SEC Petition Evaluation Report

Petition SEC-00188, Addendum 2 (1997-2011) 

Report Rev Number: Addendum 2 (1997-2011)

Report Submittal Date: April 1, 2019

Subject Expert(s): Tim Adler, Joe Guido

Site Expert(s): N/A

Petition Administrative Summary

Petition Under Evaluation

Petition Number: SEC-00188 Addendum 2 (1997-2011)

Petition Type: 83.13

Petition Receipt Date: July 18, 2011

Qualification Date: October 21, 2011

DOE/AWE Facility Name: Sandia National Laboratories

Petition Class

Class Evaluated by NIOSH: All personnel that worked in any area at Sandia National Laboratories in 

Albuquerque, New Mexico, for the period from January 1, 1997 through May 21, 

2011.

NIOSH-Proposed Class(es) to be 

Added to the SEC:

None

Related Petition Summary Information

SEC Petition Tracking Number(s): SEC-00162 and SEC-00188

Petition Type(s): 83.13

DOE/AWE Facility Name: Sandia National Laboratories

Petition Status: SEC-00162: Class added to the SEC for Jan. 1, 1949 through Dec. 31, 1962

SEC-00188: Class added to the SEC for Jan. 1, 1963 through Dec. 31, 1994 

SEC-00188 Addendum (1995-1996): Class added to the SEC for Jan. 1, 1995 

through Dec. 31, 1996

Related Evaluation Report Information 

Report Title: SEC Petition Evaluation Report Petition SEC-00162

SEC Petition Evaluation Report Petition SEC-00188 

SEC Petition Evaluation Report Petition SEC-00188 Addendum (1995-1996) 

DOE/AWE Facility Name: Sandia National Laboratories

ORAU Preparation and Review

ORAU Lead Technical Evaluator: Tim Adler

ORAU Peer Review Completed By: Daniel Stempfley
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DCAS Review and Approval

Peer Review Completed By:

[Signature on File]

Charles Nelson 

April 1, 2019 

SEC Petition Evaluation Reviewed 

By: [Signature on File]

James W. Neton

April 1, 2019

SEC Petition Evaluation Approved

By: [Signature on File]

Stuart L. Hinnefeld 

April 1, 2019
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Addendum 2 (1997-2011) to Sandia National Laboratories-Albuquerque 

(SEC-00188) Special Exposure Cohort Evaluation Report

Purpose and Scope of this Addendum 2 (1997-2011) 

This Addendum 2 provides results from continued site and program assessments at Sandia National 

Laboratories in Albuquerque, New Mexico (SNL-A), that were previously unevaluated in the SEC 

Petition Evaluation Report for petition SEC-00188, covering 1963-1994 (NIOSH, 2012) and in an 

Addendum to that report, covering 1995-1996 (NIOSH, 2018). In these two evaluations, NIOSH 

defined classes of employees for which NIOSH cannot estimate radiation doses with sufficient 

accuracy. These previously-identified classes (combined) include all employees of the Department of 

Energy, its predecessor agencies, and their contractors and subcontractors who worked at Sandia 

National Laboratories in Albuquerque, New Mexico, from January 1, 1963 through December 31, 

1996.

In the original SEC-00188 Evaluation Report, NIOSH established December 31, 1994 as the SEC 

class end date after considering data-retrieval problems known to exist into the very early 1990s, 

limited internal monitoring results, limited program documentation availability, the existence of a 

relatively-undeveloped internal monitoring record database during that period, and the use of Controls 

for Environmental Pollution (CEP) analytical services for bioassay well into 19941

. 

1 Beginning in 1992, the Santa Fe company Controls for Environmental Pollution (CEP) was contracted to provide part of 

SNL-A’s bioassay analytical services. CEP tested approximately 500 employee urine samples for SNL-A between 1992 

and 1994. SNL-A officials stopped using CEP’s services in 1994 because quality control testing raised questions about the 

reliability of CEP’s reports. It is NIOSH’s policy that all data provided by CEP are unacceptable for EEOICPA dose 

reconstruction use.

In the SEC-00188 Addendum (1995-1996), NIOSH extended the existing class to December 31, 1996 

due to concerns with air monitoring data availability and uncertainties associated with the transitional 

and developmental nature of SNL-A’s internal monitoring program. During 1996, significant changes 

to the internal dose monitoring program took place, including a requirement for internal dosimetry 

review and assignment of DAC-hrs, and a requirement to forward DAC-hr records to Internal 

Dosimetry if DAC fractions exceeded 0.1 DAC. Philosophical changes in the internal dosimetry 

program also took place in 1996, which included a change of emphasis from internal dosimetry to 

internal radiation protection, and reliance on other types of monitoring to indicate the need for 

bioassay. 

This Addendum 2 presents conclusions from NIOSH’s continued evaluation of SNL-A dose 

reconstruction feasibility for the remaining SEC-00188 petitioner-requested timeframe (January 1, 

1997 through May 21, 2011). 

 
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Evaluation Report Summary: SEC-00188 Addendum 2 (1997-2011)

Class Evaluated by NIOSH (in this Addendum 2)

All personnel that worked in any area at Sandia National Laboratories in Albuquerque, New Mexico, 

for the period from January 1, 1997 through May 21, 2011.

NIOSH Determination about the Proposed Class to be Added to the SEC (in this Addendum 2)

NIOSH has obtained information regarding post–1996 occupational monitoring as well as program 

policies and procedures related to implementation of 10 C.F.R. pt. 835. Based on its analysis of these 

available resources, NIOSH found no part of the class under evaluation for which it cannot estimate 

radiation doses with sufficient accuracy.

Feasibility of Dose Reconstruction

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

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

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

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

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

to estimate the maximum internal and external potential exposure to members of the evaluated class 

under plausible circumstances during the specified period.

The NIOSH dose reconstruction feasibility findings are based on the following:

• As previously identified in the SEC-00188 Evaluation Report, NIOSH finds that it is feasible to 

reconstruct occupational medical dose for Sandia National Laboratories-Albuquerque employees

with sufficient accuracy.

• As previously identified in the SEC-00188 Evaluation Report, principal sources of internal 

radiation for members of the proposed class included exposures to plutonium, tritium, uranium, 

americium, and fission and activation products. Potential exposure pathways could have involved 

the handling of these radionuclides during waste-burial operations or exposure to surface or air 

contamination associated with reactors and/or accelerators work. Considering the potential 

exposure scenarios, program policies, procedures, and monitoring data availability, NIOSH finds 

it is able to estimate these internal exposures with sufficient accuracy for the period from January 

1, 1997 through May 21, 2011.

• As previously identified in the SEC-00188 Evaluation Report, principal sources of external 

radiation for members of the proposed class included exposures to beta, gamma, and neutron 

radiation. NIOSH finds that it is feasible to reconstruct all occupational external dose for Sandia 

National Laboratories-Albuquerque workers with sufficient accuracy for the entire evaluated 

period.
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• Pursuant to 42 C.F.R. § 83.13(c) (1), NIOSH determined that there is sufficient information to 

either: (1) estimate the maximum radiation dose for every type of cancer for which radiation doses 

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

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

maximum dose estimate.

Health Endangerment Determination

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

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

the evaluated class.
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Revised Excerpts of the SEC Petition Evaluation Report for SEC-00188

NOTE: FROM THIS POINT FORWARD, THIS SEC-00188 ADDENDUM 2 ONLY ADDRESSES 

THOSE SECTIONS IN THE SEC-00188 SANDIA NATIONAL LABORATORIES SEC PETITION 

EVALUATION REPORT THAT REQUIRE DISCUSSION REGARDING THE 1997-2011

PERIOD. THEREFORE, THE SECTION NUMBERING IS NOT CONTIGUOUS. WHEN 

DEEMED HELPFUL TO THE READER, ADDITIONAL ER TEXT IS SOMETIMES INCLUDED 

FOR CONTEXT.

3.2 Class Evaluated by NIOSH

This Addendum 2 presents conclusions from NIOSH’s continued evaluation of SNL-A dose 

reconstruction feasibility for the remaining SEC-00188 petitioner-requested timeframe (January 1, 

1997 through May 21, 2011).

3.3 NIOSH Determination about the Proposed Class to be Added to the SEC

NIOSH has obtained information regarding post-1996 occupational monitoring as well as program 

policies and procedures related to implementation of SNL-A’s radiation protection program. Based 

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

which it cannot estimate radiation doses with sufficient accuracy.

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class

As is standard practice, NIOSH completed extensive database and Internet searches for information 

regarding SNL-A. The database searches included the DOE Legacy Management Considered Sites 

database, the DOE Office of Scientific and Technical Information (OSTI) SciTech Connect database, 

the Defense Technical Information Center, and the Hanford Declassified Document Retrieval System. 

In addition to general Internet searches, the NIOSH Internet search included OSTI OpenNet Advanced 

searches, Nuclear Regulatory Commission (NRC) Agency-wide Documents Access and Management 

(ADAMS) web searches, and a DOE-National Nuclear Security Administration-Nevada Site Officesearch. Attachment Three includes a summary of SNL-A documents. The summary includes data 

capture details and general descriptions of the documents retrieved.

In addition to the database and Internet searches listed above, NIOSH reviewed numerous other data 

sources to obtain information relevant to determining the feasibility of dose reconstruction for the 

class of employees under evaluation. This focused primarily on determining the availability of 

information on personal monitoring, area monitoring, industrial processes, and radiation source 

materials. This effort included three new official data capture requests submitted to SNL since the 

July 2018 issuance of Petition SEC-00188, Addendum (1995-1996). The first request (July 2018) 

pursued various clarifications regarding the site’s “WebDose” monitoring data database (WebDose is 

a database used by SNL-A for bioassay monitoring record retention and as a radiation dose reporting 

tool). The second request (January 2019) further explored air monitoring data availability. The third 

request (also January 2019) focused on retrieval of radiological records for some interviewed SNL 

employees.
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4.3 Facility Employees and Experts

Prior to this Addendum 2, twenty interviews were conducted with sixteen SNL personnel in support 

of the post-1994 evaluation work (some personnel were interviewed more than once). Workers 

interviewed included [job category redacted] staff members, a [program name redacted] manager, 

[function name redacted] department managers, security officers, an [job title redacted], a [function 

name redacted] manager, and a researcher (Personal Communication, 2013a-b; 2014a-m; 2017a-d; 

2018a). That work culminated in the first ER Addendum and also provided insights for this current 

effort. 

For Addendum 2, the following additional interview was conducted regarding monitoring for SNL’s 

security force employees per the employees’ request. A summary of this discussion is provided in 

Section 7.4 

• Personal Communication, 2018b, Personal Communication with Sandia National Laboratories 

Current or Former Employees; Telephone interview by NIOSH and ORAU Team; December 20, 

2018; SRDB Ref ID: 175475. 

4.4 Previous Dose Reconstructions

NIOSH reviewed its NIOSH DCAS Claims Tracking System (referred to as NOCTS) to locate

EEOICPA-related dose reconstructions that might provide information relevant to the period from 

January 1, 1997 through May 21, 2011. Table 4-1 summarizes the results of this review. (NOCTS 

data available as of January 7, 2019.) 

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

Description Totals

Total number of claims submitted for dose reconstruction 747

Total number of claims submitted for energy employees who worked during the period under 

evaluation (January 1, 1997 through May 21, 2011) 275

Total number of claims submitted for energy employees who started their employment during the 

period under evaluation (January 1, 1997 through May 21, 2011) 67

Number of dose reconstructions completed for energy employees who worked during the period

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

Department of Labor for final approval).

233

Number of claims for which internal dosimetry records were obtained for the time period in the 

evaluated class definition 11

Number of claims for which external dosimetry records were obtained for the time period in the 

evaluated class definition 120

NIOSH reviewed each claim that fell within the time period under evaluation to determine whether 

internal and/or external personal monitoring records could be obtained for the employee. As indicated 

in Table 4-1, of the total number of claims submitted for energy employees who worked within the 

period from January 1, 1997 through May 21, 2011, 11 (4%) contain internal monitoring data and 120 

(44%) contain external monitoring data. 
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4.5 NIOSH Site Research Database

NIOSH also examined its Site Research Database (SRDB) to locate documents captured from the site 

supporting the assessment of the evaluated class. Over 5,500 documents in this database are identified 

as pertaining to Sandia National Laboratories in Albuquerque, New Mexico. Since the initial SEC 

Petition Evaluation Report for Petition SEC-00188 (February 21, 2012), more than 900 documents 

have been added to the SRDB; these documents were reviewed and evaluated for their relevance to 

this Addendum.

The focus of the post-1994 data capture efforts for SNL-A includes the following:

• Internal SNL-A procedures

• Facilities and process information

• Incident reports

• 10 C.F.R. pt. 835 compliance and self-assessment reports/memos

• Internally and externally-conducted Radiation Program audits and assessments

• Air monitoring records (breathing zone and general area)

• Internal and external monitoring records

• Radiation Worker Permits (RWPs) and Radiation Work Orders (RWOs)

• Specific word/radionuclide information searches

4.6 Other Technical Sources

NIOSH also investigated the following databases in an effort to assess available internal monitoring 

data, and compliance with 10 C.F.R. pt. 835 requirements:

• Extracts from SNL-A’s “WebDose” database, which the site uses for bioassay monitoring record 

retention and as a reporting tool

• SNL-A databases and reports containing breathing zone and Derived Air Concentration (DAC)-

hour tracking results

• The DOE Noncompliance Tracking System (NTS): This database was reviewed for 10 C.F.R. pt. 

835 violations, site responses, and corrective actions. Out of a total of 171 documents listed, 72 

were deemed potentially relevant, captured in full, and loaded into the SRDB for review.

• The DOE Occurrence Reporting System (ORPS): This database was also reviewed for 10 C.F.R. 

pt. 835 violations, site responses, and corrective actions. Out of a total of 1,498 documents listed, 

194 were deemed potentially relevant, captured in full, and loaded into the SRDB for review.
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5.1 SNL Plant and Process Descriptions

Descriptions of radiological operations and source terms relevant to the 1997-2011 evaluation can be 

found in Section 5.1 of the original SEC Petition Evaluation Report for Petition SEC-00188 (NIOSH, 

2012). The 2012 Evaluation Report provides considerable scope and detail of SNL’s potential 

exposure areas, processes, and source terms. NIOSH is nevertheless providing some additional 

process details in the subsections below regarding four areas considered to represent SNL’s higher 

internal exposure potential concerns. These areas are the Radiological and Mixed Waste Management 

Facility (RMWMF), Annular Core Research Reactor (ACRR), Hot Cell Facility, and the Sandia Pulse 

Reactor (SPR). Notably, discussions with the SEC-00188 petitioner as well as other members of the 

Security Force revealed concerns with work they performed in the SPR area.

Radiological and Mixed Waste Management Facility (RMWMF)

From 1957 to 1988, low-level radioactive waste (LLW) and mixed waste (MW) generated by various 

programs at SNL-A were disposed of at the Mixed Waste Landfill (MWL) disposal site, located in 

Technical Area III at SNL-A. Beginning in 1988, this facility was no longer available to accept LLW 

or MW due to DOE requirements prohibiting further disposal. As a result, SNL-A needed a wastehandling facility.

Construction of the Radioactive and Mixed Waste Management Facility (RMWMF) began in 1989 

and was completed in 1995 (ORAUT-TKBS-0037, PDF p. 40). The RMWMF serves as a centralized 

facility for receipt, characterization, compaction, treatment (if necessary), repackaging, certification, 

and storage of LLW, MW, and TRU (transuranic waste). The RMWMF is also used for extended 

storage until disposal and/or treatment sites are identified that can accept these materials. The facility 

enables SNL-A to handle and store the waste in compliance with applicable federal, state, and local 

environmental regulations, DOE Orders, and offsite waste acceptance criteria. In addition, the facility 

allows SNL-A to prepare the waste for shipment for treatment and disposal in accordance with 

specific requirements regarding waste certification, packaging, and transport (RMWMF, 1998a).

The RMWMF Compound, located in the southeastern portion of Technical Area III, consists of the 

following:

• Building 6920 (Waste Management Facility)

• Building 6921 (Waste Assay Facility)

• Building 6925 (Waste Storage Facility)

• Prefabricated skid-mounted storage building for reactive waste

• Prefabricated skid-mounted storage building for flammable waste

• Prefabricated building for compressed gas cylinder storage

• Paved outdoor LLW and MW storage area

• Unpaved (gravel) outdoor LLW storage area

• Lined retention pond designed to hold site surface-water run-off, sprinkler discharge from a design 

fire, and fire-hose streams

• Office trailers
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• Building 6920 is designed to manage classified and unclassified waste. Waste processing in 

Buildings 6920 may include unpacking, sorting, repackaging, sampling, storing, staging, 

treatment, and preparing waste for offsite shipment to a permitted disposal site. Treatment may 

include dewatering, separation of select explosive devices, neutralization, solidification, 

stabilization, amalgamation, cutting, decontamination, and compacting.

Waste-processing operations in the Waste Assay Facility (Building 6921) are limited to 

characterization work conducted in the Counting Room. Personnel in Building 6921 evaluate 

samples, swipes, filters, and similar items collected during facility activities. The Assay Bay houses 

the radioassay equipment for characterizing waste packages. No more than two pallets or eight 55-

gallon waste drums are permitted at any one time in Building 6921.

Building 6925 is the primary waste storage facility at the site. Waste is also stored in Building 6920, 

in the skid-mounted waste-storage sheds, and in “transportainers” on the paved and unpaved outdoor 

storage areas of the RMWMF site. The maximum storage capacity at the MWMF Compound is 

approximately 285,000 cubic feet (8,000,000 liters) (RMWMF, 1998a).

Annular Core Research Reactor (ACCR)

Located in Area V, the Annular Core Research Reactor (ACRR) pool-type reactor is a 2-MW reactor 

that can be operated in either a pulse or steady-state mode. The reactor uses cylindrical BeO-UO2 fuel 

elements arranged in a close-packed lattice. The facility provides a large central irradiation cavity (23 

cm diameter), a neutron radiography facility, and two large interchangeable fuel-ringed external 

cavities known as FREC I & II (38 and 51 cm diameter). The annular-shaped core is formed by single 

fuel elements with their longitudinal axes vertical, arranged in a hexagonal grid around the central 

cavity. The complete core assembly consists of the fuel elements, six fuel-followed control rods, two 

fuel-followed safety rods, and three void-followed transient rods. Depending on experimental 

requirements, the typical number of fuel elements varies between 200-250 (HCF, 1995, PDF p.18). 

The ACRR has been in operation since 1978 for defense radiation effects and other advanced nuclear 

technology experiment programs (SNL, 1998, PDF p. 444). The primary purpose for the ACCR

during this evaluation period (1997-2011) was the production of medical isotopes such as Mo-99, 

whose daughter Tc-99m is used in nuclear medicine applications (Mo-99, 1998) 

Sandia Pulse Reactor Facility (SPRF)

The Sandia Pulsed Reactor Facility (SPRF), which is also located in Area V, was built to supplement 

the Sandia Engineering Reactor Facility (SERF) in support of the radiation-effects testing program. 

Three reactors were used over the history of SPRF: SPR-I, SPR-II, and SPR-III. The reactors 

provided unique near-fission spectrum radiation environments for testing a wide variety of 

technologies that supported both defense and non-defense activities. The primary mission of the 

facility was to produce high-neutron fluence or pulsed high-neutron doses for the testing of electronic 

subsystems and components. Critical experiments were conducted in the facility to support other 

programs (SNL, 1998). The facility consisted of a heavily-shielded reactor building, a control room 

building, an instrumentation building, a beam-catcher building, and several vaults for the storage of 

the reactor and fissionable and radioactive materials. SPRF was located in TA-V, four miles due 

south of TA-I, the major installation of SNL-A (SPRF, 1961).
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The first reactor, SPR-I, operated from 1961 until 1967 (HP Log, 1961-1962; HP Log, 1966-1967). 

Other than the potential for residual contamination and activation products, SPR-I is not relevant to 

this evaluation.

SPR-II operated from 1967 to 1978 as the sole SNL fast-burst reactor (FBR). In August 1978, SPRIII became the primary SNL FBR for irradiation service; however, infrequent operation of SPR-II 

continued until 1995 (SAR, 1995, PDF p. 9). The SPR-II reactor was a fast-pulse (or fast-burst) 

reactor with a bare, unreflected, and unmoderated cylindrical assembly of 93 percent enriched U-235 

with 10 weight-percent molybdenum (U-10 Mo) (SNL, 1998). As with SPR-1, the SPR-II reactor is 

only relevant to this evaluation as a potential source of residual contamination and activation products.

SPR-III operations began in 1978. Operations were suspended in 2000, and the core was placed in 

secure storage (SPRF, 2005). In 2005, SPR-III came out of a five and a half-year storage. It operated 

safely for 159 days, conducting 563 operations from January through September 2006 (SPRF, 2007). 

Like SPR-II, SPR-III also used an unmoderated cylindrical assembly of solid uranium metal enriched 

to 93 percent U-235 with 10 weight-percent molybdenum. The SPR-III core consists of 18 stacked 

fuel rings mechanically fastened into two groups of nine rings each. The masses of the individual 

rings varied between 6.8 kg and 15.4 kg. The core support structure held the nine upper rings 

stationary, and high-strength bolts mechanically fasten together the nine lower rings. (SNL, 1998).

Fuel from SPR- II was sent to LANL for reprocessing. Fuel from SPR-III was sent to the Nevada 

Test Site for storage as part of the National Nuclear Security Administration’s (NNSA) nuclear 

material consolidation and disposition effort (SPRF, 2007, PDF p. 2). Over 13,000 operations were 

performed at SPRF from 1961-2006 (SPRF, 2007, PDF p. 3).

Hot Cell Facility

Also located in Area V, the Hot Cell Facility (HCF) is used for post-irradiation examination of sealed 

experiments. Full contained packages irradiated in either SPR-III or ACRR are generally sent to the 

HCF for opening and evaluation. The HCF was in operation throughout this evaluation period (1996-

2011).

The HCF, which includes the Hot Cell with Steel Containment Boxes (SCB), the Glove Box 

Laboratory (GBL), and ancillary equipment and instrumentation in the support area, was designed and 

developed to support SNL-A experimental programs in which Special Nuclear Material (SNM) and/or 

radioactive materials are used. Operations include the preparation of materials for testing, experiment 

assembly, post-testing disassembly, preparation of samples for post-testing examination, and posttesting microscopy and wet chemical analysis. The facility was used extensively to process medical 

isotopes, such as the Mo-99 produced at ACRR. In addition, the Hot Cell and GBL are used for the 

preparation and packaging of SNM for reprocessing and for the preparation and packaging of 

radioactive and contaminated waste for final disposition. The facility was designed with four 

separate ventilation zones; areas with the highest levels of radioactivity are isolated from other areas 

(HCF, 1995, PDF pp. 17-18).
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5.2 Radiological Exposure Sources from SNL-A Operations

The radiological exposure sources relevant to the 1997-2011 evaluation, including sources from the 

RMWMF, ACRR, the SPRF, and the HCF described above, can be found in Section 5.2 of the 

original SEC Petition Evaluation Report for Petition SEC-00188 (NIOSH, 2012). 

6.0 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH

The following subsections provide an overview of the state of the available internal monitoring data 

for the SNL-A class under evaluation. 

6.1 Available Sandia National Laboratories Internal Monitoring Data

Occupational internal monitoring data available for the 1997-2011 period include in vitro (primarily 

urinalysis), in vivo (whole-body and lung counting), personal air sample (PAS) data, and Derived Air 

Concentration-Hour (DAC-hour) tracking data. 

6.1.1 SNL In Vitro Data Summary

The urinalysis summaries presented below were obtained from a WebDose database extract obtained 

by NIOSH from SNL-A. Table 6-1a below shows the number of urine sample results available and 

the number of persons sampled for the time period from 1997 through 2011. Note that each 

individual urine sample may yield multiple sample results, depending on the particular analytes 

associated with the sample (i.e., samples are often analyzed for multiple radionuclides). 

Table 6-1a: Available WebDose Urine Bioassay Data: 1997-2011

Year Non-H3 Sample 

Results

Persons Sampled 

(Non-H3) 

H3 Sample 

Results

Persons Sampled 

(H3) 

1997 111 45 238 100

1998 144 59 375 126

1999 187 67 440 83

2000 119 46 375 50

2001 90 39 426 58

2002 111 46 575 78

2003 160 55 679 78

2004 158 51 677 70

2005 172 60 647 69

2006 128 40 500 51

2007 115 35 438 47

2008 101 33 424 40

2009 121 42 435 40

2010 138 48 446 39

2011 165 47 534 54

Total 2020 317 7209 362
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Table 6-1b shows the relative volume of available urine bioassay results by radionuclide. As shown, 

the predominant nuclides measured were H-3, Pu-238/239, Am-241, uranium, and thorium. 

Table 6-1b: Available WebDose Non-H3 Urine Bioassay Data: 1997-2011 (Number 

of Urine Sample Results by Radionuclide)

Radionuclide No. of Results

Am-241 759

Am-243 11

Cm-242 4

Cm-243 15

Cm-244 8

Co-60 9

Cs-137 10

I-125 3

I-126 1

K-40 6

Ni-63 1

Np-237 15

Pu-238 856

Pu-239 869

Pu-241 118

Pu-iso 26

Ra-226 5

Sr-90 746

Tc-99 8

Th-228 201

Th-230 201

Th-232 200

Th-iso 1

U 411

U-232 3

U-234 119

U-235 690

U-238 689

Total 5985

NOTE: The total number of results do not match the total number of samples from 

Table 6-1a above because samples are often analyzed for multiple radionuclides.
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6.1.2 In Vivo Data Summary 

Table 6-1c summarizes the frequency of in vivo bioassay measurements performed at SNL-A between 

1997 and 2011. A total of 1115 measurements were performed involving a total of 207 individuals. 

Table 6-1c: Available WebDose In Vivo Count Data: 1997-2011

Year Measurements Persons

1997 59 54

1998 66 55

1999 58 52

2000 265 40

2001 73 33

2002 54 43

2003 102 61

2004 60 46

2005 65 58

2006 61 54

2007 45 42

2008 29 28

2009 48 40

2010 40 39

2011 90 50

Total 1115 207

6.1.3 Air Monitoring Data Summary 

During 1996, significant changes to the internal dose monitoring program took place, including a 

requirement for internal dosimetry review and assignment of DAC-hrs, and a requirement to forward 

DAC-hr records to Internal Dosimetry if DAC fractions exceeded 0.1 DAC. Philosophical changes in 

the internal dosimetry program also took place in 1996, which included a change of emphasis from 

internal dosimetry to internal radiation protection, and reliance on other types of monitoring 

(particularly air monitoring) to indicate the need for bioassay. 

Personal air sampling (often called breathing zone (BZ) or lapel monitoring) was used extensively at 

Sandia during the period 1997 through 2011, with individual samples being analyzed for both gross 

alpha and gross beta/gamma activity. There are currently six sources of BZ monitoring data available 

within the site research database (SRDB). The contents of these datasets are categorized and 

summarized in Sections 6.1.3.1 – 6.1.3.6 below. 
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6.1.3.1 BZ Sample Records Contained in the WebDose Database Extract

Table 6-1d below is a summary of the available WebDose BZ monitoring data for the period 1997 

through 2011 (WebDose, 2018). A total of 26 mrem CEDE was assigned to [number redacted]

individuals; the maximum assigned dose was 10 mrem. As discussed below in Section 6.1.3.2, the 

WebDose entries represent a rollup of individual BZ samples associated with an individual during a 

defined period and do not necessarily represent the results of a single BZ sample. For this reason, it is 

not possible to relate the number of WebDose BZ entries.

Table 6-1d: Available WebDose Breathing Zone Air Monitoring Results: 1997-2011

Year WebDose BZ 

Entries

WebDose BZ 

Persons

Total Associated CEDE 

(mrem)

1997 90 44 0

1998 89 53 10

1999 41 25 0

2000 24 19 0

2001 9 [number redacted] 0

2002 14 10 0

2003 16 [number redacted] 12

2004 0 [number redacted] 0

2005 0 [number redacted] 0

2006 0 [number redacted] 0

2007 0 [number redacted] 0

2008 1 [number redacted] 0

2009 0 [number redacted] 0

2010 1 [number redacted] 4

2011 0 [number redacted] 0

Total 285 116 26

NOTE: The sum total of WebDose BZ Persons is less than the sum of the WebDose BZ 

Persons for each year because the same individuals are often monitored in multiple years.

NOTE: For Column 3, numbers under 10 were redacted due to Privacy Act concerns.

6.1.3.2 DAC-hr Tracking Reports 

There are nine SRDB files containing DAC-hr tracking reports spanning the time period January 1997 

through November 2002 (Alpha BZ Analysis, 2019; DAC-hr, 1999; DAC-hr, 2000; DAC-hr, 2000-

2001; DAC-hr, 2001a; DAC-hr, 2001b; DAC-hr, 2001c; DAC-hr, 2002a; DAC-hr, 2002b). These 

nine files contain records for 113 individuals (264 records) with a combined total of 86 DAC-hr (215 

mrem). Individual sample values range from 0 to 6.78 DAC-hr (0 to 17 mrem). The total 

accumulated internal dose (per individual) for the three-year period covered ranges from 0 to 8.5 

DAC-hr (0 to 21 mrem). These DAC-hr reports are the basis for the WebDose dose entries for BZ 

sampling. That is, each WebDose entry represents a rollup of the DAC-hr records for an individual 

over the applicable month and, accordingly, represents the results for multiple BZ samples for each 

entry.
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6.1.3.3 WebDose ‘PAS-Survey’ Table Provided in Response to a NIOSH Data Request

The ‘PAS-Survey’ table was provided by Sandia in response to NIOSH data request Sandia-FY15-01 

(PAS-Survey, 2015). The ‘PAS-Survey’ table contains 107 entries, with two from 2003, seven from 

2012, and 97 from 2013. This data source does not allow one to determine the actual BZ result (e.g., 

filter activity, DAC-hr, etc.). However, most entries are accompanied by a comment stating that zero 

dose is assigned because the calculated dose did not exceed the Decision Level threshold of 10 mrem. 

This is consistent with the known Sandia practice of censoring BZ results at 10 mrem for a single BZ 

instance.

6.1.3.4 Listing of Lapel Surveys in VSDS 

A spreadsheet contains 976 entries spanning 2008 through 2015, and represents radiological surveys

that are indexed in the Visual Survey Data System (VSDS) survey system with ‘lapel’ in either the 

survey title or survey purpose (VSDS, 2015). There are no available quantitative data traceable to

these entries. The existence of this spreadsheet is described here primarily because it is evidence of an 

active personal air sampling program during this time period.

6.1.3.5 MS Access Database from RWMWF

A Microsoft® Access® database (‘HAZ summary data1.mdb’) contains records for 704 samples, 

spanning the period 2009 to 2012 (Hazard Summary, 2015). The results are simply provided in cpm. 

Since there are no corresponding DAC or DAC-hr values presented, or sufficient data to compute 

them, these records have little quantitative value for the purposes of dose reconstruction. As with the 

VSDS spreadsheet, this database is described here primarily because it is additional evidence of an 

active personal air sampling program during this time period.

6.1.3.6 BZ Monitoring Raw Data Sheets

There is a collection of 11,283 pages of air sample data sheets contained within multiple sets of data 

files (BZ Data1, 2018; BZ Data2, 2018, BZ Data3, 2019). These data files contain individual General 

Area and Breathing Zone samples collected across the Sandia site. Samples were analyzed for gross 

alpha and gross beta/gamma radiation with results reported in either total filter activity or as activity 

per unit volume sampled. In a small number of instances, data were also reported for either tritium or 

low-energy beta-emitters (generally Pu-241). Breathing Zone samples contained demographic 

information on the individual wearing the sampler, the duration of the sampled activity, and whether 

respiratory protection was worn. Table 6-1e shows the availability of BZ monitoring results in the 

SRDB. Note that this tabulation does not necessarily represent the number of BZ samples actually 

collected by SNL-A in each year. It is a summary of sample results that are currently available to 

NIOSH. For example, it is likely that samples were collected for years 2003 and 2011; however, data 

for those years are not currently available to NIOSH. Additional information regarding data quality 

can be found in the Data Pedigree discussion (Section 7.1.1.3).
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Table 6-1e: Available Breathing Zone Air Monitoring Results: 1997-2011

Year BZ Sample Results

1997 357

1998 1583

1999 708

2000 336

2001 172

2002 585

2003 0

2004 274

2005 388

2006 208

2007 231

2008 445

2009 76

2010 26

2011 0

Total 5389

6.1.4 Summary of Internal Dose Assigned in WebDose

Internal dose assignment records are contained in the WebDose database extract provided by Sandia 

on May 2, 2018 (WebDose, 2018). Table 6-1f provides a summary of the total internal dose (CEDE) 

assigned for each year from 1997 to 2011 in units of mrem for each of the various monitoring 

methods employed. 

Table 6-1f: Total Internal Dose (CEDE) Assigned (mrem): 1997 to 2011 by Monitoring Method

Year H3 Urine BZ Sample Non-H3 Urine 

Sample In Vivo Total

1997 0 0 0 0 0

1998 0 10 0 0 10

1999 0 0 0 0 0

2000 0 0 0 5 5

2001 0 0 0 0 0

2002 0 0 0 0 0

2003 0 12 0 0 12

2004 0 0 0 0 0

2005 0 0 0 0 0

2006 0 0 0 0 0

2007 0 0 0 0 0

2008 0 0 0 0 0

2009 0 0 23 0 23

2010 0 4 19 0 23

2011 4 0 0 0 4

All 4 26 42 5 77
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7.1 Pedigree of SNL Data

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

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

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

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

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

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

feasibility evaluation presupposes that data pedigree issues have been settled.

7.1.1 Internal Monitoring Data Pedigree Review

In determining the pedigree of SNL monitoring data and the sufficiency of available data to bound 

worker doses, NIOSH evaluated the following:

• The overall suitability of SNL’s Internal Dosimetry Monitoring Program;

• The use of bioassay sampling for specific groups of workers for confirmatory purposes;

• Incident response involving bioassay;

• Internal exposure potential of the workforce;

• Internal Exposure Monitoring Data (WebDose)

• Breathing Zone air monitoring data;

• Internal dose (CEDE) assigned by Sandia.

7.1.1.1 Internal Dosimetry Monitoring Program

Sandia implemented a radiation protection program that included baseline, termination, and routine 

internal monitoring (TBD, 1995). From the onset, the program identified “technology shortfall”

radionuclides for which air monitoring would be employed as the primary means of internal 

monitoring (TBD, 1995, PDF p. 203). Interviews with the Internal Dosimetrist at the time indicated 

that initial selection for internal monitoring program participation was by individual department 

managers, and that, over time, this process was changed to focus monitoring on individuals with a 

higher risk of exposure (Personal Communication, 2017c). The reason for this change was noted by 

this same individual as being the high program cost relative to the low potential for internal exposure. 

A 1996 external assessment of the internal dosimetry program by a technical expert proposed the 

implementation of DAC-hr tracking (using personal air samples) as the primary method of internal 

exposure monitoring (with the exception of tritium, for which routine bioassay sampling was retained) 

(Assessment, 1996). Requirements for assigning DAC-hr equivalents based on air monitoring data,

and the forwarding of these type of records to Internal Dosimetry for assignment as doses of record,

appeared in procedures starting in the latter half of 1996 (SNL, 1996).

The following subsequent procedure revisions further refined the procedural requirements for 

documentation and retention of air monitoring records used to assess internal dose:

• RPO-04-420, Air Sampling, Issue 2 (3/18/1996), was revised to include requirements for internal 

dosimetry review and assignment of DAC-hrs (RPO, 1996)

• RPID-00-01, Program Overview, Issue 4 (8/27/96), indicates that results from personal air 

samplers are provided to the Radiation Protection Internal Dosimetry (RPID) group weekly. 

Those results are used to track exposure, and ultimately, to determine if bioassay monitoring is 
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required. It should be noted that the purpose of this revision was to: ...reflect philosophical 

changes in the internal dosimetry program. This includes change of emphasis from internal 

dosimetry to internal radiation protection and reliance on other types of monitoring to be 

indicative of the need for bioassay. (RPID, 1996) 

• RPID-20-04, Personal Air Sampler Results Processing, Issue 1 (7/16/1997), provided a

mechanism for the electronic capture of PAS sample results as well as requirements for review by

Internal Dosimetry staff (RPID, 1997).

• RPID-20-03, Entering Internal Dose Equivalents in SANDOS, Issue 3 (1/14/1999), was revised to

provide instructions on entering dose from PAS samples into the dose tracking system (RPID,

1994).

• RPID-02-01, Records Management Life Cycle, Issue 3 (10/1/1999), was revised to include

personal air sample results and dose records in the records series (RPID, 1999).

• The transition away from routine bioassay (except for tritium) was clarified in RPID-00-10,

Technical Basis Document: Internal Dosimetry, Issue 3 (10/8/1998), which states: Personal air

sampling (PAS) is the primary indicator of intakes at SNL. (RPID, 1995)

7.1.1.2 Confirmatory Sampling

Sandia maintained routine bioassay sampling for specific groups of workers based on work activity 

(i.e., job category) for confirmatory purposes. 

A February 3, 1998 summary of an RMWMF Safety Committee discussion on the need for routine 

bioassay indicated the following (RMWMF, 1998b): 

• RCTs at the RMWMF are on routine bioassay and results are reviewed to identify any trends.

Furthermore: If a trend developed indicating internal doses, RMWMF personnel would

undoubtedly be asked to submit special bioassay samples to determine the scope of the problem.

• If trends developed indicating elevated air concentrations or increased surface contamination

levels, special bioassay samples would be requested from appropriate facility personnel.

• Job-specific RWPs require bioassay, as appropriate, for those workers involved with tasks where

significant levels of radionuclides, or certain specific radionuclides (e.g., 3H) are handled.

Similarly, a May 30, 2001 memo documenting the routine bioassay program for Radiological Control 

Technicians (RCTs) at TA-V indicated the following (TA-V, 2001): 

• Current schedule calls for annual whole-body counts and semi-annual urinalysis samples for U,

Th, Am, and Pu.

• Furthermore: The SNL bioassay program is confirmatory in nature. The Bioassay program

confirms the results and effectiveness of contamination control and other personnel protection

activities.
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• Since Radiological Control Technicians (RCTs) must be present in all work activities where the

possibility of meaningful intakes is credible, their bioassay serves as a good proxy indicator for

potentially exposed line personnel...

7.1.1.3 Incident Response 

Although routine bioassay monitoring was not used as the primary means of internal dose monitoring, 

evidence was located indicating the implementation of bioassay monitoring in response to specific 

incidents. Table 7-1a provides a sample of incident responses that included bioassay monitoring. 

Table 7-1a: Incident Response Actions Involving Bioassay Monitoring

Date Triggering 

Event

Summary Follow-up SRDB Ref ID

02/07/97 Puncture 

wound

[Incident description redacted] Bioassay Sampling 175709

03/20/97 Area survey Unexpected surface contamination 

detected during post-job survey.

Bioassay Sampling 175706

04/16/97 Odor during 

opening drum

Upon opening drum, a strange odor was 

detected. Tritium contamination 

detected.

Bioassay Sampling 175707

05/29/97 Area monitor 

alarm

Tritium monitor alarmed during work. Bioassay Sampling 175703

02/12/98 Area survey Unexpected surface contamination 

detected during post job survey.

Bioassay Sampling 31028

07/23/98 Personnel 

contamination 

monitoring

Unexpected levels of contamination 

detected during work process. Work 

stopped, follow-up survey identified 

unexpected high levels of surface 

contamination. 

Bioassay Sampling 23716

10/30/98 BZ air sample Unexpectedly high air sample result 

during work.

WBC and Bioassay 

Sampling

23716

01/19/99 BZ air sample Unexpectedly high air sample result 

during work.

Bioassay Sampling 23716

01/26/99 Area survey Unexpected surface contamination 

detected during post-job survey.

Bioassay Sampling 23716

03/19/99 BZ air sample Unexpectedly high air sample result 

during work.

Bioassay Sampling 23716
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7.1.1.4 Internal Exposure Potential 

As initially implemented in 1995, Sandia’s Radiation Protection Program indicated that routine 

bioassay sampling would only be used to ensure that workplace controls were adequate. It further 

indicated that, because of effective engineering controls, the use of protective clothing and respiratory 

protection, as well as contamination surveys and air monitoring, routine bioassay samples would not 

be expected to contain any radioactive material indicative of a new intake (TBD, 1995). This assertion 

is consistent with external program reviews conducted in 1996 and 1999 (Assessment, 1996; 

Assessment, 1999), in which it was indicated that exposure to site personnel in excess of 100 mrem 

CEDE would be unlikely. In May 1999, the site Radiation Protection Plan was revised to indicate that 

it was not likely that individuals would receive greater than 100 mrem of internal exposure, and 

accordingly, a routine internal dosimetry program was not required (RPP, 1999).

7.1.1.5 Internal Exposure Monitoring Data (WebDose)

The current repository of all Sandia monitoring data is termed WebDose. The completeness of the 

urinalysis data contained in the WebDose system was assessed by comparing sample records from 

seven laboratory data files (captured by the ORAU Team in April 2007) to the records contained in a 

WebDose extract file provided to NIOSH in July 2014 (WebDose, 2014). ORAU identified 95 

samples for which results were provided in the laboratory file but that were not in WebDose. A 

formal request was submitted to Sandia for resolution of the issue. It was subsequently determined 

that a change in the primary key used to associate individual names to monitoring records (i.e., from 

employee social security number to Sandia ID) resulted in the disconnection of some monitoring 

records from the record identifying the associated individual. Sandia determined that 548 records 

associated with 73 individuals were affected. This condition was corrected within Sandia’s WebDose 

system and a new WebDose extract file was provided to NIOSH on May 2, 2018 (WebDose, 2018). 

The comparison between laboratory data files and the corrected WebDose extract was repeated using 

another set of laboratory data files (Urinalysis, 1994; 1995a; 1995b; 1995c; 1996; 1999). The only 

inconsistency found were instances in which a laboratory returned results for radionuclides that were 

not requested; such results were not input into WebDose (e.g., 22 instances in which isotopic thorium 

results were provided when total uranium results were requested).

Review of whole-body count records in WebDose indicate a lack of any ‘result’ associated with 

counts performed prior to 2000. It was confirmed that, prior to 2000, results for negative whole-body 

counts were not input into WebDose. In order to confirm this practice, hard copy records for 10% of 

the measurements performed between 1995 and 1999 (a total of 54 records) were requested and 

compared to corresponding WebDose entries. This comparison confirmed that the records with blank 

results were, in fact, non-detect measurements. It was also determined that there were three instances 

in which the whole-body count record in WebDose was not accurate (i.e., the record number for the 

WebDose record does not match the record on the raw data source). This discrepancy has not been 

resolved with the site, but it has been determined that a complete record of all whole-body counts 

associated with an individual could still be retrieved by the site using hard-copy record indexes.
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The completeness of dose entries that originated from personnel air sample (BZ) results was assessed 

by compiling a list of individuals garnered from all known data sources (data sheets, WebDose, 

DAC-hr Tracking Reports, and RMWMF Database). Monitoring records were requested for these 

individuals. In total, data on 22 individuals were evaluated and compared. In 15 of the 22 instances, 

the monitoring data provided by Sandia was consistent with the raw data sources. In five instances, 

there were inconsistencies related to the assignment date; however, the results were consistent (albeit

0). The two instances in which the data were not consistent were for individuals sampled in 1995 and 

1996. 

7.1.1.6 Breathing Zone Air Monitoring Data

Air-monitoring data presented in Section 6.1.3 consists of raw field-monitoring data sheets that were 

obtained during data capture activities by the ORAU Team. This dataset is known to be incomplete, 

as follows: 

• For some years, there are zero captured monitoring results: 2003 and 2011

• The data for the period 1997-2002 appear to represent data sheets that were sent to the Internal

Dosimetry program office (as indicated by a “reviewed by ______” stamp on the majority of the

pages). Interviews with site personnel indicate that air sample results exceeding threshold values

were submitted to Internal Dosimetry; thus, it is reasonable to assume that the dataset represented

by these sheets is biased high. The practice of only sending datasheets that exceed threshold

values is consistent with air-monitoring procedures obtained from the site.

• The VSDS listing of lapel samples described in Section 6.1.4 indicates that a larger number of

lapel surveys were performed than are currently represented by the datasheets obtained by data

capture activities.

• Some of the captured datasheets have either missing or illegible data that renders them unusable

for the purpose of assessing potential internal exposure to the associated individual (e.g., for 2002,

32 of 585 records contain no duration entry).

7.1.1.7 Internal Dose (CEDE) Assigned by Sandia 

Internal dose data discussed in Section 6.1.4 was obtained from the WebDose extract file (an Excel 

formatted file) provided on May 2, 2018 (WebDose, 2018). The data were pulled from the various 

‘dose’ sheets provided in the Excel file and are presumed to represent the dose records that are stored

within Sandia’s onsite record-keeping system. A query of the DOE REMS system 

(https://apps.orau.gov/CER/REMSQueryTool) indicates comparable, albeit not equivalent results (108 

person-mrem accrued between 1997 and 2011 versus 77 person-mrem obtained from the WebDose 

extract file). However, there is 28 person-mrem noted in WebDose as received “offsite” (e.g., dose 

received by Sandia personnel at other sites). Once this 28 person-mrem is added in for these years

(i.e., 77 + 28 = 105 person-mrem), the REMS and WebDose values agree favorably (i.e., 108 vs. 105 

person-mrem). 
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7.2 Evaluation of Bounding Internal Radiation Doses at Sandia National 

Laboratories

The principal sources of internal radiation doses for members of the class under evaluation were

exposures to plutonium, tritium, uranium, americium, and fission and activation products (NIOSH, 

2012). The following subsections address the ability to bound internal doses, methods for bounding 

doses, and the feasibility of internal dose reconstruction. 

7.2.1 Evaluation of Bounding Process-Related Internal Doses

The following subsections summarize the extent and limitations of information available for 

reconstructing the process-related internal doses of members of the class under evaluation.

7.2.1.1 Bioassay Data 

As indicated previously in Section 6.1.3, by 1997 Sandia had shifted the emphasis of the internal 

monitoring program from reliance on bioassay monitoring to the use of breathing zone sampling as a 

primary method of monitoring. Sandia maintained the position that no individual was likely to 

receive an exposure in excess of 100 mrem; this is indicated in both internal technical basis 

documentation (RPP, 1999) as well as in external assessments performed in 1996 and 1999 

(Assessment, 1996; Assessment, 1999). Program documentation indicates that radiation control 

technicians were maintained on routine bioassay programs as a confirmatory measure in the RMWMF 

and within Technical Area V (RMWMF, 1998b; TA-V, 2001).

Because of the confirmatory nature of Sandia’s bioassay monitoring program, and the fact that 

breathing zone sampling was deemed the primary method of internal dose monitoring, it is not 

feasible to rely solely on bioassay monitoring to assess potential internal exposure to Sandia 

personnel. 

7.2.1.2 Breathing Zone Sampling 

The breathing zone sampling data discussed in Section 6.1.3.6, Table 6-1e, were primarily data for 

individuals who were wearing respiratory protection. These data were used to assess the potential 

exposure to co-located individuals who were not being monitored and were not wearing respiratory 

protection. 

The internal dose associated with each BZ sample record was calculated as follows: 

1. When the filter activity was provided, the intake quantity was calculated by multiplying the filter

activity by the ratio of the breathing rate for Reference Man (20 L/m) to the sample flow rate

(generally between 3 and 4 L/m).

2. When the filter concentration (activity per volume sampled) is provided, the filter activity was

calculated by multiplying the filter concentration by the associated volume, and then the intake

quantity was calculated as in Step 1 above.

3. The doses associated with the intake quantities calculated in either Steps 1 or 2 above were

calculated by dividing the intake quantity by the stochastic ALI (based on the values listed in 10

C.F.R. pt. 835) and multiplying by 5000 mrem. NOTE: For this calculation, a conservative
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(claimant-favorable) nuclide (Type S plutonium) was assumed, unless the associated survey 

indicated otherwise.

4. Steps 1 to 3 above were performed independently using gross alpha, gross beta/gamma, and H3

LSC results along with applicable ALI values.

As indicated in Section 7.1.1.6, there are a small number of instances during which insufficient 

information is available to arrive at the dose associated with an air sample filter record. For 2002, 

there are 32 instances (out of 585) for which there is insufficient information to perform a dose 

assessment. These samples were excluded from the final analysis; however, they represent a very 

small portion of the available data and are dosimetrically-insignificant (i.e., they have an average 

activity of less than 0). 

BZ air sampling results, which give the dose in mrem for exposures to airborne radioactive materials, 

were analyzed to determine the distribution of the data grouped by event. An event is defined two 

ways: a radiological work task at a given location on a given day, and all radiological work on a given 

day.

Gross Alpha Analysis 

The gross alpha air sample results were analyzed to determine the mean radiological doses from these 

data. Table 7-1b below shows the number of available alpha BZ sample results used in the analysis 

along with the number of samples grouped by work activity and work day. 

Table 7-1b: Available Gross Alpha Data

Year Available Alpha 

BZ Results

Number of Individual 

Work Activities

Number of Work 

Days with a Sample

1997 357 148 130

1998 1581 368 211

1999 708 186 120

2000 334 84 78

2001 172 90 82

2002 553 296 155

2004 131 53 44

2005 177 77 65

2006 75 33 32

2007 111 42 39

2008 189 68 63

2009 38 16 16

2010 23 6 6

Figure 7-1 is a QQ Plot of the individual dose (CEDE) in mrem associated with each BZ sample. This 

is a mixture of a normal distribution (the analytical noise) and a lognormal distribution (the real 

exposures). Note the negative (< 0) results. The parameters for the lognormal component of the 

distribution can be determined by censoring the results below 1 mrem and fitting a lognormal model 

to the remaining data. This lognormal dataset is then used to replace negative values in the original 

full dataset. This same method is used for analyzing censored bioassay data for co-worker models 

(ORAUT-RPRT-0053, Analysis of Stratified Coworker Datasets; ORAUT-RPRT-0071, External 
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Dose Coworker Methodology; and ORAUT-RPRT-0096, Multiple Imputation Applied to Bioassay 

Coworker Models).

The resulting revised dataset (with the negative values replaced) was used to compile a dataset 

representing the dose associated with individual work activities (i.e., all samples collected in a 

particular area during a particular time period) and all individuals working on a particular day (i.e., all 

samples collected on a particular day regardless of work location). The median dose for an event in 

this analysis was 0.48 mrem, with an associated geometric standard deviation of 5.8 for an event 

defined by particular area and time, and 0.51 mrem with a GSD of 5.2 for all individuals working on a 

particular day.

Figure 7-1: Normal QQ Plot of Alpha Dose Data
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Gross Beta/Gamma Analysis

The gross beta/gamma air sample results were analyzed to determine the mean radiological doses 

from these data. Table 7-1c below shows the number of available alpha BZ sample results used in the 

analysis along with the number of samples grouped by work activity and work day. 

Table 7-1c: Available Gross Beta/Gamma Data

Year Available Beta/Gamma 

BZ Results

Number of Individual 

Work Activities

Number of Work Days 

with a Sample

1997 357 148 130

1998 1583 368 211

1999 708 186 120

2000 336 84 78

2001 172 90 82

2002 553 296 155

2004 137 53 44

2005 177 77 65

2006 72 32 32

2007 170 42 39

2008 358 68 63

2009 74 16 16

2010 26 6 6

Figure 7-2 is a QQ Plot of the individual dose (CEDE) in mrem associated with each BZ sample. This 

is a mixture of a normal distribution (the analytical noise) and a lognormal distribution (the real 

exposures). Note the negative (< 0) results. The parameters for the lognormal component of the 

distribution can be determined by censoring the results below 0.1 mrem and fitting a lognormal model 

to the remaining data. This lognormal dataset is then used to replace negative values in the original 

full dataset. This same method is used for analyzing censored bioassay data for co-worker models 

(ORAUT-RPRT-0053, Analysis of Stratified Coworker Datasets; ORAUT-RPRT-0071, External 

Dose Coworker Methodology; and ORAUT-RPRT-0096, Multiple Imputation Applied to Bioassay 

Coworker Models).

The resulting revised dataset (with the negative values replaced) was used to compile a dataset 

representing the dose associated with individual work activities (i.e., all samples collected in a 

particular area during a particular time period) and all individuals working on a particular day (i.e., all 

samples collected on a particular day regardless of work location). The median dose for an event in 

this analysis was 0.001 mrem with an associated geometric standard deviation of 8.0 for an event 

defined by particular area and time, and 0.001 mrem with a GSD of 7.0 for all individuals working on 

a particular day.
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Figure 7-2: Normal QQ Plot of Beta/Gamma Dose Data

Tritium Analysis

The tritium air sample results were analyzed to determine the mean radiological doses from these data. 

Table 7-1d below shows the number of available alpha BZ sample results used in the analysis along 

with the number of samples grouped by work activity and work day. NOTE: When converting BZ 

results to dose, the dose conversion factor for Insoluble (Type S) Metal Tritides was assumed. 

Table 7-1d: Available Tritium Data

Year Available Tritium 

BZ Results

Number of Individual 

Work Activities

Number of Work Days 

with a Sample

2004 119 45 39

2005 165 67 57

2006 88 41 39

2007 52 20 19

2008 8 5 5

Figure 7-3 is a QQ Plot of the individual dose (CEDE) in mrem associated with each BZ sample. This 

is a mixture of a normal distribution (the analytical noise) and a lognormal distribution (the real 

exposures). Note the negative (< 0) results. The parameters for the lognormal component of the 

distribution can be determined by censoring the results below 0.2 mrem and fitting a lognormal model 

to the remaining data. This lognormal dataset is then used to replace negative values in the original 

full dataset. This same method is used for analyzing censored bioassay data for co-worker models 

(ORAUT-RPRT-0053, Analysis of Stratified Coworker Datasets; ORAUT-RPRT-0071, External 

Dose Coworker Methodology; and ORAUT-RPRT-0096, Multiple Imputation Applied to Bioassay 

Coworker Models).
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The resulting revised dataset (with the negative values replaced) was used to compile a dataset 

representing the dose associated with individual work activities (i.e., all samples collected in a 

particular area during a particular time period) and all individuals working on a particular day (i.e., all 

samples collected on a particular day regardless of work location). The median dose for an event in 

this analysis was 0.007 mrem with an associated geometric standard deviation of 4.4 for an event 

defined by particular area and time, and 0.007 mrem with a GSD of 4.3 for all individuals working on 

a particular day.

Figure 7-3: Normal QQ Plot of Tritium Dose Data
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7.2.1.3 10 CFR 835 Regulatory Monitoring Threshold 

10 C.F.R. pt. 835, Occupational Radiation Protection, specifies regulations that are pertinent to all 

DOE facilities. These regulations were issued on December 14, 1993 with an implementation 

deadline of December 31, 1995. These regulations contained specific requirements related to 

individual monitoring (§ 835.402) and recordkeeping (§ 835.702). 

The original rule, dated December 14, 1993, states the following regarding individual monitoring (10 

C.F.R. § 835.402): 

§835.402 Individual monitoring. [Original rule, 1993]

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

evaluation programs (including routine bioassay programs) shall be conducted for: 

(1) Radiological workers who, under typical conditions, are likely to receive 0.1 rem (0.001 

sievert) or more committed effective dose equivalent, and/or 5 rems (0.05 sievert) or more 

committed dose equivalent to any organ or tissue, from all occupational radionuclide intakes in a 

year. 

These monitoring thresholds correspond to 2% and 10%, respectively, of the occupational exposure 

limits for these categories of exposure for general employees (10 C.F.R. § 835.202). The requirement 

for monitoring based on organ and tissue committed dose equivalent (CDE) was removed in 1998, as 

explained in the Federal Register notice:

The monitoring threshold based upon committed effective dose equivalent obviates the need for 

this threshold because, through application of the weighting factors defined in §835.2(b), the 

committed effective dose equivalent always provides a more restrictive basis for individual 

monitoring. (63 FR 59683)

The amended rule, dated November 4, 1998, states (10 C.F.R. § 835.402): 

§835.402 Individual monitoring. [Amended rule, 1998]

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

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

(1) Radiological workers who, under typical conditions, are likely to receive a committed effective 

dose equivalent of 0.1 rem (0.001 sievert) or more from all occupational radionuclide intakes in a 

year.

Records of conducted monitoring were required to be maintained per § 835.702 in order to document 

compliance with 10 C.F.R. § 835.402: 

§835.702 Individual monitoring records. 

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

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

exposures, accidents, and emergency conditions.
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DOE Occupational Radiation Exposure (DOE/EH-0575, 1997), Section 2.1, Radiation Protection 

Requirements, states:

10 CFR 835 became effective on January 13, 1994, and required full compliance by January 1, 

1996. In general, 10 CFR 835 codified existing radiation protection requirements in DOE Order 

5480.11. The rule provides nuclear safety requirements that, if violated, will provide a basis for 

the assessment of civil and criminal penalties under the Price-Anderson Amendments Act of 1988, 

Public Law 100-408, August 20, 1988 as implemented by 10 CFR 820 “Procedural Rules for DOE 

Nuclear Activities,” August 17, 1993. 

Sandia-Albuquerque 10 C.F.R. pt. 835 Implementation Documentation 

10 C.F.R. pt. 835 required all DOE sites to develop a radiation protection program (RPP) document 

outlining how compliance would be achieved and certifying compliance (or indicating elements that 

were not in compliance) by the December 31, 1995 deadline. 

The initial version of the Sandia-Albuquerque 10 C.F.R. pt. 835 Radiation Protection Program (RPP) 

document, issued on December 29, 1994, includes the requirement for individual monitoring, as 

defined in 10 C.F.R. § 835.402(c) (RPP Plan, 1994). The RPP indicates that compliance with this 

section would be achieved upon revision of the site Internal Dosimetry Technical Basis Document 

(TBD). The revised site Internal Dosimetry TBD was issued on May 5, 1995 (TBD, 1995). 

Subsequent versions of the RPP document (RPP, 1999; RPP, 2011) issued in 1999 and 2011 

characterize the Sandia bioassay monitoring program as ‘confirmatory’ with the assertions that: (1) no 

individual at Sandia is likely to receive an internal exposure exceeding 100 mrem CEDE; and (2) a 

routine internal dosimetry program is not required. A revision of the RPP issued between 1994 and 

1999 is not available; however, other program documents issued in the 1996 and 1997 time frame 

(RPID, 1996; TBD, 1996) clearly indicate the internal monitoring program’s shift from routine 

bioassay sampling to breathing zone air sampling while maintaining the 100 mrem monitoring 

threshold. 

Internal and External Program Assessments

NIOSH reviewed 22 internal and external assessments of the radiological protection programs at 

Sandia generated between 1997 and 2008. Attachment One summarizes these assessments. The 

assessments were performed by Sandia personnel, SNL’s “External Advisory Board,” DOE’s 

Independent Oversight and Performance Assurance (in 2003, 2005 and 2008), and the Inspector 

General’s Office (in 2008). None of the findings in these assessments would likely affect NIOSH’s 

ability to perform individual dose reconstructions. 

DOE ORPS Reports

NIOSH reviewed the DOE Occurrence Reporting System (ORPS) for SNL-A 10 C.F.R. pt. 835 

violations, as follows: 

• NIOSH identified a total of 1,498 reports that were available. 

• Of these 1,498 reports, 194 report titles were deemed potentially relevant and were selected for 

review.

• NIOSH found none of these reports to be problematic regarding dose reconstruction feasibility. 
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DOE Noncompliance Tracking System (NTS) Reports

NIOSH reviewed the NTS system for SNL-A 10 C.F.R. pt. 835 violations, site responses, and 

corrective actions, as follows:

• 171 SNL report titles were listed in the system.

• 72 were considered potentially relevant and were requested for review.

Of the 72 reviewed, [number redacted] were considered pertinent to compliance with 10 C.F.R. 

§ 835.402(c)(1) or 10 C.F.R. § 835.702(a). A summary of these [number redacted] cases is provided 

in Appendix Two. None indicated either a failure to Identify/Monitor People with Potential to Exceed 

100 mrem or Unavailable/Lost Personal Monitoring Records.

7.2.2 Evaluation of Bounding Ambient Environmental Internal Doses

NIOSH can bound ambient environmental doses to Sandia National Laboratory personnel using the 

methodology described in ORAUT-TKBS-0037, Site Profile for Sandia National Laboratories in 

Albuquerque, New Mexico, and the Tonopah Test Range, Nevada. Alternatively, the assignment of 

intakes that would result in doses of 100 mrem CEDE would be bounding for all sources of internal 

dose, including the relatively small (a few mrem) ambient environmental contribution.

7.2.3 Methods for Bounding Internal Dose at SNL-A

The following subsections summarize the methods for bounding internal dose at Sandia Albuquerque.

Based on its review of radioactive material use at Sandia-Albuquerque and the associated radiation 

protection programs, NIOSH has concluded that intakes for unmonitored workers with access to 

controlled areas were unlikely to have resulted in committed effective dose equivalents (CEDE) in 

excess of 0.1 rem per year. This conclusion is not wholly based upon the implementation of 10 C.F.R. 

§ 835.402, but rather on a review of exposure monitoring records for individuals involved in high-risk 

radiological activities at the site during the period under evaluation. More specifically:

• The total assigned internal dose (CEDE) for all employees combined for the 15-year period from 

1997 through 2011 is 77 mrem (Section 6, Table 6-1f). 

• A review of available breathing zone bioassay data (Section 7.2.1.2) indicates that the median 

quantity of radioactive material available for internal uptake to individuals located alongside 

personnel performing high risk radiological work would correspond to an internal dose of 0.5

mrem per work event or per work day. This dose quantity assumes that the individual is present 

within the work area and is not wearing respiratory protection (which is typically the case). The 

fact that such individuals would be afforded a significant reduction in intake potential by the 

separation between the actual work and the area that can be occupied without the same level of 

radiological controls is not considered in this assessment. In any case, consistent with the 

recorded internal dose discussed above, it is not likely that an individual would be able to receive 

100 mrem per year of internal exposure under these conditions (i.e., an individual would have to 

be present for 200 events, based on the median dose, to receive an exposure in excess of 100 mrem 

in a year).
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Therefore, in the absence of internal dosimetry records indicating the contrary, NIOSH may assume 

that intakes by workers did not result in doses exceeding 0.1 rem CEDE.

Bounding intake quantities corresponding to a CEDE of 0.1 rem may be defined as 2% of the 

stochastic Annual Limit on Intake (ALI), or SALI. The ALI is defined in 10 C.F.R. § 835.2. The 

SALI is the value of intake of a given radionuclide in a year by the Reference Man (ICRP Pub. 23, 

1975) that would result in a CEDE of 5 rem (0.05 sievert).

An unmonitored worker with access to controlled areas may be assumed to have been exposed to 2% 

of the SALI per year from any of these potential radionuclides. For purposes of bounding dose 

reconstruction, the radionuclide and lung clearance class selected for each year’s intake would be the 

one resulting in the highest dose to the organ of interest at the time of cancer diagnosis. As indicated 

in Section 7.2.1.2, available air sample data indicate that the potential for exposure to airborne alpha 

activity is more than 100 times more likely than beta/gamma. For this reason, only alpha-emitting 

radionuclides need be considered when applying the 2% SALI intake.

Intakes of radon and their progeny by unmonitored workers with the potential for exposure may be 

bound by assuming an exposure of 40 DAC-hr per year. During the period under evaluation, 

10 C.F.R. pt. 835 permitted the DAC values for Rn-220 and Rn-222 to be replaced by 1 working level 

(WL) and 1/3 WL, respectively. DCAS-TIB-011 provides a method for converting exposures 

expressed in working level months (WLM) into individual organ doses. A WLM is equivalent to 170 

WL-hours. Therefore, 40 DAC-hrs is equivalent to 0.24 WLM for Rn-220 and 0.078 WLM for 

Rn-222. 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion

In the SEC-00188 Sandia-Albuquerque ER, NIOSH defined a single class of employees for which 

NIOSH cannot estimate radiation doses with sufficient accuracy (NIOSH, 2012). The class included 

all employees of the Department of Energy, its predecessor agencies, and their contractors and 

subcontractors who worked at the Sandia National Laboratory in Albuquerque, New Mexico from 

January 1, 1963 through December 31, 1994. A subsequent addendum dated July 26, 2018 extended 

that class through December 31, 1996 (NIOSH, 2018).

It is NIOSH’s position that, regardless of whether Sandia could be shown to be in full compliance 

with 10 C.F.R. pt. 835, the salient sections of the regulation regarding monitoring and record retention 

(10 C.F.R. § 835.402 and 10 C.F.R. § 835.702) were in fact bounding of the actual exposure 

conditions at SNL-A for individuals without monitoring data indicating otherwise. Therefore, in the 

absence of internal dosimetry records, NIOSH may assume that intakes by workers lacking 

monitoring data to the contrary did not result in doses exceeding 0.1 rem CEDE.

In conclusion, for the period of this evaluation (January 1, 1997 through May 21, 2011), NIOSH finds 

that it has access to sufficient information to: (1) estimate the maximum radiation dose for every type 

of cancer for which radiation doses are reconstructed, and that could have been incurred in plausible 

circumstances by any member of the class; or (2) estimate radiation doses of members of the class 

more precisely than an estimate of maximum dose.
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7.4 Evaluation of Petition Basis for SEC-00188

The following assertion was made on behalf of petition SEC-00188 for Sandia National Laboratories:

Assertion: The petitioner asserted that [job title redacted] working at SNL-A were tasked with 

working in and around radioactive hazard areas and machines. Duties listed included the [job duties 

redacted]. He (and two other employees via affidavit) asserted that, at times, external monitoring 

devices were not properly worn and that no internal monitoring was performed. In addition, results 

received following requests for external monitoring records have been incomplete.

Response: During the course of the previous evaluation (NIOSH, 2012) and the subsequent 

Addendum (NIOSH, 2018), NIOSH found that the issues identified by the petitioner required further 

evaluation and that an expansion of the evaluated class was justified. NIOSH found that from January 

1, 1963 through December 31, 1994 (initial petition) and from January 1, 1995 through December 31, 

1996 (addendum), potential internal doses associated with SNL-A work were not completely known 

and access to internal monitoring data and program information was limited. This current evaluation 

(covering the remaining petitioned period from January 1, 1997 through May 21, 2011) focuses only 

on internal monitoring because the prior evaluation determined that reconstruction of external dose 

was feasible.

Captured site memos document multiple [job category redacted] personnel concerns of exposure 

potential and inadequate monitoring dating back to mid-1992 (if not earlier). During the course of an 

exposure event investigation in April 1991 (Tritium, 1991), it was determined that [job category 

redacted] personnel unexpectedly had positive tritium bioassay results. The source of exposure was 

ultimately determined to be tritium [description redacted] (unrelated to the original event). Tritium 

bioassay samples were collected from all [job category redacted] and a total of 80 mrem was assigned 

to [number redacted] individuals. All other individuals were assigned a dose of 0 mrem.

A July 2, 1992 document describes meetings with [job category redacted] personnel to discuss 

exposure concerns associated with the movement of materials (Stanley, 1992). [Number redacted] 

individuals associated with the event were monitored via urine bioassay samples, whole-body and 

lung counting (whole-body and lung counts were performed at Los Alamos National Laboratory). 

Whole-body and lung counts indicated “no abnormal activities with respect to background” while 

uranium urine samples for [number redacted] individuals indicated low but detectable U-234 ([number 

redacted]) and U-238 ([number redacted]). Ultimately, less than 1 mrem CEDE was assigned. The 

observed contamination during the [work category] work was determined to be radon daughters 

trapped within clothing.

The leaking tritium [description redacted] events reinforced unmonitored [job category redacted] 

personnel’s concerns regarding their radiological exposure potential while executing their assigned 

tasks at SNL. Specific concerns noted by them at that time included wanting to know what 

measurements could be made immediately to evaluate possible uptake of radioactive materials by [job 

category redacted] personnel. In addition, there were concerns regarding a lack of adequate 

radioactive material-handling procedures.

Several follow-up memos from October, 1992 (Internal Dosimetry, 1992-1993, PDF pp. 6, 8, 12, 14) 

further document [job category redacted] personnel’s continued concerns for potential exposure and 

monitoring inadequacy. These documents note that a meeting was held on October 8th, 1992 to 

discuss [job category redacted] participation in the SNL’s Internal Radiation Dosimetry Program.
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Topics on the agenda included: 

• Current [job category redacted] guidance for entry into contaminated or airborne-activity areas

• [Job category redacted] concerns about internal radiation dosimetry

• Required bioassay monitoring for all [job category redacted] personnel 

• When routine bioassay monitoring is necessary 

• The Incident Sampling Procedure and suggested revisions 

As a result of that meeting, a follow-up memo was issued on October 12, 1992 showing that [job 

category redacted] management and SNL Internal Dosimetry personnel agreed upon the following 

(Internal Dosimetry, 1992-1993, PDF p. 8):

• A baseline urinalysis and whole-body count would be required for all current and new [job 

category redacted] personnel. 

• [Job category redacted] personnel were to inform their department manager of any suspected 

internal exposure to radioactive materials and of involvement in any radiological 

incident/accident, such as an inhalation, personal contamination, or skin break that could result in 

the intake of radioactive materials. Bioassay sampling may be required at that time. The 

"Incident Sampling" procedure (PRDP-21-04) would be followed in handling these incidents. 

• [Job category redacted] personnel would participate in a routine bioassay program (i.e., wholebody counts and urinalysis would be required on an annual basis). Lead Internal Dosimetry 

personnel would calculate appropriate bioassay frequency if annual screening was not deemed 

sufficient. A termination whole-body count and urinalysis would be required for all [job category 

redacted] personnel. 

• If routine bioassays of radiation workers who performed "hands-on" work indicated positive 

exposures, required bioassays would be expanded to include any [job category redacted] personnel 

who may have been present when the exposures occurred. Air sampling and contamination 

surveys would also be used in determining if special bioassays were needed. 

• An Internal Dosimetry staff member would make arrangements with [designated [job category 

redacted] representatives] to accompany [job category redacted] personnel on routine duties in 

Area V. This would enable Internal Dosimetry staff to evaluate the necessity of a greater 

monitoring frequency in the routine bioassay program. 

• The draft "Incident Sampling" procedure, PRDP-21-04 was reviewed by all present. The only 

necessary edit was a clarification of "skin break" guidance for individuals. 

Another October 1992 memo (Internal Dosimetry, 1992-1993, PDF p. 12) from SNL’s Radiation 

Dosimetry Program Lead confirmed the above agreements. It also reiterated that urinalysis and 

whole-body counting would be performed annually on all [department name redacted] personnel and 

that additional, appropriate bioassay would be performed if any personnel were directly involved in an 

incident or in the event that reportable dose was received by any non-Department monitored worker 

with whom that employee was involved. This memo also noted that the Fiscal year 1993 budgets 

would not cover total program costs and negotiations were still needed.
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Following the aforementioned events and agreements, bioassay samples were submitted by 37 [job 

category redacted] individuals. However, these samples were all submitted to CEP2 and, as such, the 

results were determined to be invalid. It does not appear that the individuals submitting these samples 

were ever resampled. An evaluation of the CEP incident (CEP, 1995) indicated that of the 533 total 

samples submitted to CEP:

2 Beginning in 1992, the Santa Fe company Controls for Environmental Pollution (CEP) was contracted to provide part of 

SNL-A’s bioassay analytical services. CEP tested approximately 500 employee urine samples for SNL-A between 1992 

and 1994. SNL-A officials stopped using CEP’s services in 1994 because quality control testing raised questions about the 

reliability of CEP’s reports. It is NIOSH’s policy that all data provided by CEP are unacceptable for EEOICPA dose 

reconstruction use.

1. 461 were baseline samples

2. 39 individuals sampled for cause but other sufficient data indicated no exposure

3. 24 individuals that were being resampled due to exposure potential at Sandia 

4. 10 individuals that were being resampled due to exposure during [action redacted].

Individuals in category 1 and 2 were not resampled. It is likely that the [job category redacted] would 

have been in these categories. 

During the period from January 1, 1997 to May 11, 2011, there are no internal monitoring records for 

any [job category redacted] personnel based on a comparison of the listing of [job category redacted] 

personnel provided by Sandia (Personnel, 2014) against the WebDose extract (WebDose, 2018). An 

interview with a [function name redacted] manager indicated that this is consistent with procedures 

and [job category redacted] work status during that period. While [job category redacted] workers are 

given general employee training (GERT), they are not considered radiological workers (Personal 

Communication, 2018a). As for all non-radiological workers, [job category redacted] personnel 

typically do not reside in close proximity to active radiological operations involving unsealed 

radioactive materials. [Description redacted] for radiological work are typically [description redacted] 

with [job category redacted] personnel occupying areas outside the [location redacted]. The analysis 

in Section 7.2.1.2 used air-monitoring data for individuals working inside radiological areas without 

considering any respiratory protection that was worn. [Job category redacted], who are stationed 

outside of these radiological work areas, would be subject to even lower exposure levels.

In summary, as indicated in Section 7.2.3, internal exposure to unmonitored individuals can be 

bounded by application of a presumptive annual exposure of 100 mrem CEDE consistent with the 

monitoring threshold contained in 10 C.F.R. pt. 835, and as supported by available radiological survey 

data.

 
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7.5 Other Potential SEC Petition Issues Identified During the Evaluation

During the feasibility evaluation for SEC-00188, a number of issues were identified that needed 

further analysis and resolution. The issues that remain germane to this Addendum 2 evaluation are 

discussed below:

• ISSUE: Use of Air-Monitoring Data in Dose Estimation is Problematic

RESPONSE: NIOSH acknowledges that retrieval of air-monitoring data continues to be 

problematic for the period under evaluation. However, the air-monitoring data that have been 

retrieved support the supposition in Section 7.2.3 that internal exposure to an individual in excess 

of 100 mrem per year is unlikely.

• ISSUE: Some Claimant Data Supplied by SNL Has Been Incomplete

RESPONSE: Issues related to the irretrievability of claimant internal monitoring are discussed in 

Section 7.1.1.

• ISSUE: Employee Concerns about Availability of Data Related to a Radiological Incident

RESPONSE: Two employee concerns were raised during the preparation of this addendum. They 

were both raised in a phone interview with NIOSH and ORAU Team personnel to specifically 

address these concerns (Personal Communication, 2018b). The concerns addressed are:

- An individual with radiological worker training performed work (described as [nature of work 

redacted]) in [location redacted], but was not issued [description redacted]. NIOSH has 

requested this individual’s exposure records and confirmed that the individual was issued 

[description and date ranges redacted]. The only exception was the period [date range 

redacted], during which time no [description redacted] was issued. The absence of issued 

[description redacted] between [date range redacted] would not preclude the performance of a 

claimant-favorable dose reconstruction because there is available co-worker data for this 

period that may be used (ORAUT-OTIB-0072).

- During work on a [description redacted] system, a [action and consequence redacted]. The 

RCT monitored the release point with a swab and indicated that the swab ‘set the meter off 

scale.’ The RCT stopped the job and instructed the individuals to submit bioassay samples for 

seven days. Prior to the seven days passing, the RCT indicated that the meter was not 

calibrated correctly and that bioassay samples would no longer need to be collected. The 

concern raised was that the workers were never provided the results of the bioassay samples. 

NIOSH has obtained monitoring records for all [number redacted] individuals and confirmed 

the presence of closely-spaced tritium bioassay samples for all [number redacted] individuals 

in [date redacted] (which is consistent with the time frame indicated for the event). Sandia did 

not assign any internal dose based on these samples (i.e., they are indicative of exposure below 

the reporting levels). A claimant-favorable dose reconstruction would be able to be performed 

using these bioassay data.
SEC-00188 Addendum 2 (1997-2011) 04-01-19 Sandia National Laboratories

7.6 Summary of Feasibility Findings for Petition SEC-00188

This report provides feasibility conclusions for completing dose reconstructions for employees at the 

SNL-A site from January 1, 1997 through May 21, 2011. NIOSH found that the available monitoring 

records, process descriptions, and source term data available are sufficient to complete dose 

reconstructions for the evaluated class of employees.

Table 7-2 summarizes the results of the feasibility findings at Sandia National Laboratories - 

Albuquerque during the period from January 1, 1997 through May 21, 2011. 

Table 7-2: Summary of Feasibility Findings for the SEC-00188 Addendum 2 

Source of Exposure Reconstruction Feasible for 

January 1, 1997-May 21, 2011? (Yes or No) 

Internal (all radionuclides) Yes

External (Gamma, Beta, Neutron, 

Occupational Medical X-ray)

Yes*

* External dose reconstruction feasibility was previously evaluated and presented in the

2012 Evaluation Report (NIOSH, 2012). No information or materials captured since the

2012 evaluation alter its conclusions.

As of January 7, 2019, a total of 275 claims have been submitted to NIOSH for individuals who 

worked at SNL-A during the period under evaluation in this report. Dose reconstructions have been 

completed for 233 individuals (~85%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00188 

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c) (3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those employees who were employed for a number 

of work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

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This present evaluation is specific to internal dose reconstruction feasibility at SNL-A for the period 

from January 1, 1997 through May 21, 2011. NIOSH concludes that it has access to sufficient 

information to estimate the maximum radiation dose for every type of cancer for which radiation 

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

of the class for the period from January 1, 1997 through May 21, 2011. 

NIOSH’s evaluation determined that it is feasible to estimate radiation dose for members of the 

NIOSH-evaluated class with sufficient accuracy based on the sum of information available from 

available resources. Therefore, a health endangerment determination is not required. 

9.0 Class Conclusion for Petition SEC-00188

Based on its full research of the class under evaluation, NIOSH found no part of said class for which it 

cannot estimate radiation doses with sufficient accuracy. This class includes all on-site personnel who 

worked at the Sandia National Laboratory-Albuquerque site from January 1, 1997 through May 21, 

2011. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the SRDB, for information relevant to 

SEC-00188. In addition, NIOSH reviewed its NOCTS dose reconstruction database to identify 

EEOICPA-related dose reconstructions that might provide information relevant to the petition 

evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 

standards of performance in determining the feasibility or infeasibility of reconstructing radiation dose 

for the class under evaluation. 
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10.0 References

10 C.F.R. pt. 835, 10 C.F.R. 835, Electronic Code of Federal Regulations; U.S. Federal Government; 

gpo.gov; current as of September 12, 2018; SRDB Ref ID: 173737

Alpha BZ Analysis, 2019, Analysis of SNL Alpha BZ Data, T. LaBone, Oak Ridge Associated 

Universities; March 21, 2019; SRDB Ref ID: 175692

Assessment, 1996, Evaluation of Radiation Protection Internal Dosimetry (RPID) Program Manual 

and Procedures for Sandia National Laboratories, external assessment performed by K. W. Skrable 

for Sandia National Laboratories; March 20, 1996; SRDB Ref ID: 136875

Assessment, 1999, Evaluation of Radiation Protection Internal Dosimetry (RPID) Program Manual 

and Procedures for Sandia National Laboratories, external assessment performed by K. W. Skrable 

for Sandia National Laboratories; March 30, 1999; SRDB Ref ID: 23908

Assessment Summaries, 2019, Sandia National Laboratories Assessment Summaries, Excel sheet 

compiled by Oak Ridge Associated Universities based on internal and external assessments conducted 

from 1997-2012 for Sandia National Laboratories; compiled February 28, 2019; SRDB Ref ID: 

175491

BZ Data1, 2018, File Inventory of BZ Air Sample Data Sheets – Round 1 Data Capture, Sandia 

National Laboratories; March 2018; SRDB Ref ID: 175487

BZ Data2, 2018, File Inventory of BZ Air Sampling Raw Data Sheets - Round 2 Data Capture, Sandia 

National Laboratories; May 2018; SRDB Ref ID: 175488

BZ Data3, 2019, File Inventory of BZ Air Sampling Raw Data Sheets - Round 3 Data Capture, Sandia 

National Laboratories; March 2019; SRDB Ref ID: 35248 (Note: Additional 1999 data captured in 

2019 added to relevant existing SRDB file.)

CEP, 1995, Report: Radiation Protection Internal Dosimetry Project and Invalid Bioassays by C.E.P., 

Sandia National Laboratories; May 1995; SRDB Ref ID: 170104

DAC-hr, 1999, Monthly DAC-hr and Dose Reports, 1999, Sandia National Laboratories; various dates 

from April through December 1999; SRDB Ref ID: 31170

DAC-hr, 2000, Monthly DAC-hr and Dose Reports, 2000, Sandia National Laboratories; various dates 

from January through September 2000; SRDB Ref ID: 136928

DAC-hr, 2000-2001, Monthly DAC-hr and Dose Reports, 2000-2001, Sandia National Laboratories; 

various dates from November 2000 to June 2001; SRDB Ref ID: 136928

DAC-hr, 2001a, Monthly DAC-hr and Dose Reports, 2001, Sandia National Laboratories; March 

2001; SRDB Ref ID: 136982

DAC-hr, 2001b, Monthly DAC-hr and Dose Reports, 2001, Sandia National Laboratories; November 

2001; SRDB Ref ID: 136911
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DAC-hr, 2001c, Monthly DAC-hr and Dose Reports, 2001, Sandia National Laboratories; December 

2001; SRDB Ref ID: 136909

DAC-hr, 2002a, Monthly DAC-hr and Dose Reports, 2002, Sandia National Laboratories; January

2002; SRDB Ref ID: 35843

DAC-hr, 2002b, Monthly DAC-hr and Dose Reports, 2002, Sandia National Laboratories; various 

dates in March through November 2002; SRDB Ref ID: 136929

DCAS-TIB-011, Dose Conversion Factors for Radon WLM, National Institute for Occupational 

Safety and Health, Division of Compensation Analysis and Support; June 28, 2018; SRDB Ref ID: 

175105

DOE/EH-0575, 1997, DOE Occupational Radiation Exposure – 1997 Report, U.S. Department of 

Energy, Office of Worker Safety and Health; DOE/EH-0575; 1997; SRDB Ref ID: 64900

EPA FGR-11, 1988, Limiting Values of Radionuclide Intake and Air Concentration and Dose 

Conversion Factors for Inhalation, Submersion, and Ingestion, Federal Guidance Report No. 11, U.S. 

Environmental Protection Agency; 1988; SRDB Ref ID: 8251

Hazard Summary, 2015, SNL-NM Hazard Summary, Lapel Monitoring Access Database, Sandia 

National Laboratories, February 17, 2015; SRDB Ref ID: 141278

HCF, 1995, NESHAP Radionuclide Compliance Project Summary Report for SNL/NM (Hermes III, 

HCF, ACRR, SPR III), Sandia National Laboratories; April 28, 1995; SRDB Ref ID: 19309

HP Log, 1961-1962, Health Physics Log for SPR I, #1, 1 March 1961 – 31 December, 1962, Sandia 

National Laboratories; various dates from March 1, 1961 to December 31, 1962; SRDB Ref ID: 

23935 – UCI

HP Log, 1966-1967, Health Physics Log for SPR I and SPR II, Log 3, 12 October 1966 – 31 October, 

1967, Sandia National Laboratories; various dates from October 12, 1966 to October 31, 1967; SRDB 

Ref ID: 100692 – UCI

ICRP Pub. 23, 1975, Report of the Task Group on Reference Man, International Commission on 

Radiological Protection; Pergamon Press; 1975; SRDB Ref ID: 22735

Internal Dosimetry, 1992-1993, Collated Memos Issued by Sandia National Laboratory Internal 

Dosimetry Program, Sandia National Laboratory, various dates in 1992 and 1993; SRDB Ref ID: 

22321

Mo-99, 1998, Annular Core Research Reactor (MOLY-99) Source Document, Sandia National 

Laboratories; April 22, 1998; SRDB Ref ID: 20442

NIOSH, 2012, SEC Petition Evaluation Report for Petition SEC-00188, Sandia National 

Laboratories-Albuquerque; National Institute for Occupational Safety and Health (NIOSH); [February 

21, 2012; SRDB Ref ID: 115521
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NIOSH, 2018, SEC Petition Evaluation Report for Petition SEC-00188, Addendum, Sandia National 

Laboratories-Albuquerque; National Institute for Occupational Safety and Health (NIOSH); July 26, 

2018; SRDB Ref ID: 172532

ORAUT-OTIB-0066, Calculation of Dose from Intakes of Special Tritium Compounds, Oak Ridge 

Associated Universities; April 26, 2007; SRDB Ref ID: 31421

ORAUT-OTIB-0072, External Coworker Dosimetry Data for the Sandia National Laboratory in 

Albuquerque, New Mexico, Oak Ridge Associated Universities; September 26, 2008; SRDB Ref ID: 

49941

ORAUT-RPRT-0053, Analysis of Stratified Coworker Datasets, Rev. 02, Oak Ridge Associated 

Universities, October 8, 2014; SRDB Ref ID: 136245

ORAUT-RPRT-0071, External Dose Coworker Methodology, Rev. 00, Oak Ridge Associated 

Universities, July 2, 2015; SRDB Ref ID: 145135

ORAUT-RPRT-0096, Multiple Imputation Applied to Bioassay Coworker Models, Rev. 00, Oak 

Ridge Associated Universities, January 24, 2019; SRDB Ref ID: 175396

ORAUT-TKBS-0037, Site Profile for Sandia National Laboratories in Albuquerque, New Mexico, 

and the Tonopah Test Range, Nevada, Rev. 00, Oak Ridge Associated Universities; June 22, 2007; 

SRDB Ref ID: 32531

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

California, Rev. 01, Oak Ridge Associated Universities; April 28, 2014; SRDB Ref ID: 132244

PAS-Survey, 2015, PAS Survey Spreadsheet, Excel spreadsheet, Sandia National Laboratories; 

January 29, 2015; SRDB Ref ID: 141277

Personal Communication, 2013a, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; January 23, 2013; 

SRDB Ref ID: 125804

Personal Communication, 2013b, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; January 23, 2013; 

SRDB Ref ID: 125804

Personal Communication, 2014a, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 9, 2014; 

SRDB Ref ID: 142257

Personal Communication, 2014b, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 9, 2014; 

SRDB Ref ID: 141878

Personal Communication, 2014c, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 9, 2014; 

SRDB Ref ID: 141879
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Personal Communication, 2014d, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 9, 2014; 

SRDB Ref ID: 141877

Personal Communication, 2014e, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 10, 2014; 

SRDB Ref ID: 141834

Personal Communication, 2014f, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 10, 2014; 

SRDB Ref ID: 141827

Personal Communication, 2014g, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 10, 2014; 

SRDB Ref ID: 141828

Personal Communication, 2014h, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 10, 2014; 

SRDB Ref ID: 141832

Personal Communication, 2014i, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 10, 2014; 

SRDB Ref ID: 141833

Personal Communication, 2014j, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 10, 2014; 

SRDB Ref ID: 141875

Personal Communication, 2014k, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 10, 2014; 

SRDB Ref ID: 141830

Personal Communication, 2014l, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 11, 2014; 

SRDB Ref ID: 141834

Personal Communication, 2014m, Personal Communication with Sandia National Laboratories 

Current or Former Employee; In-person interview by NIOSH and ORAU Team; September 11, 2014; 

SRDB Ref ID: 142254

Personal Communication, 2017a, Personal Communication with Sandia National Laboratories 

Current or Former Employee; Telephone interview by NIOSH and ORAU Team; October 11, 2017; 

SRDB Ref ID: 168055

Personal Communication, 2017b, Personal Communication with Sandia National Laboratories 

Current or Former Employee; Telephone interview by NIOSH and ORAU Team; October 25, 2017; 

SRDB Ref ID: 168054
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Personal Communication, 2017c, Personal Communication with Sandia National Laboratories 

Current or Former Employee; Telephone interview by NIOSH and ORAU Team; November 21, 

2017; SRDB Ref ID: 169443

Personal Communication, 2017d, Personal Communication with Sandia National Laboratories 

Current or Former Employee; Email interview questions by NIOSH and ORAU Team; November 30, 

2017; SRDB Ref ID: 168389

Personal Communication, 2018a, Personal Communication with Sandia National Laboratories 

Current or Former Employee; Telephone interview by NIOSH and ORAU Team; January 29, 2018; 

SRDB Ref ID: 169937

Personal Communication, 2018b, Personal Communication with Sandia National Laboratories 

Current or Former Employee; Telephone interview by NIOSH and ORAU Team; December 20, 

2018; SRDB Ref ID: 175475

Personnel, 2014, List of [job category redacted] Personnel, Sandia National Laboratories; September 

12, 2014; SRDB Ref ID: 136896

RMWMF, 1998a, Radioactive and Mixed Waste Management Facility Source Document, Sandia 

National Laboratories, April 9, 1998; SRDB Ref ID: 20476

RMWMF, 1998b, Discussion with RMWMF Personnel Regarding Bioassay, Sandia National 

Laboratories, February 3, 1998; SRDB Ref ID: 35484

RPID, 1994, Entering Internal Dose Equivalents into Sandos, Sandia National Laboratories; 

November 10, 1994; SRDB Ref ID: 35807

RPID, 1996, Radiation Protection Internal Dosimetry Program Overview, Sandia National 

Laboratories; August 27, 1996; SRDB Ref ID: 22095

RPID, 1997, Personal Air Sample Results Processing, Sandia National Laboratories; July 16, 1997; 

SRDB Ref ID: 35808

RPID, 1999, Radiation Protection Internal Dosimetry Records Management Life Cycle, Sandia 

National Laboratories; October 1, 1999; SRDB Ref ID: 136870

RPO, 1996, Document Change Notice for RPO-04-420, Air Sampling, Sandia National Laboratories; 

March 18, 1996; SRDB Ref ID: 170197

RPP, 1999, Radiation Protection Program, 10 CFR Part 835, Occupational Radiation Protection, 

Sandia National Laboratories; May 20, 1999; SRDB Ref ID: 22080

RPP, 2011, Radiation Protection Program, 10 CFR Part 835, Occupational Radiation Protection, 

Sandia National Laboratories; April 29, 2011; SRDB Ref ID: 136922, PDF p. 19

RPP Plan, 1994, Radiation Protection Program Plan, 10 CFR Part 835, Occupational Radiation 

Protection, Sandia National Laboratories; December 29, 1994; SRDB Ref ID: 22086
SEC-00188 Addendum 2 (1997-2011) 04-01-19 Sandia National Laboratories

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SAR, 1995, Safety Analysis Report (SAR) for the Sandia Pulsed Reactor Facility (SPRF), 

SAND2003-2805, Sandia National Laboratories; October 1995; SRDB Ref ID: 23963 - UCI, OUO

SNL, 1996, Radiological Survey Documentation-Radiation Protection Operations Department 

Radiation Protection Operating Procedure, RPO-04-425, Issue No. 04; Sandia National Laboratories 

(SNL); effective June 5, 1996; SRDB Ref ID: 170190

SNL, 1997, Personal Air Sample Results Processing, RPID-20-04, Issue No. 01; Sandia National 

Laboratories (SNL); effective July 16, 1997; SRDB Ref ID: 136876, PDF pp. 227-231

SNL, 1998, Final Draft, Sandia National Laboratories SNL/NM Facilities and Safety Information 

Document, Volume II, Sandia National Laboratories; November 1998; SRDB Ref ID: 22791

SPRF, 1961, Hazards of the Sandia Pulsed Reactor Facility (SPRF), SC-4357A(RR) report prepared 

by the Sandia Corporation for the U.S. Atomic Energy Commission; February 1961; SRDB Ref ID: 

172402

SPRF, 2005, Report of the Defense Science Board Task Force on Nuclear Weapon Effects Test, 

Evaluation, and Simulation, Office of the Under Secretary of Defense for Acquisition, Technology, 

and Logistics, Washington, DC; April 2005; SRDB Ref ID: 80376

SPRF, 2007, Sun Sets on Sandia Pulsed Reactor, Sandia National Laboratories news release; 

September 4, 2007; SRDB Ref ID: 171777

Stanley, 1992, Memorandum of Record, A. L. Stanley, Sandia National Laboratories; July 2, 1992; 

SRDB Ref ID: 35041, PDF pp. 83-84

Stanley, 1993, Interim Internal Dosimetry Policy, correspondence; A. L. Stanley; December 20, 1993; 

SRDB Ref ID: 23894

TA-V, 2001, TA-V Bioassay Program, memo to file, Sandia National Laboratories; May 30, 2001; 

SRDB Ref ID: 31293

TBD, 1995, Technical Basis Document: Radiation Protection Measurements Department, Radiation 

Protection Internal Dosimetry Project, Sandia National Laboratories; October 31, 1995; SRDB Ref 

ID: 136878

TBD, 1996, Sandia Internal Dosimetry Technical Basis Document, Rev. 2, Sandia National 

Laboratories; November 1, 1996; SRDB Ref ID: 135882

Tritium, 1991, Tritium Contamination in Building 984, Tech Area IV, Sandia National Laboratories; 

April 23, 1991; SRDB Ref ID: 18272

Urinalysis, 1994, Laboratory Urinalysis Data Files for 1994, Sandia National Laboratories; various 

types of records and dates in 1994; SRDB Ref ID: 35329

Urinalysis, 1995a, Laboratory Urinalysis Data Files for 1995, Sandia National Laboratories; various 

types of records and dates in 1995; SRDB Ref ID: 35107
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Urinalysis, 1995b, Laboratory Urinalysis Data Files for 1995, Sandia National Laboratories; various 

types of records and dates in 1995; SRDB Ref ID: 35105

Urinalysis, 1995c, Laboratory Urinalysis Data Files for 1995, Sandia National Laboratories; various 

types of records and dates in 1995; SRDB Ref ID: 35106

Urinalysis, 1996, Laboratory Urinalysis Data Files for 1996, Sandia National Laboratories; various 

types of records and dates in 1996; SRDB Ref ID: 35386

Urinalysis, 1999, Laboratory Urinalysis Data Files for 1999, Sandia National Laboratories; various 

types of records and dates in 1999; SRDB Ref ID: 35281

VSDS, 2015, Listing of All Radiological Lapel Surveys in VSDS, Sandia National Laboratories, April 

28, 2015; SRDB Ref ID: 152510

WebDose, 2014, SNL WebDose (Formerly SANDOS) Bioassay Data Spreadsheet, Sandia National 

Laboratories, Radiation Protection Dosimetry Program to Oak Ridge Associated Universities (ORAU) 

Team; July 8, 2014; SRDB Ref ID: 133724

WebDose, 2015, Interpretation of Air Data in WebDose, email from Sandia National Laboratories, 

Radiation Protection Dosimetry Program to Oak Ridge Associated Universities (ORAU) Team; 

October 16, 2015; SRDB Ref ID: 175453

WebDose, 2014, WebDose Extract Dated 07/08/2014, Excel spreadsheets received on flash drive 

from Sandia National Laboratories – Albuquerque; database extract created July 8, 2014; SRDB Ref 

ID: 133724

WebDose, 2018, WebDose Extract Dated 05/02/2018, Excel spreadsheets received on flash drive 

from Sandia National Laboratories – Albuquerque; database extract created May 2, 2018; SRDB Ref 

ID: 172158
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Attachment One: Summary of Internal and External Assessments

NIOSH reviewed 20 internal and external assessments of the SNL-A radiation protection programs 

generated between 1997 and 2008 (see Section 7.2.1.3). The assessments were performed by Sandia 

personnel, SNL’s “External Advisory Board,” DOE’s Independent Oversight and Performance 

Assurance (in 2003, 2005 and 2008), and the Inspector General’s Office (in 2008). Table A1-1 

summarizes these assessments.

Table A1-1: Internal and External Assessments of the SNL-A Radiation Protection Programs

Document Title Year Findings and Comments SRDB 

Ref ID

Area Monitoring 

Checklists

1997 Contains area and contamination monitoring checklists: Bldg. 870 (Room 

1004); SPR Breezeway; HCF; Bldg. 905 Rm 1100G; PBFA-Z; Hermes III 

Exposure Cell; Bldg. 884 Rooms 1E and 10; Bldg. 805 Room 123.

One issue with CAM placement is noted, but indicates that source term 

changes had diminished the necessity for that CAM.

146852

Monitoring in the 

Workplace SelfAssessment

1997 Internal assessment of Program Content and Program Implementation. For 

Program Content: unclear links noted between the Radiation protection 

Program Manual (RPPM) and 10 C.F.R. 835 requirements; out-of-date 

Quality Functional Deployment (QFD) matrix maintenance; inconsistent 

procedure information; RPOs lacking review cycles. For Program 

Implementation: required surveys being performed; improperly monitored 

operation in Bldg. 884 (promptly corrected); an air-sampling procedure that 

was not being implemented (i.e., no air samples taken) because it had not 

been distributed (poor RPO and RPRE integration); inappropriate waste 

accumulation in the HCF and Building 805 Room 123.

146864

Radiation Protection -

Phase I Appraisal (98-I002)

1998 Nine concerns and one observation were documented. All are generally 

related to weaknesses in program documentation and delineation of roles 

and responsibilities. 

Contains a memo addressing in detail an ES&H finding regarding 

discrepancies between airborne concentration monitoring requirements and 

10 C.F.R. 835 DACs. The Dosimetry Subject Matter Expert (SME) pointed 

out the differences between stochastic and non-stochastic DACs, which 

resolved the issue originally raised. 

35469

Interim Report - ES&H 

and Quality Appraisal 

of the Radiation 

Protection Program.

1998 Several Strengths were noted along with some non-critical Observations. 

One Issue: The current 3-year limitation on staff augmentation contractors 

has increased the difficulty of recruiting and maintaining critical RP 

personnel.

146863

Rad Ops SelfAssessment - Radiation 

Standards Facility, 

Building 818

1998 Used SNL's Radiological Operation Self-Assessment Checklist. The 

checklist "follows the SNL's RPPM." Series of questions answered 

Y/N/NA. Passed with no problems identified short of one minor labeling 

issue that was noted and slated for correction.

146869

Report of Assessment 

of SNL Radiation 

Protection Program

1998 Internal review of Sandia Radiation Protection Program. Identified issues 

with configuration management for procedures and traceability of 

requirements implementation.

146871
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Document Title Year Findings and Comments SRDB 

Ref ID

Radiation Protection 

Safety Committee 

Triennial SelfAssessment Report

1999 Forty-five (45) findings were identified as potential minor non-compliances. 

These were in the areas of Entry Control, Training, Monitoring, Posting and 

Labeling, and Records. Of the 13 monitoring findings, 10 were related to 

deficiencies in either area monitoring or individual monitoring not being 

performed. The other 3 were related to monitoring being performed, but 

inadequately. No areas of improvement were identified in the review of 

RPPM monitoring chapters. The majority of deficiencies were personnel 

error (inattention to detail) and the RPSC will communicate lessons learned 

back to the line. All 4 records findings were the result of either records being 

lost or not properly created and managed; the cause of these findings were 

not the RP Program documentation process, but rather personnel error 

(inattention to detail). No findings were categorized as PAAA-significant 

non-compliances.

146866

Self-Assessment of 

Department 7124, 

Radiation Protection 

Line Support Team

2000 One Finding and 7 Observations. Issues related to survey documentation 

and area postings.

146872

Radiation Protection 

Operations & Support 

Self-Assessment 

Checklist

2001 One of the line self-assessments. Review of entry requirements, postings 

and survey documentation. No significant findings.

146865

Triennial SelfAssessment of the Rad 

Protection Source and 

Device Program

2001 No findings were identified as non-compliant with the RPPM, 10 C.F.R. 

835, or DOE N 441.1.

146874

Radiation Protection 

Safety Committee 

Triennial SelfAssessment Report

2002 Twenty-one (21) RPPM non-conformances identified, including: Work 

Planning and Controls (5); Training (5); Source Control (3); RadiationGenerating Device Control (5). All judged of minor consequence. No 

systemic or programmatic issues identified.

146867

External Advisory 

Board (EAB) Meeting 

of April 7-9, 2003

2003 Discussions and activities included: continuing efforts on retraining RCTs; 

shadowing visits with the RCTs; follow-up regarding internal audits and 

participation with the DOE-wide EFCOG Committee. EAB still concerned 

about the line organization in TA 4, the ES&H support team, and the RPP 

staff. The production on neutrons in the Z-machine facility became known 

to the Radiation Protection staff only in announcements in the Sandia 

Employee Newsletter and the local newspaper. The Board believes that these 

are examples of a less-than-proactive relationship between the TA 4 line 

organizations and the 3100 organization.

146855

External Advisory 

Board (EAB) Meeting 

of August 25-27, 2003

2003 Discussions and activities included: continuing efforts on retraining RCTs; 

shadowing visits with the RCTs; field visit to the sled track and the soil 

contamination area evaluation; continued follow-up regarding internal 

audits. Many favorable efforts noted regarding RCTs, RMWMF operations, 

and Hot Cell. Some suggestions and complaints, but nothing of a safety 

significance. The EAB is concerned about the line organization in TA 4, the 

ES&H support team, and the RPP staff; they should be strengthened and 

more proactive.

146856

External Advisory 

Board (EAB) Meeting 

of February 10-13, 

2003

2003 Discussions and activities included: internal self-assessment program; 

ALARA review at the RMWMF facility; follow-up on instrumentation 

calibration training for RCTs; the project leaders meeting; and tour of the 

Monzano bunkers.

146857

External Advisory 

Board (EAB) Meeting 

of October 6-8, 2003

2003 Discussion included: the sled track soil contamination area evaluation; 

neutron dosimetry in accelerator facilities (suggestions made for better 

monitoring approach; however, no outright accusations of missed 

exposures); laboratory layout and design; data bias questions related to 

liquid-scintillation counting.

146858
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Document Title Year Findings and Comments SRDB 

Ref ID

Radiation Protection 

Safety Committee 

Triennial SelfAssessment Report

2005 Roll-up report of the line self-assessments. The most significant results 

were the large increase in training non-conformances. The report notes 

upfront that "the reported non-conformances have minor safety significance 

in and of themselves. Personnel did not receive unnecessary radiation 

exposure, radioactive contamination did not spread out of established 

boundaries, and there was no loss-of-control of radioactive material."

146862

EAB Visit of April 25-

27, 2005

2005 Visit entailed: EAB Follow-up ALARA review of the RPLS Laboratory and 

Office Building; Building 1090 Design Review; Tech Area IV optimization 

of decisions regarding replacement or refurbishment of components for Z 

machine and RITS machine. 

146853

External Advisory 

Board Visit of October 

23-25, 2006

2006 Primarily called upon to investigate positive dosimeter readings. Actions 

included: review of glow curves; discussion of neutron exposures and 

dosimetry; Administrative Control Level (ACL) discussions held; status of 

ZR machine, ACRR, and SPR discussed.

146860

External Advisory 

Board Visit of August 

20-22, 2007

2007 Discussions included: development of the electronic radiation survey system 

(VSDS); WebREMS software system implementation in TA-V; Neutron 

Dosimetry & Neutron Spectral Measurements Phantoms; update of 

DOELAP accreditation issues; implementation of new (2007) 10 C.F.R. 835 

revisions; instrumentation funding; shadow visits; staff training; thoriated 

welding rods.

146859

Independent Oversight 

Inspection of 

Environment, Safety 

and Health Programs at 

the Sandia National 

Laboratory

2008 All findings were related to ES&H programs; there were no analyses 

specific to Radiation Protection Program elements.

80357
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Attachment Two: Summary of Pertinent NTS Reports

NIOSH reviewed the DOE Noncompliance Tracking System (NTS) for SNL-A 10 C.F.R. pt. 835 

violations, site responses, and corrective actions (see Section 7.2.1.3). Of the 171 SNL report titles 

listed, 72 were considered potentially relevant and reviewed. Table A2-1 summarizes the seven

reports considered pertinent to compliance with 10 C.F.R. § 835.402(c)(1) or 10 C.F.R. § 835.702(a). 

Table A2-1: Summary of NTS Reports Pertinent to 10 C.F.R. § 835.402(c)(1) or 10 C.F.R. § 835.702(a) Compliance

Title Summary SRDB 

Ref ID

Inspection of 

Environment, Safety 

and Health 

Management

The DOE Office of Independent Oversight reported 8 findings, one of which was the WM 

subcontractor did not have sufficient formality in the implementation of RC consistent 

with the ES&H manual (i.e., by not clearly identifying controls and job-specific RWPs that 

were documented and understood by the workers).

165468

Laboratories Wide 

Radiation Protection 

Self-Assessment for 

Compliance with 10 

C.F.R. § 835.102

1999 tri-annual review was completed, which included Self-Assessment Requirements 

Documents (SARDs).

165473

NTS Report for 

PNOV EA-1999-03

The DOE Office of Enforcement and Investigation, EH-10, conducted a review of the SNL 

Price Anderson Amendments Act program in March 1999. EH-10 analyzed a series of 

SNL events and activities that occurred during 1997 and 1998, and identified potential 

violations of DOE nuclear safety requirements.

165480

Neptunium (Np) 

Oxide Spill in 

Building 819

Multiple issues with a spill of Np-oxide and poor RP controls before and after incident; no 

RWP sign in; improper monitoring.

Radiological surveys conducted subsequent to the event indicated that there was no spread 

of contamination to uncontrolled areas. Bioassays conducted on

personnel involved with the work indicated that there was no internal intake of radioactive 

material. Personnel dosimetry readings show that there was no

measurable exposure to radiation during the event.

165491

Lapel Monitoring 

Not Performed 

during Waste 

Sorting Activities 

Radiological Work 

Permit Violations

On [date redacted], a waste-sorting team at the Radioactive Mixed Waste Management 

Facility (RMWMF) failed to wear lapel air monitors during one waste-sorting session, as 

required by the applicable Radiological Work Permit (RWP). The sorting team members, 

comprised of [numbers and job titles redacted], were wearing respirators. Based on room 

air sampling results, the team did not receive any internal exposure from the waste-sorting 

activity. The workers involved had previously worn lapel monitors along with their 

respirators during similar sorting evolutions.

165530

Internal Dosimetry 

Process

Failure to review 50 anomalous (unconfirmed positive) bioassays for 24 individuals from 

September 2009 to May 2012. Follow-up on these samples was not performed in a timely 

manner; however, a preliminary review conducted at the time the issue was identified 

indicated that no exposures in excess of the administrative control level (100 mrem) were 

likely. This discovery was made during a review of the Radiation Protection Dosimetry 

Project (RPDP) Internal Dosimetry Technical Basis Document (TBD).

165539

Repetitive 

Deficiencies in 

Radiological Work 

Control Practices 

and Control of 

Radioactive 

Materials

As a result of the SNL PAAA Review Committee screening, a number of events were 

documented via the SNL Radiological Process Improvement Reports (RPIRs). SNL 

submitted this NTS report to identify programmatic deficiencies associated with 

establishing and maintaining controls for radioactive materials, and the documentation, 

use, and adherence to technical work documents governing radiological work. Some 

deficiencies involved discovery of unlabeled radioactive materials stored outside 

radioactive materials areas. Exposure rates were very low.

165483
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Attachment Three: Data Capture Synopsis

Attachment Three is a summary of SRDB holdings that pertain to the SEC-00188 Addendum evaluation efforts. Table A3-1 includes documents that were 

captured between January 26, 2012 and February 28, 2019 for the purpose of evaluating the post-1994 years. These efforts are in addition to the data 

capture efforts previously detailed in Attachment One of the SEC-00188 Petition Evaluation Report. 

Table A3-1: Summary of Holdings in the SRDB for Sandia National Laboratories-Albuquerque Captured between January 26, 2012 and February 28, 2019

Data Capture Information General Description of Documents Captured Date Completed Uploaded

Sandia National Laboratories - Albuquerque, New Mexico Site and area-specific environmental reports, SANDOS and WebDose 

dosimetry databases, radiation protection and dosimetry procedures, 

bioassay requests, audits and assessments, a list of cancelled procedures, 

incident tracking, neutron measurements, air sample results, air sample 

DAC-hr and dose reports, bioassay reports, bioassay assignments, the 

technical basis for air-monitoring, specific bioassay procedures, DOELAP 

assessments, failure analyses, and accreditations, radiological technical 

work documents, radiological work permits, external Advisory Board 

meeting minutes, listings and bioassay results of selected personnel, 

radiological incident response, lapel sample results, the technical basis for 

implementing air sampling, and the response to Data Request SandiaFY18-004, complete radiation dose histories for selected workers, 

analysis of a bioassay review deficiency, the interpretation of WebDose 

results, tallies of captured breathing zone air sampling results, and a list of 

SNL, NM assessments.

Ongoing

(Additional BZ 

monitoring data 

have been 

requested.)

538

Cincinnati Public Library Fission and activation product production, Mo-99 production and waste 

processing, improved accelerator shielding calculations, photoneutron 

production, and neutron effects in gallium arsenide laser diodes.

05/02/2012 6

DOE Germantown A NIOSH researcher's notes from the review of classified documents. 03/18/2014 1

Internet - DOE Noncompliance Tracking System (NTS) NTS radiological incident reports including program deficiencies, 

contamination events, radiation exposure events, radioactive material 

releases, discoveries of legacy material and contamination, unqualified 

personnel performing surveys, radiological work permit violations, loss of 

control of radioactive material, radioactive material spills, posting 

violations, radioactive material quantities exceeding authorization bases, 

survey and monitoring deficiencies, quality assurance deficiencies, and 

training deficiencies. 

02/07/2017 73
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Data Capture Information General Description of Documents Captured Date Completed Uploaded

Internet - DOE Occurrence Reporting and Processing System 

(ORPS)

ORPS radiological reports including contamination events, unauthorized 

entries into radiological areas, procedural violations, failure to monitor 

shipping containers, radioactive material releases, radioactive material 

and contamination in uncontrolled areas, loose contamination found 

outside posted contamination areas, work conducted without required 

bioassay, unanticipated radiation exposures, loss of control of radioactive 

material, discoveries of legacy materials and contamination, identification 

of a previously unrecognized radiological area, radiological work permit 

violations, improper transfer and transportation of radioactive material, 

failures to follow procedures, tritium leaks from equipment, and a tritium 

stack release. 

06/29/2017 187

Internet - DOE Office of Scientific and Technical 

Information (OSTI) Energy Citations

The fourth revision of Sandia acronyms, initialisms, and abbreviations. 05/07/2012 1

Internet - DOE Office of Scientific and Technical 

Information (OSTI) Information Bridge

Institutional plans, emergency preparedness approach, building hazard 

analyses, management of depleted uranium, a laboratory history, 

transportation technology, and the environmental baseline.

04/17/2013 9

Internet - DOE Office of Scientific and Technical 

Information (OSTI) SciTech Connect

The proceedings of a fast burst reactor workshop. 05/01/2018 1

Internet - Google Z Machine fusion technology reports, a compliance self-assessment, 

occupational radiation exposure summaries, independent oversight audits, 

the FY 2014 ten-year site plan, the impact of switching to ICRP-74 

neutron flux to dose rate conversion factors, the characterization of a 

neutron irradiation system, a preliminary notice of violation for 1997 and 

1998 events, 1994 status reports on the implementation of the DOE 

radiological control manual, and the approach for determining the need 

for air sampling.

05/01/2018 22

Internet - National Institute for Occupational Safety and 

Health (NIOSH)

The February 2012 SEC-00188 Petition Evaluation Report, the May 2012 

designation of a class of Sandia employees, minutes of the 70th meeting 

of the Advisory Board on Radiation and Worker Health, July 2018 

Petition Evaluation Addendum Report, and the October 2018 HHS 

designation of additional members of the SEC. 

01/20/2019 5

Internet - Sandia National Laboratories - Albuquerque, New 

Mexico

Security requirements for contracted escorts. 12/18/2018 1

NIOSH A NIOSH Research Health Scientist's meeting and research notes, an 

ORAU Team Health Physicist's meeting notes, the tables list for the 

WebDose database, the tables list for the SANDOS database, a draft 

internal dosimetry database, and occupational dose records for 23 selected 

workers.

03/02/2016 11
SEC-00188 Addendum 2 (1997-2011) 04-01-19 Sandia National Laboratories

52 of 52 

Data Capture Information General Description of Documents Captured Date Completed Uploaded

ORAU Team The Sandia Site Profile, the report of a 2007 data capture trip, a 1995 to 

2011 Nuclear Materials Management and Safeguards System report, 

documented communications with key Sandia personnel, and a radiation 

protection self-assessment listing.

12/20/2018 25

Personal Files – [Name redacted] Office of Oversight radiological protection task team reports. 07/16/2018 1

Sandia National Laboratory - Livermore, California Interview notes of SNL, CA personnel. 04/29/2013 1

TOTAL Not applicable Not applicable 882