Draft 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

National Institute for Occupational Safety and Health 

REVIEW OF THE SUMMARY SITE PROFILE FOR THE SANDIA 

NATIONAL LABORATORIES AT LIVERMORE, CALIFORNIA 

Contract No. 200-2009-28555 

SCA-TR-SP2012-0003, Revision 0

Prepared by 

Joseph Fitzgerald 

S. Cohen & Associates 

1608 Spring Hill Road, Suite 400 

Vienna, Virginia 22182 

Saliant, Inc. 

5579 Catholic Church Road 

Jefferson, Maryland 21755

October 2012 

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

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Document No. 

SCA-TR-SP2012-0003 

Effective Date: 

Draft – October 2, 2012 

S. COHEN & ASSOCIATES: 

Technical Support for the Advisory Board on 

Radiation & Worker Health Review of 

NIOSH Dose Reconstruction Program Revision No. 0 – (Draft) 

REVIEW OF THE SUMMARY SITE 

PROFILE FOR SANDIA NATIONAL 

LABORATORIES AT LIVERMORE, 

CALIFORNIA

Page 2 of 73 

Task Manager: 

________________________ Date: ___________ 

Joseph Fitzgerald 

Supersedes: 

N/A 

Project Manager: 

________________________ Date: ___________ 

John Stiver, CHP 

Reviewer(s): 

 John Mauro 

 John Stiver 

Record of Revisions 

Revision 

Number 

Effective 

Date Description of Revision 

0 (Draft) 10/02/2012 Initial issue 

10/17/2012 Minor redactions that were limited to some legal interpretations were made in this 

document when cleared for potential Privacy Act-protected information. No 

technical information was redacted. 
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NOTICE:

TABLE OF CONTENTS 

Acronyms and Abbreviations ..........................................................................................................4 

1.0 Executive Summary.............................................................................................................7 

1.1 Summary of Primary Findings.................................................................................8 

1.2 Opportunities for Improvement .............................................................................11 

2.0 Scope and Introduction ......................................................................................................12 

2.1 Review Scope.........................................................................................................12 

2.2 Assessment Criteria and Methods..........................................................................14 

2.1.1 Objective 1: Completeness of Data Sources.............................................14 

2.1.2 Objective 2: Technical Accuracy..............................................................14 

2.1.3 Objective 3: Adequacy of Data.................................................................14 

2.1.4 Objective 4: Consistency among Site Profiles..........................................15 

2.1.5 Objective 5: Regulatory Compliance........................................................15 

2.3 Report Organization...............................................................................................15 

3.0

.................................................................................................................................17 

Findings Identified in the Sandia National Laboratory, Livermore, California Site 

Profile

3.1 Finding 1: Lack of Characterization of Offsite Worker Activities.......................17 

3.2

...............................................20 

Finding 2: Incomplete and Unclear External and Internal Monitoring Data 

Makes Their Use in Dose Reconstruction Difficult

3.3

...................................................26 

Finding 3: Absence of Internal Dosimetry Personnel Monitoring for 

Radionuclides Other than Tritium and Uranium

3.4

.....................................................30 

Finding 4: The TBD has Not Adequately Characterized the External 

Monitoring Program Implemented at SNL CA

3.5

............................................................................................34 

Finding 5: The SNL CA TBD has Not Adequately Characterized Neutron 

Exposures and has Not Accounted for the Lack of Response of NTA Film to 

Low-Energy Neutrons

3.6 Finding 6: Lack of Consideration of Special Tritium Compounds.......................35 

3.7

................................................................................................................40 

Finding 7: Assumptions for Uranium Dose Assessment are Not Claimant 

Favorable

3.8 Secondary Findings................................................................................................44 

4.0 Overall Adequacy of the Site Profile as a Basis for Dose Reconstruction ........................50 

4.1 Objective 1: Completeness of Data Sources.........................................................50 

4.2 Objective 2: Technical Accuracy..........................................................................51 

4.3 Objective 3: Adequacy of Data.............................................................................53 

4.4 Objective 4: Consistency among Site Profiles And Other NIOSH Documents ...53 

4.5 Objective 5: Regulatory Compliance....................................................................53 

4.6 Ambiguous Dose Reconstruction Direction ..........................................................53 

4.7 Unresolved Policy or Generic Technical Issues....................................................54 

5.0 References..........................................................................................................................55 

Attachment 1: Summary of Site Expert Interviews......................................................................62 
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ACRONYMS AND ABBREVIATIONS 

Advisory Board 

or ABRWH Advisory Board on Radiation and Worker Health 

AEC U.S. Atomic Energy Commission 

AMAD Activity median aerodynamic diameter 

ANL Argonne National Laboratory 

AP Anterior-Posterior 

ARG Accident Response Group 

CATI Computer Assisted Telephone Interview 

CDHS California Department of Health Services 

CEP Controls for Environmental Pollution 

CFR Code of Federal Regulations

Ci curie 

CRF Combustion Research Facility 

D&D decontamination and decommissioning 

DOD Department of Defense 

DOE U.S. Department of Energy 

DOE-AL Department of Energy – Albuquerque 

DOELAP Department of Energy Laboratory Accreditation Program 

dpm disintegrations per minute 

DU Depleted Uranium 

EEOICPA Energy Employees Occupational Illness Compensation Program Act of 2000 

ESE entrance skin exposure 

EU Enriched Uranium 

FDA Food and Drug Administration 

g gram 

GPS Gas Purification System 

HEPA High Efficiency Particulate Air 

HHS Health and Human Services 

HTO tritiated water vapor 

IAAP Iowa Army Ammunition Plant 

ICRP International Commission on Radiological Protection 
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IREP Interactive RadioEpidemiological Program 

KCP Kansas City Plant 

L liter 

LANL Los Alamos National Laboratory 

LAT Lateral 

LLNL Lawrence Livermore National Laboratory 

LOD Limits of Detection 

keV kiloelectron volt 

kVp peak kilovoltage 

mA milliamperes 

MAP Mixed Activation Products 

MDA Minimum Detectable Amount 

MDL Minimum Detection Limit 

MeV megaelectron-volt, 1 million electron-volts 

MFP Mixed Fission Products 

mR milliRoentgen 

mrem millirem 

NIOSH National Institute for Occupational Safety and Health 

NTA Nuclear Track Film Type A

NTS Nevada Test Site 

NU Natural Uranium (or U-nat) 

OBT Organically-bound Tritium 

ORAUT Oak Ridge Associated Universities Team 

OTIB Oak Ridge Associated Universities Team Technical Information Bulletin 

PA Posterior-Anterior 

pCi picocurie 

PNNL Pacific Northwest National Laboratory 

POC Probability of Causation 

PPG Pacific Proving Ground 

ppm parts per million 

R&D Research and Development 

RadCon Radiological Control 
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NOTICE:

RDC Radiation Detection Company 

RFP Rocky Flats Plant 

RESL Radiological and Environmental Sciences Laboratory 

SC&A S. Cohen & Associates, Inc. 

SDI Strategic Defense Initiative 

SEC Special Exposure Cohort 

SLL Sandia Laboratories – Livermore 

SNL Sandia National Laboratory 

SNL NM Sandia National Laboratory in Albuquerque, New Mexico 

SNL CA Sandia National Laboratory in Livermore, California 

SRDB Site Research Database 

SRS Savannah River Site 

SSTB Salton Sea Test Base 

STC Special Tritium Compound 

TBD Technical Basis Document 

TIB Technical Information Bulletin 

TLD Thermoluminescent dosimeter 

TLV Threshold Limit Value 

TRL Tritium Research Laboratory 

TTR Tonopah Test Range 

TWA Time-weighted Average 

U-nat Natural Uranium (or NU) 

VERS Vacuum Effluent Recovery System 

yr Year 
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1.0 EXECUTIVE SUMMARY 

This draft report presents the S. Cohen and Associates’ (SC&A’s) evaluation of the National 

Institute for Occupational Safety and Health (NIOSH) Site Profile for the Sandia National 

Laboratories in Livermore, California (SNL CA) (ORAUT 2007a), which was issued as a 

summary site profile document. This work was authorized by the Advisory Board on Radiation 

and Worker Health (Advisory Board) and by SC&A’s Project Officer during the full Board 

meeting held in Augusta, Georgia, on December 16–18, 2008. This review was conducted 

during the period February 2009 through February 2010. It was conducted in accordance with 

the Board’s “Data Access and Interview Procedures,” (ABRWH 2009a) as well as Boardapproved SC&A procedures for the conduct of site profile reviews (SC&A 2004). 

Sandia National Laboratory (SNL) originally established a facility in Albuquerque, New Mexico, 

in 1949. At the direction of the Atomic Energy Commission (AEC), Sandia was asked to 

establish a second facility in Livermore, California, in 1956. Construction was completed in 

1959. Its mission was to provide ordnance engineering support to Lawrence Livermore National 

Laboratory (LLNL). The Sandia National Laboratory – Livermore (SNL CA) facility was 

originally a 75-acre lot on East Avenue, across the road from LLNL. In 1970 and 1979, SNL 

CA acquired an additional 86 acres and 24 acres, respectively, for a total of 185 acres. In 1985 

and 1986, there was an additional 228 acres added for security purposes. Two test sites, 

Tonopah Test Range and Kauai, are operated under Sandia. The current missions of Sandia 

National Laboratories are (Loeber 2002, Sandia 1983): 

 Conduct research and engineering activities 

 Conduct experiments on nuclear weapons effects 

 Design non-nuclear components and perform related system engineering 

 Manufacture selected non-nuclear components 

 Modify weapons to meet new requirements 

 Provide safety and reliability assessments of the stockpile, including verification of the 

integrity of weapons in the stockpile 

 Develop and apply advance technologies to protect nuclear material 

Nuclear ordnance work includes “safing;” command and control; arming, fusing, and firing 

systems; aerodynamics and structures; and related testing and instrumentation. After weapons 

are in the stockpile, quality assurance evaluators periodically obtain samples and test them in the 

laboratory and the field to assure that the components continue to operate safely and reliably. 

Sandia personnel are involved with a nuclear weapons program from its inception through 

retirement from the stockpile. Sandia also began participating in a national effort to develop new 

or improved sources of energy. Although numbers of employees for all years are not available, 

the employee population from 1968 to 1982 ranged from 868 to 1,088. 

A site visit was conducted from June 8–12, 2009, encompassing a comprehensive document 

review and site expert interviews. A subsequent telephone interview was conducted on June 28, 
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2009. Interviews were conducted with 10 former and current SNL CA and SNL NM workers, 

including personnel from radiological control (RadCon) and dosimetry; weapons program 

development, design, and testing; environmental monitoring and waste management; and other 

Research and Development (R&D) programs. The purpose of these interviews was to hear firsthand accounts about past radiological control and personnel monitoring programs, and site 

operations. 

This draft report was prepared at the request of the Advisory Board and provides an evaluation of 

ORAUT-TKBS-0053, Summary Site Profile for Sandia National Laboratories in Livermore, 

California, Rev. 00 (ORAUT 2007a). As part of our evaluation, SC&A also reviewed other 

documents that were considered relevant, including the following: 

 Special Exposure Cohort (SEC) petition documentation for SNL CA 

 Relevant technical information bulletins (TIBs) 

 Select documents that were referenced in the SNL CA site profile 

 Documents contained in the NIOSH Site Research Database (SRDB) 

 Documents retrieved from data captures at SNL NM and SNL CA 

 Other site profiles providing input to the SNL CA site profile 

The review found that the Summary Site Profile document for SNL CA (ORAUT 2007a) does 

not provide adequate and sufficient information to guide dose reconstruction for a number of 

critical sources of historic internal and external exposures to SNL CA personnel. The site profile 

fails to address the adequacy and completeness of the SNL CA internal and external personnel 

monitoring data, especially that received during offsite visits or assignments. Bioassay 

monitoring for isotopes other than uranium and tritium is lacking, although there was potential 

exposure to other radionuclides both onsite and offsite. From a preliminary review of available 

SNL CA records and interviews with SNL CA personnel, there is sufficient reason to question 

the completeness, accuracy, and accessibility of bioassay records. The review identified gaps in 

claimant-specific dosimetry data, a lack of direction on where to find other sources of dosimetry 

data, and a lack of direction for the assignment of missed external and internal dose for workers 

potentially exposed to radiation. The site profile does not mention the availability or 

applicability of external or internal coworker models. 

1.1 SUMMARY OF PRIMARY FINDINGS 

A summary of SC&A’s findings for the SNL CA site profile is presented below. The findings 

are detailed in Section 3 of this report. 

Finding 1: Lack of Characterization of Offsite Worker Activities 

There is evidence that many SNL CA workers also worked at other facilities within the weapons 

complex, using SNL CA as their home office (referred to here as “offsite worker” activities). 

However, the SNL CA site profile provides only minimal discussion with respect to those 

activities. The site profile would benefit from (1) a discussion of offsite work activities, 

(2) references to other technical basis documents (TBDs), as appropriate, (3) consideration of the 
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completeness of records provided for exposures during offsite activities, and (4) treatment of 

doses potentially received by the SNL CA workers (which, in many cases, may have exceeded 

doses from onsite activities). Little or no external and internal exposure data exists for those 

individuals who traveled offsite and were potentially exposed to tritium, plutonium, uranium, 

thorium, mixed fission products (MFPs), mixed activation products (MAPs), and other 

radionuclides. 

Finding 2: Incomplete and Unclear External and Internal Monitoring Data Makes Their 

Use in Dose Reconstruction Difficult 

In a preliminary review of claimant files, incomplete, inaccurate, and redundant data was found. 

As a general rule, the dose reconstructor uses the data in the claimant file and default 

assumptions in the site profile to assign doses. Protocol does not require them to consult other 

sources of radiation exposure data, such as processing or analysis logs, bioassay result lists, or 

log sheets that may contain results. Radiation exposure information provided for claimants 

contain monitoring gaps, including periods where all personnel onsite were assigned dosimetry. 

Internal monitoring data is limited in claimant files, but may be found in the medical files where 

such information is often available. In order to obtain a complete monitoring record, additional 

data is available on the SRDB for use, but may be absent from the actual claimant files. The site 

profile does not provide guidance to the dose reconstructor on consulting these additional 

sources, which are sometimes the only source of monitoring data available for the worker. 

Furthermore, there are no internal or external dosimetry coworker models or alternative 

methodologies proposed for the assignment of dose to individuals who were monitored, but for 

whom data is missing or erroneous. Offsite monitoring data is extremely limited in claimant 

files, and requests for data from the visited sites is completely dependent upon input provided by 

the claimants in the Computer-Assisted Telephone Interviews (CATIs), placing an undo burden 

on the claimant (energy employees and survivors) to recall sites visited during employment at 

SNL CA. 

Finding 3: Absence of Internal Dosimetry Personnel Monitoring for Radionuclides other 

than Tritium and Uranium 

The site profile incorrectly considers internal dose from only tritium and depleted uranium (DU) 

at SNL CA. To some extent, SNL CA handled numerous other radionuclides, including thorium, 

thorium daughters, radium, radium daughters, enriched uranium (EU), MFPs, and MAPs. The 

quantity and details of handling are not readily available and require further investigation. The 

absence of an internal monitoring program for radionuclides other than tritium and uranium can 

lead to potential missed dose for onsite activities involving these other radionuclides. Additional 

information on processes involving these materials may only be available in classified 

documentation. Internal exposures were as likely, if not more likely, for activities Sandia 

personnel conducted at other DOE Complex sites. Potential exposures to radionuclides 

encountered at other sites include plutonium, thorium, MFPs, and MAPs. The limited tritium 

and uranium monitoring implemented at SNL CA is not adequate for detection of these other 

radionuclides, assuming any uptakes occurred. Furthermore, information obtained from other 

DOE sites for Sandia workers does not typically include internal monitoring data. SNL NM has 
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also not been able to locate internal monitoring data for workers monitored at sites other than 

SNL CA, with exceptions for only a few facilities and time periods.

Finding 4: External Monitoring Program, as Implemented at SNL CA, is Not Adequately 

Characterized

There is a need to conduct further research on external dosimetry prior to 1989 to better 

understand the details and capabilities of the dosimetry systems implemented. Without sufficient 

information on the dosimetry technology, calibration methods, dose calculation algorithms, and 

adjustments to recorded doses, the development of correction factors, uncertainty, and bias 

factors is not defensible. Some dosimetry systems used at SNL CA had inadequate 

discrimination between beta, photon, and neutron exposures, yet exposure reports from this 

period include breakdowns of penetrating and non-penetrating doses. Assumptions regarding 

radiation energy distributions encountered in the field are not based on documented field 

measurements or other objective data. The SNL CA site profile attempts to compensate for its 

lack of dosimetry program data by adopting measurement uncertainty estimates from the 

Hanford site profile. The selection of these values requires further justification, given the 

numerous uncertainties related to dosimetry technology, calibration, processing, and recording 

practices, and differences in exposure conditions between Hanford and SNL CA. There are 

additional uncertainties associated with the assignment of missed dose, since the minimum 

detection limits (MDLs) and exchange frequencies were estimated and cannot be determined 

from records. This concern is confounded by the absence of annual or cycle processing data and 

the reliance on cumulative data in many claimant files. 

Finding 5: Lack of Response of Nuclear Track Type A (NTA) Film to Low-Energy 

Neutrons, and Discrepancies in the Neutron Source Calibration

The site profile does not specifically address the subject of NTA film neutron energy threshold. 

NTA film decreases in response starting at neutron energies below 1 MeV, and is almost 

completely insensitive to neutrons below 0.5 MeV (ORAUT 2007a); therefore, radiation fields 

containing an appreciable percentage of the total dose equivalent due to neutron exposures below 

1 MeV must be evaluated carefully, with attention given to the dose missed resulting from this 

threshold effect. The site profile should address this issue, and make clear and technically sound 

recommendations to compensate for the incomplete neutron doses recorded by NTA film and 

contained in the dose of record. 

Finding 6: Lack of Consideration of Special Tritium Compounds 

The site profile fails to adequately consider potential uptakes of special tritium compounds 

(STCs). Special tritium compounds were generated as a result of dynamic activities conducted at 

the Tritium Research Laboratory (TRL). Uranium and palladium tritide beds were used. Special 

research was conducted to study microstructures of metals and evaluated the effects of pressure, 

temperature, and concentration on diffusion or permeation of tritium gas into metals. Special 

tritium compounds resulted as a byproduct of reactivity, diffusion, and permeation of handling of 

large quantities of tritium gas and tritiated water in structural material and routinely used oils and 

solvents. The site profile assumes HTO for calculation of tritium dose, although other forms of 
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NOTICE:

tritium were present. Assumption of an intake of HTO in place of STCs can underestimate dose 

by orders of magnitude, depending on the type of STC and organ of concern. Currently 

proposed approaches developed by NIOSH for estimating dose from STCs rely on the use of 

urine bioassay results in concentration (e.g., μCi/L) and the ability to identify workers exposed to 

STCs. The site profile should discuss in detail how they will estimate dose from STCs, 

particularly those compounds not readily disassociated to soluble compounds in the body. 

Furthermore, the solubility type assigned for uranium tritide should be consistent with available 

literature and assumptions made in other site profiles and dose reconstruction documentation. 

Finding 7: Assumptions for Uranium Dose Assessment are Not Claimant Favorable 

The detection limit assumed for uranium urinalysis analyzed by fluorometry appears to be too 

low in comparison with detection limits reported elsewhere in the industry for this procedure. 

Detection limits should be re-evaluated or validated with SNL NM and other bioassay providers 

to ensure that they are appropriate. Defaulting to DU for conversion of bioassay in units of mass 

concentration (μg/l) to activity, when the site handled NU and EU, would result in an underestimation of dose for those individuals exposed to normal or EU. Uranium urinalysis samples 

collected from Controls for Environmental Pollution (CEP) (1990–1993, as defined in the site 

profile, and 1992–1994 as defined by the SNL NM contract) is suspect and cannot be used for 

the determination of uranium dose or for inclusion in a coworker model. The solubility 

assumption for UO2 should reflect current literature, and take into account the potential that a 

fraction of this material may behave like Type M rather than Type S material. The solubility for 

uranium tritide is listed as Type S material, whereas uranium tritide is actually a Type F material. 

This correction should be reflected in former, as well as current, dose reconstructions. 

1.2 OPPORTUNITIES FOR IMPROVEMENT 

While the TBD provided some detailed information concerning the history, operational 

developments, and facilities at SNL CA, there was insufficient in-depth development in many 

areas to support adequate dose reconstruction recommendations. Some of these areas are: 

 Different types/sources of radiation fields and their potential exposure to workers 

 Dosimetry systems, changes, and associated problems 

 Accuracy, availability, and adequacy of external dosimetry and bioassay records 

 Data integrity of dose records as record systems changed 

 Coworker internal and external dose data and/or dose reconstruction recommendations 

for under-monitored or unmonitored workers 

The SNL CA site profile was developed without the full benefit of the worker outreach efforts 

described under OCAS-PR-012, Worker Outreach Program and its predecessor ORAUT-PROC0097, Conduct of the Worker Outreach Program (ORAUT 2005e), and implemented in 

ORAUT-PROC-0031, Site Profile and Technical Basis Document Development (ORAUT 

2007f). As a result, there are gaps in the characterization of radiological exposure for SNL CA 

workers, which were confirmed during SC&A site expert interviews. 
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2.0 SCOPE AND INTRODUCTION 

The review of the Summary Site Profile for Sandia National Laboratories in Livermore, 

California (ORAUT 2007a) was authorized by the Advisory Board at its December 16–18, 2008, 

meeting in Augusta, Georgia, and conducted during February 2009–February 2010 by a team of 

health physicists and technical personnel. Pertinent records reviewed included both classified 

and unclassified documents located at SNL CA and SNL NM. This review was performed in 

accordance with the Data Access and Interview Procedure (ABRWH 2009a), which provides for 

appropriate onsite coordination and data access protocols in conjunction with the Advisory 

Board, NIOSH, and DOE, and the Department of Energy Classification Review of Documents

(ABRWH 2009b), and provides for appropriate security clearance reviews. 

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

supplemented with NIOSH 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. However, 

future revisions in the SNL CA site profile would serve to mitigate some of the gaps and issues 

raised in this report. 

2.1 REVIEW SCOPE 

The Advisory Board on Radiation and Worker Health (Advisory Board) is mandated to conduct 

an independent review of the methods and procedures used by NIOSH and its contractors for 

dose reconstruction. As a contractor to the Advisory Board, SC&A supports 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 the TBD related to historical occupational exposures at SNL 

CA, ORAUT-TKBS-0053, Summary Site Profile for Sandia National Laboratories in Livermore, 

California (ORAUT 2007a). 

To date, the site profile has not been supplemented by site-specific TIBs, but there are several 

generic TIBs that provide additional guidance to the dose reconstructor. Two SNL CA-specific 

SEC petition evaluation reports were issued in 2007, which serve to inform this review: 

 SEC-00059, SEC Petition Evaluation Report, Sandia National Laboratories – Livermore, 

Petition SEC-00059, Rev. 00, March 26, 2007 (NIOSH 2007a). 

 SEC-00059 Addendum, SEC Petition Evaluation Report – Addendum, Sandia National 

Laboratories – Livermore, Petition SEC-00059-Addendum, Rev. 00, September 6, 2007 

(NIOSH 2007b). 

 ORAUT-OTIB-0006, Technical Information Bulletin: Dose Reconstruction from 

Occupationally Related Diagnostic X-ray Procedures, Rev. 03-D, December 21, 2005 

(ORAUT 2005a). 
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 ORAUT-OTIB-0066, Calculation of Dose from Uptakes of Special Tritium Compounds, 

April 26, 2007, (ORAUT 2007e). 

 ORAUT –TKBS-0036-4, Lawrence Livermore National Laboratory – Occupational 

Environmental Dose, October 7, 2005 (ORAUT 2005b). 

 ORAUT-TIB-0055, Technical Basis for Conversion from NCRP Report 38 Neutron 

Quality Factors to ICRP Publication 60 Radiation Weighting Factors for Respective 

IREP Input Neutron Energy Ranges, June 5, 2006 (ORAUT 2006a). 

SC&A also reviewed other pertinent documents, including those cited on the SRDB. SC&A has 

critically reviewed the SNL CA TBD, as well as supplementary and supporting documents, 

against the following three evaluation criteria: 

 Determine the completeness of the information gathered by NIOSH, 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 guidelines for the use of the data in dose reconstructions

SC&A’s review of the TBD, along with its supporting supplemental documentation, 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 SC&A 

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 dose reconstructions, 

bridging uncertainties, or correcting technical inaccuracies. 

The SNL CA site profile document serves as site-specific guidance document to be used in 

support of dose reconstructions for claimants. It provides the health physicist who conducts the 

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

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

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

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

data, and process description information or source term data. 

 
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2.2 ASSESSMENT CRITERIA AND METHODS 

SC&A was charged with evaluating the approach set forth in the site profiles that are used in the 

individual dose reconstruction process. These documents are reviewed for their completeness, 

technical accuracy, adequacy of data, consistency with other site profiles, and compliance with 

the stated objectives, as defined in SC&A Standard Operating Procedure for Performing Site 

Profile Reviews (SC&A 2004). This review is specific to the SNL CA site profile; however, 

items identified in this report may be applied to other facilities, especially facilities with similar 

source terms, exposure conditions, and mobile workforces. 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 (SC&A 2004). 

2.1.1 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, 

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

development of the site profile, and (3) determining how worker input was considered in the 

development of the site profile. 

2.1.2 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 CA. 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. 

2.1.3 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. 
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2.1.4 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 CA TBD was 

compared to other TBDs, particularly those referenced in the site profile and those related to 

frequently visited facilities. This assessment was conducted to identify areas of inconsistencies 

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

reconstruction process. 

2.1.5 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 TBD for 

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

dose reconstructions. 

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 information has been incorporated into the 

report. 

All review comments apply to Rev. 00 of the SNL CA site profile document, which is the most 

recently published version. Site expert interviews were conducted with former and current SNL 

CA site workers to assist SC&A in obtaining a comprehensive understanding of the radiation 

protection program, site operations, and historic exposure experience. 

Attachment 1 to this report provides a summary of the collective interviews conducted by SC&A 

during the course of this review, and approved by interviewees. Although limited in number, the 

interviewees included radiological control (RadCon) operations and dosimetry, engineering and 

technical staff, and support workers that worked at the site from 1959 to present. Secure 

interviews were conducted onsite by Robert Bistline (SC&A/Saliant, Inc.) and Kathryn 

Robertson-DeMers (SC&A/Saliant, Inc.), in Livermore, California, on June 8–12, 2009. A 

follow-up telephone interview was conducted on June 28, 2009. Additional interviews were 

conducted with staff members of SNL in Albuquerque who were knowledgeable of the 

dosimetry program and history of SNL CA. 

2.3 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 (Findings Identified in the SNL CA Site Profile) 

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

Based on the issues raised, SC&A prepared a summary list of findings, which are presented in 

the Executive Summary. Issues are designated as “Primary Findings” if SC&A believes that 

they represent deficiencies 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 Findings if they simply raise questions, which, if addressed, would further improve 

the site profile and may possibly reveal deficiencies that will need to be addressed in future 

revisions of the site profile. Detailed analyses of the primary and secondary findings are 

provided in Section 3.0 of this report. 

 

 
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3.0 FINDINGS IDENTIFIED IN THE SANDIA NATIONAL 

LABORATORY, LIVERMORE, CALIFORNIA SITE PROFILE 

Findings are categorized into Primary and Secondary Findings. Those designated as Primary 

Findings are likely to have an impact on the organ dose and the dose reconstruction outcome, 

while Secondary Findings are provided primarily to improve the quality of the site profile. 

3.1 FINDING 1: LACK OF CHARACTERIZATION OF OFFSITE WORKER 

ACTIVITIES 

SNL CA technical personnel frequently traveled to other DOE sites where there was a potential 

for radiation exposure. The site profile has not adequately characterized the potential exposures 

received by these SNL CA workers as a result of exposures to radiation from these site visits. 

The site profile stresses that although SNL CA was responsible for design and engineering of 

weapons, the production of parts and final weapons was completed at other DOE complex sites. 

The site description states (ORAUT 2007a, pg. 11): 

SNL/CA was to engineer, or weaponize, the nuclear weapons package designed 

by LLNL; production of parts and final weapons was accomplished at other 

weapons complex sites. 

This gives the impression that radiation exposure was limited to those radioactive materials 

existing at the site in Livermore, California. To understand the potential for exposure, a more 

indepth understanding of the work conducted by Sandia personnel, especially technical staff, is 

needed. 

SNL CA was established to provide ordnance engineering support to LLNL in 1956. The 

process for weapons development involved distinct phases, which allude to the types of activities 

in which workers were involved throughout the weapons cycle, as follows. 

The DOE laboratories and production plants are responsible for the design, 

development, testing and certification, maintenance, stockpile surveillance, and 

retirement of the warhead. These activities occur in seven phases: 

Phase 1 evaluates new concepts and advances in technology for possible 

application to nuclear weapons. 

Phase 2 involves a technical and cost feasibility study examining the 

military requirements and cost effectiveness of a new weapon system. 

Phase 3 commences when the DoD [Department of Defense] decides to 

proceed with a weapon system acquisition. It involves the engineering 

development work for a warhead, including overall design definition and 

component development. 
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Phase 4 is production engineering. Development is completed and 

thousands of drawings are produced. Manufacturing and assembly 

processes are established. 

Phase 5 begins with first production. These first units are rigorously 

checked in the laboratory and in the field. Ancillary equipment and 

manufacturing are completed during this phase. 

Phase 6 is quantity production of the weapon and maintenance of the 

weapon in the stockpile. Upgrades or modifications may be performed 

during Phase 6 if required. Stockpile evaluation sampling and 

surveillance continue throughout stockpile life. 

Phase 7 retires the weapon from the stockpile and reclaims nuclear 

material and reusable parts. (Loeber 2002) 

Sandia personnel were involved with a nuclear weapons program from its inception through 

retirement from the stockpile. Nuclear ordnance work conducted by SNL CA employees 

included safing; command and control; arming, fusing, and firing systems; aerodynamics and 

structures; and related testing and instrumentation. After weapons were in the stockpile, quality 

assurance evaluators periodically obtained samples and tested them in the laboratory and field to 

assure that the components continued to operate safety and reliably (Furman 1990). As a result 

of these and other testing activities, employees came into contact with radioactive material, 

starting with Phase 3 of the process and continuing through Phase 7, either at SNL CA or as 

visitors to R&D and/or production facilities. Potential exposure exists not only at other DOE 

complex sites, but also at military installations throughout the world. 

Sandia established a permanent installation at the LLNL Site 300 in September 1957. SNL CA 

participated in testing at Sandia Corporation testing sites, including the Tonopah Test Range 

(TTR), the Salton Sea Test Base (SSTB), and test facilities located at SNL NM (SNL CA no 

date). 

Test activities have always provided a major role in the weapons projects of 8100 

[A directorate of SNL established in Livermore, California to perform weaponry 

work in support of the University of California Radiation Laboratory]. The 

activities included providing the environmental test capabilities at Livermore, and 

the coordination and conduction of tests at LLNL’s Site 300, at SandiaAlbuquerque, and at most of the Department of Defense test ranges. 

SNL operates the Tonopah Test Range for the DOE. TTR covers 525 square miles within the 

boundaries of the Nellis Air Force Base Bombing and Gunnery Range, and was established in 

1956 to function as a complex outdoor laboratory for testing weapons systems. The first drop 

test was conducted on February 8, 1957, and Rocket Testing began July 27, 1957. During the 

1960s, there were about 500 tests conducted each year at TTR. Participation in activities at TTR 

was inclusive of SNL CA personnel. Although the SNL NM site profile includes a section on 

potential exposures at TTR, SSTB, and Coyote Canyon, a similar discussion is absent from the 
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SNL CA site profile. Exercises at SSTB involved recovery training. Potential exposures to 

Am-241, Pu-238, and Pu-239/Pu-240 were identified in the SNL NM TBD (ORAUT 2007b) as a 

result of the Clean Slate operation at TTR. Furthermore, in the SC&A review of the SNL NM 

TBD (ORAUT 2007b), uranium was identified as a potential exposure hazard at TTR and SSTB. 

In addition to the above test activities, SNL CA staff participated in weapons testing at NTS, the 

PPG, and other continental tests associated with the Plowshare program. During weapons 

testing, responsibilities of scientists and engineers from SNL NM and SNL CA included “the 

determination of the sizes of nuclear devices to be detonated, how deep they should be buried, 

blast-safety studies, arming and firing of the devices, the resulting craters, and other blast 

phenomena” (SNL CA no date). In cooperation with the military, they conducted weapons 

effects studies to evaluate the effect of radiation on equipment. While Sandia personnel were 

involved in the arming and firing during most weapons tests, specific tests mentioned by 

claimants included Diesel Train (December 8, 1969), Diana Mist (February 11, 1970), Mint Leaf 

(May 5, 1970), and Dido Queen (August 5, 1973). Events Camphor (June 1971) and Cypress 

(February 1969) were SNL-sponsored radiation effects tests. In addition to their involvement 

with nuclear weapons tests at NTS, SNL CA participated in experiments conducted to assure the 

safety of weapons during shipment and storage. 

Sandia’s responsibility in supporting the Pacific tests included (SNL CA no date): 

(1) Fusing and firing systems for certain test devices. 

(2) Telemetry instrumentation in rockets and other test devices. 

(3) Meteorology and microbaragraphics studies. 

(4) Tracking radar and tracking mounts for optical instruments. 

(5) Assistance in assembling and logical support of the actual test devices. 

In Livermore, the activity was enormous with everyone involved in the design, 

fabrication, shipping, scheduling, and movement of equipment to the test area.

SNL CA personnel were involved in Project Dominic, the last atmospheric test series conducted 

by the United States in 1962. This effort was conducted in the Pacific near Christmas Island and 

at Johnson Island, and included bomb drops, rocket launched high-altitude nuclear bursts, and 

submarine-launched tests (SNL CA no date). Many employees from Livermore spent several 

months away from home in the Pacific during this test series. 

The site profile acknowledges that a number of Sandia personnel traveled to other DOE complex 

sites to conduct work activities; however, it fails to acknowledge the extent of travel by technical 

and support staff to DOE production and Department of Defense (DOD) facilities, where there 

was a potential for exposure to radiation. Other DOE Complex facilities visited by SNL CA 

employees, as mentioned in site expert and claimant interviews, included, or in the case of active 

facilities, include visits to SNL NM, the Mound Plant, the Rocky Flats Plant (RFP), the NTS, the 

PPG, TTR, the Pantex Plant, the Y-12 Plant, LLNL (including Site 300), the Medina Plant, the 

Clarksville Plant, Iowa Army Ammunition Plant (IAAP), the Pinellas Plant, the Kansas City 

Plant (KCP), the Savannah River Site (SRS), Argonne National Laboratory (ANL), Pacific 

Northwest National Laboratory (PNNL), Los Alamos National Laboratory (LANL), and military 
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installations. As a part of a smaller effort to improve the uranium enrichment process, some 

SNL CA employees visited the gaseous diffusion plants. Based on site expert interviews, review 

of documentation, and review of CATIs, visits could last from a day to several months. Experts 

indicated in some situations that they visited other sites multiple times. In some cases, claimants 

mentioned involvement in incidents while at other sites. 

For some SNL CA employees, activities at other sites required entry into radiological areas, and 

involved activities associated with handling and testing of components. Site experts indicated 

that entry or tours into production areas at these sites were not uncommon. The monitoring 

requirements were determined by the host site, and were limited primarily to external exposure 

and/or tritium exposure depending on the site. Follow-up monitoring for radionuclides 

encountered at host sites, but not routinely monitored at the SNL CA site, also was not done. 

Limited internal monitoring is available in the records collected for visits to other sites to date, 

and a majority of the potential internal radionuclides encountered during offsite visits are not 

included. The general consensus from site expert interviews was that the likelihood of radiation 

exposure was greater during offsite visits versus exposure they may have received at the SNL 

CA facility. 

While the site profile acknowledges offsite visits by SNL CA workers, it has failed to 

acknowledge the frequency and extent of these visits and the potential for radiation exposure for 

some categories of workers received during these visits. The TBD does not reference other 

TBDs, consider the completeness of records provided for exposures during offsite activities, or 

consider the dose potentially received, which in many cases potentially exceeded exposures 

associated with onsite activities. There was a reliance on the host site to provide personnel 

monitoring serves to SNL CA visitors. SNL CA internal monitoring programs do not provide 

coverage of potential exposures to radionuclides encountered at other sites, including plutonium, 

thorium, MFPs, MAPs, and other radionuclides. Coverage of tritium and uranium exposure by 

the onsite internal monitoring program would be dependent upon the solubility of the tritium, the 

adequacy of the bioassay method, and the sample date relative to the exposure date. It is clear 

that the site profile would have benefited from input from a worker outreach meeting specifically 

addressing SNL CA activities, as offsite activities were raised frequently during site expert 

interviews with SC&A. 

3.2 FINDING 2: INCOMPLETE AND UNCLEAR EXTERNAL AND INTERNAL 

MONITORING DATA MAKES THEIR USE IN DOSE RECONSTRUCTION 

DIFFICULT 

Quality assurance evaluations on incoming data presented by DOE and its contractors are critical 

to the dose reconstruction process. In a preliminary review of claimant files, SC&A observed 

incomplete, inaccurate, and redundant data. Requests for claimant dosimetry data were made 

more than once to SNL NM; however, data provided to NIOSH for individual claimants contain 

significant data gaps for external monitoring and minimal internal monitoring data. Generic 

data, such as dosimeter processing logs or cumulative exposure summaries, were available in the 

SRDB to mitigate some gaps in claimant files; however, no direction is provided in the site 

profile requiring that dose reconstructors access these additional sources of dosimetry 

information. Some urinalysis data were available in the individual Medical files, but were not 
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necessarily duplicated in the individual radiation exposure files. Again, generic lists and 

processing logs, including tritium and uranium bioassay data, are available on the SRDB; 

however, no direction is provided in the site profile requiring dose reconstructors to access these 

data. There is an absence of offsite monitoring data in the claimant files, requiring NIOSH to 

identify all offsite activities for a claimant and request data directly from visited sites. Finally, 

no internal or external dosimetry coworker models are available for the assignment of dose in 

cases where data are missing and personnel were involved in work with radioactive material. 

The subject of data completeness is considered in the following sections for external and internal 

monitoring records. 

External Dosimetry 

SC&A performed a preliminary review of data completeness, using claimant files and other data 

retrieved from Sandia on the SRDB. The external dosimetry records in the claimant data, which 

is the primary source of data for dose reconstruction, are incomplete. External monitoring data 

provided on claimants, which constitutes a majority of the data retrieved for SNL CA workers, 

were primarily from logbook or printout listings. This review of available claimant records was 

complicated by claimant files being poorly organized and often redundant (e.g., one claimant’s 

file had six separate electronic documents providing redundant information on the worker’s 1965 

first quarter badge reading). A document that yielded more than one piece of claimant-specific 

data per page was a rare find. Some documents contained no internal identification of the time 

period represented or headings for the data columns. A dose reconstructor would have a tedious 

and time-consuming job extracting relevant exposure data from the claimant files that SC&A 

reviewed. 

Gaps in Claimant File Monitoring Data 

Documentation indicates that all personnel onsite were monitored from the establishment of SNL 

CA through 1970. A 1960 memorandum from R.L. Hanzel (SNL CA) to G.L. Rhodes (SNL 

CA) indicates that all personnel, including contractors and visitors, were badged at that time 

(Hanzel 1960). 

At the present time, all Livermore Laboratory and on-site contractor personnel 

and all individuals who visit the Livermore Laboratory are issued film badges to 

determine accumulated individual radiation exposures received while on the 

premises. This policy has been in effect from the time the Sandia Corporation, 

Livermore Laboratory was established. 

The SEC petition evaluation report, post-dating the site profile, indicates that the practice of 

badging all personnel at SNL CA continued until 1970 (NIOSH 2007a). 

From information in a memo dated October 6, 1965 and information available in 

annual dose summary reports, it can be concluded that until 1970, all personnel 

at SNL-L were badged (DeSelm, 1965; AEC, Various dates). After 1970, only 

employees working with or around radiation-generating devices or those that had 
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the potential to exceed a pre-specified threshold were badged (ORAUT-TKBS0053, Section 6.4.1.1 [ORAUT 2007a]). 

The preliminary data review revealed gaps in the external monitoring data in claimant files 

during years when all personnel were reportedly monitored. Disregarding cumulative reports, 

such as a single line representing 1957–1965 or “lifetime” exposure, few data points prior to 

1971 could be located in the selected claimant files. For example, one claimant’s file contains 

only two quarterly badge results for the 10-year span from 1961 through 1970. In a 12-year span 

from 1959 through 1970, another claimant’s file contains four quarterly badge results and two 

values that appear to be yearly totals. A third claimant file includes only 1 yearly total, 10 

monthly badge results, and 4 quarterly results (less than 3 years worth of monitoring data) for the 

11 year span from 1960 through 1970. Each of the claimant files reviewed also had data gaps 

after 1970. In some cases, data for a particular year is incomplete; in other cases, gaps of 1 to 

5 years are interspersed with occasional results. It was not readily apparent that any of the 

workers were intentionally unmonitored due to changes in their work activities. 

Dosimetry records form the primary basis for conducting dose reconstruction. A quality 

assurance review of the data received from the site is critical to ensuring appropriate and 

complete records are provided for consideration in the dose reconstruction process. The 

incomplete nature of the claimant files, and the resulting dose assignment techniques for large 

gaps in data are not adequately reflected in the site profile. The Sandia National Laboratory, 

Livermore Special Exposure Cohort Petition (Petition SEC-00059) raised issues associated with 

the availability of monitoring records and difficulty in collecting data for the period prior to 

1989, but indicated subsequent data capture trips to SNL CA remedied the situation (NIOSH 

2007b). Many of the cited data sources captured by NIOSH are generic logbooks and lists that 

are only available through the SRDB. These data sources are scattered and, although available, 

were not always duplicated in the individual claimant file. Direction is not provided in the site 

profile which directs the dose reconstructor to these data sources. A combination of the 

dosimetry data in the individual radiation exposure file, the medical file, and the generic 

logbooks and lists are required to compile a complete radiation exposure history for an 

individual. Consulting the SRDB generic dosimetry logbooks and lists will mitigate some, but 

not all gaps in the radiation exposure data for individuals. 

Section 6 of the site profile does not reference or provide any coworker data for use in assigning 

doses to workers who should have been monitored, but were not monitored after the termination 

of site-wide badging. Given the observed gaps in the monitoring data, a coworker model or 

alternate methodology is needed to assign dose to unmonitored workers who should have been 

monitored during the era when the site did not badge all employees. Since gaps in the claimant 

records continue beyond this period, further evaluation of the completeness of individual 

monitoring data for radiation workers is necessary. 

Uncertainties and Discrepancies in Records 

In many cases, it is difficult to interpret dosimetry data present in the claimant files. One 

claimant had a monthly badge result for 1962 (the only result for the year). A comment in 

another document raised doubts about the validity of that result. Another claimant file listed a 
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value for x-ray/gamma exposure for a particular month in 1971. The following page, a 

“Dosimetry Update Error Listing” for the same monitoring interval, listed the same value. It was 

not clear whether the value was an error or a correction. In several cases, reports that listed issue 

and return dates were missing entries for the month of return. Reviewers were not certain if 

these blanks represented badges that were not returned (“0” versus no result) or simple omissions 

in record keeping, 

Several reports and records had blanks rather than zeroes for the majority of the workers listed. 

It appeared to be accepted practice to record, or to search computer records, for only positive 

results, letting the absence of data imply a negative result. One claimant had group annual 

exposure reports in his medical record covering each year from 1970 through 1985. The 

presentation of the claimant’s data in these reports made it difficult to discern if the worker had 

been monitored during those years. The data row with the claimant’s name was completely 

blank (no badge number, issue/return dates, current results, or year-to-date exposure); only the 

“prev” and “cum” rows contained values. Since specific monitoring results were located in other 

document files for several of these years, it appears that the claimant was monitored. 

 

Contributing Factors 

Specific dosimetry program concerns that may have contributed to data gaps might be gleaned 

from internal correspondence. According to Hanzel (1960), there was some concern that badge 

issuance and exchange were not centralized: 

In general, the administrative and physical problems which must be coped with in 

maintaining such an extensive program arise from the fact that no single

organization issues and exchanges film at the laboratory. 

Additional recordkeeping difficulties arose because the radiation exposure records were based on 

security badge numbers, which were not permanent identifiers. Hanzel (1960) goes on to say: 

Some individuals have been issued two, three or even four security badge 

numbers during the past year, which has proven to be a troublesome records 

problem for both the Medical and Safety Section, responsible for administrating 

the film badge program, as well as the contractor providing the services. 

In addition, Hanzel (1960) noted that a significant fraction of workers (20%–25%) routinely 

failed to exchange their badges during the normal monthly exchange period. 

Hanzel (1960) advocated reducing the external dosimetry program to workers and visitors who 

worked in specific areas where potential exposures of 30 mR to personnel existed. His 

suggestion that “the receipt, storage, issue of badges and record keeping involving fewer 

individuals could be more closely supervised” seems to imply that monitoring and documenting 

exposures for all personnel and visitors was too cumbersome to be effectively managed with 

available resources. 
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The external exposure data for individuals working onsite at SNL CA is incomplete. Claimantspecific dosimeter results from before 1970 (when documentation indicates that all personnel on 

site were monitored) were sparse within the claimant files reviewed by SC&A. The years after 

1972 were better represented in the claimant files, but there appears to be gaps in these data, as 

well. 

Internal Dosimetry Completeness 

In the case of onsite workers, tritium bioassay was collected on a biweekly or weekly basis for 

workers routinely assigned to the TRL. Routine uranium samples were conducted for a small 

group of individuals associated with machining uranium. There was no routine bioassay 

program for other radionuclides handled at SNL CA. According to worker interviews, SNL CA 

sometimes collected bioassay from workers upon return from other DOE Complex facilities; yet 

records from these bioassay samples are not available. Site experts indicated that, due to releases 

at the Mound site, they were sampled upon return to SNL CA by Medical, but records do not 

reflect such sampling. SNL NM did not start to maintain internal dosimetry records for SNL CA 

until 1990 for tritium (ORAUT 2007a, pg. 43). For uranium bioassay records, the site profile 

states that all bioassay samples were sent to SNL NM for analysis starting sometime prior to 

1968 (ORAUT 2007a, pg. 47); however, it is not clear whether SNL NM was responsible for 

maintaining records for these personnel, or they just sent the bioassay results back to SNL CA 

for them to maintain. 

Based on a preliminary review of claimant files, it was found that little or no internal monitoring 

data exist in claimant files, and a majority of the data located for claimants are found in medical 

files. Bioassay data identified are limited to tritium and uranium urinalysis. Generic logs and 

lists of internal monitoring are available in various documents included in the SRDB, which may 

or may not be duplicated in the claimant files. As a general rule, the dose reconstructor uses data 

in the claimant file or default assumptions in the site profile to assign dose. The use of actual 

monitoring data is preferable to assignment of dose based on generic assumptions. Protocol does 

not require dose reconstructors to consult other sources of radiation exposure data, such as 

processing or analysis logs, bioassay result lists, or log sheets with results, which in the case of 

SNL CA, may contain additional monitoring data. The site profile needs to provide direction for 

consideration of these additional sources. There is a lack of offsite internal monitoring data 

available, including data requested from other sites as a result of site visits. Tritium data is 

available for some periods of time for LLNL, but this is the extent of offsite internal monitoring 

data identified by SC&A in claimant file reviews and on the SRDB. Further investigation is 

needed on the extent and availability of internal monitoring data and how this information will 

be compiled for complete monitoring histories. 

The site profile does not mention the availability or applicability of coworker internal dose 

models for tritium and uranium, nor has SC&A identified a TIB providing a coworker model. In 

lieu of a coworker model, the site profile proposes to assign dose for gaps in internal monitoring 

data of workers potentially exposed to tritium and uranium, but not monitored, based on 10% of 

the airborne radionuclide concentration limits. It is prudent to review all available tritium and 

uranium bioassay data for use in the development of a coworker model, rather than basing 

internal dose on a fraction of the regulatory air concentration limits. This is contrary to the 
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hierarchy of data defined for use in the dose reconstruction process. For those individuals with 

data gaps, or those who should have been monitored but were not, it would be advantageous to 

have a viable coworker model to use in the assignment of unmonitored dose. 

Availability of Offsite Exposure Information 

The SNL CA site profile gives the impression that host sites were requested to provide radiation 

exposure reports, and that SNL CA workers were directed to request internal and/or external 

monitoring if they entered a radiological control area (ORAUT 2007a, pg. 19). 

When workers traveled to other locations, such as across the street to the LLNL 

site, the LLNL Site 300, or other non-SNL-operated sites, the host sites were to be 

requested to report exposures at those locations to the appropriate staff at 

SNL/CA or SNL/NM (SNL/CA – updated b). A response to the DOE site 

appraisal finding related to offsite dosimeters indicated that SNL/CA directed 

employees to “request internal and/or dosimetry, workplace monitoring, etc., if 

they must enter radiation controlled areas at the visited facility” in 1985 (Wallace 

1988). 

Site expert interviews indicated that this policy was not well communicated to those involved in 

offsite visits, and that the host site determined the monitoring requirements. When workers 

visited other sites, they were sometimes assigned a dosimeter [i.e., film badge or 

thermoluminescent dosimeter (TLD)] by the visited site. It was noted that visitor data returned 

to NIOSH on claimants participating in offsite visits indicated that minimal or no data was 

located. This is true for workers who not only visited other DOE Complex sites, but those who 

entered into production areas and in some cases were involved in incidents. A review of the 

dosimetry records indicates that external data was provided to NIOSH for RFP, NTS, and Pantex 

Plant. Tritium data was present for some time periods from LLNL. Workers indicated they do 

not recall being told to request monitoring at a visited site, or to request that internal and external 

monitoring results be provided to SNL CA. Health Physics staff indicated that if dosimetry 

reports were requested from workers visiting other sites, they would be sent to SNL NM and not 

to SNL CA. It is important to note that visitor records are often stored separately from employee 

records and may require additional searches. Visitor or temporary status should be specified in 

requests to visited sites. Historically, there was no emphasis placed on providing visitor 

dosimetry results to the home site. Some facilities, such as the NTS, routinely sent visitor 

results, while others did not implement this practice routinely until it became a regulatory 

requirement. Tracking visitor dose is complicated when the home site does not incorporate 

visitor dosimetry data into individual-specific dosimetry files. 

Although the site profile touches on offsite visits, it does not provide guidance on how to ensure 

all offsite dosimetry records are collected, and how to incorporate these potential exposures into 

the dose reconstruction process, nor does the dose reconstruction process acknowledge the time

spent by SNL personnel at other sites during established SEC periods. NIOSH has a policy to 

request records from offsite visits if information is provided in the CATI regarding these visits. 

There is no specific question asking about offsite visits, so the claimant (both energy employees 

and survivors) must recall these visits and raise them as an additional comment in the CATI. A 
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review of the CATIs and NIOSH follow-up requests for offsite exposure data indicate that 

dosimetry information from sites mentioned specifically in the CATI is requested by NIOSH for 

the visited site. If no information is specifically provided by the claimant, no information for 

offsite exposure is requested. In addition, it was noted that monitoring was not located for 

Sandia workers at a majority of the host sites. A brief review of exposure information retrieved 

for specific claimants and radiation exposure summary reports available on the SRDB indicate 

that most of the data were for external dose, with a limited amount of tritium data found for 

LLNL. A review of the claimant SNL CA dosimetry files indicated that in only a few 

circumstances was the offsite exposure data included in the SNL CA dosimetry file. In some 

cases, the monitoring dates and information did not correspond to the monitoring information 

available in dosimetry summary reports. Furthermore, it appears that dose information on offsite 

exposure available through the SRDB is not clearly inclusive of all dose received offsite; there 

was a disconnect between specific information provided in site expert interviews related to 

offsite visits, and exposure information available in either the SNL CA dosimetry file or the 

dosimetry information provided by the visited site.

Given the extent of offsite visits, the lack of monitoring data for such visits, and the potential for 

exposures at these sites, additional consideration of the potential impact of missed external and 

internal dose incurred by Sandia personnel during routine offsite visits to other facilities requires 

further treatment in the site profile, particularly where there was a potential for radiation 

exposure. The frequency and length of offsite visits, particularly for those sites with existing 

SEC status, requires further investigation and documentation. Reliance on claimant-provided 

information on offsite visits in the CATI is questionable at best, considering that there is no 

specific question on the CATI to solicit this information. Furthermore, survivor claimants may 

not have specific knowledge on offsite visits and activities. A validation of the completeness and 

adequacy of the visitor dosimetry data is needed, since workers indicate that it is possible most 

of their dose was received during offsite visits and visitor dosimetry data are not always reflected 

in the individual dosimetry files provided by Sandia. In addition, visitor dosimetry data are not 

being effectively retrieved from some DOE complex sites, indicating that the facilities are not 

doing complete dosimetry records recovery, or that personnel were not monitored effectively 

while visiting other sites. 

3.3 FINDING 3: ABSENCE OF INTERNAL DOSIMETRY PERSONNEL 

MONITORING FOR RADIONUCLIDES OTHER THAN TRITIUM AND 

URANIUM 

The SNL CA site profile failed to consider potential internal exposure from “other” 

radionuclides. The site profile indicates that the only radionuclides of concern for internal dose 

at SNL CA were tritium and uranium (ORAUT 2007a, pg. 43). Routine bioassay for 

radionuclides other than tritium and uranium are lacking (ORAUT 2007a, pg. 43). 

The primary detection method for intakes of 3

H at all SNL facilities has been 

urine bioassay (Potter ca. 1997). There is no evidence that bioassay samples 

were analyzed for any radionuclides except H-3 and natural uranium (U-nat), or 

that other types of bioassay i.e. fecal analyses or in vivo counting, were employed 

at SNL/CA. The H-3 bioassay was limited to TRL experimenters and staff. The 
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uranium bioassay was performed on individuals involved in machining DU as 

well as others involved with handling uranium powders or those in areas where 

air concentrations potentially exceeded 10% of the air concentration guidelines 

(Wright 1979). 

This begs the question of whether the employees at the SNL CA were adequately monitored for 

potential exposure to other radionuclides used at the site. 

Documentation has been obtained by SC&A that as many as 24 different radionuclides were 

used at the SNL CA facility. This documentation was provided to the California Department of 

Health Services (CDHS) by SNL CA through the Albuquerque office of the Department of 

Energy (DOE-AL) in response to the CDHS request to DOE. The memorandum states (Ormond 

III 1989): 

From the mid 50’s to present, Sandia has used the following radionuclides within 

California. These materials have been used at the Sandia National Laboratories, 

at Livermore. Considerable effort would be required to track usage. 

Radionuclides: 

H-3 Kr-85 Tl-204 Co-60 U-238 

C-14 Tc-99 Tb-161 Pu-239 U-235 

Tl-204 Ba-133 Pu-238 Fe-55 Ir-192 

Pm-147 Cd-109 RaD+E Ni-63 Ir-192 

Sr-90 Cs-137 Co-57 Ru-106 Cf-252 

Am-241. 

However, the CDHS requested a list of each DOE (or predecessor) use of radioactive material 

within California from 1940 to the present (Themelis 1989); hence, the supplied list of the 

radionuclides used at SNL Livermore. These types of radionuclides range from long-life alpha 

emitters to beta emitters and gamma emitters, presenting various potential exposure concerns. 

Stanford (1989) noted that identifying the quantities of these radionuclides used would be 

classified. Thus, the extent of the use of these various radionuclides and the quantities has not 

been obtained by SC&A. 

Thorium, Pu-239, and MFPs are identified as being in “Storage Facilities” in Table 2-1, “Area” 

information and parameters. Thorium is identified in the profile several times as being used at 

the site and is not discussed in the internal dose section. Section 2.3, “Site Activities,” states: 

There were some thorium metal parts used on test systems as well (Wright 2006). 

Section 4.4.1, “Locations of Concern,” states: 

An aerial survey of LLNL and SNL/CA, conducted in 1975 (Tipton 1977), found 

gamma-emitting radioactivity in excess of background levels in the vicinity of 

Building 9143 (the Radiography Building at the time) and to a much lesser extent, 
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in the vicinity of a waste holding area known to contain DU and thorium 

(Building 9122), and a material storage vault known to contain DU, thorium, and 

small amounts of shielded 60Co and 133Ba, and 235U (Building 921, incorrectly 

referred to as B-291 in the Tipton 1977 report). 

Attachment A of the site profile, “Summary of Activities at Site Buildings,” lists natural thorium 

as being contained in Building 927, Radiological Material Storage. Natural thorium relatively 

quickly becomes a concentrated generator of thoron (Rn-220) gas after it is produced from the 

extraction process of thorium ore milling, because the radium daughter/decay product (Ra-224) 

that produces the thoron comes into activity equilibrium with the Th-228 in the natural thorium 

within a few weeks. Therefore, NIOSH should investigate the possibility of internal doses to 

claimants from thoron at the site. 

In 1978, 75% of the total SNL CA waste was uranium-contaminated waste (primarily DU). 

Classified radioactive waste was accumulated and shipped offsite when sufficient quantities had 

accumulated (Jones 1978). 

Mixed fission products and uranium contaminated wastes account for about 

99 percent of the total SLL wastes. The fission product waste is generated from 

weapons tests at NTS and the uranium waste comes from research and 

development at the site. 

Futhermore, 

Materials from NTS are generally returned to SLL, Bldg. 913 and 921 designed 

as number 16 and 4 respectively in Figure 2 (Lovell 1974). 

This would indicate that there were activities involving fission products at the site. 

Radiation dosimeters are required when working with weapon systems (1) for any activity that 

requires personnel to spend more than 16 hours per calendar quarter at distances closer than 

1 meter to weapons with >1 kilogram of DU or thorium, and (2) for any activity that requires 

personnel to spend more than 4 hours per calendar quarter at distances closer than 1 meter to 

weapons with >1 kilogram plutonium (Russell 1995). 

There is indication that radionuclides other than tritium and uranium were handled at SNL CA. 

Details on the quantities, forms, and handling conditions deserve further consideration in the site 

profile. With the presence of these radionuclides, and the absence of bioassay data for 

radionuclides other than tritium and uranium, consideration needs to be given to missed dose 

from exposure to these radionuclides due to the relative position of the dosimeter to the radiation 

source. Furthermore, an investigation into radionuclides handled as a part of classified activities 

is warranted to ensure that potential exposure situations to other radionuclides did not exist. 

Plutonium-239 and MFPs were handled in at least trace amounts, according to the site profile 

(Table 2-1), but no discussion is given in the internal dose section to account for any potential 

exposures and intakes of these. Since bioassay was not performed to detect intakes of thorium, 

Pu-239 or MFPs and these radionuclides were handled or at least stored at the site, NIOSH must 
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confirm and explain in more detail that there was no potential for occupational intakes of these 

other radionuclides before assuming intakes did not occur. 

Offsite Internal Exposure 

Sewell (1959) specifically authorized the thorium hydrodynamics program at Site 300 in 1959. 

This indicates that SNL CA workers located at, or visiting, Site 300 of LLNL were potentially 

exposed to thorium in addition to the DU and tritium mentioned in the SNL CA site profile. 

Thorium bioassay data is unavailable for Sandia workers potentially exposed to thorium at Site 

300 or in the thorium machining area. 

As previously mentioned, Sandia personnel were involved in testing at PPG, NTS, and other 

areas. In addition, post-shot materials were returned to the site following detonations for testing 

and evaluation. These activities exposed them to plutonium, uranium, tritium, MFPs, and MAPs. 

The conditions for exposure during weapons testing were unique, with a wide variety of 

radionuclides present in the source term. Bioassay monitoring through the NTS and PPG 

monitoring programs only included gross gamma and beta activity, and fission and activation 

product concentrations varied with the time of exposure after detonation. The available 

monitoring records, process descriptions, and source term data are inadequate to support internal 

dose reconstruction. Sponsoring laboratory personnel worked in conjunction with NTS and PPG 

workers as previously explained, some being assigned to NTS and PPG for extended periods of 

time. Equipment and materials returned to SNL CA from weapons tests may have been 

contamination with plutonium, uranium, tritium, MFPs and MAPs. Although there is mention 

that items were returned from the test sites, there is a general lack of detail on what was sent to 

SNL CA and how long after detonation this occurred. There is no method to identify the 

radionuclides present in the exposure source term. 

The adequacy of monitoring data at DOE weapons testing sites is not a unique concern, but data 

adequacy issues are associated with monitoring data at other sites visited, including LLNL, RFP, 

the Mound Plant, LANL, IAAP, and the Y-12 Plant. The internal monitoring program for 

tritium and uranium at SNL CA would not encompass potential exposure for these other 

radionuclides at visited sites. 

Internal monitoring data identified for offsite activities consisted of tritium for some years at 

LLNL; however, the internal exposure potentials were not limited to tritium, but included 

plutonium, thorium, MFPs, MAPs, and other radionuclides. The policy for monitoring visitors 

throughout the complex is not clear from site to site, and data for visitors is often difficult to 

locate, since it is not always stored in the same location as permanent employee records. Some 

analysis of the completeness of data for Sandia travelers is necessary, as the data do not appear to 

be available through SNL NM or through many of the host sites. 

The SNL CA internal monitoring programs does not provide coverage of potential exposures to 

radionuclides encountered at other sites, including plutonium, thorium, MFPs, MAPs, and other 

radionuclides. Coverage of tritium and uranium exposure by the onsite internal monitoring 

program would depend on the solubility and date of sampling relative to date of exposure. This 

data may or may not be useable, depending on the individual situation under consideration. In 
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the case of offsite exposure, the assumption of DU is not always appropriate. Bounding 

exposures for offsite visits is very difficult, considering the visitor or temporary status of Sandia 

personnel at these sites, the difficulties in locating visitor bioassay monitoring records, and the 

lack of information available for offsite exposures within the Sandia monitoring records system. 

Quantifying these exposures is critical to the assessment of dose to many Sandia workers, as 

internal exposure was more probable from offsite activities for those who frequented other DOE 

complex sites. 

3.4 FINDING 4: THE TBD HAS NOT ADEQUATELY CHARACTERIZED THE 

EXTERNAL MONITORING PROGRAM IMPLEMENTED AT SNL CA 

There is limited information on the dosimetry systems implemented at SNL CA prior to 1989, 

including a lack of information on the MDLs, exchange frequency, dosimetry calibration, dose 

calculation algorithms, and uncertainties and bias associated with each dosimetry technology. 

There is also indication that some dosimetry systems implemented by SNL CA lacked the ability 

to discriminate between beta, photon, and neutron exposures. Assumptions are made regarding 

the types and energies of external radiation hazards without consideration of actual field 

measurements. Finally, there are uncertainties associated with the assignment of missed dose, 

since MDLs and exchange frequency were estimated. 

Inadequacies in External Dosimetry System 

SNL CA has utilized several outside laboratories and contractors in the administration of its 

external dosimetry system, including LLNL (1956–1959), Radiation Detection Company (RDC; 

1959–1971), Radiological and Environmental Services Laboratory (RESL; 1972–1988), and 

SNL NM (1989–present). SNL CA workers wore a two2-element beta/photon film badge with 

NTA film from 1956 to 1971. Sometime between 1966 and 1972, the site switched to a 

2-element TLD. It appears that NTA film remained in use through 1971 for monitoring neutron 

exposures, but it is not clear how RESL measured neutron exposures from 1972–1982. An 

Eberline 3-element TLD was used for beta, photon, and neutron detection from 1982 to 1988. 

With the transition of the program to SNL NM in 1989, a multi-element TLD was implemented. 

The first DOELAP-accredited dosimetry system, a multi-element TLD, was implemented in 

1991 and continues to be in use (ORAUT 2007a). 

Radiological activities are associated with the Weapons Laboratory Facility Complex (Buildings 

910, 912, 913, 914, 916, and 918), Radiography (Building 923), Micro and Nano Technologies 

Laboratories (Buildings 941, 942, and 943), the Explosives and Environmental Testing Complex 

(Buildings 955, 956, 966, 972, 974, 976, 977, 978, 979, 981, and 983), and the Storage Facilities 

(Buildings 921, 927, 961, and 982). Table 6-4 of the site profile indicates that neutron exposures 

are limited to Radiography Building 923 and testing/repair of neutron and x-ray detectors 

(neutron and x-ray generators) in the Weapons Laboratory Facility Complex. Indications of 

“minor fast neutron exposures in Building 912, Building 913, and the trailers adjacent to 

Building 914” (Rhodes 1960) appear to be consistent with this analysis. Rhodes (1958) 

characterized x-ray sources at SNL CA as ranging from 50–250 kVP. Alpha, beta, and gamma 

sources have been identified in SNL CA records, including Cobalt-60, Cesium-137, Iridium-192, 

Thulium-170, radium, Strontium-90, uranium, and related project metals. External radiological 
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hazards resulted from handling uranium and thorium. The presence of other radionuclides, such 

as Kr-85, EU, and MFPs, also contributed to external exposure at SNL CA (Wright 2006, Jones 

1978, Russell 1995). 

Table 6-4 of the site profile lists radiation energies and percentages for beta, photon, and neutron 

radiation by site location and process activity. The distribution of beta, photon, and neutrons into 

energy categories is based primarily on estimates by site personnel (ORAUT 2007a). These 

values should be substantiated based on documented field measurements, some of which may be 

classified in nature. The site profile does not appear to consider external dose sources other than 

radiography sources, neutron/x-ray generators, and DU, although several isotopes have been 

identified in SNL CA records (refer to the preceding paragraph). It is not readily apparent that 

all of these activities and sources have been considered in Table 6-4 or in Attachment A: 

“Summary of Activities at Site Buildings.” Further assessment of field documentation is 

necessary to assure that the external radiation sources at SNL CA have been adequately 

characterized. 

Issues have been raised regarding the ability of SNL CA dosimeters to adequately distinguish 

radiation exposures from the source term to which workers were exposed. SNL CA used a 

2-chip, single-filter dosimeter from 1972 to 1982. The badge was incapable of distinguishing 

between types of penetrating (deep dose) radiations and non-penetrating (skin or shallow dose) 

radiations (Wright 1981, Lovell 1983). The site profile states: 

As mentioned previously, the 2-chip, single filter TLD dosimeters in use from 

1972 to 1982 apparently could not directly measure each of the various dose 

quantities reported in the record for this period. No definitive information has 

been located with respect to adjustments to recorded dose, nor has any 

information been found regarding dose calculation algorithms, system MDLs, or 

uncertainty/bias doses during this period. (ORAUT 2007a, pp. 61–62) 

Lovell (1983) outlines the deficiencies of the dosimeter related to its lack of energy 

discrimination. 

1. Lack of Energy Discrimination 

a. TLD cover is 30 mg/cm2

 (density X thickness) 

1) skin sensitive layer 7 mg/cm2

2) critical organs 1000 mg/cm2

b. Insensitive to beta particles between 50 keV and 200 keV. Beta particles 

>70 keV can reach the radiosensitive layer of the skin (7 mg/cm2

). 

c. Does not distinguish between beta particles/low energy X-rays and gamma 

rays, and high energy X-rays/gamma-rays. 
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d. SNL CA is forced to add all exposures to low energy X-rays and beta particles 

– to whole body penetrating dose, unless the exposure circumstances are 

known. 

The dosimetry records for the period include beta, photon, and neutron dose results, as 

acknowledged in the site profile. Lovell (1983) does not discuss the impact of this dosimeter on 

neutron uncertainties and biases. 

For the period of 1972 to 1988, the dosimetry services were outsourced to RESL in Idaho Falls, 

Idaho (Wright 1993, Wallace 1988, Ormond 1986). The site profile indicates the following: 

Currently, no information is available regarding calibration of TLD badges used 

by SNL/CA between 1971 and 1988 (the period in which RESL performed 

dosimetry services). (ORAUT 2007a, pg. 59) 

In addition to problems with the 2-chip TLD used at SNL CA, the site profile indicates 

incomplete or inadequate information for the 3-element Eberline TLD badges: 

Like the earlier period in which 2-chip TLD’s were used at SNL/CA and 

processed by RESL in Idaho, there is no documentation regarding dose 

calculation algorithms, adjustments to recorded dose, or uncertainty/bias for the 

3-element Eberline TLD badges used from 1982 to 1988. (ORAUT 2007a, 

pg. 62) 

As indicated in the site profile, there is a lack of information regarding the dosimetry program 

prior to 1989 (ORAUT 2007a, pg. 61). Furthermore, the site profile fails to identify the year of 

transition from the film badge to the TLD (ORAUT 2007a, pg. 57). 

For a dosimeter to adequately determine the dose, the program must assess and account for 

several parameters, including the workplace radiation fields (e.g., types of radiation, exposure 

geometry, environmental conditions), the physical capabilities of the dosimeter (i.e., response to 

different types and energies of radiation), administrative practices used to calculate and record 

dose, calibration, and similarity of the calibration method to the conditions and sources of 

exposure encountered in the workplace. Without adequate documentation of how these factors 

were addressed, it is difficult to characterize the uncertainties associated with the doses of record. 

It may be necessary to apply dosimeter correction factors to account for inadequacies identified 

with dosimetry systems, but additional information is needed to support the development of 

appropriate correction factors. 

Dosimetry uncertainties for SNL CA dosimeters presented in the site profile are based on bias 

and uncertainty estimates in the Technical Basis Document for the Hanford Site – Occupational 

External Dosimetry (ORAUT 2006c). The rationale in the site profile for using Hanford 

uncertainties is that “some general analogies can be drawn between Hanford and SNL/CA in 

terms of dosimetry technologies employed during various time periods of interest” (ORAUT 

2007a, pg. 67). Given the numerous uncertainties related to SNL CA’s dosimetry technology, 
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calibration, processing, and recording practices, the selection and use of Hanford uncertainty 

values requires more explicit justification. 

In summary, given the uncertainties in the dosimetry technology, calibration, dose calculation 

algorithms, adjustments to recorded dose, and uncertainty and bias factors, there is a need to 

conduct further research on radiological conditions and external dosimetry systems utilized at 

SNL CA prior to 1989. Since SNL CA used offsite dosimetry services, including LLNL (1956–

1959), RDC (1959–1971), and RESL (1972–1988), some of the necessary information regarding 

dosimetry processing, design, and calibration may be obtainable from these vendors. Some 

information is available in the ORAUT Idaho National Laboratory – Occupational External 

Dosimetry TBD (ORAUT 2007c) on calibration techniques used at RESL and the laboratory 

uncertainties associated with these techniques. The characterization of radiation energies and 

relative percentages, estimated primarily by site personnel, should be validated based on actual 

field measurements. Justification should be provided regarding the use of surrogate data (i.e., 

Hanford uncertainty corrections). Finally, clear directions are needed to support consistent use 

of tables, data, adjustments, and corrections to ensure reliable and claimant-favorable dose 

reconstruction. 

Missed Dose Determination 

The lack of documentation on dosimeter MDLs for the period prior to 1989 has resulted in a 

necessity to estimate dosimetry MDLs based on dosimetry systems of contemporary 

technologies used at other AEC or DOE facilities during corresponding periods. These estimated 

MDLs were estimated based on the Technical Basis Document for Oak Ridge National 

Laboratory – Occupational External Dose (ORAUT 2004b), the Lawrence Livermore National 

Laboratory – Occupational External Dose (2005c), Technical Basis Document for the Hanford 

Site – Occupational External Dosimetry (ORAUT 2006c), and the Summary Site Profile 

Document for Brookhaven National Laboratory (2006d). The estimated maximum annual 

missed photon, beta, and neutron dose is presented in Table 6-6 (ORAUT 2007a, pg. 66). The 

use of surrogate data from other AEC and DOE sites requires the demonstration of equivalency 

between the field exposure conditions, dosimetry system, processing protocol, and recording 

practices used at SNL CA, and those sites from which surrogate data is used. While the SNL CA 

site profile indicates that the dosimetry system used at SNL CA was similar to contemporary 

technologies used at other sites, it does not provide a discussion justifying the equivalency 

between the SNL CA dosimetry system and those from the sites above. 

Missed dose is based on estimates of dosimetry system MDLs and exchange frequencies of the 

dosimeters assigned to personnel. The site profile also raises uncertainties regarding exchange 

frequencies for dosimeters (ORAUT 2007a, pg. 55). 

While not made explicitly clear in Section 8.4.1 of SNL’s External Dosimetry 

Program Manual (Ward et. al., 1994), routine field dosimeter exchanges appear 

to occur on a monthly or quarterly basis, while nonroutine exchanges occur on a 

bi-weekly basis (for special radiation work cases, exchange periods may vary). 
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Table 6-6 assumes a monthly maximum exchange frequency, with exchange frequencies for 

TLD systems ranging from quarterly to annually. The data provided to NIOSH from SNL CA 

included minimal cycle-specific data. In some cases, only cumulative exposure summaries are 

provided, which cover years of monitoring. This, combined with the lack of dosimetry program 

history prior to 1989, makes establishing an exchange frequency difficult. Although this 

information may not be readily available through SNL CA, much of this information is likely 

retrievable through the dosimetry vendor employed by SNL CA. 

In the absence of MDL and exchange frequency values available for SNL CA, the site profile has 

relied on estimates. These estimates were derived from surrogate information from other AEC 

and DOE sites. Given the scope of activities and extent of the dosimetry programs at ORNL, 

LLNL, Hanford, and BNL compared to those at SNL CA, discussion of data equivalency should 

be provided in the TBD to demonstrate assumptions from these other DOE sites are appropriate 

for SNL CA. This is particularly prudent, given discussions regarding use of surrogate data from 

other sites at the Advisory Board meeting in February 2010 (ABRWH 2010). Further 

investigation into the protocols for dosimetry exchange should be conducted, since this is a 

critical factor to the assignment of missed dose. 

3.5 FINDING 5: THE SNL CA TBD HAS NOT ADEQUATELY CHARACTERIZED 

NEUTRON EXPOSURES AND HAS NOT ACCOUNTED FOR THE LACK OF 

RESPONSE OF NTA FILM TO LOW-ENERGY NEUTRONS 

The site profile does not specifically address the subject of NTA film threshold. The threshold 

energy of NTA film (0.5–1.0 MeV) and the amount of dose not registered because of this 

threshold is important in neutron dosimetry. NTA film decreases in response starting at neutron 

energies below 1 MeV, and is almost completely insensitive to neutrons below 0.5 MeV 

(ORAUT 2005d, pg. 27); therefore, radiation fields containing an appreciable percentage of the 

total dose equivalent due to neutrons with energies below 1 MeV must be evaluated carefully, 

with attention given to the dose missed due to this threshold effect. NTA tracks fade more 

rapidly with time as the interacting neutron energy decreases, resulting in more missed neutron 

dose. Section 6.4.2 indicates NTA film was used through 1971 to monitor for neutron exposure. 

Table 6-4, Selection of Radiation Energies and Percentages, provides the exposure energy 

spectra, including neutron energy spectra less than 1 MeV (ORAUT 2007a, pg. 65). According 

to Lovell (1983), SNL CA personnel were potentially exposed to fission spectrum neutrons up to 

14 MeV during radiography work, with some operations involving accelerators. It is reasonable 

to assume that, regardless of the initial neutron energy produced from a neutron source or 

neutron generator, the spectrum to which workers were exposed would contain neutron energies 

less than 1 MeV. This is consistent with information from other DOE sites with similar 

operations. 

RDC issued an informational bulletin on The R-D Neutron Film Badge Service (RDC, no date) 

describing the R-D Universal Film Badge, which contained both beta-gamma film and an 

Eastman-type NTA track plate film. The NTA track plates were calibrated with a poloniumberyllium source. High-energy neutrons were determined by the number of tracks in 25 fields. 

Thermal neutrons were determined by increased density under the cadmium filter of the R-D 

beta-gamma film. RDC (no date) went on to describe that NTA emulsion is subject to latent 
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image fading, recommending bi-weekly or monthly exchange. With this exchange frequency, 

RDC (no date) indicated that the latent image fading would be low “unless low neutron energies 

were encountered.” 

While the site profile considers a correction factor for conversion from NCRP Report 38, 

Neutron Quality Factors, to ICRP Publication 60, Radiation Weighting Factors (ORAUT 2006a), 

it does not consider the lack of or reduced response of NTA film to neutron energies less than 1 

MeV. The lack of details on this issue may lead to a lack of understanding on the part of the 

dose reconstructor regarding how to address low-energy neutrons in dose reconstruction. An 

appropriate correction factor or alternate methodology should be included in the site profile to 

compensate for the under-response of NTA film to low-energy neutrons. The recommended 

approach for adjustment of neutron dose is also inconsistent with the approach presented in other 

site profiles where low-energy neutrons were of concern. 

3.6 FINDING 6: LACK OF CONSIDERATION OF SPECIAL TRITIUM 

COMPOUNDS 

The site profile discusses the use of tritium at the TRL from 1976 through 1992 when operations 

were terminated. Clean-up activities were conducted from January 1992 to December 1995 

(ORAUT 2007a, pg. 42). The site profile focuses on tritium exposures at the TRL, indicating 

that “tritium exposure primarily occurred at TRL” (ORAUT 2007a, pg. 43). Discussion on 

uranium alloy machining mention the use of uranium tritide beds in Building 968 (ORAUT 

2007a, pg. 43). Attachment A, “Summary of Activities at Site Buildings,” lists tritium as a 

nuclide of concern for Buildings 913, 961, 969, 974, and ESA in addition to the TRL facility 

(ORAUT 2007a, pg. 84–86). Information on tritium usage at SNL CA has concentrated on the 

TRL, and little information is provided on tritium-related activities at other areas of the site, 

including bioassay requirements. The site profile has not adequately characterized the potential 

for exposure to special tritium compounds (STCs), either from intentional R&D activities or 

from production of these compounds as a byproduct of diffusion, absorption, and reactivity of 

elemental tritium and HTO with structural material. Formation of byproduct STCs becomes 

important when conducting intrusive activities on tritium handling systems or during 

decontamination and decommissioning (D&D) of a tritium facility. 

SNL CA involvement with design and development of neutron generators and tritium reservoirs 

pre-dated the existence of the TRL. Sandia personnel were responsible for developing 

innovative technologies for tritium reservoirs and associated gas valves. In 1960, SNL began 

designing reservoirs capable of maintaining their charge for longer periods. In about 1968, SNL 

CA built a tritium research laboratory to develop ways to handle, store, and inject the rare gas 

into weapon components. Researchers learned they needed exotic metal alloys that could resist 

embrittlement caused by helium, tritium’s decay product (Maroncelli and Karpin 2002). The 

operational safety requirements for the TRL describe tasks conducted in the facility as follows 

(Putz et al. 1988): 

The research and development tasks conducted at the TRL are dynamic. The 

processes and process variables associated with these studies are in a continuous 

state of change as the investigation requirements change. 
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Examples of R&D activities conducted at SNL CA clearly involved charging of metal and metal 

alloys with tritium, use of tritium storage beds, diffusion studies, and evaluation of tritium 

containers. 

 Tritium was introduced at elevated temperatures into titanium alumide samples by use of 

a charging apparatus. This allowed for autoradiography to observe the microstructural 

distribution of hydrogen in alloys (Perra et al. 1988). 

 Tritium gas was introduced into titanium alloy fracture mechanics specimens to observe 

hydrogen diffusion behavior during mechanical stressing (Perra et al. 1987). 

 Studies were conducted on tritium solubility in metals as a function of temperature and 

pressure. Experiments included investigation of low solubility metals, such as copper, 

gold, aluminum, and beryllium (Stulen et al. 1987). 

 TRL conducted experiments with tritium-labeled liquids used in corrosive and stress 

corrosion cracking studies (Putz et al. 1987). 

 SNL CA established a program associated with loading, monitoring and sampling of 

Tritide Studies Program (TSP) storage units. The units were tritium-charged in the TRL 

assay station and/or the high-pressure station, and periodically sampled (Ormond 1988). 

 Uranium and palladium beds were used to store tritium as uranium tritide and palladium 

tritide, respectively, and to provide a source of tritium for TRL research and operations 

(Wall 1994a, Wall 1994b). 

 Experiments with palladium samples previous tritided were conducted in Building 913 

(Hruby 1990). 

Field RadCon staff, in interviews conducted with SC&A, indicated that tritium (gas and water) will 

eventually permeate through rubber gloves, seals, gloveboxes, etc. As a result, there was tritium 

contamination in accessible areas (see Attachment 1). In addition to production and R&D 

activities, STCs are formed as byproduct materials from prolonged exposure to materials (DOE 

2008). 

DOE facilities have used a wide variety of metals (e.g., Ti, Zr, U, and Hf) in 

tritium research, purification, and storage creating an equally wide variety of 

materials referred to as “metal tritides.” Metal oxides (e.g., rust), siliceous 

materials (environmental dust), and carbonaceous materials (e.g., polymers or 

environmental dust) can also become tritium contaminated and exhibit particulate 

properties. Tritium may also react with organic material, resulting in the 

formation of organically-bound tritium (OBT). The main types of OBT 

encountered in the DOE complex are solvents, oils, and solid particulates (e.g., 

plastics, nylon, and organic dust forms). OBT can be particulate or nonparticulate in nature. 
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Furthermore, 

Tritiated metals, metal oxides, dust, and oil can occur in nearly any tritium area. 

Any tritium contamination collected on a swipe survey or a particulate filter 

should be viewed as a potential combination of these. (DOE 2006)

 And 

Any area where tritium is used, handled or stored may result in the formation of 

metal tritides. (Pantex 2004) 

Other significant sources of metal tritides are areas where neutron generator residues (titanium 

tritides) may be present (Pantex 2004). Furthermore, involvement in offsite assembly and 

disassembly operations had the potential to result in exposure to STCs not specifically handled at 

SNL CA. 

The extent of diffusion, absorption, and reactivity is dependent on factors including pressure, 

temperature, and tritium concentration. Sandia experiments involved a wide range of 

temperatures and pressures depending on the specific study. 

The potential for exposure to compounds other than elemental tritium and HTO occurred during 

the removal of tritium beds from gloveboxes, handling of tritium in unenclosed systems (allowed 

for small quantities), assembly and storage areas, waste handling, system maintenance and 

repair, and during D&D of tritium facilities. While a preponderance of tritium activities were 

conducted in gloveboxes, there were situations where lapse of control occurred. In statements 

provided to NIOSH by Tri-Valley Cares (TVC 2007) on the site profile, two examples of lapse 

of control were provided. 

A tritium leak occurred at Sandia Livermore, when a Teflon seat in a pressure 

regulator valve on a deuterium/tritium bottle cracked after exposure to the 

800-psi gas mixture. Operations personnel didn’t realize that the pressure 

regulator contained Teflon; therefore, they took no special precautions. 

And, 

Four workers involved with dismantling the Vacuum Effluent Recovery System 

(VERS) and Gas Purification System (GPS) were involved in an incident with 

tritium contaminated hardware. The VERS typically collects effluent from 

gloveboxes and the exhaust from vacuum pumps. The oil from the vacuum pumps 

normally condenses in its exhaust manifolds. In BUILDING 968 Room 115A, 

workers were cutting up contaminated copper and steel pipe with Jaw of Life 

units. They encountered an unknown oil pocket which spilled on one worker’s 

garment and shoes. Work was suspended, the oil spill was cleaned up and the 

room evacuated. Bio-assay and perspiration swipes (sample) were immediately 

taken which showed elevated radioactive levels in the body. 
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The diffusion is much more pronounced in systems where the tritium is under high pressure, as is 

the case in some programs. These reactions can lead to formation of tritium oxide or “rust,” 

which is very insoluble, with penetration into the metal matrix. Thus, stainless steel gloveboxes, 

gloves, gaskets, and other components in production, disassembly of weapon systems, or 

research facilities can become contaminated with SMTs or OBTs. The extent of this diffusion 

and reactivity is significantly increased with increased pressures and temperatures. 

The issue of diffusion, absorption, and reactivity of tritium has been discussed with site experts 

at SRS, SNL, LANL, the Pantex Plant, and the Mound Plant. 

Tritium Handling and Safe Storage (DOE 2008) states: 

Tritium has a high coefficient of diffusion. It readily diffuses through porous 

substances such as rubber and can also diffuse through metals. 

Tritium gas permeates through most materials, that is, it travels through them by 

way of spaces or interstices in them. The rate depends upon the material and its 

thickness. 

Recently, sensitivity to STC contamination has been increased as a result of 

recent DOE activities involving decontamination and decommissioning [D&D] of 

older facilities. These activities may compromise the effectiveness of the design 

features and allow releases of STC contamination to the surrounding areas. Such 

releases may cause exposures to individuals in the area and releases of STCs to 

the environment both on- and off-site. 

It should be pointed out that design features implemented in later tritium facilities did not always 

exist in earlier facilities, or in areas where STCs were generated byproducts. 

The site profile discusses the protocol and frequency of bioassay sampling conducted for tritium 

at SNL CA. The criteria for placing individuals on a routine tritium bioassay program are 

defined in the Health Physics Programs and Implementing Procedures (SNL CA 1990). 

Individuals who work with tritium handling systems, equipment, materials or 

samples contaminated above the “Control Area” limit of 10,000 dpm/100 cm2 or 

who have been in areas where a low level alarm has occurred or Derived Air 

Concentrations exceeded, will submit urine samples as described below. Casual 

visitors or tour groups are expected to remain with escorts who are familiar with 

the bioassay requirements. Any person who has visited another tritium facility 

within the past 30 days should submit to baseline urine sample. DOE personnel, 

and contractors from other sites with tritium facilities, are expected to submit a 

baseline and followup sample. All visitors to the TRL are required to log-in at the 

entrance at least once per visit period in order to provide their employer with 

bioassay results. 
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Personnel, contractors, or frequent users of the TRL were required to submit urine samples either 

weekly or at the end of a visit/job, whichever is shorter, as a minimum frequency. A database 

was used to calculate the average tritium concentration in urine for each person for the quarter 

and the number of samples collected. Radiation doses are normally calculated assuming chronic 

exposures unless significant acute exposures are found. In this case, the quarterly dose was the 

sum of chronic and acute doses. If the quarterly dose exceeded 10 mrem, the tritium dose will be 

added to the individual’s quarterly whole-body dose equivalent. Dose calculations assumed 

tritiated water with a default biological half-life of 10 days. Personnel were removed from 

tritium work when their urine concentration reached the reference level of 10 μCi/l until a 

subsequent urinalysis fell below the reference level (SNL CA 1990). These calculations assume 

an intake of tritiated water. 

In Table 5-9, the solubility shown for tritium only includes tritiated water, which is not inclusive 

of all forms of tritium at SNL CA. The site profile (ORAUT 2007a, pg. 43) mentions the 

Uranium Tritide Bed installed at the TRL in 1991, which presented a potential for exposure to 

uranium tritide. Uranium tritide is assigned a solubility of Type S followed by the statement, “no 

data to show tritide is more soluble than metal” (ORAUT 2007a, pg. 52). The assumption of 

Type S for uranium tritide is in conflict with DOE (2008), which identifies uranium tritide as a 

soluble particulate tritium compound. Furthermore, the assumption of Type S is inconsistent 

with the Type F class assumed for the Mound Plant. For intermediately soluble or insoluble 

tritium compounds, the effective dose equivalent and the lung dose equivalent will be 

underestimated if urine bioassay data are interpreted assuming an intake of tritiated water. The 

ability to detect tritium in urine relies on the disassociation of the tritium compound, and in some 

cases, these compounds are very stable. 

The solubility of OBT compounds is dependent on the specific compound, and can range from 

more soluble than HTO to an order of magnitude or more less soluble. Taylor (1986) states: 

It is concluded that although the ICRP OBT model may underestimate doses for 

specific compounds by up to an order of magnitude, it can still be applied with 

caution for prospective radiological protection purposes, but it should not be 

applied for the interpretation of bioassay data. 

The site profile considers only HTO in the calculation of tritium dose at SNL CA. Special 

tritium compounds (STCs) formed intentionally or as byproducts of handling large quantities of 

tritium gas and tritiated water are not adequately considered by the site profile. Solubilities and 

biokinetic distribution of STCs vary from that of HTO and must be considered in the assessment 

of tritium dose. For tritium, it is important that the dose reconstructor chooses claimantfavorable 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. Doses from exposure to STCs can be 

underestimated by orders of magnitude if dose is calculated based on an HTO uptake in place of 

an STC uptake. Given the existence of STCs at SNL CA, further consideration needs to be given 

to potential exposures and resulting doses from these STCs. Furthermore, assignment of Type S 

solubility for uranium tritide is inconsistent with the available DOE documentation and 

assumptions made for dose reconstruction at other sites handling uranium tritide. 
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Currently proposed approaches developed by NIOSH for estimating dose from STCs rely on the 

use of urine bioassay results in concentration (e.g., μCi/L). In the absence of bioassay data, the 

site profile should discuss in detail how dose will be estimated for STCs, particularly those 

compounds not readily disassociated to soluble compounds in the body. 

3.7 FINDING 7: ASSUMPTIONS FOR URANIUM DOSE ASSESSMENT ARE NOT 

CLAIMANT FAVORABLE 

During the period of the first uranium bioassay (prior to 1968, specific date not identified by 

NIOSH) to 1990, fluorometry was used to determine uranium mass concentration (μg/l) in urine. 

The site profile indicates that from 1990–1993, samples were analyzed by a contractor 

laboratory, CEP, which was subsequently found to be providing suspect bioassay results. 

NIOSH determined that these recorded results should not be used (ORAUT 2007a, pg. 48). 

From 1993 to the present, NIOSH does not confirm the method of analysis, but suggests it was 

probably done using ICP-MS. 

Uranium bioassay was conducted for SNL CA workers who met the following criteria (SNL CA 

1990): 

The technical basis for uranium bioassay sampling is based upon the potential for 

uptake by the various modes, such as inhalation, ingestion, or skin absorption. 

Soluble forms of uranium are infrequently handled at SNL Livermore, and usually 

in small quantities. Air sampling may be inadequate to identify uptakes resulting 

from skin absorption, particularly if the material is handled in a chemical fume 

hood. Personnel will be started on a minimum bioassay program if they meet any 

of the following criteria: 

1. When air sampling of the workplace demonstrates that uranium air 

concentrations may reach or exceed 10% of the Derived Air 

Concentration: 2 E-11 μCi/ml. 

2. Wet or dry machining or other operations where air sampling may not 

be indicative of uptake. 

3. The handling of soluble uranium compounds, where airborne 

measurements may not be indicative of uptake, such as by skin 

absorption. 

4. Routine work in an area posted as a “Contaminated Area” regardless 

of the air sample results.

For Class D uranium compounds, routine samples were collected monthly, and for Class W or Y 

uranium compounds, samples were collected semi-annually. Non-routine uranium bioassay 

samples were submitted under the following conditions (SNL CA 1990): 
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The technical basis for nonroutine bioassay is not based upon measured or 

potential air concentrations, but rather accidental or suspected exposure when 

air sampling data is not available. A bioassay sample will be collected 48 hours 

post exposure for the following incidents: 

1. Skin contact with a soluble form of uranium. 

2. Exposure to a uranium fire, or an event resulting in contaminated 

nasal wipes. 

3. A cut or lesion that may have injected uranium or it’s compounds 

under the skin. Wound counts may not be sensitive enough to detect 

depleted uranium in a deep cut. 

4. Baseline samples may be collected for personnel starting work with 

uranium.

An investigation level set for uranium was 0.3 Allowable Limit on Intake (ALI)/N, where N is 

the number of monitoring periods, or 2.25E-2 g (insoluble uranium) and 1.2E-2 g (soluble 

uranium). The uranium dose is included in the effective dose if the concentration is equal to or 

greater than 0.1 ALI/N. An assumption of 1 micron AMAD is assumed for dose assessment 

purposes (SNL CA 1990). 

Detection Limits 

The uranium bioassay detection limits recommended for 1973–1987 appear to be too low for 

analysis by fluorometry. Uranium bioassay samples were forwarded to SNL NM for processing. 

In Section 5.9, “Summary Tables,” Table 5-8, “Detection limits for total uranium bioassay,” 

NIOSH identifies the minimum detectable activity (MDA) for uranium bioassay performed by 

fluorometry between 1973–1986 to be 1.1 micrograms per liter (μg/l), during 1975 to be 

0.7 μg/l, and for 1986–1987 to be 3 μg/l. The health physics program and implementing 

procedures state (SNL CA 1990): 

The measurement technique currently used by SNL Albuquerque is flourimetry of 

urine samples. SNL Albuquerque reports a MDL of 1–3 μg/L. Most of the 

uranium handled at SNL Livermore is depleted uranium making radioanalytical 

measurements difficult. 

Prior to 1973, the fluorometry bioassay MDA for uranium was identified to be 5 μg/L (which has 

been the industry standard MDA for this method), from 1987–1990 to be 10 μg/L, from 1991–

1992 to be 12 μg/L (analyses by CEP determined to be invalid), and from 1993–present analyzed 

by ICP-MS (a much more sensitive method than fluorometry) to be 0.1 μg/L. The use of these 

significantly lower MDAs (than 5 μg/L) during the period from 1973–1987 is suspect, because it 

is questionable that the laboratory that performed these analyses could achieve a lower MDA 

than 5 μg/L. This “industry standard” MDA of 5 μg/L was identified in the site profiles by 

NIOSH to be in use at Portsmouth from 1954–1995 (ORAUT 2004a), Paducah from 1952–1998 
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(ORAUT 2007d), and Oak Ridge K-25 (ORAUT 2006b) from 1958–1989, which are sites that 

handled uranium in all forms of enrichment including DU. These questionably unusual and low 

MDAs that NIOSH plans to use for 1973–1987 will lead to significantly lower missed dose 

(minimum detectable dose) estimates than the use of 5 μg/L as the MDA. 

Controls for Environmental Pollution (CEP) 

Uranium bioassay samples from SNL CA were sent to SNL NM for analysis either in-house or 

by a contracted laboratory (Potter 1994). SNL NM, to which SNL CA samples were sent, 

contracted with CEP for bioassay services starting in February 1992 (Friedman 1998). The SNL 

NM site profile indicates that services continued through April 1994 (ORAUT 2007b). CEP had 

come under suspicion of data falsification in 1994 after bioassay data provided to Sandia were 

found to be questionable. SNL identified problems with the analyses performed by CEP (Ball 

et al. 1995) and eventually invalidated the uranium bioassay results received from CEP. This 

event calls into question the reliability of CEP’s analytical services for Sandia, and thus SNL 

CA, who relied on Sandia to process their non-tritium bioassay samples. Table 5-2, “Preliminary 

time line uranium in urine analysis,” specifies CEP as the source of bioassay analysis from 

1990–1993 (ORAUT 2007a, pg. 48); however, the SNL NM site profile indicates the contract 

with CEP was from 1992 to 1994. This raises some question regarding the adequacy of data 

from 1990 to 1994. Bioassay data for this time period from other sources has not been located to 

date. The site profile identifies that uranium bioassay results from this period are not to be used; 

however, it does not give instruction to the dose reconstructor on how to assess uranium intakes 

and doses that could have occurred during this period for the staff that gave bioassay samples 

(these staff were identified by NIOSH to be at higher risk of exposure, according to the SNL CA 

monitoring policy). Furthermore, these data are not suitable for use in a coworker model. The 

complete lack of bioassay data places a reliance on the air sampling data conducted at SNL CA 

and its representativeness of worker exposure. This issue is discussed later in this report. 

Solubility Assumptions 

Table 5-9, “Solubility type, fraction activity and particle size,” shows DU is likely in Type S 

solubility form; however, if it has not been highly oxidized, it may contain a significant fraction 

of Type M form, which would lead to different calculated internal doses to organs, depending on 

the organ of concern. Industrial uranium oxides are often mixtures of relatively soluble and 

insoluble fractions, with variability strongly influenced by process history (Edison 1994). 

NIOSH should further investigate the solubility of the DU handled at the site or recommend that 

more soluble forms, with a component of Type M, must also be considered if these assumptions 

increase the assessed dose to organs under consideration for the claimant. The site profile does 

not specify how the solubility issue will be addressed. 

TRL handled uranium tritide in the form of powder in storage beds. This material is classified as 

metallic Type S material. The site profile goes on to further say that there is no data to show 

uranium tritide is more soluble than metal. The Radiological Control Programs for Special 

Tritium Compounds (DOE 2004) indicates that uranium tritide is a Type F compound. This 

should be corrected in the table and considered in former and current dose reconstructions. 
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Uranium Enrichment 

In Section 5.3.2 of the site profile, the dose reconstructor is directed to assume a specific activity 

for DU when converting uranium bioassay mass concentrations to activity concentrations. The 

site profile further indicates that there is no information to demonstrate appreciable amounts of 

natural uranium (NU) or EU were used at SNL CA (ORAUT 2007a). 

A “small” amount of U-235 (typically indicating highly EU) is identified as being at the site in 

Section 4.4.1, “Locations of Concern:” 

An aerial survey of LLNL and SNL/CA, conducted in 1975 (Tipton 1977), found 

gamma-emitting radioactivity in excess of background levels in the vicinity of 

Building 9143 (the Radiography Building at the time) and to a much lesser extent, 

in the vicinity of a waste holding area known to contain DU and thorium 

(Building 9122), and a material storage vault known to contain DU, thorium, and 

small amounts of shielded 60Co and 133Ba, and 235U (Building 921, incorrectly 

referred to as B-291 in the Tipton 1977 report).

Furthermore, Section 5.2 states: 

There is no evidence that urine bioassay samples were analyzed for any 

radionuclides except H-3 and natural uranium (U-nat)... 

NIOSH needs to clarify these apparently conflicting statements – “samples were analyzed for... 

natural uranium (U-nat)” and no “appreciable amounts of either natural or enriched uranium 

were used”... Was the uranium urine bioassay for U-nat or DU or total U, and was the analysis 

specifically for detecting DU intakes or was it possible that other enrichments of U could have 

been involved with intakes? This is critical when using mass concentration (μg/l) units in dose 

and intake calculations. 

There appears to be some uncertainty regarding the handling of NU and EU at SNL CA. Little 

information has been identified regarding the form of the NU and EU, or the operations 

conducted with these materials. The range of enrichment is also unknown and requires further 

investigation. 

If natural, low- and/or high-enrichment uranium was handled at site, this brings into question the 

appropriateness of assuming DU to convert mass concentrations to activity concentrations. The 

total uranium activity changes greatly with enrichment changes. Use of DU for dose estimates, 

when using bioassay data in units of mass concentration (μg/l), would cause an underestimation 

of dose for those exposed to normal or EU. 

In summary, the uranium detection limits recommended in the site profile for the period 1973–

1987 appear to be too low for analysis by fluorometry. The values proposed are well below the 

industry standard for this technique for this period of time. Uranium urinalysis samples collected 

from CEP (1990–1993 as defined in the site profile, and 1992–1994 as defined by SNL NM 

contract) is suspect and cannot be used for the determination of uranium dose or for inclusion in 
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a coworker model. Solubility assumptions require update and correction based on currently 

available scientific data. The assumption for a mass conversion factor should be reflective of all 

enrichments of data handled at SNL CA, and not limited to DU. Defaulting to DU for 

conversion to activity when using bioassay data in units of mass concentration (μg/l) when the 

site handled NU and EU, would cause an underestimation of dose for those individuals exposed 

to normal or EU. 

3.8 SECONDARY FINDINGS 

Finding S1: Environmental Source Terms are Inadequately Characterized for SNL CA 

Workers Located or Participating in Activities at Site 300 of LLNL

When the AEC decided to established a Livermore branch of Sandia National Laboratory, 15 

individuals were transferred from SNL NM to a temporary location at LLNL. 

When I first came here in September 1955, our entire office consisted of space in 

Building 151 of UCRL. As we grew larger, we occupied additional space in 

Building 144. Later, we overflowed and maintained spaces in Buildings 136, 142, 

and 166. (SNL CA, no date) 

A review of the LLNL TBD indicates that both Building 151 and Site 300 handled radioactive 

materials potentially resulting in exposures to SNL CA workers. 

Building No. Building Activity Radionuclide 

151 Isotope Sciences, Environmental Services 

Laboratory 

Ni-63, I-129, U-233, U-234, U-235, U-238, 

Np-237, U-236, Pu-236, Pu-238, Pu-239, Pu-240, 

Pu-241, Pu-242, Pu-244, Am-241, Am-243, 

Cm-242, Cm-244, Cm-246, Cm-248, Cf-249 

Site 300 Explosives Testing, Linear Accelerator, 

Radiography 

H-3, N-13, Ar-41, U-234, U-235, U-238, O-15; 

H-3, C-14, Na-22, corrosion products, MFP, 

transuranics, U, Pu, Th 

Sandia personnel continued to work at Site 300 throughout the operation of the SNL CA facility, 

including involvement in hydroshot testing. This is evident in the SNL CA claimant medical 

records, as working out at Site 300 required special medical clearance for at least some period of 

time. 

The site profile is incomplete in its description of activities occurring at Site 300 and the 

potential radiological exposure conditions associated with these activities. Minimal dose 

reconstruction guidance is provided for environmental occupational dose, and it is clear from 

operational descriptions that guidelines allowed for experiments with NU, DU, natural thorium, 

tritium, and beryllium. Sewell (1959) specifically authorized the thorium hydrodynamics 

program at Site 300 in 1959. No method for assessment of environmental dose from alpha 

emitters and tritium is available prior to 1961 and 1972, respectively. Further evaluation of the 

implemented monitoring for this area and its adequacy for the radionuclides involved in tests is 

necessary. 
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Finding S2: No guidance is given to determine the environmental particulate radioactivity 

intakes for the period 1956–1960, and it is assumed that the alpha emitters U-234 and 

Pu-239 are the only contributors to dose from alpha emitters coming from the LLNL site 

releases from 1961–1970, which may not be claimant favorable in all cases

Section 4.3.3, “Annual Intake of Radioactivity” (ORAUT 2005b), does not provide intakes of 

particulate radionuclides for the years 1956–1960 apparently due to the fact that LLNL did not 

perform any site perimeter air sampling during this period. For all other years of operation, 

1961–2004, LLNL south perimeter air sample data for particulates are used by NIOSH to 

estimate the maximum intakes of, and doses from, particulate radionuclides that SNL CA 

unmonitored personnel may have received. There is no explanation by NIOSH or guidance to 

the dose reconstructor for this period beyond restating that there is no data for 1956–1960 to 

estimate intakes of particulate radionuclides. NIOSH should investigate further the possibility 

that particulate radionuclides could have been inhaled by unmonitored staff during the period 

1956–1960 and describe how these intakes will be calculated. 

NIOSH identifies LLNL as the only source of particulate radionuclide exposure to unmonitored 

employees, and it is known that they handled several alpha emitters other than Pu-239 and 

uranium isotopes, which included thorium isotopes, Am-241, Cm-244, etc. In fact, NIOSH 

states, “In addition to 3

H, LLNL has processed and handled a number of radionuclides including 

uranium and transuranic elements, mixed fission products, and accelerator-produced isotopes.” 

The assumption by NIOSH that gross alpha air sample results and therefore intakes of alpha 

emitters were only from U-234 (NIOSH assumes U-234 for all uranium isotope activity, because 

it has the largest dose factor of all uranium isotopes) or Pu-239 may not be accurate or claimant 

favorable. Since other alpha emitters (thorium isotopes, Am-241, Cm-244, etc.) could have been 

part of the released radionuclides, these should be considered as part of the intakes for dose 

assessment if the assumption of only U-234 and/or Pu-239 intakes do not provide higher doses to 

the organ of the claimant. Since NIOSH is basing the particulate radionuclide intakes by 

unmonitored employees on the nearest LLNL boundary air sampling data, NIOSH should 

consider alpha-emitting radionuclides other than Pu-239 and uranium isotopes, such as Th-232, 

as possibly detected in the air samples analyzed by gross alpha from 1961–1970. 

Finding S3: NIOSH has assumed that there were no SNL CA-generated particulate 

radioactive airborne emissions of significance, which is somewhat unverifiable because of 

the lack of monitoring data.

Apparently, SNL CA essentially did not perform stack effluent monitoring for particulates or 

have onsite or perimeter environmental air monitoring stations that were designed to detect 

radioactive particulates. According to NIOSH (Section 4.3.2, “Source Terms for Internal 

Dose”): 

No onsite environmental sources or outdoor concentrations of radionuclides have 

been reported for SNL/CA before the beginning of operations of TRL in 1979. 

NIOSH states that they used “absolute” filters in four buildings to attempt capturing radioactive 

particulates before being released in the effluents. Even if these filters were equivalent to HEPA 
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filters or other highly rated filters, it is standard practice that any exhaust stack/vent that 

potentially releases airborne radionuclides, whether filtered or not, is monitored or sampled at a 

frequency determined to be adequate to verify releases are within limits and kept ALARA. 

Additionally, air sampling stations are typically placed at locations of expected highest 

concentrations, with near-critical receptors (such as at boundaries and near populations or 

buildings) for verifying that stack effluent controls and monitoring systems are operating 

properly. Without these, verification that effluent controls (e.g., “absolute” filters) are 

performing properly cannot be done, and it becomes more of an assumption that there were no 

airborne radionuclide effluents from these stacks. NIOSH should perform further verification 

that there were no possible onsite particulate radionuclide air emissions to which unmonitored 

workers were exposed. 

Finding S4: The assumption that environmental TLDs placed significant distances from 

the locations that unmonitored personnel were exposed are representative of their 

maximum external doses may be inaccurate, and there are an unexplained low dose and 

other irregularities in the tables of gamma and neutron external doses. 

NIOSH assumes that all external exposures to unmonitored staff were from LLNL site 

operations and can be assigned by assuming the LLNL perimeter TLD results are the maximum 

external dose to unmonitored staff from effluents and any other sources. This is reasonable if, 

and only if, maximum exposures could have been from only LLNL effluent releases and neutron 

fields. NIOSH bases much of this assumption on a 1975 aerial survey (Tipton 1977) that found 

the only “gamma-emitting radioactivity in excess of background levels” to be in areas that had 

access limited (NIOSH appears to be inferring that limited access means no unmonitored 

employees could enter these areas). Several of the sources of photon-emitting radiation at the 

site were x-ray machines and accelerators, which only would have been detected by the aerial 

survey if it had equipment capable to detect these (x-ray machines and accelerators can have 

very short pulse times and be difficult to detect with standard monitoring equipment) and if the 

machines and accelerators were operating during the survey. The site operated for 

approximately 30 years past this survey date and it is possible that more gamma-emitting 

sources, x-ray machines, and/or accelerators were acquired during those years that could have 

increased environmental external radiation hazards. NIOSH should verify that this 1975 aerial 

survey applies to all external radiation conditions from 1956–2004. As mentioned in Finding 3, 

no stack or ambient particulate radionuclide monitoring was performed at SNL CA; therefore, 

there was no total verification that DU was not released from their operations. DU has a strong 

beta emitter in its decay chain (Pa-234m, which grows into equilibrium with the U-238 activity 

within a few months after aging), which could give very large skin doses if a particle lands on 

the skin. This provides further emphasis that NIOSH should verify that no particulate 

radionuclides could have been released from site operations. 

In Table 4-4 [“External gamma radiation dose based on 2,500 hr/yr exposure duration 

(mrem/yr)”], the dose for 1967 (15 mrem/yr) is less than one-tenth (1/10) of the dose for the 

prior year and following year (both 156 mrem/yr). The 1967 dose is the lowest annual dose in 

the site history shown in this table, and it is embedded in a period of much larger doses in the 

years nearest to it. NIOSH needs to either correct this dose in the table if it is a typographical 

error, or explain why it deviates so much from doses in the years before it and year after it. 
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There are also several “Maximum Dose Rate” values that do not agree with the sum of the 

“Average Perimeter” and “Error,” from which NIOSH states the Maximum Dose Rate is derived. 

For example, in 1991, the Average Perimeter is 16 mrem/yr and the error is 5 mrem/yr, which 

sums to 21 mrem/yr for the Maximum Dose Rate, and the table has 20 mrem/yr shown in the 

column. This also occurs in Table 4-5 (“Elevated neutron dose due to LLNL perimeter neutron 

source”), where the summation of “North perimeter dose” and “Error” do not always add up to 

the value in the “Maximum dose” column. NIOSH should correct these summations, or if there 

is a reason for these to not sum directly to the actual values due to “rounding” up or down, it 

should be so stated. 

Finding S5: NIOSH states that all airborne tritium releases and resulting intakes should 

be assumed to involve tritiated water (HTO), although the site handled various forms, 

because its mission involved research on tritium compounds. 

At SNL CA, various chemical forms of tritium were fabricated and handled as metal tritides and 

likely several other chemical forms. Tritium was handled often in gloveboxes, which infers that 

any of these forms got airborne and presumably into the exhaust ventilation systems. NIOSH 

should defend the assumption that all intakes from environmental releases of tritium are in the 

form of HTO and not other forms that would result in different organ doses. 

(1) NIOSH has assumed that there were no SNL CA-generated particulate radioactive 

airborne emissions of significance, which is somewhat unverifiable because of the lack of 

monitoring data. 

(2) The assumption that environmental TLDs placed significant distances from the locations 

that unmonitored personnel were exposed are representative of their maximum external 

doses may be inaccurate, and there is an unexplained low dose and other irregularities in 

the tables of gamma and neutron external doses. 

(3) NIOSH states that all airborne tritium releases and resulting intakes should be assumed to 

involve tritiated water (HTO), although the site handled various forms, because its 

mission involved research on tritium compounds 

Finding S6: Protocols describing the frequency and type of x-ray examinations for SNL 

CA workers from 1956 to the present has not been located. Information is absent from the 

site profile, including types of x-ray equipment, technique factors, filtration, whether 

screens and grids were used, and some machine calibrations. 

Although default protocols have been established for frequency and type of occupation medical 

x-rays, SC&A would like to stress the importance of reviewing the claimant-specific x-ray 

information, which may deviate from the standard assumptions. For example, lumbar spine xrays were taken after employment of the individuals at times. It appears this was associated with 

a specific project or job. Individuals assigned to Site 300 were also given special exams; 

however, the details of these exams were unavailable. 

 
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As a result of the lack of medical x-ray information, the site profile relied on a review of the 

claimant medical records to ascertain the frequency and types of x-rays (ORAUT 2007a): 

However, claimant files available at the time of this documents preparation 

generally indicate that a single posterior-anterior (PA) chest x-ray examination 

was performed at hire, annually, and possibly at termination from 1956 through 

the 1980s. They also show that anterior-posterior (AP) and lateral (LAT) lumbar 

spine x-rays were at least sometimes performed at hire as late as 1971. 

SC&A was able to obtain information regarding the medical x-ray program. The method for 

determining who was included in the health surveillance program at SNL CA has undergone 

changes through time. Radiation workers were included in those workers who participated in the 

health surveillance program. For the purposes of determining whether workers should 

participate in the health surveillance program, SNL CA defined a radiation worker as (Wright 

1979): 

A “radiation worker” at SLL [Sandia Laboratories Livermore] shall be defined 

as an employee who receives or could potentially receive radiation exposure from 

his job in excess of 10% of the applicable standard from internal or external 

radiation. This includes the following categories of personnel. 

1. Those individuals working with ionizing radiation producing equipment or 

sources as part of their job and must enter restricted or controlled areas 

as defined by 10 CFR 20. 

2. Those individuals working with radioactive materials which present a 

potential exposure as an internal emitter of radiation (except D-38). 

In 1982, Lovell indicated the following in a memorandum to Dr. Rhodenbaugh (Lovell 1982). 

Based on codes and regulations followed by DOE, medical surveillance is 

recommended on the basis of some demonstratable exposure. This exposure level 

is normal at 10 to 50% of the permissible exposure limit. For example, those 

exposed to ionizing radiation would require medical surveillance if dosimetry 

indicated a 10% permissible level (500 mR/year) by internal or external 

dosimetry. Most toxic chemicals have a trigger level at 50% of the TLV 

[Threshold Limit Value] based on TWA [time-weighted average] of the airborne 

contaminant. For example, medical surveillance would be required for 

perchloroethylene exposure at 25 ppm [parts per million]. 

SNL CA has taken a more conservative position and focuses on “exposure 

potential.” If there is a potential for exposure with a plausible exposure 

mechanism, medical surveillance is requested.

In 1987, the DOE Office of Nuclear Safety, DOE/HQ, entered into an interagency agreement 

with the Food and Drug Administration (FDA) to acquire third-party health physics surveys of 
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medical diagnostic equipment. DOE Albuquerque Operations Office (DOE-AOO) notified its 

contractors that the Center for Device and Radiological Health would provide surveys at a 2-year 

frequency, and that documentation of these surveys would be provided to DOE-AOO and the 

contractor (Themelis 1987). SC&A located documentation on a survey conducted on September 

13, 1988, of the medical x-ray unit at SNL CA. The unit was tested for reproducibility, linearity, 

filtration, collimation and x-ray/light field alignment. Stevenson (1988) stated in his survey 

report: 

The skin entrance exposure (ESE) for a 26 cm P/A chest at 110 kVp, 300 mA and 

1/60th of a second was 14 mR. There was no technique factors listed for the 

23 cm chest, but the ESE at 110 kVp, 150 mA and 1/40th of a second was 10 mR. 

This would indicate that PA chest x-rays were being taken on some workers until at least 1988. 

Furthermore, there is data available of x-ray surveys for at least some periods of time, which 

serve to validate assumptions made in the site profile. This data should be used wherever 

available to derive occupational medical x-ray exposure doses. 

One concern noted during the evaluation of individual medical records on the Request for X-ray 

Exam form for the early 1960s was the option for a “large chest” or “small chest” x-ray. 

Photofluorography film is smaller than the standard x-ray film. The meaning of “small chest” 

procedure needs to be defined to ensure this is not indicative of photofluorography use at the site. 
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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 OBJECTIVE 1: COMPLETENESS OF DATA SOURCES 

Internal and external dosimetry records form the primary basis for conducting dose 

reconstruction. A quality assurance review of the data received from the site is critical to 

ensuring appropriate and complete records are provided for consideration in the dose 

reconstruction process. A preliminary review of claimant files indicate gaps in the external 

monitoring data, particularly for those years were the policy was to monitor all workers at the 

site. Limited internal monitoring data is available for Sandia in the individual radiation and/or 

medical file. Sandia has not provided cycle-by-cycle badge data, or in some cases, annual data. 

Much of the data provided is cumulative and may or may not include radiation exposure received 

offsite. Generic logbook data is available to fill some of the gaps identified in the claimant files; 

however, there is no direction to the dose reconstructor to consult this data. 

The site profile inadequately characterizes offsite work activities involving SNL CA workers, 

which were extensive for some categories of workers. The impression presented in the site 

profile and within Sandia documentation is that host sites monitored Sandia visitors 

appropriately for internal and external dose during their visit. Furthermore, it is assumed this 

data is readily available through either the Sandia or visited sites. The data is lacking in SNL 

NM records requests, as well as those from visited sites. Travel offsite potentially exposed 

workers to plutonium, thorium, MFPs, MAPs, and other radionuclides without the benefit of 

internal monitoring in most cases, either at the visited site or upon return to SNL CA. 

NIOSH identifies offsite visits through the CATI process and requests dose from the host site 

where a visit is captured in the CATI. If information on site visits is not specifically provided by 

the claimant, no information for offsite exposure is requested. Total reliance on the CATIs for 

offsite visits, particularly in the absence of a question related to these offsite visits, creates 

inconsistencies between survivor and energy employee claimants. Consideration should be 

given to alternative ways to identify visits to other DOE sites. Some thought needs to be given 

regarding how visitor records are requested from DOE sites, as visitor data is often stored 

separately from regular employee data. 

In addition, it was noted that monitoring was not located for Sandia workers at a majority of the 

host sites. A brief review of exposure information retrieved for specific claimants and radiation 
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exposure summary reports available on the SRDB indicate most of the data was external dose, 

with a limited amount of tritium data found for LLNL. A review of the claimant SNL CA 

dosimetry files indicated that in only a few circumstances was the offsite exposure data included 

in the SNL CA dosimetry file. In some cases, the monitoring dates and information provided by 

host sites did not correspond to the monitoring information available in the Sandia dosimetry 

reports. 

4.2 OBJECTIVE 2: TECHNICAL ACCURACY 

The site profile does not adequately address issues associated with the implemented dosimetry 

systems and the characterization of external exposure at SNL CA. There is a lack of information 

on dosimetry systems implemented at SNL CA prior to 1989, including uncertainties related to 

the dosimetry technology, dosimetry calibration procedures, dose calculation algorithms, 

adjustments to recorded dose, dose recording policies and practices, and uncertainty and bias 

factors. Furthermore, there is a lack of information on the MDLs and exchange frequencies. As 

a result, in the case of assignment of missed dose and dosimetry uncertainties, surrogate data 

from the dosimetry programs at ORNL, LLNL, Hanford, and BNL were used to estimate 

parameters for SNL CA. Discussion of data equivalency in the site profile between the 

dosimetry programs at these sites and SNL CA is inadequate and further demonstration of 

equivalency is necessary. This is particularly prudent, given discussions regarding use of 

surrogate data from other sites at the Advisory Board meeting in February 2010 (ABRWH 

2010). 

Issues have been raised in SNL CA documentation and the site profile regarding the ability of 

SNL CA to discriminate between radiation types encountered by SNL CA workers. The 

characterization of radiation energies and relative percentages provided in the site profile are 

based on estimates provided by site personnel, and on the assumption that tritium and DU were 

the primary source terms. The estimated energies and percentages are not substantiated by actual 

field measurements. Furthermore, external exposures from other radionuclides (e.g., Kr-85, EU, 

and MFPs) and operations (e.g., classified work) are not considered. In the absence of a reliable 

radiological characterization of the source term, the relative impact in inadequacies in the SNL 

CA dosimetry system is unknown. The need for a correction factor to account for the 

inadequacies of the dosimetry system to discriminate penetrating and non-penetrating exposures 

requires further investigation. 

The variety of neutron sources and operating conditions at SNL CA warrant further 

characterization of the neutron energies encountered at SNL CA. Table 6-4, “Selection of 

radiation energies and percentages,” indicates that at least some fraction of neutrons were less 

than 1 MeV (ORAUT 2007a, pg. 65). It is reasonable to assume that regardless of the initial 

neutron energy produced from a source or neutron generator, the spectrum to which workers 

were exposed would contain neutron energies less than 1 MeV. This is consistent with 

information from other DOE sites with similar operations. While the site profile considers a 

correction factor for conversion from NCRP Report 38, Neutron Quality Factors, to ICRP 

Publication 60, Radiation Weighting Factors (ORAUT 2006a), it does not consider the lack of, 

or reduced response of, NTA film to neutron energies less than 1 MeV. An appropriate 
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correction factor or alternate methodology should be included in the site profile to compensate 

for the under-response of NTA film to low-energy neutrons. 

Several SNL CA documents lead to the conclusion that radionuclides other than tritium and 

uranium were handled at SNL CA. The site profile itself indicates that Pu-239 and MFPs were 

handled in at least trace amounts (ORAUT 2007a, Table 2-1). Details on the quantities, forms, 

and handling conditions deserve further consideration in the site profile. With the presence of 

these radionuclides, and the absence of bioassay data for radionuclides other than tritium and 

uranium, consideration needs to be given to potential missed dose from exposure to these 

radionuclides. Furthermore, an investigation into radionuclides handled as a part of classified 

activities is warranted to ensure that potential exposure situations to other radionuclides did not 

exist. In addition, the SNL CA internal monitoring programs did not provide coverage of 

potential exposures to radionuclides encountered at other sites, including plutonium, thorium, 

MFPs, MAPs, and other radionuclides. The site profile assumes individuals were monitored at 

the visited site; however, very limited internal monitoring data has been recovered from other 

DOE sites. The existing bioassay program at SNL CA would provide adequate coverage to 

internal exposures received offsite in most cases. 

The site profile fails to adequately consider potential uptakes of STCs. These compounds were 

generated during the course of experimental activities, and as byproducts resulting from the 

absorption, reactivity, and diffusion of tritium into structural material and chemicals used in the 

tritium processing areas. Compounds range from soluble to highly insoluble. Much of the work 

was conducted in engineered enclosures (at least at the TRL); however, there was a potential for 

exposure during the removal of tritium beds from gloveboxes, handling of tritium in unenclosed 

systems (allowed for small quantities), assembly and storage areas, waste handling, during 

system maintenance and repair, and during D&D of tritium facilities. In addition, there were 

conditions when there were lapses in radiological control. Assumption of an intake of HTO in 

place of STCs can underestimate dose by orders of magnitude, depending on the type of STC. 

Given the existence of STCs at SNL CA, further consideration needs to be given to potential 

exposures and resulting doses from these STCs. Currently proposed approaches developed by 

NIOSH for estimating dose from STCs rely on the use of urine bioassay results in concentration 

(e.g., μCi/L) and the ability to identify workers exposed to STCs. The site profile should discuss 

in detail how they will estimate dose from STCs, particularly those compounds not readily 

disassociated to soluble compounds in the body. Furthermore, the solubility type assigned for 

uranium tritide should be consistent with available literature and assumptions made in other site 

profiles and dose reconstruction documentation. 

With respect to the adequacy of the uranium bioassay program, the uranium detection limits 

recommended in the site profile for the period 1973–1987 appear to be too low for analysis by 

fluorometry. The values proposed are well below the industry standard for this technique for this 

period of time. Uranium urinalysis samples collected from CEP (1990–1993 as defined in the 

site profile, and 1992–1994 as defined by SNL NM contract) is suspect and cannot be used for 

the determination of uranium dose or for inclusion in a coworker model. Solubility assumptions 

require update and correction based on currently available scientific data. The assumption for a 

mass conversion factor should be reflective of all enrichments of uranium handled at SNL CA, 

and not limited to DU. Defaulting to DU for conversion to activity when using bioassay data in 
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units of mass concentration (μg/l), when the site handled NU and EU, would cause an 

underestimation of dose for those individuals exposed to normal or EU. 

4.3 OBJECTIVE 3: ADEQUACY OF DATA 

The Sandia TBD describes bioassay results from a commercial laboratory, CEP, that 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 that may have occurred during this time period. Considering this was the only 

source of uranium data for SNL CA workers for 1992 to 1994, and possibly from 1990 to 1991, a 

methodology for addressing missed dose during this period should be developed. 

4.4 OBJECTIVE 4: CONSISTENCY AMONG SITE PROFILES AND OTHER 

NIOSH DOCUMENTS 

Sandia was actively involved in testing activities at NTS (including TTR) and in some cases 

PPG. Special Exposure Cohort (SEC) classes have been established for both NTS and PPG. 

Sandia personnel participated in equivalent activities as PPG and NTS employees. The 

eligibility of national laboratory participants in weapons testing SEC classes requires 

clarification and should be considered in the site profile. In addition, consideration should be 

given to how the weapons laboratory workers may be affected by other existing SEC classes at 

Mound, LANL, LLNL, Mound Laboratory, IAAP, Amchitka Island Nuclear Explosion Site, the 

Y-12 Plant, and RFP. The inadequacies in monitoring data identified at these sites existed for 

Sandia visitors, and onsite monitoring was not adequate to mitigate this situation in many cases. 

Other site profiles have established methodologies to compensate for the lack of response of 

NTA film to low-energy neutrons. This is absent from the SNL CA site profile, although the 

potential for neutron exposure was present at SNL CA, and the laboratory had a neutron 

monitoring program. 

4.5 OBJECTIVE 5: REGULATORY COMPLIANCE 

No regulatory compliance issues were identified by SC&A in the SNL CA site profile. 

4.6 AMBIGUOUS DOSE RECONSTRUCTION DIRECTION 

In regard to external dosimetry, the site profile identified several uncertainties and concerns 

regarding dosimetry technology, calibration, dose calculation, and recording practices (refer to 

Finding 4). Directions guiding dose reconstructors to account for these uncertainties were 

cursory, at best. For example, in Section 6.4.2.1, the site profile acknowledged that a transition 

from film to TLDs may have occurred sometime between 1966 and 1972. To assure a claimantfavorable estimate of missed dose in light of this uncertainty, the site profile recommends 

assuming that film dosimeters were used until about 1972 in cases where missed dose is 

estimated. No specific guidance is provided regarding appropriate corrections to apply for the 

film dosimeter’s MDL and exchange frequencies. Additionally, no guidance is provided for 

situations in which annual or badge cycle data is unavailable (cumulative exposures only). 
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NOTICE:

Guidance is absent or ambiguous in regard to the absence of calibration data and methodology 

prior to 1989, the absence of dose calculation and reporting practices prior to 1989, and 

application of surrogate bias and uncertainty factors adopted from the Hanford site profile. No 

practices are identified to address the concern regarding energy discrimination deficiencies of the 

2-chip, single-filter TLD badge used from 1972–1982. 

Table 6-2 (page 62) identifies circumstances and protocols for dose adjustment or estimation, but 

the instructions for dose assignment are vague. 

4.7 UNRESOLVED POLICY OR GENERIC TECHNICAL ISSUES 

 

General policy issues, such as consistency in SEC process determinations and applications, are 

critical to sets of SNL CA workers conducting radiological activities at sites where classes have 

been previously established (e.g., NTS, PPG, Mound, RFP). Quality assurance of the claimant 

data provided to NIOSH by some facilities (including SNL CA) is insufficient and requires 

further consideration by NIOSH. The retrieval of monitoring records for DOE site visitors is 

another issue that requires further evaluation; some DOE sites appear to be inherently unable to 

identify and retrieve visitor monitoring data. Finally, it is paramount that NIOSH conduct 

outreach efforts and site expert interviews to gather pertinent information on site activities for 

each site profile, regardless of the size of the facility’s claimant population. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

5.0 REFERENCES 

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NIOSH (National Institute for Occupational Safety and Health) 2008. SEC Petition Evaluation 

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and Analysis, Cincinnati, Ohio. February 6, 2008. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

OCAS 2009a. Worker Outreach Program, OCAS-PROC-012, Office of Compensation and 

Analysis, National Institute for Occupational Safety and Health, Cincinnati, Ohio. March 2, 

2009. 

ORAUT (Oak Ridge Associated Universities Team) 2004a. Portsmouth Gaseous Diffusion 

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ORAUT (Oak Ridge Associated Universities Team) 2004b. Technical Basis Document for the 

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to ICRP Publication 60 Radiation Weighting Factors for Respective IREP Input Neutron Energy 

Ranges, ORAUT-OTIB-0055, Rev. 00, Oak Ridge Associated Universities, Oak Ridge, 

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ORAUT 2006b. K-25 Gaseous Diffusion Plant – Occupational Internal Dose, Revision 01PC-1, 

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Tennessee. October 5, 2006. 

ORAUT 2006d. Summary Site Profile for Brookhaven National Laboratory, ORAUT-TKBS0048, Rev. 00. Oak Ridge Associated Universities Team, Cincinnati, Ohio. August 30, 2006. 
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Health for factual accuracy or applicability within the requirements of 42 CFR 82. 

ORAUT 2007a. Summary Site Profile for Sandia National Laboratories in Livermore, 

California, ORAUT-TKBS-0053, Rev. 00. Oak Ridge Associated Universities Team, 

Cincinnati, Ohio. May 1, 2007. 

ORAUT 2007b. Site Profile for Sandia National Laboratories in Albuquerque, New Mexico, 

and the Tonopah Test Range, Nevada, ORAUT-TKBS-0037, Rev. 00. Oak Ridge Associated 

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ORAUT 2007c. Idaho National Laboratory – Occupational External Dosimetry, ORAUTTKBS-0007-6, Revision 2, Oak Ridge Associated Universities Team, Oak Ridge, Tennessee, 

June 18, 2007. 

ORAUT 2007d. Paducah Gaseous Diffusion Plant – Occupational Internal Dose, Revision 02, 

ORAUT-TKBS-0019-5, April 4, 2007. 

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November 1988. 

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Wright 1993. Wright, D.A., History of Radiation Dosimetry at SNL/CA as Remembered by D.A. 

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

ATTACHMENT 1: SUMMARY OF SITE EXPERT INTERVIEWS 

INTRODUCTION 

As a technical support contractor assisting the Advisory Board on Radiation and Worker Health 

(Advisory Board), SC&A has been tasked with reviewing NIOSH’s site profile for Sandia 

National Laboratories – Livermore, California, site. One component of SC&A’s review is a 

series of interviews with site experts, including current site workers, former site workers, and 

worker representatives. The purpose of these interviews is to obtain first-hand accounts of past 

radiological control and personnel monitoring practices in order to better understand how 

operations and safety programs were implemented at the site over time. Interviewees were 

identified through available site reports, other interviewees, and site personnel. This report 

summarizes the results of those interviews that were reviewed and accepted by the interviewees. 

SC&A representatives, Kathryn Robertson-DeMers and Robert Bistline, conducted interviews at 

SNL CA in Livermore, California, between June 8 and June 12, 2009. No Advisory Board 

members participated in these interviews. Additional SNL CA site expert interviews were 

conducted during a data retrieval effort at SNL NM, where SNL CA dosimetry records are 

stored. One interview was conducted via telephone on June 28, 2009. A total of 10 site experts 

were interviewed. 

The workers whose interviews are summarized below represent the time period from 1959 

through 2009. Their work involved all elements of weapons design, development, and testing, as 

well as energy research. One SNL CA interviewee also worked at Lawrence Livermore National 

Laboratory (LLNL) in areas relevant to the review of the SNL CA site profile. The programs 

and facilities represented by the interviewees include the following: 

 Combustion Research Laboratory 

 Division Management 

 Environmental Management 

 Energy Research and Development (Solar Energy) 

 Maintenance and Crafts 

 Radiological Operations and Dosimetry 

 Research and Exploratory Chemistry (Chemistry Division) 

 Site Historical Research 

 Strategic Defense Initiative (SDI) 

 Tritium Research Laboratory (TRL) 

 Weapons Research and Development 

 Weapons Engineering and Technical Support 

Several interviewees participated in offsite work for SNL CA at other DOE Complex and 

military sites (refer to the Offsite Radiological Activities section for details). 

SC&A explained that the interviews were being conducted on behalf of the Advisory Board as 

part of their review of NIOSH’s site profile report. Due to the potential for disclosure of 
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classified information, interviews were conducted in a secure location appropriate for classified 

discussions. Notes from these interviews were subsequently reviewed and cleared by SNL CA 

classification staff. Summaries from each interview set were prepared and provided to the 

interviewees for review. Approximately 30% of the participants did not respond to the request 

for review; the information obtained from non-responders has been withheld from this master 

summary. 

The information provided by the workers and site experts is invaluable in helping SC&A better 

understand the operations at SNL CA. This summary report is not a verbatim presentation of the 

material contained in the interview notes, nor is it a statement of SC&A findings or opinions. It 

is a consolidated summary of statements, opinions, observations, and comments that the 

interviewees communicated to SC&A. Its sole intent is to communicate to the Work Group, the 

Advisory Board, and other interested parties information acquired by SC&A during these 

interviews. Comments in brackets indicate clarifying statements made by SC&A.

Information provided by the interviewees is based entirely on their personal experience at SNL 

CA; the site experts’ recollections and statements may need to be further substantiated. 

However, they stand as critical operational feedback and reality reference checks. These 

interview summaries are provided in that context. Key issues raised by site experts are similarly 

reflected in our discussion, either directly or indirectly. Interviews from all workers who 

reviewed and approved their individual interview summaries were consolidated into a single 

summary document. The information has been categorized into topical areas related to onsite 

operations, offsite radiological activities, radiological controls and monitoring, environmental 

monitoring and waste management, occupational medical exposure, incidents and unusual 

occurrences, comments on the site profile, and miscellaneous comments. Where conflicting 

observations and statements have been received, both perspectives have been retained in this 

summary report. 

With the preceding qualifications in mind, this summary has contributed to SC&A’s 

understanding of issues raised in the site profile review report. 

SNL CA OPERATIONS 

The Livermore facility was established in March of 1956 and is still in existence today. SNL CA 

was set up to support the weapons development of LLNL. SNL CA provided and continues to 

provide support to the weapons design and development conducted at LLNL. LLNL was 

responsible for all work on the physics package; Sandia was responsible for the mechanisms that 

made it work. Sandia provided design and test support, conducted tritium research supporting 

neutron generation, and later performed solar energy and combustion research. They were also 

involved in the trajectory portion of the weapon; the electrical systems; arming, fusing, and firing 

mechanisms; warhead interfaces; GE re-entry systems; and materials research. The lab also does 

some field testing of equipment. Sandia participated in stockpile surveillance testing, where 

weapons/components are randomly removed from the field for testing (such as non-destructive 

analysis). Because of the lack of historical knowledge, former SNL CA employees have been 

asked to provide consultation services for safe dismantlement of older weapons. 
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SNL CA had its own Vice President. There were about 800–1,000 employees there at the peak. 

Information on the numbers of employees is available for some years. The division numbers 

associated with the California site are the 8000 divisions. 

Much of the work performed by SNL CA operations staff was secret. SNL CA engineers 

developed a series of components that permitted the Minuteman to go nuclear. These 

components would allow the tritium to dump into the pit during the explosion. This work was 

done in collaboration with LRL [Lawrence Radiation Laboratory]. Other work involved 

working with different components, such as valves. Collectively, interviewees worked on the 

Minuteman, the Hawk, the Lance, the 8” Artillery Shell, the Spartan, the Peacekeeper, and the 

W-89 programs. 

There were several phases in the design of a weapons system. In Phase I and II, personnel 

developed ideas for a weapon and created the design definition. Under Phase III, they developed 

prototype components and units. Phase IV starts the production of the weapons system for the 

arsenal. Not all weapons designs operated as intended and required troubleshooting. For 

example, there was an issue associated with the pit tube on the Minuteman. 

At SNL CA, they formed project teams. The team worked on all aspects of weapons design and 

component exposures; they interfaced with the military. The Level One Manager worked with 

the LLNL engineers. LLNL was responsible for development testing (Phase II) [including 

effects testing of weapons components]. A prototype of the warhead was developed, and they 

would fly the prototype to simulate actual exposure conditions. SNL CA and LLNL worked 

together; they would build the warhead, ship it up to a military base, hook it up to the missile 

portion, and ship the test unit out to the testing area. 

The Chemistry Division was involved in materials research and exploratory chemistry. The 

Solar Power Research group was involved in the Molten Salt Project. SNL CA was involved in 

the Strategic Defense Initiative (SDI), which evaluated materials for underground tests. In 

Applied Energy and Combustion Engineering, SNL CA developed techniques for remotely 

sensing materials in the atmosphere. 

Work done at the CRF [Combustion Research Facility] is a collaborative effort with the Office 

of Science. The goal is to increase combustion efficiency by cleaning up engines and furnaces. 

This is done with the use of lasers and computer modeling. Only non-ionizing radiation is used 

in this area. 

The weapons evaluation laboratory runs the non-nuclear parts through tests. There are functional 

tests of weapons, such as spins, vibration, etc. 

Metallurgists were involved in conducting diffusion studies into metals. This work was done in 

combination with the Savannah River Site (SRS). They were looking at fracture mechanics of 

the vessels. The studies were concerned with this through the stem (where the highest 

permeation occurred). There is a steady-state release after a couple of years. There is diffusion 

of some gases at the reservoir and valve. 
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OFFSITE RADIOLOGICAL ACTIVITIES 

Personnel from SNL CA and SNL NM traveled to other DOE sites frequently. Initially, Sandia 

Corporation employees worked on the LLNL site to provide support to LLNL. They conducted 

work at Site 300 and conducted some of their own testing there. There were some SNL CA 

individuals who were permanently housed out at Site 300 of LLNL and others that visited. 

SNL CA was primarily established to support the weapons development program at LLNL, and 

this remained a primary mission throughout its history. There was a lot of crossover between 

SNL CA and LLNL, especially during the weapons production process. SNL CA personnel 

would physically visit the LLNL site. The level of interaction between SNL CA and LLNL was 

dependent on the particular weapons development program. Some workers accessed Site 300 in 

the context of their support of LLNL projects. An interviewee recalled one occasion in which 

Sandia personnel observed the hydroshot testing. SNL CA helped with the build-up of the unit, 

and LLNL performed the shot. Individuals were in the bunker at the time of the shot. 

[In comparison to SNL NM], there were fewer people based at SNL CA, but they were just as 

mobile as those individuals at SNL NM. There was a lot of traveling back and forth between the 

two Sandia locations. The weapons group would also travel back and forth to other DOE sites. 

The activities also moved back and forth between SNL NM and SNL CA. For example, 

Livermore personnel would have tests run at SNL NM reactors. SNL CA employees may have 

overseen some of the testing done onsite at SNL NM at the TA-3 and Coyote Canyon facilities. 

They were also likely involved in testing done at the TTR. Individuals [from SNL CA] were 

involved in retrofits and design modifications. Travel to storage sites was primarily handled by 

SNL NM. Both Sandia facilities [SNL CA and SNL NM] were involved in the Plowshare 

project. 

SNL CA technical personnel (Design Engineers, Electronics and Monitoring personnel, Quality 

Assurance Personnel, etc.) frequently traveled to other DOE sites where there was a potential for 

radiation exposure. Other facilities visited by SNL CA workers included the Mound Plant, RFP, 

NTS, TTR, the Pantex Plant, the Y-12 Plant, the Medina Plant, the Clarksville Plant, IAAP, the 

Pinellas Plant, KCP, SRS, LANL, ANL, PNNL, and military installations. Sandia personnel also 

visited production facilities that did not handle radioactive material. Visits could last from a day 

to several months. In some situations, workers visited a site multiple times. 

Activities performed during offsite visits ranged from meeting attendance and tours to assistance 

with operational activities at the visited site. Engineers would have to transfer their knowledge 

to the production facilities, so staff involved in Phase III worked with the weapons production 

plants on a regular basis. For example, the original machining was done at SNL CA, but 

subsequent machining was performed at the production facility, where SNL CA workers would 

oversee the operation. Some SNL CA employees required entry into radiological areas at other 

sites; they performed activities associated with quality assurance testing, assembly and 

disassembly, weapons testing, and hydroshots. If DOD had issues, the SNL CA engineers may 

accompany them on a flight. 
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A Production Liaison for design and engineering at RFP was required to look at the process and 

quality assurance on the product. He visited the RFP once or twice per week; he toured 

production areas at the plant (Buildings 371, 779, 880, 881, etc.), reviewed tools, and went to the 

Plutonium Metallurgical Laboratories. They were concerned about the quality of the welds 

(morphology). He visited the Pantex Plant. He also visited Tonopah and SNL NM to test 

devices that contained uranium. 

Pantex had the responsibility for assembly and disassembly. LLNL would assemble the nuclear 

package and turn the work over to SNL CA to finish the reservoirs, timing, fusing, etc. The unit 

could be bolted or bonded together. SNL CA was also involved in the surveillance of the 

weapons, fabrication of tools, disassembly, and final certification. 

There were some underground tests at NTS to test the effectiveness of the components. 

Vulnerability and hardening testing was a big deal. Effects testing of weapons’ components was 

performed. The weapon would explode, and the radiation would travel down to chambers where 

equipment was housed. The equipment was exposed to large amounts of radiation to see how it 

would handle the radiation. The horizontal tunnels had doors that sealed to prevent the radiation 

from escaping the line of sight pipes. SNL CA was not responsible for re-entries, but the 

equipment was recovered, and SNL CA would get the disassembled test equipment for 

evaluation. SNL CA was involved with Hudson Moon and Hudson Seal. 

SNL CA workers provided oversight for the beryllium and copper valves work at the Kansas 

City Plant (KCP). Sandia personnel were also sent to Mound to oversee work with reservoirs. 

There was no neutron generator work conducted in California; New Mexico was involved with 

this. 

JTAs [Joint Test Assemblies] are compiled by the military to make sure the interface still works. 

When JTAs are flown on a test missile, SNL CA makes sure the data is collected. The test 

squadron is responsible for dropping bombs at TTR. SNL CA recovers the units, and they are 

sent to Pantex for disassembly and evaluation. 

One interviewee indicated that he “traveled all over the place.” This individual was involved in 

quality assurance testing at the NTS and later did testing on the 8” Artillery Shell at the TTR. 

The interviewee visited Pantex several times and was involved in the assembly of the Minuteman 

and the 8” Artillery Shell. During his time at Pantex, the SNL CA worker did make entries into 

the igloos. The interviewee spent time at [LLNL] Site 300, where there was plutonium. He 

visited other sites, including the Y-12 Plant in Oak Ridge and Medina. He also went to other 

production facilities that did not handle radioactive material. 

[Other personnel, in addition to the weapon teams, also travelled offsite.] A RadCon worker 

visited Pantex and made some trips to SNL NM. He was sent there to oversee the work they 

were doing and find ways to reduce dose if possible. At Pantex, this included entry into the 

cells. 
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RADIOLOGICAL CONTROL 

There has always been a safety organization at SNL CA. Initially, health physics work was 

primarily conducted by a single individual. There was also an industrial hygienist, a Fire 

Marshall, and a couple of sample engineers. As time progressed, health physicists oversaw the 

operations, surveys, counting laboratory, bioassay, dose assessments, instrument calibration, 

source checks and other activities at facilities. [Specific responsibilities were delegated to the 

Radiation Protection staff.] Currently, the Health and Safety organization is imbedded into the 

line management. 

One interviewee stated that he was responsible for radiological control at the TRL; two 

additional technicians covered the remainder of the site. Technicians were responsible for dayto-day radiological controls, including routine radiological surveillances. Technicians at TRL 

were also involved in the analysis of tritium bioassay samples. One interviewee recalls being 

escorted by radiological control staff when he went to TTR to take specimens. 

When TRL was discontinued, the former TRL RadCon staff got involved in various RadCon 

projects and work planning for the site as a whole. Interviewees noted that additional RadCon 

personnel were hired as a result of the SNL CA Tiger Team assessment (DOE 1990). 

Characterization of Source Term 

Most of the exposure at SNL CA was from chemicals and heavy metals with some work 

involving uranium and beryllium. Uranium was primarily considered a chemical hazard. The 

mock-ups handled by Sandia personnel contained DU and potentially thorium. 

The radioactive materials and devices used at SNL CA varied by program and location. In 

Building 913, they handled classified units, with some units undergoing modifications or 

retrofits. Depleted uranium (DU) and tritium components were changed. In Building 927, they 

have handled Co-60 and Cs-137 radiography sources. Historically, there have been some AmBe 

sources handled onsite. There was an AmBe source in Building 961 and a Cf-252 source in 

Building 941. Thorium was used as check sources for radiation detection instruments. 

In Building 941, there are x-ray devices. Some interviewees worked with sealed sources, such as 

x-ray diffraction units. 

SNL radiological activities included radiography, radiation generating devices (e.g., x-ray 

diffraction), and TRL. The major radionuclides of concern onsite were DU and tritium. SNL 

CA did not handle fissile material. Most of the potential radiological exposure occurred offsite. 

The [weapon] design process does not involve radioactive material, but the testing phase 

involves radiation. There were test cells in Building 983. They used radiography sources to 

check prototype components and do calibrations. There were some radiation hardening studies 

done at SNL CA and SNL NM. 

The SDI [Strategic Defense Initiative] program by Ronald Reagan (aka the Star Wars Program) 

did not require the use of radioactive material. 
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Most of the exposure at SNL CA was from chemicals and heavy metals, with some work 

involving uranium and beryllium. Uranium was primarily considered a chemical hazard. There 

was some machining of DU and beryllium in Building 913 in the 1950s and 1960s. 

Other unsealed radioactive sources handled at SNL CA included some thorium oxide powder, 

trace quantities of natural uranium, trace quantities of low-enrichment uranium (gram values), 

and radioactive solutions for making standards. There were small research quantities of enriched 

uranium and plutonium handled onsite. Some Kr-85 was in storage for a period of time; the 

interviewees did not know how it was used. 

SNL CA worked with tritides from time to time. As a result, SNL CA RadCon staff sat on the 

Stable Tritium Compound Working Group (Tritium F-cog) for a while. Primarily, SNL CA 

worked with protium and deuterium, then passed the tritide work to Mound and SRS. 

External Monitoring 

At one point in history, everyone onsite was monitored for external exposure. In the earlier days, 

more individuals were monitored than probably needed to be. Positive exposures did/do not 

occur often. Over time, the monitoring was reduced to those working with radioactive sources. 

During this period, the first-line managers determined who was monitored for external exposure. 

Those individuals that are likely to receive 100 mrem in a year are/were monitored. Neutron 

dosimetry was a component of the routine dosimeter. 

Dosimeters were stored onsite. Most individuals complied with this requirement and did not 

take them offsite. You were not supposed to take your dosimeter with you to other facilities. 

When Sandia personnel visited other DOE sites, the [destination] site was responsible for 

providing internal and external monitoring. For example, if they went to Pantex or NTS, Pantex 

and NTS were responsible for providing the monitoring. When workers visited other sites, they 

were sometimes assigned a dosimeter (i.e., film badge or TLD) by the visited site. For example, 

RFP and Pantex Plant assigned dosimeters to SNL CA workers. Any dosimetry reports from 

workers visiting other sites would be sent to SNL NM and not to SNL CA. Some interviewees 

do not recall being told to request monitoring at a visited site, or to request that internal and 

external monitoring results be provided to SNL CA. 

When Sandia personnel went to DOD facilities, they wore the Sandia dosimeter plus a dosimeter 

provided by the DOD facility. 

Internal Dosimetry 

Internal monitoring is job-dependent and based on the potential for airborne radioactivity. Preand post-job samples are collected. Post-job bioassay is collected immediately after the end of 

the job. 

Tritium bioassay sample analysis was conducted at the TRL facility by RadCon staff during the 

operating phase of the facility; RadCon workers were sampled [as well as operations workers]. 
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The routine bioassay program for TRL required collection of at least weekly bioassay samples. 

These were sometimes more frequent for special projects. The bioassay sample analyses for 

tritium were completed onsite at SNL CA via liquid scintillation counting. SNL CA was also 

responsible for tritium dose assessment. Records for laboratory analysis and dose assessment 

were transferred to SNL NM. 

Uranium urinalysis was completed for limited operations areas at SNL CA. A RadCon worker 

has submitted about one uranium bioassay in the past 10 years. Depleted uranium beds used at 

TRL were confined in vessels, so there was no need for routine bioassay sampling. Uranium 

urinalysis samples were shipped to SNL NM. 

There is really not much dose received anymore at this site. When the interviewee first arrived, 

they were using more radioactive material, particularly tritium. 

Workers were not sent over to LLNL for any type of internal monitoring. 

The only offsite internal monitoring interviewees reported was receipt of a whole-body count at 

Pantex. At the time, Sandia personnel were working in the cells with the warheads and in 

machining areas. There was also pre- and post-job bioassay sampling [for this project]. At NTS, 

one interviewee was only assigned a dosimeter without any internal monitoring.

Radiological Surveillance and Contamination Control 

The machining operation was enclosed and performed as a wet operation. They conducted air 

sampling during machining operations. There were routine surveys around the equipment to 

look for chips and fines. There was some contamination with DU and tritium at times. Depleted 

uranium would get into the nooks and crannies of the machines. This was a pretty sloppy 

operation until the Tiger Team came in. This resulted in improvements to the process. 

Air sampling at the TRL included fixed and portable air sampling equipment to monitor the 

room air. These were Overhoff air monitors. In addition, there was air flow and hood airflow 

testing in at TRL. Occasionally, when people were working around high levels of tritium, 

technicians monitored their sweat for tritium activity. 

Tritide operations were conducted in gloveboxes. An interviewee indicated there was no 

potential for exposure as a result [of these controls]. Other interviewees noted that tritium (gas 

and water) eventually permeates through the rubber gloves, seals, gloveboxes, etc. As a result, 

there was tritium contamination in accessible areas. 

During the decontamination, decommissioning, and reuse project at TRL, everything was 

checked per a plan developed for this work. On rare occasions, they would have contamination 

outside the gloveboxes. The facility was so clean that workers were not even required [to wear] 

shoe covers or lab coats in most cases. During the D&D of TRL, the contaminated pump oils 

were the most challenging issue to deal with. 
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Surveys were conducted on the medical x-ray unit until the mid-to-late 1990s, when SNL CA got 

rid of the unit. These surveys were done on an annual or semi-annual basis. In addition, 

RadCon surveyed any industrial unit that generated x-rays or radiation. These were surveyed for 

leakage. A copy of the unit survey was sent to the owner of the x-ray unit. TLDs were used to 

check the pulse x-ray equipment. RadCon technical staff indicated that they had not identified 

appreciable contamination around radiation-generating devices or from leaking sources. 

There was a period of time at SNL CA when individuals were allowed to smoke everywhere. 

This occurred mainly in offices adjacent to a lab, but in the same air space. However, personnel 

were not allowed to smoke in explosive handling and storage areas. 

ENVIRONMENTAL MONITORING AND WASTE MANAGEMENT 

In the earliest days, the overall environmental group was a part of a single department, 

Environmental Safety and Health. The environmental staff now works under both the 

Environmental Management and Environmental Operations departments. At an interim point in 

time, environmental monitoring was a part of Hazards Control. 

Prior to the startup of TRL, SNL CA relied on LLNL for their environmental monitoring except 

for stack monitoring. LLNL also performed soil and vegetation sampling for SNL CA. LLNL 

was responsible for conducting environmental monitoring at Site 300. An interviewee indicated 

that LLNL site boundary samples would not be representative of activity at Site 300, because 

Site 300 was located 15 miles from the LLNL main facility. 

There were five TLD monitoring locations onsite for measurement of ambient external dose 

located within the perimeter of the site. These date back to at least 1991. The TLD sites at SNL 

CA are separate from the LLNL results. LLNL results are used as a source of comparison. A 

background dosimeter is maintained in a pig in the laboratory. 

Historically, most of the environmental monitoring at SNL CA consisted of monitoring for 

tritium at the TRL stack. The site used to have dosimeters and bubblers for tritium around the 

site for conducting environmental monitoring. Air and water samples for tritium are available 

for TRL back thru 1979. The sampling was specific for tritium. Samplers used a pump and 

silica gel as an absorber. The material was collected every 2 weeks and was analyzed through a 

distillation process. No particulate air sampling was conducted. There was also an ambient air 

tritium sampling network starting in the early 1990s and continuing until the shutdown of TRL. 

There were a couple of soil and sediment sampling locations on the SNL CA site. SNL CA has 

environmental data for air, groundwater, storm water, and the sanitary sewer system. 

The counting laboratory at SNL CA performed analyses on environmental samples, such as 

water, ambient air, and stack samples. There were other types of samples analyzed also. The 

groundwater and storm water samples are analyzed for tritium via liquid scintillation counting. 

Annual environmental reports for SNL CA date back to the 1970s. Routine and incidental 

releases are included in the annual reports. Environmental releases occurred from TRL through 
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time and are chronicled in various reports. There were some episodic releases up-stack from 

tritium labs when upset conditions occurred, such as a burp. Although there was uranium 

machining, release of uranium was not a concern, because this operation was contained at the 

source. 

Interviewees were not aware of any substantial radiation spills to the environment. No outside 

radiation contamination areas are known. There were no issues with animals contaminated 

onsite. There were not that many sources of radiological material on the SNL CA site. The State 

of California does not do routine environmental monitoring at the site. They conducted some 

background sampling, and for a year or two, there was some dual sampling. 

San Francisco Water Company provided drinking water; it was totally separate from any of the 

process water systems. 

There is no radioactive waste burial onsite. The low-level waste from SNL CA was shipped to 

NTS. Other waste was sent to SNL NM. There was a Navy landfill where construction debris 

from the Navy and early LLNL were buried, but this did not involve radioactive or chemical 

waste. The paint yard inherited from the Navy had to undergo cleanup. 

There was no incineration of waste at SNL CA. Uranium welding and machining was performed 

at SNL CA, but intentional burning of uranium chips or turnings, or any other material (except 

classified documents) did not occur at the site. 

OCCUPATIONAL MEDICAL EXPOSURE 

There was a requirement for an annual exam for personnel in the Field Testing Group and the 

Accident Response Group (ARG). There were chest x-rays every couple of years. Chest x-rays 

included a posterior-anterior shot. The frequency of x-rays has changed over time. 

Building 911 (Medical) used to have their own x-ray machine. After SNL CA got rid of the 

medical unit [mid- to late-1990s], they sent workers over to LLNL or to a regular community 

medical clinic. More recently employed interviewees recall having physical exams onsite, but 

they do not recall receiving x-rays as a part of the exam. 

SANDIA RECORDS 

SNL CA maintains their Environmental Safety and Health records, project and program records, 

and technical reports. Sandia testing records could be located at both SNL CA and SNL NM. 

Photographs have been sent to SNL NM. The facilities office has the building drawings. 

Specifics on the material used and everything about the weapons programs would be classified. 

Sandia Corporation produced annual reports, which are classified and available through the 

corporate archives. Building files would likely list spills that occurred. In the annual budget 

reports, the SNL CA budget was separate. 

Radiological records presently stored at SNL CA consist of surveys, source leak checks, 

Radiation Generating Device checks, etc. 
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Scientists and engineers were and continue to be encouraged to publish in journals. There are 

also period progress reports issued (i.e., quarterly, monthly, annually) and annual operating 

plans. These reports offer some detail on what was occurring onsite at a particular time and 

facility. There isn’t a historical summary document discussing the health physics program at 

SNL CA. 

One current employee reviewed his radiation exposure record and thinks information from 

[offsite] visits were reflected in his record. 

INCIDENTS AND UNUSUAL INCIDENTS 

[The incidents described by interviewees included both onsite and offsite incidents.] 

Around 1965–1970, one interviewee was visiting the Mound Plant, working in radiological areas 

at one of the facilities. There was a valve hooked up so the tritium could be dumped into a Bell 

jar. The pressure in the Bell jar was too high and the lid lifted off the jar, dumping the tritium 

gas to the air. This contaminated the entire room and the personnel involved. All the alarms in 

the building went off, and the entire building had to be evacuated. There was also concern about 

release to the environment. There were 2–3 Mound people in the clean room. The interviewee 

was outside reaching into the area where the Bell jar could be handled. The individual recalls 

being required to shower and was told to go home and drink lots of liquids. The interviewee did 

not recall being asked for a urine sample at Mound; however, when he returned to SNL CA the 

next day, Medical conducted testing on his urine daily for 5 days. 

About a year after the Minuteman warheads were sent to the silos, one interviewee was involved 

in an incident at RFP. Personnel were testing a new aluminum wire that had been affected by the 

plutonium. This was done by pulling the wire to test the valve. Because the wire was 

contaminated, involved personnel were required to strip down, shower, and be monitored. 

Bioassay samples were taken, but lung counts were not done. RFP indicated that they lost this 

interviewee’s badge. 

There was a tritium uptake at TRL while they were disassembling a component; the tritium had 

adsorbed on the outside of the vessel. This incident was documented in an investigation report. 

An interviewee received approximately 0.5 Rem; the highest individual exposure from this 

incident was 1.5 Rem.

 

NIOSH DOSE RECONSTRUCTION/SITE PROFILE COMMENTS 

Some individuals expressed concern that the dose reconstruction paperwork returned to 

claimants is too complicated, and that it could not be understood. The dose reconstruction report 

does not contain enough information in the assessment to answer many questions. Concern was 

raised about the assumption that the sources at SNL CA were leaking sources. 

NIOSH/ORAUT conducted two visits to SNL CA [as of June 2009]. One interviewee indicated 

that he was interviewed by NIOSH during their visit. 
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NOTICE:

MISCELLANEOUS 

 Illnesses identified as occurring among SNL CA workers include bladder cancer. 

 Valley Fever was the biggest safety concern at the 300 Site [at LLNL]. Spores would 

cause lung infections. 

 SNL used standard wording rather than code words. The only code word the interviewee 

was aware of was tuballoy. 

 There was a release from LLNL in the 1980s. 

REFERENCES RECOMMENDED BY INTERVIEWEES 

(1) SAND97-8004-UC-402, Characterization, Minimization, and Disposal of Radioactive, 

Hazardous, and Mixed Waste. 

(2) SAND96-8004-UC-407, August 1996 – Related to environmental release. 

(3) SAND95-8216-UC-402, Radiological Characterization Plan for the TRL, SNL/CA 

(4) SAND-2001-3742P, The Combustion Research Facility: Model for a 21st Century Open 

User Facility, Carlisle, R.P., Monetta, D.J., and Sparks, W.L. 

Interviewees also recommended review of the facilities collection on buildings, Safety Material 

Handling and Movement inventories, and Environmental Restoration reports.