SEC Petition Evaluation Report

Petition SEC-00188, Addendum (1995-1996)

Report Rev Number: Addendum (1995-1996)

Report Submittal Date: July 26, 2018

Subject Expert(s): Tim Adler, Jim Bogard, Joe Guido

Site Expert(s): Not Applicable

Petition Administrative Summary

Petition Under Evaluation

Petition Number: SEC-00188 Addendum (1995-1996)

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, 1995 through May 21, 

2011.

NIOSH-Proposed Class(es) to be 

Added to the SEC:

All employees of the Department of Energy, its predecessor agencies, and its 

contractors and subcontractors who worked in any area at Sandia National 

Laboratories in Albuquerque, New Mexico, from January 1, 1995 through 

December 31, 1996, for a number of work days aggregating at least 250 work 

days, occurring either solely under this employment, or in combination with work 

days within the parameters established for one or more other classes of employees 

in the Special Exposure Cohort.

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 January 1, 1949–December 31, 1962

SEC-00188: Class added to the SEC for January 1, 1963–December 31, 1994

Related Evaluation Report Information

Report Title: SEC Petition Evaluation Report Petition SEC-00162

SEC Petition Evaluation Report Petition SEC-00188

DOE/AWE Facility Name: Sandia National Laboratories

ORAU Preparation and Review

ORAU Lead Technical Evaluator: Tim Adler

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

Peer Review Completed By:

[Signature on File]

Charles D. Nelson

July 26, 2018

SEC Petition Evaluation Reviewed 

By: [Signature on File]

James W. Neton

July 26, 2018

SEC Petition Evaluation Approved 

By: [Signature on File]

Stuart L. Hinnefeld

July 26, 2018
SEC-00188 Addendum (1995–1996) 07-26-2018 Sandia National Laboratories 

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Addendum (1995-1996) to Sandia National Laboratories-Albuquerque

(SEC-00188) Special Exposure Cohort Evaluation Report

Purpose and Scope of this Addendum (1995-1996) 

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

National Laboratories in Albuquerque, New Mexico (referred to as SNL-A throughout this report) that 

were previously unevaluated in the “SEC Petition Evaluation Report” for petition SEC-00188 

(NIOSH, 2012). In that report, NIOSH defined a single class of employees for which NIOSH cannot 

estimate radiation doses with sufficient accuracy. The previously-identified class includes 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, 1994. Also in that report, NIOSH concluded that it is feasible 

to reconstruct or bound external doses for all members of the NIOSH-proposed class for the entire 

SEC-00188 evaluation period (i.e., January 1, 1963 through May 21, 2011). 

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

date on several bases. NIOSH made the determination after considering data retrieval problems 

known to exist into the very early 1990s, limited internal monitoring results and 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 1994. For timeliness, and because of the known information 

sufficiency problems occurring well into 1994, NIOSH issued the SEC-00188 Evaluation Report 

recommending a class from January 1, 1963 through December 31, 1994, based on a presumption that 

additional internal monitoring documentation and an improved internal monitoring record database 

would become available to evaluate dose reconstruction feasibility for the remaining period qualified 

by the SEC-00188 petition. 

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

internal dose reconstruction feasibility for the remaining SEC-00188 petitioner-requested timeframe

(January 1, 1995 through May 21, 2011). The feasibility recommendations presented in this 

Addendum are for the January 1, 1995 through December 31, 1996 timeframe. Although NIOSH has 

performed an extensive evaluation of the entire remaining 1995–2011 petitioner-requested timeframe, 

recently identified issues in SNL-A’s monitoring records database, known as “WebDose,” prevent 

NIOSH from presenting internal monitoring discussions and feasibility conclusions for the January 1, 

1997 through May 21, 2011 period within this Addendum. NIOSH is analyzing an updated version of 

WebDose that was delivered in May 2018. The 1997–2011 data analysis is ongoing and necessary to 

accurately assess and present monitoring data availability and sufficiency for the remaining time 

period. Therefore, the remaining SEC evaluation results for January 1, 1997 through May 21, 2011, 

will be presented in a separate report once NIOSH completes its WebDose analysis.
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Evaluation Report Summary: SEC-00188 Addendum (1995-1996)

Class Evaluated by NIOSH (in this Addendum)

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

for the period from January 1, 1995 through May 21, 2011. 

Please note that, while NIOSH did evaluate the period from January 1, 1995 through May 21, 2011, 

this Addendum focuses on results for January 1, 1995 through December 31, 1996. NIOSH’s findings 

for January 1, 1997 through May 21, 2011, will be presented in a separate report after NIOSH 

completes its analysis of the updated WebDose database.

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

NIOSH has defined a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. The NIOSH-proposed class includes all employees of the Department of 

Energy, its predecessor agencies, and its contractors and subcontractors who worked in any area at 

Sandia National Laboratories in Albuquerque, New Mexico, from January 1, 1995 through December 

31, 1996, for a number of work days aggregating at least 250 work days, occurring either solely under 

this employment, or in combination with work days within the parameters established for one or more 

other classes of employees in the Special Exposure Cohort. 

The period from January 1, 1995 through December 31, 1996, was added to the recommended SEC 

class because of concerns with air monitoring data availability and uncertainties associated with the 

transitional and developmental nature of SNL-A’s internal monitoring program. 

Feasibility of Dose Reconstruction

Per EEOICPA and 42 C.F.R. § 83.13(c) (1), NIOSH has established that it does not have 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 

not sufficient to estimate the maximum internal potential exposure to members of the class for the 

January 1995 through December 1996 period under plausible circumstances. 

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 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

contact with radionuclides during waste-handling operations or exposure to surface or air

contamination associated with reactors and/or accelerators work. NIOSH has found that source

terms and associated exposures varied over the evaluated period. Considering the potential
SEC-00188 Addendum (1995–1996) 07-26-2018 Sandia National Laboratories 

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exposure scenarios, as well as concerns with air monitoring data availability and uncertainties 

associated with the transitional and developmental nature of SNL-A’s internal monitoring 

program, NIOSH finds it is unable to estimate these internal exposures with sufficient accuracy for 

the period from January 1, 1995 through December 31, 1996. 

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

radiation for members of the proposed class included exposures to alpha, 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.

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

• Although NIOSH found it is not possible to completely reconstruct radiation doses for the

proposed class, NIOSH intends to use any internal and external monitoring data that may become

available for an individual claim (and that can be interpreted using existing NIOSH dose

reconstruction processes or procedures). Therefore, dose reconstructions for individuals employed

at Sandia National Laboratories from January 1, 1995 through December 31, 1996, but who do not

qualify for inclusion in the SEC, may be performed using these data as appropriate.

Health Endangerment Determination

Per EEOICPA and 42 CFR §83.13(c) (3), a health endangerment determination is required because 

NIOSH has determined that it does not have sufficient information to estimate dose for the members 

of the proposed class from January 1, 1995 through December 31, 1996. 

NIOSH did not identify any evidence supplied by the petitioners or from other resources that would 

establish that the proposed class was exposed to radiation during a discrete incident likely to have 

involved exceptionally high-level exposures. However, data availability issues and uncertainties 

associated with the site’s developing internal monitoring program during this period preclude 

assurance that workers in the proposed class could not have possibly accumulated chronic exposures 

through episodic intakes of radionuclides, combined with external exposures to gamma, beta, and 

neutron radiation. Consequently, NIOSH has determined that health was endangered for those 

workers covered by this evaluation who were employed for at least 250 aggregated work days either 

solely under their employment or in combination with work days within the parameters established for 

other SEC classes.

Once NIOSH has completed its analysis of recently acquired data, NIOSH will make a health 

endangerment determination for the period from January 1, 1997 through May 21, 2011.
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Revised Excerpts of the SEC Petition Evaluation Report for SEC-00188

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

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

EVALUATION REPORT THAT REQUIRE DISCUSSION REGARDING THE 1995–1996 

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 

Although NIOSH has performed an extensive evaluation of the entire remaining January 1, 1995–May 

21, 2011 petitioner-requested timeframe, recently identified issues in SNL-A’s monitoring records 

database, known as “WebDose,” prevent NIOSH from presenting feasibility conclusions for the 

period from January 1, 1997 through May 21, 2011, within this Addendum. NIOSH is analyzing an 

updated version of WebDose that was delivered in May 2018. NIOSH’s analysis is ongoing and 

necessary to accurately assess and present internal monitoring data availability and sufficiency for the 

remaining time period. Therefore, the remaining SEC evaluation results for January 1, 1997 through 

May 21, 2011, will be presented in a separate report once NIOSH completes its WebDose analysis.

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

internal dose reconstruction feasibility for the remaining SEC-00188 petitioner-requested timeframe

(January 1, 1995 through May 21, 2011). NIOSH’s feasibility recommendations presented in this 

Addendum are for the January 1, 1995 through December 31, 1996 timeframe. 

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

NIOSH has defined a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. The NIOSH-proposed class to be added to the SEC includes all employees 

of the Department of Energy, its predecessor agencies, and its contractors and subcontractors who 

worked in any area at Sandia National Laboratories in Albuquerque, New Mexico, from January 1, 

1995 through December 31, 1996, for a number of work days aggregating at least 250 work days, 

occurring either solely under this employment, or in combination with work days within the 

parameters established for one or more other classes of employees in the Special Exposure Cohort. 

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 One 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 identified and reviewed 

numerous other data sources to determine information relevant to determining the feasibility of dose 
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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.

4.3 Facility Employees and Experts 

Twenty interviews were conducted with sixteen SNL personnel specifically to support the post-1994 

Addendum evaluation work (some personnel were interviewed more than once). Workers interviewed 

included health physics/radiation protection staff members, a Radiation Program manager, internal 

dosimetry department managers, security officers, an industrial hygienist, a database manager, and a 

researcher (Documented Communications, 2013a–b, 2014a–m, 2017a–d, 2018). 

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, 1995 through December 31, 1996. Table 4-1 summarizes the results of this review. 

(NOCTS data available as of July 25, 2018.) 

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

Description Totals

Total number of claims submitted for dose reconstruction 722

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

evaluation (January 1, 1995 through December 31, 1996) 243

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

period under evaluation (January 1, 1995 through December 31, 1996) 22

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).

198

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

evaluated class definition 5 

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

evaluated class definition 95

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, 1995 through December 31, 1996, 5 (2%) contain internal monitoring data and 

95 (39%) contain external monitoring data.

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 5,400 documents in this database are identified 

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

designation, more than 800 documents have been included in the SRDB; these documents were 

reviewed and evaluated for their relevance to this Addendum. 
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The focus of the post-1994 data capture efforts for SNL-A includes the following: 

• Internal SNL-A dosimetry program and monitoring 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); and

• 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: 

• 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 Nonconformance 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; and

• 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.

6.1 Available Sandia National Laboratories Internal Monitoring Data

Occupational internal monitoring data available for the 1995–1996 period include in vitro and in vivo

bioassay data, general area (GA) air sample data, and personal air sample (PAS) data. Samples 

labeled “breathing zone” (BZ) and “lapel” (both equivalent to PAS data) have also been captured. 

The available air monitoring data captured for the 1995–1996 period is limited to hard copy PAS and 

GA data retrieved from SNL-A long-term storage repositories during site visits and from formal data 

capture requests. No air monitoring data of either type are stored in SNL-A’s WebDose database. For 

this period, NIOSH has captured 104 personal air sample monitoring records for 22 individuals. 

NIOSH has additionally captured 37 GA sample records (monitoring data sheets). 

Available 1995–1996 bioassay monitoring data are maintained within the WebDose database. 

Bioassay data for this period were reportedly hand-entered from hard copies. As mentioned earlier in 

this report, issues identified within this database have resulted in recent delivery of a replacement, 

updated WebDose extract for NIOSH’s review. Analysis of the updated SNL-A WebDose database 
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delivered to NIOSH in May 2018 is ongoing and necessary to accurately assess monitoring data 

availability.

7.1.1 Internal Monitoring Data Pedigree Review

Data Pedigree addresses the background, history, and origin of the available monitoring 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 dose reconstruction feasibility. 

Information sources relative to the 1995–1996 period depict an Internal Dosimetry program 

undergoing continuing development. Though internal monitoring had been performed on an ad hoc 

basis at SNL-A for decades prior, formalization of an Internal Dosimetry program did not begin until 

1993. This is likely due in large part to the generally low internal exposure potential of the work 

performed at SNL-A. The first documented “Interim Internal Dosimetry Policy” was established in 

December 1993 (Stanley, 1993), following deficiencies noted during internal SNL-A and DOE Tiger 

Team assessments. During the 1995–1996 period, SNL-A’s Internal Dosimetry program was still 

working to meet development and evolutionary requirements. This work included: monitoring 

approach changes; procedure development; and data collection, review, and retention formalization. 

Available documentation and interviews indicate that during the 1995–1996 period, SNL-A’s Internal 

Dosimetry program still primarily relied upon bioassay sampling for worker dose determinations (as 

done in earlier years). Though documented to a lesser extent, it is also apparent that work 

environments were also being assessed via air monitoring, with results supporting subsequent 

bioassay sampling requirement needs and/or changes. During most of the 1995–1996 period, 

procedural requirements for air sampling records review and retention appear to have been minimal

(as evidenced by data capture findings). Captured field air-monitoring records show PAS results and 

DAC-hour calculations for individual workers and events; however, the first procedure requiring 

routing PAS and DAC-hour results to Internal Dosimetry for review was not issued until June 1996 

(SNL, 1996). Records demonstrating individual DAC-hour tracking and accrual are not available for 

1995–1996 at all and were not procedurally required until 1997 (SNL, 1997, PDF p. 228). Evidence 

of a DAC-hour tracking database does not exist until 1997. Though some air monitoring data from 

1997 and later were stored in various electronic formats, all air data prior to this time exists only in 

original hard copy form stored and retrieved from inactive (long-term) record holdings. As such, 

these earlier records are considered primary records and therefore considered to have sufficient data 

pedigree from that perspective. However, the lack of required records retention and review 

procedures coupled with issues identifying and retrieving records from long-term storage makes 

determining the total PAS and DAC-hour data quantity and completeness logistically infeasible.

Documented program assessments, internal memos, and NIOSH-conducted interviews with SNL-A 

employees knowledgeable of 1995–1996 processes revealed additional characteristics indicative of an 

internal monitoring program undergoing continuous (and rapid) development. Observations and 

criticisms noted in these assessments, memos, and interviews included: insufficient staffing levels to 

meet current program developmental tasks; lack of a fully functional internal monitoring database for 

efficient and reliable record entry, retention, and retrieval; under-developed procedures; and underuse 

of air monitoring for the evaluation and control of work environments. Though 1995–1996, bioassay 

analytical results are now stored within the WebDose database; an interviewee indicated (Documented 
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Communications, 2017c) that the data were predominantly hand entered (rather than electronic input) 

and the quality control for the hand-entry process is now unknown. 

During the course of evaluating the entire remaining petitioned evaluation period (January 1, 1995–

May 21, 2011), NIOSH performed an additional data pedigree-related assessment. Though limited by 

sample size, the assessment indicates pertinent data pedigree information applicable to the 1995–1996 

period. The assessment focused on evaluating SNL-A’s PAS monitoring record retention and 

retrieval abilities. Air monitoring records for 23 individuals representing monitoring conducted over 

the 1995–2011 evaluation period were selected from various captured sources (raw data sheets, post1996 DAC-hour tracking reports, area-specific spreadsheets, etc.). Record retention and retrieval

practices for the SNL-A PAS monitoring program were recorded temporally and by record-source 

type. The 23 names were then provided to SNL-A with a request to provide all dosimetry records 

available using the site’s currently established reasonable search protocol for EEOICPA claims. The 

records received from Sandia were compared to the original PAS monitoring records captured by 

NIOSH to determine if returned information was both consistent and indicative of the PAS monitoring 

indicated in the NIOSH-captured air monitoring records.

Three of the 23 individuals chosen had captured records within the 1995–1996 time frame. Of these 

three, no search acknowledgement or records of any type were returned for one individual, indicating 

a possible inadvertent omission from NIOSH’s request. Acknowledgement of records searches for the 

remaining two individuals was supplied; however, data previously captured by NIOSH for these two 

individuals were not retrieved/supplied by the site in response to this request. 

7.2 Evaluation of Bounding Internal Radiation Doses at Sandia National Laboratories 

As mentioned previously, only very limited air monitoring data have been captured for the 1995–1996 

timeframe. The air monitoring data are judged insufficient due to a lack of required, record retention 

and review procedures, and due to logistical issues with identifying and retrieving records from longterm storage. Though bioassay data are available to a much greater extent via the WebDose database, 

data pedigree shortcomings also remain with these data with regards to unknown QC protocols used 

during the original hand entry of the data and the implementation of follow-up sampling. As such, 

additional evaluation and discussion of available data types and their subsequent incorporation into 

methods used to bound process-related internal doses for the 1995–1996 period are not warranted. 

7.2.4 Internal Dose Reconstruction Feasibility Conclusion

NIOSH has determined that workplace monitoring data and documentation are insufficient to support 

bounding EEOICPA internal doses for the January 1, 1995 through December 31, 1996, portion of the 

evaluated class. 

Although NIOSH found that it is not possible to reconstruct internal radiation doses for the period 

from January 1, 1995 to December 31, 1996, NIOSH intends to use any internal monitoring data that 

may become available for an individual claim (and that can be interpreted using existing NIOSH dose 

reconstruction processes or procedures). Dose reconstructions for individuals employed at SNL-A 

from January 1, 1995 through December 31, 1996, but who do not qualify for inclusion in the SEC, 

may be performed using these data as appropriate. 
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7.4 Evaluation of Petition Basis for SEC-00188 Addendum

An evaluation of the petition basis for SEC-00188 will be presented in the upcoming report addressing 

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

7.5 Other Potential SEC Petition Issues Identified During the Evaluation

As applicable, other potential SEC issues identified during the evaluation of SEC-00188 will be 

presented in the upcoming report addressing the remaining period from January 1, 1997 through May 

21, 2011. 

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, 1995 through December 31, 1996. NIOSH found that bioassay 

monitoring program documentation and workplace monitoring data are insufficient to support 

bounding EEOICPA internal doses for the January 1, 1995 through December 31, 1996 portion of the 

evaluated. Air monitoring data are judged insufficient due to a lack of required, record retention and 

review procedures during January 1, 1995 through December 31, 1996 period, as well as logistical 

issues identifying and retrieving records from long-term storage. Additionally, uncertainties and 

concerns associated with the transitional and developmental nature of SNL-A’s internal monitoring 

program exist. 

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

period from January 1, 1995 through December 31, 1996. 

Table 7-2: Summary of Feasibility Findings for SEC-00188, Addendum (1995–1996) 

Source of Exposure

Reconstruction Feasible for

January 1, 1995–December 31, 1996 

(Yes or No)

Internal No

External Yes

Gamma Yes

Beta Yes

Neutron Yes

Occupational Medical X-ray Yes

As of July 25, 2018, a total of 243 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 198 individuals (~81%).

Although NIOSH found that it is not possible to reconstruct internal radiation doses for the proposed 

class, NIOSH intends to use any internal monitoring data that may become available for an individual 

claim (and that can be interpreted using existing NIOSH dose reconstruction processes or procedures). 

Therefore, dose reconstructions for individuals employed at SNL-A during the period from January 1, 

1995 through December 31, 1996, but who do not qualify for inclusion in the SEC, may be performed 

using these data as appropriate. 
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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. 

NIOSH’s evaluation determined that it is not 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, the resulting NIOSH-proposed SEC class must include a minimum 

required employment period as a basis for specifying that health was endangered. 

9.0 Class Conclusion for Petition SEC-00188 

Based on its full research of the class under evaluation, NIOSH has defined a single class of 

employees for which NIOSH cannot estimate radiation doses with sufficient accuracy. The NIOSHproposed class to be added to the SEC includes all employees of the Department of Energy, its 

predecessor agencies, and its contractors and subcontractors who worked in any area at Sandia 

National Laboratories in Albuquerque, New Mexico, from January 1, 1995 through December 31, 

1996, for a number of work days aggregating at least 250 work days, occurring either solely under this 

employment, or in combination with work days within the parameters established for one or more 

other classes of employees in the Special Exposure Cohort. 
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10.0 References

Documented Communications, 2013a, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

January 23, 2013; SRDB Ref ID: 125804 

Documented Communications, 2013b, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

January 23, 2013; SRDB Ref ID: 125804 

Documented Communications, 2014a, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 9, 2014; SRDB Ref ID: 142257 

Documented Communications, 2014b, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 9, 2014; SRDB Ref ID: 141878 

Documented Communications, 2014c, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 9, 2014; SRDB Ref ID: 141879 

Documented Communications, 2014d, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 9, 2014; SRDB Ref ID: 141877 

Documented Communications, 2014e, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 10, 2014; SRDB Ref ID: 141834

Documented Communications, 2014f, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 10, 2014; SRDB Ref ID: 141827 

Documented Communications, 2014g, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 10, 2014; SRDB Ref ID: 141828

Documented Communications, 2014h, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 10, 2014; SRDB Ref ID: 141832 

Documented Communications, 2014i, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 10, 2014; SRDB Ref ID: 141833 

Documented Communications, 2014j, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 10, 2014; SRDB Ref ID: 141875 
SEC-00188 Addendum (1995–1996) 07-26-2018 Sandia National Laboratories 

15 of 19 

Documented Communications, 2014k, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 10, 2014; SRDB Ref ID: 141830 

Documented Communications, 2014l, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 11, 2014; SRDB Ref ID: 141834 

Documented Communications, 2014m, Documented Communications with Sandia National 

Laboratories Current or Former Employee; In-person interview by NIOSH and ORAU Team; 

September 11, 2014; SRDB Ref ID: 142254 

Documented Communications, 2017a, Documented Communications with Sandia National 

Laboratories Current or Former Employee; Telephone interview by NIOSH and ORAU Team; 

October 11, 2017; SRDB Ref ID: 168055 

Documented Communications, 2017b, Documented Communications with Sandia National 

Laboratories Current or Former Employee; Telephone interview by NIOSH and ORAU Team; 

October 25, 2017; SRDB Ref ID: 168054

Documented Communications, 2017c, Documented Communications with Sandia National 

Laboratories Current or Former Employee; Telephone interview by NIOSH and ORAU Team; 

November 21, 2017; SRDB Ref ID: 169443 

Documented Communications, 2017d, Documented Communications with Sandia National 

Laboratories Current or Former Employee; Email interview questions by NIOSH and ORAU Team; 

November 30, 2017; SRDB Ref ID: 168389 

Documented Communications, 2018, Documented Communications with Sandia National 

Laboratories Current or Former Employee; Telephone interview by NIOSH and ORAU Team; 

January 29, 2018; SRDB Ref ID: 169937 

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 

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 

Stanley, 1993, Interim Internal Dosimetry Policy, correspondence; A. L. Stanley; December 20, 1993; 

SRDB Ref ID: 23894
SEC-00188 Addendum (1995–1996) 07-26-2018 Sandia National Laboratories 

16 of 19 

Attachment One: Data Capture Synopsis

Attachment One is a summary of SRDB holdings that pertain to the SEC-00188 Addendum evaluation efforts. Table A1-1 includes documents that were 

located between January 26, 2012 and May 15, 2018, 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 A1-1: Summary of Holdings in the SRDB for Sandia National Laboratories-Albuquerque Captured between January 26, 2012 and May 15, 2018

Data Capture Information Data Capture Description Date 

Completed 

No. Uploaded 

into SRDB

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, and the technical basis for 

implementing air sampling.

Ongoing 531

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

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, unauthorized entries into radiological areas, 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
SEC-00188 Addendum (1995–1996) 07-26-2018 Sandia National Laboratories 

17 of 19 

Data Capture Information Data Capture Description Date 

Completed 

No. Uploaded 

into SRDB

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, and minutes of the 70th meeting of the Advisory Board on 

Radiation and Worker Health. 

08/31/2015 3

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

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.

12/07/2017 20

Sandia National Laboratory - Livermore, 

California

Interview notes of SNL/CA personnel. 04/29/2013 1

TOTAL Not Applicable Not Applicable 866
SEC-00188 Addendum (1995–1996) 07-26-2018 Sandia National Laboratories 

18 of 19 

Table A1-2: Database Searches for Sandia National Laboratories-Albuquerque Captured between January 26, 2012 and May 15, 2018

Database/Source Keywords Hits Uploaded 

into SRDB

Defense Technical Information Center (DTIC)

COMPLETED 10/06/2017

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

1,091 0

DOE Comprehensive Epidemiologic Data Resource (CEDR)

COMPLETED 05/27/2010

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

4 0

DOE Hanford Declassified Document Retrieval System (DDRS) and 

Public Reading Room

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

38 0

DOE Legacy Management Considered Sites

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

0 0

DOE National Nuclear Security Administration (NNSA) - Nevada 

Site Office

COMPLETED 10/05/2017

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

730 0

DOE OpenNet

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

560 16

DOE OSTI Energy Citations

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

1,340 1

DOE OSTI Information Bridge

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

2,609 23

DOE OSTI SciTech Connect

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

247 0

Energy Employees Claimant Assistance Project (EECAP)

COMPLETED 01/10/2014

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

15 3

Google

COMPLETED 10/06/2017

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

4,381,733 132

Health Physics Journal

COMPLETED 10/06/2017

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

346 6
SEC-00188 Addendum (1995–1996) 07-26-2018 Sandia National Laboratories 

19 of 19 

Database/Source Keywords Hits Uploaded 

into SRDB

International Journal of Occupational and Environmental Health 

COMPLETED 10/05/2017

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

3 0

National Academies Press

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

2,253 1

NRC ADAMS Reading Room

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

4,290 11

United States Army Corps of Engineers (USACE)

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

0 0

U.S. Transuranium & Uranium Registries

COMPLETED 04/10/2013

Database search terms and Internet URL are available in the Excel file 

called “Sandia NM SEC Addendum (Rev 01) and Full (Rev 04) 06-25-18” 

under the Summary of SRDB Holdings tab.

0 0