeded an 

administrative threshold (Hasenkamp 1961). NIOSH captured a collection of bioassay data from 

the archives at SNL, which they indicate will be considered in the update of the site profile. 

Little information is provided regarding the bioassay data available from the SNL records 

archive. A brief review of the bioassay sampling data for SNL workers available on the NIOSH 

Site Research Database indicates gross alpha, gross beta, plutonium, tritium, and uranium results 

are available back to the 1950s. A majority of these samples were collected for tritium analysis. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

Limited samples were collected for plutonium, uranium, gross alpha and gross beta analysis. 

Very few bioassay samples were obtained for Po-210, Np-237, S-35, actinides, and C-14 through 

the years. In-vivo counting was available for gamma emitters through LANL starting in 1955. 

In 1993, SNL established a whole-body counting program. There are relatively little data 

available on the internal dosimetry program prior to establishment of a formal bioassay program 

in 1992. 

A more detailed analysis of the completeness and representativeness of the archived data is 

needed. Information on types of bioassay available, relative exposure potentials, and work 

locations of individuals who were monitored should be addressed. Since bioassay was 

conducted primarily in response to incidents, it is unclear whether all potentially exposed 

workers were monitored, or even whether the most exposed workers were monitored. 

Uranium 

Depleted, natural, and enriched uranium were handled at SNL. Depleted uranium (DU) was 

encountered at TTR, Coyote Canyon, and weapons storage facilities. Dose assignment to 

unmonitored potentially exposed workers is based on the maximum counts for depleted uranium 

and U-235 taken in 1989 with the Helgeson lung counter. Dose reconstructors are instructed to 

use the maximum results from this dataset for overestimating assumptions. Early uranium 

bioassay data provided total uranium. Although the TBD provides a table of activity fractions, 

information on what enrichments of uranium were handled, in what locations, and for what time 

periods is not clear from the TBD. The use of maximum results for DU and U-235 departs from 

the default assumption in other TBDs, wherein guidance is provided that such activity should be 

attributed to U-234. This is because U-234 is the most significant dose contributor in the decay 

chain of uranium isotopes in natural or enriched uranium sources. There is also no mention of 

assumptions made for workers handling U-233. 

The SNL considered the potential for intakes of uranium to be small, because they considered 

most uranium to be of the nonrespirable particle size (ORAUT 2007a). Thus, incidents 

involving individuals working with uranium may have been considered low risk and not properly 

monitored. However, a number of tests with DU involved high kinetic impacts, explosions, and 

high-temperature burns, all of which would have led to extensive small particle volatization. 

Other examples of potential exposures to uranium are noted in the TBD on pages 75 and 76. 

Likewise, it is noted on page 96 of the TBD that workers handling weapons assemblies at 

weapons storage sites may have been exposed to unsealed uranium, especially before 1957. 

Because no preservative was used in the sample collection bottles, the TBD notes that plating 

occurred. An acid wash would be required to collect the uranium that could have been plated 

out on the surface of the bottle during sample transport and storage. It is not noted in the TBD 

when this problem was discovered and how many years this may have been a problem. If an 

acid wash was not used and less uranium was collected, there would have been an 

underestimation of the amount of uranium uptakes for workers. This problem may also exist 

with the plutonium urine samples that were taken over the same time period, leading to a similar 

underestimation of plutonium uptakes. 
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Plutonium 

While the site profile does address missed intakes for plutonium in the early years on page 67, it 

likewise states that the long-term excretion pattern of plutonium isotopes can permit plutonium 

intakes that produced bioassay results below the detection threshold to become detectable as the 

sensitivity of the analysis technique improved over time. The date of the intake may not be 

directly related to the last bioassay result below the detection level. Although this is all true, the 

workers may have had early plutonium bioassay results below the detection level, and then either 

terminated or retired without further sampling. Thus, significant early intakes of plutonium 

could have been missed in the dose of record. 

Mixed Activation and Fission Products 

It appears that whole-body and lung counting, as well as bioassay analysis, have been done for 

the most likely fission and activation products found at SNL since 1992. However, routine 

bioassay sampling appears to be limited to only several of these, and in-vivo counting done only 

in suspected incidents prior to 1992. It is not clear to SC&A whether termination whole-body or 

lung counts were done for individuals that had worked with fission or activation products prior to 

1992. It is likewise unclear how dose reconstruction is to be done for workers potentially 

exposed to Sr-90. Section 5.2.5 (ORAUT 2007a) states that urinalyses are very sparse, that 

samples were apparently sent to an outside laboratory, and that dose can currently be 

reconstructed only when Sr-90 results are actually listed for an individual. 

Other Radionuclides 

The TBD acknowledges the presence of pure americium, thorium, neptunium, selenium, 

polonium, tantalum, and strontium, yet it is unclear how dose will be assessed to unmonitored 

workers from these radionuclides. The TBD indicates that radionuclides like Se-75 and tantalum 

can be detected in gamma spectroscopy of urine; yet gross gamma data are rare. There is no 

direction provided for how to assess unmonitored dose from thorium. The radionuclides and 

available bioassay techniques should be evaluated to ascertain whether bioassay coverage was 

available for all years of potential exposure. The presumption is that gross beta urine analysis 

can be used to detect mixed fission and activation products; however, gross beta results are 

minimal in the early years. In order to effectively assign unmonitored dose to workers, there 

must be a clear understanding of the time period radionuclides were handled or produced, either 

intentionally or as a byproduct or trace material, and who was potentially exposed. This should 

be evaluated against bioassay available at the time to ascertain whether there was coverage for 

these radionuclides. Air monitoring data is proposed in lieu of personnel monitoring; however, 

there are problems associated with the use of this data to bound internal dose to primary as well 

as secondary radionuclides (see Section 3.4). 

In summary, SC&A finds that further evaluation is warranted for radionuclides handled at SNL 

by workers onsite and offsite to determine the extent of potential exposures, periods of exposure, 

quantities handled, and impacts on dose reconstruction to specific organs. Attempts should be 

made to evaluate archived bioassay data where it is available, and determine whether these data 

are complete and representative enough to develop a bounding or coworker dose. Appropriate 
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methods for internal monitoring were not always available for all years of potential exposure. 

NIOSH/ORAUT should develop missed dose methodologies in the absence of monitoring data, 

based on available data, technical reports, and other sources of information, to ascertain potential 

exposure to non-traditional radionuclides. Additional consideration should be given to the 

exposure hazards associated with operation of accelerators, target handling, component 

activation and byproduct radiation. 

3.6 LACK OF GUIDANCE PROVIDED TO SUPPORT DOSE ESTIMATION FOR 

OFFSITE WORK ACTIVITIES 

Offsite activities and associated exposures are acknowledged, but the importance of involvement 

in these activities is underestimated. Offsite operations involving exposure to radionuclides that 

are not adequately treated in the TBD include the following: 

• Assembly, disassembly, retrofit, and modifications to weapons in the field and at 

assembly plants 

• Firing and arming of weapons for testing 

• Radiation and weapons-effects testing 

• Data collection activities during testing 

• Verification of treaty compliance 

• Response to international radiological emergencies 

Early missions focused on research and development (R&D) for the weapons program and 

subsequent field testing activities. The missions involved considerable work off the SNL New 

Mexico site, as described by the TBD: 

From 1945 to the present, SNL employees have routinely been involved in 

operations at a number of Sandia Corporation sites. These sites include 

Livermore, California; Hattiesburg, Mississippi; NTS, Nevada; Clarksville, 

Tennessee; and Salton Bay Station, California. SNL employees also routinely 

spent time at other DOE facilities.... SNL has also been responsible for 

surveillance of the nation’s stockpiled weapons (Ullrich 1998). Since 1949 when 

weapons storage sites were opened and until 1967, SNL stationed staff at the 

storage sites to monitor, maintain, and assemble the weapons [7]. 

(ORAUT 2007a, pg. 54)

Dose reconstructors are cautioned in the TBD about potential offsite exposure (ORAUT 2007a, 

pg. 95): 

Dose reconstructors should note any indication that a worker might have 

accompanied their equipment to a test site or a weapons storage site where the 

potential for intake could have been higher than at the SNL site where the design 

or fabrication took place. Also, SNL workers assigned to weapons storage sites 

may have handled unsealed materials (McConn 2006) and did not participate in 
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bioassay monitoring programs at the storage site or immediately upon return to 

SNL (Argall 2007a). 

Information available for dose reconstruction, especially for workers involved in testing and 

special projects, is limited, inadequate, and sometimes not available. The TBD indicates that 

exposure data from other sites may not be available in the SNL radiation exposure file (ORAUT 

2007a, pg. 95): 

Dosimetry records from other sites are typically not included in the dosimetry 

records supplied for the SNL site. If records are not found, but exposure at other 

sites is indicated, then these records can be requested or site technical basis 

documents can be consulted. 

The treatment of dose reconstruction for offsite activities in the TBD is inadequate, given the 

limited availability of exposure data for offsite activities and the shortcomings in monitoring that 

may have been conducted at offsite locations. 

Weapons and Components Testing and Monitoring 

As previously mentioned, SNL workers were actively involved in weapons and components 

testing at various locations. In fact, SNL had test locations at the Salton Sea Base, the Tonapah 

Test Range, and Coyote Canyon. The TBD provides some information on weapons tests in 

Table 5-3; however, this is not all-inclusive of the test activities in which SNL was involved 

(ORAUT 2007a): 

Table 5-3 lists some of the weapons tests and other related activities to assist the 

dose reconstructor in identifying terms that might be referenced in personnel 

records or the telephone interview [Argall 2007d]. Workers whose routine jobs 

did not involve work with nuclear materials could have encountered internal 

exposures while participating in weapons testing. 

SNL took a much broader role in weapons testing than the TBD indicates. Its involvement in 

testing included support to atmospheric, underwater, and underground tests. SNL staff first 

became involved in weapons testing during the Able and Baker tests for Operation Crossroads in 

1946: 

Z-Division began moving to Albuquerque in September of 1945, with the field 

testing organization leading the way and the final group arriving in February 

1947.... The group immediately began testing to improve the Fat Man design, 

and initiated development efforts for the new Mk IV, the first new weapon 

designed in the postwar period. However, planning for Operations Crossroads, 

the first postwar nuclear test, interrupted this work. Held in the summer of 1946, 

Crossroads absorbed the attention of Los Alamos and Z-Division months before 

the actual tests. (Ullrich 1998) 
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SNL participated in the evaluation of weapons effects at several atmospheric tests, including 

Operation Sandstone, Operations Ranger, Greenhouse, Buster-Jangle, Tumbler-Snapper, UpshotKnothole, Castle, Ivy, Teapot, Plumbob, Redwing, Hardtack I, Argus, and Hardtack II. They 

participated in weapons effects studies from underwater detonation during Operation Wigwam. 

These operations occurred at the NTS and the PPG from 1948–1958. Arming and firing of test 

devices has been SNL’s responsibility since Operation Greenhouse in 1951 (Banister 1994). The 

TBD’s list of nuclear tests includes only Operation Crossroads, occurring in 1946, and Operation 

Sandstone, occurring in 1948, for the period of atmospheric testing. 

The TBD indicates that SNL was involved in underground testing conducted between 1962 and 

1973. SNL was involved in its first tunnel shot at NTS, the Rainer Shot, in September 1957, 

and continued its involvement until 1992. Detonations of devices in tunnels and drilled shafts 

focused on conducting effects tests to study the response of nuclear weapons to radiation. Other 

studies included ground motion, air pressure, and cratering phenomena studies. SNL continued 

its arming and firing function for Lawrence Livermore National Laboratory (LLNL) shots until 

the end of testing. SNL was also involved in a nonproliferation experiment in 1993 (Banister 

1994). 

Two SNL-sponsored tests, Cypress (February 12, 1969) and Camphor (June 29, 1971) were 

executed in G-tunnel. These tests were conducted to expose components and experiments to 

radiation, and determine the effects. Cypress was successful, but a containment failure occurred 

during the Camphor event, allowing debris to escape into the tunnel (Banister 1994). 

SNL took an active interest in the Plowshare Project. In addition to tests conducted at PPG and 

NTS, SNL workers were involved in studies at Fallon, Nevada; Hattiesburg, Mississippi; 

Farmington, New Mexico; and Colorado. SNL took extensive free-field and surface ground 

motion measurements for the Milrow and Cannikin tests in Amchitka, Alaska, and provided 

arming and firing for Cannikin. 

Other Offsite Activities 

Many of the early component field tests were conducted at Salton Sea Base involved use of Joint 

Test Assemblies (JTAs). Johnson (1996) explains how these tests were conducted: 

 

For quality assurance of the stockpile, a bomb was selected at random and taken 

from the stockpile. After removal of its nuclear core, Sandia replaced the core 

with a Joint Test Assembly (JTA) package that simulated the bomb’s electrical 

functions and transmitted data on how it performed. Sandia then handed it to an 

aircraft crew for use as if during a combat mission. The crew flew to the Salton 

Sea and dropped the bomb on their own. The military service then evaluated the 

crew’s accuracy while Sandia analyzed the bomb performance.... The range 

crew sometimes referred to these as JTA tests. 

The JTA package may have substituted DU for plutonium. As a result, consideration should be 

given to potential exposure at Salton Sea Base. 
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The JTA tests were continued at Yucca Flats and the Tonopah Test Range in Nevada. The TBD 

acknowledges in the site description that testing at TTR involved components containing DU. In 

1962, Project Roller Coaster was initiated, which included a series of four nuclear weapons tests 

that resulted in plutonium dispersal in the surrounding soils. SNL conducted the Double Tracks 

test to investigate the impacts of one-point safety detonations on ground deposition. As a part of 

this test, burros, dogs, and sheep were exposed to respirable amounts of plutonium and uranium. 

Animal stations became contaminated not only from the detonation, but also from the 

contaminated urine and feces excreted by the animals, which contributed to potential plutonium 

exposure. Three Clean Slate shots were designed to compare weapons accidents in open storage, 

storage in igloos, and storage in igloos with earth covers. A minor animal experiment was done 

during Clean Slate 2. Clean Slate tests used plutonium during the detonation experiments, and 

high explosives coupled with uranium as a substitute for plutonium for other tests (NVO 1964). 

About 700 individuals investigated the abilities of weapons storage igloos to contain accidental 

blasts (Johnson 1996). Cleanup occurred following the shots, but further remediation of the area 

was required in 1996 to reduce the level of transuranic radionuclides in some areas to less than or 

equal to 200 pCi/g (Sanchez et al. 2001). Animal housing areas were particularly contaminated. 

SNL participated in One-Point Safety Studies at Coyote Canyon and NTS. A series of nuclear 

device tests with DU were conducted in Coyote Canyon to study fallout and particle sizes from a 

variety of staged accidents. It is clear from the site profile and other operational histories that 

use of DU was prevalent at many of the test sites (e.g., TTR and Coyote canyon), and that tests 

involved repeated kinetic impacting, explosions, and high-temperature burns leading to extensive 

volatization of radiological material. This potential seems to be corroborated by whole-body 

count measurements taken by Hegelson in 1989 (HSS 1989), as cited in the site profile, where 

uptakes of DU and U-235 were noted (notwithstanding that low-level uranium urinalyses were 

often confounded by the elevated natural uranium levels in the local environment). This early 

work eventually led to Project 57 in 1957 and Project Roller Coaster in 1962 (Banister 1994). 

SC&A finds that further research is warranted on hydrodynamic and other field tests conducted 

at this location to better define exposure conditions. 

Adequacy and Completeness of Dose Estimation for Offsite Activities 

Several NIOSH documents indicate an inability to conduct dose reconstruction for specific 

activities in which SNL workers were involved. This is complicated by SNL’s lack of 

monitoring upon return from offsite activities. SNL personnel worked side by side with Alaskan, 

Reynolds Electrical and Engineering Company (REECo), and Pacific Proving Group (PPG) 

workers during atmospheric, underground, and underwater testing. NIOSH has identified 

problems with dose reconstruction for PPG (SEC-00020, Harrison-Maples 2005) and NTS (SEC00055, Harrison-Maples et al. 2006). In their evaluation of the feasibility of completing dose 

reconstruction for employees working at the PPG from 1946 through 1962, NIOSH clearly 

indicates that workers had the potential for internal exposure (Harrison-Maples 2005): 

The principal potential source of internal radiation doses for members of the 

class would have been inhalation or ingestion due to contamination caused by the 

fallout from the nuclear detonations. 
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Furthermore: 

Fallout associated with some of the detonations, both on the land surface and in 

the water, was a potential source of internal exposure. The possibility existed for 

inhalation and ingestion of radiological particles during a fallout event as well as 

exposure to re-suspended fallout remnants at some later date. Radiological 

particles on the land surface could potentially have been disturbed and resuspended by wind, personnel traffic through contamination areas, construction 

activities disturbing contaminated soil, or by decontamination efforts, and been 

inhaled or ingested by personnel operating in contaminated areas (HarrisonMaples, 2005). 

SEC-00020 indicates that due to lack of data, it was not feasible to perform reconstruction of 

internal dose from inhalation of radionuclides at PPG: 

NIOSH finds that the external monitoring records and operational histories 

available are sufficient to complete external dose reconstruction for these 

employees, with the exception of neutron exposure, which was not fully evaluated. 

Existing NIOSH procedures could be used to estimate possible occupational 

medical exposures. However, NIOSH lacks access to source term data, bioassay 

or internal monitoring data to estimate internal doses associated with potential 

inhalation of radionuclides.

The same potential for internal exposure also existed during the atmospheric tests at the NTS. 

SEC-00055 (Harrison-Maples et al. 2006) further indicates that calculation of internal dose is not 

feasible: 

Consequently, based on the available data, NIOSH is unable to estimate with 

sufficient accuracy internal exposures and resulting doses for the class of 

employees covered by this evaluation. The initial class for which feasibility was 

considered by NIOSH in response to SEC Petition SEC-00055 comprised 

laboratory assistants who worked at the NTS from January 27, 1951 through 

December 31, 1962. The basis for the infeasibility of dose reconstruction for the 

petitioner’s specific claim was the inability of NIOSH to adequately address 

potential exposures associated with the changing and undefined source term 

during multiple atmospheric tests at the NTS. While it is very likely that 

individuals in the forward areas during atmospheric nuclear testing would have 

received exposure exceeding those of other groups of workers, NIOSH is unable 

to determine which workers were or were not potentially exposed to the changing 

radiological conditions during atmospheric nuclear testing. 

 

The current class definitions for the PPG and NTS SECs specify DOE employees, contractors or 

subcontractors who were monitored, or should have been monitored, at PPG and NTS, 

respectively. Although SNL scientists and staff were actively involved in testing operations 

along with those employed at PPG and NTS, it is unclear in the SNL TBD how such offsite 

exposures are to be addressed under these circumstances. Furthermore, later testing eras are still 
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being evaluated as part of the NTS SEC petition review. Participation in these events could have 

led to significant internal exposures for some SNL workers and should be thoroughly considered 

in the SNL TBD. 

In summary, SNL took an active role in conducting weapons effects, ground motion, air 

pressure, crater phenomena, and other studies during the testing of weapons. SNL workers were 

responsible for the arming and firing of weapons from 1951 through 1992. They were 

responsible for monitoring, maintaining, and assembling weapons at storage sites. A 

recharacterization of the extent of SNL involvement in weapons testing and other offsite 

activities (e.g., research on hydrodynamic testing, treaty verification, assignments to other DOE 

sites) should be completed. Offsite activities related to the weapons and components testing, 

surveillance, in-field retrofit and modifications, treaty verification, and managing storage sites 

and their corresponding monitoring programs have not been adequately addressed in the SNL 

TBD. This is confounded by the absence of offsite data in the SNL exposure files and the lack of 

direction to the dose reconstructors on when to request data from other sites. 

While it is understood that NIOSH under EEOICPA protocols establish work location, including 

work at other AEC or DOE sites, to enable dosimetry records to be obtained, it is not clear from 

the SNL, NTS, or PPG site profiles how visiting SNL employees were monitored for neutron and 

internal radiation exposures. Internal and external exposure hazards during field testing require 

further consideration to determine if appropriate internal and external monitoring occurred. If 

adequate monitoring did not occur at these offsite work locations, the TBD does not provide 

instructions for bounding these potential exposures. A missed dose methodology should be 

included for unmonitored or inadequately monitored workers who participated in weapons 

testing and other field activities. Where available, references to other site profiles are 

appropriate. Methodologies for activities at continental tests outside of Nevada require treatment 

in the site profile, a separate site profile, or a TIB. 

3.7 THE MAXIMIZING AND BEST-ESTIMATE INTAKE PARAMETERS FOR 

TRITIUM MAY NOT BE APPROPRIATE 

The potential for tritium exposure in multiple forms existed at SNL. Tritium is a radionuclide 

with wide historical and current application at SNL. It is also encountered as a significant 

contaminant on tools, parts and surfaces, and targets. Table 5-1 of the TBD indicates tritium use 

in Buildings 891, 884, 807, 844, and 819, Technical Area (TA)-II and TA-III, the Particle Beam 

Fusion Accelerator (PBFA)-II, the Sandia Accelerator and Beam Research Experiment 

(SABRE), the Annular Core Research Reactor, Hot Cell Facility, and the SPR. Tritium was (and 

is) encountered in several forms; tritiated water (HTO), tritiated gas (HT), organically bound 

tritium (OBT), and metal tritides (MTs). 

Unclear and sometimes conflicting instructions are provided to dose reconstructors regarding 

tritium dose assignment. Page 96 of the SNL TBD states the following: 

Chronic intakes of tritium are possible and not uncommon as shown in the 

summary of 1989 tritium bioassay results by Hallman (1990) —“several 

workers had bioassay results between 10 and 74 μCi/L in 1989.” — These 
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maximum results can be used to determine overestimating doses for unmonitored 

workers. However, there is no evidence to suggest that workers with potential 

for tritium intake were not monitored. [Emphasis added.] 

Monitoring frequencies were established such that acute uptakes of HT and HTO could be 

missed. Potential tritium uptakes are assumed to be from HTO, when exposures actually may be 

from special tritium compounds (STCs). Tritium urine sampling began at SNL in 1949 (Argall 

2007b). Although tritium urinalysis existed, urine sampling for tritium was done quarterly. This 

is ineffective and inadequate in many cases for tritium uptakes in the form of HT or HTO, 

because the effective half-life in the body is substantially shorter than 3 months. A weekly 

sampling frequency is typically recommended for exposed workers in order to capture acute 

intakes. The urine bioassay data for tritium dose reconstruction is thus very suspect and may be 

of little value for use by the dose reconstructors, given the relatively short biological half-life of 

tritium in the body. 

In the absence of bioassay data, the worker is assigned the maximum dose as determined by a set 

of tritium bioassay results from several workers in 1989 and after. The representativeness of 

these workers, as compared with all workers exposed to tritium, is not discussed in the TBD. As 

an alternative to bioassay sampling, the TBD recommends the use of air sampling. ORAUTTKBS-0037 (ORAUT 2007a, pg. 94) states the following: 

 

Maximum and average airborne contamination levels for selected buildings are 

listed in Table 5-29. Examples of incidents and intakes are listed in Table 5-32. 

Average airborne contamination levels either are derived as simple averages or 

are reported as averages listed in reports. Simple averaging is assumed for SNL 

reports, but no information on the methods used to obtain these reported averages 

is available. 

The problems of simple averaging have been addressed in Issue 3.4 regarding the use of air 

sampling data. Likewise, this approach appears to be inappropriate for maximizing and bestestimating tritium intake, particularly when one looks at the tritium contamination levels in 

Buildings 642, 805, and 806, and statements made in Section 5.2.3, page 72, of the TBD 

(ORAUT 2007a): 

Smear surveys of Building 642 in 1972 indicated significant tritium contamination 

on tools and target area parts. Some smears indicated more than 5 × 106 dpm of 

tritium on parts and surfaces, especially those related to the target. 

Contamination was also found on the floors of the area. Buildings 805 and 806 

are also a potential source of intakes — “Smearable tritium of 2000 dpm or less 

was considered a clean area. 

The TBD further states on page 74 that for tritium intakes, an administrative control was 

established for individuals with urine bioassay of 20 μCi/L (which represented approximately 

0.25 rem or 1/20 of the 5 rem annual dose from AEC requirements). Workers who exceeded this 

administrative control would have been excluded from tritium work until they reached 10 μCi/L. 

Is this administrative control an arbitrary value established by SNL? Does this mean that 10 
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μCi/L is the chronic missed dose that NIOSH will be using for all tritium workers and security 

inspectors that used tritium sights on their M-16 rifles? The approach provided for assigning 

tritium dose for monitored workers at LLNL (ORAUT 2007a, pg. 74) appears logical, but it is 

not clear if this will be the assigned chronic dose for SNL employees working in tritium areas. 

The TBD directs the dose reconstructor to assume HTO in the absence of compound specific 

data or work area. The TBD refers the dose reconstructor to specific guidance provided in 

Tritium Calculations with IMBA (NIOSH 2003), when the dose records indicate an exposure to 

tritium labeled compounds. Additional guidance is available in Calculation of Dose from 

Special Tritium Compounds, OTIB-0066 (ORAUT 2007b), and Technical Information Bulletin: 

Tritium Calculations and Missed Dose Estimates, OTIB-0011 (ORAUT 2004d). 

Urinalysis techniques were the same for all forms of tritium, including STCs. Tritium in metal 

hydrides is a special chemical form for tritium, also called MTs. MTs are somewhat insoluble 

forms of tritium compounds (Inkret et al. 1999, Cheng et al. 1997) that do not exhibit similar 

biokinetic behavior to the more common forms of tritium, such as HTO or elemental tritium. 

Tritium from MTs does not enter the systemic compartment as quickly as HTO after inhalation 

and, therefore, the interpretation of tritium urine bioassay data cannot be treated with standard 

tritium excretion models (McConville and Woods 1995). Due to being relatively insoluble, 

inhaled MTs deliver the highest component of dose contribution to the lungs. Tritium from these 

particles also can convert to OBTs from contact with lung tissue and further complicate the 

metabolic process (DOE 2004). The analysis for metal tritides has been shown not to be 

detectable by the analytical methods used for HTO, and thus the missed dose or overestimating 

assumption potential for tritium would be much greater than that given as guidance for dose 

reconstructors on page 74 of the site profile. 

The main types of OBTs found are tritiated solvents, tritiated oil, and solid particulates (e.g., 

organic dust, plastics, etc.). The dose from intakes of OBTs can be different than HTO intakes 

of the same activity and is dependent on the specific chemical compound in which the material is 

bound. The effective dose equivalent per unit uptake has been estimated to be two times larger 

for OBT than HTO (DOE 2004). OBTs in the form of solid particulates reside in the lungs for a 

longer period of time, resulting in higher dose to the lungs. ORAUT-OTIB-0066 (ORAUT 

2007b) states that “a Type 1 calculation underestimates systemic dose approximately 30% for 

intakes of OBT because half of the intake is not uniformly distributed in the body-water space.” 

In the recommendations from ORAUT-OTIB-0066, it is stated that this method (from ORAUTOTIB-0011, ORAUT 2004d) can be used without modification to calculate doses from intakes of 

OBTs to all organs and tissues, which appears to be unfavorable for claimants if it 

underestimates systemic dose by approximately 30%. More information on how prevalent OBTs 

are in the SNL work environments should be gathered, and consideration given to the potential 

difference in resulting dose. 

The dose consequences from STCs may be significantly larger than those from HTO; therefore, 

dose reconstructors need to be familiar with the special tritium compounds handled, the 

quantities of material, the locations and time periods of potential exposure, and the physical 

behaviors of tritium compounds in the environment (e.g., conversion to HTO, formation of rust) 

to correctly characterize tritium exposure. Furthermore, they should be made aware of the 
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characteristics of STC excretion in urine to enable them to distinguish between STCs and 

tritiated water or gas, at least in some cases. 

Bounding techniques proposed in ORAUT-OTIB-0066, Calculation of Dose from Special 

Tritium Compounds (ORAUT 2007b), cannot be effectively developed and applied without some 

basic understanding of the compounds handled and the extent to which individuals were 

exposed. From the recommendations in ORAUT-OTIB-0066, it is stated that “the selection of 

the appropriate tritium compound in an intake evaluation must usually be based on process 

knowledge of the source terms in the workplace.” It is important that the dose reconstructor 

chooses claimant-favorable forms of tritium for the dose estimation if there is a lack of process 

knowledge about the form that may have been involved with exposures. The dose to the lung 

from intakes of MTs can be underestimated by orders of magnitude if it is incorrectly assumed 

that the dose can be calculated with the methods used for HTO (ORAUT 2007b). 

3.8 ENVIRONMENTAL SOURCE TERMS ARE INADEQUATELY 

CHARACTERIZED FOR USE IN PERFORMING THE EXPOSURE 

ASSESSMENT FOR AIRBORNE EMISSIONS 

The environmental exposure calculations used for assessing intakes of airborne radionuclides 

provided in the SNL environmental dose TBD, ORAUT-TKBS-0037 (ORAUT 2007a), used 

source term data that may be inaccurate, incomplete, and not claimant favorable. There are 

periods of time for which NIOSH could not find any emission or environmental monitoring data 

to calculate the actual air concentrations that to which unmonitored workers could have been 

exposed. The methods that NIOSH used to assign intakes for some of these areas were not 

clearly explained, and in some cases when the methods were explained, there is a question on the 

validity of the assumptions used. For some areas of environmental exposure, NIOSH appears to 

have left out potentially significant radionuclides in the assessment of environmental dose. 

 

In Section 4.2.1 of the TBD (ORAUT 2007a), NIOSH appears to rely on site environmental 

monitoring reports (Millard et al. 1984) for tritium release information, but it appears these 

reports are not always clear on whether or not releases occurred. In Table 4-4, the TBD assumes 

that constant 3E+03 Bq intakes occur each year from 1948–1972 in TA-I and TA-II, because 

NIOSH could not find any monitoring data for this period and therefore used the average for all 

monitored data collected afterwards. This table shows that intakes for 1978 and 1979 were 6E+4 

and 7E+4 Bq, respectively; this is 20 to 25 times higher than the 1948–1972 assumed annual 

intake level. This indicates the potential for significant variable releases and intakes, and further 

discussion is needed on why these could not have occurred in the earlier years. For years from 

1980 through 1995, Table 4-4 shows very low tritium intakes for TA-I, TA-II, and TA-IV. This 

appears unusual with intakes being much higher in the preceding and following years, and 

discussion is needed to support this. 

The TBD does not discuss the potential for source terms that could cause environmental 

exposures from the operations in Thunder Range within the Coyote Test Field. Table 2-2 of the 

TBD identifies that there were fire and explosion tests at this location and that DU was the major 

radionuclide in the area. If these tests did use DU, there is some probability that contaminated 

soil could have been at this area which could get resuspended and expose personnel through the 
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air pathway. In particular, high temperature burns and explosions would have generated 

volatized small particle DU that would have been widely dispersed and respirable to nearby 

workers. 

The development of the intake estimates for TA-III is not described in significant detail and the 

assessment for this area appears somewhat arbitrary. The TBD states that there was no emission 

monitoring for the area before 1973, and it identifies that there were diffuse sources of airborne 

radionuclide releases. The TBD does not state how it estimated the air concentrations that 

caused intakes in this area. There is no discussion on any air monitoring in TA-III for emissions 

from waste landfills after 1973. If resuspension modeling of contaminated soils was used to 

estimate the air concentrations, detailed information about the resuspension factors and levels of 

soil contamination assumed needs to be presented. 

 

An available environmental monitoring report that covers earlier years at the site (Brewer 1973) 

states that the Sandia Engineering Reactor (SER) in Area V, a 5 megawatt (MW) research 

reactor that was water cooled, had a liquid waste disposal system (LWDS) that connected to a 

drain field and later to an evaporation pond. There is no discussion on the final disposition of the 

drain field and pond, such as remediation and disposal of the contaminated soils that must have 

been left. This situation could have left contaminated soil with resuspension potential for this 

area that could have also affected TA-III, because TA-V is within the boundary of TA III. It is 

not apparent that NIOSH accounts for this potential source of environmental exposure in the 

TBD. This report states that a soil, water (including potable water wells), and vegetation 

sampling program started in 1959. It also states that starting in 1969 soil sampling was done in 

the Area 3 radioactive waste site areas and Area V liquid waste disposal pond. This further 

suggests a soil contamination resuspension issue. Another issue regarding the environmental 

intake estimates for TA-V is the lack of the gaseous fission products from 1961–1966 shown in 

Table 4-6. These were years that the SER and SPR Facility were operating and Table 2-2 in the 

TBD shows it is likely for these reactors to produce “reactor-produced” radionuclides similar to 

the Annular Core Research Reactor (ACRR), so it is not clear why the start up of the ACRR in 

1967 was the initial and only source of the gaseous fission products assumed by NIOSH. 

Section 4.3, “Radionuclide Screening SNL New Mexico,” (ORAUT 2007a) states that no 

effluent monitoring information is available before 1973. The environmental report covering 

1964–1972 (Brewer 1973) states in a footnote: “Stack release data available on AEC Form 

789A submitted annually.” It is not apparent that NIOSH has made an effort to retrieve this 

stack monitoring data. It also is apparent that NIOSH may not have reviewed any of the 

environmental monitoring data (ambient air, soil, vegetation, water) that may be available for 

these years because this data is not discussed in the TBD (only post-1980 environmental TLD 

data for ambient external exposure is discussed). If these data are available to NIOSH, it is 

likely that the estimates of exposures and intakes NIOSH has developed for these years could be 

presented with more certainty if the data was reviewed. 

There is no discussion in the TBD regarding fugitive emissions that could have given rise to 

environmental doses. The Tiger Team inspections (Smith 1991) made a finding stating that the 

air quality management program needed to add a requirement for the line organization to 

minimize fugitive emissions wherever possible, and develop a standard operating procedure for 
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the control of fugitive emissions. Therefore, it can be assumed that there may have been some 

activities that released airborne radionuclides as fugitive emissions having exposure potential 

which could only have been accounted for through ambient air monitoring or a resuspension 

model because the source was not monitored at the point of emission. 

Section 2.4.6 of the TBD describes the activities at the Tonopah Test Range (TTR), and 

identifies tests involving components containing depleted uranium (DU). It also states that 

“there is some evidence of DU contamination at the site.” DU is not considered by NIOSH in 

the environmental dose source term at TTR in this TBD, and there is no discussion why it is not 

considered. NIOSH estimates the radionuclide intakes for all years at TTR going back to 1963 

using air monitoring data from 1996–1997, which analyzed for Pu isotopes and Am-241. 

Proposing that it is reasonable to assume the air concentrations were similar in the earlier years 

may not be accurate when considering that soil radionuclide concentrations and resuspension 

rates could be different due to weathering of the soil. In the LANL Occupational Environmental 

Dose TBD ORAUT-TKBS-0010-4, Rev. 00 (ORAUT 2004c), it is stated that soil with older 

contamination (such as the soil at TTR in 1996–1997) is less of a resuspension issue than soil 

recently contaminated (such as in the earlier years at TTR) because erosion and downward 

migration of radionuclides from the upper soil layers diminish the source term over time. 

 

 In Section 4.5.1 of the TBD (ORAUT 2007a), NIOSH states that the 1991 Tiger Team 

assessment questioned emission monitoring adequacy. The site’s response was to eventually 

improve monitoring systems, leading to increased reporting of effluents, with the increasing 

trend continuing through 2004. This infers that earlier monitoring data (before the 1990’s) may 

have been lacking some emissions reporting. It is not apparent that NIOSH has assessed the 

impact that inferred incompleteness and inadequacy of the earlier monitoring data could have 

had on the emissions estimates. This section of the TBD also states “years with data vary by 

facility, but the most complete information is available for 1991 and later.” NIOSH typically 

used facility-specific averages to fill in these data gaps. This approach assumes that effluent 

controls (such as filters, height of stacks) and workloads were similar throughout these periods. 

It is not clear that NIOSH verified the appropriateness of these assumptions for using the 

approach of extending averages during periods of data gaps. 

3.9 THE ENVIRONMENTAL EXTERNAL DOSE COMPONENT IS DEVELOPED 

WITH INADEQUATE JUSTIFICATION AND MAY BE INCOMPLETE 

The assignment of the environmental external doses from TLD data does not have a clear basis, 

and is not supported with any apparent analysis of background and onsite environmental 

dosimeters to accurately determine if there were higher levels onsite. There is no discussion 

detailing the dosimeter locations that were placed on site and whether these were representative 

for estimating unmonitored worker dose. Assessment of possible doses from radioactive 

particles on skin is missing, in disagreement with discussion in the Scope of the TBD (ORAUT 

2007a, Section 1.2) which identified this as being covered in the environmental dose section. 

The TBD states that external radiation dose information for SNL is available for 1980 to 2004. 

Reported doses for 1980 to 1985 and 1993 to 1999 were reported as site averages plus one 

standard deviation without identification of doses at specific monitoring locations. This leaves a 
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lot of periods and locations requiring estimation of external doses without directly applicable 

data. The TBD assigns “< 1 mrem/yr” for environmental external dose in TA I and TA II from 

1948–1979 without any discussion or defense of this determination. For other periods the TBD 

assigns 5 mrem/yr (TA-I, TA-II from 1980 to 2004, TA-III from 1961 to 2004) or 10 mrem/yr 

(TA-IV from 1980 to 2004, TA-V from 1961 to 2004) and states that this is claimant favorable 

without further discussion. Using environmental TLDs to determine an above background dose 

from emissions/radiation fields can be difficult if the detected levels are similar to background 

stations (choosing an appropriate background station is potentially difficult because of the need 

for similar background source factors—soil, geology, altitude). An example of data that 

challenges the assessment by NIOSH is available in the 1986 Environmental Monitoring Report 

(Millard et al. 1986). Table 4 in this document gives an onsite environmental TLD range of 88–

153 mrem annually. The range for the offsite environmental TLDs was 77–99, which could be 

assumed to represent the regional background dose. Averages were 108 for the onsite TLDs and 

89 for the offsite TLDs. This data appears to indicate that onsite doses above background could 

have been more than 10 mrem. 

Regarding radioactive particles on skin of unmonitored workers that could give a high localized 

skin dose, NIOSH does not appear to address this in the environmental dose section, although it 

is stated to be covered in this section according to the scope of the TBD (Section 1.2). Depleted 

uranium was handled at both SNL (New Mexico) and SNL-TTR, per statements in the TBD, and 

because it is often in soil contamination left from explosives testing, it can be a source of 

radioactive particles on the skin due to becoming airborne from resuspension. The U-238 

component of DU can impart a significant dose to the skin and shallow tissue near the particle 

from the strong beta radiation emitted by its progeny Pa-234m. This type of exposure is 

discussed thoroughly in Site Profiles for Atomic Weapons Employers that Refined Uranium and 

Thorium (Battelle 2006). 

3.10 CRITERIA FOR BADGING WORKERS WERE NOT DEFINED 

ORAUT-TKBS-0037 (ORAUT 2007a) does not provide any information concerning the criteria 

for badging workers at the SNL during the period 1949–2007. The criteria that were used to 

determine who was badged, for what type of exposure (i.e., photon, beta, and neutrons), and how 

the badging policy varied as a function of work location/facility and time needs to be addressed 

in the TBD for dose reconstruction purposes and to assist in determining if the coworker data 

presented in the TBD is valid. Based on interviews with SNL health physics personnel (see 

Attachment 2), line managers in each department made the decision regarding which workers 

were badged or bioassayed, leading to issues of consistency between SNL departments and over 

time. Dose data for badged workers with ≥50 mrem of penetrating gamma dose is provided in 

Table 6-4, and for non-penetrating dose, it is listed in Table 6-5 of the TBD. However, it is not 

presently known if this data is representative of all workers at SNL at all locations for each year 

listed. This data could represent only highly exposed workers, average workers, cohort badging, 

or even random badging during some periods. 

In the present TBD, the dose reconstructor is not provided with sufficient information needed to 

determine if a claimant should have been monitored and was not, or if a claimant was not 

monitored because the worker was located in a non-radiation work area and did not need to be 
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monitored. Additionally, the badging policies as a function of time and location need to be 

further separated into photon, beta, and neutron badging criteria. A thorough review of this topic 

is needed in the SNL TBD to provide guidance to the dose reconstructor for reasonable dose 

assignments. 

3.11 LACK OF DOSIMETRY RECORD INFORMATION 

Throughout the Occupational External Dose section of ORAUT-TKBS-0037 (ORAUT 2007a), 

the dose data records are referred to as containing the necessary and correct dose for exposed 

workers throughout the entire period from 1949–2007. However, except for the brief statement 

on page 99 concerning the electronic file records created since 1986, there is no mention of the 

actual dose records; the dose information they may or may not contain (i.e., if neutron and 

photon components were recorded separately, or if only the total penetrating dose was retained 

during certain periods, as was the practice at some of the labs); the different recording systems 

(such as the change-over from handwritten to computerized records); and different recording 

methods/programs used after switching to electron data storage. 

The major areas of concern are as follows: 

Data Integrity and Completeness

Verification of data during transfer between systems (i.e., comparison of original records to 

electron data systems) is needed to ascertain the integrity of the dose data that will be used in 

dose reconstruction, and also for the coworker dose data. Additionally, no mention is made in 

the TBD concerning data completeness, i.e., there must be some methodology established to 

assure that all records were transferred during each system change-over. These are data accuracy 

issues that must be addressed to determine if the dose data contained in the current records are a 

correct representation of the original data recorded. 

Meaning of Different Dose Terms

The form in which the data was recorded is important. For example, if the neutron and photon 

penetrating doses at SNL were sometimes combined and entered as one value, it will make it 

difficult for the dose reconstructor to separate them out for individual dose assignments in the 

IREP Input tables. In the 1960 AEC Report (AEC 1960), the only listings are “Total Body,” 

“Total Wrist,” and sometimes only “Total.” There is also an apparent conflict regarding the use 

of dose terms on page 99 of the TBD, where it states that starting around 1971, the Whole Body 

Dose = Deep Dose + Neutron Dose. However, to arrive at the n/p value of 0.36 in Table 6-9 of 

the TBD, one must assume that the deep dose data (Column K) in Widner 2006c, Tab “All DD 

>49,” contains the total of the neutron plus the photon dose, as illustrated in Table 2. 

Note that it must be assumed that the deep dose value contains both the photon plus the neutron 

doses instead of just the photon dose in this case; or, if the Deep Dose contains only the photon 

dose value, then the values in Table 6-9 of the TBD are not correct, i.e., the n/p geometric mean 

(GM) would be 0.25 instead of 0.36. 
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Table 6-4 uses the term “penetrating dose” in the title and lists “gamma dose” in the column 

headers. However, when looking at the detailed data lists [Widner 2006a and associated 

spreadsheet, Widner 2006c, Tabs “87” through ‘05”]2

, it was found these values were take from 

the deep dose (column K), which, as demonstrated above, appears to contain photon plus neutron 

doses and would not be appropriate for use in determining coworker gamma (photon) dose. 

Additionally, the data contained in the currently available reference Widner 2006a (and 

associated spreadsheets Widner 2006b, 2006c, 2006d, and 2006e) do not contain a data sheet for 

1985 or any useful data for 1986. Table 6-5, however, lists gamma dose values for these two 

years. 

Table 2. Calculation of 1987–2005 Neutron-to-Photon Values for Table 6-9 of TBD 

Year Deep Dose Neutron Dose p=(DD-N) n/p 

1987 1310 160 1150 0.14 

1991 1230 110 1120 0.10 

1992 924 135 789 0.17 

1987 880 160 720 0.22 

1991 804 113 691 0.16 

1990 786 100 686 0.15 

1987 730 120 610 0.20 

1988 970 400 570 0.70 

1989 651 112 539 0.21 

1988 760 290 470 0.62 

1988 720 300 420 0.71 

1988 500 150 350 0.43 

1989 373 120 253 0.47 

2005 396 168 228 0.74 

1987 430 290 140 2.07 

1987 320 210 110 1.91 

GM= 0.36 

Shallow and Nonpenetrating Dose

It important to determine what meaning the terms Shallow and Nonpenetrating dose had when 

they were entered into the original data sheets, and how they were defined in each data system as 

they were transferred between data systems. Table 6-5 on page 100 of the TBD uses both the 

term “nonpenetrating’ and “shallow.” Additionally, it covers only the period of 1977–2005, and 

does not contain data or instructions for the dose reconstructor concerning the values to use for 

assigning nonpenetrating coworker dose for the period 1949–1976, when nonpenetrating doses 

were not measured and/or recorded. The data contained in the currently available reference 

Widner 2006a and associated spreadsheets Widner 2006b, 2006c, 2006d and 2006e do not 

contain a data sheet for 1985 or any useful data for 1986. Table 6-5, however, lists 

nonpenetrating dose values for these two years. Random checks of data values in the reference, 

 2

 Thomas E. Widner performed these analyses whle employed as a contractor to the Oak Ridge Associated 

Universities Team (ORAUT). 
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Widner 2006a, and associated spreadsheet Widner 2006c, indicate that these references do not 

contain all the data entries used to create Table 6-5 for 1985–2005. Attempts to duplicated 

values in this table from the data sheets lead to a lower number of entries found in the data sheets 

than are listed in the table. For example, for 1987, the table lists 138 workers with a mean dose 

of 370 mrem, but Widner 2006c, Tab “87,” only lists 114 workers with a shallow dose ≥50 mrem 

and with a calculated mean dose of 428 mrem. 

Dose terms should be consistent and defined when used in the TBD, and the TBD should 

investigate their meanings when they were used in the different record systems and provide this 

information for use by the dose reconstructor. A small amount of information concerning dose 

recording terms is provided in the TBD on pages 98, 99, and 104. However, this information 

may not be sufficient to provide the dose reconstructor with the tools necessary to sort out the 

details of the dose data contained in a claimant’s records. 

Background Subtraction 

An issue not addressed in the TBD was if SNL’s dosimetry practice was to subtract background 

badge readings from the workers’ badge readings before recording the final dose. This issue is 

important to the dose reconstructor when determining if environmental external site doses should 

be assigned. 

3.12 INSUFFICIENT ANALYSES OF RADIATION FIELDS, DOSES, AND 

UNCERTAINTIES 

ORAUT-TKBS-0037 (ORAUT 2007a) does not cover the subject of photon and neutron 

radiation energy fields and associated doses/uncertainties as a function of work location and time 

periods sufficiently to allow the dose reconstructor to accurately assign dose. 

Energy Calibration

Some information concerning the expected energy ranges is provided in the TBD in Table 6-8 

for beta/photons and in Table 6-11 for neutrons. However, except for the period 1959–1971 for 

beta/gamma calibration listed in Table 6-1, the TBD does not specify what photon calibration 

energies were used for different locations at the SNL and how these changed with time. Neutron 

calibration is only mentioned in Table 6-2 for Nuclear Track Film Type A (NTA) film, but 

NIOSH recommends not using NTA data; therefore, no relevant neutron calibration information 

is provided. 

Neutron-to-Photon Ratio Values and Application Dates

The text in the TBD (ORAUT-2007a, page 104) indicates that the following: 

There should not typically be significant neutron dose exposure of unmonitored 

workers. However, if estimation of neutron dose is called for, the recommended 

option is to apply the neutron-to-photon distribution data from Table 6-9 to 

measured or estimated missed or unmonitored photon doses.
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NIOSH states that one n/p value (0.39, cited on page 104, Table 6-9) (Widner 2006d) was 

determined by evaluation of worker neutron doses from 1977 to 1984 data (38 annual records). 

NIOSH considers this to be representative of the dose to workers in the 1949–1976 time period. 

NIOSH has not provided enough additional dose data beyond the 38 annual records to validate 

that this assumption is correct. NIOSH further states the following: 

This process of calculating a neutron dose is based on the assumption that the 

distribution of neutron doses to unmonitored workers is equivalent to the 

distribution of neutron doses measured for monitored workers. 

Again, NIOSH has not provided enough validation data to document this assumption. The text 

also does not adequately validate that one n/p value (0.36) obtained from 1987 to 2005 data (16 

annual records) is applicable and sufficient for the period from 2005–2007 (Widner 2006a). This 

is too large a time period for varied neutron exposures in various locations and conditions, 

especially using 1977–1984 data for early 1949–1976 workers. There is no evidence provided in 

the TBD to support the assumption that these 38 records from an 8-year time span, coupled with 

16 records during a 19-year time span (usable data points available from only 7 of these 19 years, 

as noted below), accurately reflect the n/p values the workers were exposed to, considering the 

many changes that took place in operations, source terms, shielding, and radiation protection 

practices. 

For the period 1949–1986, 38 annual records were used to calculate the n/p value of 0.39 based 

on 1977–1984 data, as these were the years that had both reliable neutron (from TLD readings) 

≥100 mrem and photon doses ≥100 mrem. The number of data points used in each year is listed 

in the following table: 

Table 3. Calculation of 1949–1986 Neutron-to-Photon Ratio Values 

for Table 6-9 of the TBD 

Year # of records 

1949–1976 0 

1977 12 

1978 3 

1979 7 

1980 5 

1981 2 

1982 4 

1983 2 

1984 3 

1985 0 

1986 0

Sum = 38 

This shows that only 8 years of data was used to calculate n/p values to cover a time span of 

38 years of operations. 

Not only are data from relatively short time intervals used to cover wide time spans, but 

examination of the details of the dose data used to create the n/p value of 0.36 for 1987–2005 

listed in Table 6-9 of the TBD shows an even narrower period of usable data. Sixteen annual 
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records were used to calculate the n/p value of 0.36 based on 1987–2005 data, but only the years 

1987–1992 and 2005 had usable data (i.e., had both neutron and photon doses ≥100 mrem). 

Therefore, while it is true 19 years (1987–2005) of data were analyzed, only 7 years of data were 

used to cover this time period. The number of data points used in each year is listed in the 

following table: 

Table 4. Calculation of 1987–2005 Neutron-to-Photon Ratio Values for 

Table 6-9 of the TBD 

Year # of records 

1987 5 

1988 4 

1989 2 

1990 1 

1991 2 

1992 1 

1993 0 

1994 0 

1995 0 

1996 0 

1997 0 

1998 0 

1999 0 

2000 0 

2001 0 

2002 0 

2003 0 

2004 0 

2005 1

Sum = 16 

MDL Values for Early TLDs

Section 6.5, page 102, second paragraph, of the TBD (ORAUT 2007a) states that “Because of 

the lack of site-specific data on MDLs for the early TLDs used 1971–1990, these dosimeters are 

estimated to have had MDLs between those for the film badges and the more advanced TLDs.” 

Additionally, footnote c of Table 6-10 on page 105 states that “Because of the lack of sitespecific data on MDLs for the early TLDs used 1971–1989, these dosimeters are estimated to 

have had MDLs between those for NTA film and the more advanced TLDs.” These assumptions 

need to be supported by documentation, especially in view of the fact that the NTA film data is 

not considered reliable and will not be used. 

Missed versus Unmonitored Neutron Dose

Page 105 addresses missed neutron dose (MND), based on LOD, but goes on to describe when

(not how) to assign MND. To be consistent with other DOE site TBDs, the worker should be 

assigned MND by use of [n/p × p] whenever the worker was badged for neutrons, even if there is 
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a zero or <LOD reading. If the worker was badged, a recorded or MND should be assigned; the 

dose reconstructor should not have the option of deciding if neutron dose should be assigned if 

the worker was badged for neutrons. Additionally, the worker should not be assigned MND or 

missed photon dose (MPD) when unmonitored, but where he could have been exposed. 

Missed dose (as defined by NIOSH) is to be assigned to monitored workers, due to the limits of 

the dosimeter or recording practices, not to unmonitored workers who were not wearing a 

dosimeter; a missed dose cannot be associated with a worker not wearing a badge. A worker that 

was not monitored, but should have been monitored, should be assigned a valid coworker dose. 

The TBD (ORAUT 2007a) goes on to state that “For periods before 1971, distribution of n/p 

values from Table 6-9 should be applied to the recorded gamma doses to estimate missed

neutron doses. Table 6-10 lists the neutron missed dose for those exposed to neutrons.” 

[Emphasis added.] Applying the n/p value to recorded dose provides a neutron dose based on a 

measured dose, not an MND based on the dosimeter’s photon dose MDL. Therefore, this 

apparently should read “...to estimate unmonitored neutron dose...,” not missed neutron dose. 

Unmonitored and MND appear to be intermixed in Sections 6.7 and 6.8 of the current TBD, 

which may make it difficult for the dose reconstructors to use consistent and correct methods to 

assign unmonitored and MNDs. 

Uncertainty values

Section 6.4, page 101 of the TBD, contains some information concerning bias and uncertainty 

factors. It appears from the first paragraph that the recommended photon error is ± 30% for all 

energies and all dosimetry systems. However, it goes on to list other photon dose uncertainties 

in Table 6-6. It is not clear in the current TBD if the dose reconstructor is to use the ± 30% 

uncertainty factor for photon doses, or some combination of the uncertainty factors listed in 

Table 6-6. Additionally, it is not clear what final uncertainty value NIOSH is recommending the 

dose reconstructor use for neutron doses as a function of time period; i.e., values for overall bias, 

range in bias, systematic, and random uncertainty factors are listed, but no combined final 

values for the dose reconstructor to use are provided. 

When determining some of the values in Table 6-6, the TBDs for Hanford (ORAUT 2004a) and 

Argonne National Lab - East (ORAUT 2006b) were cited as references for beta/gamma film, 

TLD, and NTA film data. However, no information was presented in the SNL TBD to 

substantiate using these other facility values for SNL. Additionally, Table 6-6, page 101, and 

Table 6-10, page 105, list data for NTA film. However, page 101 and 105 recommend using the 

n/p method to determine measured and MND. It could be assumed that NIOSH included the 

NTA film data for completeness, but does not intend that it be used by the dose reconstructor in 

reconstructing doses in actual cases; but this is not stated in the TBD and could be a point of 

confusion for the dose reconstructor. 
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3.13 SECONDARY ISSUES 

 

3.13.1 The Site Profile Table 5-24 is of very Limited Value and it is Uncertain why the 

MDA for the Whole-Body Counting in Table 5-24 is approximately Twice as Big in 

2001 as it was in 1994. 

Table 5-24 on page 85 of ORAUT-TKBS-0037 (ORAUT 2007a) is of very limited value, as it is 

based on averages of whole-body counts of only 3 individual workers in 1994 and a single 

worker in 2005. There is no indication whether these measurements represent normal unexposed 

individuals, other than the statement that the individual measured in 2005 was said to be a 

“typical individual.” 

It is difficult to understand the two columns in Table 5-24, where the first column is for 1993–

2000, which must be based on the three measurements in 1994, but then a change in MDA in 

2001, when the only other evaluation was based on a single individual in 2005. It is not 

explained in Section 5.3.2 why the MDA degraded by approximately a factor of 2 from 1994 to 

2001. It would seem more reasonable that the MDA would improve with time, unless some 

change occurred during this time period that is not given in the site profile. 

3.13.2 The Site Profile Recommends the Use of the LANL MDA Values for Bioassay 

Analysis Performed at SNL before 1992. Better Justification should be Provided. 

The site profile (ORAUT. 2007a, pg. 68) states the following: 

Minimum detectable activity levels for bioassay performed at SNL before 1992 are 

not generally available unless listed with specific sample results. However, 

analytical techniques and instrumentation similar to those used at LANL were used 

at SNL; therefore, the MDAs would likely have been similar (Argall 2007a). 

This is a major assumption on the part of NIOSH. It would be helpful if NIOSH could provide 

further documentation to support this assumption, other than noting a “likely” similarity. The 

differences in laboratory conditions and technician differences make this assumption 

questionable, if not invalid. 

3.13.3 The TBD lacks a Discussion of Other Potential Medical X-ray Exposures and the 

Procedures needed to Maximize Medical X-ray Dose 

Section 3.0 of the SNL TBD (ORAUT 2007a), Occupational Medical Dose, references ORAUTOTIB-0006, Rev. 03 (ORAUT 2005), regarding dose reconstruction from occupationally related 

diagnostic x-ray procedures in the TBD reference list, but fails to discuss its use and application 

at SNL in regards to additional special job-related medical x-rays. OTIB-0006 goes a long way 

in ensuring that occupational medical exposures are included, and that all forms of medical x-ray 

exposure are identified when determining a worker’s potential exposure. OTIB-0006 Rev. 03 

concludes that other examinations may be included, such as special job exams (e.g., special chest 

radiography for respirator certification; for beryllium workers, asbestos workers, food handlers 

etc.) and termination exams. The potential for exposure from these other medical x-ray dose 
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exposures is not discussed, nor addressed, in the SNL TBD (ORAUT 2007a). When the 

individual medical record is lacking in specific information, the TBD also offers no other default 

means to develop a realistic medical x-ray history that might also include these special job 

examinations or termination examination that might be a part of the annual physical. The 

Occupational Medical Dose section of the SNL TBD (ORAUT 2007a), in this regard, does not 

refer the dose reconstructor to Revision 3 of OTIB-0006 (ORAUT 2005). 

Another factor not discussed in the TBD is the potential and impact of x-ray procedures 

utilized by medical authorities to do special screening and to evaluate the result of injury 

and trauma. 

In Table 3-1, in the SNL TBD (ORAUT 2007a), it is mentioned that for the period 1953–1966, 

“Selected individuals could have received standard 14 by 17-in PA chest radiographs in addition 

to PFG” (ORAUT 2007a, pg. 21). It goes on the say at the end of that entry that “In the absence 

of any records of X-ray procedures, the dose from the photofluorography (PFG) should be 

assigned on an annual basis for this period.” There is, however, no guidance for the dose 

reconstructor on which groups or individuals should receive an annual 14 in ×17 in chest x-ray 

during the years 1953 to 1966 when the medical record is silent on such annual chest x-rays. 

The TBD (ORAUT 2007a, pg. 22) also states that “The review of employee medical records 

indicated that SNL took PA chest films for most but not all employees on an annual or biennial 

frequency through 1966...” The TBD should provide guidance to the dose reconstructor, unless 

contrary to what appears in the worker’s medical record, that specifies assignment to the worker 

of a dose for both an annual PFG and an annual 14 in x 17 in chest x-ray, unless the employee’s 

medical record indicates otherwise. 

The Occupational Medical Dose section of the TBD also does not discuss the application of 

ORAUT-PROC-0061 (ORAUT 2006a) that instructs dose reconstructors to: 

As described in Section 6.0, unless otherwise noted in Table A-1 the following 

procedures apply: For a maximizing assessment, the organ doses should be 

multiplied by 1.3 and treated as a constant in IREP; for a best estimate 

assessment, the organ doses should be assigned as a normal distribution in 

Parameter 1 with 30% of the organ dose entered in Parameter 2 in IREP; and for 

a minimizing assessment, the organ doses should be assigned as a constant in 

IREP. (ORAUT 2006a, pg. 13) 

There is no entry for SNL in Attachment A, Table A-1 of PROC-0061 (ORAUT 2006a). 

When PROC-0061 is updated, SNL should be added to the table. The TBD does not 

discuss, when determining a maximizing estimate, the multiplication of organ dose by a 

factor of 1.3 to account for uncertainty. The TBD also does not instruct the dose 

reconstructor to use PROC-0061 when applying the maximizing approach. It, therefore, 

appears that the multiplication factor of 1.3 has not been applied to SNL medical x-ray 

dose when applying the maximizing approach. 
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3.13.4 The Reference in the SNL TBD for Stout 2005 does not include the Backup 

Documentation Cited 

SNL X-ray History (Stout 2005) is used as the source of documentation in six places in the SNL 

TBD (ORAUT 2007a), but lacks the backup documentation. This reference is a memorandum 

from Kay Stout to Ron Kathren that only includes a discussion of the lack of shielding for 

lumbar spine examinations in the 1950’s and TLD measurements on a dummy to obtain x-ray 

doses. This reference is used in five other places as the source of Table 3-1 data on frequency 

and types of medical examinations; as providing information regarding interviews with former xray technologists Kay Sanderville and Louise Bland; as providing information with a former xray technologist on the type of apparatus used from 1953 to 1958; as providing information on an 

August 28, 1978 Herb Abbott survey performed on the x-ray unit at that time; as mention of a 

correction made 11 days after the survey report; and as the source of information on periodic 

lumbar spine examinations prior to 1978. This leaves documentation lacking for positions taken 

by NIOSH unsupported in these five instances. 

3.13.5 The TBD does not adequately describe the Approach and Data used in the Exposure 

Calculations 

NIOSH does not describe the emissions of airborne effluents with enough details to allow a 

thorough review of their source term development. The 69 radionuclides it says are identified in 

all of the emissions data it reviewed (ORAUT 2007a, Section 4.3) could be listed in a table or 

appendix by facility. 

 

There is no discussion covering a comparison of site ambient (air, soil, vegetation, water) 

monitoring data with the air concentrations estimated from modeling stack/vent emissions. This 

can be used to confirm that emissions monitoring is accurate and claimant favorable or identify 

disagreement between the two methods of estimating exposures. Uranium-238 was identified as 

the only uranium isotope of concern for emissions and intakes, but no U-234 or U-235 was 

considered even though it is shown in the site description that the site handled natural uranium 

and different levels of enriched uranium. In other NIOSH TBDs, the assumption is the uranium 

inhaled or ingested is U-234 when there are types other than DU. This is because U-234 is the 

most significant dose contributor of the uranium isotopes in natural or enriched uranium sources 

(it has the highest dose factor of the three isotopes, and is the highest activity component for any 

level of enrichment). If the site performed uranium mass analysis, rather than isotopic analysis 

of environmental and emission samples (which appears to be the case at SNL), it is most 

appropriate to assume U-234 is all of the uranium detected. Unless there was isotopic analysis of 

emission samples that NIOSH is aware of or they are sure that only depleted U was involved in 

U emissions, they should use U-234 instead of U-238. 

 

Some assumptions made in the exposure conditions and calculations may neither be 

representative nor claimant favorable. One example is the breathing rate, which may be higher 

for construction, maintenance, and outdoor workers with labor intensive work than with light 

activity. The particle size distribution of the particulates for inhalation intakes is assumed to be 
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5μm AMAD per Table 2-2 in the TBD; however, this may not be applicable to environmental 

aerosols and NIOSH should determine if there is a range of particle sizes that should be used in 

dose calculations to assess the most claimant favorable dose. 

NIOSH does not discuss the level of uncertainty in the stack/vent emissions monitoring in any 

detail. It may be possible that uncertainties (standard deviations) could have been reported in the 

original stack emissions concentration data to determine the laboratory component of the source 

term uncertainty. For stack emission concentration results that are near the detection limit the 

counting uncertainty alone can be a significant fraction of the result. Assuming a GSD of 2 may 

be reasonable, but it is not obvious that this is connected to an attempt to propagate component 

uncertainties to obtain a total uncertainty for the intake estimates. 

3.13.6 The TBD does not give Guidance on Combining the Environmental Intakes from 

Emissions at More Than One TA (i.e., Multiple TA Internal Exposures) and does 

not address Inadvertent Ingestion 

There is the possibility for unmonitored workers in one technical area (TA) to get exposure to 

plumes emitted from another TA. The TBD provides no discussion on adding intakes from other 

TAs together for an employee that worked in one TA and received internal exposure from 

another TA. The discussion on environmental external dose in Section 4.0 states that it can be 

assumed there are plumes from one TA that affect other TAs external doses, therefore intakes 

(internal dose) from environmental releases may also involve sources outside of the TA the 

workers was assigned to. It is apparent that the radionuclide intake tables for the different TA’s 

are only applicable to an employee that worked only in that TA. The TBD needs to give 

direction on adding intakes from plumes emitted at TAs outside of the TA that the worker was 

assigned to. 

 

The TBD states the environmental dose section covers only unmonitored workers (assumed to be 

those not assigned dosimeters or bioassays). The NIOSH document, OTIB-0014, Assignment of 

Environmental Internal Doses for Employees Not Exposed to Airborne Radionuclides in the 

Workplace (ORAUT 2004b), states that internal dose (from an environmental pathway) to a 

monitored employee can be assigned when it is from a radionuclide for which they are not 

monitored (i.e., bioassay or air sampling). An example of this would be a worker that routinely 

works with uranium and submits bioassays for uranium analysis who also receives 

environmental exposure to tritium through emissions from another facility that handles tritium. 

The scope statement in the environmental dose discussion (ORAUT 2007a, Section 4.1.2) states 

that the section covers inadvertent ingestion. In section 4.6, it is just stated that this did not occur 

at either the New Mexico or TTR sites. No details were given on how this determination was 

made. OCAS-TIB-009, Estimation of Ingestion Intakes (OCAS 2004), gives guidance on how to 

estimate ingestion intakes from air concentrations (fallout) and this could be used for inadvertent 

ingestion from environmental emission because NIOSH is using air concentration calculations to 

estimate all intakes at both sites. 
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3.13.7 Reliance on CATI in the Absence of Complete Records 

The SNL site profile relies on the Computer Assisted Telephone Interviews (CATIs), in the 

absence of complete records, to identify potential exposures to metal tritides and offsite source 

terms. The following excerpts from the TBD clarify these functions of the telephone interview: 

The telephone interview might provide indications that an energy employee had 

worked in locations where a potential for exposure to MT existed. (ORAUT 

2007a, pg. 73) 

Work at off site locations is indicated by either the Department of Energy records 

or the telephone interview [18]. Offsite dosimetry records are typically not 

contained in the SNL records, but are supplied directly from the appropriate sites 

[19]. If the telephone interview or work history indicates that the worker 

participated in nuclear weapons testing, and if no dosimetry records are found for 

that period, then the individual’s site profiles can be reviewed to obtain 

information necessary to calculate potential missed dose. (ORAUT 2007a, 

pg. 60) 

The table of nuclear weapons tests is included here to assist the dose 

reconstructor in recognizing the names of these tests in the event that these names 

are mentioned in the telephone interview or other records. (ORAUT 2007a, 

pg. 108) 

Part of the rationale for conducting a CATI is to ensure the completeness and accuracy of the 

assumptions incorporated into a particular dose reconstruction. Reliance on telephone interviews 

to identify situations where potential exposures occurred (such as exposure to metal tritides and 

offsite exposure) presents several problems. These difficulties must be taken into consideration, 

particularly when information from the interview is an exclusive source for determining the 

assignment of dose or the retrieval of additional records. 

Classification and Claimant Knowledge: SNL was involved in a variety of research and 

development, stockpile stewardship, and testing activities that are of a classified nature. As such, 

an individual has to have the appropriate clearance and need-to-know for access to particular 

information. Due to the complexity of work assignments or, in some cases, classified work 

assignments or locations, family member claimants may not know what the employee did. In 

fact, energy employees without a need-to-know may not always know to what source terms they 

were exposed. For example, many of the details about work with metal tritides remains 

sensitive. It is not reasonable to assume that all employees working around this material would 

be aware of their exposure, and it is certainly not reasonable to assume that surviving family 

members would have adequate information. Even if an energy employee is knowledgeable, 

classification concerns may prevent them from discussing such work in the context of an 

unclassified interview. 

Interview Process Limitations: The CATI process requires the interviewer to ask questions from 

a script that may not trigger relevant memories and information. For example, the interview 
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does not specifically ask about temporary assignments or visits to other DOE sites. The claimant 

is expected to recognize the importance and relevance of such information and to provide it 

without specific prompting. Regarding sources of potential exposure, there is a significant 

discrepancy in the interview process for energy employee claimants versus survivor claimants. 

While the energy employee interview form specifically asks what types of radioactive material 

an individual was exposed to, the survivor interview form does not. Coworker interviews may 

offer some possibilities to offset survivor claimants’ lack of knowledge, but coworker interviews 

are not commonly conducted. Finally, it is not reasonable to assume that claimants have the 

scientific knowledge to recognize the importance of special exposure conditions, such as 

exposure to special forms of tritium or other radionuclides. Without specific prompting, many 

claimants may not be in a position to determine which exposure conditions may be relevant to 

the dose reconstruction. 

Additional Sources of Information: Offsite work conducted by SNL, including shots at Nevada 

Test Site (NTS), Pacific Proving Grounds (PPG), and other continental sites, is well documented 

in event-specific reports. In fact, SNL has compiled lists of departments and individuals 

involved in particular tests. In addition, NTS incident reports list specific individuals involved in 

particular incidents, including laboratory staff. These information sources can link individual 

workers to offsite exposure conditions without relying on the claimant to produce the 

information. If these information sources could be compiled and referenced during claim 

reviews, they could enhance the accuracy and equity of the claim review process for energy 

worker and survivor claimants. An effort to compile this information would ensure that offsite 

dose (at least from NTS) was appropriately considered. An alternative would be to request 

worker exposure and incident data for all SNL claimants from key sites such as NTS, PPG, and 

SNL-Livermore. In the case of exposure to special forms of radionuclides, the claimant 

favorable approach would be to assume a claimant was exposed to the special chemical form 

given that this form of the radionuclide produces a higher organ dose. 

In summary, it is not reasonable to rely on claimants to know, remember, identify, and 

communicate critical information regarding offsite exposures or special chemical forms, 

particularly in the absence of direct queries. The highly classified nature of many SNL 

operations increases the level of concern for this site, because many claimants could be unaware 

of (or inhibited from discussing) specific exposure conditions. In order to minimize reliance on 

claimant knowledge and memory, NIOSH/ORAUT should consider claimant favorable 

assumptions in the case of unknowns, and should request data from key SNL locations for all 

SNL claimants who require a maximizing or best estimate approach. 
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4.0 OVERALL ADEQUACY OF THE SITE PROFILE AS A BASIS FOR 

DOSE RECONSTRUCTION 

The SC&A procedures call for both a “vertical” assessment of a site profile for purposes of 

evaluation specific issues of adequacy and completeness, as well as a “horizontal” assessment 

pertaining to how the profile satisfies its intended purpose and scope. This section addresses the 

latter objective in a summary manner by evaluation of (1) how, and to what extent, the site 

profile satisfies the five objectives defined by the Advisory Board for ascertaining adequacy; 

(2) the usability of the site profile for its intended purpose, i.e., to provide a generalized technical 

resource for the dose reconstructor when individual dose records are unavailable; and (3) generic 

technical or policy issues that transcend any single site profile that need to be addressed by the 

Advisory Board and NIOSH. 

4.1 SATISFYING THE FIVE OBJECTIVES 

4.1.1 Objective 1: Completeness of Data Sources 

The completeness, accuracy and availability of data for use in dose reconstruction and as a basis 

for coworker approaches should be validated to demonstrate its usefulness. Verification of data 

during transfer between systems (i.e., comparison of original records to electron data systems) is 

needed to ascertain the integrity of the dose data that will be used in dose reconstruction, and 

also for the coworker dose data. Additionally, no mention is made in the TBD (ORAUT 2007a) 

concerning data completeness, i.e., there must be some methodology established to assure that all 

records were transferred during each system change-over. These are data accuracy issues that 

must be addressed to determine if the dose data contained in the current records are a correct 

representation of the original data recorded. 

Throughout the Occupational External Dose section of ORAUT-TKBS-0037 (ORAUT 2007a), 

the dose data records are referred to as containing the necessary and correct dose for exposed 

workers throughout the entire period from 1949–2007. However, except for the brief statement 

on page 99 concerning the electronic file records created since 1986, there is no mention of the 

actual dose records. The dose information may, or may not, demonstrate: (1) if neutron and 

photon components were recorded separately; (2) if they were only recorded and retained as the 

total penetrating dose, which was the practice at some labs; (3) if there were different recording 

systems used (such as the change-over from hand written to computerized records); and/or if 

different recording methods/programs were used after switching to electron data storage. 

The SNL electronic database is incomplete, and hard copy bioassay records are not complete in 

individual radiation exposure files; they lack data regarding specific radionuclides to which 

workers were potentially exposed. LANL was considered the primary source for bioassay 

services prior to 1991; however, reviews of the LANL bioassay data in previous reviews by 

SC&A and by the ORAUT found the LANL bioassay data to be incomplete or inadequate 

(SC&A 2006, Vitkus et al. 2007). Additionally, the adequacy of offsite vendor data is suspect, 

suggesting a need for further verification of data completeness and accuracy. 
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There is limited bioassay data available for SNL workers prior to 1992 when a routine 

monitoring program was implemented. Bioassay records before 1989 have been found in paper 

or microfiche format in the data archive; however, the records are limited to uranium, plutonium 

and tritium bioassay, and are not typically retrieved by SNL as a part of the claimant file. Data 

provided to NIOSH for dose reconstruction is limited to summary reports, including dose 

information in some years for tritium, plutonium, and uranium. Analysis of the source terms 

indicate that individuals were exposed to tritium (H-3), Uranium (U-234, U-235, U-238), fission 

and activation products (e.g., Sr-90, Cs-137, Zn-65, Co-60, Ta-182), plutonium (Pu-238, Pu-239, 

Pu-240, Pu-241), and americium (Am-241), yet adequate bioassay data is not available for 

several of these nuclides. The limited hardcopy bioassay data appears indicative of incomplete 

individual exposure files and/or a limited bioassay program. 

Likewise with respect to completeness of scope, the site profile does not fully address: (1) the 

significance of radiological incidents (onsite and offsite); (2) how these incidents may have 

contributed to worker dose; (3) where information is provided in individual exposure records; 

and (4) how the incidents should be addressed in dose reconstruction. Claimant data, relying 

primarily on summary reports, does not consistently incorporate exposures arising from onsite or 

offsite incidents. Reliance on the claimants to remember, identify, and communicate critical 

information regarding offsite exposures or special chemical forms, particularly in the absence of 

direct queries, is not adequate. The highly classified nature of many SNL operations increases 

the level of concern for this site, because many claimants could be unaware of (or inhibited from 

discussing) specific exposure conditions. 

In light of these key questions, the validation and verification process should be reviewed to 

assure that internal and external dosimetry information provided to dose reconstructors is 

accurate, complete, and consistent. Where data gaps cannot be corrected, clear instructions 

should be provided to allow for a consistent and claimant favorable approach to dose 

reconstruction. 

4.1.2 Objective 2: Technical Accuracy

SC&A finds that the existing site profile does not address inaccurate dose records for SPR 

operators due to under-recording of external gamma/neutron dose received during shutdown 

maintenance activities. This under-recording resulted from inadequate dosimetry at the time for 

a severe gradient of radiation fields experienced by personnel working close to the reactor vessel. 

Such under-recording can lead to an underestimate of whole body dose by at least a factor of 

1.75, and likely higher, prior to installation of additional shielding in 1982. As annual dose 

levels for these operators were among the highest at SNL, approaching the annual limit of 5 rems 

in some cases, this would have significant implications for the accuracy of dose reconstruction. 

While known to SNL management at the time, no retroactive correction was apparently made to 

individual dose records maintained by the Department of Energy. 

For external radiation dosimetry, SC& A finds that there are insufficient analyses of radiation 

fields, doses, and uncertainties in the TBD (ORAUT 2007a). Information concerning the criteria 

for badging workers at the SNL is lacking during the period 1949–2007. The TBD does not 

cover the subject of photon and neutron radiation energy fields and associated doses with related 
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uncertainties as a function of work location and time periods. The lack of specifics on energy 

fields, associated doses, and their uncertainties is not sufficiently developed to allow the dose 

reconstructor to accurately assign dose. Some information concerning the expected energy 

ranges is provided in the TBD (ORAUT 2007a) in Table 6-8 for beta/photons and in Table 6-11 

for neutrons. However, except for the period 1959–1971 for beta/gamma calibration listed in 

Table 6-1, the TBD does not specify what photon calibration energies were used for different 

locations at the SNL and how these changed with time. Neutron calibration is only mentioned in 

Table 6-2 for NTA film, but NIOSH recommends not using NTA data; therefore, no relevant 

neutron calibration information is provided, nor is a clear uncertainty value provided that can be 

applied for neutron doses as a function of SNL time period. The single n/p ratio value cited in the 

TBD is based on a relatively small number of records over an 8-year time span and would likely 

not be representative of laboratory conditions over that timeframe and beyond. 

As the TBD acknowledges, no formal routine bioassay program existed at SNL prior to 1992, 

leading to the likelihood that workers in areas containing radioactive materials may have had the 

potential for internal exposures that would not have been monitored. With their work areas in 

many cases being unknown, a backup means of estimating dose is not apparent in the TBD. The 

instructions given for dose reconstructors in the site profile do not appear to be adequate for 

determining or quantifying the radioactive isotopes to which unmonitored, or even monitored 

workers, may have been exposed. Assigning potential missed dose by work location is 

particularly questionable in the absence of complete work history records. Furthermore, the 

feasibility of this approach is questionable for site-wide workers (e.g., security guards and 

maintenance staff) and workers involved in offsite activities in Nevada and other locations. In 

cases where work area information is not available, the TBD should provide further instruction. 

Bioassay monitoring of workers was primarily dependent on the air monitoring program as 

opposed to, and in default of, a routine bioassay monitoring program. With inadequate air 

sampling, or no air sampling data at all, this brings into question the effectiveness of the special 

bioassay monitoring program and the use of air sampling data as a substitute for bioassay 

sampling. It certainly appears, without routine bioassay monitoring, that dependence upon air 

sampling for detecting exposures to workers likely led to unmonitored intakes by workers over 

the years at SNL. It also could have led to intakes that could not be measured or estimated 

accurately due to use of area air monitoring data. Furthermore, reliance on field indicators to 

trigger special bioassay is problematic, particularly in areas where air monitoring equipment 

placement is inadequate or non-existent. Some consideration should be given in the TBD to the 

representativeness of the sampling, and the consistent use of field indicators as a trigger for 

bioassay. 

SC&A finds that further evaluation is warranted for radionuclides handled at SNL by workers, 

on and offsite, to determine the extent of potential exposures, periods of exposure, quantities 

handled, and impacts on dose reconstruction to specific organs. Attempts should be made to 

evaluate archived bioassay data where it is available, and determine whether these data are 

complete and representative enough to develop a bounding or coworker dose. Appropriate 

methods for internal monitoring were not always available for all years of potential exposure. 

For tritium, it is important that the dose reconstructor chooses claimant favorable forms of 

tritium for the dose estimation if there is a lack of process knowledge about the form that may 
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have been involved with exposures. The dose to the lung, from intakes of metal tritides, can be 

underestimated by orders of magnitude, if it is incorrectly assumed that the dose can be 

calculated with the methods used for HTO. The SNL TBD (ORAUT 2007a) is incomplete in it 

consideration of missed dose to unmonitored exposed workers potentially exposed to all the 

various MFPs and MAPs, including activation products produced by accelerators. Additional 

consideration should be given to the exposure hazards associated with operation of accelerators, 

target handling, component activation and byproduct radiation. NIOSH/ORAUT should 

develop missed dose methodologies in the absence of monitoring data based on available data, 

technical reports, and other sources of information to ascertain potential exposure to nontraditional radionuclides. 

SNL took an active role in conducting weapons effects, ground motion, air pressure, crater 

phenomena, and other studies during the testing of weapons. SNL workers were responsible for 

arming and firing of weapons from 1951 through 1992. They were responsible for monitoring, 

maintaining, and assembling weapons at storage sites. A re-characterization of the extent of 

SNL involvement in weapons testing and other offsite activities (e.g. research on hydrodynamic 

testing, treaty verification, assignments to other DOE sites) should be completed. Offsite 

activities related to the weapons and components testing, surveillance, in-field retrofit and 

modifications, treaty verification, and managing storage sites and their corresponding monitoring 

programs have not been adequately addressed in the SNL TBD. This is confounded by the 

absence of offsite data in the SNL exposure files and the lack of direction to the dose 

reconstructors on when to request data from other sites. 

While it is understood that NIOSH, under EEOICPA protocols, establishes work location 

(including work at other AEC or DOE sites to enable dosimetry records to be obtained), it is not 

clear from the SNL, and other NTS, or PPG site profiles how visiting SNL employees were 

monitored for neutron and internal radiation exposures. Internal and external exposure hazards 

during field testing require further consideration to determine if appropriate internal and external 

monitoring occurred. If adequate monitoring did not occur at these offsite work locations, the 

TBD does not provide instructions for bounding these potential exposures. A missed dose 

methodology should be included for unmonitored or inadequately monitored personnel who 

participated in weapons testing and other field activities. Where available, references to other site 

profiles are appropriate. Methodologies for activities at continental tests outside of Nevada 

require treatment in the site profile, a separate site profile, or a TIB. 

4.1.3 Objective 3: Adequacy of Data 

Historically, SNL relied heavily on outside vendors to provide bioassay data. Concerns about the 

accuracy and completeness of data from these support contractors have not been fully considered 

in SNL’s TBD. If LANL was the prime source of bioassay results for years before 1991, this 

could have a significant impact on the internal dose assessments of SNL workers. Data 

deficiencies during the 1943–1949 time period would clearly impair the ability to conduct dose 

reconstructions on SNL workers, who were a part of the Z-division of LANL during this time. 

From 1950 to 1975, there are data deficiencies for mixed fission products/mixed activation 

products (MFP/MAP), which have been identified as a major contributor to internal dose at SNL. 
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SNL housed several reactors, accelerators, and was heavily involved in testing that potentially 

resulted in exposures to fission and activation products. 

In addition to concerns regarding LANL bioassay data, the SNL TBD describes bioassay results 

from a commercial laboratory, CEP, which were invalidated based on the results of quality 

control samples and other data integrity issues (ORAUT. 2007a, pg. 59). No explanation is 

provided, however, on how the TBD will address acute uptakes which may have occurred during 

this time period. Considering the importance of bioassay data from LANL and CEP, further 

verification of data completeness and accuracy is warranted. It would be highly desirable for the 

verification and validation process to be used and identified in the revised site profile. 

The environmental exposure calculations used for assessing intakes of airborne radionuclides 

provided in the environmental dose section of the SNL TBD, ORAUT-TKBS-0037 (ORAUT 

2007a), used source term data that may be inaccurate, incomplete and not claimant favorable. 

There are periods of time that NIOSH could not find any emission or environmental monitoring 

data to calculate the actual air concentrations to which unmonitored workers could have been 

exposed. The methods that NIOSH used to assign intakes for some of these areas were not 

clearly explained, and, in some cases when the methods were explained, there is question on the 

validity of the assumptions used. For some areas of environmental exposure, NIOSH appears to 

have left out potentially significant radionuclides in the assessment of environmental dose. It is 

not apparent that NIOSH has assessed the impact that inferred incompleteness and inadequacy of 

the earlier monitoring data could have had on the emissions estimates. 

DU is not considered by NIOSH in the environmental dose source term at Tonopah Test Range 

(TTR) in this TBD, and there is no discussion why it is not considered. NIOSH estimates the 

radionuclide intakes for all years at TTR, going back to 1963, by using air monitoring data from 

1996–1997, which analyzed for Pu isotopes and Am-241. Proposing that it is reasonable to 

assume the air concentrations were similar in the earlier years may not be accurate, particularly 

when considering that soil radionuclide concentrations and resuspension rates could be different 

due to weathering of the soil. 

The assignment of the environmental external doses from TLD data does not have a clear basis, 

and is not supported with any analysis of background and onsite environmental dosimeters to 

accurately determine if there were higher levels onsite. There was no discussion detailing the 

dosimeter locations that were placed on site and whether these were representative for estimating 

non-monitored worker dose. Assessment of possible doses from radioactive particles on skin is 

missing, and is in disagreement with discussion in the Scope of the TBD (ORAUT 2007a, 

Section 1.2) which identifies this as being covered in the environmental dose section. 

There is no discussion on any air monitoring in TA-III for emissions from waste landfills after 

1973 (ORAUT 2007a). 

The TBD states that there was no emission monitoring for the area before 1973, and it identifies 

that there were diffuse sources of airborne radionuclide releases. The TBD (ORAUT 2007a) 

does not state how it estimated the air concentrations that caused intakes in this area. There is no 

discussion on any air monitoring in TA-III for emissions from waste landfills after 1973. 
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NIOSH may not have reviewed environmental monitoring data (ambient air, soil, vegetation, 

water) that may be available for these years because this data is not discussed in the TBD 

(ORAUT 2007a). Only post-1980 environmental TLD data for ambient external exposure is 

discussed. There is also no discussion in the TBD regarding fugitive emissions that could have 

given rise to environmental doses. 

NIOSH does not discuss the level of uncertainty in the stack/vent emissions monitoring in any 

detail. It may be possible that uncertainties (standard deviations) could have been reported in the 

original stack emissions concentration data to determine the laboratory component of the source 

term uncertainty. 

4.1.4 Objective 4: Consistency among Site Profiles 

The SNL TBD attempted to include offsite activities, such as those at NTS and TTR, in the site 

description. This inclusion is an improvement over the site profiles for LANL and LLNL. The 

TBD indicates to the dose reconstructor that data from facilities other than SNL may have to be 

requested for a full dose reconstruction, and informs them that TBDs from other facilities may 

apply. 

Table 6-8, footnote a on page 104, indicates that a multiplication factor of 1.876 should be used 

to obtain the low-energy photon dose, but the text in the paragraph below the table lists a 

multiplication factor of 1.86 to obtain the low-energy photon dose. 

In the second sentence of the last paragraph on page 105 of Section 6.9, it states, “...100% 

fission spectrum neutrons (0.1 to 1 MeV) is used.” However, in Table 6-11on page 106 for 

Reactor operations, the neutron energy is listed as 0.1–2 MeV at 100%. 

4.1.5 Objective 5: Regulatory Compliance 

No regulatory compliance issues were identified by SC&A in the SNL Site Profile. 

4.2 USABILITY OF SITE PROFILE FOR INTENDED PURPOSES 

4.2.1 Ambiguous Dose Reconstruction Direction 

The site profile points out that because of the perception that the potential for intakes at SNL was 

small, the routine bioassay program was not formalized until after 1992. Before that time, 

monitoring for intakes was not regularly performed. Then, for plutonium and uranium (ORAUT 

2007a, pp. 67 and 76), it notes that a special sampling program would be initiated when a 

radiological incident occurs or “A positive routine bioassay sample result is obtained that 

indicates the possibility of an unexpected dose of 100 mrem CEDE or more” (emphasis 

added). This may be valid after 1992; however, there was no formalized routine bioassay 

monitoring program prior to 1992. 
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ORAUT 2007a (pg. 76) further notes the following: 

Because no workers participate in a routine bioassay program, there is no 

protocol for routine sampling on a Friday or Monday (Potter 2006c). 

Then it goes on to state the following: 

According to a 1993 memorandum, individuals handling 10 μCi or more of DU 

would be required to participate in the bioassay program (SNL 1992c). 

Which of these statements is true? 

The appearance of conflicting statements in the case of tritium is described in Finding 3.7. 

If the neutron and photon penetrating doses at SNL were sometimes combined and entered as 

one value, it will make it difficult for the dose reconstructor to separate them out for individual 

dose assignments in the IREP Input tables. 

Unmonitored dose and MND appear to be intermixed in Sections 6.7 and 6.8 of the current TBD, 

which may make it difficult for the dose reconstructors to use consistent and correct methods to 

assign unmonitored and MNDs. 

It is not clear what final value NIOSH is recommending the dose reconstructor use for the 

uncertainty for neutron doses as a function of time period; i.e., values for overall bias, range in 

bias, systematic and random uncertainty factors are listed, but no combined final values are 

provided for the dose reconstructor to use. 

Determination of shallow and nonpenetrating doses from original data sheets covers only the 

period of 1977–2005, and does not contain data or instructions for the dose reconstructor 

concerning the values to use for assigning nonpenetrating coworker dose for the period 1949–

1976, when nonpenetrating doses were not measured and/or recorded. 

The TBD does not address if SNL’s standard dosimetry practice was to subtract background 

badge readings from the workers’ badge readings before recording the final dose. This issue is 

important to the dose reconstructor when determining if environmental external site doses should 

be assigned. 

4.2.2 Inconsistencies and Editorial Errors in the Site Profiles 

Dose terms should be consistent and defined when used in the TBD, and the TBD should 

investigate their meanings when they were used in the different record systems and provide this 

information for the dose reconstructor. A small amount of information concerning dose 

recording terms is provided in the TBD on pages 98, 99, and 104; however, this information may 

not be sufficient to provide the dose reconstructor with the tools necessary to sort out the details 

of the dose data contained in a claimant’s records. 
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4.3 UNRESOLVED POLICY OR GENERIC TECHNICAL ISSUES 

A number of issues identified in the SNL TBD review represent potential generic policy issues 

that transcend any individual site profile. Issues raised in the review that are common to other 

ongoing investigations include dose assessments for STCs, dose reconstruction to workers 

involved in weapons testing, the adequacy of bioassay techniques to evaluate exposure to nonroutine radionuclides, and the lack of characterization of external exposure fields, particularly 

neutron exposure. 
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5.0 REFERENCES 

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Massachusetts, February 6, 2007. 

Argall, R.S., 2007b. Discussion of the status of the bioassay analysis and results prior to 1992; 

email correspondence with [Name redacted] (SNL retiree). ENSR/AECOM, Westford, 

Massachusetts, February 6, 2007. 

Argall, R.S., 2007c. Statement based on review of records by Rowena S. Argall, CHP. ENSR. 

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Argall, R.S., 2007d. Note that explains that a table of nuclear weapons tests is included to assist 

the dose reconstructor in recognizing the names of these tests. Argall, Rowena S. CHP. ENSR. 

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Banister, J.R., 1994. Historical Sketches of Sandia National Laboratories Nuclear Field Testing, 

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.
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ATTACHMENT 1: NIOSH TECHNICAL DOCUMENTS CONSIDERED 

DURING THE REVIEW PROCESS 

Technical Basis Document 

ORAUT-TKBS-0037, Rev. 00, (ORAUT 2007a). Site Profile for Sandia National Laboratories 

in Albuquerque, New Mexico, and the Tonopah Test Range, Nevada,), June 22, 2007. 

Technical Support Documents 

OCAS-TIB-002, Rev. 00 (OCAS 2003). Technical Information Bulletin – Tritium Calculations 

with IMBA, OCAS (Office of Compensation Analysis and Support), Cincinnati, Ohio, April 22, 

2003. 

OCAS-TIB-009, Rev. 00 (OCAS 2004). Estimation of Ingestion Intakes., Office of 

Compensation Analysis and Support, Cincinnati, Ohio, April 13, 2004. 

ORAUT-OTIB-0002, Rev. 01 PC-2, (ORAUT 2004a), Technical Information Bulletin, 

Maximum Internal Dose Estimates for Certain DOE Complex Claims, Oak Ridge Associated 

Universities, Oak Ridge, Tennessee, May 7. 

ORAUT-OTIB-0006, (ORAUT 2005c). Technical Information Bulletin: Dose Reconstruction 

from Occupationally Related Diagnostic X-ray Procedures , Rev. 03, Oak Ridge Associated 

Universities, Oak Ridge, Tennessee. December 21, 2005. (Kathren and Shockley 2005). 

ORAUT_OTIB-0014, Rev. 00, 2004b. Technical Information Bulletin – Assignment of 

Environmental Internal Doses for Employees Not Exposed to Airborne Radionuclides in the 

Workplace, ORAUT-OTIB-0014, Rev. 00, Oak Ridge Associated Universities Team , Oak Ridge 

Associated Universities, Oak Ridge Tennessee, June 22, 2004. 

ORAUT-OTIB-0018, Rev. 01, (ORAUT 2005d). Technical Information Bulletin – Internal 

Dose Overestimates for Facilities with Air Sampling Programs, Oak Ridge Associated 

Universities, Oak Ridge, Tennessee, August 9, 2005, (Brackett & Bihl 2005). 

ORAUT-OTIB-0033, Rev. 00, (ORAUT 2005b). Technical Information Bulletin – Application 

of Internal Doses Based on Claimant-Favorable Assumptions for Processing as Best Estimates, 

Oak Ridge Associated Universities Team ,Oak Ridge Associated Universities: Oak Ridge, 

Tennessee, April 20, 2005. 

ORAUT-PROC-0061, Rev 01, (ORAUT 2006a). Occupational X-Ray Dose Reconstruction for 

DOE Sites, Oak Ridge Associated Universities, Oak Ridge, Tennessee, July 21, 2006, (Winslow 

2006) 
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ORAUT-OTIB-0066, Rev. 00, (ORAUT 2007b) Technical Information Bulletin: Calculation of 

Dose from Special Tritium Compounds. Oak Ridge Associated Universities Team, Oak Ridge 

Tennessee, April 26, 2007. 
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ATTACHMENT 2: SITE EXPERT INTERVIEW SUMMARY 

[TBD] 
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ATTACHMENT 3: KEY QUESTIONS AND RESPONSES FOR 

NIOSH/ORAU REGARDING SITE PROFILE DOCUMENTS 

SC&A submitted questions related to Revision 00 of the SNL Site Profile Documents (dated 

August 8, 2007) to NIOSH on February 21 2008. The NIOSH/ORAUT team provided written 

responses to these questions on March 21, 2008. Both the questions and responses have been 

provided below. 

Site Description 

1. The TBD indicates that SNL employees have routinely been involved in operations at a 

number of Sandia Corporation sites. These sites included SNL-Livermore; Hattiesburg, 

Mississippi; the Nevada Test Site; Clarksville, Tennessee; and Slaton Bay Station, California. 

Furthermore, Table 5-3 includes nuclear weapons tests that occurred at Bikini Atoll and 

Fallon, Nevada. SNL also stationed staff at the weapons storage facilities (pg. 54, 57). The 

TBD indicates that exposure data from these sites may not be included in the SNL dosimetry 

records. With incomplete records, how can NIOSH with certainty determine whether 

workers were potentially exposed at these other facilities? For which sites is NIOSH 

automatically pursuing dose records other than SNL? 

ORAUT: Records are routinely requested from facilities other than SNL based on 

documented employment at other facilities. 

2. Is it assumed that the dose reconstruction for 1945–1949 is covered under the LANL site 

profile? 

ORAUT: Although work performed in the early years prior to 1950 was for the LANL site, 

SNL was considered a separate entity starting in 1949, according to the DOE Office of 

Heath, Safety and Security website. The Sandia site profile covers the time at the 

Albuquerque facility with some references to LANL. ORAUT will use the best available 

information to complete dose reconstructions. 

Occupational Internal Dose 

1. On page 76, paragraphs 4 and 5 under Sampling Protocol, aren’t these two paragraphs 

conflicting? “Because no workers participate in a routine uranium bioassay program, 

there is no protocol for routine sampling on a Friday or Monday.” And, “According to a 1993 

memorandum, individuals handling 10 μCi or more of DU would be required to participate 

in the bioassay program.” (emphasis added) 

ORAUT: The second statement says “would be” required to participate, indicating that no 

workers were working with the specified quantity of material but would be placed on a 

program if such work should occur. Also, the lack of a routine program doesn’t mean that 

there is no monitoring at all for uranium workers. The first paragraph in the section 

discusses incident, confirmatory, and follow-up samples. It’s agreed that this section could 

be expanded to make this clearer. 
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2. Doesn’t the first paragraph of the Sampling Protocol section also appear to have conflicting 

statements? “Historically and currently, there has been no routine sampling program for 

uranium.” And, “A special sampling program would be initiated when a radiological 

incident occurs or a positive routine bioassay sample result is obtained that indicates the 

possibility of an unexpected dose of 100 mrem CEDE or more.” (emphasis added) 

ORAUT: Agreed. It would appear that generic information about a special sampling 

program was included in this paragraph rather than information specific to the particular 

nuclide under discussion. 

3. The TBD mentions several times that bioassay results performed by Controls for 

Environmental Pollution (CEP) between 1992 and 1994 should be considered invalid. How 

does NIOSH plan to assess incidental intakes during this time period? 

ORAUT: Currently, cases where individuals have monitoring after the CEP period can be 

done using standard assumptions, except in the case of short-retained nuclides, such as H-3, 

because the later result can be used to put an upper bound on intakes. Missed dose can be 

calculated for those with endpoints during the CEP period assuming the Sandia requested 

MDA at the end of their employment. We're currently in the process of looking at a 

coworker study, including the determination of whether we can bound those two years with 

the earlier and later data. 

4. The TBD refers to a memorandum of understanding between SNL-NM and LANL to 

conduct bioassay for tritium from 1945–1949. The evaluation report for SEC-00051 has 

stated that dose reconstruction is not feasible for tritium from 1943–1949. How can NIOSH 

reconstruct dose for tritium samples analyzed at LANL for Sandia when it was determined 

tritium dose at LANL cannot be reconstructed? 

ORAUT: SEC determination at LANL does not cover Sandia and infeasibility for a nuclide 

does not necessarily apply. In the absence of other data, tritium data for Sandia employees 

would be evaluated assuming LANL did the analyses. 

5. The TBD indicates that SNL had an MOU with LANL to perform whole-body and lung 

counting for workers. Furthermore, the TBD indicates that whole-body counts were 

performed for workers with potential intakes of fission and activation products. The 

evaluation report for SEC-00051 has stated that reconstruction is not feasible for mixed 

fission and activation products from 1943–1975 which encompasses some years where 

whole-body/chest counting was available at LANL. How can NIOSH/ORAUT reconstruct 

dose for SNL workers when it was determined dose reconstruction for mixed fission products 

(MFP)/Mixed Activation Products (MAP) at LANL is not feasible? 

ORAUT: The infeasibility at LANL is not because of inadequacies in the whole body 

counting technique but one of insufficient data for individuals who should have been 

monitored but were not. This issue would not automatically carry over to Sandia. 
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Occupational External Dose 

1. Uncertainty – Section 6.4 of the TBD contains some information concerning bias and 

uncertainty factors. It appears from the first paragraph that the recommended photon error is 

+30% for all energies and all dosimetry systems (is this correct, or is the dose reconstructor 

(DR) to use some combination of the uncertainty factors listed in Table 6-6?). Additionally, 

it not clear what final value NIOSH is recommending the DR use for the uncertainty for 

neutron doses as a function of time period; i.e., values for Overall bias, Range in bias, 

Systematic and Random Uncertainty factors are listed, but no combined final values for the 

DR to use are provided. Could NIOSH please clarify this issue by stating the final 

uncertainty values for photons and neutrons the DR is to use? 

ORAUT: The photon dose component is typically evaluated using a constant dose for IREP 

parameter #1 in which the measured dose is multiplied by 1.3 using a claimant favorable 

option for the Site Profile stated ±30% variability. Prior to 1972, neutron doses are 

determined by multiplying the measured and missed photon dose times a neutron-to-photon 

ratio and using the photon dose uncertainty. From 1972 the measured neutron dose is used in 

the dose reconstruction along with a calculated missed neutron dose. 

2. Early TLD Minimum Detectable Limits (MDLs) – Section 6.5, page 102, second 

paragraph, of the TBD states that “Because of the lack of site specific data on MDLs for the 

early TLDs used 1971–1990, these dosimeters are estimated to have had MDLs between 

those for the film badges and the more advanced TLDs.” Additionally, Footnote c. of 

Table 6-10 on page 105 states that “Because of the lack of site specific data on MDLs for the 

early TLDs used 1971–1989, these dosimeters are estimated to have had MDLs between 

those for NTA film and the more advanced TLDs.” This assumptions needs to be supported 

by documentation. Could NIOSH provide further support for using this methodology? 

ORAUT: ORAUT-OTIB-0008, “A Standard Methodology for Overestimating External 

Doses Measured with Thermoluminescent Dosimeters” lists a history of implementation of 

TLD-based external dosimetry programs at DOE sites. Because TLDs have technical 

advantages over film dosimeters such as near tissue-equivalent response and general 

insensitivity to many environmental parameters, the limit of detection for TLDs is lower than 

film dosimeters. The highest limit of detection for photon TLD dosimeters from all the sites 

listed in the OTIB is 0.020 rem which is the limit of detection used for the Sandia site when 

TLDs were implemented. This should be a reasonable estimate for the TLDs used at Sandia. 

3. Use of NTA data – Table 6-6, page 101, and Table 6-10, page 105, lists data for NTA film. 

However, page 101 and 105 also recommends using the n/p method to determine measure 

and missed neutron dose. Is it correct to assume the NTA data is included for completeness 

and not to be used by the Dose Reconstructor (DR) in reconstructing doses in actual cases? 

ORAUT: The NTA film data is included for completeness. The neutron-to-photon ratios 

should be used prior to 1972. As with all sites that fit in this category, a comparison should 

be performed using the actual positive neutron dosimeter results and the dose calculated 

based on an N:P ratio, using the higher of the two. 
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4. Use of thermoluminescent dosimeter (TLD) n/p data for what time period(s) – Table 6-9 

on page 104 of the TBD lists recommended n/p values to be used for workers that were not 

monitored for neutrons. It is not clear from the TBD if these values are to be used only for 

unmonitored workers, when neutron dose reconstruction is needed, for the time periods of 

1977–1984 and 1987–2005 when this data was obtained, or if these n/p values are also to be 

used for workers that were monitored using NTA film, or should have been monitored but 

were not, during 1949–1971 because of the problems with the NTA film response as stated 

on page 101 of the TBD, second paragraph of Section 6.4 and also during other years when 

TLDs were used. Could NIOSH please provide a statement concerning the time period(s) 

and conditions when the n/p values in Table 6-9 are to be applied? 

ORAUT: The parameters of the distributions of neutron-to-photon dose ratio distributions in 

Table 6-9 are used prior to 1972 when thermoluminescent dosimeters replaced NTA film at 

SNL-NM for neutron dosimetry. Whether or not to assign neutron doses for unmonitored 

workers is determined based on the records provided as discussed in the first paragraph of 

section 6.7. 

5. Use of TLD n/p data for all periods – If the n/p values in Table 6-9 on page 104 of the 

TBD are to be used to assign neutron dose to workers during the 1949–1971 time period 

when NTA film was used and during other years when TLDs were used, what has NIOSH 

done to verify the use of this limited number of n/p values (over a limited time period) to all 

other time periods and exposure conditions when operating conditions, sources, shielding, 

and safety precautions varied considerably from the later time period (during which the n/p 

values were determined)? 

ORAUT: The distribution of measured neutron and photon doses and the associated 

variability is indicative of worker exposures with the TLD. For earlier years, the uncertainty 

of the distribution is used to provide a reasonable estimate of the neutron to photon dose ratio 

to be used. The use of the 95th percentile ratios from Table 6-9 is expected to provide a 

claimant-favorable option. 

Occupational Medical Exposure 

1. In the (Stout 2005) memorandum of December 14, 2005, it was pointed out that, as a result 

of the review of a few film jackets, there appeared to be no shielding for lumbar spine 

examinations done in the 1950s. In developing the calculated ESEs for lumbar spines in 

Table 3-2 (ORAUT 2007a, pg. 26), how was this lack of shielding taken care of in 

developing the calculated ESEs in Table 3-2 (ORAUT 2007a, pg. 26)? Please explain how 

this is resolved in developing the more realistic value of 400 mR for the ESE for an AP 

lumbar spine and an AP angle lumbar spine radiograph and the more realistic ESE of 2,250 

mR for a LAT lumbar spine radiograph and a LAT Lumbar spine spot film during the period 

1953 to 1978, based on BRH 1970, pp. 159–160? 

ORAUT: None of the ESEs would have been reduced to account for use of gonadal 

shielding, even if evidence of its use was found for Sandia. 
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Occupational Environmental Dose 

1. In the section covering ambient external radiation (4.4), NIOSH discusses the monitoring 

done by Sandia with environmental TLDs and their modeling of external doses from plumes 

of short-lived activation products. It is not clear how NIOSH estimated the three 

environmental external doses (<1 mrem, 5 mrem, 10 mrem) assigned to workers at SNL-NM 

shown in Table 4-2. Did NIOSH base the external radiation doses for workers at SNL-NM 

on the TLDs or modeling of exposure from plumes or both? 

ORAUT: Based on the TBD, it appears that plumes of short-lived activation products was 

used prior to 1980, and starting in 1980 TLDs were used. 

If it was based on TLDs, did NIOSH determine these were in locations of maximum 

environmental exposure and did NIOSH find appropriate background TLD values to subtract 

from the onsite TLD measured doses? 

ORAUT: Many area locations were monitored including areas that were monitored because 

of higher external dose rates. Outliers were removed from the data prior to the analysis. 

Additionally, some of the higher results were used to apply higher doses to adjacent areas as 

a claimant-favorable assumption. The doses include either external radiation doses, doses 

from passing plumes, or both, depending on the years. 

2. NIOSH uses 1996–1997 ambient air monitoring data to estimate intakes and doses from 

resuspension of Pu-238, Pu-239/240, and Am-241 at TTR that occurred several years earlier. 

In the LANL Occupational Environmental Dose TBD (Cehn and McDowell-Boyer 2004), it 

is stated that soil with older contamination is less of a resuspension issue than soil recently 

contaminated because erosion and downward migration of radionuclides from the upper soil 

layers diminish the source term over time. Why does NIOSH assume that using 1996–1997 

air monitoring data to estimate intakes as much as 33 years earlier is being claimant 

favorable with respect to the inference from the LANL TBD statement that the older soil 

(that was there in 1996–1997) may not have generated as much of a resuspension source as 

the contaminated soil did in the earlier years (going back to 1963)? 

ORAUT: Section 4.2.2 discusses how each of the Clean Slate sites was cleaned up shortly 

after each test. Test-related debris was bladed into a hole at ground zero and backfilled. 

Fences were built around each test area for control. Therefore, for the majority of workers at 

TTR, the resuspension values mentioned would result in reasonable dose estimates. For the 

few workers that worked on the cleanup of the Clean Slate sites in 1963, higher values would 

be more appropriate. For those workers another method would have to be used to calculate 

an internal dose. 

Document Requests 

1. Throughout the TBD (Buddenbaum et al. 2007) ORAUT references discussions with SNL 

retirees and current staff. ORAUT also calls out interviews conducted with [names 

redacted]. SC&A requests access to interviews, notes, and correspondence between ORAUT 
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and current or former workers at SNL. Furthermore, SC&A requests access, under 

appropriate security protocol, to classified interviews that may have been conducted. 

Interview information is not currently available in the ORAU Site Research Database. 

ORAUT: When interviews were documented, the documentation is uploaded to the Site 

Research Database. There are some cases where interviewers did not document the 

interviews performed, and references to these interviews will not appear in future revisions of 

the Site Profile. The Site Research Database remains the repository for project documents, 

including interview notes.