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 UNITED STATES OF AMERICA 

 DEPARTMENT OF HEALTH AND HUMAN SERVICES 

 CENTERS FOR DISEASE CONTROL AND PREVENTION 

 + + + + + 

 NATIONAL INSTITUTE FOR OCCUPATIONAL 

 SAFETY AND HEALTH 

 ADVISORY BOARD ON RADIATION AND 

 WORKER HEALTH 

 + + + + + 

 WORK GROUP ON MOUND 

 + + + + + 

 MEETING 

 + + + + + 

 THURSDAY, MAY 28, 2009 

 + + + + + 

 The Work Group convened at 9:30 

a.m., in the Zurich Room of the Cincinnati 

Airport Marriott Hotel, Josie M. Beach, Work 

Group Chair, presiding. 

MEMBERS PRESENT: 

 JOSIE BEACH, Chair 

 BRAD CLAWSON 

 PHILLIP SCHOFIELD 

 PAUL L. ZIEMER* 
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MEMBERS ABSENT: 

 ROBERT PRESLEY 

ALSO PRESENT: 

 THEODORE M. KATZ, Acting Designated 

 Federal Official 

 BOB BISTLINE, SC&A 

 ELIZABETH BRACKETT*, ORAU Team 

 RON BUCHANAN, SC&A 

 MELTON CHEW, ORAU Team 

 LARRY ELLIOTT, NIOSH 

 LEO FAUST*, ORAU Team 

 JOE FITZGERALD, SC&A 

 EMILY HOWELL, HHS 

 KARIN JESSEN, ORAU Team 

 TOM LaBONE*, ORAU Team 

 JOYCE LIPSZTEIN*, SC&A 

 ROBERT MORRIS, ORAU Team 

 JAMES NETON*, NIOSH 

 GENE POTTER, ORAU Team 

 BRYCE RICH*, ORAU Team 

 KATHY ROBERTSON-DeMERS, SC&A 

 MUTTY SHARFI, ORAU Team 

 DON STEWART, ORAU Team 

 BRANT ULSH, NIOSH 

*Present via teleconference. 
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 TABLE OF CONTENTS 

 

Page 

Welcome..................................... 8 

NIOSH - Neutron dose reconstruction......... 8 

issue 14&15 

NIOSH - High-Fired PU-238 issue 9......... 130 

SC&A - Radon issue 2...................... 162 

NIOSH - exposure to non rad buildings..... 194 

issue 17 

NIOSH - "Road Map" Integrated issues...... 259 

1,3,4,7 & 8 

NIOSH - D&D years......................... 236 

WG - Assigned Action Items, future........ 264 

meeting plans 
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 P-R-O-C-E-E-D-I-N-G-S 

 9:33 a.m. 

 MR. KATZ: Good morning, everyone 

in the room and on the line. This is Ted 

Katz. I am the acting designated federal 

official for the Advisory Board of Radiation 

Worker Health. And this is the second of the 

two-day meeting of the Mound Working Group. 

And we are ready to begin. 

 And we will begin with roll call, 

starting with Board members in the room. 

Please, everyone who responds to the roll call 

except people in the public, of course, speak 

to your conflict of interest as well status. 

Thanks. 

 Beginning in the room? 

 CHAIR BEACH: Josie Beach, Working 

Group Chair. No conflicts. 

 MEMBER CLAWSON: Brad Clawson, 

Working Group Member. No conflict. 

 MEMBER SCHOFIELD: Phillip 

Schofield, Working Group Member. No conflict. 
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 MR. KATZ: And on the line? Do we 

have any Board members on the line? 

 MEMBER ZIEMER: Paul Ziemer. No 

conflicts. 

 MR. KATZ: Welcome, Paul. 

 Okay. And then in the room, the 

NIOSH ORAU team? 

 MR. ELLIOTT: Larry Elliott, 

Director of the Office of Compensation 

Analysis and Support. No conflict. 

 MS. JESSEN: Karin Jessen, ORAU 

team. No conflicts. 

 MR. CHEW: Mel Chew, ORAU team. No 

conflict. 

 MR. MORRIS: Robert Morris, ORAU 

team. No conflict. 

 MR. STEWART: Don Stewart, ORAU 

team. No conflict. 

 MR. SHARFI: Mutty Sharfi, ORAU 

team, conflicted. 

 DR. ULSH: Brant Ulsh from NIOSH. 

No conflict. 
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 MR. KATZ: On the line, NIOSH/ORAU 

team? 

 DR. NETON: This is Jim Neton, 

NIOSH. No conflicts. 

 MS. BRACKETT: Elizabeth Brackett, 

ORAU team. I do have a conflict. 

 MR. KATZ: This is Bryce Rich, ORAU 

team. I'm conflicted. 

 MR. FAUST: Leo Faust, ORAU team. 

No conflicts. 

 MR. KATZ: Any more NIOSH or ORAU 

team on the line? 

 MR. LaBONE: Yes, yes. This is Tom 

LaBone. I am conflicted. 

 MR. KATZ: Okay. And then so that 

takes care -- now, HHS or other federal 

officials or contract staff in the room? 

 MS. HOWELL: Emily Howell, HHS. No 

conflicts. 

 MR. KATZ: And on the line? Any 

federal officials or contract staff? 

 (No response.) 
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 MR. KATZ: Okay. And then members 

of the public? Oh, no. SC&A in the room? 

 MR. FITZGERALD: Yes. Joe 

Fitzgerald, SC&A. No conflict. 

 MR. BUCHANAN: Ron Buchanan, SC&A. 

 No conflict. 

 DR. BISTLINE: Bob Bistline, SC&A. 

 No conflict. 

 MS. ROBERTSON-DeMERS: Kathy 

Robertson-DeMers, SC&A. Conflicted. 

 MR. KATZ: And SC&A on the line? 

Any members of SC&A on the line? 

 (No response.) 

 MR. KATZ: Okay. And then any 

members of the public who want to identify 

themselves on the line or staff of 

congressional offices? 

 (No response.) 

 MR. KATZ: Okay. Then just let me 

remind everyone on the line to please keep 

your phones on mute except when you're 

speaking to the group here. And if you don't 
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have a mute button, *6 will work. And to take 

yourself off mute, just hit *6 again. 

 Thank you. Josie? 

 CHAIR BEACH: Okay. Good morning. 

 And welcome to Mound's fourth Working Group 

meeting, second day. We are going to start 

with neutron dose reconstruction issues number 

14 and 15. And NIOSH is going to kick this 

off this morning. And I'll turn it to Brant. 

 DR. ULSH: Okay. Thanks. 

 Just to let you know what is 

coming, I have asked Bob Morris to give a 

PowerPoint presentation. He first gave this 

presentation at a worker outreach meeting that 

we held in the first week of April. 

 Basically kind of the history of 

the neutron issue, it probably goes back even 

earlier than I am about to say, but some of 

the former workers that we have been 

consulting and dealing with discussing the 

Mound issues with right from the early days of 

the SEC petition brought up the way that 
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neutron doses were handled in the Mound TBD 

and brought up some issues that they thought 

we might want to consider on that. So we have 

been looking at it at least since then. 

 And, finally, we decided to -- I 

asked Bob and his team to take a look at the 

neutron, the way we did it in the TBD and to 

come up with some improvements. We discussed 

a lot of issues in the context of this SEC 

Working Group as well. 

 We have come up with a revised 

approach. It is going to be kind of a hybrid 

approach depending on the data that we have 

available for different time periods. Bob 

presented this. He gave his PowerPoint 

presentation at the meeting that we had with 

the workers in the first week of April. 

 The purpose of that meeting was 

basically to lay out our new approach and to 

solicit any comments or thoughts or insights 

from these about 20 or so workers. 

 These workers were chosen not 
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really by need but by some of the former 

workers who have expertise in neutron 

dosimetry. 

 They included health physicists in 

charge of the SM building and PP building, T 

building, also just a variety of workers, 

including even the two ladies who actually sat 

down and read the NTA films. So we really 

tried to get a broad cross-section. 

 So we gave that presentation. It 

was very well-received. They made a few 

comments and suggestions that we might want to 

consider. And I know Bob was in the process 

of considering them. 

 The next development that occurred 

on the neutron issue, we issued a white paper. 

 SC&A has looked at that, and we had a 

conference call with SC&A on April 28th. Ron 

Buchanan offered a few comments that we 

thought were very productive. So we are in 

the process of taking a look at those as well. 

 So this will just give you kind of 
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a snapshot of where we are with this issue. 

And, with that, I will turn it over to Bob. 

 MR. MORRIS: Thank you. I 

appreciate your moving the schedule to 

accommodate my -- 

 CHAIR BEACH: No problem. 

 MR. MORRIS: -- sixth grader's 

commencement into seventh grade. So it is 

important. 

 So I want to introduce the 

colleagues who helped me with this. I think 

both are on the telephone line. At least I 

think Leo is. Leo Faust is a key person in 

doing the research on this topic and Billy 

Smith. Billy, have you joined us yet? 

 (No response.) 

 MR. MORRIS: Billy Smith is a 

coauthor on this also. 

 DR. ULSH: If I could interrupt you 

for just a second? We're going to turn down 

the lights. 

 MR. MORRIS: And, just for 
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background, Billy ran the NTS dosimetry 

program for many years, external *9:41:52 

program, actually kicked off the use of their 

first TLD system at NTS. So he's got a broad 

background in that. And Leo has got a long 

resume in dosimetry. 

 Next slide, please. I wanted to 

give a little bit of background. As Brant 

mentioned, we have presented this similar 

presentation to a group of Mound workers in 

April. That was actually very well-received. 

 And they appreciated the presentation. 

 You didn't mention that there 

actually were technicians who had made some of 

the measurements beyond reading the NTA forms 

but also actually carried the meters into the 

field to make some of the measurements that we 

used to consider the neutron/photon ratio 

data. 

 Also, there was a gentleman there 

who had made many of the original neutron 

spectra measurements that are available for us 
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in published literature. And so he actually 

was a pioneer in the development of neutron 

spectra measurements and was there and 

provided some very constructive criticism to 

us in our presentation. 

 We have had the benefit of SC&A 

having reviewed our white paper at this point 

and got very constructive comments. We are in 

the process of updating those and 

incorporating them. 

 The issues fundamentally are 

limited to the era prior to use of TLD 

dosimetry technology. And so that is what 

most of this focused on. That is not to say 

that we don't have a method for the TLD. You 

know, it's the same as defined in our 

technical basis document. 

 The doses are designed as we have 

reconstructed them here, to be 

claimant-favorable and accurate enough to make 

an appropriate compensation decision. But we 

don't want to represent that these are 
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perfectly accurate numbers. When there are 

uncertainties, we have moved the choice of 

correction factors to the high side. 

 Neutron dose estimation is 

necessary for our compensation decision. Not 

all workers were monitored for neutron dose, 

especially in the earliest years of the 

operations. And so dose must be inferred from 

other information. 

 This goes to a problem that we have 

seen on many other sites, use of NTA film. 

NTA stands for neutron type-A film, generally 

from Kodak in the early days. But it's 

generally that acronym has superseded the 

definition. NTA is how we would think of this 

kind of technology. 

 It was a highly resolved grain 

film. And in order to read it as a neutron 

event, there would have to be a sequence of 

grains that actually developed in the 

development process. We see them as a track 

at least three grains long. In some cases 
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more grains would be in a row. 

 And those would be easier to spot 

as a track. That is what the people who look 

through the microscopes are there, to read 

neutron tracks, were doing this. They were 

taking a tiny field on a film and then blowing 

it up into a visible size and counting with a 

scoring device, like an umpire might use, the 

number of tracks that were in that area. 

 And so it to some extent was 

subjective in that you just had to say, "Oh, I 

recognize these three grains or more in a row 

that is being tracked." And once it is 

recognized, then you can actually tally it. 

 As you can imagine, people get 

better with that technology as they continue 

to do it. And so that is why you see very 

little turnover in these groups of people that 

tend to read the films. And they would be the 

same people that read the calibration films 

would also be reading the actual exposure 

films that would monitor the workers. 
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 One of the frailties of the NTA 

system is that it takes a certain amount of 

energy to create three grains developed on the 

form in a row. And that is effectively the 

threshold of detection of the neutron detector 

for this system. 

 So it's widely accepted that at 

about half a MeV, a neutron with an energy 

carrying more than .5 MeV, mega-electron 

volts, is capable of creating that three-track 

in a row pattern. Some people say it's a 

little lower. Some people say it's a little 

higher. But for a rule of thumb, we assume -- 

and this is part of our OCAS literature that's 

been approved. 

 We assume that the film is 

responsive to the neutrons that carry more 

than half an MeV of energy. And, for 

practical purposes, although there is an 

exception here of a pure thermal neutron 

field, for practical purposes, we assume that 

the dosimeter, the NTA dosimeter, is not 
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responsive to neutrons that occur less than a 

half an MeV. 

 So we have got this problem of if 

the exposure was predominantly on the lower 

energy side of the neutron spectrum, then 

there is a larger correction that has to be 

made for the lack of registry that was made. 

 Another problem with NTA film is 

that it is not as sensitive as our modern 

techniques that we have become accustomed to 

with CR-39 and the TLD methods. 

 So there was some potential for 

misdose on every readout cycle, then. This 

wouldn't have been registered as a different 

than background fogging on the film. So those 

are the kinds of things that we have got to 

deal with in dealing with NTA as a dosimetry 

device. 

 Unmonitored workers or workers with 

a zero in the readout cycle present 

interpretations, problems for how to interpret 

the data or lack of data and then infer it 
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into a dose calculation. Unmonitored workers 

are assigned a dose similar to the monitored 

workers in the same period. That's the very 

familiar coworker model that you guys have 

seen. 

 Now, the question is, where do we 

get the data for the coworker model? And how 

do we put it into a distribution? And what 

are the values that we choose for that? That 

is the kind of detail that gets resolved with 

SC&A's help. 

 The other kind of problem we get 

when we are interesting this is the people who 

actually wore a dosimeter, wore an NTA film 

dosimeter. But then their dose is recorded as 

zero by the person who read the film. 

 In fact, as I mentioned, there is a 

sensitivity cutoff on this. So the dose may 

not really be zero but some fraction of the 

detection limit. In fact, it's possible the 

dose really is zero, but we can't prove that 

one way or another. 
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 So, the very familiar methods that 

have been developed at other sites and with a 

lot of precedent to correct the misdose 

problem get applied. 

 So when we address this misdose 

concept, it is generally a sign that is 

one-half of the reporting limit. So if, for 

example, if the reporting limit for a two-week 

NTA readout cycle is 50-millirem, then each 

monitored worker had a zero recorded on their 

dosimeter would be a sign of half of that 

reporting limit. And for that two-week cycle 

then would be given in our dose reconstruction 

method 25-millirem, when the record, the dose 

of record, was actually zero. 

 So there are ways to infer neutron 

dose to help monitor the workers. We can use, 

as I said before, coworker model or we can 

choose to use a concept of the neutron to 

photon dose ratio. 

 We have seen the neutron/photon 

ratio used in other places. I think it's in 
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conversation right now at Hanford and other 

sites. 

 So the concept here is that the 

workers wore photon dosimeters, a film badge 

that was capable of measuring X-rays or gamma 

rays. 

 And when we take that number, if we 

can find a consistent ratio between neutron 

exposure and gamma ray or photon exposure in 

the facility, then we can take that number and 

multiply it by the ratio and get some kind of 

proportionality so that if you had -- let's 

say we would hope to find a ratio of perhaps 

two millirem of neutron for every one millirem 

of photon dose you would get and then we knew 

that the worker wore a photon dosimeter that 

measured 100, we would then assign 200 

millirem for neutrons that would be added in 

as external dose. So we approached that 

problem. 

 There are two sources of data that 

could be useful for establishing that neutron 
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to photon ratio. We could potentially get it 

from paired instrument measurements, where a 

monitor would have taken a radiation detector 

capable of measuring neutrons into the field, 

making a dose rate measurement and then at the 

same location and coincidentally in time 

making a gamma ray measurement. So we looked 

at a lot of data that would have potentially 

given us that information. 

 The other approach to getting 

neutron to photon ratios is to take actual 

data sets from fully monitored workers, those 

people who wore neutron NTA film and wore 

their gamma ray badge, gamma ray dosimeter, 

and see if we can come up with a ratio between 

those two things. 

 So, again, this harkens back to the 

outreach meeting we had, where we actually go 

into some explanation of what the coworker 

model is. And at risk of boring you, I will 

go through that quickly because you folks all 

know that, I think. 
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 The dose data from all monitored 

workers is corrected for misdose in the 

coworker model. And then the other factors, 

the correction factors, are applied. And then 

the data are grouped by time. 

 So it depends on how much data 

you've got. It could be annualized or you 

might choose a two-year time cycle or a 

quarterly time cycle. Really, it depends on 

how strong the data set is. 

 The data are fit to a log-normal 

distribution. There is an assumption that 

there is a log-normal distribution underlying 

all this. Fiftieth and 95th percentiles of 

the distribution are determined. 

 And then a value can be assigned to 

the unmonitored worker from that coworker 

model. Most workers are getting the 50th 

percentile value while some workers with high 

exposure potential are assigned to the 95th 

percentile. 

 Now, in all cases since OTIB-0052, 
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the construction worker dose considerations 

technical information bulletin was published a 

couple of years ago. We now have a 1.4 

multiplier on external dose for unmonitored 

construction workers when a coworker model is 

applied. 

 So we take 140 percent of whatever 

those values, the 50th or 95th percentile, 

would be if your job description defines you 

as a construction trade worker; for example, 

pipe-fitters. A lot of maintenance people 

fall into this category. It's not just new 

construction-type work or retrofit 

construction. So it's a pretty broad brush 

that we define construction workers with. 

 So the point about this in this 

bullet is the construction workers get a 40 

percent premium of dose assigned to them under 

this assumption. 

 Now, why would we assume a 

log-normal distribution in the coworker model? 

 In some levels, it becomes an article of 
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faith. The data fit something. And over and 

over again, we have found that log-normal 

distribution tends to be a very good one. 

It's got a few characteristics that make it 

appropriate. 

 We know that many environmental 

exposures are well-described by it. The model 

is constrained so that the number can never go 

below zero. And it allows for a relatively 

large portion of the values to be biased to 

the low side, at the same time accommodating a 

small fraction of outliers as a normal 

expectation. So a number of higher exposures 

do occur. It turns out that this has been a 

pretty successful assumption set that we just 

begin with. 

 Now I want to look at the paired 

instrument data that we had access to. As I 

mentioned earlier, a neutron rem-meter and a 

gamma ion chamber, dose rate measurements were 

taken at the same location. 

 This was a practice that continued 
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over and over at Mound for many years. And 

the monitor would take these instruments to 

specific places, make the pair of instruments, 

and write down the record. 

 We found approximately 46,000 pairs 

of instrument data from the R, T, SM, and PP 

facilities. A sample, which I have to admit 

is a really remarkably large sample, of that 

46,000 was actually entered into a 

spreadsheet, X/Y pairs. 

 And we then sorted that data, 

hoping to find some statistical significance 

in the numbers and more or less arbitrarily 

but based on our occupational experience in 

controlling and measuring radiation fields, 

especially neutron fields. 

 We set an arbitrary threshold to 

look at data that was only in excess of two 

and a half millirem per hour for both kinds of 

measurements. 

 The reasoning behind that is that 

when you look at the number of counts per 
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minute per millirem per hour that have to be 

registered in a neutron meter in order to get 

a millirem of dose, you find that statistical 

significance is pretty high for the numbers 

below a couple or three millirem per hour. 

 And so we chose to censor our data 

set that way in order to hopefully not get 

bogged down with the statistical fluctuations 

of the lower doses. That resulted with 5,162 

paired measurements that were in excess of two 

and a half millirem per hour. 

 And this is kind of what our data 

set looked like. If you look, notice that it 

is a logarithmic scale on both the x and the 

y-axis. And notice that it is essentially a 

shotgun pattern that goes from high to low, no 

obvious -- I actually told the joke at one 

point that, of course, we fed a straight line 

through this data set and it matches 

perfectly, which, of course, isn't true. 

 It's hard to find a strong 

correlation in any degree at all. We actually 
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did the statistical correlation tests on these 

data. And they approach zero correlation. 

 So that hope that we had had of 

finding this ratio of neutron to photon dose 

rates that could then be applied to the 

measured photon numbers seems to have fallen 

on fallow ground here. 

 We don't see a real pattern. It 

may be possible that we could look at this 

again, try to separate it out more by year, 

and potentially separate it out more by 

facility, but the big picture is we just 

didn't find anything that gave us a clue that 

there was going to be a strong correlation, 

strong enough that we could make an argument 

on top of it. 

 Now I want to talk about our NTA 

film. We had a good set of data, very 

well-documented program on NTA film. There 

was a lot of history about what was done, when 

it was done, when changes occurred, how 

calibrations were made. And this comes from 
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history of the external dosimetry program. 

 So it turns out that in my 

estimation, that people who were in charge of 

that program or the dosimetry program at Mound 

were chronic note keepers, and they just wrote 

a lot of information about what they did. 

 So we were able to find a lot of 

original source material that was 

contemporaneous and provided you a reason to 

believe that this is how they ran their 

program. 

 As I mentioned before, we needed to 

correct for neutron energy response less than 

.5 mega- electron volt energies. We needed to 

consider the calibration source that was used 

in the test irradiations of the time. The 

calibration source changed over time. 

 We also needed to consider the 

geometric factors. The calibration of the NTA 

film was done in a perpendicular plane to the 

beam coming out of the neutron source. 
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 But unless you are exclusively a 

glove box worker, which, you know, a lot of 

people are glove box workers, but, then, there 

are other people who are not. 

 You are actually more oftentimes in 

a rotational geometry, not just that 

interior/posterior geometry. So we considered 

to some extent correction factors for rotating 

geometry in the workplace. 

 And then another factor I didn't 

mention in my preliminary conversation was 

this idea of track fading. As I said before, 

it takes three grades in a row to score a 

track. 

 But after those are developed, they 

actually have a tendency to fade with time. 

And so depending on when you read the film 

after it is developed, you might get a 

different answer depending on whether you read 

promptly or if you read more later. 

 So there is this well-established 

problem called track fading. And track fading 
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was considered contemporaneously. And we 

needed to make sure that the appropriate 

factors were applied for track fading. 

 We started with a lot of 

information. Neutron spectra are available 

from a lot of sources. The graph you see here 

on the screen was actually published in 

peer-reviewed literature. The measurement was 

made by a Mound scientist at Mound. And the 

date on this is 1967. This is pretty early 

for making these kinds of measurements. 

 Now, you can find exactly the same 

spectra in modern published literature. You 

can actually run a program that will from 

first principles calculate what this kind of 

spectrum would look like. 

 If you say, "I've got a plutonium 

oxide source" or "I've got a plutonium 

beryllium source," there are programs 

available that will effectively calculate this 

and print it out. 

 What we find is that there is a 
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very self-consistent and pre-extensive number 

of neutron spectra measured at Mound in the 

facility. If you notice, the low-energy 

component is not registered below a half MeV 

on that graph. And that's because in 1967, 

the way you measured neutron spectra only had 

one data point down at the thermal range. It 

was missing some data points between the 

lowest energy and the half MeV numbers. 

 So that's what the more modern 

publications of neutron spectra can give to 

us, is that missing information in that 

low-energy data. Nevertheless, we had neutron 

spectra to start with from many different 

sources. And they all seem to be 

self-consistent. 

 One of the problems, then, about 

getting to the point of how much of the 

information would be missed by the threshold 

effect of energy is figuring out how much 

dose-equivalent is delivered by neutron in 

specific energy. 
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years ago, more than 25 years ago, published 

this graph, which is a neutron flux to 

dose-equivalent rate conversion factor. This 

is data for neutrons. 

 The interesting thing about this 

graph you'll see is that the numbers don't 

really matter that much except the shape of 

the curve matters. You will see that below 

one MeV the amount of dose that any individual 

neutron delivers falls off precipitously, and 

above one MeV, it's more or less a straight 

horizontal line. 

 So high-energy neutrons carry in 

that context energies above one MeV, carry 

more or less the same dose per neutron while 

lower-energy neutrons, the ones that the NTA 

film doesn't see very well, really don't carry 

much individual dose per interaction. So 

that's in the favor of the dosimeter there. 

 So even if you are missing some 

dose, it's missing registering some of the 
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neutrons that hit the film. The dose per 

neutron that hits the film is relatively low. 

 Okay. Go ahead, please. And so 

this is one slide that summarizes a lot of 

work, essentially. It just gives you a 

snapshot of what we did. 

 We used the computer program called 

MCNP. It's a program that is widely used in 

nuclear science fields. And it is currently 

supported at Los Alamos. 

 I understand the last time I heard 

there were more than 500 Ph.D. years invested 

in the development of MCNP. It's highly 

reliable now if you model the geometry 

correctly and apply and use the right data 

libraries. 

 So what we did is we started with 

that neutron spectrum that I described to you 

earlier. And we put that in as the input 

energies for the neutrons. The Monte Carlo 

code, then, MCNP, that's what's called a 

random walk. And it lets a neutron start at 
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this location, move through space, and 

randomly interact with some molecule or some 

atom that's in its path. 

 It randomly then scatters according 

to the cross-sections. And say the 

probability of a neutron getting this way and 

then scattering this way is X. It does this 

for thousands and thousands and thousands of 

interactions until the uncertainty of the 

number of neutrons crossing a plane in space 

as you set the problem up becomes very small. 

 I think we stop this problem at about one 

percent uncertainty. 

 So effectively what you see now is 

I have expanded this scale down, this 

logarithmic scale, on the x-axis. And we 

applied the NCRP weighting factor. And you 

can see that almost none of the dose below 

100, or .1 MeV, is available. It's all up 

under -- the area under the curve is, 

proportional to the dose from the spectrum. 

 So if you integrate the area under 
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the curve from 0 to 500 KeV or .5 MeV and you 

integrate the area under the curve from .5 MeV 

to the top of the curve, you get effectively a 

ratio of measurable dose to unmeasurable dose 

by the NTA film. 

 We did this for several different 

scenarios with several different materials to 

start with, plutonium oxide -- I have to go 

back to my chart here to figure it out. 

 Yes. You can go to the next one. 

And we did it for plutonium fluoride, 

plutonium oxide, and polonium beryllium. We 

did it with various thicknesses of water 

shielding surrounding the source. 

 And we find that the thicker the 

water shield, the slower the neutrons are, the 

lower-energy they are. And so the more 

misdose you have. 

 Now, it is interesting to see how 

this graph works is that for unshielded 

neutron sources, we potentially miss 15 to 25 

percent of the dose with the NTA film. 
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 So you could say if you knew you 

had an unshielded source and you were missing 

25 percent of the dose, you could take the 

measured dose and divide it by that value and 

actually come to a reasonable correction 

factor. 

 The challenge then becomes picking 

the scenario to model with. And it is some 

place between zero and where we think of being 

16 centimeters, which is 15 centimeters is 6 

inches of water. 

 So at some point in here it is a 

reasonable scenario for how much dose was not 

detectable using the NTA film, what fraction 

of the dosimetry results should be corrected. 

 We also looked at the Benelex 

shielding and found that it had no effective 

difference compared to water, as you would 

expect. And the point of all of this is now 

one can select a value and from that develop a 

correction factor, making the NTA film useful 

as a measurement device that can be 
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effectively used to make dose reconstruction 

measurements. 

 So the NTA data needs to be 

corrected and the misdoses then applied. Now, 

there is this database called MESH, which is 

where all of the external dosimetry data was 

rolled up into. And, unfortunately, we had a 

problem with using it because it was rolled up 

on an annualized basis. 

 We don't have the raw data back on 

the two-week cycle with readouts. So we end 

up with lots of misdose driving this problem. 

 If you assign to people who 

actually got zero dose every two weeks, if you 

assign them 25 millirem, you are going to see 

that once you do that 26 times a year, all of 

a sudden, that has turned into a pretty big 

number. 

 So our MESH, our neutron data as 

it's reported in MESH, tends to bound the 

problem that certainly appears to overestimate 

the actuals that we can see by any other 
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indication. 

 So we'll go through the next one. 

We took the NTA data that was reported in 

MESH. And we applied a set of correction 

factors. This is just a few years out of a 

long table that is in our report. And some of 

these factors are changing based on some of 

the comments that SC&A has provided to us. 

 The bottom line is that we think 

that we are able to take the data in MESH, 

apply correction factors to it, and come up 

with a bounding value for the data as it is 

tabulated in MESH. 

 In some cases we found reports in 

this journal of the dosimetry work over the 

years that said, "We recommend that 

dosimeters, the data of record from NTA film 

between 1970 and 1977 be multiplied by a 

factor of 2 retrospectively to create the dose 

of record." So that is not showing there, but 

in the years 1970 to '77, that value would 

have been a factor of 2. 
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arbitrarily applied correction factors could 

be removed. And then we could go in and 

individually apply the correction factors that 

account for energy threshold, for calibration 

mismatch, for track fading, for angular 

response. And so we could systematically look 

at each one of these corrections. 

 The bottom line as you look at many 

of these is that when you tally up all the 

correction factors and apply them, it turns 

out that the correction factor in general sums 

up to be about 1.8 or 2 or a little bit more 

than 2 in some cases. 

 But the reality is that we think we 

could take the MESH data and multiply it by 

the type of correction factor and come up with 

a reasonable number that way. 

 We did try to look at this data 

set, then, after we applied the correction 

factors and found that they varied widely by 

year. So this is taking the people that had 
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neutron data of record and photon data of 

record and getting the ratio of this too on an 

annualized basis. 

 And you'll see that those ratios 

range from close to zero up to 25. And that 

they tend to be in the few, the three to seven 

range of neutron to photon ratios, based on 

the MESH data. 

 But, as I said earlier, the MESH 

data is probably driven by misdose in most 

cases. Since we don't have the cycle-by-cycle 

readout, it is hard for us to understand that 

exactly. All we can do is say it is obviously 

boundable by this kind of approach. 

 Let's go to the next one. And I'll 

show you how it changed by year. We actually 

looked at these neutron-photon ratios from 

MESH by year. 

 And these probably represent some 

changes in processes, changes in materials, 

changes in facilities that were going on. The 

big picture is that there are ratios that can 
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be developed by these methods. 

 So our opinion at this point is 

that using these ratios from the MESH data, 

although they can be bounding, they tend to be 

overestimating to the point that we are not 

very comfortable with that. 

 And so we have looked for another 

approach for years where there was other data 

available. So it turns out that in the 

earlier days of the program at Mound, there 

were NTA data reported in the monthly or 

quarterly health physics progress reports. 

These were written routinely and with the same 

format month after month. Same topics were 

covered. And some changes are obviously 

trackable. 

 If you look in there near the 

bottom of that screen, you will see that the 

neutron, number of neutron films processed in 

this example period, -- this was a quarterly 

period -- the films were worn over a two-week 

period. And in the quarter, they processed 
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818 NTA films. Seven hundred ninety-eight of 

those read less than 100 millirem. 

 Now, this is contemporaneous. The 

correction factors that we have discussed were 

not applied. But, nevertheless, the people 

who were counting the grades in a row came to 

the conclusion that only 20 out of the 818 

films that they saw had doses recorded on them 

in excess of 100 millirem. 

 So what that really does tell us is 

that most of the doses were substantially low, 

even after correction factors were made. It's 

possible to take this data and actually 

force-fed into a log-normal distribution. 

 And, you know, granted, we don't 

have the kind of number resolution that you 

would get from real number data. In this case 

we've got what you might describe more as 

categorical data as bin data, this low bin, 

this middle bin, and this high bin. 

 But, nevertheless, that is still a 

lot of information. Seven hundred 
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ninety-eight out of 818 were below this 

threshold of dose. 

 And so when you take that kind of 

information, it's possible to fit it with a 

significant uncertainty. When you do that, 

it's possible then to -- one more slide, 

please -- calculate the geometric mean of 

standard deviation and actually come up with 

that 50th and 95th percentile number value 

after corrections and misdoses are applied. 

 And you'll see just by a quick look 

of this monthly data from 1951 and '52 that 

the numbers are going to be about 400 or 200 

depending on the time changed and the 

practices of calibration change. 

 So we can come up with a 95th 

percentile dose for these 10 or so years, 10 

or 12 years, that we've got quarterly report 

data for. 

 So the big picture is this is our 

approach. We've got, as Brad said, to start 

with, a hybrid model. Some periods we've got 
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more refined data. Some periods we've got 

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cases we've got real data for real individuals 

from the NTA film. 

 So we will apply some combination 

of that. And I think that we can make a case 

at this point that we bound in dose for a 

neutron. (***PART 2, 10:22:06***) 

 CHAIR BEACH: Thanks, Bob. 

 MR. MORRIS: You're welcome. 

 CHAIR BEACH: Are there any 

questions? I'm sure SC&A wants to respond, 

but any questions before of the slides or 

Bob's presentation? 

 MEMBER ZIEMER: Josie, Ziemer here. 

 CHAIR BEACH: Yes. Hi, Paul. 

 MEMBER ZIEMER: First let me thank 

Bob for the presentation. It was very, very 

well-done. Can you e-mail me a copy of the 

PowerPoint? 

 CHAIR BEACH: Yes. I am having one 

downloaded to my Flash drive right now. 
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paper itself. I think the shotgun pattern is 

probably not so surprising for the field 

measurements. You have got all kinds of 

scattering situations, which are very 

different in every field measurement. 

 So I like the approach that you 

used here: use the NTA film and do the 

correlation. And I think that's a good 

approach. I assume on the field measurements, 

many of these neutron instruments are also 

gamma-sensitive. 

 So unless they're correcting for 

the gamma or they have set the sensitivity 

setting high, you actually get neutron plus 

gamma to compare. You have to correct that 

back out. I assume they have done that. Is 

that correct? 

 MR. MORRIS: Well, Paul, thank you 

for the comment. We didn't try to do anything 

as subtle as finding out what the interference 

-- 
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 MEMBER ZIEMER: Yes. It probably 

wouldn't have made much difference on that. 

 MR. MORRIS: Right. I think 

probably what drives our large differences, as 

much as anything, is the actual radiation 

protection practices that were applied after 

the measurements were taken. 

 If you think about how you would 

shield with a lead blanket, for example, -- 

 MEMBER ZIEMER: Right. 

 MR. MORRIS: -- you can drastically 

alter the photon -- 

 MEMBER ZIEMER: Right. 

 MR. MORRIS: -- to neutron ratio 

with a -- 

 MEMBER ZIEMER: Once you get the 

reading, you go ahead and make some changes. 

 MR. MORRIS: That's right. 

 MEMBER ZIEMER: Yes. And so the 

reality is that we probably did see those 

kinds of ranges of photon to neutron doses all 

over the facility just because some places 
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were easily shielded, some places were not. 

 MEMBER ZIEMER: Thank you. 

 CHAIR BEACH: Thanks, Paul. 

 Did you have -- 

 MEMBER CLAWSON: I was wondering. 

This construction coworker that you were 

talking about -- 

 MR. MORRIS: Yes. 

 MEMBER CLAWSON: -- explain that a 

little bit to me. 

 MR. MORRIS: Sure. I'll be glad to 

unless you would like to, Mel. Why don't you 

go ahead and do that. 

 MR. CHEW: Okay. 

 MR. MORRIS: I've been talking 

about -- 

 MR. CHEW: What was the question? 

 MEMBER CLAWSON: Well, I got this 

140 times the coworker dose for the 

construction workers. 

 MR. CHEW: Yes, sure. Yes. Let's 

go back to OTIB-0052. I'm glad you asked the 
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question. Remember when we did OTIB-0052, the 

key was, how do you apply an exposure to a 

construction worker that apparently either the 

data was missing or should have been monitored 

if it was not monitored. 

 So that is the focus. It was not 

the person who was monitored. You are a 

construction worker who is monitored. You 

took your actual information. 

 So we went across the complex, as 

you probably already all know, and looked at 

many, many data of people who were monitored 

and tried to compare that to exposures of 

construction workers who were monitored. 

 And so now you can think of this 

because Idaho was a good example, Savannah 

River was a good example, the big sites here, 

where a lot of construction went on, Hanford, 

example, Y-12, Oak Ridge. 

 So you do a coworker model of the 

full people that were monitored. You can see 

at some point in time almost everyone was 
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monitored. They first started monitoring some 

people. Then the monitored everyone, you 

know, how the things change. 

 And so we look at it. Secretaries 

are monitored. Clerical workers are monitored 

because it came along with their badge. So 

you can see how a coworker study could be 

skewed a little bit on the lower end here, 

especially if you had a construction worker 

who actually went into a process area. 

 Example, if he was not monitored, 

which is highly unusual, but anyway he wasn't 

monitored, his exposure could have been higher 

than the average or the 50th percentile, the 

90th percentile, how you are going to look at, 

of everyone who was monitored. You can see 

where that is going. 

 So that is why when we looked at 

all of the data, the majority of the sties 

here are construction workers. If we pulled 

it out of even everyone who was monitored, you 

can tell generally they were even lower than 
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even the coworkers studied. 

 However, in a few incidences, you 

know, we can point them out. In certain 

years, they were higher. Example, Savannah 

River was the one that kind of jumped out at 

us. And we talked a lot about that in 

discussions here. 

 The pipe-fitters went in. And the 

people who drilled the holes into the concrete 

and things like this got higher exposures than 

you would have applied to everyone who was 

monitored this time. 

 So that's why when we sat back and 

looked at it, it appeared that it was much 

easier to just go ahead and apply a correction 

factor. 

 We looked at all of the factors of 

the people who were monitored for the 

construction worker, as compared to the whole 

set. And it showed that there were higher 

exposures for those particular constructions 

for those few years. And we determined that 
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the correction factor of 1.4 should be applied 

to the construction worker. 

 Don't forget this is applied to the 

people who were not monitored or should have 

been monitored and for who, let's say, 

information was missing. So that's where the 

correction factor came in. So it basically 

helps that we can apply that to just the 

construction workers over and be doing the 

coworker for that entire site. 

 MR. MORRIS: So it becomes a 

complex-wide policy decision-level correction 

that applies to any coworker model on any site 

if you were a construction trade worker. 

 MR. CHEW: Does that help, Brad? 

Do you need more detail? 

 MEMBER CLAWSON: No. It does. I'm 

just thinking about the worker that was there 

that was dealing with this on and off all 

through the thing. All of a sudden a 

construction worker comes in that is getting 

1.4 more than what he does. He's actually 
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working for it. 

 MR. CHEW: Well, looking at that, 

if a worker was in there, most likely he would 

have been monitored. 

 MEMBER CLAWSON: Yes. 

 MR. CHEW: Okay. So you would have 

used his actual data, right? The coworker 

study really is to try to give some assessment 

to people who should have been monitored who 

were not monitored or, for some reason, the 

information was not there. 

 MEMBER CLAWSON: Okay. You said 

that you found in this data -- and this is 

probably from Mound or whatever -- that for 

ten years there, they timesed everything by 

two? 

 MR. MORRIS: There was a memo that 

we found that instructed that data to be 

multiplied by a factor of two. 

Retrospectively, they took the database and 

increased the number of the dose of record. 

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everybody? 

 MR. MORRIS: All neutron. It was 

NTA neutron numbers. 

 MEMBER CLAWSON: Right. 

 MR. STEWART: And that was actually 

only for the PP building. What they found was 

their neutron calibration was slightly 

underestimating dose to the PP building, so 

large amounts of shielding there. So they 

retroactively realized it's just simpler to 

run a factor of two for those workers in the 

PP building. 

 MEMBER CLAWSON: Okay. Because 

what I got out of this is that you guys 

basically took that times two off, right, to 

bring it back to normal to everybody else? 

 MR. MORRIS: And then we reapplied 

it as a specific factor that we could actually 

account for, instead of being, let's just 

multiply everything by two. 

 Our factor comes out very close to 

two at the end, but now we know why it does. 
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You can pull out each factor. 

 DR. ULSH: So it's actually kind of 

reassuring that at the time that they were 

proposing to do this, what was it, early '70s? 

 MR. MORRIS: '77. 

 MR. STEWART: When the memo came 

out. 

 DR. ULSH: We've got all these 

issues, and we think it's about two. But they 

didn't really break it up. So we took that 

off, and we looked at those issues 

specifically, combined all of those correction 

factors. And it actually came out pretty 

close to what they had estimated, which I 

guess considering the caliber of neutron 

dosimetrists and neutron scientists at Mound 

is not too surprising. They were among the 

best in the country. 

 MEMBER CLAWSON: So on this data, 

you're saying that you had ten years worth of 

data, this y-axis MESH data? 

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 MEMBER CLAWSON: You had ten years 

of this y-axis? I'm trying to -- 

 MR. MORRIS: So you're talking 

about the last few slides I showed. 

 MEMBER CLAWSON: Yes. You were 

talking about you have ten years. 

 MR. MORRIS: Yes, ten years from 

the early '50s to the early '60s for the 

health physics quarterly or monthly progress 

reports provided us in that categorical zero 

to 100, 100-300 millirem data or neutrons. 

 MEMBER CLAWSON: What did you use 

after that? Did they have -- 

 MR. MORRIS: That was a good 

question. The MESH data ratios -- 

 MEMBER CLAWSON: Okay. So then we 

were able to use the MESH database. 

 MR. MORRIS: We still think that is 

a larger number than we think is appropriate, 

but that is the data we have got. 

 DR. ULSH: Another way to say it is 
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when we got this data from the health physics 

reports, it is preferable to the MESH data 

because certainly it sets a bounding number, 

but it is a very high bounding number. We 

think that the health physics reports gives us 

a bounding number, but it is a more 

restrictive number. It is a more realistic 

number. So when we've got that data, we'll 

use it over the MESH. 

 CHAIR BEACH: Does SC&A want to 

present or -- 

 MR. FITZGERALD: Yes, I think just 

briefly. I certainly want to acknowledge the 

amount of progress work that has been done 

over the past year. And this sort of started 

out as a bit of a blank slate. There has been 

a lot of progress on it. So it's very 

positive. 

 We had a technical call. And as 

was mentioned, we covered a lot of details 

which had been addressed. And there will be 

notes from that call available. 
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 I think, really, there are two 

novel approaches. I don't know if I can call 

it novel but certainly ones we haven't seen. 

NTA film, of course, was rather universal 

across the Department. 

 So we've kept this issue almost in 

every SEC. And different approaches were 

posed in terms of how does one deal with the 

same issues as fading and energy dependence? 

 And the two aspects that I've -- 

and Ron I think will go through in detail, but 

the two aspects that we want to clarify and 

understand better, one is the -- I don't know 

if this has been applied before, but the MCNP 

model, you know, certainly a well-thought-out, 

well-researched, and respected model, I don't 

think I've seen it applied for this purpose at 

other sites. So I think we want to understand 

that better. 

 And the second thing is the 

constructive coworker model, which we didn#t 

get into in our technical call, I think we 
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want to expand upon it a little more, 

certainly those two issues. 

 The rest I think as we I thought 

made clear we felt were constructive to the 

site profile that you're revising. And I 

think we don't need to get into those specific 

details now. If anyone is interested, we will 

have some in this meeting, and we'll lay out 

those issues. 

 Ron, if you want to tee it off 

certainly first on those two issues or any 

other issues you think ought to be raised? 

And then others can get started on it. 

 MR. BUCHANAN: Okay. Well, thank 

you. And I thought that NIOSH did a very good 

presentation of what we plan on doing on the 

neutron issue. 

 For those who might not be familiar 

with it, I would like to put it in 

compartments so that you can wrestle with it 

maybe a little better. 

 We have the issue that the neutron 
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film measured the dose above half MeV. What 

do we do with the dose that wasn't measured 

below a half MeV? And so what kind of 

correction factors are appropriate to apply to 

the recorded dose to make sure the worker is 

assigned his full neutron dose? That is issue 

number one, which we'll get into the detail. 

 Issue number two is for the worker 

that should have been monitored for the 

neutrons and was not monitored for neutrons. 

Then what model can we use to assign him 

neutron dose? Okay. 

 So those are the two issues. And 

in the latter part, where the person was 

unmonitored but should have been monitored, 

there are two parts. 

 What they are doing here is looking 

at using the n/p ratio obtained from people 

who were monitored and apply it to that 

unmonitored worker or going back and looking 

at the neutron doses of people that were 

monitored and creating a coworker model. 
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Unfortunately, that is in categorical 

intervals, rather than exact doses. 

 And so those are the three areas I 

would like to expand on a little more and make 

SC&A's comments on. And so the first one is 

what do you do with the missed neutron dose 

below a half MeV? 

 Now, granted, the NTA film monitors 

the dose above a half MeV. And so sometimes 

the dose below a half MeV is rather small, 

like he illustrated, because the amount of 

neutrons needed to create a substantial dose 

that's small. As energy goes down, it does 

less damage to the tissue. 

 And if you have a bare neutron 

source and it's a small amount that's over 

dose, if the person is working around a very 

moderated source where the neutrons are 

thermalized a lot and get lower energy, then a 

lot of them fall below that threshold level. 

And so that could be a substantial person, a 

person's total dose. 
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 Generally at Mound, you would not 

have 100 percent dose below the half MeV 

threshold. And so it's going to be some 

fraction of whole dose. 

 And so what they did, I would like 

to briefly go over their table 4-3. Would 

that be too much trouble to bring table 4-3 

back up? 

 DR. ULSH: Yes. 

 MR. BUCHANAN: It would? Okay. 

 DR. ULSH: I do have hard copies. 

 MR. BUCHANAN: Because they broke 

it down into five factors there. And I want 

you to be aware of what factors we're 

discussing because they can all kind of run 

together. 

 If you turn to page 16, if you turn 

to page 16, table 4-3 -- and from Brad's 

question, I want to clarify something there. 

If you look at column 1, it is the year. And 

so then you look, column 2 is a correction 

factor that was applied by Meyers and his 
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group or recommended by the -- Meyers noted 

it. It was recommended by the health physics 

group. 

 In 1970 to '77 -- this is kind of 

an important factor because, you see, it's one 

down to 1969, which we agree with, and then 

they divided it by 2 because it had been 

doubled in the past. So we want to take that 

back out. 

 That's 1970 to 1977. So that was 

the period you were talking about, Brad. 

 DR. ULSH: Right. 

 MR. BUCHANAN: And so that is the 

reason that .15 appears there is that in the 

record, it has been doubled. So we want to 

unfold that and bring it back to where it 

should be. And we have some site profile 

issues about that, but they are minor, not 

fancy issues. 

 And so you will see that there are 

five columns there. And then there is a sixth 

column, which is all the correction factors 
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rolled into one. 

 Now, SC&A would like to discuss 

column 3, which the NTA film threshold 

response, from which this was derived using 

the Monte Carlo NP model. And so this is the 

one we want to discuss. 

 Column 4 is the neutron energy 

calibration source. And we do not have a 

problem with this because what this is saying 

is that the neutron source that was used for 

calibrating the film matched what was being 

used in the field. 

 Now, this is the raw source of 

neutrons, not what the worker was exposed to, 

but the origination, the nuclear reactor that 

created the neutron to begin with. So we 

don't have a problem with that. 

 The next one is track fading, as 

Bob alluded to. We do have some issues with 

that from 1963 to 1969, which can be resolved. 

 Those were some more site profile issues, 

rather than SEC issues. However, if they 
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remain the way they are, I would consider them 

not reconstructing doses with accuracy. 

 And an angular response in the next 

column, 1.3.3; that is, if you are getting 

irradiated from the side, rather than directly 

on, that's fairly published literature. We do 

not have a problem with that. 

 And we feel that column 7 is a good 

move for the dose reconstructor. These are 

all multiplied out. And that's his final 

number over to the right there at what you 

would multiply it by, their recorded dose. 

 So what I would like to concentrate 

on is the third column. And then after we 

discuss that, I would like to move on to the 

NP models and the coworker dose models. 

 So factor 3 is the factor you can 

multiply the workers', the monitored workers', 

neutron dose by to arrive at his true dose, 

which includes the dose that was missed below 

the half MeV mark. 

 And so what NIOSH is proposing is 
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the MCNP model, which SC&A does not have a 

problem with the model itself. This is a 

fairly well-known worldwide model that you 

take data in, you sit up a parameter, you 

determine what amount of dose is missed below 

a certain dose amount. And then that gives 

you a factor, the output, 19 percent or 33 

percent, 36 percent, or whatever. 

 And so the two issues that SC&A has 

are the input parameters and comparing any of 

the output to real Mound-reported data. And I 

would like to explain that at this point, 

then. 

 The way this MCNP model was 

constructed was they said, what was the likely 

moderation and scattering situation at Mound? 

 And as you get more scatter, it decreases 

energy neutron. And so you register less and 

get more moderation. It moderates the 

neutrons. And you register less by NTA film. 

 So what they did was take a 

wall-less source, point source, surround it 
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with none, 2, 4, 6 inches of water in the 

middle of a concrete silo and take 12 inches 

of concrete -- and if I am wrong on any of 

this, jump in -- 12 inches of concrete on the 

floor, 12 inches on the wall, and 12 inches on 

the ceiling, 3 meters in diameter and 3 meters 

high, or something like that. 

 Anyway, it would simulate a person 

working in an environment with a source and 

the neutrons being thermalized or moderated. 

Thermalized should be moderated. 

 And then what would the operator 

get, 60 centimeters, and an observer, say, a 

rad tech or something out here, 240 

centimeters because he would be closer to the 

wall. How much of his dose would be missed 

because of the scattering and moderation? 

 And in that handout they showed 

you, it shows some tables showing the percent 

missed. And what they found out was the 

observer actually missed more on his film 

badge, showed more of the misdose, than the 
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operator because he was standing by the 

scatter from the wall. 

 And this amounted to 19 percent for 

the polonium beryllium sources, which were 

used in an early part of Mound's operation, 

and would be 36 percent would not be 

registered during the polonium operations, 

such as the PP building. 

 And so if you take 1-19/1, you get 

this factor 1.23 you see in the third column 

there up through '63. Then in the mid '63, 

Mound went to using strictly a plutonium-like 

calibration because it's a lower-energy 

source. And so they looked at a use of 

plutonium factor of 36 percent. 1-36/1 is 

1.56, which you see is the rest of the years 

that the NTA film was used. 

 Well, that's where the 1.23 factor 

and 1.56 factor come from. And we don't 

really have any heartburn with the NTA MCNP 

model and what they put in and what they got 

out. 
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 Our two contentions are that we do 

not see that the input parameters, this 

concrete silo I was talking about, was 

actually taken from the Mound operating 

conditions. It is a generic. 

 This would fulfill most conditions 

at Mound of what happened, but we did not see, 

for example, say, five situations, a glove box 

worker, an RTG worker, whatever the operations 

were, say, and put into the model and see what 

the misdose below half MeV was on the output. 

 That's a number one question on this. Is 

there a direct tie to Mound operations to set 

aside the SEC requirement? 

 Number two is, then once you got 

this output, it would be more substantial if 

we could compare that to some kind of 

benchmark pattern. I know that the reason we 

are creating this model is that there is not a 

whole lot of this information available. 

 But, as Bob pointed out, there were 

some measurements made. There is one 
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particular measurement that was made. In 

1978, where they took NTA film and TLD 

dosimeters -- of course, the TLDs do not 

suffer from a half MeV threshold. In fact, it 

is more responsive at lower energy and less 

responsive at higher energies. Some develop a 

huge dose. 

 Anyway, they did a ratio. And this 

is where this magic number two came from 

originally to correct the 1970 to 1977 data 

was that when they were switching over to 

TLDs, they did NTA film and TLD badges 

simultaneously in the PP building and found 

out that they were missing about half the 

dose. 

 The NTA was reading about half of 

what the TLD was reading. And so that is the 

reason that they had a directive to go back 

and increase this dose by two. 

 So that is one benchmark that our 

MCNP model could be compared to. And I think 

it misses the mark some because they came out 
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with a factor of two just for the energy 

correction. This did not include the angular 

dependency and some of the other things that 

are in here. 

 And so SC&A's point is that we 

don't have a problem with the Monte Carlo 

model. We just have a problem with tying the 

inputs to actual Mound situations, validating 

some benchmarks on the output to show that the 

results limit or where do the results fall 

within the actual data. 

 Such tasks as OTIB-0049 were able 

to show that this bounded the situation. And 

how does it compare? If we did some real life 

in and out, would we see some trends we didn't 

expect or just some sort of physical real 

world validation of an input and output? 

 So that is where we stand on 

determining the misdose below a half MeV. 

Now, the other issue is, what if the person 

did not have NTA film and should have been 

monitored? 
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 Yes? 

 MR. KATZ: I'm just going to 

suggest since that is a chunk right there 

maybe. That's -- 

 MR. BUCHANAN: Okay. 

 DR. ULSH: Well, we discussed this 

to some extent, where these parameter values 

came from. I'll let Bob expand on that, but 

these were meant to represent realistic 

situations at Mound. 

 And I think I even remember Joe and 

I having a discussion about could you come up 

with worse conditions; in other words, 

conditions that would have led to more 

misdose? And the answer is, sure, you could 

have, but our response was that wouldn't be 

realistic for Mound. 

 So as you are no doubt aware, with 

any model, you want to kind of approach this 

from a sensitivity standpoint. And I think 

Bob has done some of that in terms of, well, 

what if the moderator was thicker than what we 
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have modeled? How much of an impact would it 

have had? And it turns out not much. 

 In fact, the parameter values that 

we picked, that was one of the specific 

questions that we asked the nonworkers that we 

met with during that outreach meeting. 

 Take a look at the parameter values 

that we picked, the conditions, the scenarios 

that we have envisioned. Are we off the mark 

here? Do these represent the kinds of 

situations that you had worked in? 

 The answer was, by and large, yes. 

 I think they did suggest that we model a 

different physical form of plutonium. 

 MR. MORRIS: They did. They 

suggested that we use a plutonium oxide in 

aqueous solution. 

 DR. ULSH: Right. 

 MR. MORRIS: But the problem with 

that model is that the amount of plutonium 

that was ever in aqueous solution is so much 

less that it probably is sort of a trivial 
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example. 

 DR. ULSH: So these are not meant 

necessarily to be worst case in the terms of 

could you sit in an office somewhere and dream 

up a worst scenario, sure, but they're meant 

to be the worst kind of bounding cases that 

are realistic for Mound. 

 MR. FITZGERALD: Well, I will just 

interject. That's kind of where we're coming 

from. This is a generalized model, where 

you're picking admittedly conservative 

parameters. And we did have this 

conversation. 

 And you're trying to come up with 

this generalized model because there isn't 

sufficient site-specific data to allow you to 

model for Mound directly; in other words, be 

able to actually take actual geometry, actual 

operations. That would be a big job. 

 So I understand where this is 

headed, but I guess as I prefaced my remarks 

earlier, I don't think we have actually had 
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this recommended or proposed for the same 

kinds of issues that other sites and SEC -- I 

just want to step back and say, this is a 

generalized model where you have clearly 

selected conservative values. 

 But at least it makes us pause a 

moment and say, they're conservative values, 

but how is one able to establish an upper 

bound for the doses or exposures at the site?; 

which is usually the point we get to in these 

SEC conversations. And we're having some 

difficulty on that because it doesn't link 

back. 

 I think Ron actually sort of cited 

this. It doesn't link back to the site and 

benchmark in such a way that not only can we 

say, Yes. Certainly you did try to put 

conservative values in here. 

 But given the fact this is being 

proposed because there isn't site-specific 

data sufficient to allow dose estimation more 

directly and you're applying a generalized 
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model that isn't founded on specific Mound 

data, I think -- and this really is 

reminiscent of the surrogate data debate, 

where what kind of justification or how can 

one demonstrate that it is truly not just 

simply conservative but we bound the doses you 

would expect at the site. 

 I think that would lead us to 

saying it almost appears that one would have 

to benchmark against something that would 

demonstrate that not only is this 

conservative, but it's bounding. 

 MR. MORRIS: If you recall, one of 

the reasons -- we said this explicitly. 

Probably one of the most important reasons we 

chose to have a Mound outreach meeting on this 

topic was exactly to get the feedback that 

you're hoping to get in some context of 

saying, is this realistic for the workplace 

that you folks were working in? 

 I think we got that affirmation 

from them, don't you? 
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 DR. ULSH: Absolutely. 

 MR. MORRIS: Yes. 

 CHAIR BEACH: Well, could we 

request NIOSH to validate its MCNP dose 

estimate by modeling against actual Mound 

data? 

 DR. ULSH: What actual Mound data 

would you like us to -- 

 MR. MORRIS: You mean like get a 

blueprint of a room and room cuts? Once you 

starting putting in turn of this corner or 

that ventilation duct, the models get 

extremely complicated and become a Master's 

dissertation. 

 CHAIR BEACH: It would be nice for 

us to look at site-specific data. And the 

technical part of it is a little probably 

above me, but I would like to see something 

modeled that we can look at that is actually 

from -- 

 MR. FITZGERALD: Even further back 

than that, you know, certainly it is a 
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laudatory thing to actually try to benchmark 

against the workers. 

 But I'm a little concerned about 

given how many years back we are trying to go 

back with the neutron issue, trying to 

recollect 30 or 40 years of history in 

providing that. 

 I haven't seen the interview notes. 

 I think that would be useful for the Work 

Group to see the interview notes to understand 

how that all fed into this. But it's the one 

part of your framework. 

 I think the framework certainly has 

come together quite well. It's the one part 

of the framework which is somewhat novel to 

us. And we're trying to understand how that's 

going to present a bounding approach for that 

level below 500. And I think it contributes 

by having workers give testimonials. 

 But I just don't think that has 

quite the edge that would allow you to say it 

is bounding and there's not a concern over 
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whether this is representative of the site. 

 I think it is conservative. I am 

not saying it isn't. I think this is the one 

element of the framework we're just not quite 

there with yet. 

 MR. MORRIS: My problem is I can't 

take -- I understand the concern. I'm not 

sure exactly how to specifically -- 

 MR. FITZGERALD: That's what I'm 

saying because I'm looking at this thing and 

saying I think that would be the caution I 

would have, but I don't have a proposal at the 

table. 

 I'm just saying how -- you know, 

you certainly considered that. And you 

certainly went to the workers as an avenue of 

trying to get some testimonials that this 

seems to be a pretty conservative approach and 

representative. 

 MEMBER ZIEMER: Josie? 

 CHAIR BEACH: Yes, Paul? Go ahead. 

 MEMBER ZIEMER: Well, of course -- 
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well, this is for Ron. I'm trying to 

understand a little better the issue that SC&A 

has raised. As I understand it, Ron, you're 

asking, could the misdose below a half MeV 

have been much greater than NIOSH is 

projecting from the model? Is that the issue? 

 In other words, are there 

geometries that would cause a much greater 

amount of, well, I won't call it thermal but 

at least below half MeV neutrons that would 

result in a significantly higher misdose? Is 

that the issue? 

 MR. BUCHANAN: Yes, Paul, that's 

the issue. 

 MEMBER ZIEMER: And so that goes to 

I think the geometry assumptions and how 

realistic they are. How much moderation could 

you get? 

 Well, for example, could you show 

no spectra -- what was it, two and a half 

millirem, fast neutron cutoff, and still have 

a significant amount of some .5 MeV neutrons? 
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 Are there some geometries that would do that? 

 Is that what you're asking? 

 MR. BUCHANAN: No. I don't think 

at Mound we are proposing that the NTA film 

would rest or nothing above the half MeV and 

you would have a large dose totally below the 

half MeV. Our question is that below half 

MeV, we can't read that dose. So what do we 

assign? And it could be a reasonable portion 

of the total dose. 

 In this case, their MCNP model 

models that amount of dose below the half MeV, 

but we don't have any benchmark to show that 

it's directly related to Mound operation and 

data that was actually taken at -- 

 MEMBER ZIEMER: It appears that one 

of your concerns is that the starting spectra 

may have been different than the calibration 

spectra or spectrum as the case may be. Is 

that right? 

 CHAIR BEACH: A lot of heads 

shaking no there, Paul. 
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 MEMBER ZIEMER: Pardon me? 

 CHAIR BEACH: A lot of heads 

shaking no on that one. 

 MR. BUCHANAN: No. We don't have 

an issue with the neutron spectrum they're 

feeding into the model. 

 MEMBER ZIEMER: Okay. I thought 

you were concerned about the one column that 

-- 

 MR. BUCHANAN: The correction 

factor, column 3, which is the correction 

factor that is applied to the recorded dose. 

Does this represent the correct amount of 

misdose below the half MeV threshold? 

 And we agree that it is 

conservative. And in most cases it probably 

does compensate for it, but we have not seen 

any proof in the pudding that it does 

compensate from examples taken from actual 

operations and recorded dose at Mound. 

 Whether the Board accepts a model 

that hasn't been validated anywhere with 
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benchmarks, that's more up to them. We would 

like to bring that point out. 

 DR. ULSH: Well, I've got a couple 

of thoughts on a number of things that have 

been said sort of a test. The first is the 

concern that we're asking workers to remember 

information from decades ago. And I think 

there is a bit of a double standard here 

because in other situations, concerns of 

workers have been raised up as almost the sole 

basis for SEC issues. 

 I would contend here that the group 

of workers that we picked were explicitly 

picked to be representative of the neutron 

expertise at Mound. These include people like 

[identifying information redacted], who I 

would say along with [identifying information 

redacted], Roger Falk are probably -- I mean, 

this is the foremost neutron expert in the 

country. 

 These are people who were hands-on. 

 They were in the buildings. We aren't asking 
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them to remember exactly where they were at a 

particular point in time. We're asking them 

to remember essentially what kind of 

conditions they worked in on a day-in/day-out 

basis. 

 So I would say that that carries a 

lot of weight in this situation. Number one, 

it's the expertise of the people, but number 

two is the breadth of the people we consulted. 

 So I would give a lot of weight to that. 

 In terms of could there be a large 

fraction of the neutron dose that fell below 

what we're detecting, you've got to keep in 

mind here that there are limits on how much 

moderation you can have. 

 I mean, you can't reach through an 

infinitely thick moderation. You can only 

reach through about six inches or so before 

you can't reach through it anymore. I mean, 

that's what we're talking about: shields that 

were placed in front of essentially glove 

boxes. 
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 So there are practical physical 

limits on how much moderation you could have. 

 And I think Bob clearly laid out that the 

dosimetric significance of these very 

low-energy neutrons is trivial. I mean, they 

just don't give you any dose, even if the flux 

is higher, to any great extent. And in terms 

-- 

 MEMBER ZIEMER: Well, the flux has 

to be about three orders of magnitude higher 

per neutron to give you equivalent doses for 

thermals. It's a tremendous difference. 

 DR. ULSH: And I would say that 

that is an unrealistic expectation that there 

would be three orders of magnitude more flux 

at those lower energies. That is just not 

realistic. 

 CHAIR BEACH: And I think you have 

a comment while we continue. Sorry. 

 DR. ULSH: One last point. Sorry. 

 With regards to this being a unique approach, 

I mean, it is really not much different from 
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the way we approach any site. It depends on 

the data that is available. And this is the 

particular data that we have available at 

Mound. 

 MCNP has been used, not just in 

industry in general but specifically in the 

dose reconstruction program. I think, 

although don't hold me to this, it was used in 

the glove box TIB, although that might have 

been another code similar to it. 

 MR. MORRIS: Similar code. 

 DR. ULSH: It was a TILA? 

 MR. MORRIS: A TILA. That's right. 

 DR. ULSH: Okay. Well, MCNP I 

think was used at the Hanford neutron dose 

approach certainly. 

 MR. MORRIS: Yes. 

 MR. BUCHANAN: Industry approach. 

 DR. ULSH: Yes. So it has been 

used. It's just not a completely out of the 

blue-type approach. It is specific to Mound, 

just like the neutron approach at Hanford is 
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specific to Hanford or the neutron approach at 

Y-12 is specific to Y-12. 

 CHAIR BEACH: One last comment from 

Kathy. And then we're going to need to take a 

ten-minute comfort break at this time. So 

Kathy? 

 MS. ROBERTSON-DeMERS: All I was 

going to say is I would reemphasize what Joe 

said, that we would like to see the notes from 

this worker outreach meeting. 

 DR. ULSH: And I don't know. Have 

those been put on the SRDB, Karin? Do you 

know? 

 MS. JESSEN: When I looked last 

time, they weren't there. 

 DR. ULSH: But we have them in the 

queue for loading up or -- 

 MS. JESSEN: I would have to 

double-check that. 

 DR. ULSH: All right. We'll make 

sure that those -- 

 MR. FITZGERALD: And, Josie, before 
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we lose the thread -- this will take 30 

seconds. 

 CHAIR BEACH: Okay. 

 MR. FITZGERALD: First, as I said, 

I think the interviewing of the HPs and former 

workers is not only laudatory. It is a very 

good approach for benchmarking. What we're 

saying, though, is: is it sufficient? That's 

what we're telling the Work Group. 

 The second thing is certainly the 

MCNP as a proposed avenue of doing what it is 

being proposed to do for Mound is certainly 

the first time for the SEC discussion that we 

have seen. And that is the reason we want to 

certainly explore that and understand it 

better. And that's why I prefaced my remarks 

before. 

 So we're not saying it doesn't have 

applications. In fact, we know it has been 

applied in the commercial sector and is a 

well-recognized, respected model. 

 It is a generalized model. And one 
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had to take these parameters as we discussed, 

so just to make those comments. Let's take a 

break. 

 CHAIR BEACH: I probably won't let 

it go out either because I would like to see 

that in practice for my own benefit. 

 DR. ULSH: What do you mean in 

practice? 

 CHAIR BEACH: As a model to 

validate your model with Mound data. 

 DR. ULSH: Okay. I'm just trying 

to be clear about what it is you would like to 

see. What Mound data do you wish to compare 

against? 

 I mean, as we have talked about, 

the reason that we are taking this modeling 

approach, instead of using Mound data, is 

because there are problems with the Mound 

data. 

 So if you can give us some idea of 

what data you would like to see us benchmark 

against, that would certainly help us to 
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respond. 

 CHAIR BEACH: Let's go ahead and 

take a ten-minute break -- 

 MR. MORRIS: And think about that. 

 CHAIR BEACH: -- and come back 

about a quarter after. Does that work? 

(***PART 3, 11:21:54***) 

 (Whereupon, the above-entitled 

matter went off the record at 11:05 a.m. and 

resumed at 11:21 a.m.) 

 MR. KATZ: This is the Mound 

Working Group. And we're coming back online. 

 And I think we're still in the discussion 

about neutron doses. 

 CHAIR BEACH: Yes. And if there 

are no further comments on the first item that 

Bob presented -- Bob, you did have two other 

points to present? 

 MR. BUCHANAN: One other, I think. 

 CHAIR BEACH: Ron. Sorry. 

 MR. BUCHANAN: Two other points. 

Yes. One other major point with two parts. 
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 CHAIR BEACH: So Ron, instead of 

Bob. Thank you. Excuse me. 

 MR. BUCHANAN: Okay. Now, we 

talked about the one subject of missing the 

dose under half MeV. The second part was for 

the person that wasn't badged wanting to 

assign them for neutron dose that should have 

been monitored. 

 And there was the possibility of 

using the badged people's information and 

determining coworker dose and then also using 

some records that were categorical and then 

also using the person's photon reported dose 

and assigning an n/p ratio. 

 So SC&A's stand on those two issues 

was, number one, we look at determining an n/p 

value from the recorded doses. And we do not 

have a problem with this method. We discussed 

on the phone some reservations about the 

values that are showing in the table of the 

handout that they fluctuated quite a bit and 

such. 
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 This was not addressed in this 

meeting to any degree, but we don't have a 

problem with the method. It's just the actual 

values that appear there. And I was trying to 

find which table that is because also we have 

the handout. 

 This is on page 21, table 4-4. And 

this would cover the '49 to '77 time frame. 

And you see there in the column there the 50 

percentile, the 95th percentile. We have 

ranging of .6 to 18.6 as the n/p ratio for the 

50th percentile and the 95th percentile 1.137. 

 Realistically this is quite a wide 

swing. And so we would like to see further 

work or comments on that as far as using it 

for an actual dose reconstruction. 

 Generally your n/p ratio in working 

environments, these types of sources would 

probably run from one or less up to 10, maybe 

on the outside 20. So we figured it would be 

37, 34 values are probably extremes. But we 

do not feel that, like the 2.6 or 2.8 and the 
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lower values would bound doses for some 

situation. So that would be one way to assign 

dose if you did not have recorded dose. 

 Now, I understand NIOSH to say they 

felt these were maybe high using this. 

Perhaps I would like to ask a question of 

NIOSH because it was kind of conflicting in 

the white paper. 

 Do you propose that table 4-4, the 

95th percentile is bounding or just 

conservative? 

 MR. MORRIS: We think that it's 

useful for dose reconstruction. And we have 

taken your comments under consideration. And 

we will probably revise those upper 95th 

percentile numbers as bounding. 

 MR. BUCHANAN: Okay. 

 MR. MORRIS: This is different from 

what we discussed. Is that right, Ron? 

 MR. BUCHANAN: Yes, that's right. 

We just wanted to make the -- 

 MR. MORRIS: We're taking your -- 
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it does make a statement that these n/p ratios 

are maximum or I assume that means bounding. 

And I want to clarify that at this point. Do 

you feel that they will be when you revise 

them? 

 MR. MORRIS: We think they will be 

when they are revised. 

 MR. BUCHANAN: Okay. 

 MR. MORRIS: They will be useful as 

an SEC bounding calculation. 

 MR. BUCHANAN: Okay. That's all I 

had on the coworker derived from reported 

dose. 

 CHAIR BEACH: Okay. Any follow-up 

from NIOSH other than what Ron has said? 

 DR. ULSH: Are there more issues 

that you are going to -- 

 MR. BUCHANAN: They're half of it. 

 It's coworker from the categorical I wanted 

to address. 

 CHAIR BEACH: Go ahead. 
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 MR. BUCHANAN: Okay. So the second 

half of determining the dose to an unbadged 

worker was NIOSH feels that the n/p values 

were somewhat excessive. So they went and got 

the categorical data and looked at it. 

 Categorical data is film badge 

results from actual workers that did not have 

the actual dose. It is actually when they 

made these reports, they put it in bins or 

categories zero to 100, 100 to 300, or above 

300, this sort of thing. 

 And so what this does is give you 

an idea of how many people were in a certain 

dose range but not the actual dose. So what I 

did is I analyzed this table. And in your 

handout NIOSH provided, that is in table 6-2. 

 What I would like to do is to look 

at -- I understand the definition of coworker 

dose. 

 CHAIR BEACH: Do you have a page 

number for 6-2? 

 MR. BUCHANAN: Oh, 28. 
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 CHAIR BEACH: Thank you. Sorry. 

 MR. BUCHANAN: Page 28, table 6-2. 

 My understanding of coworker dose is that 

some were monitored and some were not 

monitored. So you would use the ones that 

were monitored. And that would reflect the 

dose of the average worker in that group at 

that time or the person that wasn't monitored. 

 So there should be some correlation 

between the dose that the person received and 

the person that wasn't monitored. It should 

follow some trend on dose values. 

 If you look at table 6-2, you will 

see that the numbers they will use, the median 

value in column 5 or the 95 percentile in 

column 6, if you look there, you can 

categorize the first full increase as around 

360. You can categorize the next entries down 

through March as around 200. And you can 

categorize the rest of the order entries 

around 600. 

 What you find out is that these 
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values follow the exchange recordkeeping 

cycle, as opposed to a measured dose. So that 

if it was weekly, it ran around 360. If it 

was on a monthly recordkeeping basis, if it 

was an exchange, it was every two weeks. And 

if it was a monthly recordkeeping cycle, it 

was 200. And if it was quarterly and every 2 

weeks exchange, then it was around 600-700 

millirem. 

 The amount in the upper brackets 

above, so essentially it boils down to the 100 

millirem interval multiplied by the, adjusted 

by the, exchange in recordkeeping cycle, that 

it does not really reflect much on what is 

above 100, in the 100 to 300 or above. 

 The 95th percentile reflects it a 

little more. Because you get some of the 

upper extremes, but it still follows that 

general cycle. 

 SC&A's position is that the 

coworker dose based upon this categorical data 

at this point is not sustainable as a good 
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working model. 

 CHAIR BEACH: Thank you, Ron. 

 NIOSH? 

 DR. ULSH: I think you hit the nail 

on the head, Ron, that the medium dose tends 

to be influenced heavily by the badge exchange 

cycle. And that's because most of the badge 

reads resulted in non-detect. 

 So I think you've got that part of 

it right. I didn't quite follow why that is 

not valid to use for coworker data, though. 

 MR. BUCHANAN: Well, the coworker 

data in a medium neutron dose is a function of 

the exchange cycle and the read cycle, which 

doesn't really reflect actual recorded dose. 

 MR. MORRIS: It does reflect 

recorded dose as corrected or missed dose. 

 DR. ULSH: Right. It reflects the 

fact that those badges were in less than 

detect. And that would tell you that unless 

the median is right around the limited 

detection, it would tell you that 50 percent 
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of the people got right around the LOD. 

 And, furthermore, I mean, what we 

are talking about here, these are the people 

who are permanently stationed in, say, for 

instance, SM building. It's reasonable to 

presume that the monitored workers were ones 

that were at least judged to be at highest 

exposure potential. 

 So when we are talking about an 

unmonitored worker, in the Mound-specific 

situation, what we are talking about is 

someone who went into, say, for instance, SM 

building, maybe a plumber, maybe a carpenter, 

who was not permanently stationed in SM 

building but was a visitor to that building, 

not to the site but to that building. 

 And they picked up a visitor badge, 

a visitor photon and neutron badge. They went 

into the site. They came back out. Unless 

their photon badge read above a certain level, 

they didn't bother to read the neutron badge. 

 So I would propose to you that 
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those people that fall into that visitor-type 

category were certainly at far lower exposure 

potential than the people who were badge and 

permanently stationed in SM. 

 Therefore, if we're applying a 

coworker model based on the people who wore 

badges who were, in fact, overestimating by 

quite a bit the dose that those unmonitored 

people could have gotten on a one or two-day 

entry into that building, the fact that even 

the monitored workers got right around the LOD 

just simply indicates that, well, I would say 

it indicates that, number one, they were 

badged frequently and, number two, it 

indicates success somewhat in limiting neutron 

dose. 

 I don't see why even at 100 percent 

or more LOD, why it would not be bounding or 

sufficient to estimate the unmonitored 

workers' dose at the LOD. I mean, that's -- 

 MR. BUCHANAN: Well, because in 

this case the dose you would assign would 
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depend upon the exchange cycle and the degree 

of the cycle of the recordkeeping, as opposed 

to any measured dose -- 

 MR. MORRIS: That's what it is when 

we do a dose reconstruction with this data 

right now. If there is an identified 

monitored worker who shows up with this NTA 

film right now we assign, most of the doses 

are driven by the missed dose concept. 

 MR. STEWART: Measured dose is a 

small fraction of the dose we assign in Mound 

claims. 

 DR. ULSH: In any claims, really. 

 MR. SHARFI: It's true for any 

assignment. They're driven by this list. 

 MR. STEWART: There are exceptions. 

 If the person worked exclusively with neutron 

sources, then their measured dose may eclipse 

in this dose to a greater or lesser degree. 

 DR. ULSH: There are very few 

situations across the complex where most of 

the dose if you look at a coworker 
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distribution is above the LOD. 

 There probably are some, but I 

would say they are pretty darned rare. This 

is not a Mound-specific situation. 

 MR. BUCHANAN: But if you step back 

for a minute, you are essentially saying if a 

person is unmonitored, you are going to assign 

them misdose. 

 DR. ULSH: Correct. 

 MR. STEWART: We don't have much -- 

there are two kinds of unmonitored doses. 

Those doses that have a zero in that column 

for that year because we only have annual data 

are assumed to be monitored and, therefore, 

get misdose. 

 If they state that they are not 

monitored in that year, which some records do, 

or if that year is missing from the MESH 

printout, that worker is assumed to be 

unmonitored in that year and does not receive 

misdose. 

 MR. BUCHANAN: But in this case, 
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this would be used for workers which should 

have been monitored, not monitored -- 

 MR. STEWART: Correct. 

 DR. ULSH: It would be used for 

workers in that situation that I described. 

It went in on a visitor badge because their 

gamma dose didn't exceed that threshold. They 

didn't bother to read the neutron badge, the 

assumption being that, well, if the gamma is 

not passing that number, then the neutron 

certainly wouldn't. 

 We are not accepting that rationale 

at face value. We're saying no. We're going 

to go back and assign the neutron dose. 

 MR. BUCHANAN: Okay. And so we 

went back and assigned a misdose on their 

badge cycles would be a simpler process and 

essentially what we're doing here. 

 MR. MORRIS: Except at the 95th 

percentile. 

 DR. ULSH: Well, in some 

situations. 
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 MR. MORRIS: I think generally 

you're probably close to right except for the 

median value. Ninety-fifth percentile value 

tends to be a little higher than that. 

 MR. BUCHANAN: I don't disagree. 

I'm just saying, is that an acceptable 

practice when it boils down to when you have 

an unmonitored worker which you want to assign 

dose to, essentially, say that we're going to 

assign him misdose because that's what the 

badge results showed on a general categorized 

basis? Is that an acceptable practice? 

 DR. ULSH: I don't think that would 

be acceptable if the actual coworker 

distribution of the monitored workers showed a 

median dose that was above the LOD. In that 

situation, if we said, "No. We're going to 

give a misdose," that would not be 

appropriate. But the fact that we have looked 

at the actual monitored worker population and 

the median dose is at the LOD, then that's 

what you use. It's not necessarily just 
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applying misdose. It's based on the 

experience of the actual worker population. 

 Now, that happens to be at the LOD, 

but that's reflective of the situation at the 

site. I don't know what else we could do. We 

can't make the median something different than 

it actually is. 

 MR. BUCHANAN: We do have some 

detailed data. I mean, for years -- this 

covers '51 through '60 or you say it will from 

the phone conference. You have some more data 

to fill in some of these months that aren't 

available as we went to a period of time, say, 

'62 or something and saying, how does this 

apply during this period when we do have some 

other data? Have we checked to see if this is 

realistic? 

 MR. MORRIS: Are you saying have we 

taken a monitored worker whom we have data for 

and reconstructed the dose -- 

 MR. BUCHANAN: Right and compared 

it. 
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 MR. MORRIS: Well, of course, you 

will find that some people have more and some 

people have less. That's the definition of 

median and 95th percentile. 

 MR. BUCHANAN: This is the first 

time, just like the Monte Carlo monitoring, 

this is the first time I have seen the 

categorical badge data used for coworker. 

 MR. MORRIS: The only question 

really is, how do you take numbers that were 

traditionally are integer values and we end up 

making an assumption that it's the middle of a 

distribution, instead of an actual number 

lower or above the middle of the distribution? 

 But our bands are pretty tight. 

It's not like they're spanning from zero to 

five rem and five to ten rem. They're 

fractions of a rem. 

 So I don't think that there's a lot 

of lost information by the fact that it's 

categorized. It's still pretty tightly binned 

data. 
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 DR. ULSH: In fact, since it's a 

log-normal distribution, almost certainly if 

you actually had the data to look inside those 

bins and see how many -- see, the first bin is 

zero to 100. If you had the power to look 

inside those bins, you're going to find that 

most of them are clustered right around zero. 

 So by using categorical data, we're 

being claimant-favorable. 

 CHAIR BEACH: So can you provide 

the Work Group with a model that has been 

validated against representative Mound doses, 

actual doses of record? 

 MR. STEWART: We have data for some 

years. In some claims, we have actual 

individual cycle data. And that I don't 

remember whether the later years have neutron 

data or not, but form 1015 in some of the 

claims has this information in it. 

 DR. ULSH: So what kind of a test 

are you looking for here? If we take a worker 

who is monitored and we have his gamma and his 
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neutron but we just say, "Well, let's just 

pretend that we don't have the neutron" and 

estimate it using this coworker model, does it 

over or under-predict the dose that we 

actually got? 

 Is that kind of what you're asking 

here? Well, half the time it will and half 

the time it won't. 

 MR. SHARFI: What's the value? 

He's a monitored worker. You can't treat him 

as a non-monitored worker, unmonitored worker, 

because he should have had dose because that's 

why he was monitored. 

 You can't put someone in a position 

where you would expect him not to have dose 

when he actually worked in a position that did 

have dose. 

 CHAIR BEACH: I just need to be 

able to validate what you're doing with the 

coworker model. 

 MR. SHARFI: We've done this 

before. This is not the first time where we 
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have seen a median zero dose. 

 DR. ULSH: Pretty much every other 

site where you have a coworker distribution. 

There might be a few where the median -- 

 MR. SHARFI: On the DOE site, 

especially in the AWEs, you see a lot of sites 

where you can find median doses were all below 

the limited detection. So then your coworker, 

really, your median coworker, would be all 

missed steps. 

 DR. ULSH: I think what you are 

asking us to do is test the coworker model 

against the data which was used to build the 

coworker model. 

 CHAIR BEACH: Actual data. 

 DR. ULSH: But you can't test the 

model against the data that was used to build 

the model. It doesn't tell you anything. 

 MEMBER ZIEMER: You are testing it 

against itself if you do that -- 

 DR. ULSH: It is a tautology. 

 MEMBER ZIEMER: Yes. 
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 MR. BUCHANAN: What I think it 

boils down to is, the end concept -- and I 

haven't seen the category-type data used 

before for coworker, but the end concept is, 

is it allowable to assign misdose to people 

that weren't badged because essentially that's 

what it boils down to. 

 MR. SHARFI: Theoretically you're 

not really assigning misdose to them. You're 

saying that misdose is about as bounding as 

you can get for the 50th percentile. And 

you're saying that I can't see anything below 

the limit of detection. And, therefore, 

really the coworker dose is something under 

misdose, but that's about as good as I can 

bound it. 

 DR. ULSH: It's an overestimate. 

 MR. SHARFI: Really, it is an 

overestimate because you don't have the 

numbers below the limit of detection. So, 

really, their real coworker dose is something 

under the limit of detection. All we can do 
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is since it's under the limit of detection, 

all we can do is give them misdose. 

 MR. FITZGERALD: You're purposely 

overestimating, really, is what you are doing. 

 That is as tight as we can get. 

 MR. SHARFI: That is as tight as 

you can get. 

 MR. FITZGERALD: I think that 

helps. 

 DR. ULSH: And that's the situation 

at every site because dosimeters at every site 

have a limited detection. 

 MR. BUCHANAN: At other sites have 

ended up with neutron coworker dose being 

assigned, mainly by misdose. 

 MR. STEWART: Well, all external 

coworker dose models include misdose, neutron 

or photon. 

 MR. BUCHANAN: But this is the 

first time I've seen it. And maybe this is 

standard practice, but at Rocky Flats and 

such, did we run into where the coworker 
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neutron model essentially boiled down to 

misdose? 

 DR. ULSH: Well, the problem with 

Rocky Flats was we were told that we couldn't 

estimate neutron dose as the basis of the 

Rocky Flats SEC. So that is probably not a 

good -- 

 MR. BUCHANAN: Well, whatever. 

Hanford is coworker neutron dose usually 

boiled down to just misdose. 

 MR. SHARFI: That would vary site 

by site. I mean, I can tell you I have seen 

gamma doses where the median for gamma dose 

was misdose in certain years alone. 

 So if you had neutron dose, I would 

imagine neutron dose probably would be, too, 

not for all years, but I have seen years where 

the 95th is the only thing that is really 

above the limit of detection. The median 

doses are all below the limit of detection. 

 So this isn't something we haven't 

seen before, probably more common. I would 
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imagine it would be more common with neutron 

because a lot of sites badged, over-badged, 

people that didn't require neutron dosimetry. 

 So you are going to see a lot more zeros. 

 DR. ULSH: And the LOD is higher. 

 MR. SHARFI: Yes. And the LOD is 

much higher. So if you are badging people on 

a weekly basis, you are probably never going 

to see enough exposure to hit those limit of 

detections. 

 Really, if they were to badge 

people quarterly, annually, the cumulative 

dose would kind of get enough to see above the 

limit of detection. So by badging people more 

frequently, you're really over-assigning dose 

by giving them misdose because you never 

really hit that cumulative dose enough to hit 

the limit of detection. 

 DR. ULSH: That is the last issue 

you were -- 

 MR. BUCHANAN: Yes. 

 DR. ULSH: If I could be 
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presumptive here, what I might -- 

 CHAIR BEACH: Go ahead. 

 DR. ULSH: What I might suggest is 

that during our conference call a few weeks 

back, there were some action items that came 

out of that. They're going to form the basis 

of a revision to the white paper. 

 I would say I've talked to Bob. 

And a realistic estimate is two, maybe three 

weeks for us to revise the white paper to 

address those points that were raised in the 

conference call. We will issue that white 

paper. 

 CHAIR BEACH: Now, does that need 

to go to DOE? 

 DR. ULSH: Yes. 

 CHAIR BEACH: Yes. So two to three 

weeks pretty -- 

 DR. ULSH: Yes. 

 CHAIR BEACH: So four to five 

weeks, I mean, really. 

 DR. ULSH: It's been pretty quick 
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lately, but I don't know that we can -- 

 CHAIR BEACH: Okay. 

 DR. ULSH: We will get it out as 

soon as we possibly can. 

 CHAIR BEACH: Okay. 

 DR. ULSH: And then if there are 

continuing points you want to raise, like, 

say, for instance, those that you raised today 

-- 

 CHAIR BEACH: And that's where I 

was going to get to, is NIOSH has agreed to 

update their white paper based on your 

technical call and the action items that came 

out of that. 

 They're also going to place on the 

O: drive the interview notes from the April 

meeting. First week of April I believe is 

what you said. 

 DR. ULSH: Yes. 

 CHAIR BEACH: So we should see 

those on the O: drive relatively soon, I am 

assuming. 
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 DR. ULSH: Right. 

 CHAIR BEACH: And then, SC&A, are 

you planning on a white paper or are you going 

to wait for the updated white paper before you 

add your comments? 

 MR. FITZGERALD: Well, one, I think 

we sent a draft set of interview notes -- not 

interview notes, meeting notes that would be 

helpful. I think it would be a help just to 

-- I think that was a pretty productive 

meeting just sort of to benchmark what you may 

see as changes in the white paper. That would 

be helpful for the Work Group to have. 

 In terms of what we would do, you 

know, we always speak of the issues. You sort 

of lose the forest. In this case, I thought 

we pretty much agreed with the factors that 

were being proposed and whatnot that would be 

reflected in these minutes. 

 So, really, I thought what we did 

today, just kind of highlight what would be 

the remaining questions or concerns. And I'm 
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not sure -- you know, in terms of a white 

paper, I think we've said just about what we 

can say at this stage. 

 I do agree that I don't have a 

ready answer, not to reopen this whole big, 

long discussion, but on the MCNP in terms of 

generalized model, I don't have a real good 

answer about how one would benchmark. Perhaps 

there is an avenue by which one could look at 

that issue. 

 I mean, I don't see a white paper 

saying that. 

 CHAIR BEACH: Right. 

 MR. FITZGERALD: But I think that 

would be the question at this point, whether 

there is any way to do that. 

 The only other thing I would add to 

that just so it's a complete record is in 

terms of picking the conservative 

representative sources, you mentioned three 

sources, did those include the and for the 

folks that worked at Mound, the special 
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operations and the SM, sort of military 

application activities? Because that would 

certainly be something I would be concerned 

about, making sure that in terms of sources 

that they are representative of all of the 

sources. 

 DR. ULSH: It would certainly 

include -- well, the group of workers in the 

top certainly included people who would have 

been involved in overseeing that kind of work. 

 I mean, we didn't talk explicitly about that. 

 MR. FITZGERALD: Right. It's 

classified, some of it. 

 DR. ULSH: Well, with good reason. 

 MR. FITZGERALD: Yes, right. And I 

just wanted to make sure that, you know, since 

that would have been a source, that that's -- 

 DR. ULSH: Well, we didn't talk 

about it specifically in those terms during 

the outreach meeting. The outreach meeting 

would have certainly included people who would 

have been familiar with that work. 
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 And we put the question out. Due 

to parameters that we pick, the scenarios that 

we pick represent what you have experienced? 

 And the answer was yes. It wasn't 

yes except for some situations. 

 MR. FITZGERALD: Right. 

 DR. ULSH: It was just yes. 

 MR. FITZGERALD: I think that's the 

nature of our comments. I mean, those are the 

comments we would have. You know, beyond what 

Ron mentioned on the coworker model, I think 

the question of applying the general model and 

upper bound, I think that is kind of one 

concern remaining for the overall framework. 

 So we would weight the white paper. 

 But certainly at this stage, I would see that 

one as being probably the one that, you know, 

takes some effort or some discussion. 

 CHAIR BEACH: Right. 

 DR. ULSH: Well, our white paper 

doesn't reflect what we talked about in the 

conference call. 
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 MR. FITZGERALD: Right. 

 DR. ULSH: They're probably not 

going to talk to the issues that we have 

discussed today. It would be much easier for 

us to respond appropriately if we had a more 

solid feel for what you are proposing, what 

kind of issues. 

 And we talked about it. If we had 

something in writing, it would help us get our 

arms around. These are exactly the points. 

 MR. FITZGERALD: Why don't we write 

-- a white paper sounds enormous. Why don't 

we write a memo through the Work Group and 

with a copy to you, obviously, to sort of 

articulate the two or three-part -- okay, 

two-part with a second to highlight what we 

have talked about in the table for the record 

in writing and go from there. 

 DR. ULSH: Will that come after our 

white papers? 

 CHAIR BEACH: That was my next 

question. After -- 
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 MR. FITZGERALD: I don't see why we 

have to have a white paper. White paper is 

based on the technical call. The worker will 

have to administer that call. And you can see 

where we are going with that. 

 This is a derivative from that 

conversation, but these are more getting down 

to sort of the end issues of SEC's importance. 

 I think that we can do in parallel, get to 

the worker and Brant and his team probably in 

the next week or two, couple of weeks, no more 

than that. 

 CHAIR BEACH: And if it's needed, 

we can always convene a conference call Work 

Group meeting over the phone to address some 

of those issues. 

 MR. FITZGERALD: I mean, we have 

winnowed down quite a bit. 

 CHAIR BEACH: Yes. 

 MR. FITZGERALD: I mean, I think 

these are more or less where the implications 

are applying this and trying to understand 
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whether it answers all the big questions or 

not. 

 MR. KATZ: So, Joe, when you go 

back and compile this memo, are you going to 

consider whether you have any suggestions 

about benchmarking? 

 MR. FITZGERALD: Like I said, I 

think that's -- you know, I agree it's not an 

easy question, but, you know, it's sort of a 

circuitous logic thing. If you don't have 

site data -- 

 MR. KATZ: Right. I understand. 

 MR. FITZGERALD: -- you're coming 

at this model. And then you kind of benchmark 

what you know is not there. So I talked to 

Ron. He mentioned one data point. 

 I'm just trying to -- I think it's 

one of these things, can you, in fact, do it 

or not? And what value would it be? I think 

that's something that we -- 

 MR. MORRIS: Let me suggest that 

there might be more value in thinking of it in 
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terms of sensitivity analysis. It's like, how 

different would things have to be before they 

change much? 

 MR. FITZGERALD: Right. 

 MR. MORRIS: And I think to some 

extent, we did that with the table that shows 

the different shielding thicknesses for each 

of the observer positions, the operator 

observer positions. 

 MR. FITZGERALD: Right. 

 MR. MORRIS: You can see that a 

six-inch water shielding is probably an 

overestimate of reality of the thickest shield 

that was there. 

 And so you can see that the changes 

start to plateau out. 

 MR. FITZGERALD: Yes. I think the 

thing that would help would be to actually 

take some representative Mound geometries. I 

mean, there's one, not to keep going back to 

that example, but this SM activity had a 

neutron source. What would you expect from 
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that? And why would you feel that this would, 

in fact -- 

 MR. MORRIS: Perhaps we should just 

invite you to say what other sensitivity 

parameters do you think we should test? I 

know we have tested water, for instance. 

 MR. MORRIS: Right. 

 MR. FITZGERALD: Are there other 

parameters that you think we ought to iterate 

on? 

 MR. MORRIS: Well, I think there is 

a lead-in question, which is, is there any way 

one can demonstrate an upper bound without 

going back to the site in terms of specific 

data? That is sort of a lead-in question. 

 The second thing is, if one cannot 

do that, can you use the approach you're 

talking about, which is achieve a degree of 

conservatism, which would give you confidence 

that even without being able to demonstrate an 

upper bound, you feel pretty conservative that 

the sources had been enveloped and are 
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representative and that kind of thing? 

 I think as a two-part thing, can 

one establish an upper bound based on actual 

site data? Right now I would say it looks 

awfully difficult for reasons we discussed. 

 The second thing is, then, if one 

defaults to a sensitivity analysis, saying 

let's make this as conservative as possible 

based on what we know and the people we've 

talked to, then I think we can explore. Are 

there ways to do that better than have been 

done? 

 I think we would take it as a 

two-part approach, saying let's address the 

first one, then address the second one as a 

fallback because, again, this is kind of a 

relatively new issue. I don't have the 

answers. 

 MEMBER ZIEMER: Joe this is Ziemer. 

 I think it makes sense to use the sensitivity 

analysis because that will at least give you 

some level of confidence as to whether or not 
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the bounding is reasonable. 

 MR. FITZGERALD: Well, there's no 

bounding. I mean, the dilemma is -- 

 MEMBER ZIEMER: Well, you're asking 

whether you can bound the doses. The 

sensitivity analysis will at least give you a 

feeling for whether your -- 

 MR. FITZGERALD: Yes, confidence. 

 MEMBER ZIEMER: -- you are close. 

 MR. FITZGERALD: Right, right. 

That's what I'm saying, that without the 

first, this would give us additional 

confidence -- 

 MEMBER ZIEMER: Right. 

 MR. FITZGERALD: -- on the 

conservatism. Right. 

 MEMBER ZIEMER: Right. 

 MR. FITZGERALD: We're in 

agreement. 

 MEMBER ZIEMER: And I am not sure 

what other approach NIOSH could take. I don't 

think we're talking about validating the model 
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per se. We're really talking about whether or 

not the model is giving you useful information 

for this situation. 

 MR. FITZGERALD: Agreed. 

 DR. ULSH: I still want to get into 

this bring me a rock situation. Let me try to 

kind of guess where you are headed and 

anticipate that. And then it turns out that 

is not really kind of what you are looking 

for. It would be helpful to us if you could 

give us a pretty clear picture on what you're 

looking for. And then we'll -- 

 MR. FITZGERALD: We may have a 

technical call if we get to a certain point 

where we'll discuss this. I used the word 

explore because, really, I think this is a 

difficult question. I think this is a lot 

worse than was done to push this in the right 

direction. 

 But I think validate is probably 

not the right word but just looking at the 

bounding nature of the confidence. And that 
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bounding nature is kind of where we are at. 

 MR. MORRIS: This will approach 

diminishing returns real quick on -- 

 MR. FITZGERALD: Yes. 

 MR. MORRIS: -- how much effort it 

takes to get a little bit more data. 

 CHAIR BEACH: Yes. Are there any 

other issues or action items that I may have 

missed that we need? And then if everybody is 

in agreement, we can move on to our next 

topic, which the question of the day is, do we 

go ahead and start with NIOSH's presentation 

and then take a break in the middle of it? 

 I know we have people joining us 

via phone. I hate to go to lunch so early. 

 MR. FITZGERALD: Why don't we check 

and see if they're on? 

 CHAIR BEACH: Okay. 

 MR. FITZGERALD: Is Joyce Lipsztein 

and Bill Leggett, are you on? Is Joyce 

Lipsztein or Bill Leggett on the phone from 

SC&A? 
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 DR. LIPSZTEIN: I'm on the phone. 

 CHAIR BEACH: Okay. 

 DR. LIPSZTEIN: I just saw an 

e-mail from Rich that the Work Group was 

behind schedule. So I can reply to him saying 

that. 

 MR. FITZGERALD: Yes. Josie is 

trying to determine how to schedule the 

discussion on PU-238. So you are very 

important for that. 

 Josie? 

 CHAIR BEACH: Well, I would propose 

that NIOSH present. I don't believe your 

presentation will take more than a half-hour 

or so. Okay. If NIOSH presents? And then we 

will see where we are on time. 

 MR. FITZGERALD: As long as Joyce 

-- 

 CHAIR BEACH: As long as Joyce is 

okay with that or we can just push on through. 

 MR. FITZGERALD: Is your schedule 

flexible, Joyce? 
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 DR. LIPSZTEIN: Yes. 

 MR. FITZGERALD: Okay. So we can. 

 If we have to break for lunch, you can come 

back? 

 DR. LIPSZTEIN: Yes. 

 MR. KATZ: Let me make sure. Liz 

and Tom LaBone, are you on the phone? 

 MS. BRACKETT: I'm here. 

 MR. LaBONE: I'm here, too. 

 MR. KATZ: Okay. They're both 

here. 

 CHAIR BEACH: And then before we go 

on, you had your hand up earlier. Did -- 

 MS. JESSEN: No. I was 

acknowledging. 

 CHAIR BEACH: Okay. Perfect. 

Okay. Sorry. I just want to make sure. 

 Okay. Then we'll let NIOSH get 

started. 

 DR. ULSH: All right. To give a 

brief history of this issue, this high-fired 

plutonium-238 issue, I think SC&A raised this 
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concern about high-fired plutonium-238 and its 

possible presence at Mound based, I guess, 

largely probably on the situation that was 

observed at Los Alamos, the Wing 9 incident. 

 Basically the Wing 9 incident 

involved the destruction of an RTG. This RTG 

had been subjected to some vibration tests. 

 By the way, RTG is radioisotope 

thermoelectric generator. So if you think 

space power; in other words, satellites, they 

put these devices on them to power them. And 

Mound was heavily involved in making these 

things. 

 So they took one apart at Los 

Alamos. And it resulted in some of what we 

considered unusual biokinetic behavior of this 

material. 

 There were some workers that were 

exposed. And the excretion patterns were not 

typical of what you might expect from 

plutonium-238. 

 I think that was kind of at least 
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one of the initiating events, for SC&A to ask 

that question about, might this be an issue 

with Mound. 

 There have been a number of 

iterations back and forth. We have issued, 

we, meaning NIOSH/ORAU, have issued, a white 

paper that proposes a model to handle this 

situation at Mound. SC&A has issued a 

response to that. 

 One of the issues I think continues 

to vex us. At least it is my observation that 

we say that we haven't seen the Los 

Alamos-type material at Mound. And SC&A 

presents examples, what they consider to be 

examples, of exactly that. And I think -- 

 MR. FITZGERALD: Not exactly that. 

 DR. ULSH: Not exactly. 

 MR. FITZGERALD: Right. 

 DR. ULSH: But I think we might be 

talking past each other on that one. What we 

mean when we say that we haven't seen this 

kind of behavior at Mound, I think we would 
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grant, certainly we would grant, that there is 

non-monotonic behavior, which means that if 

you were to measure the concentration of 

plutonium-238 in the urine following an 

intake, non-monotonic would mean that you see 

a level and then you test a little bit later 

and throughout time and it rises, initially 

rises, the concentration in urine rises and 

then levels off and tapers off. 

 We would certainly grant that you 

see that kind of behavior at Mound. But it's 

that initial -- degree to which it doesn't 

show up in the urine. 

 We don't see the same kind of 

behavior at Mound that is seen in the Los 

Alamos incident. So the material at Los 

Alamos was extremely insoluble initially. You 

almost saw nothing in the urine. I think we 

don't see that at Mound, but we do see this 

non-monotonic behavior. 

 So I think to some extent our two 

statements are talking -- 
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 MR. FITZGERALD: Well, because of 

the genesis of the issue, I think. 

 DR. ULSH: Yes. So we have issued 

our white paper. And SC&A has issued a 

response to that. At this point I think I 

would like to turn it over to Liz and/or Tom. 

 I'll let you guys flip for it and walk 

through some of the points that were raised. 

(***PART 4, 12:02:50***) 

 MS. BRACKETT: I will start with 

this. I would just like to expand a little on 

what Brant said in that I would think probably 

the initiator of this at Mound was that there 

was an incident at Mound, in particular, that 

involved several people that showed this 

non-monotonic behavior. It's just that there 

had been a paper published on the Los Alamos 

data with material that appeared as though it 

could be similar. 

 So we do have quite a few 

Mound-specific cases with data that we used to 

develop the model. It's not necessary to look 
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to Los Alamos. We could use Mound-specific 

data. 

 We can get more into the model 

itself later. And I will let Tom do that 

because he actually developed the model. But 

the white paper that SC&A wrote, they stated 

in a few different places that they agreed 

conceptually that a bounding model could be 

developed. But their issue was its 

application. And they questioned the ability 

to meet the sufficient accuracy test. 

 So from a standpoint of an SEC, 

then, the model development wouldn't be an 

issue if there is agreement that we could 

actually develop a model. 

 We feel that we have developed it, 

as Brant mentioned. And we based it on the 

Mound data. But the white paper then goes on 

to state; the SC&A white paper, that is, that 

a similar model is developed. 

 Several items need to be addressed. 

 And I will go through these here. We don't 
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feel that any of these issues are actually 

plutonium-238 or in some cases even 

Mound-specific. 

 They're somewhat generic issues 

that we deal with across the complex. And we 

addressed some of them yesterday in other 

conversations and other topics, such as the 

stable metal tritides. 

 The first item, they say that we 

need to explicitly state to whom the model 

will be applied. I believe we addressed this 

in the last Work Group meeting in October. 

 And we said that we would apply 

that to anyone who had the potential for 

intakes of plutonium-238. So that would be 

anybody who had a bioassay result indicating 

that they had or were indicated to be for 

plutonium-238 or someone who worked in an area 

where plutonium-238 was handled. 

 Again, this issue was somewhat 

discussed yesterday and when we were talking 

about how we determined what nuclide to apply 
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to an individual. 

 The second item was how we would 

recognize the occurrence of ceramic 

plutonium-238. We have stated that this would 

be just another material type that we would 

use to model the plutonium. 

 The SC&A document states that there 

were ample opportunities for exposure to the 

special absorption type and that, in fact, 

there were uptakes of it. 

 So, given that, if there exists a 

possibility that people would have been 

exposed to it, then we feel it's appropriate 

to just add it to the M and S types that we 

would normally assess for plutonium-238 and 

make this a third type that the dose 

reconstructor would evaluate. And they would 

select the one that gave the largest dose. 

 I believe there was some concern 

that this would result in too large of a dose 

and, therefore, not be a sufficient accuracy 

requirement. 
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 But this form, this type set, the 

model that we have developed, does not result 

in extremely large doses relative to the other 

material types. And, in fact, types M and S 

will give a larger dose in many situations. 

 The white paper that we developed 

goes through different scenarios of acute and 

chronic intakes and bioassay collected at 

varying times following intake. And this type 

does not always yield the largest dose to a 

particular ordinance. 

 The third issue was how we would 

handle results below the MDA. Well, we have a 

standard method for assessing results below 

the MDA. And we see no reason why this would 

be any different from any other material type. 

 And this is addressed in OTIB-0060. 

 It's called assumptions that the dose 

reconstructor uses in how the MDA or less than 

MDA results are handled. 

 The fourth item is, how do we 

differentiate bioassay results for 
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plutonium-238 versus other alpha-emitting 

radionuclides, including plutonium-239? 

 There was an extensive discussion 

yesterday about this subject regarding gross 

alpha results or results that were specific 

for plutonium-238. So I believe this was 

addressed at length. Then we can go back and 

revisit it if necessary, but I won't do that 

right now. 

 DR. ULSH: It was also addressed in 

the October Working Group meeting. It was 

raised and addressed there, too, as were a 

number of -- 

 MS. BRACKETT: Right. And the 

fifth and final issue on this list of items in 

the white paper is how we would use bioassay 

results to use a coworker model for 

plutonium-238 if solubility types of compounds 

are unknown. Again, this relates to some of 

the other issues. We would treat it as just a 

third solubility type for plutonium-238. 

 The coworker studies when we do 
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them, we come up with the set of bioassay 

results. And then those results are modeled 

with each possible material type for that 

given nuclide. 

 And all of them are presented in 

the coworker OTIB. And the dose reconstructor 

would run each of them for the particular case 

and assign the intakes that yield the largest 

dose for the particular situation. 

 I think one thing that I would like 

to point out is that there has been some 

discussion in this white paper about having to 

look at different scenarios because this 

material behaves differently. And while 

that's true it does behave differently, that 

is not a reason to change our default 

assumptions. 

 I think one issue is that when I 

personally think of applying these models, I 

am envisioning more of the people who have 

mostly no results greater than the MDA or at 

most one or two because that is the majority 
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of cases that we see, people who didn't have 

large potentials for intake or large intakes 

where they have positive results. And so we 

used the false assumptions to model those 

people given a lack of any information at all. 

 These are standard default 

assumptions that you would use, even outside 

of the project, for example, when you would 

assume an acute intake occurred. 

 If there were more positive results 

for a person, then certainly we would look at 

the individual's data. We wouldn't 

necessarily apply default assumptions. The 

dose reconstructor would have to look at the 

pattern of results for the person and make 

decisions based on that. 

 But also keep in mind that most 

cases don't require what we call a best 

estimate. Don Stewart discussed this 

yesterday. I forget what issue we were 

discussing. In many cases an under or an 

overestimate is sufficient for the requirement 
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for this program. 

 So you don't need to get into the 

fine detail of the specific pattern for the 

person. You can do the claim in an 

expeditious manner by making some assumptions 

without having to get into a long complicated 

process and doing the best estimate. 

 MR. KATZ: Liz, can I just 

interrupt you for a second? It's not such a 

bother in the room, but it might be for other 

people on the phone. Someone's phone is not 

on mute, and we have some music in the 

background. So somebody needs to mute their 

phone unless that is on your end, Liz. 

 MS. BRACKETT: It's not me. I can 

just barely hear it. 

 DR. ULSH: We've had enough TimeLife background music 

 MR. KATZ: It just went away. 

Thank you, somebody. Oh, no, it didn't. 

 MS. BRACKETT: Well, actually, that 

was the end of what I had to say. Those were 
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the five that had been stated in the documents 

that we would need to address. 

 MR. FITZGERALD: Can we do these in 

pieces? Joyce? 

 DR. LIPSZTEIN: Hello? 

 MR. FITZGERALD: Did you want to 

comment on Liz's remarks? 

 DR. LIPSZTEIN: I would like to. 

Actually, I would like to see it written all 

the amounts she is talking about. I think 

that differently from what was first 

presented, I think we think that there were 

many opportunities for exposure to this 

special absorption type of plutonium-238. And 

they were different from the ceramic plutonium 

from what we had seen from other data besides 

that accident that was examined by NIOSH/ORAU. 

 While we agree, we agree that 

probably there is a bounding model that can be 

developed for a special solubility type of 

plutonium, but we didn't see it yet. So we 

are waiting for one that will really be a 
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bounding one. 

 I really think the model is not an 

SEC question. I think that eventually it's 

going to be a bounding model for ceramic 

plutonium. But it has not yet come. So NIOSH 

has to show us that there is a bounding model. 

 With relation to what Liz is 

saying, I think it's very difficult to 

recognize the occurrence of ceramic plutonium 

exactly because of the delays which are 

patterned. So we don't know if your data may 

fit a chronic intake or may fit this special 

type of intake. 

 And especially when there is not 

much data or the results are below the 

detection limits, where you have very few 

sporadic positive data that are slightly above 

the detection levels, it is very difficult to 

differentiate between acute and chronic 

intakes. 

 So I think the scenarios that have 

to be compared are acute intake and granted 
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intakes using different types, it is very 

difficult to deal with all of those scenarios 

at the same time to find a bounding assumption 

to be made, especially exactly when results 

are very low and you have a lot of results 

below detection levels. 

 So I didn't see a reason to analyze 

exactly how NIOSH can handle these results. 

And I think that SC&A will be happy to see in 

the white paper an explanation of all of that 

so we can see that, really, it's feasible to 

do dose reconstruction with any model that 

NIOSH presents and a model that is bounded 

especially. 

 So the problems on building a 

correct model, I know that we have to 

interpret results in terms of this particular 

type of compound. It is not just one more 

because it is a question of how to interpret 

the data that you have as chronic, as acute, 

what gives a higher dose. So it's not as 

simple as is expressed here today. 
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 So I think I say I would like to 

give credit to NIOSH to develop and to answer 

our questions, but we would like to have it 

written so that we can analyze each point that 

NIOSH is making. 

 In summary, I don't think there is 

too much to discuss here in this meeting, but 

we would like to have our white paper answered 

by NIOSH in a written way how they are going 

to handle, how they are going to do, give 

examples on how so that we are satisfied that, 

really, it can be applied to Mound dose 

reconstruction and that it is feasible to do 

dose reconstruction. 

 CHAIR BEACH: Joyce, this is Josie. 

 I was going to ask NIOSH to respond in detail 

to the white paper. I'm hoping Brant is going 

to tell us about that now. 

 DR. ULSH: Actually, I was just 

going to ask if Jim Neton is on the line. 

 DR. NETON: Yes, I am. 

 DR. ULSH: Do you have any? I 
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mean, Joyce, when you say that you agree that 

there is a bounding model but you're still 

waiting to see it, we have presented our model 

in the white paper that you have responded to, 

you know. 

 DR. LIPSZTEIN: Yes. But we didn't 

agree it was a bounding model. 

 DR. ULSH: Well, it bounds 896 

cases at Mound. 

 DR. LIPSZTEIN: Yes, but it didn't 

bound other cases that apparently had also the 

same type of exposures. The problems is that 

at Mound, probably there were different types 

of, different forms of ceramic plutonium, not 

just one. So each incident means a different 

form of plutonium. 

 MR. FITZGERALD: Joyce? 

 DR. LIPSZTEIN: But I really think 

it's a question of doing modeling. 

 DR. NETON: Joyce, this is Jim 

Neton. 

 I think Tom LaBone actually looked 
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at all of the cases at Mound that he could 

find. He could find no evidence -- Tom is on 

the phone, he can speak to this -- that there 

was a ceramic form that was similar to the one 

that you're citing that existed at Los Alamos. 

 DR. LIPSZTEIN: No. I'm saying 

that we found some different forms of 

plutonium exposure and different than the ones 

that were presented as type L in the white 

paper. 

 DR. NETON: You mean the -- 

 DR. LIPSZTEIN: And the model that 

was presented as type L in the white paper 

didn't bound to two cases that we had a very 

big suspicion that were exposures to this kind 

of plutonium. 

 There are several urinary plots 

that we have presented that could look either 

to an exposure to this kind of plutonium or to 

a chronic intake. And we don't know. We 

don't think it's possible to distinguish 

between the both of them, -- 
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 DR. ULSH: All right. I think. 

 DR. LIPSZTEIN: -- those kinds. So 

they have to be a bounding type that is good 

for all possible forms of plutonium at Mound. 

 Until now we haven't seen that. 

 DR. ULSH: Okay. I think I know 

what you are talking about now, Joyce. Tom 

modeled the 900 or so cases. And I think in 

your response to our white paper you presented 

two particular cases where you felt our 

moderate model did not adequately account of 

those two cases, right? 

 DR. LIPSZTEIN: Yes. Right. 

Right. 

 DR. ULSH: Tom, do you want to 

speak to that? 

 MR. LaBONE: Yes. I sent you, 

Brant, a little note on the 18th of May that 

went through and modeled case 2 from the 1960 

incident. And I guess W-1 is the reference in 

the SC&A white paper if that's correct. 

 So, anyway, I went through and 
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modeled the two of those and compared them. 

And I sent that to you. And basically I think 

that those are fundamentally the same curves. 

 I don't know if you have that with 

you and you can show the people there what I 

am talking about or -- 

 DR. ULSH: No. I'm just looking 

for a high-level response, Tom. I think Josie 

is going to task us with responding to SC&A's 

white paper. And that level of detail would 

go in there. 

 DR. NETON: I think that we 

probably would choose to send that in writing 

over to SC&A and present that to them. And it 

might actually require a technical call 

because I think it would benefit from some 

one-on-one discussions of people looking at 

the same set of data in my mind. 

 DR. LIPSZTEIN: And the other 

thing, Jim, you said there was no exposure to 

the same form that people were exposed at Los 

Alamos. I don't know. I think that this has 
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to be demonstrated also. 

 Jim, I really think that the 

modeling question is not just a question of 

SC&A and NIOSH to discuss. And I think the 

most important thing is the NIOSH to -- I 

think we will come up with a bounding model 

because I think this is something that 

probably can be done. 

 I think that the important thing is 

that NIOSH answers all the other questions to 

see that even if we have a bounding model, if 

this is feasible to do the dose 

reconstruction. 

 MR. FITZGERALD: Joyce, this is 

Joe. 

 I think what we have been trying to 

do, actually, by coming up with these events 

and highlighting these events for NIOSH to 

model is to try to look at that upper bound. 

I mean, we did find two cases that we thought 

weren't covered in the original analysis that 

may, in fact, demonstrate that it wasn't 
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bounded by the model. 

 That was a lot of what was in the 

white paper that we just gave. I think what 

we heard from Tom LaBone is that they, in 

fact, have looked at this and feel, in fact, 

it is bounded. We haven't seen that, but I 

think that would go a long ways to moving this 

thing forward. 

 I think Jim's comment about, you 

know, we were actually proposing a technical 

call on this issue for obvious reasons. I 

still think it would benefit from having a 

technical call because there are a lot of ins 

and outs on this thing. 

 I think, really, at this stage we 

have gone a long ways. And I don't think 

there is any disagreement. Conceptually I 

think this can be modeled. 

 Now, we hesitated to say it's not 

an SEC issue because, you know, we wanted to 

test whether or not it is upper bounding. And 

I think that is part of what we have been 
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doing. 

 DR. LIPSZTEIN: Yes. 

 MR. FITZGERALD: There are some 

application issues as well. But I think maybe 

the next step is to go ahead and have that 

technical call with the information from Tom 

as a starting point and see where that takes 

us and then maybe get back to the Work Group 

as far as do we think we have crossed a t or 

not. 

 I mean, it has been moving forward. 

 I think part of this issue is just one of 

looking at this model and, as Joyce was 

pointing out, feeling confident that it is an 

upper bound model. 

 I think a lot of the testing that 

she is referring to we have done. So, really, 

I think we've moved this thing forward. 

 DR. ULSH: I would propose that in 

response to this white paper, we would prepare 

that, give it to you, give you some time to 

look at it. And then we will have a 
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conference call to discuss it. 

 MR. FITZGERALD: Okay. 

 CHAIR BEACH: I agree with that 

approach. What about the other Work Group 

members? 

 MEMBER CLAWSON: That's fine. 

 MEMBER SCHOFIELD: Sounds good to 

me. 

 MEMBER ZIEMER: That makes sense to 

me. 

 CHAIR BEACH: Okay. 

 MEMBER CLAWSON: We will get a copy 

of that white paper? 

 MR. FITZGERALD: Well, yes. It 

will be -- 

 MR. KATZ: And, Brant, you will let 

the Working Group know about the technical 

call, when it is going to be held? 

 DR. ULSH: Sure. 

 CHAIR BEACH: And to be fair, I 

will have to ask NIOSH how soon they think 

that they can get that out. 
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 DR. ULSH: Tom and Liz, you are on 

the hot seat here. 

 (Laughter.) 

 DR. ULSH: It sounded like someone 

hung up. 

 MR. KATZ: Tom or Liz, did you hear 

that question? 

 MS. BRACKETT: Yes. And the 

technical issues are few. You've got a lot of 

this already done. 

 MR. LaBONE: As far as about what 

the best parameters are for the model? 

 DR. ULSH: Well, Tom, I think what 

we are looking for here is you have SC&A's 

response to our white paper. And I would 

envision that we would prepare a response to 

that document, where we go through kind of on 

a point-by-point basis and examine the issues 

that SC&A has raised and give our take on it. 

 I think Liz is right. You have 

done a lot of the analytical work in terms of 

these two particular cases. We just have to 
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format it and then, of course, run it through 

the review cycles. 

 DR. NETON: I think that piece is 

probably sufficient to get the ball rolling. 

The other items, you know, Liz had gone 

through in my mind are fairly simple. 

 The only concern I have outstanding 

is Joyce's issue with chronic versus acute. 

It seems to be raising an issue that I thought 

we put to bed about five years ago. 

 So that may require some 

revisiting, but I don't know that we need to 

start rewriting that position. I mean, I 

think it's pretty clear what we're doing and 

why. 

 I think that to get the bounding 

nature of the model on the table, I think Tom 

has gotten his analyses done pretty much. We 

can just button that up and send it on. 

 And then we can reserve the other 

questions and discuss them point by point 

maybe on the call because I think most of 
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these in my mind, the rest of them, go away 

pretty rapidly. 

 DR. ULSH: Okay. So, Jim, you're 

suggesting that we just go ahead with what Tom 

has already proposed, have the call, and then 

we'll issue our response to SC&A's white 

paper. 

 DR. NETON: Well, I think so 

because I think the other issue that I'm 

hearing on the call to be addressed, from our 

perspective, I think we feel that they are 

very simple and can be answered very quickly. 

 I'm afraid if we put something 

together, we're going to say, "Well, that's 

not what we were talking about." I think 

we're missing maybe something here. 

 MR. FITZGERALD: What I would 

propose, then, is that -- it's kind of 

straightforward. I think what Joyce is asking 

for is maybe a chance to have that dialogue. 

Why not talk about those issues as part of the 

call? 
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 DR. NETON: Right. But, frankly, I 

don't see us putting together anything 

substantive other than the bounding nature of 

the model. The other issues are fairly 

simplistic in our minds. 

 MR. FITZGERALD: Well, then I think 

we would benefit from the call. And I would 

just keep the paper focused on it, too, the 

two cases. 

 DR. LIPSZTEIN: Yes. And when you 

do the bounding model, look at all of the 

plots that we have presented. We presented a 

lot of plots of variable that could be in 

intake plutonium-238 from this. It could 

either be a chronic intake or could be an 

acute intake involving this ceramic 

plutonium-238 compound. 

 And your bounding model has to 

respond to all those plots, not only for a 

case that was published in the literature. So 

it has to be a real bounding model that would 

bound either using chronic or using acute or 
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using everything. There must be something 

that -- 

 MR. LaBONE: I'm not sure. We 

might disagree there. We can talk about that 

more on our call. 

 DR. ULSH: Okay. So I will send 

over to you the little piece that Tom has 

prepared. Joe, how about you and I then will 

get together and discuss it when it makes 

sense to -- 

 MR. FITZGERALD: Yes, right. 

 CHAIR BEACH: That works for me. 

Is everybody in agreement to close or not to 

close but actually to -- 

 (Laughter.) 

 CHAIR BEACH: Sorry. Misspoke. I 

think it's lunchtime. 

 MR. KATZ: At the end of that, 

after the technical call, then there will be a 

memo or something from you to the Work Group 

about where things stand for the focus group. 

 CHAIR BEACH: Right. 
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 DR. NETON: Sounds good. 

 CHAIR BEACH: So let's take an hour 

lunch break. It's 12:30 now. And reconvene 

at 1:30. 

 DR. LIPSZTEIN: One question. Are 

we going to go back to plutonium or not? 

 CHAIR BEACH: I believe we are 

going to wait, Joyce. Unless you have 

something else you want to discuss, we are 

going to wait until the technical call. 

 DR. LIPSZTEIN: Okay. Thank you. 

 CHAIR BEACH: Okay. 

 DR. LIPSZTEIN: That's good for me. 

 CHAIR BEACH: Thank you, Joyce. 

 DR. LIPSZTEIN: Thank you. 

 CHAIR BEACH: Okay. Lunch. 

 MR. KATZ: Okay. So we'll be back 

on around 1:30. 

 CHAIR BEACH: Around. 

 MR. KATZ: Around 1:30. Thank you, 

everyone on the line. 

 (Whereupon, a luncheon recess was 
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taken at 12:29 p.m.) 
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 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 

 (1:36 p.m.) 

 MR. KATZ: This is the Mound 

Working Group of the Advisory Board of 

Radiation Worker Health. And we are just 

reconvening after a lunch break. Let me just 

check on the phone. 

 Dr. Ziemer, are you with us? 

 (No response.) 

 MR. KATZ: Let me check. Is there 

anyone on the line who can hear us? 

 DR. NETON: I can hear you, Ted. 

 MR. KATZ: Okay. Great, Jim. So 

Dr. Ziemer again? 

 (No response.) 

 MR. KATZ: Okay. How about Bob 

Presley? 

 (No response.) 

 MR. KATZ: He never made it 

yesterday. 

 CHAIR BEACH: Yes. 

 MR. KATZ: Okay. Okay, then. 
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 CHAIR BEACH: Okay. So we will go 

ahead and get started with our agenda item, 

"Radon issue number 2." And SC&A is going to 

take the lead on this. 

 MR. FITZGERALD: Well, I think I 

will get the background. And since NIOSH has 

been, I guess, the last round issued a white 

paper, maybe they can explain what the white 

paper says. And then we can go from there. 

 CHAIR BEACH: Sounds good. 

 MR. FITZGERALD: Okay. Really, as 

far as background, in the ER, there was a 

reference to, frankly, radon values in various 

buildings during Mound's history. 

 And the concern we expressed was a 

particular location, the SW building, where 

there essentially was one radon value that was 

highlighted. And that did not address the 

limited measurements before the events. 

 If you can imagine, this was a 

laboratory space that was constructed over 

where the old cave at the Mound was located. 
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And they had an individual who exhibited 

elevated lung counts. And they thought it 

might be Pu perhaps contamination. 

 They were concerned. They traced 

it back and I think established that there was 

a potential for exhalation of radon into his 

space. And they did a grab sample and found a 

fairly elevated flow of radon into a space. 

And his desk was right by the hole to which 

the radon was apparently coming through. 

 So they did at that point in time, 

one point in time, a grab sample, established 

radon flow. They did some monitoring in the 

tunnel underneath and pretty much established 

that this individual had elevated counts, 

probably due to that, and proceeded to come up 

with certain control measures, proposals, and 

effectively ran a vent to the underlying 

tunnel and were able to mitigate most of the 

radon. 

 So, really, after 1980, much of 

that issue went away. But before '80 and 
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after the SW complex was built, there's a 

period of time where clearly radon, elevated 

radon, levels may have been implicated. 

 So we had raised that issue from 

that standpoint and also noted that a 

confounding issue was there were other radon 

isotopes, actinon and thoron, that were 

apparently present in appreciable quantities 

based on this one sampling they did on the 

tunnel. 

 And our point was with only 

effectively the one sample that was taken, we 

didn't believe that was a reliable 

characterization of how much radon exposure; 

in fact, workers in this particular area, were 

being exposed to. That was, again, some time 

ago. 

 In response, NIOSH indicated it 

found quite a few records from an earlier 

period that would be relevant to the issue. 

And that was the core of the white paper that 

came back, a method to apply that data. 
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 I'll leave it to Brant to walk 

through the white paper or Don to walk through 

the white paper that we just received. 

 MR. STEWART: Sure. You know, 

first of all, we don't have radon data for 

every year. So what we are attempting to do 

is to bound this with the large measurements 

that we have found. 

 What we found was when they began 

the old cave operation, they had spread 

airborne contamination on an unprecedented 

scale. 

 In fact, that led to the early 

termination of that process, early remediation 

of the cave. So they had intended to use it 

for other activities but found that wasn't 

tenable given the large amounts of alpha 

contamination in the air. So radon was a 

continuing problem for this. 

 After they terminated the process 

in '54, they took some mitigation measurements 

to clean out the operation. And they kept 
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finding it wasn't all that cleanable. And 

they actually ended up four years later 

completely disassembling the facility and 

capping it with concrete. 

 That room went from being SW 1A to 

SW 19 at some point. It was a laboratory that 

was built on a cap over the old SW 1 building. 

 But being porous, of course, they still had a 

radon problem there. 

 The data we have are the values. 

Once they saw that they had this issue, they 

began keeping track of short-lived daughter 

products in the air. And we used those data, 

compared those, and simply just took the 

largest we could find during the era of 

operation and considered that a bounding dose. 

 We have one measurement that 

actually separates the concentrations into the 

reconstituents thoron, radon, and actinon. So 

we used that to go back and set up ratios, 

proportions year by year for those values. 

And we assigned working-level values based on 
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those calculations. 

 CHAIR BEACH: So, Don, those are 

based on one sample? 

 MR. STEWART: What we used was the 

largest measured value for short-lived 

daughter products in the air in the 

operational period of the old cave. And the 

old cave I think we picked that because we 

thought that that would surely be a bounding 

scenario. 

 The material that was used in the 

old cave was largely composed of thorium and 

had a very high radon emission rate. 

 MR. FITZGERALD: Don, you may be 

referring to the sample that broke out the 

different isotopes. 

 MR. STEWART: Yes, a single sample. 

 CHAIR BEACH: I thought you had 

mentioned that. I just wanted to make sure I 

was clear. 

 MR. STEWART: Yes. What they had 

was they had a -- there was a ventilation 
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tunnel underneath this room that stayed 

intact. 

 CHAIR BEACH: Right. 

 MR. STEWART: And that was kind of 

the worst case scenario as far as their 

measurements went, very, very high working 

levels in that room. 

 CHAIR BEACH: Right. 

 MR. STEWART: People weren't in 

there breathing that, but we thought that was 

the only data point that we had to establish 

the mix of radionuclides of the different 

isotopes of radon after that. 

 We just back-calculated it. We 

assigned working-level month dose values by 

year. Assignment, individuals were assigned 

to R and SW buildings. And that's the 

approach we took. This would be implemented 

in the TBD when the internal part of the TBD 

is revised. 

 Brant, did you have anything to add 

on that? 
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issue that Josie asked about that one sample 

that was used to split out the overall sort of 

daughter products and used that grab sample to 

split those out, I think that's a 

claimant-favorable approach, right? 

 MR. STEWART: Yes. 

 DR. ULSH: I mean, it would be a 

concern if we used one sample, as opposed to 

an approach that was not indicative. 

 MR. STEWART: Yes. I think 

claimant favorability arises from this is 

where the stuff is coming. This is closest to 

the emanation point that this could come. And 

those values are going to change drastically 

as the source is diluted in a room. The 

short-lived species are going to die off. 

 So that is a claimant-favorable -- 

 I should have studied up on this a little 

bit. It is claimant-favorable to assume those 

concentrations persist in the working 

environment; whereas, the bad actors are going 
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to drop out fairly rapidly compared with the 

radon-222 because they have a shorter 

half-life. 

 MR. FITZGERALD: Don, spatially I 

think you're quite correct. That is fairly 

close to where the workers would have been 

exposed to the relative concentrations of the 

isotopes. 

 MR. STEWART: Well, workers 

wouldn't, in fact, be exposed in this area 

because it's -- 

 MR. FITZGERALD: No, no. I'm just 

saying it's as close as you can get. That 

sample was taken -- 

 CHAIR BEACH: So you took the 

sample in an area but not the area the workers 

were actually working in, the tunnel? 

 MR. STEWART: Yes, the tunnel 

itself, where the -- 

 CHAIR BEACH: There are two 

separate areas. It was two separate areas. 

It wasn't actually where the work was being 
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performed? 

 MR. STEWART: Right. That's 

correct. 

 CHAIR BEACH: I'm sorry for 

interrupting, Joe. 

 MR. FITZGERALD: Well, no. My 

question -- I don't disagree with your point 

on that one, but we sort of got into this 

issue because we only had one sample prior to 

'80 that was actually the sampling of the 

concentration with the radon. 

 I was wondering, would there be any 

variability in your splits given the fact of 

just one sample? Do you think that would be 

likely the most favorable split? I don't 

know. 

 MR. STEWART: The most favorable 

split? 

 MR. FITZGERALD: Well, I'm just 

saying, is that a representative split? 

 MR. STEWART: We're not really in a 

position to say that it is or is not. I would 
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say it would tend more to claimant 

favorability that close to the emanation. 

 DR. ULSH: I would say the answer 

to your question is that no, it's not 

representative because it's closer to the 

emanation point than actual workers would be. 

 So what is the effect of that? 

Well, it's an overestimating assumption. So 

is it representative? No. It's 

overestimating. 

 CHAIR BEACH: Is it plausible? I 

mean, could the workers have actually gotten 

that dose? 

 DR. ULSH: It doesn't result in 

doses that are implausibly high. It is 

certainly overestimating. 

 MR. STEWART: Yes. Radon, what is 

high with radon? I've asks the question, that 

question, to this group before. What is high 

with radon? Is compensable high? 

 Because, you know, basically any 

time we apply these values to a lung cancer 
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claim, it's a compensable case based solely on 

radon. 

 DR. ULSH: But most lung cancer 

claims are already paid anyway. 

 MR. STEWART: See, what happens, 

radon, probably a causation calculation is 

very sensitive to the radon input. You could 

put in even a fraction of a working-level 

month and see a significant -- sorry -- 

fraction of the working level per year. 

 That's how you put it in and see a 

very significant increase of probability 

causation such that currently the value 

recommended in TBD is ten working levels per 

year. 

 And so you put that value in. So I 

said, "Okay. Where does it stop being 

compensable?" And the cases that I looked at 

were hypothetical runs, you know, one year of 

employment, no external dose, no other 

internal dose, only do radon dose. 

 In some cases working on an annual 
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working level of three is non-compensable 

based on a short latency or some other 

periods. But when you start to get up into 

that ten category, they're all compensable. 

So it's a pretty high number. 

 CHAIR BEACH: I guess I need to 

know a little bit more about the sample. How 

was it taken? Was the instrument calibrated? 

 Because you're basing a lot on one sample if 

I'm getting hits correct. 

 DR. ULSH: Well, not really. 

 CHAIR BEACH: Oh, really? 

 DR. ULSH: In terms of determining 

the concentration of the short-lived daughter 

products in air, we have -- Don, would you say 

thousands? 

 MR. STEWART: I'm sorry? 

 DR. ULSH: The short-lived daughter 

products in air, how many data comply, 

thousands? 

 MR. STEWART: Yes. We had a lot of 

data. I think there were about 2,000 lines of 
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data. 

 DR. ULSH: So, Josie, the only 

thing that we used that one sample for was, 

okay, we've got these short-lived daughter 

products, radon-222. Some of it is actinon. 

Some of it is thoron. How do you split out 

that gross measurement into those three 

subspecies? 

 The way that we have done it is we 

have taken the sample, a grab sample, that was 

closest to the source, which is going to be 

the most limiting case, the most 

claimant-favorable case split out of those 

three. 

 CHAIR BEACH: So did you have other 

samples that you could have chosen from or did 

you just have that -- 

 MR. STEWART: We have a single data 

set, just that one single -- 

 CHAIR BEACH: Just that one? Okay. 

 MR. STEWART: Well, it was during 

the detailed radon study that was conducted as 
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a result, as was said earlier, and the 

technician actually undertook to measure the 

proportions, we don't have any other data for 

that. At least that is the earliest data. 

 DR. ULSH: But the point is you 

could make other assumptions in terms of other 

splits of those three and it wouldn't make 

much difference. I think it could even be 

less, it would be a less claimant-favorable 

assumption. 

 So that would bring up the question 

of, well, is this implausibly high, which is 

what I think you asked earlier? 

 CHAIR BEACH: Yes. 

 MR. STEWART: And that is kind of a 

point that we have been making all along, that 

once you get to a certain point, it doesn't 

matter if it is 10 times higher or 100 times 

higher. But it's also a fact that there were 

some very high radon concentrations at Mound. 

 So the fact that we have got 

three-quarters of the lung cancers paid 
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anyway, I think the values that we're 

proposing were certainly based on radon values 

that were observed at Mound. 

 So in that sense, they're not 

implausible. However, it is certainly 

overestimating. At least that is our 

contention. Because the values that we have 

chosen were during the active operational 

phase when that project was going on. 

 Once that project ended, up until 

the time that they did the remediation that 

Joe described, our contention is that 

certainly the values were not higher than what 

we were observed during the operation phase. 

 MR. FITZGERALD: But just to recap, 

I mean, it sounds like what you are saying is 

that, even if this wasn't a single grab 

sample, this is almost like a sensitivity 

thing. You really couldn't adjust those 

isotopic, relative isotopic, activity levels 

proportionately that would give you much of a 

difference as far as the end result of dose. 
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 MR. STEWART: That's very likely. 

 DR. ULSH: If we did, it would be 

lower. How much lower I don't know. 

 MR. FITZGERALD: Because that was 

missing from the white paper. And I realize 

it was just that one grab sample. So I was 

wondering. You know, who knows what it might 

have been the next time that -- went down and 

sampled a tunnel. And whether it would have 

been a different result that would have 

affected the end result or not I don't know. 

 MR. STEWART: I would have liked a 

robust data sample to use to determine that. 

Then we could determine the sensitivity of the 

final doses to that. (***PART 5, 1:53:27***) 

 DR. ULSH: Well, it can't be any 

worse than all of one of the three species. 

 MR. FITZGERALD: The upper bound 

would be the -- right. It couldn't be any 

worse than all of that. 

 MR. STEWART: Yes, you could do 

that. 
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 MR. FITZGERALD: I'm just saying 

that if there were more than one sample, I 

guess that's better. But with just the one 

sample, which got us into this in the first 

place, -- 

 MR. STEWART: Sure. 

 MR. FITZGERALD: -- you're saying 

subjectively you don't think it's going to 

make much of a difference. 

 MR. STEWART: In terms of the 

proportion of compensable cases, it will make 

zero difference. 

 MR. FITZGERALD: Is that the 

benchmark? I think the benchmark is dose 

reconstructability. I mean, would it make a 

difference as far as giving you a different 

benchmark. 

 MR. STEWART: Well, you know, they 

said it was going to be large. 

 MR. FITZGERALD: Yes. 

 MR. STEWART: You know, measurement 

may have been 1980 was large. 
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 MR. FITZGERALD: Yes. 

 MR. STEWART: So given the 

sensitivity of lung cancer patients to radon 

inputs, it's inescapable that any radon dose 

that we assign is going to have very large -- 

 CHAIR BEACH: Well, what about the 

time period? When was the sample taken? Was 

it at '79 in the winter or are you using that 

data for what time period? 

 MR. STEWART: We are going back to 

1949 for the R building and 1952 for the SW 

building. And we are using that. We are 

projecting that measurement back that far. 

 However, we are decay correcting, 

the different parent radionuclides there. You 

know, these are thorium, actinium, and radium. 

 There have to be those things in the soil 

that are causing these things to emanate. 

 So the proportion of those is going 

to change over the years. So what we did is 

we took this sample here and said there is 

this much iridium, this much thorium, and this 
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much actinium. But in 1949, there would have 

been this much actinium, this much thorium, 

this much iridium, done that year by year and 

use that to balance the radon concentrations 

by changing the proportions of the daughter 

products, the radon, actinon, thorium. 

 DR. ULSH: Think of it like a pie 

chart with three different slices of pie. One 

slice is radon. One slice is actinon. One 

slice is thoron. You could change the size of 

the slices of pie, but the pie remains the 

same size. 

 CHAIR BEACH: I guess I wonder if 

you didn't have that one grab sample how you 

would assess that dose or if it would be 

possible. 

 MR. STEWART: At that point we 

would likely have assessed the most 

claimant-favorable. It wouldn't have been too 

far from what we -- 

 CHAIR BEACH: Right. 

 MR. FITZGERALD: Okay. Well, I 
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think that's sort of a question. But the 

larger question -- is Jim Neton on the phone? 

 DR. NETON: Yes, I am. 

 MR. FITZGERALD: Yes. Okay. This 

is going to be a familiar issue. And I was 

hoping you would be here. 

 I guess my question on this -- and 

I think we have sort of got to the point where 

we looked at all the data that was available 

and probably done what we can. 

 This is sort of reminiscent of sort 

of the surrogate data question. And sort of 

get your opinion because, really, there is one 

sample point for pre-1980 radon or SW-19. 

We've got that one value. We have a number of 

values after 1980. That's where this issue 

had come from for SW, the lab space. 

 And the approach that I think I am 

hearing and reading is that we are going to go 

back to the old cave in the '50s and pick 

radon concentrations which clearly are very 

high, meaning that there is no question during 
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the operations of the old cave. We had some 

very high radon concentrations. 

 But the exposures we're addressing 

in the '70s, say, or certainly the time frame 

we're talking about were post-D&D. The cave 

was bulldozed, well, D&D first, bulldozed over 

and dope over. So you had a number of things 

going on. 

 I guess in my opinion it's sort of 

like a surrogate data question, meaning the 

facility we're talking about, which is the 

office or lab space that started this whole 

thing with the individual involved and the 

exposure potentials to the occupants is not 

the same as this SW cave in 1954 and '55 that 

we're using radon values from. 

 I mean, they are certainly 

bounding, but I guess I think they're 

implausibly high. I just don't see how one 

would expect to see those same values. 

 I think certainly I am trying to 

follow this surrogate data debate. I think 
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the notion there was that there is a 

justification for applying data from different 

time periods and different configurations. I 

think we're sort of in that situation of 

having to justify applying values from 

different time periods, which are from a 

different source, which I think in our opinion 

may be implausibly high. 

 You know, we don't get into a 

situation often where we're saying, "Look, 

it's almost too extreme." In this case I just 

don't think the operations are the same and 

the values are going to be much higher than we 

would have expected the individual to be 

exposed to. 

 I just want to open that discussion 

up because I think that's really the one thing 

that comes to mind seeing this approach is 

that issue. What is your opinion on that? 

 DR. NETON: It's surrogate data not 

in the sense of from another site, but it is 

from another era. I honestly have not been 
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involved in this enough to put a position 

forth right now, but what I think I would like 

to do is go back and look at this in light of 

what IG-004 said, which is our paper on the 

use of surrogate data and what conditions need 

to be met. 

 I don't know that this is 

necessarily a bad approach or not. I mean, it 

sounds like there are very good reasons why it 

is a bounding value. 

 But I think you're right. I would 

like to take an opportunity to go back and 

look at it in light of the IG-004 of procedure 

or policy. 

 DR. ULSH: I would like to bring a 

little perspective into this. I mean, keep in 

mind that the radon concentrations at Mound 

were so high that they deemed that it was 

appropriate to remediate for it. And it 

doesn't take much radon to put these all into 

compensable range anyway. 

 DR. NETON: What I'm hearing is 
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that these concentrations are somewhere on the 

order of one to two hundred picocuries per 

liter. Is that sort of a rough guess? 

 MR. STEWART: Well, we ended up 

with them in working level months. And they 

range from 12.2 working level months to about 

.1. 

 DR. NETON: It's about an average 

of a working level in -- I mean, a high of a 

working level, which with 50 percent 

equilibrium could be as high as 200 picocuries 

per liter, a rough number. 

 MR. STEWART: Yes. 

 DR. NETON: The other thing is that 

it's a little bit misleading that small 

amounts of radon can produce a very high 

compensability rate. But I think, as I 

discussed at the last Board meeting, there's 

this time sense exposure, which is an 

exponential function in the risk model that 

rapidly decrements the risk after the exposure 

stops. 
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 So, for example, if a person quit 

working in '58 and developed lung cancer in 

'98, they would have to have very, very high 

concentrations of radon to get a PC close to 

50 percent. 

 I am not sure those arguments 

really should come into play here anyway, but 

-- 

 MR. FITZGERALD: Yes. I think the 

IG-004 is the one I am kind of concerned 

about. I have an excerpt because I wanted to 

make sure I -- because, again, I haven't been 

as close to that as you and some others have 

been. 

 The piece I thought applied from 

IG-004 was when a bounding exposure model is 

developed using surrogate data, the upper 

bound must be plausible. That is, it must be 

realistically possible given the nature of 

operations at the facility being modeled and 

other relevant factors. 

 While it's not possible to provide 
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fixed criteria for evaluating plausibility, 

certain reasonableness tests can be applied. 

And there are a number of examples. 

 Just in this case, since we don't 

really have any useable data, we do have some 

-- we have one sample, I just don't think the 

conditions inside of the cave at the worst 

point in its history is the same as what this 

individual might have been exposed to in, God 

forbid, the office or lab space in SW. I just 

think those are two different conditions. So 

that is certainly the concern that we have on 

that. 

 DR. NETON: I guess I need to know 

a little bit more about the other sample that 

we didn't use. I mean, it sounds to me like 

there were a lot of samples and we chose its 

high value for some reason. 

 MR. FITZGERALD: Those are the 

samples in '54 and '55. In the contemporary 

with the exposure period of concern, there was 

one sample that was taken. And that is what 
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got this whole thing started because -- 

 DR. NETON: I see. I see. Yes. 

 MR. FITZGERALD: And I think Brant 

is -- 

 DR. NETON: We'll have to go back 

and look. And I have no idea where it talks 

about similar operations and going back. I 

really think that we owe it to the working 

group an analysis of why this is an 

appropriate value to use in light of what 

IG-004 says. I think that should probably be 

an action item for us if it isn't already. 

 MR. KATZ: Jim, if you don't mind, 

let me just add a remark, too, because it has 

come up in a number of statements now about 

plausibility. And I understand where you just 

noted it with respect to IG-004 plausibility 

level. 

 But, just to go back to sort of the 

foundation document, the SEC rule, what it 

says about plausibility is that your 

circumstances have to be plausible. And 
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surely your doses are reflective of the 

circumstances. 

 Some of the conditions of 

circumstances that you model have to be 

plausible. So there is a distinction there 

versus arguing that the dose level itself is 

plausible, it's like you have to consider 

circumstances that are plausible. I mean, 

that relates to what Joe said, certainly. 

 DR. NETON: I think they kind of go 

hand in hand. I mean, if circumstances are 

plausible, they have reasonable doses that are 

bounding. 

 You know, what I think IG-004 was 

trying to get at, you know, you don't produce 

doses that are lethal or could cause scar 

damage to the lungs or something like that, 

you know. 

 The idea is you just can't put a 

bounding number up there to say it's bounding 

and it had to be some ridiculously large value 

that it requires some deterministic effects. 
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 You are absolutely right. The SEC 

regulation speaks of it in different terms. 

So, anyway, I think that we should go back and 

look at this in light of that and just see 

what we think. 

 I am not suggesting that it is an 

inappropriate value, but I think it would be 

good for us to go back and document why it is 

indeed appropriate. 

 CHAIR BEACH: And then no question 

on using it to break out the three different 

pie charts, as Brant explained. That is not a 

question that's on one single sample. 

 MR. FITZGERALD: Well, I think what 

I hear is that there is a way to demonstrate 

that that is bounding, but it hasn't been -- 

you know, I haven't seen anything, really, on 

that other than the fact that that is what it 

is based on. 

 So it might be useful just to get 

something that explains why that would -- not 

just simply -- I don't think there are any 
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disagreements. It's worker claimant-favorable 

because it is taken downstream close to the 

room. I think the question is, is one 

confident the split is claimant-favorable 

itself. 

 DR. NETON: I guess my question was 

-- and I don't want to lengthen this too much 

longer, but if there was thoron in that room 

as well, are we finding these working levels 

of radon-222? Is that what I am hearing? 

 MR. STEWART: We're assigning 

working levels of each. 

 DR. NETON: Oh, of each? Okay. So 

we do have working levels of thoron and radon. 

 MR. STEWART: And actinon because 

actinium-227 is in the soil. So each one of 

those will be included. 

 MR. FITZGERALD: Yes. The 

difficulty that we have is that in 1979, one 

series of samples is taken in the workplace 

and one grab sample taken from the tunnel. 

And the sample from the tunnel is where the 
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analysis is split is taken from. And it's 

just one sample. 

 DR. NETON: Okay. I need to know 

more, I guess. I'm ignorant on this at this 

point. So I will shut up. 

 CHAIR BEACH: Okay. So for the 

work group, so NIOSH is going to re-look at 

this issue. Jim Neton wants to review some 

document. 

 MR. FITZGERALD: Just those two 

issues. 

 CHAIR BEACH: Just those two 

issues. And then you will get -- how will you 

report that back to the work group? In a 

memo? Well, we say white paper. We know 

that's a huge -- I mean, we can get at it with 

this document. So just a memo, I guess. 

 MEMBER CLAWSON: There should be 

some document so that we have something to 

come back to. 

 CHAIR BEACH: Well, it is kind of 

interesting work on that. Thank you very 
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much, Ted. The plausible issue is very 

important and how you explain that kind of 

circumstance. 

 Okay. So anything else? Any other 

questions, comments on radon? 

 Okay. Then if we're all ready. So 

the next item on the agenda is exposure to 

non-rad buildings. And that would be issue 

17. NIOSH is going to take that one. 

 DR. ULSH: This issue was presented 

under matrix issue 17, which I believe dealt 

with external dose badging policies more or 

less. 

 The first I think written piece 

that we have on this is SC&A's report, I 

think, written by Bob Alvarez, where he looked 

at four buildings, D, S, M, 48 -- 

 MR. FITZGERALD: I think maybe we 

should step back. 

 DR. ULSH: Oh, go ahead. 

 MR. FITZGERALD: I think we got 

into the discussion, additional discussion on 
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badges most exposed. And I think there was 

agreement that there isn't any documentation 

or documented badging policy to point to. 

There's no way to really resolve the history 

in that regard. 

 I think it was proposed -- and I 

just can't remember by whom -- that maybe 

there is a way to test the hypothesis by 

looking at ostensibly -- and I've got to throw 

that in -- ostensibly non-radiological 

buildings and see if, in fact, they may have 

been frequented by non-badge personnel. And I 

think that's where that came from because we 

were on the badging issue because then we 

shifted into this sort of test. 

 DR. ULSH: And so I think the point 

of SC&A's white paper -- and I know you will 

correct me if I am wrong -- was here are four 

buildings which SC&A has said had been 

classified as non-rad buildings, where there 

was -- those aren't my special effects, I 

promise -- these four buildings, which SC&A 
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classified as non-rad buildings. And then 

they presented examples of radioactive 

material in these buildings. 

 And so I think the question was 

then, well, if these are non-rad buildings, 

did that mean that people weren't required to 

be badged but, in fact, there was radioactive 

material in them? 

 And so that might be an example of 

a situation where people could have been 

exposed externally but not badged. 

 MR. FITZGERALD: Yes. And this 

became a little bit of a point of contention. 

 These were ostensibly non-rad buildings 

because, again, they were identified to us as 

four candidate buildings that were seen as 

"non-radiological" but may have had 

radiological materials, which sounds like a 

non sequitur. But in a sense, that was the 

way to perhaps test the hypothesis. 

 DR. ULSH: So it was never really 

clear to me what the source of those 
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 MR. FITZGERALD: Yes. That's what 

I'm saying. It's a little fuzzy on who 

recommended those four buildings. They were 

recommended as four that we should look at. 

And we did. 

 DR. ULSH: There was D, S, M, 89 -- 

 MR. FITZGERALD: Yes. I have it 

here. 

 DR. ULSH: And 40 something. 

 CHAIR BEACH: Forty-eight. 

 MR. FITZGERALD: Yes, 48 I think. 

 CHAIR BEACH: And M. It was M, 89, 

DS. 

 MR. FITZGERALD: Right. 

Forty-eight, 89, M and DS. 

 DR. ULSH: Okay. So kind of the 

thrust of our response to that paper was to 

question the basis of SC&A's belief that these 

were, in fact, non-rad buildings and will, 

therefore, present an example of the kind of 

situation that we're talking about here 
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because I think we presented a number of 

documents where they were not considered 

non-rad buildings. 

 And our main point was that there 

was no evidence that there were workers in 

these buildings who were not badged. And, 

furthermore, the citation of some 

contamination levels I think largely during 

the D&D era but there might be others as well 

do not in and of themselves demonstrate a 

significant exposure potential. 

 Bryce Rich, are you on the line? 

 MR. RICH: I am. 

 DR. ULSH: Okay. How about I turn 

it over to you, then, to fill in any blanks I 

might have left or -- 

 MR. RICH: Sure. The definition of 

-- well, first of all, there are a number of 

perceptions that were introduced, I think, as 

a result of this paper. And I would like to 

just, if I could, briefly go down to those 

perceptions and in so doing perhaps address 
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what we have come up with. 

 The SC&A white paper suggested that 

the work group may want to direct the exposure 

pathway primarily between T and DS be examined 

and also if there is sufficiency of data to 

support dose reconstruction for all four, for 

89 and the DS. 

 We have done due diligence. Leo 

Faust and myself are both permanently 

cross-eyed from reviewing records. And our 

white paper, of course, presents our response. 

 We used primarily the references 

that were listed in the SC&A white paper and 

address from our response from a different 

basis. There is a myriad of additional 

references dealing with previous operational 

history and all that we could give you a good 

if you like it, but they are voluminous 

dealing with things like operational safety 

reports, routine safety reports, going back to 

'49 and forward. 

 First, if we could just talk about 
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some of the misconceptions? First of all, the 

rad/non-rad perception would perhaps lead to a 

perception that there wasn't any radioactive 

materials in the facilities and consequently 

radiation safety concern or attention. 

 This coupled with the fact that a 

series of pre-D&D surveys -- and I would like 

to talk about the difference in the type of 

surveys -- indicated that there was legacy 

contamination in all of these buildings. 

 And that would lead to through the 

misperception that there weren't any 

radiological protection programs to protect 

workers that were in these facilities during 

the period of time when the contamination was 

introduced. 

 I would just like to say that 

non-rad was not a facility descriptor. They 

used the terms "high hazard," "low hazard," 

and "clean." And all of the records of their 

routine reports referred to those designators 

and listed a number of swipes and a number of 
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other evidence of radiological protection 

programs in force in those categories. 

 It is interesting to note that the 

clean facilities had less than ten percent of 

the number of sites that were listed for high 

hazard, which it expects about a site a little 

bit less than that. 

 Another general perception that I 

would like to visit applies directly to Mound, 

I think. And that is that I think there may 

be a perception -- and I pick up on that from 

various comments made by the Board and others 

-- that the early years' radiation protection 

programs were remedial or they were certainly 

not advanced and the results more suspect in 

later programs. 

 I would like to just indicate that 

my own personal/professional health physics 

experience at the applied level goes back to 

January of 1953, when I first entered the 

health physics programs. 

 During that period of time, there 
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were a lot of programs, facilities being 

introduced for the first time. These were R&D 

programs, the introduction of one-of-a-kind 

operations, and a variety of things. 

 I was really impressed, even during 

those very early days, that the radiation 

protection programs were mature in their 

comprehensiveness. For example, at Idaho, 

they had master's-level health physicists who 

were actually doing the field survey work and 

fundamentally because of the fact that in a 

lot of cases, the processes and the facilities 

were the first out of the box. 

 And so I see evidence of that at 

Mound also. As you look at the reports, the 

confinement barrier monitoring surface 

contamination, personnel contamination, air 

monitoring, radiation detection, plus the fact 

that, even in those early days, they had what 

we call CAMS, or radiation air monitoring 

systems, that were alarming constant air 

monitors. 
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 They wouldn't be placed in all 

areas but primarily at the confinement barrier 

for process materials so that you get an 

immediate alert that a confinement barrier has 

been breached. 

 Those instruments were in place at 

the very front end of the radiation protection 

experience. And we see evidence of that as we 

review the records at Mound. 

 In the early years, Mound, the 

programs are facility-specific, rather than 

site-wide-specific. In other words, the 

radiation protection programs, although 

covering the comprehensive nature of the 

control programs were different, the selecting 

program and how they handled the materials was 

different facility to facility. 

 They all covered the same 

operational concepts that in the early '80s 

primarily due to change in federal regulation 

where it specified radiation work permit basis 

-- these operational philosophies, by the way, 
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covered the same thing that would be covered 

under a radiation work permit. 

 Control of the radiological hazards 

was by key. The facilities, the laboratories 

were locked. And only those that had 

knowledge and responsibility for controls had 

keys to the facility. This is both from a 

security standpoint and a radiological 

protection basis. The procedures for control 

of those, each of these facilities, was posted 

in a unique posting at the top of the doors. 

 A little bit later on they changed 

to a radiation work permit, in which it was 

then they didn't have to retrain the 

technicians when they sent them to different 

facilities. They had a consistent radiation 

work permit across the site. 

 But the point is that from a 

perception ratio, there was a comprehensive 

program in place right at the start of the 

program in '49, about as far back as we had 

gone. 
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 Perhaps one of the other 

conceptions or perceptions that is listed 

deals with the location of the DS facility on 

top of the T building, which is one of the 

first process facilities built in 1948, an 

unusual facility in the fact that it -- the 

description is on page 9 of our response. It 

had 17-foot-thick heavy, reinforced walls, 

8-foot ceilings, effectively a 10-foot floor, 

built below ground, no windows. It was a 

self-enclosed. It was designed to be 

bombproof, 2,000-pound penetrating bombs. 

 About 20 years later, then DS was 

built using the T building as a construction 

base. It didn't share any of the utilities. 

And certainly there was no interaction. 

 In order to get from T building to 

DS building, you had to go outside and then up 

a berm and then back in the DS facility. We 

note also that in the SC&A paper that the 

listing of the total effluent in the hundred 

of thousands of curies per year discharge 
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through the stacks, that's to indicate that 

there is a lot of effluent, T building being 

one of the primary facilities. 

 DS was no more susceptible to that 

effluent than any other facility on site 

because the discharge went up a 200-foot 

stack. And those numbers were monitored with 

a stack monitor. There was no interchange 

between T and DS. 

 Maybe we could talk a little bit 

about the type of surveys. It is standard 

complex-wide standard operating procedure that 

you have routine surveys to check for 

contamination or a breakdown in the 

confinement barriers of the process, where 

your process material is involved. 

 All of these facilities, so-called 

non-rad facilities, which we would say would 

be low-hazard or clean facilities, were on a 

routine survey list. Those surveys were 

probably infrequent because of any material 

that was taken into DS, for example, would be 
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under the guidance and support by radiation 

safety, but routine surveys were done. 

 But routine surveys were only to 

look for major issues; for example, survey the 

doorknobs and traffic patterns. And if there 

is anything detected, then, of course, you 

would return to look for what the source was. 

 That program was in place. It's in 

the routine reports through the years. The 

pre-D&D survey, which was done in the late 

'90s and early 2000, serves as the basis of 

concern, I think, to indicate -- well, even 

indicate perhaps we ought to cover building 

48, for example. 

 There's precious little 

contamination from the legacy standpoint 

that's even there. But even its history would 

indicate that it was a facility that was known 

to handle radiological material. 

 The only one in the past that was 

designed to develop radiological material was 

building 89. That was built in 1985. It was 
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primarily designed to store detonators that 

would be analyzed in building 48. That one, 

there are a couple of pieces of equipment that 

had fixed contamination. 

 N building was actually a process 

building. It was a machine shop and housed 

all of the crafts people. All of us people 

would have, even in the early days -- uniform 

badging for everybody only occurred in the -- 

well, about 1987, I think. 

 But even before then, people who 

were involved in process buildings or had 

access, need for access, to the process 

buildings were given personal dosimeters. And 

it was on a select basis at that time. 

 So I think, just even from the D&D, 

pre-D&D, survey, we see no evidence of the 

fact that there was any material there that 

would cause any degree of concern. 

 DS is the main one, primarily from 

the standpoint that there were a lot of 

surveys, a lot of contamination indicated. 
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And the listing of one of the sites, which 

indicated tritium of a couple of million 

disintegrations per minute on the slide, if 

you look at it carefully, that was in a green 

storage cabinet. 

 The history of DS, we find that it 

was known to be a facility in which 

radiological materials were handled. And, as 

I indicated, this handling was done under the 

control of not only the management. 

 This was a metrology laboratory. 

The people involved in this would actually go 

to the operating area, then also bring 

equipment or tools or whatever back to the DS 

facility. The standard practice was to 

involve health physics. 

 We interviewed a long-term health 

and safety manager. He said in the '80s they 

had become a little bit lax in actually 

calling for support, I think primarily because 

when you do a lot of operations and you don't 

have any problems, you get a little bit 
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casual. And that was fixed. 

 And so the standard operating 

procedure was reinforced, again. We have 

every evidence of the fact that any 

contamination that was handled or brought into 

the facility was not being processed. They 

weren't doing process work with unconfined 

radiological material. It was primarily 

pieces of equipment like electronic equipment 

that would be in for calibration or tools or 

other equipment. 

 Standard operating procedure is 

also as you released these tools, pieces of 

equipment for evaluation, that they be 

surveyed at the points in the operating 

facilities. 

 As they did that, of course, DOE 

operating procedures did allow for fixed 

contamination or particularly in electronic 

equipment and other things of the kind, where 

it's almost physically impossible to clean all 

of the circuit boards and everything else 
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completely, could be handled under direct 

control, which was done. 

 So in all of the operating reports, 

we see that DS was known as a facility that 

handled radiological materials with the 

admonition that before it was D&D, it would 

require a thorough survey. 

 The D&D survey if you are familiar 

with MARSSIM, the survey that converted some 

survey system that means putting off a 

facility -- I don't think the survey, the 

pre-D&D survey, was done to that degree, but 

it was done with the same purpose of assuring 

that there was no radioactive material in 

these facilities that was to be D&Ded that 

would result in the release of debris to the 

public or to landfill that had significant or 

detectable, for that matter, contamination. 

 MEMBER CLAWSON: Hey, Bryce? 

 MR. RICH: Yes? 

 MEMBER CLAWSON: This is Brad. 

Didn't they release some equipment that they 
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had to recall back, though? 

 MR. RICH: I'm sure that that's 

true. 

 MEMBER CLAWSON: Part of the thing 

is, too, you know, we've got a lot of 

employees that were not really badged. And 

this even went on in the earlier years. They 

kind of badged per facility, didn't they? 

 MR. RICH: They badged by facility, 

fundamentally by the operation. 

 MEMBER CLAWSON: And I understand 

this. Part of where this came from was from 

electricians and so forth, some other people 

that were designed that basically were not 

assigned to a facility per se but they were 

actually ending up going in the back way of 

the buildings pulling wires and so forth like 

that, but they weren't badged, I think is 

where a little bit of this comes from. 

 MR. RICH: Normally the operating 

procedure would be that anybody that had 

access to radiological controlled areas would 
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be controlled to the procedures that were 

established. 

 MEMBER CLAWSON: And I understand 

that part of where this came from was that in 

the back of some of the radiological 

buildings, they weren't really set up for it, 

but that's where a lot of the power and so 

forth came into. 

 And this is where some of the 

electricians and so forth came into that. And 

this is what kind of raised some of this 

question because you're right. 

 Per procedure going into the -- I 

guess what I would say, the front end of the 

building, they were badged and -- 

 MR. RICH: And it's a controlled 

facility, Brad. Pardon me. As you went into 

areas where the material was being processed, 

in a glove box or whatever it might be, then 

there were strict control procedures, 

including dressing out and procedures for 

surveying it as you crossed the boundary. 
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 MEMBER CLAWSON: Okay. 

 MR. RICH: Now, there were, of 

course, their vent lines and cable chases and 

others that became contaminated. The process 

was that any time you worked on the facility, 

that it had to be surveyed before it was 

released for work. 

 I can't say that there weren't 

specific examples when those procedures were 

not followed exactly. 

 MEMBER CLAWSON: Right. And I 

understand that. And this is part of the 

reason why there were modifications later on 

to part of the working procedures, because 

they actually pulled cables from inside of the 

facility out, which brought the contamination 

out through that, the cables. And that's part 

of where the issue came and arose from. 

 MR. RICH: Obviously that is a 

mistake. That resulted in an incident and 

brought a lot of attention that caused the 

operating procedures to be changed in a 
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facility, which people do things that were 

contrary to good sense. 

 But normally those incidents occur 

and draw a lot of attention. So it's not a 

matter of not being able to be aware of and 

need for additional bioassay analysis and what 

have you. 

 DR. ULSH: Okay. But, Bryce, I 

think the question Brad or the situation that 

Brad is bringing up kind of gets to the heart 

of the issue. 

 And that is it seems that in SC&A's 

white paper, they are equating exposure to 

various levels of contamination, some of which 

on paper appear to be quite eye-popping, there 

are big numbers, equates to the need for 

external dosimetry. 

 And I think is a misconception. 

That's one of those misconceptions -- 

 MR. RICH: I think that's been 

modified, Brad, to include internal, as I 

recall from reading the comments on the Board 
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before. And we looked at it from that 

standpoint, the need for external. 

 And, frankly, there is no need for 

external based on what was handled in any of 

these facilities except for whether they were 

doing machining of uranium and other things. 

 In those cases, they would be 

badged appropriately. However, what was 

handled in DS was, you know, there was 

functionally no external exposure. 

 And then, of course, the real issue 

that appeared to be of concern was the fact 

that the contamination surveys, which were the 

exhaustive, extensive surveys prior to D&D of 

the facility, are to document the conditions 

in each one of these facilities prior to D&D. 

 Those showed a number of, 30 to 40 percent 

of, the rooms had detectable spots of 

contamination in D and S. 

 And so we proceeded from that 

standpoint. What you mentioned, Brad, is 

exactly right. If you look at the -- and we 
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have these addressed on page 6 and others. 

The smearable contaminations, even from a 

potential internal intake standpoint, are 

functionally of little concern. The smears 

themselves would indicate that. 

 CHAIR BEACH: Bryce? 

 MR. RICH: If you look at the 

smears also, there is one smear that was 2 

times 106. And that was tritium. 

 CHAIR BEACH: Bryce, this is Josie, 

the work group chair. 

 MR. RICH: Yes? 

 CHAIR BEACH: If you don't mind, I 

would like to interrupt you. And I have a 

question for SC&A based on the white paper 

that was presented to the Work Group in April. 

 Have you had a chance to review? 

Do we need to take some time to review that 

white paper? 

 MR. FITZGERALD: No, no. We've had 

a chance. I want to give Kathy the one chance 

to comment. And then I think we can maybe 
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wrap this as far as where we are coming from. 

 CHAIR BEACH: Okay. So, Bryce, if 

you don't mind, I am going to let SC&A speak 

for a moment. 

 MR. RICH: Sure. 

 MS. ROBERTSON-DeMERS: I just had 

one problem with the NIOSH response. 

 CHAIR BEACH: Can you speak up a 

little? 

 MR. RICH: Yes. I can't hear you. 

 MS. ROBERTSON-DeMERS: I had one 

problem with the NIOSH response I just wanted 

to point out. Perhaps it just needs to be 

removed. That was a statement made that after 

1987, all personnel who entered the control 

area wore personal dosimeters and were subject 

to routine internal monitoring. 

 CHAIR BEACH: Was that in the ER or 

-- 

 MS. ROBERTSON-DeMERS: That is on 

page 6. 

 CHAIR BEACH: Page 6 of the -- 
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 MS. ROBERTSON-DeMERS: Of the white 

paper. 

 CHAIR BEACH: -- of the white 

paper. Okay. Thank you. 

 MS. ROBERTSON-DeMERS: And then 

indicated internal monitoring occurred at 

least once per year, urine sampling. And to 

test that thesis, I took the 25 people that I 

had looked at in the completeness section and 

looked to see if they had at least one 

bioassay for 1988 to the end of their 

employment for tritium and plutonium. And 

that was not the case. So I think that that 

statement is incorrect. 

 CHAIR BEACH: Is that in the 

response, Kathy, or was that in the initial -- 

 MR. RICH: That's probably in the 

response. 

 CHAIR BEACH: Okay. We're just 

trying to find it. 

 DR. ULSH: Is it our white paper? 

 MR. RICH: Yes. 
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 DR. ULSH: Our response, Kathy? 

 MS. ROBERTSON-DeMERS: Yes, page 6. 

 DR. ULSH: I see prior to 1987, 

those workers were housed in the S building. 

Is that the correct response, top of the page? 

 MS. ROBERTSON-DeMERS: Second 

paragraph, after 1987, all personnel who 

entered the control area. 

 CHAIR BEACH: Okay. We're having 

trouble finding it. 

 DR. ULSH: Oh, wait, wait, wait. 

Here it is. After 1987, all personnel who 

entered the control area wore personal 

dosimeters and were subject to routine 

internal monitoring at least one per year, 

urine sampling. That's the sentence. 

 I think I see where your concern is 

coming from. Certainly -- well, maybe. 

Certainly in the D&D era, there was a criteria 

that we expected to have a 100-millirem per 

year exposure. And if you were less than 

that, it wasn't required that you were 
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monitored. 

 MR. RICH: I think the term is 

subject to -- 

 MS. ROBERTSON-DeMERS: I guess what 

I'm saying is that is an incorrect statement 

that people were internally monitored once per 

year. And it needs to be revised. 

 DR. ULSH: All right. We'll take a 

look. 

 MR. RICH: We can certainly take a 

look at that. 

 MS. ROBERTSON-DeMERS: And that was 

it. 

 DR. ULSH: Okay. 

 MR. RICH: That came as a response 

to an interview response. 

 MR. FITZGERALD: Okay. Well, you 

know, we'll be the first to admit that it was 

an imperfect test of a difficult question, 

which was, can you demonstrate that the most 

highly exposed individuals, in fact, badge? 

 So, Brant, you're not going crazy. 
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 Actually, it was an external badging issue. 

It morphed. As we got into these buildings, 

it kind of morphed into, well, they also 

bioassay. But it began with the badging 

question. 

 We interviewed over 40 workers. 

And I think I said this the last time we 

touched on this issue. And one of them 

challenged the supposition that, in fact, they 

were not badged going into controlled areas. 

 I think there was a statement, 

though, in the ER that -- (***PART 6, 

2:44:26***) 

 CHAIR BEACH: Page 71, I think it 

is. 

 MR. FITZGERALD: Okay. I won't 

dispute that. The concern is that because it 

kind of asserted that because workers were 

required to wear dosimeters in 

radiation-controlled areas, it is certain, 

quote/unquote, that those receiving the 

highest dose were monitored, we wanted to find 
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somebody to substantiate that. 

 I think this came up as a 

possibility. And I think we accept certainly 

NIOSH's very detailed findings on this. And I 

don't dispute that these ostensibly rad 

buildings had certain histories, as Bryce has 

gone through. That doesn't really give us any 

relief on the question. 

 So I think we are back where we 

were saying that since we have not, frankly, 

heard any statements or testimonials, as we 

have at other sites, I might add, that there 

was some discrepancy on wearing badges and 

everything. I don't see going any further on 

this issue. 

 CHAIR BEACH: Well, I'm just 

thinking out loud. I haven't even thought -- 

as I was listening to this, I was thinking 

about the D&D time period. If we close this 

item, is there any concern for the later years 

that we haven't just yet addressed? 

 MR. FITZGERALD: I can't say we 
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haven't studied D&D per se. 

 CHAIR BEACH: Right. 

 MR. FITZGERALD: But based on the 

experience at Rocky Flats, where they actually 

modified the dosimetry program and selectively 

badged and bioassayed certain workers as a 

function of what they were exposed to, I would 

reserve judgment on that. I am kind of 

talking about the operating period, which 

pretty clearly they had a centralized control 

system that was fairly rigorous. 

 MR. RICH: Josie, if I could just 

make a statement, too? 

 CHAIR BEACH: Sure. 

 MR. RICH: Our review fundamentally 

covered the operational history of the 

buildings in question. It did not cover the 

D&D. 

 CHAIR BEACH: Okay. That's all I 

needed to know. Thank you. 

 So at this point, SC&A, you are 

okay with this? 
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 MR. FITZGERALD: Yes. I mean, like 

I said, we thought this would be a good way to 

test the hypothesis. It turned out not to be 

a good way to test it. But, you know, that's 

the way it goes. 

 And I think at this stage, without 

any other corroborating information that 

suggests otherwise, I mean, I think we can 

accept certainly the statement there. 

 And we were concerned that the 

statement didn't seem to have corroboration. 

And when we went and looked for documentation, 

it turned out there wasn't a badging policy 

that we could find in writing. 

 CHAIR BEACH: Right, right. 

 MR. FITZGERALD: And so one step 

led to another. And that's how we came down 

this road. 

 CHAIR BEACH: Right. 

 MR. FITZGERALD: It's so hard to 

remember all of that, but that's how we came 

down the road. 
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 So I think, rather than expend more 

resources trying to find something on this, I 

think if I would make a statement, I think we 

would have heard more concerns expressed by 

the workers. 

 CHAIR BEACH: The workers. 

 MR. FITZGERALD: They would 

probably want to do more, but I think the 

workers uniformly felt they were badged in 

controlled areas. So I think we have 

confidence based on that at least. 

 CHAIR BEACH: And I guess since 

Kathy brought up initially, are you 

comfortable with that as well, Kathy? 

 MS. ROBERTSON-DeMERS: I would just 

like to see that statement that everyone was 

monitored annually internally taken out of 

here. 

 MR. CHEW: Or modified. 

 MS. ROBERTSON-DeMERS: Or modified, 

yes. 

 MR. CHEW: Modified, yes. 
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 CHAIR BEACH: So, then, NIOSH 

agrees with that. 

 From my standpoint, based on the 

fact that we have closed the other issue early 

yesterday on the non-badging issue, I think 

it's clear that there isn't an issue with 

badging based on what the workers have said in 

their interviews. 

 I have no problem closing this 

issue, but I do want to hear from other Work 

Group members on their thoughts or -- 

 MEMBER CLAWSON: I just found it -- 

and this is just from the interviews that we 

have there because there was no question about 

going into the controlled areas and so forth. 

 As a matter of fact, a lot of the maintenance 

people made comments that they had different 

badges for different areas for them to be able 

to go in there. 

 But what they stated to me was that 

the problem got into when they were working 
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outside the buildings, where they shouldn't 

have been when they needed to be. And then 

tieing into these old buildings is where they 

got into some of the issues where they weren't 

badged. 

 I don't know how to follow up with 

that, but I just want to go on record as 

saying that there were times where this came 

from with the electricians and so forth 

because they were basically on the other side 

of the walls of the production. So they felt 

okay. We're not violating any RWPs or 

anything else like that or digging enough 

lines. 

 All of a sudden, they got into 

stuff that they did not expect. 

 DR. ULSH: I think you have to ask 

what happened in situations like this. Let's 

envision a scenario, Brad, where a worker was 

going into an ostensibly clean area and then 

it's discovered later, after he worked on a 

particular piece of equipment, that that 
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equipment was contaminated. So what would you 

do? 

 MEMBER CLAWSON: Well, part of the 

thing came out that this side of the building 

was actually considered non-radiological and 

so forth and they had put in a whole new power 

bank that had been in there. 

 And then they've basically come to 

find out as they were doing the QA inspection 

of these power banks that were in there, 

they've come to find out that it was actually 

an almost high radiation area. And they never 

knew that until they got into it. 

 Then they went and put the -- 

 DR. ULSH: When you say high 

radiation area, I assume you're talking about 

contamination levels? 

 MEMBER CLAWSON: Well, yes, 

contamination I guess, radiation. 

 CHAIR BEACH: So high 

contamination. 

 MEMBER CLAWSON: High contamination 
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area or whatever because I guess what it was 

was the pipes and so forth that went over into 

the operational area and so forth. 

 DR. ULSH: Yes. 

 MEMBER CLAWSON: And what they 

ended up doing was actually pulling a lot of 

that wire back in. It was all laid out there. 

 And they got into issues on that. 

 My question to them was, well, what 

happened after that? And he said there was 

just a change to the RWP and the outside of 

the door, they put up a potential internal 

contamination area. 

 DR. ULSH: I think you would be 

concerned in a situation like that. If a 

worker went into an area where there wasn't 

supposed to be any contamination and it turns 

out that there was, if they didn't follow up 

and go make that worker give a bioassay or if 

he wasn't on a routine bioassay program, I 

think that might be cause for concern. 

 MEMBER CLAWSON: Right. 
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 DR. ULSH: But I haven't seen 

evidence that that is the case. I mean, 

certainly there were situations where, like 

you described, they went into a situation 

where there was unexpected contamination. 

 But what you would hope to see I 

think that we did see would be in a situation 

like that, the worker would be required to 

give bioassay or he was already on a routine 

bioassay program. 

 MEMBER CLAWSON: Right. And -- 

 MR. RICH: Brant, that is true that 

these were -- it's par of the discovery 

process. And incidents happened like that. 

And that would trigger, that did trigger, 

special sampling and whatever to make sure 

that the workers and properly clothed were 

covered by evaluation of what intake would 

have occurred. 

 MR. CHEW: Brad, I think I would 

need to make a comment. And you know this for 

the record here. When you talk about the 
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contamination, especially with things at 

Mound, you know, a badge, a TLD badge, does 

not pick that up. 

 MEMBER CLAWSON: Right. 

 MR. CHEW: When you talk about high 

radiation, it could be contamination level. 

But that does not necessarily mean that the 

badging is going to pick that up. 

 MEMBER CLAWSON: Right. 

 MR. CHEW: I just wanted to be sure 

you know that. 

 MEMBER CLAWSON: Yes. I appreciate 

that. You know, I just wanted to make sure 

that we addressed that because we had heard it 

a few times. But I just don't want to close 

the door. 

 MR. FITZGERALD: Well, that's the 

down side to badging just for the 

rad-controlled areas because if there was 

anything that arose outside of those areas, 

there is potential there. Again, I think -- 

 MEMBER CLAWSON: And I think in the 
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 MR. CHEW: You need to know what it 

is. 

 MR. FITZGERALD: Yes. 

 MEMBER CLAWSON: -- when they broke 

into those lines and stuff, I think there was 

a line that was broken loose out in the ground 

there that -- 

 MR. FITZGERALD: This gets into the 

events. 

 MEMBER CLAWSON: Yes. That gets 

into the events. 

 MR. FITZGERALD: What is the 

protocol for responding to those events I 

think is what -- 

 MEMBER CLAWSON: Okay. Well, I 

just -- 

 MR. FITZGERALD: But I think D&D, 

though, is a different set of conditions 

because I think the monitoring system changed. 

 And I think that would be a different story 

that would need to be looked at. 
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 MEMBER CLAWSON: Okay. 

 CHAIR BEACH: And I only brought 

that up because I didn't want to lose anything 

in that era. But it sounds like we're okay. 

 With the lack of policies, I know 

SC&A has looked for policies on the non-rad 

buildings, haven't found anything. So I guess 

I couldn't see anything more further that we 

could ask SC&A to do. 

 And with no complaints from workers 

on the badging issue, I feel like we just are 

at a point where we should close this item 

unless anybody feels strongly or has an idea 

of anything else that we could look at. 

 MEMBER CLAWSON: No, I don't. 

 CHAIR BEACH: Yes. Okay. So we 

will consider -- 

 MR. MORRIS: You -- 

 CHAIR BEACH: Go ahead, Bob. 

 MR. MORRIS: Considering that it 

takes a rewrite of the DOE classification 

review to get it changed to a document or not 
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-- 

 DR. ULSH: This wouldn't require 

DOE review. It's not a separate issue. 

 MR. MORRIS: You've got it in the 

transcript. I was wondering if we really 

needed to revise this last document. 

 DR. ULSH: It's a matter of -- 

 CHAIR BEACH: No. I think just 

deleting the sentence should be a simple 

matter. Thank you for pointing that out, but 

Kathy did ask. And NIOSH did agree to delete 

that sentence. Okay. 

 So are we okay, then? 

 (No response.) 

 CHAIR BEACH: Great. So let's 

consider that closed. And I think it's time 

for a break. So let's take 15 minutes. 

Resume at, let's say, ten after. Is that 

okay? 

 (Whereupon, the above-entitled 

matter went off the record at 2:55 p.m. and 

resumed at 3:06 p.m.) 
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 CHAIR BEACH: We're going to jump 

to the place in the D&D years. And basically 

the reason I put that on the agenda is I just 

had a question to pose to NIOSH on what we 

were going to do with the D&D years, where we 

were going with that or when we would see 

something on those years. 

 DR. ULSH: Okay. Well, just to do 

a very brief recap, when we presented our 

evaluation, our ER, at the Las Vegas meeting, 

-- I don't even remember when it was now -- 

beginning of 2008, I think -- 

 CHAIR BEACH: Yes. 

 DR. ULSH: -- we reserved -- I 

mean, we recommended a class, '49 to '59, and 

then no class after that, but we reserved 

judgment on the D&D years. And the basis for 

that reservation was the Price-Anderson Act 

violations. 

 CHAIR BEACH: I'm not clear on 

that, what that means. 

 DR. ULSH: The Price-Anderson Act 
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violations, in and of themselves, the 

Price-Anderson Act violation doesn't say 

necessarily anything about the ability to 

reconstruct dose. But in this situation, they 

dealt with adequacy of the Mound bioassay 

program. 

 So we wanted to take some time to 

evaluate whether or not those Price-Anderson 

Act violations impacted our ability to 

reconstruct internal dose at Mound. 

 I think, Josie, that we have 

captured this item at other places in the 

matrix under, I think it is, issue 21, the 

Price-Anderson Act. 

 CHAIR BEACH: Right. 

 DR. ULSH: So I don't necessarily 

think that we have a separate matrix item to 

deal with the D&D years unless there are other 

questions beyond that. But that is -- 

 MEMBER CLAWSON: I've got one thing 

because just looking at the work history on 

this, after this Price-Anderson Act incident 
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happened, isn't this when Dade Moeller and 

Associates came in and did -- 

 CHAIR BEACH: MJW. 

 MEMBER CLAWSON: MJW. Oh, okay. 

MJW came in and did a -- I think it was 

because of that that they came in, wasn't it? 

 I'm just trying -- 

 DR. ULSH: I think that's accurate. 

 MEMBER CLAWSON: Okay. They did a 

-- 

 MS. ROBERTSON-DeMERS: It was from 

a lawsuit. 

 DR. ULSH: Oh, that's right. It 

was because of a lawsuit, Brad, that it was 

filed. 

 MEMBER CLAWSON: Okay. That's when 

they came in, and they went through some of 

the dose -- 

 MS. ROBERTSON-DeMERS: The internal 

dosing. 

 DR. ULSH: That's right. 

 MR. FITZGERALD: I guess the 
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context of that issue for us was more the 

change in regime that's experienced under D&D, 

whether that poses any implication for dose 

reconstruction. 

 We didn't see it as a 

Price-Anderson Act, per se. And, actually, I 

think we ere more focused on the other issue 

that dealt with the Price-Anderson 

implications, as treating that issue. 

 So, to some extent, I think we have 

a different frame of reference for what that 

issue, D&D, would be. This was also from the 

experience with Rocky Flats. 

 You know, it just was two different 

regimes. And we went through some effort to 

figure out whether that change had to be 

changed for dose reconstruction. 

 You recall we went through this 

question of lack of terminal bioassays, 

transient workers, how they would badge, and 

all of this. And I think we wanted to address 

that, but it was being held open -- not open 
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but deferred. So we couldn't really engage 

that issue. 

 Now, going back to the matrix, I 

think that is the way it was described in our 

issue matrix. But that would be the question 

I would think I would raise on that. 

 DR. ULSH: Matrix somewhere? 

 MR. FITZGERALD: Yes. And, of 

course, I -- 

 MS. ROBERTSON-DeMERS: I have a 

copy of it, but I -- 

 MR. FITZGERALD: I have a copy, but 

I think -- 

 MEMBER CLAWSON: Their whole rad 

practices changed after the production era, 

didn't it? 

 MS. ROBERTSON-DeMERS: Yes. Their 

whole rad practices changed as a result of 

that lawsuit. 

 MEMBER CLAWSON: Well, I thought 

after the lawsuit a lot of things went on, but 

then through the D&D era, they had a lot of 
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changes to who was being bioassayed and 

everything else like that if I remember 

directly some of the issues. 

 MS. ROBERTSON-DeMERS: Well, I'm 

not just talking from the standpoint of 

bioassay. I'm talking from field monitoring 

-- 

 MEMBER CLAWSON: Right. 

 MS. ROBERTSON-DeMERS: -- and 

upgrades to field monitoring. 

 CHAIR BEACH: It's on number 10. 

It's issue 10. Sorry. I just realized that. 

 MR. FITZGERALD: Yes. This is our 

statement I am reading from, actually your 

response from last July: Evidence exists that 

worker exposure residual contamination to 

sources generated during the life of the 

plant, particularly during D&D activities, in 

which bioassay is not performed. Lapel 

sampling and DAC-hour tracking were used as a 

primary means of tracking internal dose, 

rather than routine bioassay. 
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 In fact, Mound went to Rocky Flats 

to model their system after Rocky. I recall 

that coming up. 

 Samplers who were assigned randomly 

to a group of D&D workers might not have 

represented the most exposed individual. You 

know, pretty much the same issues I think we 

addressed at Rocky would be the same issues we 

would want to be clear on here. 

 SC&A agrees that issues like these 

associated with internal exposure during D&D 

activities warrant special consideration in 

the context of the SEC. 

 Actually, there was NIOSH response. 

 And it says, the SC&A statement above does 

not accurately represent NIOSH's concerns with 

the bioassay program in the D&D era. 

 And then you went on to talk about 

Price-Anderson. 

 DR. ULSH: You see that problem 

persists. 

 MR. FITZGERALD: It says, NIOSH has 
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never expressed concerns about lapel sampling 

and worker exposure, residual contamination, 

and all the other points we raised. And that 

is kind of where it ends. 

 DR. ULSH: So our NIOSH response as 

of July 5th, 2008 is kind of the last action 

on this issue? 

 CHAIR BEACH: It is exactly the 

last action. 

 DR. ULSH: Okay. 

 CHAIR BEACH: That's why I raised 

it today. 

 DR. ULSH: I see. 

 CHAIR BEACH: We need to know what 

is happening and where we are going with that. 

 DR. ULSH: There is more you would 

like to see, in addition to our response? 

 CHAIR BEACH: Well, Joe, you said 

SC&A is kind of not touching it because -- 

 MR. FITZGERALD: Well it was being 

reserved for further research. And that was 

-- 
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 MS. ROBERTSON-DeMERS: We're in the 

process of investigation. 

 MR. FITZGERALD: We are doing more 

investigation. Now, the context is 

Price-Anderson, but the issues that we are 

concerned about are pretty much the same 

issues we are concerned about in Rocky as far 

as the change in regime and going to lapel 

sampling and whether or not that provided 

sufficient basis for estimating doses on those 

deeds. 

 And that is kind of where we left 

it in pursuing it from that point. And I 

think that it has been held open as a pending 

item. So I don't know. That's one reason I 

guess we are -- 

 DR. ULSH: So is there an action 

item that you would like to see? 

 CHAIR BEACH: Well, either SC&A 

tackles it or you guys unless you're saying 

that is your response and that is what you are 

sticking by or if you want to review it and 
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get back to us. I mean, I know it is -- 

 MEMBER CLAWSON: I thought we had 

kind of separated those out and didn't want to 

deal with the D&D era right now, we wanted to 

get the earlier years as kind of a focus 

field. We kind of separated it into two 

issues. I think I got the feeling -- it's my 

personal opinion, but that's why we kind of 

just held that one back and separated it in 

two eras. 

 MR. FITZGERALD: Well, I think the 

first time we broached it, the feedback from 

NIOSH was they wanted to do further 

investigation. 

 Now, I think it became clear by 

last year the context was Price-Anderson, but 

it was one of these we don't want to have this 

liberation in the meantime because we are 

doing further investigation. 

 Because we had enough issues to 

keep us occupied, we put it aside. But the 

question at this stage is, you resolved the 
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Price-Anderson questions through various 

means, but we still have what was originally 

identified as some of these monitoring issues 

in the D&D period that we need to address. 

 Now, we could. You know, basically 

we could pull something together since at this 

stage we know based on the July response that 

you don't agree there were any implications 

for dose reconstruction from the D&D period. 

That kind of puts the monkey on our back to 

show why there might be. 

 One thing we could do is just put 

this on a fast track and say, there is no 

Price-Anderson implication from D&D, but there 

may be some other implications. We need to 

get back to the Work Group and offer any 

illumination on that particular issue. 

 But the issues are very similar to 

Rocky. And I think we ended up, although 

there were some concerns at the end whether we 

might be able to resolve those issues, we did 

end up resolving them. 
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 There was a stark difference in the 

regime. 

 CHAIR BEACH: But I think we owe it 

to the claimants to answer that question in 

that time period. So I am hoping -- I mean, I 

am fine with SC&A jumping up and writing 

something up or if you want to -- 

 DR. ULSH: No. That's fine. 

 CHAIR BEACH: Because my note said, 

Placeholder Under Investigation. 

 MR. FITZGERALD: Yes. 

 DR. ULSH: We might have had this 

conflated with the Price-Anderson Act. I 

would like to take you up on your offer, Joe. 

 MR. FITZGERALD: Yes. We'll take 

responsibility to -- I think we have the 

documentation. We just need to clean this up, 

be very specific about what -- if we -- we 

haven't really finished any kind of analysis. 

 If we feel there are issues that 

might bear on dose reconstruction of an SEC 

significance, then we need to bring that back 
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to you and to NIOSH and go from there. 

 CHAIR BEACH: That's sounds great. 

 MR. KATZ: Just a clarification. 

Did the petitioner raise the D&D period as an 

issue? 

 CHAIR BEACH: I don't know if it 

came from that. It included the D&D. 

 MR. KATZ: The period did? 

 CHAIR BEACH: Yes. It goes to 

2007, yes. 

 MEMBER CLAWSON: Because the 

petitioners raised concern of the change of 

rad practices and everything else like that, 

moving equipment and so forth. All of a 

sudden, buildings that were -- 

 CHAIR BEACH: So I'm assuming that 

you're going to develop a white paper on that. 

 And I'm not asking for a time because I don't 

want -- 

 MR. FITZGERALD: What's good for 

the goose is good for the gander. 

 We've heard the last two days that 
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NIOSH is going to. You know, we will 

certainly do that. And we are not starting 

from scratch. 

 CHAIR BEACH: Yes. 

 MR. FITZGERALD: I mean, I think we 

did gain a lot of experience with the same 

issue at Rocky. So I think we can know what 

we are looking for and will be able to come 

back with something. 

 I know you are going to ask me next 

about DOE's review and six or seven -- 

 CHAIR BEACH: And I was going to 

say, Joe, that I wasn't going to put you on 

the -- 

 MR. FITZGERALD: I feel obliged to 

offer to get it out. But we will certainly 

move as fast as we can to do that. 

 CHAIR BEACH: Yes. 

 MR. FITZGERALD: And probably we 

will try to get back by the end of July 

depending on DOE. 

 CHAIR BEACH: And I think, 
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actually, at the end of the meeting today, 

most of the action items are on NIOSH again. 

So we are kind of back to the incline on your 

side of the table. 

 Okay. That's great. 

 MEMBER CLAWSON: Joe, do you think 

this would be where you could kind of give us 

an update on this one maybe because we are out 

here where Mound is at? I was just wondering 

if -- 

 MR. FITZGERALD: I'm going to try 

to do what we can. I mean, I think because 

there are more recent records, this is a much 

different issue than trying to dig back into 

the '40s and '50s. We're talking '90s. 

 So the question is being able to 

understand the system. And we did read some 

-- make sure we understand the system fully 

and look at the implications, similar to what 

we saw with Rocky because they did actually 

model the Mound program. They did track Rocky 

to see what they were doing in D&D and brought 
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that back. So there should be a lot of 

similarities. 

 MS. ROBERTSON-DeMERS: Actually, 

the Rocky Flats regime moved to rad. 

 MR. FITZGERALD: Okay. 

 MEMBER CLAWSON: I was just 

wondering where we were up there modeling the 

Mound area so that some of the issues -- 

 MR. FITZGERALD: The biggest issue 

came down to because they went from badging 

every single worker who was the most exposed 

individual in the DOE Act to, in fact, be 

monitored or not to try to answer that 

question. 

 And we got into an issue of 

terminal bioassays at Rocky. A lot of 

transient workers left the site, never got any 

final bioassays. And how would you address 

that? We did address it through the process 

of Rocky. 

 So, you know, I think we have a 

pretty good running start on those issues. 
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 MEMBER ZIEMER: Josie, I have a 

question on this. 

 CHAIR BEACH: Okay. Hi, Paul. 

 MEMBER ZIEMER: This is kind of my 

standard question. It's not completely clear 

to me what SC&A will do versus what NIOSH is 

doing, but I want to make sure that SC&A is 

not undergoing an investigation that should 

rightly be done by NIOSH. 

 Can you clarify, Joe, a little 

more? I didn't get the full implication of 

what it is SC&A is going to do next. 

 MR. FITZGERALD: We're going to 

just focus on the D&D period, where they went 

to lapel sampling. This will sound a little 

bit familiar for Paul because this is the 

issue we looked at at Rocky Flats, which is 

when they went from an every person gets 

badged and going into a rad area to selecting 

those who they believe to be the most exposed 

individual and monitoring that person with 

lapel samples and if the lapel sample shows 
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something positive, then do the bioassay. So 

it's a different system. 

 The question at Rocky and the 

question here would be, is there 

documentation? Certainly we have interviews 

already, whether or not that was, in fact, the 

way it was implemented and you can rely on the 

data as being those who were, in fact, exposed 

during the D&D period. 

 MEMBER ZIEMER: Well, my question 

is, let me emphasize what I am saying. You 

have raised the question. My question is, who 

answers it? 

 CHAIR BEACH: And that's a good 

question, Paul. 

 DR. ULSH: Well, I think the 

problem, though, is that it is not clear 

exactly what the questions are, the issues 

that are of concern. I understand -- 

 MEMBER ZIEMER: Okay. So you're 

asking SC&A to clarify the nature of the 

question? 
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 DR. ULSH: Yes, yes. 

 MEMBER ZIEMER: Okay. That's fine. 

 I just want to make sure that SC&A is not 

raising a question and then determining the 

response. 

 MR. FITZGERALD: Well, just to be 

clear on the tasking, though, we can certainly 

tee up the specific findings and be able to 

back those findings up and then see what the 

Work Group wants to do next. 

 MEMBER ZIEMER: Yes. 

 MR. FITZGERALD: Okay. 

 MEMBER ZIEMER: Well, I think, 

Josie, you understand what I am asking here. 

 CHAIR BEACH: I understand 

completely. 

 MEMBER ZIEMER: Because it's kind 

of my standard question. 

 CHAIR BEACH: Yes. 

 MEMBER ZIEMER: Make sure that the 

right group is doing -- 

 CHAIR BEACH: Doing the work. 
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 MEMBER ZIEMER: -- the work. 

 CHAIR BEACH: Yes. 

 MR. KATZ: Can I just seek 

clarification, then? In the NIOSH report, did 

you reserve this section with respect to the 

evaluation report or -- 

 DR. ULSH: Yes, but that was based 

on Price-Anderson. 

 MR. KATZ: Okay. 

 DR. ULSH: These are separate. 

 MR. KATZ: So it is still reserved 

in the NIOSH report as the documentation -- 

 DR. ULSH: We revised the 

evaluation report if that is what you mean. 

 MR. KATZ: Okay. 

 DR. ULSH: And we have given our 

position on the Price-Anderson Act issues on 

the record here at a Work Group meeting, but 

we have not revised the evaluation. 

 MR. KATZ: I see. But in giving 

your response with respect to that, do you 

think that closes out the reservation? That 
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completes the evaluation report, in effect, 

with respect to that period? 

 DR. ULSH: That closes out our 

reservations based on the Price-Anderson Act. 

 But Joe is saying that there might be others 

-- 

 MR. KATZ: I understand. I am just 

saying that if we hadn't closed out our work, 

then it would be really OCAS' step, not 

SC&A's, to lay out questions or criticisms. 

It would be OCAS' to lay out, here is how we 

plan to do things and then SC&A to consider 

that. 

 DR. ULSH: Well, I think we have 

done that for the Price-Anderson Act stuff. 

We are going back and forth. I mean, still I 

think the latest iterate was SC&A's response 

to our white paper that agrees on some issues 

and a couple of issues doesn't hit. So that 

is still -- 

 MR. KATZ: Well, I'm just sort of 

resonating with what Paul is saying. 
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 DR. ULSH: Yes. 

 MR. KATZ: If it is not clear what 

OCAS plans to do going forward. Then it 

shouldn't be for SC&A to lay out, here is 

where we think the vulnerabilities or problems 

are if what OCAS has already laid out, here is 

what we are going to do. 

 DR. ULSH: No. Our position is 

during the D&D years, we can do dose 

reconstructions with sufficient accuracy. 

 MR. KATZ: Okay. 

 DR. ULSH: But SC&A has raised some 

questions related to D&D. We just want to 

clarify what those issues are. 

 MEMBER ZIEMER: Okay. I just 

wanted to make sure that that was the case. 

 CHAIR BEACH: So I guess we will 

retract what I said about a white paper. And, 

really, what SC&A is going to do is pose the 

questions back to NIOSH. 

 MR. KATZ: If it has concerns. 

 CHAIR BEACH: If it has concerns. 
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Okay. That helps. Thanks, Paul. 

 MEMBER ZIEMER: Yes. 

 MR. KATZ: Thank you. 

 CHAIR BEACH: Okay. Anything else 

on that portion? 

 (No response.) 

 CHAIR BEACH: I guess the last item 

on the agenda, then, is to look at the road 

map, integrated issues and -- 

 MEMBER CLAWSON: You know what, 

Mel? I really would like to -- I apologize. 

I didn't think you -- 

 MR. CHEW: Yes. I was going to 

walk down exactly where we are with news and 

the road map. I think there were two action 

items that came out of the last July meeting. 

 They were put into incident reports and then 

looked at the RWPs relating to the D&D area. 

 The first part has been 

incorporated into this new road map. I was 

going to walk you through to see what is new. 

 I just want to make sure from a security 
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standpoint that this version that you have, 

the pfp version, has been redacted by the DOD. 

 I made probably a fatal error that 

I will never make again. I sent Kathy a Word 

file, which I will probably regret later on. 

Anyway, let's delay it to next time. It will 

be worthwhile for you to look at the -- 

 CHAIR BEACH: So the only thing 

that I want to ask on the road map is I know 

there is an additional version to it. I would 

like to see if that version can be shifted to 

Hanford for viewing by Kathy and myself, 

Dennis. 

 DR. ULSH: Yes. We'll coordinate 

with Gina Cano and Greg Lewis and see if we 

can make that happen. 

 MR. CHEW: The other version I want 

to make sure -- this will only take a few more 

seconds -- I was going to point out clearly 

locations were referred to Appendix B. Okay? 

 And we're very cautious not to 

assume that if anything was in Appendix B that 
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I saw what was in Appendix B and also did not 

see any of the other reference documents that 

were used in unclassified sources here they 

are not in here. I just want to make sure you 

know that. 

 The caution that we all need to 

exercise is that this is a road map that came 

from many different sources. And so you 

understand the implications of that. 

 You understand the reports that are 

there. There are 75 of them. We gave you the 

SRDB numbers to reference that. That was one 

of the deliverables. And so we can talk about 

the PWPs or the work permits for the D&D area. 

 There is a lot more detail in this 

particular document than what you have seen in 

the past. Please start at the very top and 

look at the color coding. You will enjoy 

that. 

 I want to first Sam Chu and Gene 

and Leo, who spent diligent hours in putting 

this kind of a road map together. 
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 CHAIR BEACH: Great. 

 MR. CHEW: I think it was very 

worthwhile because Mound is a very complex 

site with a lot of different things. And what 

I was showing them was how it shows up 

chronologically. You don't get that feeling 

when you look at this particular road map of 

chronology, when those things were handled. 

And that's why I was going to talk to walk 

through it. 

 Maybe we can do something to get 

that in your hands so you know that it has 

been handled, redrumming of zoning for this 

particular period and time in that particular 

building. You get that feeling. 

 DR. ULSH: I think when we 

reconvene at another location, we will maybe 

take you up on your offer to walk us through. 

 CHAIR BEACH: Yes. 

 MR. FITZGERALD: We can dovetail. 

It is something we're going to have to do 

later. 
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 MR. CHEW: I'm done. 

 CHAIR BEACH: Thank you. 

 And apologies if that seemed really 

quick, but we are losing two Work Group 

members now. 

 MR. FITZGERALD: I think that's a 

good point. Let me read. We have been trying 

to figure out what the evaluation report said. 

 Actually, it matches pretty much both of what 

we are saying. So I guess we both feel about 

it. 

 It's three sentences, D&D era 

bioassay. There had been concerns expressed 

by numerous former workers about whether the 

bioassay requirements matched the exposure 

potential to workers during the D&D era. This 

is exactly what we are focusing on. 

 Then the next sentence, Envision 

there were several Price-Anderson Act 

violations and crimes during that period. 

NIOSH continues to investigate whether these 
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occurrences compromise its ability to perform 

dose reconstruction with sufficient accuracy. 

 That is the only entry that is there. 

 DR. ULSH: I think I see where the 

confusion comes. The third sentence related 

to the second and not -- 

 MR. FITZGERALD: Right, right. 

 DR. ULSH: -- from us. 

 MR. FITZGERALD: Right. And I 

think that first sentence captures what we are 

looking at, which is whether the exposure 

potential of workers matched the requirements 

and whether those requirements were 

implemented effectively during that era. That 

is kind of what we have to tee up. 

 This appears that the ER actually 

acknowledges the concerns. We heard the same 

concerns in our interviews from the D&D era 

workers. So I think that is an open issue 

that we ought to -- actually, ER acknowledges 

that it is an open issue. 

 CHAIR BEACH: And, in closing, for 
NEAL R. GROSS

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the last item, Future Meetings, we have 

nothing planned at this time. The action 

items that came from the two-day Work Group, I 

will send out an e-mail to the Work Group and 

NIOSH, SC&A. And then we can make additions 

or changes if there is something I may have 

missed. 

 MR. KATZ: It's about a two-month 

time frame for a lot of these deliverables -- 

 CHAIR BEACH: Right. 

 MR. KATZ: -- that have been teed 

up today. So it is looking like the next 

Working Group meeting probably won't happen 

until early August. 

 CHAIR BEACH: Right. I agree with 

that. Okay. Thank you. 

 MR. KATZ: Thanks, everyone on the 

phone. 

 (Whereupon, the above-entitled 

matter was concluded at 3:30 p.m.) 
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

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