SEC Petition Evaluation Report

Petition SEC-00214

Report Rev #:0 Report Submittal Date: September 26, 2013

Subject Expert(s): Tim Adler

Site Expert(s): N/A

Petitioner Administrative Summary

Petition Under Evaluation

Petition # Petition 

Type

Petition A

Receipt Date DOE/AWE Facility Name

SEC-00214 83.14 August 22, 2013 Sandia National Laboratories-Livermore

NIOSH-Proposed Class Definition

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

who worked in any area at Sandia National Laboratories-Livermore in Livermore, California, from October 1, 

1957 through December 31, 1994, 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 #(s)

Petition 

Type DOE/AWE Facility Name Petition Status

N/A N/A N/A N/A

Related Evaluation Report Information

Report Title DOE/AWE Facility Name

N/A N/A

ORAU Lead Technical Evaluator: Tim Adler ORAU Peer Review Completed By: Daniel Stempfley

Peer Review Completed By: [Signature on File] 9/26/2013

Sam Glover Date

SEC Petition Evaluation Reviewed By: [Signature on File] 9/27/2013

J. W. Neton Date

SEC Evaluation Approved By: [Signature on File] 9/27/2013

Stuart L. Hinnefeld Date
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Evaluation Report Summary: SEC-00214, Sandia National 

Laboratories-Livermore

This evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addresses a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the 

Energy Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. 

§ 7384 et seq. (EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees 

as Members of the Special Exposure Cohort Under the Energy Employees Occupational Illness 

Compensation Program Act of 2000.

NIOSH-Proposed Class Definition

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

subcontractors who worked in any area at Sandia National Laboratories-Livermore in Livermore, 

California, from October 1, 1957 through December 31, 1994, 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.

Feasibility of Dose Reconstruction Findings

NIOSH lacks sufficient information, which includes internal and external personnel monitoring data, 

process data, and radiological source term information, to allow it to estimate with sufficient accuracy 

the potential internal and external exposures to radionuclides which include but are not limited to 

uranium, uranium tritides and hydrides, tritium, and thorium, as well as potential exposures from

radiological classified activities to which the proposed class may have been subjected. NIOSH finds 

that it is likely feasible to reconstruct occupational medical dose for Sandia National LaboratoriesLivermore workers with sufficient accuracy up through 1989. After 1989 medical X-rays are not 

applicable because they were performed offsite.

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

• Sources of internal radiation for members of the proposed class included exposures to depleted 

uranium, tritium, uranium tritides, uranium hydrides, thorium, and highly enriched uranium. 

Primary sources of potential internal doses to depleted uranium were from machining performed 

in the Weapons Laboratory Facility Complex. Tritium, uranium tritide, and uranium hydride dose 

sources were associated with research activities taking place within the Tritium Research 

Laboratory. Highly enriched uranium and thorium may have been involved in classified activities 

at other site locations and also resulted in potential internal doses.

• NIOSH has access to records suggesting that tritium and uranium urinalyses were performed for 

workers within the Tritium Research Laboratory and those machining depleted uranium. NIOSH 

does not, however, have access to all internal monitoring results nor complete source term and 

process records, nor can it assess what fraction of the records are available. 
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• Principal sources of external radiation for members of the proposed class included exposures to 

highly enriched uranium, uranium hydrides, thorium, Radiography Facility isotope sources, and 

potentially other radionuclides from classified work.

• NIOSH has access to records suggesting that external monitoring was performed for many site 

workers. NIOSH does not however, have access to all external monitoring results nor complete 

source term and process records. 

• 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 that 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-Livermore during the period from October 1, 1957 through December 

31, 1994, but who do not qualify for inclusion in the SEC, may be performed using these data as 

appropriate.

Health Endangerment Determination

The NIOSH evaluation did not identify any evidence supplied by the petitioners or from other 

resources that would establish that the class was exposed to radiation during a discrete incident likely 

to have involved exceptionally high-level exposures, such as nuclear criticality incidents or other 

events involving similarly high levels of exposures. However, the evidence reviewed in this 

evaluation indicates that some workers in the class may have accumulated chronic radiation exposures 

through intakes of tritium, uranium, and possibly from direct exposure to radioactive materials. 

Therefore, 42 C.F.R. § 83.13(c)(3)(ii) requires NIOSH to specify that health may have been

endangered for those workers covered by this evaluation who were employed for a number of work 

days aggregating at least 250 work days within the parameters established for this 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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Table of Contents

Evaluation Report Summary: SEC-00214, Sandia National Laboratories-Livermore ........................... 3

1.0 Purpose and Scope....................................................................................................................... 7

2.0 Introduction ................................................................................................................................. 7

3.0 NIOSH-Proposed Class Definition and Petition Basis................................................................ 8

4.0 Radiological Operations Relevant to the Proposed Class ........................................................... 8

4.1 Operations Description....................................................................................................... 8

4.2 Radiation Exposure Potential from Operations................................................................ 12

4.3 Time Period Associated with Radiological Operations.................................................... 14

4.4 Site Locations Associated with Radiological Operations ................................................ 15

4.5 Job Descriptions Affected by Radiological Operations ................................................... 15

5.0 Summary of Available Monitoring Data for the Proposed Class.............................................. 15

5.1 Data Capture Efforts and Sources Reviewed ................................................................... 16

5.2 Previous Dose Reconstructions........................................................................................ 16

5.3 Worker Interviews............................................................................................................ 17

5.4 Internal Personnel Monitoring Data ................................................................................. 18

5.4.1 Tritium Bioassay .................................................................................................. 19

5.4.2 Uranium Bioassay ................................................................................................ 19

5.5 External Personnel Monitoring Data ................................................................................ 20

5.6 Workplace Monitoring Data............................................................................................. 21

5.7 Radiological Source Term Data ....................................................................................... 21

6.0 Feasibility of Dose Reconstruction for the Proposed Class ...................................................... 22

6.1 Feasibility of Estimating Internal Exposures ................................................................... 23

6.2 Feasibility of Estimating External Exposures .................................................................. 25

6.3 Class Parameters Associated with Infeasibility................................................................ 26

7.0 Summary of Feasibility Findings for Petition SEC-00214........................................................ 27

8.0 Evaluation of Health Endangerment for Petition SEC-00214................................................... 28

9.0 NIOSH-Proposed Class for Petition SEC-00214 ...................................................................... 28

10.0 Evaluation of Second Similar Class.......................................................................................... 29

11.0 References ................................................................................................................................. 31

Attachment One: Data Capture Synopsis.............................................................................................. 35
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Tables

Table 4-1: SNL-Livermore Employee Population (1980-1994) ............................................................. 9

Table 4-2: SNL-Livermore Major Process Complexes Handling Radioactivity .................................. 10

Table 4-3: SNL-Livermore Radiation Types, Energies, and Percentages............................................. 12

Table 5-1: No. of SNL-Livermore Claims Submitted Under the Dose Reconstruction Rule............... 17

Table 6-1: No. of Internal Monitoring Reports Captured by NIOSH and Not Supplied by SNLLivermore .............................................................................................................................................. 24

Table 6-2: No. of External Monitoring Reports Captured by NIOSH and Not Supplied by SNLLivermore .............................................................................................................................................. 25
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SEC Petition Evaluation Report for SEC-00214

ATTRIBUTION AND ANNOTATION: This is a single-author document. All conclusions drawn from 

the data presented in this evaluation were made by the ORAU Team Lead Technical Evaluator: Tim 

Adler, Oak Ridge Associated Universities (ORAU). The rationales for all conclusions in this 

document are explained in the associated text.

1.0 Purpose and Scope

This report evaluates the feasibility of reconstructing doses for employees who worked at Sandia 

National Laboratories–Livermore during a specified time. It provides information and analysis 

germane to considering a petition for adding a class of employees to the Congressionally-created SEC.

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH, with the exception of the employee whose dose reconstruction could not be completed, and 

whose claim consequently led to this petition evaluation. The finding in this report is not the final 

determination as to whether or not the proposed class will be added to the SEC. This report will be 

considered by the Advisory Board on Radiation and Worker Health (the Board) and by the Secretary 

of Health and Human Services (HHS). The Secretary of HHS will make final decisions concerning 

whether or not to add one or more classes to the SEC in response to the petition addressed by this 

report.

This evaluation, in which NIOSH provides its findings both on the feasibility of estimating radiation 

doses of members of this class with sufficient accuracy and on health endangerment, was conducted in 

accordance with the requirements of EEOICPA and 42 C.F.R. § 83.14.

2.0 Introduction

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services add a class of employees to the SEC. The evaluation is 

intended to provide a fair, science-based determination of whether it is feasible to estimate, with 

sufficient accuracy, the radiation doses of the proposed class of employees through NIOSH dose 

reconstructions.

1

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioners and the 

Advisory Board on Radiation and Worker Health. The Board will consider the NIOSH evaluation 

report, together with the petition, comments of the petitioner(s) and such other information as the 

Board considers appropriate, to make recommendations to the Secretary of HHS on whether or not to 

add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

 1 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas.
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advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this final decision process, the 

petitioner(s) may seek a review of certain types of final decisions issued by the Secretary of HHS.

2

3.0 NIOSH-Proposed Class Definition and Petition Basis

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-Livermore in Livermore, California, from October 1, 1957 through December 31, 1994, 

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. During this period, employees at this 

facility were involved with nuclear ordnance design and testing, and scientific research.

The evaluation responds to Petition SEC-00214 which was submitted by an EEOICPA claimant 

whose dose reconstruction could not be completed by NIOSH due to a lack of sufficient dosimetryrelated information. NIOSH’s determination that it is unable to complete a dose reconstruction for an

EEOICPA claimant is a qualified basis for submitting an SEC petition pursuant to 42 C.F.R. § 

83.9(b).

4.0 Radiological Operations Relevant to the Proposed Class

The following subsections summarize the radiological operations at Sandia National LaboratoriesLivermore (abbreviated as SNL-Livermore throughout most portions of this report) from October 1, 

1957 through December 31, 1994 and the information available to NIOSH to characterize particular 

processes and radioactive source materials. Using available sources, NIOSH has attempted to gather 

process and source descriptions, information regarding the identity and quantities of radionuclides of 

concern, and information describing processes through which the radiation exposures of concern may 

have occurred and the physical environment in which they may have occurred. The information 

included within this evaluation report is meant only to be a summary of the available information.

4.1 Operations Description

SNL-Livermore activities were established in Livermore, California in early 1956 to provide direct 

support for Lawrence Livermore National Laboratory (LLNL) nuclear weapons designs (SNL, 2005). 

Design support for LLNL was originally provided by a small group of engineers and support staff. 

Initially, approximately two dozen employees worked with LLNL on LLNL property in abandoned 

naval air station barracks (Johnson, 1997, pdf p. 90). By the end of 1956, plans were completed to 

increase Livermore staff to about 1,000 personnel and to invest 5 million dollars in the construction of 

permanent buildings and support facilities across the street from LLNL. SNL-Livermore employees 

occupied their first building (Building 911) on the newly developing SNL-Livermore site in October 

1957 (Johnson, 1997, pdf p. 90). By 1958, with over 800 employees, SNL-Livermore worked on the 

 2 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas.
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W38 warhead for Titan I and Atlas missiles (Ullrich, 2003). The SNL-Livermore site presently 

consists of approximately 70 buildings/facilities on 410 acres and is located just across East Avenue 

from LLNL in Livermore, California. Although NIOSH does not know the specific number of 

employees on site for each year being evaluated in this report, various captured Atomic Energy 

Commission (AEC) Annual Radiation Reports indicate SNL-Livermore’s worker population to have 

ranged from approximately 1,000 to 1,300. Table 4-1 (using employee counts from SNLAlbuquerque’s Human Resource Department) shows the number of SNL-Livermore employees 

beginning in 1980 through 1994. 

Table 4-1: SNL-Livermore Employee Population (1980-1994)

Year No. of 

Employees Year No. of Employees Year No. of Employees

1980 1067 1985 1076 1990 1074

1981 1081 1986 1061 1991 1038

1982 1082 1987 1080 1992 1041

1983 1106 1988 1074 1993 1050

1984 1101 1989 1050 1994 1018

SNL-Livermore’s primary mission during the time coinciding with the Cold War (1956 to 1989) was 

to design and test non-nuclear components of nuclear weapons designed by LLNL. SNL-Livermore 

was to engineer, or “weaponize,” the nuclear physics packages designed by LLNL; production of parts 

and final weapons was accomplished at other weapons complex sites. Support for LLNL also 

expanded to include effects test analyses and telemetry for LLNL nuclear tests of nuclear weapon 

designs. In 1959, SNL-Livermore also moved into evaluation of nuclear detonation as part of the 

Plowshare Program (which ended in the early 1970s) (Ullrich, 2003).

Sandia Corporation, a Lockheed Martin Company, currently operates SNL-Livermore and Sandia 

National Laboratories-Albuquerque in Albuquerque. From 1956 to 1993, SNL-Livermore was 

managed and operated by American Telephone and Telegraph. In 1993, the contract was awarded to 

Martin Marietta Corporation, now known as Lockheed Martin Corporation (DOE, 2003, pdf p. 26).

The Environmental Test Building for the new SNL-Livermore site (completed by the end of 1958) 

was used for some testing of new designs. During the 1960s, additional support facilities were built, 

including storage and a maintenance shop. Additional test facilities (the centrifuge and Explosive 

Test Facility) were also constructed. In 1970, 86 acres were added to the site, providing an additional 

buffer area.

Although SNL-Livermore has never lost their core mission of nuclear ordnance design and testing, the 

laboratory moved further into scientific research in the late 1960s, bringing in scientists, 

mathematicians, and materials specialists to work in applied research. SNL-Livermore’s initial move 

into research on tritium grew out of its familiarity with, and use of, tritium in components. In 1974, 

the first structure dedicated to tritium research at SNL-Livermore, the Tritium Research Laboratory 

(TRL), was added to the site, with completion of the basic laboratory building during the summer of 

1975 (Garcia & Gorman, 1996, pdf p. 15). The TRL became operational in late 1978.
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Ranging further from weapons engineering, SNL-Livermore also pursued combustion research and, 

during the 1973 to 1974 energy crisis, began conducting some research into alternative energy. The 

expanded purpose resulted in an increased variety of facilities within the site. In addition to the TRL, 

a large complex of structures for the Combustion Research Facility was completed in 1980. An 

additional 24 acres of land was added as a buffer zone on the east side near the Tritium Facility in 

1979. In 1986, an additional 228 acres was obtained, allowing an alternative exit route from the 

facility. Finally, in 1998, SNL-Livermore took part in a small land exchange to create a consistent 

buffer zone line along the western boundary, in which 2.8 acres were received in exchange for 5.4 

acres (ORAUT-TKBS-0053). This brought the site’s area down to 410 acres where it remains today. 

In support of the various missions identified above, a number of activities were undertaken at SNLLivermore over the years, some of which involved the handling and release of radioactive materials. 

A complete list of buildings including known information about present and past uses and the 

presence of radioactive materials is provided in Summary Site Profile for Sandia National 

Laboratories in Livermore, California (referred to as ORAUT-TKBS-0053 throughout this 

document). A subset of this building list has been compiled in Table 4-2 below to present the known 

major process complexes at the SNL-Livermore site that handled radioactivity in some manner over 

the years, and to show the predominant radiologically-related activities that took place in these 

complexes. 

Although information is available indicating that SNL-Livermore employees were not physically 

located on SNL-Livermore property until October 1957, details of the early work performed and the 

first presence of radionuclides on the site are not available to NIOSH (detailed source term and 

process documentation for the earliest period of the site’s development have not been captured). 

Without such documentation, NIOSH assumes that source terms potentially capable of producing 

external and internal exposures from October 1957 forward may have been present due to ongoing 

nuclear weapons design and test support work performed for LLNL. 

Table 4-2: SNL-Livermore Major Process Complexes Handling Radioactivity

Table 4-2 spans two pages.

Area Building 

Number(s) Time Period Activities Radionuclides

Weapons Laboratory Facility 

Complex

910, 912, 

913, 914, 

916, and 918

1958–1998 Test/repair neutron 

detectors, machining of 

depleted uranium (DU), 

radiography of weapons 

components, 

radiography for 

materials science 

studies, tritium storage 

studies, ion beam 

analysis of materials, 

Radiflo leak tests

Depleted uranium, 

tritium, neutron 

generator, 

accelerators, sealed 

sources, amounts of 

krypton-85

Radiography 923 Unknown–

Early 1990s

Radiography using Xrays, gamma rays, 

neutrons, and beta 

particles

Cobalt-60, iridium192, californium252, X-ray machines

Micro and Nano 941, 942, Unknown– Radiography for In Building 941 
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Table 4-2: SNL-Livermore Major Process Complexes Handling Radioactivity

Table 4-2 spans two pages.

Area Building 

Number(s) Time Period Activities Radionuclides

Technologies Laboratories and 943 Present materials science 

studies

only: X-ray, 

uranium-238, and 

beta sources (sealed)

Former Tritium Research 

Laboratories (Currently the 

Chemical and Radiological 

Detection Laboratory)

967, 968, 

and 969

1974–1996 Tritium research: >0.1 

g tritium handled in 

glovebox, 0.0005–0.1 g 

in high velocity air 

hoods

Tritium, depleted 

uranium (no 

radionuclides after 

decommissioning 

complete in 1996)

Explosives and 

Environmental Testing 

Complex

955, 956, 

966, 972, 

974, 976, 

977, 978, 

979, 981, 

and 983

1958–Present Environmental testing 

of mock-up weapons 

and components

Depleted uranium

Storage Facilities 921, 927, 

961, and 982

Unknown–

Present

Storage and packaging 

of waste materials

Tritium, depleted 

uranium, natural 

thorium, trace 

plutonium-239 and 

mixed fission 

products

Notes: This table is a modified version of Table 2-1from ORAUT-TKBS-0053.

According to SNL-Livermore annual environmental reports dating back to 1983, the laboratory 

typically handled kilogram amounts of depleted uranium, gram amounts of tritium (when the TRL 

was operational), and only microcurie quantities of other isotopes (SNL, 1983, pdf p. 3). However, 

the 1992 Environmental Impact Statement for LLNL and SNL-Livermore noted that 100 Ci iridium192 and cobalt-60 radiographic isotopes and many other smaller sealed sources with activity ranging 

from 1 μCi to 500 mCi, were stored in a shielded radiography cell (DOE, 1992; ORAUT-TKBS0053).

DU is, and has been, largely in the form of alloyed metal components, often encapsulated (ORAUTTKBS-0053). Wet machining of uranium metal did occur over the years (SOP#1066; ORAUTTKBS-0053). Powdered depleted uranium sealed in storage containers for tritium-storage studies (as 

the tritide) has also been present (post-1988) in approximately 1-kg amounts (SOP#757). A classified 

activity involving powdered uranium hydride in gram amounts was conducted in gloveboxes in 

buildings 979, 916, and the TRL (Personal Communication, 2006). There were some thorium metal 

parts used on test systems as well (Personal Communication, 2006).

Classified interviews and data capture work have also revealed that kg quantities of highly enriched 

uranium were on site during the middle 1960s to the middle 1970s. Additionally, kilogram quantities 

of thorium were present from the middle 1970s to middle 1980s. 
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4.2 Radiation Exposure Potential from Operations

The potential for external radiation dose existed at multiple SNL-Livermore locations including the 

Weapons Laboratory Facility Complex, Radiography, Micro and Nano Technologies Laboratories, the 

Explosives and Environmental Testing Complex, and the storage facilities. Radionuclide sources 

potentially involved include highly enriched uranium, uranium hydride, thorium, and other various 

sources, as identified in Table 4-3 below. Based on the site operations outlined in Section 4.1, beta, 

photon, and neutron exposures were possible and are estimated and summarized in Table 4-3. 

Additional classified activities may have also resulted in external dose potential. 

Table 4-3: SNL-Livermore Radiation Types, Energies, and Percentages

Table 4-3 spans two pages.

Area Process Description Radiation 

Type

Energy 

Selection 

(keV)

Percentage a

Weapons Laboratory Facility 

Complex 

(Buildings 910, 912, 913, 914, 916, 

918)

Years: 1958-1998

Test/repair of neutron and Xray detectors (neutron and Xray generators)Photon

Neutron

>250

10-100

100-2,000

2,000-

20,000

100

5

5

90

Wet machining of depleted 

uranium

Beta 

Photon

>15

30-250

>250

100

50b

50b

Radiography for weapons 

components

Beta 

Photon

>15

30-250

>250

100

50b,c

50b,c

Radiography for materials 

science studies (X-ray 

diffraction operations later 

moved to building 941)

Beta

Photon

>15

<30

30-250

>250

100

40

30

30

Tritium storage studies Photon 30-250

>250

50b,d

50b,d

Ion beam analysis of 

materials

Photon 30-250

>250

30

70

Radiflo leak tests

 

Beta 

Photon

>15

30-250

>250

100

10

90

Radiography 

(Building 923) 

Years: Unknown-Early 1990s

Radiography using X-rays, 

gamma rays, neutrons, and 

beta particles (cobalt-60, 

iridium-192, californium252)

Beta

Photon

Neutron

>15

<30

30-250

>250

10-100

100-2,000

2,000-

100

 

5

45

50

5

70

25
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Table 4-3: SNL-Livermore Radiation Types, Energies, and Percentages

Table 4-3 spans two pages.

Area Process Description Radiation 

Type

Energy 

Selection 

(keV)

Percentage a

20,000

Micro and Nano Technologies 

Laboratories

(Buildings 941, 942, and 943)

Years: Unknown-Current

Radiography for materials 

science studies (radiological 

materials in building 941 

only; uranium-238 and sealed 

beta sources)

Beta

Photon

>15

<30

30-250

>250

100

40

30

30

Explosives and Environmental 

Testing Complex

(Buildings 955, 956, 966, 972, 974, 

976, 977, 978, 979, 981, 983)

Years: 1958–Current

Environmental testing of 

mock-up weapons and 

components (DU)

Beta

Photon

>15

30-250

>250

100

50

50

Storage Facilities

(Buildings 921, 927, 961, 982)

Years: Unknown–Current

Storage and packaging waste 

materials (tritium, natural 

thorium, trace plutonium239, and mixed fission 

products)

Beta

Photon

>15

30-250

>250

100

70

30

Notes: 

This table is a modified version of Table 6-4from ORAUT-TKBS-0053.

a. Estimated primarily by site personnel.

b. Based on favorable to claimant default assumptions provided for depleted uranium.

c. Assumes radiography primarily associated with weapons mock-ups and depleted uranium.

d. Assumes only external exposures would be associated with depleted uranium beds in tritium storage facility.

Primary sources of internal radiation exposure at the site included tritium research conducted in TRL, 

limited uranium operations, and depleted uranium machining. Information obtained via classified 

interviews and data capture indicated that highly enriched uranium and thorium were onsite in 

significant quantities. Activities involving these sources included classified work, which may also 

have presented internal exposure potentials.

The TRL was completed in 1978 for the purpose of performing research and development functions 

for the DOE Office of Defense Programs to support weapons development. At its peak operation, the 

TRL employed approximately 35 experimenters and support personnel (Garcia & Gorman, 1996, pdf 

p. 10). TRL operations were generally concerned with the physical and chemical characterization of 

tritium and its compounds. It was generally handled in the form of a gas, although effluents could be 

in the form of a gas, liquid, or solid. Additional work included fabrication of tritium compounds for 

use as engineering components and examining the behavior of hydrogen isotopes and helium in 

metals to understand transport and structural properties. All operations involving gram quantities of 

tritium were conducted inside gloveboxes. Other activities using smaller quantities were performed in 

the “Radioactive Materials Area” which was separated from the rest of the facility by two sets of 

double doors. The ventilation system for this area was designed to direct airflow from clean areas to 

areas of increasing contamination potential (Wright, 1981). Mixed solid and liquid tritiated waste was 

generated; the majority of the waste was in the form of scintillation cocktails, which were shipped 
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offsite for incineration in Florida (ORAUT-TKBS-0053). Larger (gram quantities) of tritium 

operations were terminated in 1992. Cleanup and tritium inventory reduction activities were 

conducted at the TRL from 1992 through 1994. In November 1994, DOE reclassified the TRL as a 

non-nuclear, low hazard, general-purpose facility. All radioactive source materials were removed by 

1996 (Johnson, 1997b, pdf p. 8)

A Uranium Tritide Bed installed at the TRL in 1991 to store tritium as uranium tritide also presented a 

potential for exposure to uranium powder (SOP#757). In addition, parts contaminated with uranium 

dioxide dust were received by SNL-Livermore (Lovell, 1982), posing a potential airborne dust hazard. 

A Safe Operating Procedure (SOP) issued in September 1994 stipulates operating procedures for the 

bed, indicating it was still in use at that time (SOP, 1994, pdf p. 6).

Uranium alloy machining was performed at the SNL-Livermore facility beginning in approximately

1971 (Adolphson, 1972). Several memos indicate that machining and testing of uranium alloys had 

previously been performed at the Union Carbide Y-12 plant and elsewhere. However, requirements 

for SNL-Livermore were such that they needed “between 50 and 100 specimens of various shapes and 

sizes per month” (Adolphson, 1972), thus requiring initiation of an on-site program. The machining 

was routinely done via a wet process. In addition to an inhalation exposure potential (relatively low 

when using a wet process), uranium machining also posed a potential exposure via industrial hazards

such as wounds. All such incidents were to be reported to the Medical Department and wound counts 

made on any puncture wounds; however, no data on wound counts were found in the available 

records.

4.3 Time Period Associated with Radiological Operations

Per the DOE Office of Health, Safety and Security, the time period associated with DOE operations at 

the SNL-Livermore site is from 1956 through present. In early 1956, approximately two dozen 

employees worked with LLNL on LLNL property in abandoned naval air station barracks (Johnson, 

1997a, pdf p. 90). By the end of 1956, plans were completed to increase Livermore staff to about 

1,000 personnel and to invest 5 million dollars in the construction of permanent buildings and support 

facilities across the street from LLNL. SNL-Livermore employees occupied their first building 

(Building 911) on the newly developing SNL-Livermore site in October 1957 (Johnson, 1997a, pdf p.

90).

NIOSH has encountered data retrieval problems while processing individual claims and performing 

SNL-Livermore data capture work. The data retrieval issues appeared to potentially affect significant 

portions of the covered time period and impact all types of workers. As such, NIOSH determined that 

the entire time period through 1994 warranted evaluation. Towards the end of 1994, internal and 

external monitoring program oversight was being performed by the SNL-Albuquerque site and 

database use to maintain resultant data was becoming integrated. Because SNL-Livermore employees 

were located on LLNL property from 1956 until October 1957, any worker exposures incurred during 

that time would be determined in association with an EEOICPA evaluation for LLNL. 

Prior to the early 1990s, SNL-Livermore’s monitoring program and subsequent records retention were 

all performed on site. During this period, records were primarily in hard copy form and no centralized 

records center or database storage was being used. As centralized record storage databases were being 
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developed at SNL-Albuquerque (approximately 1989 for external data and 1993 for internal data), 

SNL-Livermore records, records retention, and oversight of the SNL-Livermore monitoring program 

were being transferred to SNL-Albuquerque. The data transfer process apparently started around 

1990 and occurred over several years. This sequence of events and the preliminary analysis of 

EEOICPA claimant data associated with SNL-Livermore indicate that the storage of both internal and 

external SNL-Livermore monitoring data, either in reliably retrievable hard-copy form or within the 

developing databases systems, was likely not well established until the 1993-1994 time period. SNLLivermore monitoring data sufficiency from 1995 to present is not within the scope of this evaluation 

but is being assessed in conjunction with an ongoing SNL-Albuquerque database evaluation. 

4.4 Site Locations Associated with Radiological Operations

Because SNL-Livermore employees were located on LLNL property from 1956 until October 1957, 

any worker exposures incurred during that time would be determined in association with an 

EEOICPA evaluation for LLNL. NIOSH has determined that the site-specific and claimant-specific 

data available for this evaluation are insufficient to allow NIOSH to characterize worker movements 

across the SNL-Livermore site between areas containing radiological source material and other areas 

of the site during the portion of the evaluation period presented in this report (effectively October 1, 

1957 through December 31, 1994). NIOSH is unable to accurately assess whether an energy 

employee, or class of employees, did or did not potentially enter specific areas of the SNL-Livermore 

site having the potential for radiological exposures during the defined period of time. NIOSH is 

therefore unable to define individual worker exposure scenarios based on specific work locations at

SNL-Livermore during the period from October 1, 1957 through December 31, 1994.

4.5 Job Descriptions Affected by Radiological Operations

NIOSH has determined that the site-specific and claimant-specific data available for SNL-Livermore

for the time period under evaluation are insufficient to allow NIOSH to determine that any specific 

work group was not potentially exposed to radioactive material releases or possible subsequent 

contamination.

NIOSH has insufficient information associating job titles and/or job assignments with specific

radiological operations or conditions. Without such information, NIOSH is unable to define potential 

radiation exposure conditions based on worker job descriptions.

5.0 Summary of Available Monitoring Data for the Proposed Class

The primary data used for determining internal exposures are derived from personal monitoring data, 

such as urinalyses, fecal samples, and whole-body counting results. If these are unavailable, the air 

monitoring data from breathing zone and general area monitoring are used to estimate the potential 

internal exposure. If personal monitoring and breathing zone area monitoring are unavailable, internal 

exposures can sometimes be estimated using more general area monitoring, process information, and 

information characterizing and quantifying the source term.

This same hierarchy is used for determining the external exposures to the cancer site. Personal 

monitoring data from film badges or thermoluminescent dosimeters (TLDs) are the primary data used 
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to determine such external exposures. If there are no personal monitoring data, exposure rate surveys, 

process knowledge, and source term modeling can sometimes be used to reconstruct the potential 

exposure.

A more detailed discussion of the information required for dose reconstruction can be found in 

OCAS-IG-001, External Dose Reconstruction Implementation Guideline, and OCAS-IG-002, Internal 

Dose Reconstruction Implementation Guideline. These documents are available at: 

http://www.cdc.gov/niosh/ocas/ocasdose.html.

5.1 Data Capture Efforts and Sources Reviewed 

As a standard practice, NIOSH completed an extensive database and Internet search for information 

regarding SNL-Livermore. The database search included the DOE Legacy Management Considered 

Sites database, the DOE Office of Scientific and Technical Information (OSTI) database, the Energy 

Citations database, and the Hanford Declassified Document Retrieval System. In addition to general 

Internet searches, the NIOSH Internet search included OSTI OpenNet Advanced searches, OSTI 

Information Bridge Fielded searches, Nuclear Regulatory Commission (NRC) Agency-wide 

Documents Access and Management (ADAMS) web searches, and the DOE-National Nuclear 

Security Administration-Nevada Site Office-search. Attachment One contains a summary of the 

available SNL-Livermore documents. The summary specifically identifies 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 data sources to determine information relevant to determining the feasibility of dose 

reconstruction for the class of employees under evaluation in this report. This included determining 

the availability of information on personal monitoring, area monitoring, industrial processes, and 

radiation source materials. The following subsections summarize the data sources identified and 

reviewed by NIOSH.

5.2 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 petition 

evaluation. Table 5-1 summarizes the results of this review. (NOCTS data available as of July 18, 

2013)
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Table 5-1: No. of SNL-Livermore Claims Submitted Under the Dose Reconstruction Rule

Description Totals

Total number of claims submitted for dose reconstruction 132

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

evaluation (October 1, 1957 through December 31, 1994) 123

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). 105

Number of claims for which internal dosimetry records were obtained for the identified years in the 

evaluated class definition 25

Number of claims for which external dosimetry records were obtained for the identified years in the 

evaluated class definition 112

NIOSH reviewed each claim to determine whether internal and/or external personal monitoring 

records could be obtained for the employee. Of the total of 123 claims submitted for employees who 

worked during the period under evaluation, SNL-Livermore has responded to 120 claims. Of these 

120 claims, SNL-Albuquerque has supplied internal monitoring data for 21 claimants (~18%). 

NIOSH captured internal monitoring data for an additional four claimants. Of the 120 claims 

receiving SNL-Livermore/DOE responses, SNL-Albuquerque has supplied external monitoring data 

for 71 claimants (59%). NIOSH captured external monitoring data for an additional 41 claimants.

5.3 Worker Interviews

There have been multiple SNL-Livermore worker interviews (individual and group interviews) with 

current and former SNL-Livermore personnel. Some of these interviews were performed by NIOSH, 

while others were interviews performed by organizations for purposes other than supporting this

specific evaluation report. These interviews have been considered and referenced throughout this 

evaluation. Interviews have been conducted via telephone and in person. They were conducted in 

accordance with site procedures for both classified and unclassified activities and are referenced 

below:

• Personal Communication, 2006, Personal Communication with an SNL-Livermore Health 

Physicist; In-Person Interview by ORAU Team; April 12, 2006; SRDB Ref ID: 23574

• Personal Communication, 2009a, Personal Communication with an SNL-Livermore Site 

Historian; In-Person Interview by SC&A/Saliant; February 18, 2009; SRDB Ref ID: 119139

• Personal Communication, 2009b, Personal Communication with an SNL-Livermore 

Engineer/Management; In-Person Interview by SC&A/Saliant; June 9, 2009; SRDB Ref ID: 

119135

• Personal Communication, 2009c, Personal Communication with an SNL-Livermore Research 

Chemist; In-Person Interview by SC&A/Saliant; June 10, 2009; SRDB Ref ID: 119134
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• Personal Communication, 2009d, Personal Communication with an SNL-Livermore Radiation 

Protection Worker; In-Person Interview by SC&A/Saliant; June 10, 2009; SRDB Ref ID: 119136

• Personal Communication, 2009e, Personal Communication with an SNL-Livermore Worker 

Involved in Environmental Monitoring; In-Person Interview by SC&A/Saliant; June 10, 2009; 

SRDB Ref ID: 119137

• Personal Communication, 2009f, Personal Communication with an SNL-Livermore Radiation

Technician; In-Person Interview by SC&A/Saliant; June 11, 2009; SRDB Ref ID: 119138

• Personal Communication, 2009g, Personal Communication with an SNL-Livermore Mechanical 

Engineer; Telephone Interview by SC&A/Saliant; June 15, 2009 & June 28, 2009; SRDB Ref ID: 

119141

• Personal Communication, 2013a, Personal Communication with Seven Former SNL-Livermore 

Employees; In-Person Interviews by NIOSH; multiple interviews with dates ranging from January 

19-24, 2013; SRDB Ref ID: 125770 & 125792

• Personal Communication, 2013b, Personal Communication with Two SNL-Livermore Workers; 

In-Person Interviews by NIOSH; January 22, 2013; SRDB Ref ID: 125756

5.4 Internal Personnel Monitoring Data

This section provides a summary of the types of internal personnel monitoring data known to have 

been collected (but not necessarily available to NIOSH) during the October 1, 1957 through 

December 31, 1994 evaluation period at SNL-Livermore. The information has been obtained via 

interviews with SNL-Livermore workers and through document data capture efforts. Monitoring data 

for the vast majority of this time period exists almost exclusively in hard copy form, in individual 

worker files, and in generally poorly indexed inactive record storage. As a result, NIOSH is unable to 

ascertain an accurate number of total internal and external monitoring results for the monitored site 

workers over the evaluated period. Additional details of problems associated with record storage are 

detailed in Section 6.0 of this evaluation.

Work with radionuclides that created a potential for internal exposure at SNL-Livermore included

depleted uranium machining, tritium research conducted in the TRL, classified operations, and other 

various research projects over the years (ORAUT-TKBS-0053). Highly enriched uranium and 

thorium were also known to be onsite and could possibly have been sources of internal exposures.

Radiation workers were monitored for internal exposures using urine bioassay.

Based on available monitoring data, the radionuclides of primary concern for internal dosimetry at 

SNL-Livermore appear to have been tritium and uranium. Tritium exposure occurred primarily in the 

TRL. The primary detection method for intakes of tritium at SNL-Livermore has been urine bioassay 

(Potter, unspecified). There is no evidence that urine bioassay samples were analyzed for any 

radionuclides except tritium and uranium, or that other types of bioassay (i.e., fecal analyses or in vivo

counting) were employed at SNL-Livermore prior to 1992. However, preliminary examination of 

SNL-Albuquerque’s internal monitoring database indicates that a few monitoring data are available 
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for thorium and plutonium isotopes, americium, and mixed fission products starting in 1992. Thus 

far, no internal monitoring data other than urine bioassay samples for uranium and tritium have been 

provided during the EEOICPA claims process. 

The uranium bioassay was performed on individuals involved in machining depleted uranium as well 

as others involved with handling uranium powders or those defined as “Radiation Workers” in areas 

where air concentrations potentially exceeded 10% of the air concentration guidelines. Captured 

documentation indicates that this monitoring requirement and definition was implemented in 1979

(Wright, 1979). Although bioassay monitoring was performed earlier, monitoring program procedural 

documentation stipulating requirements have not been captured. Additionally, insufficient data 

availability precludes using co-worker models to fill in data gaps.

5.4.1 Tritium Bioassay

According to a final facility status report for TRL (Garcia & Gorman, 1996), tritium bioassays were 

performed on a weekly basis for individuals involved in experimental work at the TRL from 1979 

through 1995 when the TRL was decommissioned. Individuals working in the Waste Handling 

Facility may also have participated in the tritium bioassay program, at least during 1991 (Garcia, 

1991a; Garcia, 1991b). Bioassays were also required for all personnel inside the TRL when an 

evacuation alarm occurred (ORAUT-TKBS-0053). Additional samples were required in some cases 

by Safe Work Permits (SWPs) or at the discretion of health physicists. The Tritium Research 

Laboratory Safety Analysis Report (Wright, 1981) specifies weekly bioassay with samples analyzed 

by liquid scintillation counting (Wright, 1981, pdf p. 100). Laboratory analyses were performed, in 

house, by the Health Physics Division. As evidenced by reviewed documentation, doses were 

calculated and reported on a monthly basis.

A 1993 memo (Wright, 1993) describes the methods by which tritium bioassay data were managed 

between 1977 and 1993. According to the memo, bioassay results were originally maintained in a 

VAX text file. The VAX files were transferred into REFLEX, a database management program in 

1988. In 1990, the files were sent to SNL-Albuquerque for entry into personnel dosimetry histories. 

As of 1993, the date of the memo, the bioassay data were collected by SNL-Livermore and a hard 

copy was sent to SNL-Albuquerque on a monthly or quarterly basis. 

The TRL Health Physics Quarterly Summaries from 1988 through 1995 confirm that urine specimens 

were collected on a weekly basis and tritium concentrations were determined by liquid scintillation 

counting. Initially, absorbed doses were calculated for all individuals whose urine bioassay results 

indicated that they might have received a dose greater than 10 mrem per calendar quarter based on the 

fact that 10 mrem was the reported sensitivity of the TLDs used for external dosimetry. From 1991 

through 1992, absorbed doses were calculated for individuals whose bioassay results indicated a dose 

greater than 2 mrem per calendar quarter (ORAUT-TKBS-0053). From 1993 through 1995, absorbed 

doses were calculated for individuals whose bioassay results indicated a dose greater than 1 mrem per 

calendar month (ORAUT-TKBS-0053). 

5.4.2 Uranium Bioassay

Uranium bioassays were required for SNL-Livermore workers involved in depleted uranium

machining and other operations where airborne uranium might have been encountered. The urine 
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bioassay criteria for depleted uranium were described in 1979 correspondence (Wright, 1979). 

Documentation of earlier monitoring requirements have not been captured. The criteria for minimum 

routine (semi-annual) uranium bioassay (from 1979 forward at least) were as follows:

• When air sampling results show concentrations at or greater than 10% of the concentration guide 

of 1E-10 μCi/cm3.

• For routine handling of uranium hydrides, solutions of uranium compounds, and uranium powders 

(>4 times per quarter).

• Machining of uranium.

• During any operation that the Hazards Control Division deemed hazardous, or requires air 

sampling in a SOP or SWP.

Non-routine bioassays were performed in the following situations:

• Cut or lesion during handling or machining of uranium.

• An individual in close proximity or exposed to a uranium metal fire.

• Skin contact with a solution of uranium.

DU alloy machining was performed under SOP 1066 (SOP#1066). The SOP required that all 

machining operations be performed wet, reducing the risk of fire and generation of airborne dust. The 

SNL SOP #1066 required semi-annual urine bioassay for uranium but noted that “more frequent urine 

samples are usually collected” (SOP#1066, pdf p. 4).

5.5 External Personnel Monitoring Data

Historical documentation related to radiological protection programs at SNL-Livermore indicates that 

external dosimetry monitoring for workers and visitors has been performed throughout the site’s 

history. As was the case with internal monitoring data as noted above in the internal monitoring data 

section, little of the external monitoring data applicable to the time period being evaluated are stored 

electronically; instead, monitoring data are stored in individual worker files or poorly-indexed inactive 

storage. Efficient retrieval of records for compiling total available measurements and results by 

NIOSH has not been feasible. 

From 1956 to 1959, LLNL performed external film dosimetry monitoring services for SNL-Livermore

(ORAUT-TKBS-0053). After that, a commercial vendor called Radiation Detection Company (RDC) 

provided film dosimetry services until the early 1970s (Hanzel, 1960, pdf p. 5; Monitoring Results, 

1961-1962; Campbell et al., 1962; Various, 1964; Lovell, 1966; Monitoring Results, 1969). In 1962, 

there was a brief transfer of contracted film processing services from RDC to a similar provider called 

Tracerlab (Campbell et al., 1962; ORAUT-TKBS-0053), but Tracerlab was quickly dropped due to 

poor performance and the contract with RDC was re-established. From about 1972 to 1988, SNLLivermore external dosimetry was outsourced to the DOE Radiological and Environmental Sciences 

Laboratory (RESL) in Idaho Falls, ID (Wright, 1993; Wallace, 1988). In 1989, dosimetry services for 
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SNL-Livermore were transferred to SNL headquarters in Albuquerque, New Mexico. In 1991, the 

dosimetry processing laboratory at SNL-Albuquerque became DOE Laboratory Accreditation 

Program (DOELAP)-accredited (Loesch, 1991) as part of the overall plan to provide centralized, 

unified, and permanent dosimetry services for SNL-Livermore and other Sandia sites (Stanley, 1991; 

Ward, 1994; ORAUT-TKBS-0053). 

Documents from early in SNL-Livermore’s history indicate a policy of maintaining permanent 

dosimetry records (ORAUT-TKBS-0053). Between 1956 and 1959, most SNL-Livermore 

employees, contractors and visitors were required to wear dosimeter badges (Hanzel, 1960; ORAUTTKBS-0053). Though LLNL was performing dosimetry services for SNL-Livermore during this 

time, records management was implemented manually by on-site personnel. Records management 

continued to be administered by SNL-Livermore (Division 8242-2) for the subsequent period in which 

RDC provided dosimetry services (1959 to about 1971). By 1965, discussions among SNLAlbuquerque management were taking place with respect to the need to badge all on-site personnel 

versus badging only personnel with access to “exclusion zones” (areas where radiation fields were 

present). Eventually, the policy of badging all personnel was abandoned in favor of badging only 

individuals with potential to exceed certain exposure limits, which appears to have occurred in 1970, 

according to summarized annual reports of external exposures (Monitoring Results, 1958-1978;

ORAUT-TKBS-0053). In 1989, oversight of the external dosimetry program at SNL-Livermore was 

transferred to SNL-Albuquerque and has since been directed and managed by SNL-Albuquerque’s 

Personnel Dosimetry Department 7715, with on-site oversight and implementation conducted by 

SNL-Livermore’s Personnel Dosimetry Department 8541 (Ward, 1994). 

5.6 Workplace Monitoring Data

Though captured documents indicate that some workplace monitoring (air sampling, surveys, smears, 

etc.) was performed over the years, to date, almost no results applicable to the 1957 through 1994 

period have been located. A few survey summaries have been captured as well as some 1994 general 

area air monitoring results for the TRL. NIOSH has recently obtained permission to view an index 

that may allow for retrieval of at least some historical workplace monitoring data. However, it is not 

anticipated that the availability of these data will negate the infeasibility of performing dose 

reconstruction due to insufficient access to personal monitoring data and source term information. 

Findings from a 1990 DOE Tiger Team assessment noted improperly calibrated portable and fixed air 

sampling units, no flow calibration procedures, and no flow calibration data availability (DOE, 1990, 

pdf p. 286). 

5.7 Radiological Source Term Data

The limited source term information available to NIOSH that is relevant to this evaluation was 

presented in Section 4.1. NIOSH has performed seven data capture visits to SNL-Livermore. Over 

1,000 records have been captured. Multiple interviews have also been performed (see Section 5.3). 

Nevertheless, NIOSH lacks sufficiently detailed source term information on unclassified and 

classified activities that would allow it to confidently estimate all potential exposures that may have 

occurred. Potential exposure locations include at the Weapons Laboratory Facility Complex, 

Radiography, Micro and Nano Technologies Laboratories, the Explosives and Environmental Testing 

Complex, the TRL, and the storage facilities. Radionuclides include tritium, depleted uranium, highly 
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enriched uranium, uranium tritide, uranium hydride, various isotope sources utilized within the 

Radiography Facility, and thorium. Classified activities may have also presented additional potential 

exposure sources.

6.0 Feasibility of Dose Reconstruction for the Proposed Class

42 C.F.R. § 83.14(b) states that HHS will consider a NIOSH determination that there was insufficient 

information to complete a dose reconstruction, as indicated in this present case, to be sufficient,

without further consideration, to conclude that it is not feasible to estimate the levels of radiation 

doses of individual members of the class with sufficient accuracy. 

In the case of a petition submitted to NIOSH under 42 C.F.R. § 83.9(b), NIOSH has already 

determined that a dose reconstruction cannot be completed for an employee at the DOE or AWE 

facility. This determination by NIOSH provides the basis for the petition by the affected claimant. 

Per § 83.14(a), the NIOSH-proposed class defines those employees who, based on completed 

research, are similarly affected and for whom, as a class, dose reconstruction is similarly not feasible.

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility for 

whom NIOSH believes that dose reconstruction is similarly infeasible, but for whom additional 

research and analysis is required. If so identified, NIOSH would address this second class in a 

separate SEC evaluation rather than delay consideration of the claim currently under evaluation (see 

Section 10). This would allow NIOSH, the Board, and HHS to complete, without delay, their 

consideration of the class that includes a claimant for whom NIOSH has already determined a dose 

reconstruction cannot be completed, and the only possible remedy under EEOICPA is the addition of 

a class of employees to the SEC.

This section of the report summarizes research findings by which NIOSH determined that it lacked 

sufficient information to complete the relevant dose reconstruction and on which basis it has defined 

the class of employees for which dose reconstruction is not feasible. NIOSH’s determination relies on 

the same statutory and regulatory criteria that govern consideration of all SEC petitions.

Section 6.0 describes what is known about pre-1994 monitoring data and source term information 

availability. Historical data storage practices, and the handling and disposition of data transferred 

from SNL-Livermore to SNL-Albuquerque have both adversely impacted current data availability 

making dose reconstruction infeasible. Comparisons of claimant monitoring data supplied by SNLAlbuquerque/DOE (now located in the NOCTS database) to data captured by NIOSH have been 

made. Discrepancies in data availability noted during these comparisons further highlight the frequent 

inconsistency between data originally collected, and that which can reliably and efficiently be 

retrieved from current data storage locations during claims processing. It is noteworthy that similar 

discrepancies stemming from data retention and availability were observed during the SNLAlbuquerque site SEC-00188 evaluation (NIOSH, 2012). Those discrepancies resulted in inclusion of 

a class into the SEC for all workers at that site up through 1994. As mentioned previously, the early 

1990s time period also saw SNL-Albuquerque assuming responsibility for the SNL-Livermore 

monitoring program direction and record retention.
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Details for internal and external monitoring data comparisons (NOCTS versus site-supplied) will be 

discussed in their respective subsections below (6.1 and 6.2). To avoid repetition however, 

descriptions of the historical events simultaneously affecting both internal and external data 

availability and sufficiency are presented in this section.

According to interviews performed with site records personnel, the SNL-Livermore records storage 

during the 1957 through 1994 period was generally decentralized (ORAUT-TKBS-0053). Many 

different operations and areas of the site maintained their own records until 1993-1994 when an onsite 

Environmental, Safety and Health Records center was established. Efforts were made to consolidate 

records within the center, and also to transfer collected monitoring records to SNL-Albuquerque

during the early 1990s time frame. This was because SNL-Albuquerque was to take over the 

administration and record maintenance functions for SNL-Livermore’s occupational radiological 

monitoring program. The completeness of both the consolidation and transfer of records to SNLAlbuquerque is uncertain for several reasons. One reason is that periodically records were moved to

long term storage in the Iron Mountain storage facility in Irvine, California, prior to the initiation of 

record transfers to the SNL-Albuquerque site. It has been learned through interviews that transferred 

record descriptions were generally insufficient to support required targeted identification and retrieval 

of monitoring records from Iron Mountain. Likewise, transferred record descriptions are insufficient 

to determine the total numbers and precise types of records moved to the facility. Personnel and area 

monitoring (and possible source term) records sent to the Iron Mountain repository have not been 

transferred back to the SNL-Albuquerque site.

Indexing of records received from SNL-Livermore during the early 1990s was also generally 

insufficient. Once received, an unknown number of these transferred records were subsequently 

moved into SNL-Albuquerque’s inactive (long term) record storage without sufficient re-labeling so 

as to allow efficient, targeted retrieval. It appears that frequently the records were moved directly to 

long-term storage without making copies for personal files or entering into the databases being 

developed at the time. At some point, electronic entry of some of the transferred, hard-copy SNLLivermore monitoring data was performed by students. However, these records are not considered 

official records by the site because the work was never quality checked. 

An official listing of all historical dose records collected at SNL-Livermore is not available. As such, 

it is not currently possible to know how many SNL-Livermore monitoring records were originally 

generated during the 1957-1994 period, or how many of these records are now stored in either of the 

inactive record storage areas used by the two sites (without suitable, detailed indexing of the records

for efficient retrieval). It is expected that the record storage problems described above affect other 

types of documents such as process, source term, and work place monitoring information.

6.1 Feasibility of Estimating Internal Exposures

NIOSH has evaluated the available personnel and workplace monitoring data and source term 

information and has determined that there are insufficient data for estimating internal exposures, as 

described below.

NIOSH has obtained relatively few internal monitoring data for the evaluated period. The total 

quantity of internal monitoring data potentially available from SNL-Albuquerque is likely low, due to 
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the relatively low internal exposure potential for many of the activities onsite. Bioassay data for the 

evaluated period have been provided in response to EEOICPA claimant data requests, and also found 

in NIOSH-obtained documents through various data capture processes. In addition to internet and 

onsite searches, NIOSH included records selected from inactive storage (long term) during data 

capture efforts.

A comparison of internal monitoring data obtained by NIOSH during its own data capture efforts to 

data supplied by SNL-Albuquerque for the EEOICPA claimant data requests has been performed. 

The results highlight the ongoing retrieval issues associated with data collected and stored prior to the 

first electronic storage systems being put in place. Of the 123 NOCTS claims filed with employment 

within the 1957 through 1994 period, at least 25 were monitored for internal doses based on data 

supplied by the site and/or obtained by NIOSH via data capture efforts. It is likely that more 

employees were monitored; however, no additional data have been captured or provided to date. Of 

these 25 monitored workers, NIOSH captured internal monitoring data for 4 workers (16%) for which

the site supplied no internal monitoring data in EEOICPA claims responses. In addition to the four 

workers for whom the site supplied no internal monitoring data, NIOSH also captured reports for 

many of the other 25 workers that contained results not supplied by the site (different years).

Numbers of individual internal monitoring reports (containing unique data) that were captured by 

NIOSH, but not supplied by SNL-Livermore during the EEOICPA claim dose reconstruction process 

are summarized by decade in Table 6-1. 

Table 6-1: No. of Internal Monitoring Reports Captured by NIOSH and Not Supplied by SNL-Livermore

Decade 1950s 1960s 1970s 1980s 1990s

No. of Data 

Reports 2 2 8 18 3

The results highlight internal monitoring data availability and retrievability problems associated with

the data collected from the beginning of the evaluated period up into the early 1990s, at a minimum. 

Two of the three 1990s monitoring reports captured by NIOSH (and not supplied by the site during 

claims processing) were from 1994. Capturing these documents highlights the unreliability of internal 

monitoring data storage and its subsequent availability for reconstructing internal doses up through 

1994.

Historically decentralized record keeping practices, improper indexing of records placed in long term 

storage, and a lack of electronic record storage has also prevented NIOSH’s ability to determine with 

confidence, that sufficient information associating job titles and/or job assignments with specific 

radiological operations or conditions are available. Without such information, NIOSH is unable to 

define potential radiation exposure conditions based on worker job descriptions. In addition, due to 

index descriptions that are insufficient for efficient retrieval, it is not known to what extent documents 

describing processes, source terms, and workplace monitoring may have been either lost or transferred 

to inactive storage locations. At a minimum, it is known that among other radionuclides listed in 

Table 4-2, potential onsite radiation sources contributing to internal dose included depleted uranium, 

tritium, and uranium tritides and hydrides. Highly enriched uranium and thorium are also known to 

have been onsite in significant quantities per classified data capture work and may have also been 

dose sources. 
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In an attempt to obtain necessary process, source term, and work place monitoring details, NIOSH has 

performed seven data capture visits to the SNL-Livermore site and captured and reviewed over 1,000 

records. Multiple interviews have also been performed (see Section 5.3). NIOSH has nevertheless 

determined it does not have access to sufficient personnel monitoring, workplace monitoring, or 

source term data to estimate potential internal exposures to tritium, highly enriched uranium, depleted 

uranium, uranium tritides and hydrides, thorium, and classified activities during the period of DOE 

operations. Consequently, NIOSH finds that it is not feasible to estimate, with sufficient accuracy, 

internal exposures to, tritium, highly enriched uranium, depleted uranium, uranium tritides and

hydrides, thorium, and classified activities and resulting doses for the class of employees covered by 

this evaluation.

6.2 Feasibility of Estimating External Exposures

NIOSH has evaluated the available personnel and workplace monitoring data and source term 

information and has determined that there are data insufficiencies for estimating external exposures, as 

described below. Data insufficiencies described would be expected to affect all external monitoring 

data including beta, gamma, and neutron monitoring data.

External monitoring data for the evaluated period have been returned during EEOICPA claimant data 

requests, and also found in NIOSH-obtained documents through various data capture processes. In 

addition to internet and onsite searches, NIOSH included records selected from inactive storage (long 

term storage) during data capture efforts.

A comparison of external monitoring data obtained by NIOSH during its own data capture efforts to 

data supplied by SNL-A for the EEOICPA claimant data requests has been performed. The results 

highlight the ongoing retrieval issues associated with data collected by SNL-Livermore and 

data/documentation storage issues described in Section 6.0. Of the 123 SNL-Livermore worker 

EEOICPA claims filed with employment within the 1957-1994 period, at least 112 of those 

employees were monitored for external exposures based on data supplied by the site and/or obtained 

by NIOSH via data capture efforts. It is possible that more employees were monitored; however, to 

date, no additional data have been discovered or provided. Of these 112 workers monitored, NIOSH 

captured external monitoring data for 41 workers (~36 %) for which the site supplied no external 

monitoring data in EEOICPA claims responses. The number of individual external monitoring reports 

(containing unique data) that were captured by NIOSH, but not supplied by SNL-Livermore during 

the EEOICPA claim dose reconstruction process are summarized by decade in Table 6-2.

Table 6-2: No. of External Monitoring Reports Captured by NIOSH and Not Supplied by SNL-Livermore

Decade 1950s 1960s 1970s 1980s 1990s

No. of Data 

Reports 11 66 62 25 12

The results highlight external monitoring data availability problems associated with the beginning of 

the evaluated period up into the early 1990s at a minimum. Three of the twelve 1990s monitoring 
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reports captured by NIOSH (and not supplied by the site during claims processing) were from 1992. 

Capturing these documents highlights the unreliability of external monitoring data storage and its 

subsequent availability for reconstructing internal doses up through 1992 at least. Uncertainty 

currently surrounds process and source term information, and internal data availability information up 

to 1994 due to the data transfer and storage processes described in Sections 6.0 and 6.1 above. As 

such, NIOSH is unable to conclusively demonstrate that external monitoring data availability for 1993 

and 1994 is sufficient to reconstruct doses incurred in those years for all workers. 

As was the case for internal record availability, historically decentralized record keeping practices, 

improper indexing of records placed in long term storage, and a lack of electronic record storage has 

also prevented NIOSH’s ability to determine with confidence that sufficient information associating 

job titles and/or job assignments with specific radiological operations or conditions are available. 

Without such information, NIOSH is unable to define potential radiation exposure conditions based 

on worker job descriptions. In addition, with index descriptions that are insufficient for efficient 

retrieval, it is not known to what extent documents describing processes, source terms, and work place 

monitoring may have been either lost or transferred to inactive storage locations. At a minimum, it is 

known that among other radionuclides listed in Table 4-2, potential onsite radiation sources 

contributing to external exposure included highly enriched uranium, uranium hydrides, the 

Radiography Facility isotope sources, and thorium. Classified work likely also presented potential

sources for exposure during the 1957-1994 period. 

In an attempt to obtain necessary process, source term, and work place monitoring details, NIOSH has 

performed seven data capture visits to SNL-Livermore and captured and reviewed over 1,000 records. 

Multiple interviews have also been performed (see Section 5.3). NIOSH has nevertheless determined 

that it does not have access to sufficient personnel monitoring, workplace monitoring, or source term 

data to estimate potential external exposures to beta, gamma, and neutron radiation from highly 

enriched uranium, uranium hydrides, Radiography Facility isotope sources, thorium, and classified 

work during the period of DOE operations. Consequently, NIOSH finds that it is not feasible to 

estimate with sufficient accuracy beta, gamma, and neutron external exposures resulting from highly 

enriched uranium, uranium hydrides, Radiography Facility isotope sources, thorium, classified work, 

and resulting doses for the class of employees covered by this evaluation.

Although NIOSH found that it is not possible to completely reconstruct external radiation doses for 

the period from October 1, 1957 through December 31, 1994, NIOSH intends to use any external 

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-Livermore during the period from October 1, 1957 through December 31, 1994, but 

who do not qualify for inclusion in the SEC, may be performed using these data as appropriate.

6.3 Class Parameters Associated with Infeasibility

Per the DOE Office of Health, Safety and Security, the time period associated with DOE operations at 

the SNL-Livermore site is from 1956 through present. NIOSH has encountered monitoring data 

retrieval problems while processing individual claims and performing SNL-Livermore data capture 

work. The data retrieval issues appeared to potentially affect significant portions of the covered time 

period and impact all types of workers. As such, NIOSH determined that the entire operational time 
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period through 1994 warranted evaluation. Towards the end of 1994 internal and external monitoring 

program oversight was being performed by the SNL-Albuquerque site and database use to maintain 

resultant data was becoming integrated with their system. SNL-Livermore monitoring data 

sufficiency from 1995 to present is not within the scope of this evaluation. 

NIOSH therefore recommends that the class include the period from October 1, 1957 through 

December 31, 1994. Because SNL-Livermore employees were located on LLNL property from 1956 

until October 1957, any worker exposures incurred during that time would be determined in 

association with an EEOICPA evaluation for LLNL. 

NIOSH has determined that there continues to be insufficient access control information and worker 

movement data to accurately assess whether an energy employee, or class of employees, did or did not 

potentially enter specific areas containing radiological source material and other areas of the site during 

the portion of the evaluation period presented in this report (October 1, 1957 through December 31, 

1994). NIOSH recommends that the class definition include all buildings and all areas during the 

specified time period.

NIOSH has determined that the site-specific and claimant-specific data available for SNL-Livermore 

for the time period under evaluation are insufficient to allow NIOSH to determine that any specific 

work group was not potentially exposed to radioactive material releases or possible subsequent 

contamination. NIOSH has insufficient information associating job titles and/or job assignments with 

specific radiological operations or conditions. Without such information, NIOSH is unable to define 

potential radiation exposure conditions based on worker job descriptions. NIOSH therefore 

recommends that the class include all workers, regardless of job titles or job/work descriptions during the 

proposed time period.

7.0 Summary of Feasibility Findings for Petition SEC-00214

This report evaluates the feasibility for completing dose reconstructions for employees at SNLLivermore from October 1, 1957 through December 31, 1994. NIOSH determined that members of 

this class may have received radiation exposures from tritium, depleted uranium, highly enriched 

uranium, uranium tritides and hydrides, and thorium. NIOSH lacks sufficient information, which 

includes biological monitoring data, sufficient process, and radiological source information, that would 

allow it to estimate the potential internal and external exposures to which the proposed class may have 

been exposed.

NIOSH has documented herein that it cannot complete the dose reconstructions related to this petition. 

The basis of this finding demonstrates that NIOSH does not have access to sufficient information to 

estimate either the maximum radiation dose incurred by any member of the class or to estimate such 

radiation doses more precisely than a maximum dose estimate.

NIOSH finds that it is likely feasible to reconstruct occupational medical dose for SNL-Livermore 

workers with sufficient accuracy up through 1989. After 1989 medical X-rays are not applicable 

because they were performed offsite.
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Although NIOSH found that 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 

SNL-Livermore during the period from October 1, 1957 through December 31, 1994, but who do not 

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

8.0 Evaluation of Health Endangerment for Petition SEC-00214

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

governed by EEOICPA and 42 C.F.R. § 83.14(b) and § 83.13(c)(3). Pursuant to these requirements, if 

it is not feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH 

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

the health of members of the class. The regulations require 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 workers 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 has determined that members of the class were not exposed to radiation during a discrete 

incident likely to have involved levels of exposure similarly high to those occurring during nuclear 

criticality incidents. However, the evidence reviewed in this evaluation indicates that some workers in 

the class may have accumulated chronic radiation exposures through intakes of radionuclides and 

from direct exposure to radioactive materials. Consequently, NIOSH is specifying that health was 

endangered for those workers covered by this evaluation who were employed for a number of work 

days aggregating at least 250 work days within the parameters established for this class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC.

9.0 NIOSH-Proposed Class for Petition SEC-00214

The evaluation defines a single class of employees for which NIOSH cannot estimate radiation doses 

with sufficient accuracy. This 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-Livermore in Livermore, California, from October 1, 1957 through December 

31, 1994, 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 Evaluation of Second Similar Class

In accordance with § 83.14(a), NIOSH may establish a second class of co-workers at the facility, 

similar to the class defined in Section 9.0, for whom NIOSH believes that dose reconstruction may not 

be feasible, and for whom additional research and analyses is required. If a second class is identified, 

it would require additional research and analyses. Such a class would be addressed in a separate SEC 

evaluation rather than delay consideration of the current claim. At this time, NIOSH has not identified 

a second similar class of employees at SNL-Livermore for whom dose reconstruction may not be 

feasible.
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11.0 References

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p 22,296; May 2, 2002; SRDB Ref ID: 19391

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

19392

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000; as amended; DCAS website

Adolphson, 1972, Machining Test Specimens in Uranium Alloys, correspondence to J. F. Bryson; D. 

R. Adolphson; April 7, 1972; SRDB Ref ID: 23662

Campbell et al., 1962, Dosimetry Program Information; collection of three correspondence; R. O. 

Campbell, Robert Crow, and Eugene Tochilin; June 1962 (7th, 18th, 19th); SRDB Ref ID: 23724

DOE, 1990, Tiger Team Assessment of the Sandia National laboratories Livermore, California, 

DOE/EH-0141; Department of Energy (DOE); August 1990; SRDB Ref ID: 23554

DOE, 1992, Final Environmental Impact Statement and Environmental Impact Report for Continued 

Operation of Lawrence Livermore National Laboratory and Sandia National Laboratories, 

Livermore, Volume II of V, Appendices A-D, DOE/EIS-0157; Department of Energy (DOE); August 

1992; SRDB Ref ID: 15935

DOE, 2003, Final Site-Wide Environmental Assessment of the Sandia National 

Laboratories/California, DOE/EA-1422; Department of Energy (DOE); January 2003; SRDB Ref ID: 

28165

Garcia, 1991a, Bioassay Program Requirements, correspondence to K. K. Babcock; T. B. Garcia; 

April 3, 1991; SRDB Ref ID: 23664, pdf p. 3

Garcia, 1991b, Radioactive/Mixed Waste Operations at Buildings 961 & 968, correspondence to D. A. 

Wright; T. B. Garcia; May 24, 1991; SRDB Ref ID: 23664, pdf pp. 4-5

Garcia & Gorman, 1996, Radiological Characterization and Final Facility Status Report Tritium 

Research Laboratory, SAND96-8004. UC-407; T. B. Garcia and T. P. Gorman; Printed August 1996; 

SRDB Ref ID: 22982
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Hanzel, 1960, Review and Evaluation of Present Film Badge Radiation Monitoring Program, Sandia 

Corporation, Livermore Laboratory, correspondence to G. L. Rhodes; Robert L. Hanzel; July 8, 1960; 

SRDB Ref ID: 23727 pdf pp. 5-9

Johnson, 1997a, Sandia National Laboratories, A History of Exceptional Service in the National 

Interest; Leland Johnson; printed in 1997; SRDB Ref ID: 84961

Johnson, 1997b, Tritium Research Laboratory Cleanup and Transition Project Final Report, 

SAND97-8009; A. J. Johnson; printed February 1997; SRDB Ref ID: 23424

Loesch, 1991, Laboratory Accreditation of Sandia National Laboratories, correspondence to Gene 

Runkle; Robert M. Loesch, Department of Energy; October 30, 1991; SRDB Ref ID: 19079

Lovell, 1966, Summary of Film Badges Cost for Fiscal Year 1966, correspondence to G. L. Rhodes; 

P. K. Lovell; September 13, 1966; SRDB Ref ID: 23678, pdf pp. 2-3

Lovell, 1982, Handling D-38 Contaminated B-83 Parts at SNLL, correspondence; P. K. Lovell; 

February 19, 1982; SRDB Ref ID: 24806

Monitoring Results, 1958-1978, Summaries of Whole-Body Radiation Exposures to Ionizing 

Radiation for Various Dates from 1958 through 1978; Sandia Laboratories; 1958-1978; SRDB Ref 

ID: 32731

Monitoring Results, 1961-1962, External Dosimetry Data for Various Dates from 1961 through 1962; 

1961-1962; SRDB Ref ID: 23720

Monitoring Results, 1969, Dosimetry Reports for Various Dates from June-December 1969; Vendor 

is Radiation Detection Company; 1969; SRDB Ref ID: 32296 & 23729

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

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

California, Rev. 00; ORAU Team Dose Reconstruction Project for NIOSH; Cincinnati, Ohio; May 1, 

2007; SRDB Ref ID: 31467

Personal Communication, 2006, Personal Communication with an SNL-Livermore Health Physicist; 

In-Person Interview by ORAU Team; April 12, 2006; SRDB Ref ID: 23574 

Personal Communication, 2009a, Personal Communication with an SNL-Livermore Site Historian; InPerson Interview by SC&A/Saliant; February 18, 2009; SRDB Ref ID: 119139 

Personal Communication, 2009b, Personal Communication with an SNL-Livermore 

Engineer/Management; In-Person Interview by SC&A/Saliant; June 9, 2009; SRDB Ref ID: 119135 
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Personal Communication, 2009c, Personal Communication with an SNL-Livermore Research 

Chemist; In-Person Interview by SC&A/Saliant; June 10, 2009; SRDB Ref ID: 119134 

Personal Communication, 2009d, Personal Communication with an SNL-Livermore Radiation 

Protection Worker; In-Person Interview by SC&A/Saliant; June 10, 2009; SRDB Ref ID: 119136

Personal Communication, 2009e, Personal Communication with an SNL-Livermore Worker Involved 

in Environmental Monitoring; In-Person Interview by SC&A/Saliant; June 10, 2009; SRDB Ref ID: 

119137

Personal Communication, 2009f, Personal Communication with an SNL-Livermore Radiation 

Technician; In-Person Interview by SC&A/Saliant; June 11, 2009; SRDB Ref ID: 119138

Personal Communication, 2009g, Personal Communication with an SNL-Livermore Mechanical 

Engineer; Telephone Interview by SC&A/Saliant; June 15, 2009 & June 28, 2009; SRDB Ref ID: 

119141

Personal Communication, 2013a, Personal Communication with Seven Former SNL-Livermore 

Employees; In-Person Interviews by NIOSH; multiple interviews with dates ranging from January 19-

24, 2013; SRDB Ref ID: 125770 & 125792

Personal Communication, 2013b, Personal Communication with Two SNL-Livermore Workers; InPerson Interviews by NIOSH; January 22, 2013; SRDB Ref ID: 125756

Potter, unspecified, Technical Basis Document for Internal Dosimetry at Sandia National 

Laboratories, Rev. 3, Radiation Protection Internal Dosimetry (RPID) Program; prepared by C. A. 

Potter; unspecified date; SRDB Ref ID: 23582

SNL, 1983, Sandia National Laboratories Livermore Environmental Summary for Calendar Year 

1983; SNL-Livermore; no publication date provided; SRDB Ref ID: 23130

SNL, 2005, Site Environmental Report for 2004 for Sandia National Laboratories, California, SAND 

2005-2628; B. L. Larsen, Sandia National Laboratories; printed June 2005; SRDB Ref ID: 22925

SOP#757, Safe Operating Procedure No. 757, Tritium Research Laboratory Uranium Tritide Bed; 

dated/revised February 26, 1991; SRDB Ref ID: 23774

SOP#1066, Sandia National Laboratories-Livermore SOP No. 1066, Machining Depleted Uranium 

Metal, Rev. C; dated October 1, 1989; SRDB Ref ID: 23733

SOP, 1994, ES&H Activity-Specific Standard Operating Procedure for Tritium Research Laboratory 

Uranium Tritide Bed, SP472820 Issue B; September 1994; SRDB Ref ID: 71581

Stanley, 1991, Basis for Wearing Only One Dosimeter, correspondence to N. R. Ortiz with select 

pages of a DOE Handbook regarding the accreditation program for personnel dosimetry systems; A. 

L. Stanley; April 22, 1991; SRDB Ref ID: 18275
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Ullrich, 2003, Cold War Context Statement, Sandia National Laboratories, California Site, 

SAND2003-0112; Rebecca A. Ullrich, Sandia National Laboratories; printed January 2003; SRDB 

Ref ID: 22926

Various, 1964, Miscellaneous Dosimetry Details; collection of ten correspondence; by various authors 

including R. O. Campbell, N. Holdon, P. K. Lovell, J. McNinn, R. Powell, C. L. Rhodes, and Eugene 

Tochilin; various dates from March through December 1964; SRDB Ref ID: 23689

Wallace, 1988, Current Status of 1985 Headquarters Nuclear Facilities Appraisal (Ref. Audit E431), 

correspondence to W. V. Ormond with attached 1985 HQ appraisal of SNL-L; S. A. Wallace; 

September 9, 1988; SRDB Ref ID: 23585

Ward, 1994, Sandia National Laboratories External Dosimetry Program, Procedure No.PRDP-00-01; 

revised by D. C. Ward; effective date March 3, 1994; SRDB Ref ID: 19237

Wright, 1979, Sandia Livermore’s Bioassay Program from Depleted Uranium, correspondence; Donn 

A. Wright; May 14, 1979; SRDB Ref ID: 24813

Wright, 1981, Tritium Research Laboratory Safety Analysis Report, SAND81-8234; D. A. Wright; 

printed August 1981; SRDB Ref ID: 22994

Wright, 1993, History of Radiation Dosimetry at SNL-Livermore as Remembered by D. A. Wright, 

correspondence to Lydia Perez; Donn Wright; June 1, 1993; SRDB Ref ID: 24811
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Attachment One: Data Capture Synopsis

Table A1-1: Summary of Holdings in the SRDB for SNL-Livermore

Data Capture Information Data Capture Description Completed No. Uploaded 

into SRDB

Primary Site / Company Name: Sandia 

National Laboratories - California (SNL/CA); 

DOE 1956-present 

Contractors:

Lockheed Martin (1995-present); Martin 

Marietta (1993-1995); AT&T (1956-1993) 

Physical Size of the Site: 423 acres

Site Population: Currently 900 staff and 250 

contractors, post-doctoral fellows, and student 

interns. There were 1,077 personnel on site in 

1972.

 

Tritium Research Laboratory Health Physics reports, liquid scintillation 

counter procedures, external dosimetry procedures, ALARA plan, a facial 

hair procedure for respiratory protection, tritium bioassay results, uranium 

bioassay results, dosimetry program evaluations, external dosimetry results, 

machining depleted uranium metal, contamination surveys, neutron 

generator procedures and doses, handling contaminated components, a 

history of site radiation dosimetry, x-ray safety, safe operating procedures, 

procedures for tritium use outside the Tritium Research Laboratory, 

instrument calibrations, records transfer reports, environmental summaries, 

operating procedures for radiation sources, building survey reports, 

interview notes, tritium procedures, and x-ray procedures.

04/29/2013 338

State Contacted: NA NOTE: Contacting the state was not considered necessary since SNL/ CA 

is an active DOE site and cooperated with relevant data collection.

07/22/2013 0

Brookhaven National Laboratory A table showing external exposure totals at sites with accelerators. 11/14/2008 1

Cincinnati Public Library The "Atoms for Peace" report and a discussion of possible combustion 

hazards in the 3013 plutonium waste container from radiolytic gas 

generation.

05/02/2012 2

Colorado State University Site environmental reports, 1998 site aerial radiological survey, 1997 

reclassification of the Tritium Research Laboratory, and a Tiger Team 

assessment.

04/10/2007 13

Department of Labor / Paragon Chemical preparation procedures, periodic evaluation of respirator use 

requirements, site wide air emissions inventory and air emissions permits, 

and safe operating procedures.

02/25/2013 16

DOE Albuquerque Operations Office A 1996 final environmental impact statement for operation of the Pantex 

Plant.

04/14/2010 1

DOE Germantown DOE records search procedures and the 1965 AEC missions policy for 

design laboratories and production plants.

08/08/2012 3

DOE Laboratory Accreditation Program 

(DOELAP)

1988 DOE Laboratory Accreditation Program (DOELAP) applications for 

Albuquerque Operations Office facilities.

06/11/2009 1

DOE Legacy Management - Grand Junction 

Office

A reference to Sandia soil sample results. 09/03/2009 1
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Table A1-1: Summary of Holdings in the SRDB for SNL-Livermore

Data Capture Information Data Capture Description Completed No. Uploaded 

into SRDB

DOE Legacy Management - Morgantown A log book of incoming memos, a 1988 assessment of DOE environmental, 

safety, and health needs, and a log of material transfers.

01/27/2011 3

DOE Legacy Management - MoundView 

(Fernald Holdings, includes Fernald Legal 

Database)

A report on incineration of solid wastes, the DOE effluent information 

system summaries for 1982 and 1984, the 1984 unusual occurrence 

summary, radionuclide air emissions for 1985, the DOE precious metals 

report for 1987, and press releases regarding the temporary suspension of 

waste shipments to commercial burial grounds.

04/23/2008 12

DOE Oak Ridge Operations Office Audit criteria for industrial hygiene programs. 11/18/2011 1

DOE Office of Scientific and Technical 

Information (OSTI)

DOE facilities site maps, a report on nickel coatings on thorium and 

uranium metal, and an annual report of waste generation and pollution 

prevention progress.

02/22/2013 3

Donn Wright Energy spectra for various Sandia National Laboratories, California 

activities and locations.

10/04/2006 1

Federal Records Center (FRC) - Denver The Photodosimetry Evaluation Book Volume IV. 06/15/2010 1

Federal Records Center (FRC) - San Bruno Health Physics quarterly reports, corrective action plan for tritium facilities, 

a report on high dosimeter readings at Lawrence Berkeley National 

Laboratory (LBNL), and participation by Sandia personnel in a LBNL 

safety review.

08/02/2012 6

Hanford A 1943-1970 AEC radiation experience summary, a lab notebook, the 

EPA's background information on radionuclide air emissions, a nuclear 

materials transaction report, and the 1996 distribution of updated site 

profiles. 

01/02/2013 5

Idaho National Laboratory (INL) The report on the fourth topical meeting on tritium technology. SNL/CA 

provided a list of tritium incidents at the site.

04/04/2012 1

Interlibrary Loan A survey of mixed-waste HEPA filters and the proceedings of the 1993 

Incineration Conference.

05/29/2012 2

Internet The 2004 report on residual beryllium contamination at DOE facilities. 06/07/2005 1

Internet - Defense Technical Information 

Center (DTIC)

A 1974 uranium alloy metallurgy report, a 1979 conference on alternative 

energy sources, and the 2010 global fissile material report.

01/09/2012 3

Internet - DOE The 1998 DOE Standard, Guide of Good Practices for Occupational 

Radiological Protection in Plutonium Facilities.

05/11/2007 1

Internet - DOE Comprehensive Epidemiologic 

Data Resource (CEDR)

No relevant documents identified. 07/26/2013 0

Internet - DOE Environmental Management Chapter 3 of "Linking Legacies". 10/28/2007 1

Internet - DOE Hanford Declassified Document 

Retrieval System (DDRS)

No relevant documents identified. 03/30/2012 0
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Table A1-1: Summary of Holdings in the SRDB for SNL-Livermore

Data Capture Information Data Capture Description Completed No. Uploaded 

into SRDB

Internet - DOE Legacy Management 

Considered Sites

A 1993 DOE report on mixed wastes. 04/24/2012 1

Internet - DOE National Nuclear Security 

Administration (NNSA) - Nevada Site Office

No relevant documents identified. 03/30/2012 0

Internet - DOE OpenNet Summaries of Mound purchase orders which include SNL/CA, Appendix B 

of "Linking Legacies", and metabolic studies.

04/24/2012 15

Internet - DOE OSTI Reports on the cleanup of the Tritium Research Laboratory and an annual 

report of radioactive waste shipments to and from Nevada Test Site.

05/10/2006 2

Internet - DOE OSTI Energy Citations 2006 and 2007 shipments to and from the Nevada Test Site, pollution 

prevention and control reports, a Lawrence Berkeley National Laboratory 

institutional plan referencing joint ventures with SNL/CA, and Lawrence 

Livermore National Laboratory tritium release and environmental reports. 

01/26/2013 13

Internet - DOE OSTI Information Bridge DOE low-level waste reports, pollution prevention and control reports, 

1998 shipments to and from Nevada Test Site, U.S. spent fuel and waste 

inventories reports, DOE air emissions reports, a Tritium Research 

Laboratory report, Savannah River Site reports on tritium technology 

research conducted with SNL/CA, and a 2010 former worker medical 

screening annual report.

01/26/2013 43

Internet - Environmental Protection Agency No relevant documents identified. 07/23/2013 0

Internet - Google SNL/CA environmental reports, LLNL environmental reports which 

mention SNL/CA, reports to Congress, workforce restructuring reports, 

DOE occupational exposure reports, the 2007 SNL/CA Administrative 

Record index, radioactive waste and waste transportation reports, and 

LLNL newsletters which mention SNL/CA.

04/04/2013 137

Internet - Health Physics Journal An algorithm for TLD fade and the application of an ICRP clarification to 

the tritium metabolic model.

07/22/2013 2

Internet - Journal of Occupational and 

Environmental Hygiene

No relevant documents identified. 07/22/2013 0

Internet - Lawrence Berkeley National 

Laboratory (LBNL)

LBNL environmental reports which mention SNL/CA. 10/18/2006 4

Internet - Lawrence Livermore National 

Laboratory (LLNL)

LLNL's 1999 monitoring plan which mentions SNL/CA. 02/07/2007 1

Internet - National Academies Press (NAP) No relevant documents identified. 03/30/2012 0

Internet - NIOSH 2006 and 2008 DOE reports on residual radioactive and beryllium 

contamination in the DOE Complex.

08/31/2011 2

Internet - NRC Agencywide Document Access The 1991 and 1992 integrated radioactive waste inventory reports, storage 03/28/2013 11
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Table A1-1: Summary of Holdings in the SRDB for SNL-Livermore

Data Capture Information Data Capture Description Completed No. Uploaded 

into SRDB

and Management (ADAMS) and disposition of weapons-usable materials reports, and design criteria for 

natural hazards reports.

Internet - Sandia National Laboratories -

California (SNL/CA)

Site environmental reports and the 2003 Cold War Context Statement. 03/26/2006 6

Internet - USACE/FUSRAP No relevant documents identified. 03/30/2012 0

Internet - US Transuranium and Uranium 

Registries

No relevant documents identified. 03/30/2012 0

Kansas City Plant External dosimetry reports and 1998 testimony before Congress. 12/04/2012 5

Lawrence Berkeley National Laboratory 

(LBNL)

Livermore employee start and termination dates. 05/23/2007 1

Lawrence Livermore National Laboratory 

(LLNL)

LLNL environmental monitoring reports, tritium release reports, SNL/CA 

employee exposures at LLNL and the Nevada Test Site, and a 1977 LLNL 

and SNL/CA aerial survey.

10/20/2009 49

Los Alamos National Laboratory (LANL) A 1987 environmental report and the DOE characterization report of Health 

Physics at accelerator facilities.

02/28/2012 2

Missouri Department of Natural Resources 1994 plutonium working group reports. 10/01/2008 2

Mound Museum Mound research progress reports and a Mound newsletter. 02/01/2012 9

National Archives and Records Administration 

(NARA) - Atlanta

The DOE indoor radon study and Contolatron/Zetatron contamination 

issues.

08/12/2004 2

National Archives and Records Administration 

(NARA) - College Park

Notes taken by NIOSH researchers during a classified material review at 

the College Park NARA.

07/26/2010 2

National Institute for Occupational Safety and 

Health (NIOSH)

Worker outreach meeting minutes and Sandia records documentation. 08/27/2012 16

Nevada Test Site (NTS) The 2003 Final Environmental Statement for NTS and other Nevada 

locations.

10/01/2003 1

Nuclear Regulatory Commission Public 

Document Room

The 1972 renewal application for License SNM-145. 11/22/2006 1

Nuclear Regulatory Commission Public Legacy 

Library

No relevant documents identified. 10/04/2012 0

Oak Ridge National Laboratory (ORNL) A 1969 Isotopes Development Center newsletter. 01/14/2013 1

ORAU Team A documented communication, a trip report, DOE annual reports of 

employee exposures, and the summary site profile and its classification 

review.

01/05/2012 8

Pantex Surface contamination procedures for component reservoirs and radon 

studies.

10/27/2004 2

S. Cohen & Associates (SC&A) Documented communications, tritium studies and release data, airborne 06/24/2010 64
SEC-00214 09-26-2013 Sandia National Laboratories-Livermore

39 of 43

Table A1-1: Summary of Holdings in the SRDB for SNL-Livermore

Data Capture Information Data Capture Description Completed No. Uploaded 

into SRDB

radioactivity studies and data, a plutonium vulnerability report, DOELAP 

assessments, Operation Grommet radiological safety reports, worker 

monitoring lists, a 1994 incident data sheet, neutron studies, and internal 

dosimetry reports.

SC&A / DOL/Paragon The 1994 Tritium Research Laboratory tritium quantity analysis. 02/18/2009 1

SC&A / INL A DOE environmental survey report on defense production facilities. 06/24/2010 1

SC&A / Pinellas Plant The 1993 annual report on waste generation and minimization. 06/24/2010 1

SC&A / SNL/CA Environmental Safety and Health quarterly reports, radiological safety 

assessments, dosimetry blind audits, urinalysis data, occurrence reports, 

Management Assurance Department reports, environmental dosimetry 

results, and air emissions monitoring and reports.

03/31/2009 49

SAIC Radiation exposure summaries. 09/02/2004 5

Sandia National Laboratories - New Mexico Ross Aviation shipment surveys, a comprehensive list of Sandia 

organizations with titles and dates, incident reports, internal dosimetry 

procedures, bioassay results, characterization of neutron fields, urinalysis 

results, tritium bioassay records, non-routine dosimeter evaluations, 

external dosimetry studies and procedures, and a Tiger Team 

environmental assessment.

01/01/2011 93

Sandia National Laboratories - New Mexico / 

SC&A

A 1986 compliance survey of Radiological Area 4. 09/15/2010 1

Tri Valley Cares Final 1992 environmental impact statement with environmental impact 

report. 

03/14/2005 1

University of Colorado Norlin Library Environmental reports, the final environmental impact statement for 

SNL/CA and LLNL, radiological characterization of the Tritium Research 

Laboratory, and the waste characterization form the cleanup of the Tritium 

Research Laboratory.

06/07/2007 16

University of Colorado Norlin Library / Sandia 

National Laboratories - California

Site environmental report. 04/18/2006 1

Unknown Historical reports, beryllium reports, the EEOICPA facility list, a database 

on thorium facility decommissioning, accident analysis for waste 

management activities, and a significant building project report.

10/12/2005 13

Unknown / SC&A Pantex Plant dosimetry records. 08/19/2003 1

Total 1,002
SEC-00214 09-26-2013 Sandia National Laboratories-Livermore

40 of 43

Table A1-2: Internet Database Searches for SNL-Livermore

Database/Source Keywords Hits Uploaded 

into SRDB

NOTE: Database search terms employed for each of the databases listed below are available in the Excel file called “Sandia CA (83 14)08-19-13.”

Defense Technical Information Center (DTIC)

https://www.dtic.mil/

COMPLETED 04/24/2012

See Note above

1,200 5

DOE CEDR

https://www.orau.gov/cedr

COMPLETED 07/26/2013

See Note above

0 0

DOE Hanford DDRS

http://www2.hanford.gov/declass/

COMPLETED 03/30/2012

See Note above 

0 0

DOE Legacy Management Considered Sites

http://www.lm.doe.gov/considered_Sites/

COMPLETED 03/30/2012

See Note above 

10 2

DOE NNSA - Nevada Site Office

www.nv.doe.gov/main/search.htm

COMPLETED 03/30/2012

See Note above 0 0

DOE OpenNet

http://www.osti.gov/opennet/advancedsearch.jsp

COMPLETED 03/30/2012

See Note above 

49 3

DOE OSTI Energy Citations

http://www.osti.gov/energycitations/

COMPLETED 03/29/2012

See Note above 

2,105 15

DOE OSTI Information Bridge

http://www.osti.gov/bridge/advancedsearch.jsp

COMPLETED 03/28/2012

See Note above 

877 1

EPA, National Service Center for Environmental 

Publication

http://nlquery.epa.gov/epasearch/epasearch?querytext

=%22Sandia+National+Laboratories%2C+Livermore

%22&typeofsearch=epa&sort=term_relevancy&result

s_per_page=10&doctype=all&originalquerytext=%22

sandia+national+laboratories%2C+livermore%22&are

aname=&faq=yes&filterclause=%28inurl%3A%22w

ww2.epa.gov%2Faboutepa%22%29&sessionid=23F9

0F4D1B752AF8277B9184661112AF&referer=http%

See Note above

360 0
SEC-00214 09-26-2013 Sandia National Laboratories-Livermore

41 of 43

Table A1-2: Internet Database Searches for SNL-Livermore

Database/Source Keywords Hits Uploaded 

into SRDB

3A%2F%2Fwww.epa.gov%2Fncepihom%2F&prevty

pe=epa&result_template=epafiles_default.xsl&areasid

ebar=search_sidebar&areapagehead=epafiles_pagehea

d&areapagefoot=epafiles_pagefoot&stylesheet=&po=

COMPLETED 07/23/2013

Google

http://www.google.com

COMPLETED 04/22/2012

See Note above

112,870 62

HP Journal

http://journals.lww.com/healthphysics/pages/default.aspx

COMPLETED 07/22/2013

See Note above

136 3

Journal of Occupational and Environmental Health 

http://www.ijoeh.com/index.php/ijoeh

COMPLETED 07/22/2013

See Note above

0 0

National Academies Press

http://www.nap.edu/

COMPLETED 03/30/2012

See Note above

1,755 0

NRC ADAMS Public Legacy Library

http://adams.nrc.gov/wba/

COMPLETED 10/04/2012

See Note above

0 0

NRC ADAMS Reading Room

http://www.nrc.gov/reading-rm/adams/webbased.html

COMPLETED 10/17/2011

See Note above

3,495 11

USACE/FUSRAP

http://www.lrb.usace.army.mil/fusrap/

COMPLETED 03/30/2012

See Note above

0 0

U.S. Transuranium & Uranium Registries 

http://www.ustur.wsu.edu/

COMPLETED 03/30/2012

See Note above

0 0
SEC-00214 09-26-2013 Sandia National Laboratories-Livermore

42 of 43

Table A1-3: Interlibrary Loan Documents Requested for SNL-Livermore

Document 

Number Document Title Requested Date

Received 

Date

CONF-950601

REF ID: 114575

The 99Mo Production Program at Sandia National Labs, June 1995, Transactions of the American 

Nuclear Society, Annual Meeting of the American Nuclear Society, Vol. 72:141-142

05/01/2012 05/02/2012

NA

REF ID: 114585

Possible Combustion Hazards in 3013 Plutonium Waste Container, 11/14/1999-11/18/1999, 

Transactions of the American Nuclear Society, Vol. 81:87-88, American Nuclear Society 1999 

Winter Meeting

05/01/2012 05/02/2012

CONF-971125

REF ID:114597

Production of Fission and Activation Product Isotopes at Sandia National Laboratories, November 

16-20, 1997, Transactions of the American Nuclear Society, Vol. 77:521-522, 1997 American 

Nuclear Society Winter Meeting

05/01/2012 05/02/2012

CONF-971125

REF ID: 114598

Waste Processing to Support 99Mo Production at Sandia National Laboratories, November 16-20, 

1997, Transactions of the American Nuclear Society, Vol. 77:556-557, 1997 American Nuclear 

Society Winter Meeting

05/01/2012 05/02/2012

CONF-860610

REF ID: 114577

Improved Shielding Calculations for the Particle Beam Fusion Accelerator II, Transactions of the 

American Nuclear Society, June 15, 1986, Vol. 52:143-144

05/01/2012 05/02/2012

NA

REF ID: 114582

Photoneutron Production Using Bremsstrahlung from the 14-TW HERMES III Electron Accelerator, 

July 1993, Nuclear Science and Engineering, Vol. 114(3):190-213

05/01/2012 05/02/2012

CONF-890723

REF ID: 114580

Neutron Effects in High-Power GaAs Laser Diodes, July 25-29, 1989, IEEE Transactions on Nuclear 

Science (Institute of Electrical and Electronics Engineers), Vol. 36(6):2076-2082, Annual Conference 

on Nuclear and Space Radiation Effects

05/01/2012 05/02/2012

NA

REF ID: 114599

A Survey of Mixed-Waste HEPA Filters in the DOE Complex, Feb 28, 2002, Waste Management 

2002 Symposium, 14 pages

05/01/2012 05/03/2012

NA

REF ID: 115622

133Cs NMR Study of Cesium on the Surfaces of Kaolinite and Illite, November 1996, Geochimica et 

Cosmochimica Acta, Vol. 60(21):4059-4074

05/01/2012 05/09/2012

NA

REF ID: 115625

Using the Tritium Plasma Experiment to Evaluate ITER PFC Safety, June 1993, Journal of Fusion 

Energy, Vol. 12(1-2):115-119

05/01/2012 05/09/2012

CONF-910920

REF ID: 115624

Simple System for Measuring Tritium Ad/absorption Using a 2. pi. Counter and Thermal Desorption 

Spectrometer, September 29-October 4, 1991, Fusion Technology, Vol. 21(2):812-817

05/01/2012 05/15/2012

NA

REF ID: 115623

Low Level Radioactive Waste Transportation Safety History, September 1997, Radwaste Magazine, 

Vol. 4(5):22-25

05/01/2012 05/25/2012

NA

REF ID: 115535

Thermal Treatment of Radioactive, Hazardous Chemical, Mixed, Energetic, Chemical Weapon, and 

Medical Wastes : 1993 Incineration Conference : Proceedings of the 1993 Incineration Conference, 

Knoxville, Tennessee, U.S.A., May 3-7, 1993 

05/16/2012 05/29/2012
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Table A1-4: OSTI Documents Requested for SNL-Livermore

Document 

Number Document Title Requested Date Received Date

SAND2005-0430C Metal hydride center of excellence & Sandia recent accomplishments 07/23/2010 NA - OSTI doesn't 

have document

SAND2005-2377C Overview of DOE metal hydride center of excellence (MHCoE) 07/23/2010 NA - OSTI doesn't 

have document