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U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH 

+ + + + +

ADVISORY BOARD ON RADIATION AND

WORKER HEALTH 

+ + + + +

TBD-6001 WORK GROUP

+ + + + +

WEDNESDAY

JULY 7, 2010

+ + + + +

The Work Group met in the Zurich Room of 

the Cincinnati Airport Marriott, 2395 Progress 

Drive, Hebron, Kentucky, at 9:30 a.m., Henry 

Anderson, Chairman, presiding.

PRESENT:

HENRY ANDERSON, Chairman

R. WILLIAM FIELD, Member

MARK GRIFFON, Member*
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ALSO PRESENT:

TED KATZ, Designated Federal Official

ISAF AL-NABULSI, DOE*

DAVE ALLEN, DCAS

TERRIE BARRIE, ANWAG*

HANS BEHLING, SC&A*

SAM GLOVER, DCAS

STU HINNEFELD, DCAS 

JOHN MAURO, SC&A

JIM NETON, DCAS

JENNY LIN, HHS

WILLIAM THURBER, SC&A

*Present via telephone
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C-O-N-T-E-N-T-S 

Roll Call.................................. 5 

Overview of TBD-6001 from DCAS............ 9 

SC&A Review 

Discussion of Finding One................. 17

Discussion of Finding Two................. 40

Discussion of Finding Three............... 44

Discussion of Finding Four................ 67

Discussion of Finding Five................ 73

Discussion of Finding Six................. 85

Observation One........................... 85

Observation Two........................... 87

Observation Three......................... 90

Observation Four.......................... 96

Observation Five.......................... 97

Observation Six.......................... 103

Observation Seven........................ 113

Observation Eight........................ 114

Observation Nine, Ten.................... 118

Observation Eleven, Twelve,

Thirteen................................. 117

Discussion of TBD-6001 use - Hooker...... 125

Next steps............................... 149

Review of Electro Met - DCAS............. 157

- Finding One............................ 172

- Finding Two............................ 203

- Finding Three.......................... 204

- Finding Four........................... 205

- Finding Five........................... 209

- Finding Six............................ 212

- Finding Seven.......................... 213

- Findings Eight, Nine................... 207

- Finding Ten............................ 218

- Finding Eleven......................... 227

- Finding Twelve......................... 229

- Findings 13/15......................... 232

- Finding Fifteen........................ 237
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- Finding Sixteen........................ 241

Next steps............................... 244

C-O-N-T-E-N-T-S (Cont'd)

Review of United Nuclear ................. 249

- Finding One............................ 254

- Finding Two............................ 258

- Finding Three.......................... 275

- Finding Four........................... 278

- Finding Five........................... 292

- Finding Six............................ 295

- Observation One........................ 303

- Next steps............................. 304

Hooker Electrochemical - 

DCAS/SC&A Status ................... 326

 

Adjournment.............................. 334
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1 P-R-O-C-E-E-D-I-N-G-S 

2 (9:32 a.m.)

3 MR. KATZ: We will begin with roll 

4 call. Just a quick overview of the agenda and 

5 then Andy may have to more to say but we are 

6 going to both generically be addressing the 

7 TBD-6001 procedure and then as time allows, we 

8 will be specifically addressing two petitions: 

9 one for Electro Met; and the second for United 

10 Nuclear.

11 And then toward the end of the day 

12 we will talk about the path forward and also 

13 address, with respect to the path forward, 

14 Hooker Electrochemical, which we will not get 

15 to substantively today. But that's just to let 

16 everybody know, just sort of the general 

17 landscape.

18 We may run out of time anywhere in 

19 the course of this. There's a lot to cover for 

20 a day and I doubt we'll get through it all. 

21 There's a long agenda. It is available to 

22 people on the internet, on the DCAS website 
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1 and I think all participants have a copy.

2 So we will begin with roll call 

3 and for all the agency-related individuals, 

4 Board and others, contractors, please state 

5 whether you have a conflict with respect to 

6 this site as well, when you respond to the 

7 roll call.

8 So beginning with Board Members in 

9 the room, with the Chair.

10 CHAIRMAN ANDERSON: Henry 

11 Anderson, Wisconsin Division of Public Health. 

12 I don't have any conflicts.

13 MEMBER FIELD: Bill Field, no 

14 conflict.

15 MR. KATZ: And on the line?

16 MEMBER GRIFFON: Mark Griffon, no 

17 conflicts.

18 MR. KATZ: Any other Board Members 

19 on the line? Okay and those are the Members of 

20 the Work Group. And then NIOSH/ORAU team in 

21 the room?

22 MR. HINNEFELD: Stu Hinnefeld, 
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1 interim director of DCAS. No conflicts at 

2 these sites.

3 DR. NETON: Jim Neton, DCAS, no 

4 conflicts.

5 DR. GLOVER: Sam Glover, DCAS, no 

6 conflicts.

7 MR. ALLEN: Dave Allen, DCAS, no 

8 conflicts.

9 MR. KATZ: And NIOSH/ORAU team on 

10 the line? Okay. SC&A in the room?

11 DR. MAURO: John Mauro, SC&A, no 

12 conflict.

13 MR. THURBER: Bill Thurber, SC&A, 

14 no conflicts.

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

16 DR. BEHLING: Hans Behling, no 

17 conflicts.

18 MR. KATZ: Very good. Then, other 

19 HHS or other agency personnel or contractors 

20 to the agencies in the room?

21 MS. LIN: Jenny Lin, HHS.

22 MR. KATZ: And on the line?
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1 DR. AL-NABULSI: Isaf Al-Nabulsi, 

2 DOE, no conflict.

3 MR. KATZ: Welcome, Isaf.

4 DR. AL-NABULSI: Thanks.

5 MR. KATZ: Okay and then, finally, 

6 members of the public on the line; there are 

7 none in the room.

8 MS. BARRIE: Terrie Barrie with 

9 ANWAG.

10 MR. KATZ: Welcome, Terrie. Very 

11 good. And I probably didn't even identify 

12 myself. My name is Ted Katz. I am the 

13 Designated Federal Official for the Advisory 

14 Board and we are ready to get started then. 

15 Andy, it's your agenda.

16 CHAIRMAN ANDERSON: First, 

17 congratulations to Mark on his appointment.

18 It's good news that you are on the 

19 line. It means there must not be some big 

20 event occurring that we don't know about yet. 

21 MEMBER GRIFFON: Yes, nothing that 

22 you don't know about. The one you know about 
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1 is the only one out there. But thank you.

2 CHAIRMAN ANDERSON: I really don't 

3 have much else. I think we ought to just get 

4 started. This, of course, Committee was broken 

5 off from the TBD-6000 because of all the 

6 different sites being addressed so the only 

7 question I would have is, I looked at the 

8 matrix and there didn't seem to be any 

9 responses yet from NIOSH. Is there? Not yet.

10 MR. ALLEN: There weren't any 

11 written responses.

12 CHAIRMAN ANDERSON: Okay. Okay. 

13 Fine. Good, I wanted to be sure I didn't miss 

14 something. So let's go on then and start up.

15 MR. KATZ: So, the first item is 

16 Overview of TBD-6001 from DCAS, just a brief 

17 summary and a chance for the Work Group to ask 

18 questions about it. 

19 MR. ALLEN: Okay, I think to start 

20 with it takes kind of a brief summary of what 

21 our contractor did for us as far as TBD22 6000/6001. The whole intent at the time was to 
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1 gather up some information on the sites that 

2 did very similar work and at the time it was 

3 decided to divide these into three primary 

4 categories with very different types of 

5 exposure conditions.

6 One being uranium metal, largely 

7 because it's a very similar type of -- you can 

8 only do so many things with uranium metals so 

9 all exposure conditions were fairly similar 

10 and the smaller sites that did that type of 

11 work were pretty abundant. And that became 

12 TBD-6000.

13 TBD-6001 was intended for the 

14 other chemical work, essentially with uranium, 

15 the processing of the uranium compounds like 

16 UF4, UF6, U02, et cetera, and that became TBD17 6001 which was -- it's labeled as uranium18 refining operations.

19 There was to be a third one at the 

20 time and that was for uranium-ore operations. 

21 That was split out because of the natural22 occurring decay products, with the radium, 
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1 thorium-230 et cetera, make for a very 

2 different exposure conditions than refining 

3 processed uranium. 

4 CHAIRMAN ANDERSON: So, just a 

5 quick question. On a product-flow basis, so 

6 kind of 6000 was earlier in the process and 

7 6000 --

8 MR. ALLEN: It was just the 

9 opposite of what I introduced. It was --

10 CHAIRMAN ANDERSON: Okay, so 6001 

11 is the ore processing, refining, and then 

12 their output went to the facilities that were 

13 6000.

14 MR. ALLEN: And then the ore would 

15 have been first so, pretty much exactly the 

16 opposite of what I introduced.

17 CHAIRMAN ANDERSON: That was what I 

18 was wondering. I thought, gee, I had looked 

19 through that document, it doesn't sound right 

20 to me. Thank you.

21 MR. ALLEN: But that was the 

22 thought process at the time. The decision on 
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1 the ore was that it is very different and very 

2 limited and the idea of a generic TBD was kind 

3 of dismissed partway into that process so a 

4 TBD to address that processing was never 

5 developed. That was going to be just a site6 by-site type of Technical Basis Document.

7 TBD-6000, 6001 are both somewhat 

8 generic type of documents. The intent is to 

9 look at the exposure conditions for a type of 

10 work with the type of material and then to 

11 apply that to other work sites that did that 

12 same type of task with the same materials.

13 The idea all along was to have 

14 this generic and then have an appendix for 

15 every site that it would apply to. The 

16 appendix would analyze and document the 

17 exposure estimate based on data from that 

18 particular site and use the generic TBD-6001 

19 and 6000 to fill in the blanks where there was 

20 no data. That was the concept when we put all 

21 that together.

22 And about the only other thing is 
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1 that SC&A was tasked with reviewing both 6000 

2 and 6001 some time ago. As you know there was 

3 a previous Work Group to deal with both has 

4 now been split up, obviously and in that Work 

5 Group we never really addressed 6001 issues 

6 because at the time there was no sites they 

7 were interested in that actually used the 

8 defaults out of 6001.

9 As I said, the appendices would 

10 use defaults where there was lack of data, but 

11 the sites we were looking at, there was no 

12 lack of data, there were no defaults used at 

13 that point in time.

14 So even though they were assigned 

15 as an appendix to TBD-6001, there was no data, 

16 no generic data that was actually pulled into 

17 that appendix. And I think that is all the 

18 background I have for you. I think that brings 

19 everybody up to speed.

20 DR. MAURO: As a preface, though, 

21 also I would like to add one thing, is this, 

22 the use of TBD-6000 and 6001 is actually, does 
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1 go to the heart of the surrogate data issue 

2 and I know we all are aware that this is a 

3 very important issue to the Board and to the 

4 public, claimants.

5 So we are really in the trenches 

6 on what I consider to be probably the biggest 

7 surrogate data issue because as we process 

8 this, and we less, or dismiss certain issues, 

9 there's always the overarching question, well 

10 wait a minute, plausibility, applicability, 

11 all the criteria that have been developed by 

12 the Board, now officially -- I believe the 

13 criteria are official -- is sort of like an 

14 overarching issue that we always have to sort 

15 of keep in mind as we move through this, 

16 whether we are doing it for TBD-6000 or any of 

17 the sites, such as United Nuclear or Electro 

18 Met. 

19 DR. NETON: I guess I would just 

20 point out, though, that these are generic 

21 documents and really the test at the end of 

22 the day comes to how it is applied to the 
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1 specific site. The data that are collected 

2 and assembled in TBD-6000 and 6001 are not in 

3 and of themselves bad or wrong, one needs to 

4 make the judgment when you apply that to a 

5 particular site: is it appropriate or not.

6 So I think there's a real 

7 distinction there. These are certainly the 

8 data but until it really gets applied, you 

9 cannot judge it against -- 

10 DR. MAURO: Agree with you.

11 CHAIRMAN ANDERSON: It's 

12 applicability. It looked to me like it was 

13 mostly kind of a library of available data.

14 DR. NETON: And that's what I was 

15 going to point out. I was going to get to 

16 this maybe a little bit later, but you almost 

17 really have to judge it against the individual 

18 site because we have three DRs out there now, 

19 these little pieces --

20 DR. MAURO: Again, we're 

21 overarching now, United Nuclear and Electro 

22 Met: I don't know the degree to which they do 
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1 draw upon 6001 so since this is on our table, 

2 I know Hooker does, I know we're getting to 

3 Hooker later, but I'm not sure whether -- I 

4 know -- whether or not -- so we may not have, 

5 I don't know if either of them do. Electro 

6 Met? No. I am trying to think of if there's 

7 any place where they did that and I don't 

8 recall.

9 DR. NETON: I don't know what they 

10 are doing in this Working Group.

11 MR. ALLEN: It's Appendix C.

12 DR. MAURO: Yes, way things are 

13 grouped, there are I think five --

14 CHAIRMAN ANDERSON: But there's

15 considerable data. 

16 DR. MAURO: For the particular 

17 sites we will be dealing with starting today, 

18 Electro Met and United Nuclear, I believe that 

19 they didn't use too much if any data from --

20 DR. NETON: See, and that's what I 

21 was getting at it because if there's a lot of 

22 data, it's --
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1 DR. MAURO: You are right. Good. 

2 CHAIRMAN ANDERSON: So, we can 

3 knock it all off today.

4 DR. MAURO: We can just knock 

5 everything off.

6 CHAIRMAN ANDERSON: Okay. Okay, so 

7 --

8 MR. KATZ: What is SC&A's --

9 DR. MAURO: Oh, we're on.

10 CHAIRMAN ANDERSON: You're on. 

11 Well, of the, this is basic TBD-6001.

12 DR. MAURO: Just by introduction, 

13 Bill Thurber and I for several years, have 

14 been really been the heart of doing all of the 

15 AWE work, which means TBD-6000, 6001, all of 

16 these appendices, all of the AWE work somehow 

17 fell with us and a few others and really Bill 

18 has been doing the heavy lifting on a lot of 

19 this and I'd like to turn it over to Bill, who 

20 is, I guess we will start with the TBD-6001 

21 matrix and take it away.

22 MR. THURBER: Just a further 
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1 comment on how this intertwines with, how TBD2 6001 is intertwined with the appendices, we 

3 originally prepared our review about two and a 

4 half years ago and it has been since that time 

5 that we have looked at some of these site6 specific appendices or the SEC petitions 

7 related thereto and in the course of that, a 

8 number of problems have surfaced as to how you 

9 can actually use TBD-6001 appropriately and 

10 where the numbers come from that weren't 

11 initially apparent when we did review and we 

12 will get into a little bit of that as we go 

13 along.

14 With regard to TBD-6001, all of 

15 the -- virtually all of the internal exposure 

16 data come from a journal article published by 

17 two guys named Christifano and Harris in 1960 

18 and these gentlemen worked for the AEC Health 

19 and Safety Laboratory and in the course of 

20 their work between 1948 and 1956 they had 

21 accumulated some 20,000 samples, air samples, 

22 from seven different AEC locations: 
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1 Mallinckrodt, Harshaw, Electro Met et cetera.

2 And so it was on the basis of this 

3 Christifano and Harris journal article that 

4 the air concentration data and the attendant 

5 exposures in TBD-6001 were derived.

6 Obviously, that's a very rich 

7 resource. Some of the problems with it --

8 there are some problems with it, though, for

9 example there are no supporting references so, 

10 as with a journal article, you don't really 

11 understand all the details of how they 

12 averaged their numbers and where all the data 

13 came from and whether any of the data was 

14 relatable to specific sites; you can't discern 

15 any of that from the Christifano and Harris 

16 paper. But that's where the internal exposure 

17 data from TBD-6001 came. 

18 In terms of external exposure, 

19 where the exposure was related to drums of 

20 uranium, uranium oxide, UF4, whatever, the 

21 drum exposure data in part came from modeling 

22 studies using MicroShield and workers standing 
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1 different distances from the source, and also 

2 in the case of pitchblende, it was actually 

3 based on measurements made at Mallinckrodt of 

4 workers standing various distances from the 

5 source.

6 In terms of the rest of the 

7 operations that are involved in the uranium8 refining process, the digestion and nitric 

9 acid, the solvent extraction, et cetera, et 

10 cetera, the data on external exposure for 

11 those operations came from Mallinckrodt, where 

12 all of these operations were conducted.

13 Now a lot of the operations were 

14 conducted at other places, as well, but the 

15 data that was built into TBD-6001 was based on 

16 Mallinckrodt data.

17 With those additional background 

18 comments, let me get into our findings and I 

19 think, hopefully people can read them. Our 

20 first finding was that -- and this speaks to 

21 the Christifano and Harris data -- as we said, 

22 while there is a lot of it presented there, 
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1 it's difficult to understand the pedigree of 

2 the data and we tried to validate the 

3 Christifano and Harris data, if you will, by 

4 comparing it with Mallinckrodt data, which 

5 presumably was a subset of it but which was 

6 well documented in the Mallinckrodt reports.

7 And in doing that, we found that -

8 - and there are a number of examples in our 

9 review and I won't go into them -- but we 

10 found that in a number of cases, it looked 

11 like the Mallinckrodt data yielded higher 

12 exposures than the numbers in TBD-6001.

13 So that is the basis for finding 

14 one. Finding two, again --

15 MR. KATZ: I'm sorry, Bill, could 

16 I just make a suggestion, if we are going to -

17 - it's probably easier to go finding by 

18 finding and have the others have a chance to 

19 be prepared on any of these to provide their 

20 input on them.

21 MR. ALLEN: Are you done with 

22 finding one then, or --? 
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1 MR. THURBER: Yes.

2 MR. ALLEN: One of the big --

3 there's some flaws in 6000 and 6001, I mean 

4 I'll admit that freely, and the biggest one in 

5 my book is what I was mentioning earlier was, 

6 the intent was to separate out ore-processing 

7 from pre-processed uranium refining and 

8 Mallinckrodt did ore-processing. They 

9 processed radium-bearing ores as well as other 

10 uranium compounds.

11 TBD-6000, the flaw I mentioned was 

12 that it was definitely not clear in there that 

13 this was not to include ore. In fact it 

14 mentioned pitchblende and some other things 

15 that it really should not have. It has not 

16 been used for any kind of ore-processing but 

17 it's certainly not clear in TBD-6000 that it 

18 is not supposed to be used for that.

19 DR. NETON: Six thousand one.

20 MR. ALLEN: Six thousand one, 

21 sorry. A lot of the findings in SC&A's report, 

22 since TBD-6001 is not clear on that, they 
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1 reference Mallinckrodt data that actually is 

2 higher due to the ore, the radium-bearing ores 

3 et cetera, that should not be applied with 

4 6001.

5 And obviously there is a -- we 

6 would have to revise 6001 to make that clear, 

7 obviously, and I think that's going to end up 

8 being the --

9 CHAIRMAN ANDERSON: So is it 

10 possible in the Christifano to sort that out? 

11 Or are we sorting it out -- you can do it in 

12 Mallinckrodt, but -- 

13 MR. ALLEN: It's possible to sort 

14 out the tasks and eliminate some of those 

15 tasks that could be either and in worst case 

16 use ones that are ore in Christifano as a 

17 bounding but I don't think we have to do that.

18 MR. THURBER: Christifano and 

19 Harris as a category, do consider ore 

20 digestion, which is, after the sampling, is 

21 the first step, assuming you have obtained 

22 concentrates from somewhere else or you have 
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1 obtained pitchblende as a feeding material.

2 CHAIRMAN ANDERSON: The raw data is 

3 not available from Christifano --

4 MR. THURBER: For ore -- 

5 CHAIRMAN ANDERSON: Twenty-thousand 

6 samples or something? 

7 MR. THURBER: Yes, yes it is. It is 

8 available and they point out, they discuss to 

9 some extent in their article the differences 

10 in processing pitchblende or concentrates, not 

11 only in the ore digestion step, but also in 

12 the solvent extraction step, in terms of 

13 external exposure. We have to be careful, 

14 sometimes we are talking about one and some 

15 times the other. But there is, they do 

16 consider --

17 DR. NETON: Was Christifano and 

18 Harris not really a journal publication that 

19 was based on a lot of AEC -- 

20 MR. ALLEN: It was Health and 

21 Safety Lab --

22 DR. NETON: Health and Safety 
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1 Laboratory reports and to my knowledge it was 

2 a fairly thick report that contained a lot 

3 more background information than what it is in 

4 the journal article.

5 MR. ALLEN: That's what I was going 

6 to say, just to clarify what Bill said --

7 CHAIRMAN ANDERSON: The article is 

8 sort of a summary. I mean, you have got ranges 

9 and stuff but it really doesn't help you, so -

10 - 

11 MR. ALLEN: We have a lot of Health 

12 and Safety Lab data and I think that's what 

13 Bill was referring to; just to be clear, the 

14 article itself does not contain all the 

15 individual samples. 

16 DR. MAURO: There's 20,000 

17 measurements.

18 CHAIRMAN ANDERSON: No, I mean --

19 DR. MAURO: In my perspective, 

20 external is a lot more manageable issue, 

21 simply because, beside measurements, you could 

22 always resort to modeling, as you know --
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1 CHAIRMAN ANDERSON: Good, we can't 

2 do that.

3 DR. MAURO: I know, modeling is the 

4 -- but we are just talking about physics 

5 modeling.

6 CHAIRMAN ANDERSON: Yes, I know, I 

7 know.

8 DR. MAURO: Which are pretty -- I 

9 mean, you are running MCNP, you run a point 

10 kernel, you do it by hand. You really cannot 

11 be too wrong, if you know the source.

12 CHAIRMAN ANDERSON: The bounding is 

13 pretty easy. 

14 DR. MAURO: The internal always is 

15 the one that you trip over.

16 MR. THURBER: Okay, are we ready to 

17 move on to finding two?

18 CHAIRMAN ANDERSON: So for finding 

19 one, are you going to revise something, I 

20 mean, is this something that as a Committee we 

21 can say, okay, it was identified, it's sort of 

22 been addressed, we are aware of it? I am not 
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1 sure every time you find -- the effort to, 

2 when you write it, as opposed to it's a 

3 working document we know about it, is this one 

4 that we need to do anything, do we need to 

5 discuss anymore or is it basically --

6 MR. ALLEN: Well, I think the 

7 problem I am having is a lot of the findings 

8 that SC&A put together, you know, they look 

9 for some examples and examples they have found 

10 in a lot of cases are this ore stuff, and 

11 that's the fault of TBD-6001 not making that 

12 clear.

13 CHAIRMAN ANDERSON: Okay.

14 MR. ALLEN: But, that means you 

15 throw a paragraph in TBD-6001 and the findings 

16 don't seem to be valid anymore but they were 

17 examples.

18 CHAIRMAN ANDERSON: So just to keep 

19 our matrix alive, it may be worth putting in 

20 there, if you agree that's what the issue is, 

21 then, if others, these findings, really are 

22 reflecting the same issue, then if, in fact, 
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1 the ore is taken out is a -- or the processing 

2 or however we want to state that -- is the 

3 issue, let's identify that with the finding 

4 and then we can kind of lay that out and get a 

5 paragraph or we just remember every time.

6 MR. KATZ: I think you wanted a 

7 finding-by-finding response, even if it may 

8 apply to more, I think you want to go finding 

9 by finding. And so, I mean -- 

10 CHAIRMAN ANDERSON: I mean --

11 MR. KATZ: -- suggested a response 

12 to the first finding, which still needs I 

13 think to be confirmed that everyone agrees if 

14 that's the resolution and then you document 

15 that and in the future you look for it to be 

16 resolved by actually changing the document.

17 MR. THURBER: I would, I have no 

18 disagreement at all with what David says but I 

19 would point out that the comment is broader 

20 than just very front end of the process. The 

21 validation work, if you will, that we did 

22 using the Mallinckrodt data against the 
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1 Christifano and Harris data indicated that for 

2 other operations like denitration and oxide 

3 reduction and recasting, the Mallinckrodt data 

4 were higher.

5 So the comment is broader than 

6 just the ore end, there's no problem with the 

7 ore end relationship but it's a broader 

8 comment.

9 DR. MAURO: By way of process, the 

10 matrix usually is our score card.

11 CHAIRMAN ANDERSON: Yes.

12 DR. MAURO: And one of the things I 

13 should you should perhaps, you may want to 

14 decide, I know like Mark, when he runs his 

15 Work Group, likes to prepare the matrix 

16 himself or in other cases, you know, we work 

17 with NIOSH to prepare the next version of 

18 this. In other words, for example NIOSH may 

19 provide a response, NIOSH makes a response, or 

20 tracking what is going on, trying to find a 

21 way to see, this discussion we just had, it's 

22 certainly captured in the transcript, but 
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1 there's always a degree to which, do we want 

2 to try to capture it, the essence of this 

3 discussion, in the matrix and how we are going 

4 to do that.

5 I think this is something that the 

6 work with, would like, I would like to go 

7 forward.

8 CHAIRMAN ANDERSON: Yes, I don't 

9 know, Bill, how you feel. Mark, you have been 

10 doing it longer than most of us so any 

11 thoughts on how we should do this?

12 MEMBER GRIFFON: Well, I mean, I 

13 think, I don't necessarily, I don't think it 

14 matters who prepares the matrix so much as --

15 but I think it would be worth, you know, 

16 carrying it through and seeing a written 

17 response from NIOSH before you close it out, 

18 you know.

19 CHAIRMAN ANDERSON: Okay.

20 MEMBER GRIFFON: Because sometimes 

21 we have caught ourselves with that, that we 

22 think we closed it out in discussions but we, 
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1 you know, never formally closed, and then we 

2 have to reopen it and so I think it's always 

3 better to, for me, it would be nice to see the 

4 written-out response to make sure I am in 

5 agreement and then have the Work Group Members 

6 vote it through and, you know, then we are 

7 done with it.

8 CHAIRMAN ANDERSON: Okay, good. So 

9 that's the process, I guess, well.

10 MR. KATZ: I think for the time 

11 being I think, if SC&A, they've started this 

12 matrix, DCAS can send them a written response

13 documenting -- and they can keep it up to date 

14 at this point. Moving down the road, I mean, 

15 there's this work underway to do this all 

16 online as part of this sort of database effort 

17 that's being used for some other Work Groups 

18 or at least for the Subcommittee on 

19 Procedures. Eventually that will be expanded 

20 and that could be done online.

21 But anyway, for the meantime, it 

22 seems like it's good for SC&A to keep up the 
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1 matrix and to receive input from DCAS for 

2 their responses.

3 DR. MAURO: On this particular 

4 item, there are some issues where let's say 

5 it's very specific. I'll give you an example, 

6 we may have some of these, where we say gee, I 

7 think you guys made a mistake. Your number is 

8 off by a factor of five, and you know, can we 

9 explain why, and then I say, Dave, I say, yes, 

10 you are right, this is not reasonable. 

11 And then at that point, it becomes 

12 very simple. NIOSH usually responds with the, 

13 we agree that there is an error. We will 

14 correct it. And what typically is done, during 

15 other procedures and other Work Groups, that 

16 item is not really closed. What it is, is it's 

17 put in this place that we call in abeyance, 

18 which means that okay, we all agree, 

19 technically, this is the approach and it will 

20 be closed when the next issue or revision 

21 comes out where it's fixed, and then it's 

22 closed.
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1 I mean this is really a choice you 

2 folks have, or we could close it right there 

3 and say, listen, it's technically agreed upon 

4 that the solution is yes, at some time in the 

5 future, we will be revising this particular 

6 procedure and we agree that this factor of 

7 five needs to be fixed.

8 This is purely, you know, whether 

9 you want to close it on that basis and not to 

10 back to it, or say no, let's leave it open and 

11 we call it, in abeyance, which means where we 

12 all agree but until it's actually fixed in the 

13 document itself, we are not going to close it 

14 out. Again, this is a choice that each one of 

15 you makes for themselves.

16 MEMBER FIELD: Myself, I would 

17 prefer the second.

18 DR. MAURO: Okay then and that 

19 would be what we would do on any others.

20 CHAIRMAN ANDERSON: Well, as time 

21 goes by, then you tend to forget and if it 

22 doesn't get -- 
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1 DR. MAURO: That's exactly the 

2 reason for it. 

3 CHAIRMAN ANDERSON: On the agenda, 

4 I mean, one or two, you can keep in your mind, 

5 but as it piles up across all the -- 

6 DR. MAURO: But, now, where I was 

7 leading, though, is, in this particular 

8 finding --

9 CHAIRMAN ANDERSON: This will stay 

10 open forever.

11 DR. MAURO: This is an important 

12 finding. If it was simply that the work that 

13 Bill has done in showing the examples where 

14 the generic numbers really are not bounding 

15 because when we look at Mallinckrodt and as 

16 Bill pointed out it's more than just the ore 

17 issue. I think the ore issue is going to solve 

18 a lot of it.

19 But I think that -- where I'm 

20 heading is I think we need a White Paper for 

21 this issue and maybe others, namely, it's not 

22 a simple story. There is enough richness to 
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1 this issue where we have, okay, here's the ore 

2 and perhaps in your White Paper you could 

3 explain, you know, this, the concern that SC&A 

4 raised about the examples, for example in our 

5 work, where the, where we feel that the 6001 

6 underestimated for some people, because of the 

7 ore issue and that would solve that.

8 But as Bill pointed out, things 

9 get a little bit more complicated when you 

10 leave the ore issue and you actually get into 

11 the process issue which is part of 6001, 

12 appropriately, where we also have some 

13 problems.

14 And I think that there's going to 

15 need to be some work done initially, let's say 

16 by NIOSH, to say, okay, let's take a look at 

17 this and see if perhaps the distributions that 

18 are currently in 6001 need to be broader, or 

19 the median has to be shifted based on a closer 

20 look at some of the data that I guess 

21 originally Battelle compiled and it was 20,000 

22 measurements.
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1 And bear in mind this is I believe 

2 all air sampling measurements and that is 

3 always an issue too. When you depend on air 

4 sampling measurements, you have to be a little 

5 careful and we all ran into this before, 

6 whether it was breathing zone, general air, so 

7 in other words, where I am getting at is that 

8 I think that item one is a simple statement 

9 but embedded in it is a richness and I think a 

10 White Paper would be appropriate. This is my 

11 recommendation to deal with this.

12 MR. ALLEN: Well, I would agree 

13 with you except that I tried to sort through 

14 the actual write-up and knowing what I knew 

15 about the ore and you guys didn't realize that 

16 at the time, and I tried to narrow it down to 

17 what was significant and honestly, in the 

18 examples, like I said, they were examples, and 

19 I realize that, for finding one, I couldn't 

20 find anything.

21 In fact there's a statement in the 

22 review that says plant four and six data are 
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1 significantly higher for ore one operation, 

2 parentheses, ore digestion and about the same 

3 as Christifano and Harris and all others.

4 DR. MAURO: Well, you know, if it's 

5 that simple, I mean, I am not disagreeing with 

6 you --

7 MR. ALLEN: No, I am not saying 

8 that it's that simple but I am saying I am 

9 kind of stuck, I think in all honesty it's 

10 kind of in your ballpark to take this new 

11 information that I have given out today and 

12 kind of re-look at the issues.

13 DR. MAURO: Bill, right now, do you 

14 feel that there are steps in the process that 

15 are appropriately part of 6001 where we still 

16 think there are some problems?

17 MR. THURBER: Well, what I 

18 mentioned, if you go to section 8.1 of our 

19 review, we showed that, for the steps I 

20 mentioned before, for digestion, denitration, 

21 oxide reduction and recasting, that the data 

22 from Mallinckrodt were higher than those from 
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1 TBD-6000 by factors of two to five.

2 DR. MAURO: So that's what I am 

3 saying, I think that it's all in, all I am 

4 saying is I think the ball is in your court 

5 and with those examples, I guess if you could 

6 convince yourself that they are fine, great 

7 and then usually the next step is that a White 

8 Paper shows up on SC&A's desk or the Work 

9 Group and we will take a look and say, oh, 

10 okay, it looks like they have fixed the 

11 problem.

12 But right now I think our position 

13 is we believe it extends beyond just the ore 

14 issue and as Bill just --

15 CHAIRMAN ANDERSON: Well, we need 

16 some, I think we need some written, you know, 

17 I think we need a written response and then --

18 DR. MAURO: And then --

19 CHAIRMAN ANDERSON: And you know, 

20 rather than just talk further here, I think 

21 that, you know, and if you think a White Paper 

22 is appropriate or not or how -- or if your 
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1 points are, compare an actual document which 

2 is two and a half years old, it may be that 

3 needs to be updated as well so let's get it in 

4 writing and then we can go back and forth.

5 MR. ALLEN: I will go through the 

6 issue, review SC&A did and, you know --

7 CHAIRMAN ANDERSON: Yes. Great.

8 MR. ALLEN: -- start parsing out 

9 that this is an ore, you know, this is ore, 

10 this is ore, and try to find what is not 

11 associated with it and respond in a White 

12 Paper. If I find nothing, I will at least fire 

13 off an email to everybody.

14 MR. KATZ: Well, I mean a White 

15 Paper is just a generic term, you know what I 

16 mean, a memorandum, whatever, it doesn't --

17 CHAIRMAN ANDERSON: I mean that 

18 would be, but I am not sure we need that 

19 amount of effort but let's see what you find 

20 and if you think it's all ore issues that make 

21 a significant difference, then clearly you 

22 need to look at it and try to sort out what 
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1 others remain.

2 Certainly ore is one of the 

3 issues, is there any further --

4 DR. MAURO: And right now we think 

5 there are.

6 CHAIRMAN ANDERSON: You think there 

7 are and NIOSH hasn't been through it enough I 

8 guess to really be able to --

9 DR. MAURO: It's good, by the way, 

10 as we go through each finding -- who has the 

11 action? And when we are done with the meeting, 

12 usually what happens is I put together what I 

13 believe to be action items and I will send 

14 them off to NIOSH, say do you agree and then 

15 this becomes our sort of score -- okay, and 

16 everyone knows who has the action.

17 MR. KATZ: SC&A would list their 

18 action items and DCAS would list their action 

19 items and then you would have the whole pool 

20 there.

21 CHAIRMAN ANDERSON: Okay. Finding 

22 two. 
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1 MR. THURBER: There's only 37 

2 findings. 

3 CHAIRMAN ANDERSON: Well, some seem 

4 to be somewhat related to each other. Maybe we 

5 can --

6 MR. THURBER: In part, finding two 

7 is related to finding one because some of the 

8 points we raised relative to finding two deals

9 with ore, deal with radium removal from the 

10 ore and things like that. They don't all but 

11 again some of them deal with that.

12 We quoted in section 4 a number of 

13 other areas like hydrofluorination where we 

14 felt that the TBD-6001 numbers may be 

15 understating things.

16 DR. MAURO: Were there also some 

17 steps that were in the process as you know it?

18 MR. THURBER: Yes. 

19 DR. MAURO: Is that part of two or 

20 is that --? 

21 MR. THURBER: Yes, no, it is, it 

22 may come up later too but -- let's touch on 
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1 it. The authors of TBD-6001 said we haven't 

2 done solvent extraction yet. We are going to 

3 do it. And so, that still remains open.

4 DR. MAURO: Another, we have all 

5 these findings, and we have a lot of findings, 

6 but we are going to find that -- and it looks 

7 like they are all separate but they are not 

8 separate. They cluster nicely very often. 

9 And here's a perfect example, for 

10 example, I think if you're going to be working 

11 on a White Paper, try to -- and if they're all 

12 linked, if there's coupling, that makes sense 

13 because then there's a story here. For example 

14 the story is perfect, you are going to start 

15 talking about the steps in the process.

16 Let's say there are 10 steps to 

17 the refining process, the first three might be 

18 ore-related, but then the rest may be, here's 

19 the step where it's addressed what is a 

20 problem because we think it's not a bounding 

21 number that you're using or you haven't 

22 captured the upper end because we have 
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1 examples.

2 But then there's another aspect to 

3 it. There are steps in the process that are 

4 not even explicitly addressed in TBD-6001 or 

5 perhaps Christifano and Harris.

6 So this is all, these are all 

7 related. This all has to do with the steps 

8 that comprise the process so I don't think we 

9 should hold ourselves hostage to the findings 

10 the way they are. If you find a way of putting 

11 a White Paper together that tells a story that 

12 knocks off three, four, five findings in one 

13 shot, that's great.

14 CHAIRMAN ANDERSON: And the other 

15 thing, as we go through these, that would be, 

16 I mean the real guts of what we need to do are 

17 the three sites that are in the appendices so, 

18 as you say, with 37 here or however many, some 

19 of these, like, what we just talked about, if 

20 that directly impacts the United Nuclear, 

21 Hooker or those, then that, I would say that 

22 pushes that them up to be addressed earlier 
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1 than these other --

2 DR. MAURO: In terms of priority of 

3 issues.

4 CHAIRMAN ANDERSON: Priority of 

5 issues so, you know I think there's a lot of 

6 work, I mean, we have already identified a 

7 couple of things where there's already work 

8 for somebody. So you know, if we don't need to 

9 do it quite as rapidly, let's identify that 

10 now because I think I would like to at least 

11 in a meeting or two, if we can, get through 

12 the sites that we need to address, unless they 

13 are directly impacted by some of these.

14 Because then if we are, then we 

15 need to knock these off before we apply that 

16 to the other sites.

17 DR. MAURO: I think we are going to 

18 find, I mean you bring up an interesting point 

19 in principle, if the real thrust here is let's 

20 deal with United Nuclear and Electro Met and 

21 the two of those don't even depend on TBD22 6001. You know we might be, perhaps we 
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1 shouldn't have started here.

2 CHAIRMAN ANDERSON: No, I think we 

3 needed to start here. As we go through a few, 

4 say "and this relates to" --

5 DR. MAURO: It's Hooker, that's 

6 going to be the one that is going to get 

7 hammered.

8 CHAIRMAN ANDERSON: Well, let's 

9 identify that, even though today we are 

10 talking about these two.

11 MR. THURBER: Well, we are going to 

12 show you an example of how an appendix is 

13 intertwined with the numbers in here to give 

14 you a feeling as to how those things meld 

15 together or attempt to meld together. 

16 CHAIRMAN ANDERSON: Okay. 

17 MR. THURBER: Finding three? 

18 MR. KATZ: So finding two, is sort 

19 of wrapped up with finding one, is that what 

20 it is?

21 MR. ALLEN: Same kind of thing like 

22 John said, I'll try to see if I can intertwine 
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1 responses into one White Paper then I'll do 

2 that. 

3 MR. THURBER: Good. Finding three 

4 deals with an external exposure question and 

5 namely it's how you estimate the external dose 

6 to a worker who is standing on a contaminated 

7 surface and this is also included in TBD-6000. 

8 At the time we prepared our review, we didn't 

9 think it had been appropriately addressed. 

10 Since then, David has written a White Paper 

11 which was presented to the TBD-6000 Work Group 

12 and as indicated in the third column there, we 

13 were satisfied that this issue had been 

14 addressed.

15 There was a minor comment in our 

16 response there, if you will, that there was --

17 it would be helpful if there was some 

18 explanation as to why seven days was used in 

19 TBD-6000 while the year, I'm sorry, there's a 

20 typo there. It should say, "while a deposition 

21 period of one year was used in TBD-6001." 

22 But the basic concept of using a 
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1 terminal settling velocity over a period of 

2 time to come up with a surface contamination 

3 level has been addressed.

4 DR. MAURO: Yes, this was a 

5 longstanding concern that I raised quite a 

6 while ago. The fundamental approach -- I think 

7 there is a point where you conceptually 

8 understand these things, because you can see, 

9 this thread runs through so many sites.

10 The fundamental approach that is 

11 taken in TBD-6000 and 6001 is that, if you are 

12 concerned about the accumulation of uranium on 

13 surfaces, one way you could -- and you don't 

14 have good measurements of what that is -- one 

15 way you could estimate it is, is well, if you 

16 know the dust loading in milligrams per cubic 

17 meter, you can assume that that dust is 

18 falling out of the air, settling out of the 

19 air at 0.00075 meters per second and that's a 

20 good deposition rate, the particles that are 

21 of this nature, like five micron particles.

22 I originally said, gee, you know, 
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1 but that's not how surfaces get contaminated. 

2 They don't get contaminated by just this 

3 respirable dust that is falling on surfaces. 

4 They get contaminated because of these big 

5 flakes of junk coming off machining 

6 operations.

7 Well, it turns out I was wrong, 

8 you know, this was an intuitive thing, I said 

9 I don't believe it. But David took the data 

10 from a very good study that measured the 

11 amount, the rate that stuff is falling out of 

12 the air as 0.00075 and showed that that's 

13 conservative.

14 So we accept that that deposition 

15 rate -- so if you know the dust loading, you 

16 can, from the dust loading alone, figure out 

17 the rate at which milligrams per second per 

18 meter squared, the rate at which it's coming 

19 down can be estimated, very reliably, with the 

20 approach that they are using.

21 Now, the only issue we have is 

22 that, well, you have to assume some time 
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1 period, how long is that going to go now. And 

2 I think our question is, seven days we know 

3 from the Adley report, that equilibrium --

4 this is coming down, right? It sure is coming 

5 down but at the same time it's leaving and we 

6 know that, in the Adley report, it was longer 

7 than seven days, where we believed things 

8 became sort of stabilized, where the 

9 accumulation sort of stayed the same, the rate 

10 of deposition equaled the rate of removal, and 

11 I think seven days is too short.

12 So we still have an issue here, 

13 but it's a narrow one. 

14 MR. ALLEN: So you're actually, I 

15 mean, from that White Paper, the time frame, 

16 depending on what parameters you ratio et 

17 cetera, it was anywhere from 5.8 to 27 days.

18 DR. MAURO: That was that short, 

19 27?

20 MR. ALLEN: TBD-6001 uses 365 days. 

21 The seven days was in TBD-6000.

22 DR. MAURO: Oh, okay. 
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1 MR. ALLEN: Why there's a 

2 difference, you are right --

3 MR. THURBER: It would seem to me 

4 that it would be good for everybody at some 

5 time, if there, if TBD-6000 and TBD-6001 are 

6 set side by side and differing assumptions are 

7 reconciled. But if --

8 DR. MAURO: This is tractable by 

9 the way, very often, I mean this is really 

10 coming to some agreement that, you know, what 

11 assumptions are we -- there is some assumption 

12 that makes the most sense.

13 CHAIRMAN ANDERSON: So is the 

14 assumption then, if you use seven days, that 

15 there is seven days' worth of accumulation on 

16 the floor?

17 MR. THURBER: Right. And it stays 

18 there.

19 MR. ALLEN: And it stays that way 

20 with no removal.

21 CHAIRMAN ANDERSON: And you are 

22 calculating the dose not from the particles as 
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1 they are dropping, you'll have dust in the air 

2 that is emitting external --

3 MR. THURBER: Yes.

4 CHAIRMAN ANDERSON: I mean the 

5 amount of --

6 MR. ALLEN: The route of exposure 

7 that is accounted for but this particular 

8 issue is just the amount of surface 

9 contamination.

10 DR. MAURO: External exposure. Good 

11 way to think about it, again, overarching, you 

12 are going to run across this every time. When 

13 you are in this kind of working environment, 

14 there's submersion, there's the external 

15 exposure you experience because you are in a 

16 cloud. 

17 CHAIRMAN ANDERSON: Yes.

18 DR. MAURO: That dose is always 

19 very, very, very small and easy to calculate 

20 and it never contributes. The other thing is 

21 the stuff that accumulates on the surfaces. 

22 That is -- and you are standing there, so you 
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1 are getting both beta and gamma radiation from 

2 it. That's a little bit more significant and 

3 that becomes important, not only during 

4 operations, while the work is going on, but it 

5 becomes the residual radioactivity that people 

6 are exposed to after operations start, stop, 

7 and so that becomes a very important issue.

8 And right now our position, again 

9 this is a recurring theme, is that we believe 

10 the approach they are using is good, can be 

11 applied for external exposure to residual 

12 radioactivity on surfaces, not only during 

13 operations but also during the residual period 

14 as a way to place a bounding estimate.

15 That third, and that's an 

16 important contributor, but by far the biggest 

17 contributor to external dose is standing next 

18 to a 55-gallon drum of yellowcake, of ore or a 

19 slab of uranium or uranium rods. That's the 

20 big driver. 

21 And on that aspect, we have long 

22 since, and this goes back to TBD-6000, we have 
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1 long since resolved that. In other words, we 

2 are all in agreement that there are 

3 measurements and there are models that confirm 

4 the measurements and so I mean, I think that 

5 that aspect, that third piece of the external 

6 exposure contribution is by and large 

7 resolved.

8 The amount of the surface is close 

9 to being resolved if you could agree how long 

10 you are going to allow this stuff to 

11 accumulate. Is it one year? Is it 28 days? But 

12 I think once that's resolved that problem goes 

13 away.

14 And the other one, the external 

15 exposure from the cloud, we agree with the way 

16 we do that and not only that it doesn't matter 

17 anyway because it never contributes.

18 CHAIRMAN ANDERSON: Yes, well 

19 that's, that's --

20 DR. MAURO: I'm sorry --

21 MEMBER GRIFFON: John, this is 

22 Mark.
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1 DR. MAURO: Yes.

2 MEMBER GRIFFON: I just thought it 

3 might be useful to -- the, you are correct, we 

4 discussed this in TBD-6000, I guess. But you 

5 might want to give a little background, 

6 especially for Bill and Henry on the Adley 

7 report and I think NIOSH developed a White 

8 Paper off of that, right, to sort of support 

9 their position on the deposition?

10 But my other point here is that it 

11 is, as I understood it anyway, it all hinges 

12 on this one study, this Adley report that was 

13 done in Hanford, is that correct?

14 DR. MAURO: Yes.

15 CHAIRMAN ANDERSON: So it, was it a 

16 laboratory story?

17 MEMBER GRIFFON: So I think it's 

18 worthwhile for them to get familiar with that 

19 report, at least to -- if you can give me an 

20 overview that would be great.

21 DR. NETON: It was a little more 

22 than that.
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1 DR. MAURO: It's a great report. 

2 MR. ALLEN: It was a work area at 

3 Hanford, there were various tasks and I'm 

4 trying to remember.

5 DR. MAURO: It did everything. It 

6 is a very large operation --

7 MR. ALLEN: In a small area.

8 DR. MAURO: Hanford metalwork 

9 facility, something -- remelt -- and just 

10 about every type of uranium processing 

11 activity is there and an immense amount of 

12 measurements were made, every aspect, every 

13 step in the process was measured and data were 

14 gathered including setting plates out to 

15 measure the rate at which uranium accumulates 

16 from falling out. 

17 And that was done over an extended 

18 period of time. I forget how many plates were 

19 set out over different seasons, to see if 

20 winter is different than the summer. It is 

21 quite a report, quite frankly. When I read 

22 that I said, this is sort of like the Holy 
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1 Grail. With this document you have the data 

2 indeed to determine whether or not reports 

3 like TBD-6000 and 6001 hold up and have the 

4 data behind it that says, yes, these are good 

5 number. So we rely very heavily on that, that 

6 and certainly Christifano and Harris and there 

7 is one other one. There are several very 

8 important source documents that are the 

9 underpinning of everything we have been 

10 talking about, not only on TBD-6000 and 6001 

11 but also on many of the appendices that we 

12 have been talking about.

13 CHAIRMAN ANDERSON: Okay.

14 DR. MAURO: I know I am talking a 

15 lot but there is one more thing that is 

16 important, and this is this, from the external 

17 point of view I made it a little too simple. 

18 The idea that you have to get a slab of 

19 uranium. Now we know that if you have a slab 

20 of pure uranium, it's two mR per hour. That's 

21 it. That's what you get, it's a penetrating 

22 dose. And if you hold your hand against it, 
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1 it's about 200 mR per hour, penetrating and 

2 non-penetrating dose.

3 Now, but there's one exception. 

4 And we thought that this is more for TBD-6000. 

5 It is when you have freshly cast uranium 

6 ingots, you do get a build-up of some of the 

7 shorter-lived progeny of the uranium, namely 

8 thorium-234, 234 or 238, 234, on the outside 

9 of the ingot, which creates a field that is 10 

10 to 20 times higher than the numbers I have 

11 just told you, very unusual metallurgical 

12 phenomenon.

13 Bill's a metallurgist and to this 

14 day you say you are not quite sure why that 

15 happens, but it happens. It doesn't always 

16 happen but it happens often. So that's a 

17 little nuance to external exposure that's been 

18 a fly in the ointment but I think we have got 

19 to the point in TBD-6000 where that issue has 

20 been resolved.

21 I am trying to paint the broader 

22 picture. We sort of left TBD-6001 but when I 
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1 was talking about external I wanted to make 

2 sure that everybody had a sense that a lot has 

3 been accomplished in coming to grips with a 

4 lot of these issues.

5 CHAIRMAN ANDERSON: So what we have 

6 really to resolve here is seven days versus a 

7 year.

8 DR. MAURO: That, for this issue, 

9 yes.

10 DR. GLOVER: One thing I would like 

11 to mention. Many TBD-6000 sites are mom and 

12 pop shop, small, short, they may only have 

13 four days of rolling in their history, and so 

14 I don't how many TBD-6001 sites have a similar 

15 short-term operations. There may be some very 

16 different reasons why you would perhaps have 

17 some of these -- well, different, they only 

18 roll, they only have four days of operation, 

19 that's it. Why do I use a year?

20 DR. MAURO: And that will be good. 

21 Right?

22 DR. NETON: You have a year of 
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1 operation, typically you are going to have air 

2 samples taken.

3 CHAIRMAN ANDERSON: Yes, I hope so.

4 MR. THURBER: There's no question 

5 that the assumption used in TBD-6001 was 

6 conservative.

7 CHAIRMAN ANDERSON: Yes.

8 MR. THURBER: The 365 days.

9 CHAIRMAN ANDERSON: Yes, okay. 

10 MEMBER FIELD: Let me ask a 

11 question about the contaminated dust. Is 

12 contaminated dust always the same or there's 

13 room for the score to vary depending on the 

14 source?

15 MR. ALLEN: This -- TBD-6000, 6001 

16 are for uranium operations.

17 DR. MAURO: And we are talking 

18 about basically a five micron, AMAD, uranium 

19 oxide. It could be type M, it could be type S 

20 and that's basically --

21 CHAIRMAN ANDERSON: So, it's not 

22 total dust we are really --
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1 DR. MAURO: It's not total -- well 

2 the reason, certainly, there are probably 

3 other dusts but these operations generate 

4 dust.

5 And the measurements could be in 

6 milligrams per cubic meter and we assume that, 

7 you know, all the measurements -- and then --

8 CHAIRMAN ANDERSON: And the 

9 assumption is it's all --

10 DR. MAURO: Yes. Well, they take a 

11 sample and they do a fluorometric analysis or 

12 they will do a gross alpha analysis so you 

13 know it's uranium.

14 DR. NETON: There's one slight 

15 added twist that after 1952 it could be 

16 recycled uranium as it went through some --

17 transuranic contamination to a small extent.

18 MEMBER FIELD: And the 

19 concentration of the uranium in the dust is 

20 not a factor?

21 DR. MAURO: It's all uranium oxide.

22 DR. NETON: When you say uranium 
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1 dust, you mean all uranium. 

2 MEMBER FIELD: All uranium.

3 MR. THURBER: Or it's reduced to 

4 that in the analyses, one way or the other.

5 DR. MAURO: And it's not an 

6 unreasonable assumption because these places 

7 were --

8 DR. NETON: Literally there were 

9 visible clouds of uranium in the air. You get 

10 to 30 milligrams per cubic meter you can see 

11 it pretty easily.

12 CHAIRMAN ANDERSON: Yes. Just as 

13 the uranium -- does it stick to the floor at 

14 all? I mean is it like --

15 DR. NETON: Become fixed?

16 CHAIRMAN ANDERSON: Yes, so that 

17 you, you know, it's like if you have lead, you 

18 would end up with a slick floor from the --

19 MR. ALLEN: It's not as malleable 

20 as lead.

21 CHAIRMAN ANDERSON: No, I know 

22 that. But the issue is when you say it 
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1 accumulates over a year, if they were cleaning 

2 on a regular basis, it still would have some 

3 residual that would be, you know, in the 

4 cement floor.

5 MR. ALLEN: Right, and that's been 

6 the rub all along kind of, it's -- I mean, you 

7 get cracks in the floor, some of this stuff is 

8 very fine powders and it can get down in there 

9 and not come up. The assumptions in the TBDs 

10 are it's all essentially loose and available 

11 for resuspension and that was, when we looked 

12 at Adley, that allowed us to get the rates and 

13 the actual contamination versus airborne 

14 concentrations et cetera and get a better 

15 handle on that.

16 DR. MAURO: Bear in mind, we are 

17 talking about AWE facilities that operated in 

18 the late `40s, early `50s, maybe up to the 

19 late `50s, where these are very dirty 

20 operations and this stuff accumulated on the 

21 floor, they didn't clean it up every day. And 

22 when you talk to workers, what was it like, 
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1 you could see it walking, you would kick it 

2 and it would come up. It is not like -- you 

3 could have a significant amount, but you don't 

4 see it, you know, you could see it, this is 

5 like -- and it was re-suspendable. It gets 

6 crunched on and even if it was a large 

7 particle that fell, it gets crunched up and it 

8 becomes certainly re-suspendable.

9 Now later on, when you have 

10 decontamination, they will say, you didn't 

11 remove that and do some clean-up, well then 

12 there's always an issue, okay, how much of it 

13 is re-suspendable now, and you eventually will 

14 encounter some of that when we get to some of 

15 these sites.

16 CHAIRMAN ANDERSON: Moving right 

17 along, so you guys are going to resolve one 

18 year versus --

19 MR. THURBER: It's not relevant to 

20 this. It's just a matter of, it's more 

21 relevant to TBD-6000's in a sense, to explain 

22 why you picked a short period.
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1 CHAIRMAN ANDERSON: Yes.

2 MR. THURBER: But 365 days for this 

3 group of sites is certainly conservative.

4 MR. ALLEN: In any case it's a 

5 different document altogether, I mean, I 

6 honestly think, and I agree that the 

7 documents, the assumptions made should be 

8 consistent, you know, throughout the 

9 documents.

10 MR. THURBER: Yes.

11 MR. ALLEN: But in this particular 

12 case, I think we can close this particular 

13 finding out, for TBD-6001.

14 MR. THURBER: As far as TBD-6000, I 

15 am satisfied.

16 DR. MAURO: The only point I wanted 

17 to make is, your starting point, though, is 

18 airborne dust loading has been, given that the 

19 airborne dust loading is a good number for a 

20 particular category of operation, that 

21 approach works. But we don't necessarily agree 

22 that the airborne dust loading that was 
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1 selected for a particular operation on the 

2 TBD-6000 over the distribution that was 

3 selected is necessarily the appropriate 

4 distribution.

5 So, you see what I am, that aspect 

6 of it --

7 CHAIRMAN ANDERSON: The cascade, 

8 the front end of the cascade --

9 DR. MAURO: Exactly -- 

10 CHAIRMAN ANDERSON: -- might be 

11 problematic, Okay.

12 MR. KATZ: So, is this finding 

13 closed?

14 DR. MAURO: I would say yes.

15 MR. KATZ: This is for this Work 

16 Group.

17 MR. THURBER: Yes. For this Work 

18 Group, this finding is closed, because what we 

19 are really agreeing on is that the use of a 

20 terminal settling value of 7.5 times 10 to the 

21 minus four meters per second is a good number.

22 Now, the rest of the pieces that 
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1 go to get to an exposure, a dose, as John 

2 says, some of those are still open issues.

3 MR. KATZ: But that's separate. MR. 

4 THURBER: Right, that separate. 

5 MR. ALLEN: Clear as mud?

6 CHAIRMAN ANDERSON: No, no, I mean, 

7 well in the initial response, NIOSH talked 

8 about seven days but in 6001, it specifically 

9 uses one year. 

10 MR. THURBER: And that's fine, it 

11 might increase --

12 CHAIRMAN ANDERSON: I mean this 

13 probably started when 6000 and 6001 were 

14 together, so as far as closing it out, you 

15 need to be very clear it's 6001.

16 MR. KATZ: Right, this Work Group 

17 can't close 6000 issues.

18 CHAIRMAN ANDERSON: Do we need a 

19 vote on that?

20 MR. KATZ: Just as long as it's 

21 clear for all Members that it's closed.

22 CHAIRMAN ANDERSON: Anybody object 
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1 to -- Mark?

2 MR. KATZ: Mark? Mark are you still 

3 with us? Are you on mute? We may have lost 

4 him.

5 DR. GLOVER: He's trying to find a 

6 copy -- we are going to send him a matrix 

7 copy, apparently he doesn't have one so we are 

8 going to try to get him.

9 CHAIRMAN ANDERSON: Oh, okay.

10 DR. GLOVER: We are taking care of 

11 it.

12 CHAIRMAN ANDERSON: Okay.

13 MR. THURBER: Finding four? 

14 CHAIRMAN ANDERSON: Finding four.

15 MR. THURBER: In TBD-6001 there are 

16 two, comprehensive summary tables relating to 

17 external exposures and how external exposures 

18 should be calculated for various job 

19 descriptions, denitration operator, solvent 

20 extraction operator, whatever. But, and within 

21 those categories, the document provides how to 

22 calculate the external dose for operators, for 
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1 laborers, for supervisors and for clerical 

2 personnel. It provides data on various 

3 durations of work weeks because in the early 

4 days, a lot of the operations were probably on 

5 a six-day work week. 

6 So these are quite comprehensive 

7 tables. The fundamental problem we have had 

8 with them is that the transparency and the 

9 traceability of the data that is in them is 

10 not apparent from TBD-6001 and when we get 

11 done with this, I would like to give you an 

12 example of that.

13 So if we could, I would like to 

14 pass on from this until we get through the 

15 rest of the list and then come back to this 

16 with some specific examples of the 

17 transparency/traceability issues related to 

18 external exposure.

19 Oh, the tables also cover the 

20 different external exposure modes that we are 

21 talking about: direct contact; submersion in a 

22 cloud; standing on a contaminated surface and 
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1 it provides exposures for all of those 

2 different environments.

3 CHAIRMAN ANDERSON: And the data 

4 source for that is?

5 MR. THURBER: The data source for 

6 the external exposure is, a lot of it comes 

7 from Mallinckrodt where there were comparable 

8 operations, or it comes from, in the case of 

9 exposure to 55-gallon drums of whatever, it 

10 comes from MicroShield calculations, or from 

11 actual measurements of 55-gallon drums 

12 containing pitchblende ores, that impacts on 

13 the ore thing a little bit, but -- so that's 

14 where the data, virtually all the data in 

15 these tables come from.

16 MR. ALLEN: Yes, plus the type of 

17 calculation we were already talking about, the 

18 air submersion, the surface contamination --

19 MR. THURBER: Yes, that's for the 

20 direct --

21 CHAIRMAN ANDERSON: The source22 terms is more than the calculation --
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1 MR. THURBER: Yes, that's for the 

2 direct exposure, the standing-on-a-cloud comes 

3 from the calculations we have discussed, the 

4 submersion comes from the kind of calculations 

5 we have discussed.

6 CHAIRMAN ANDERSON: Okay. 

7 MR. THURBER: So, I would like to 

8 pass --

9 DR. MAURO: I know, but when you 

10 talk about Mallinckrodt data, you are talking 

11 about, we have a group of workers that we know 

12 were doing a particular operation, they were 

13 wearing a film badge and you can see what 

14 their exposures are, so that is one way you 

15 can get at what kind of exposures.

16 Because those exposures reflect 

17 not only the radiation field the person is in, 

18 but also how long they worked and how close 

19 they worked. Because you know, when you run 

20 the model, what it tells you is, here's your 

21 millirem or microR per hour, at this distance, 

22 at this distance, at this distance, and you 
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1 know those numbers are good.

2 The real question is, well, for 

3 real workers, how long were they standing --

4 how long were they in contact? And that's 

5 where the Mallinckrodt experience helps you 

6 get an insight of what assumptions should be 

7 made.

8 So it's like, the field is one 

9 thing, but those are based on physics 

10 calculations and it's straightforward. The big 

11 question is, how long do we assume a person 

12 is, and at what distance, from this -- what 

13 source, the size of the source, and the type 

14 of source?

15 So, and I think, correct me if I'm 

16 wrong, it's both of those that is the 

17 Mallinckrodt experience and the models that 

18 are married and that's how these tables were 

19 produced, the 7-3, I believe, it's for any 

20 given worker, I would say it's like you said, 

21 a denitration operation or whatever it is, the 

22 exposure distribution that's in there for, 
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1 let's say a supervisor, a matrix table, that 

2 has embedded in it some assumption regarding 

3 duration of exposure, like hours per year?

4 MR. THURBER: Now, I believe that 

5 those are based on actual measurements.

6 DR. MAURO: Okay, so, all right, 

7 all right.

8 CHAIRMAN ANDERSON: So this is 

9 really a surrogate exposure?

10 MR. THURBER: Yes.

11 CHAIRMAN ANDERSON: Because you 

12 are, I mean, mostly your table is generated 

13 based on the distance and the time and stuff 

14 from Mallinckrodt. Then the question is, are 

15 the other facilities, do the workers spend, 

16 are they so identical and the process is so 

17 identical that worker A in nuclear spends the 

18 same amount of time afoot from whatever it is, 

19 and --

20 MR. ALLEN: Like we said from the 

21 start, TBD-6001 is surrogate data, that's 

22 pretty much the purpose of the document and 
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1 then the applicability, as you're saying, is 

2 essentially a site-specific thing. You can't 

3 really judge it on the generic document basis.

4 CHAIRMAN ANDERSON: Okay. We will 

5 come back. Your job is to remember. We're 

6 going to come back at 4:30 and you're going to 

7 be stuck here.

8 MR. THURBER: Okay, finding number 

9 five. This again deals with inhalation 

10 exposures and the issue here is this. 

11 Christifano and Harris provide data from 1948 

12 through 1954, I believe. Some of these 

13 operations began as early as 1942. So the 

14 question is, and certainly there is a lot of 

15 anecdotal evidence that suggests that in the 

16 very early days things were much worse than 

17 they were at the time that Christifano and 

18 Harris began their measurement protocols.

19 And clearly during the course of 

20 the time that Christifano and Harris did their 

21 air sampling, beginning in 1948, there was 

22 continuous improvement, continuous lowering of 
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1 the dust levels.

2 So, in the absence of data prior 

3 to 1948, NIOSH is -- well, the NIOSH approach 

4 was this: they took the average value for that 

5 period where they had data, 1948 to 1954, and 

6 they said the data in the first year where we 

7 have data was 6.8 times higher than the 

8 average, so 1948 was 6.8 times, roughly, 

9 higher than the average for the period `48 to 

10 `54.

11 So we are going to take that 6.9 

12 factor and we are going to use that going 

13 backwards in time and we are going to hold it 

14 at that level back to 1942. And we make some 

15 arguments in our review saying that that is 

16 not claimant favorable, that if you develop 

17 some kind of a regression line for the period, 

18 you will find that the numbers are higher than 

19 that approach would yield. So that is what 

20 underlies this finding.

21 DR. MAURO: Any chance we could put 

22 this up?
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1 MR. THURBER: I don't know.

2 CHAIRMAN ANDERSON: I can see it 

3 becoming --

4 DR. MAURO: Yes, you have probably 

5 seen this if you took a look at the report. 

6 You can see when you go before 19, let's say, 

7 `46 and all the way back to 1942, we deemed 

8 that the correction factors may be too low by 

9 a factor of 10 so for those years, the generic 

10 approach used by TBD-6001 to account for the 

11 early years being worse. But we think that 

12 correction factor is too low and I guess this 

13 is a question worth posing to NIOSH, do you 

14 think that -- there is a correction factor 

15 that can be derived but we think it's about 10 

16 times higher, if you want to go back to 1942.

17 MR. ALLEN: I believe we had, when 

18 the document was created, was you had 

19 essentially a war effort in `42 to `45, about 

20 the last thing on anybody's mind was health 

21 and safety, it was a very low priority. That 

22 same process is pretty much continued until it 
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1 was, the weapons program was turned over to 

2 the Atomic Energy Commission once it was 

3 created.

4 And one of the first organizations 

5 to start worrying about health and safety --

6 not that there was no worry about it -- but 

7 one of the first ones to put some significant 

8 effort into it was the Health and Safety Lab 

9 and that's kind of what created them were 

10 these AWEs, I think the big seven that Naomi 

11 Harley talks about.

12 And you can see that very clear in 

13 the data, that when they started up, 1948, you 

14 see the data as considerably higher than even 

15 1949 and just steady improvement right down 

16 the line.

17 The individual reports from 1948, 

18 it's very clear there was no controls to speak 

19 of at these facilities. They made a lot of 

20 recommendations at least some of which got 

21 implemented and then more and more as they 

22 continued to try to improve.
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1 DR. NETON: Yes, I don't quite see 

2 the basis for a straight-line extrapolation 

3 back if the processes were similar. They only 

4 generate so much dust with certain types of 

5 equipment, and we agreed, this was manual, 

6 shoveling, lifting.

7 DR. MAURO: Let's just circulate --

8 this is my copy -- let's send this around the 

9 table, it's self-explanatory.

10 DR. NETON: I understand what 

11 you're saying, that you're going a straight12 line extrapolation back.

13 DR. MAURO: The question is what do 

14 you do?

15 DR. NETON: The question is why

16 would you believe that a straight-back 

17 extrapolation is appropriate, other than the 

18 fact it's more conservative, because of 

19 process similarities. I mean, you can look at 

20 the equipment being used and say this process 

21 is very similar to what was being done in 

22 1950, 1948, going back, and there's no local 
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1 capture ventilation all those sort of 

2 parameters, you know, I'm having trouble --

3 other than the fact it's more conservative, I 

4 just don't know that that is necessarily going 

5 to make it right.

6 DR. MAURO: I agree with that but 

7 right now we are in this funny place. You see, 

8 you picked 6.8 as your maximum multiplier that 

9 goes all the way back to 19 -- and if you were 

10 to extrapolate according to the graph, it 

11 would be 10 times higher. Now, which is the 

12 right number? I don't know. And you know, in 

13 the world we are in, unless you can make a 

14 case, as you are starting to make right now, 

15 why 6.8 is the right number all the way back 

16 to forty --

17 CHAIRMAN ANDERSON: It couldn't 

18 have been any worse than it was in `48 is what 

19 you are saying.

20 (Simultaneous speaking.) 

21 DR. MAURO: And we are not 

22 convinced of that.
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1 MR. ALLEN: In most cases the 

2 improvements, the slope of that graph is 

3 caused by Health and Safety Lab starting to 

4 sample in that year. 

5 DR. MAURO: So you would argue that 

6 starting in wherever the break point is on 

7 that graph, that before that, that at that 

8 point in time, that's how bad it always was.

9 And then it got better after that.

10 DR. NETON: Especially since you 

11 have no controls for six years, that's about 

12 as bad as it's going to be. It's not like they 

13 --

14 DR. MAURO: Well still, I remember 

15 talking to Bill about this --

16 DR. NETON: Well, we will have to 

17 look at --

18 CHAIRMAN ANDERSON: Well, I mean, 

19 the other issue would be you've got data from 

20 `48 to `56 and you know, will you go back 

21 further than that?

22 You could simply say we aren't 
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1 going to assign, you can't assign, there's no 

2 data from there. All that we know is it was 

3 bad. But we don't know, could it have been 

4 worse? In some of the place, it could have 

5 been better. You never know.

6 DR. NETON: When you look at the 

7 processes, I mean, with that logic I don't 

8 know why you wouldn't do an exponential curve. 

9 I mean, what difference does it make? But I 

10 think we owe it to justify those, that --

11 MR. THURBER: We are not saying 

12 that this is the way to go. As we indicated, 

13 we are merely saying this is an alternative 

14 and I would point out that one has essentially 

15 the same problem in Electro Met when we get 

16 into that, because there was very little data 

17 early in the process and so NIOSH took the 

18 approach that since the process was the same, 

19 that that was not an unreasonable thing to do.

20 We argue in our NIOSH, our review 

21 of Electro Met, I'm sorry, that there was some 

22 evidence to support that assumption and there 
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1 is also some evidence that refutes that 

2 assumption. So it's clearly a question that 

3 needs some more attention.

4 We are the first to admit this is 

5 not the right answer but we don't think a 

6 horizontal extrapolation without good 

7 justification is the way to go.

8 CHAIRMAN ANDERSON: Do we have from 

9 any of these sites workers' testimony? I mean 

10 is there anyone saying, boy, you know, that 

11 was bad in `48 but I was there in `44 and it 

12 was, you know, you couldn't be in there.

13 MR. ALLEN: You are kind of getting 

14 into the issue of this generic document and 

15 you know the applicability to an individual 

16 site. Like we said before, Electro Met, United 

17 Nuclear kind of had their own data. We are not 

18 even really using values out of those, so you 

19 now, you don't get a lot of specific comments 

20 from workers on a generic issue, you know, it 

21 is something to be addressed on an individual 

22 site specific TBDs.
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1 DR. MAURO: I guess a good question 

2 is, you know, when, I guess, when the 

3 measurements were made, they go back to 19 --

4 I guess they started in `48, `46? `48.

5 MR. THURBER: Christifano and 

6 Harris.

7 DR. MAURO: Christifano and Harris. 

8 Now whether or not their data, air sampling 

9 data that go earlier than that, I bet you 

10 there are. I mean we are talking about, I 

11 mean, my guess is they took --

12 DR. NETON: I am not sure.

13 MR. ALLEN: Mallinckrodt you can 

14 find some, other than that, I mean, that's --

15 MR. THURBER: There's a little 

16 Electro Met data in the early period and as I 

17 recall, there was a change where they put in a 

18 vacuum cleaner or something and so on a month19 to-month basis they got a big improvement so 

20 that's some of the kind of information that 

21 may prove relevant to developing a position on 

22 this question.
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1 DR. MAURO: And this is an ongoing 

2 discussion. You know, when you were talking 

3 about, okay, what's a reasonable default dust 

4 load. Now, we are not asking the question, 

5 what's reasonable that represents typical 

6 discussions occur across the complex of AWE 

7 facilities at that time.

8 We are really asking the question, 

9 what's the upper end that it is likely to 

10 represent so that if we are going to pick a 

11 number and we have a guy, and we know a guy 

12 who worked there in 1942 and we are going to 

13 assign some dust load onto him, you don't want 

14 to assign to him your best estimate. You are 

15 going to say listen, I want to assign to him a 

16 number that I am feeling pretty sure it was 

17 not higher than that. You know, we want to 

18 place, we want to give him the benefit of the 

19 doubt.

20 And in our opinion, one of the 

21 recurring themes that we are going to see over 

22 and over again is, there's a difference 
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1 between saying what is a reasonable number 

2 that represents typical conditions at the 

3 facility in a given year and a typical 

4 operation, and what we believe to be the right 

5 number to pick, to assign to a person that you 

6 are sure probably didn't have much of an 

7 exposure that was higher than that.

8 So it's, you know, this 

9 extrapolation is sort of a way to say, you 

10 know, even the numbers themselves, the actual 

11 numbers that are plotted, are we plotting the 

95th 12 percentiles here, of these 

13 concentrations? You know what do you -- I am 

14 always concerned that -- this project is not 

15 concerned with coming up with realistic 

16 estimates of typical workers. It's concerned 

17 with coworker models that provide a level of 

18 assurance that when you assign a number to a 

19 guy, a real person, that you are not 

20 underestimating him.

21 So you always want to pick a 

22 number that you can argue, it's very unlikely 
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1 this guy had a higher exposure than that. And 

2 this curve, I think, that's why this curve 

3 troubles us.

4 DR. BEHLING: John, this is Hans 

5 Behling. Can I make a comment here?

6 DR. MAURO: Sure.

7 DR. BEHLING: One of the things 

8 that I looked at when I looked at MetLab, 

9 which is really time zero for this whole 

10 program, and that is, and you'll see it 

11 referenced throughout some of the TBDs or Site 

12 Profiles in the early years, and that is the 

13 tolerance level and when you look at the 

14 tolerance level it gives you some 

15 understanding how high the air concentrations 

16 could have been without concern for the 

17 protection of workers.

18 And in my reports for the Met Lab, 

19 and it was part of the 250 day issue, I cited 

20 tolerance levels that were astronomical by 

21 today's standards and clearly define a very, 

22 very different set of acceptable limits for 
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1 air concentrations, body burdens et cetera.

2 DR. MAURO: So, I think, to close 

3 this down, when you addressed this issue of 

4 extrapolation back in `42, you can make your 

5 case whether it's flat or it goes up, I think 

6 it's important also to, the overarching thing 

7 is that when we go back in time, you want to 

8 do it in a way that we can say with a degree 

9 of confidence, it's unlikely that anyone would 

10 have experienced an annual exposure higher 

11 than this dust loading -- not the best 

12 estimate, because that would be claimant 

13 neutral. If you picked the best estimate, you 

14 are being claimant neutral. You want to be, 

15 you want to make sure that all workers that 

16 worked at that time are unlikely to experience 

17 concentrations higher than that over the 

18 course of a year. 

19 We realize in any given day the 

20 numbers can be very high but over the course 

21 of a year, you know, the exposure a person 

22 might have experienced because of his job, 
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1 unlikely to be higher than this.

2 DR. NETON: Well, I think we've had 

3 the action --

4 CHAIRMAN ANDERSON: Yes. 

5 DR. NETON: -- in this document, 

6 why we believe our values are appropriate.

7 MR. THURBER: So are we good on 

8 finding five?

9 CHAIRMAN ANDERSON: Yes. 

10 MR. THURBER: Six. This relates to 

11 the fact that radon was not included. I think 

12 that given what David said earlier, that we 

13 can probably pass this on by, if that's 

14 agreeable to everyone?

15 MR. ALLEN: That was going to be my 

16 response so --

17 DR. MAURO: If there's no water, 

18 there's no radon.

19 DR. NETON: So that's close.

20 MR. THURBER: Now we have a number 

21 of observations. These should go more quickly, 

22 because the more generic issues were findings 
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1 -- the first observation deals with the fact 

2 that it would be helpful if some basis for the 

3 selected time period was provided. It just 

4 appeared as `42 to `58. Why? 

5 And we noted that in another place 

6 in the document it said `44 so this is a -- I 

7 don't think it requires much more discussion 

8 than that, but if anybody has any clues?

9 CHAIRMAN ANDERSON: Fifty-eight end 

10 is --

11 MR. ALLEN: That's I believe the 

12 end of the data was `58. And the beginning 

13 was essentially meant prior to `58 and you can 

14 see where we went to some effort to try to 

15 back-extrapolate prior to the data showing and 

16 whether you agree with that or not, the basis 

17 was prior to `58.

18 MR. THURBER: Observation two. 

19 Actually, we already touched on this. The TBD20 6001 said that data on the solvent extraction 

21 step was under development and that's probably 

22 worth an indication of what is going to happen 
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1 with regard to that piece of the operation.

2 MR. ALLEN: Again, frankly, we 

3 haven't found any situations where we needed 

4 that information. I mean, this solvent 

5 extraction pretty much happened at the bigger 

6 sites where we have data from that site 

7 instead of needing the generic numbers. So --

8 MR. THURBER: Mallinckrodt 

9 attributable. Yes. Okay.

10 MR. ALLEN: Yes, Fernald and 

11 Mallinckrodt. I don't know if we actually 

12 intend to fill that in until it's needed.

13 MR. THURBER: Again, if you revise 

14 the document, you might say that.

15 MR. ALLEN: Yes.

16 CHAIRMAN ANDERSON: Well, yes, I 

17 mean if you're saying it's under development 

18 but it isn't, you could simply change that to 

19 say, do you recognize this is an issue but up 

20 to this point, it doesn't seem to be a generic 

21 assessment that's needed.

22 MR. THURBER: Perfect.
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1 CHAIRMAN ANDERSON: That way, it 

2 would lay it to rest.

3 MR. ALLEN: If we were to revise 

4 the document.

5 CHAIRMAN ANDERSON: Again, if it 

6 says it's under development and you say well, 

7 yes, we are working hard on it, we don't need 

8 it, but we don't need it, we don't need it. 

9 Okay. 

10 MR. THURBER: Observation three 

11 relates to ore handling and radon exposures 

12 and that's been addressed. 

13 DR. MAURO: That's like a radon 

14 problem. Radium-226 and thorium-230 go away if 

15 you don't have water.

16 MR. THURBER: Okay. 

17 CHAIRMAN ANDERSON: So --

18 MR. KATZ: It's a non-issue.

19 CHAIRMAN ANDERSON: We need to 

20 state up front though, that these facilities 

21 don't contain these?

22 DR. MAURO: No, this TBD --
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1 MR. THURBER: This document doesn't 

2 cover --

3 DR. MAURO: Doesn't cover that.

4 MR. THURBER: Doesn't cover floor 

5 handling.

6 MR. KATZ: That's handled in the 

7 finding one, already handled by the finding 

8 three decision.

9 CHAIRMAN ANDERSON: Yes.

10 MR. ALLEN: There's some action 

11 necessary but it's covered in the finding.

12 DR. NETON: I frankly wonder if 

13 there is a little more than that, though.

14 MR. KATZ: This is handled by that. 

15 DR. NETON: It is, but maybe these 

16 could be like, marked held in abeyance until 

17 the document is revised to state that.

18 MR. ALLEN: Well, they're covered 

19 under finding one and two and --

20 DR. MAURO: That's what I was 

21 saying earlier.

22 MR. ALLEN: Where, you know, we 
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1 just need to go on without that.

2 DR. NETON: Well, what I'm saying 

3 is that these can be specifically closed right 

4 now, if we just say we are going to revise the 

5 documents and say it's not applicable. But you 

6 can't close finding one just by saying that. 

7 That's my point.

8 DR. MAURO: Oh, okay, I see what 

9 you are saying.

10 MR. THURBER: No, I understand.

11 MR. ALLEN: What is the process on 

12 observations? Are we closing these? Are we 

13 treating them like findings or are they just 

14 noted?

15 MR. THURBER: I think some of these 

16 require some action as we'll see.

17 DR. MAURO: In the past, some of 

18 our authors feel that it's important to 

19 separate things that we really think that are 

20 important from things that are less important. 

21 I think even though something might in the 

22 author's judgment 
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1 be designated as an observation, I would not 

2 automatically say that this need does not to 

3 be addressed.

4 In fact, when I was looking at 

5 these observations, some of them I would have 

6 called findings. So I think that though they 

7 have been categorized, some clearly are 

8 observations that are really not that 

9 important and in fact we have a whole section 

10 where we found typos and inconsistencies, all 

11 of which have to be cleaned up, so, house 

12 cleaning.

13 But I think some of these, I 

14 wouldn't discount some of these yet so I would 

15 like to go through the observations.

16 CHAIRMAN ANDERSON: Yes, I want to 

17 go through them --

18 DR. MAURO: And they need to be 

19 addressed.

20 CHAIRMAN ANDERSON: I'm also 

21 thinking in terms of the rest of the Board, 

22 when we come back to them they are going to 
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1 have this matrix and somebody is going to say, 

2 well, what about this? 

3 So somehow we need to have at 

4 least a mention in here that, you know, 

5 observation three, that because this, 6001 

6 address doesn't address ores that contain or 

7 processes that --

8 DR. MAURO: Let me ask you, when we 

9 reissue this matrix, there's a column called 

10 "NIOSH initial" -- the next column over you 

11 see is the response. Basically we deferred the 

12 response.

13 CHAIRMAN ANDERSON: Yes.

14 DR. MAURO: Are you folks going to 

15 fill that in? 

16 MEMBER FIELD: Yes, we'll fill that 

17 in.

18 MR. ALLEN: Yes, we can, I was just 

19 having a hard time with that very first 

20 finding on the, telling you this was, ore was 

21 not associated with it, to address these is 

22 more of a big White Paper rather than a 
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1 paragraph or a sentence and --

2 DR. MAURO: Well, I can see on the 

3 radon and the thorium-230 and the radium-226, 

4 simply say this issue is being addressed under 

5 finding one.

6 MR. ALLEN: Yes, I think most of 

7 the observations are going to be a one 

8 sentence --

9 MR. KATZ: For finding one, in the 

10 matrix, you can just write, "White Paper 

11 addresses."

12 MR. THURBER: Yes. But recall now, 

13 as Jim said, as we expanded our discussion on 

14 finding one, we pointed out there were several 

15 places that went beyond the ore question and 

16 that's why, again, as Jim said, we shouldn't 

17 pile a lot of these things into finding one. I 

18 think a simple statement that TBD-6001 was not 

19 intended address ore processing or something 

20 to that effect, does that job.

21 DR. NETON: Because that way you 

22 don't have to rely on closing finding one to 
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1 close all these other things.

2 DR. MAURO: You could close this.

3 I understand what you are saying. I am fine 

4 with that.

5 MR. THURBER: Absolutely. 

6 Absolutely.

7 DR. MAURO: I'm fine with that.

8 CHAIRMAN ANDERSON: Okay, why don't 

9 you --

10 DR. MAURO: Because of one item, 

11 right. 

12 MR. THURBER: Observation four 

13 points out that there is no discussion of 

14 handling recycled uranium or enriched uranium, 

15 the ores we have already talked about. It 

16 seems at a minimum there should be a statement 

17 of intent that this is not intended to address 

18 sites that handle recycled uranium or enriched 

19 uranium or some provision as to how those 

20 should be handled.

21 MR. ALLEN: Yes, it actually, there 

22 actually is a table in there with the, on page 
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1 five of the TBD that has the recycling, 

2 recycled uranium components, plutonium, 

3 neptunium, technetium et cetera. It says to 

4 address those after 1952.

5 MR. THURBER: I missed it I'm 

6 sorry. Yes, I mean it's, it should be, you 

7 know, tell us that.

8 MR. ALLEN: I know. That part is in 

9 there. The enriched uranium it doesn't 

10 mention, and just like it needs to be revised 

11 for -- but you know, make it clear that it 

12 doesn't cover ore, I think it also needs to 

13 mention that about the enriched uranium, I 

14 think you're right on that one.

15 MR. THURBER: Good. Observation 

16 five. The document says that you should use a 

17 default air concentration of seven dpm per 

18 cubic meter for non-operational areas.

19 That requires some further 

20 discussion I think, because if you look at 

21 some of the available data for clerical people 

22 and others in the Mallinckrodt documents, 
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1 you'll find that nurses and whatever are 

2 exposed to higher levels than seven dpm per 

3 cubic meter.

4 So it seems to me that either you 

5 need to think a little bit more about whether 

6 that is an appropriate default value, or 

7 somehow explain what non-operational areas of 

8 the plant are, or both.

9 MR. ALLEN: Yes. I am --

10 CHAIRMAN ANDERSON: Let the record 

11 show he's nodding and shaking his head at the 

12 same time.

13 MR. ALLEN: I understand the 

14 comment. It's difficult in a generic basis to 

15 address this kind of thing rather than site16 specific. I mean I'll come up with some sort 

17 of response for this matrix at least but I'm 

18 not clear where I go at this point.

19 MR. THURBER: Well, if there's, if 

20 there's data that says that seven dpm per 

21 cubic meter is not a good number, then you can 

22 think about revisiting that number.
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1 CHAIRMAN ANDERSON: What's the 

2 basis of the number?

3 MR. ALLEN: I don't know. I was 

4 going to say I don't recall off the top off my 

5 head.

6 MR. THURBER: It somehow is tied in 

7 with one percent of 100 MAC or something like 

8 that.

9 CHAIRMAN ANDERSON: But it isn't 

10 based on measurements or anything?

11 MR. THURBER: No. It was based on -

12 - 

13 DR. NETON: I think a lot of this 

14 depends on what we define as a non-operational 

15 area. Maybe that needs to be clarified.

16 MR. THURBER: Well, that's why I 

17 say, that's a possibility and, but I did 

18 notice somewhere that --

19 CHAIRMAN ANDERSON: So it's a 

20 calculate --

21 MR. ALLEN: I mean, it gets 

22 difficult --
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1 CHAIRMAN ANDERSON: You could call 

2 it a bottled number.

3 MR. ALLEN: I mean, when you're 

4 having a hard time with them sampling 

5 operational areas and you know they are not 

6 sampling all of them. You can see there's not 

7 a lot of data for office buildings and that 

8 sort of thing.

9 DR. MAURO: These rules of thumb, 

10 we run into this seven dpm per cubic meter and 

11 on a number of occasions we have seen it as 

12 being, we are going to assign this -- and 

13 their rationale originally, as I recall, was 

14 that, there was an observation that when you 

15 were measuring numbers in an operational area, 

16 then you went off some place where there 

17 wasn't an operational area, in general the 

18 concentrations in the non-operational area are 

19 about one percent of the concentrations in the 

20 operational area. 

21 Now, the implications being that 

22 operational areas in these kinds of facilities 
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1 typically have 700 dpm per cubic meter. So, 

2 therefore seven dpm per cubic meter is 

3 probably a good number for a non-operational 

4 area.

5 So I think there are two aspects 

6 to this issue. One is, is 700 a good number to 

7 represent a bounding concentration for an 

8 operational area at these classes of 

9 facilities, and yes, we agree that the one 

10 percent, because we see the data, that yes, on 

11 many occasions we see non-operational areas 

12 are much, much lower than operational areas 

13 and the issue becomes, all right, from an 

14 implementation point of view, you have got to 

15 be careful when you do that.

16 And Bill, you gave lots of, 

17 several examples on page 20 of this report 

18 where it shows that there are places where 175 

19 dpm, per cubic meter, this was a dispensary at 

20 a facility. Another location where some 

21 numbers as high as 50 were observed.

22 Now, whether or not the average 
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1 over the course of the year, which is what you 

2 can do when you do these dose reconstructions, 

3 or whether, you know, what do you, the 1.5 to 

4 175 for example for the dispensary, were those 

5 annual average or those individual 

6 measurements? I'm not sure.

7 DR. NETON: Also, were those at a 

8 facility that only processed uranium and not 

9 uranium ore? That can make a big difference.

10 DR. MAURO: Yes, okay.

11 DR. NETON: We measured some short12 lived daughters in there -- 

13 DR. MAURO: And I will be the first to 

14 admit I'm not --

15 DR. NETON: I would be surprised if 

16 it would be several MAC --

17 DR. MAURO: I understand but when 

18 you see these numbers track --

19 DR. NETON: If you get airborne 

20 though, I mean, this sounds to be --

21 DR. MAURO: I would, again, this 

22 is, I would agree, the fact that you went into 
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1 a dispensary and at one point in time picked 

2 up 175 dpm per cubic meter in a given day, 

3 that doesn't mean that's what you're going to 

4 experience over the course of a year.

5 And I think that, you know, so if 

6 you're go with the seven, you have got to make 

7 your case a little stronger.

8 DR. NETON: I guess we are not 

9 arguing, we just -- prepare some kind of 

10 response.

11 DR. MAURO: And this crosses a lot 

12 of sites, where I've seen this number at least 

13 10 or 12 times.

14 DR. NETON: You have got to come up 

15 with some kind of lower bound, I mean, 

16 sometimes we have used like 10 percent of the 

17 air concentration and one percent of the 

18 actual value in the plant. But --

19 MR. ALLEN: Well, many of these 

20 smaller sites, we don't have the information 

21 to place somebody in an office versus an 

22 operational area and you end up essentially 
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1 putting everybody in the operational area.

2 DR. MAURO: You give them the big 

3 one anyway. 

4 MR. ALLEN: It's moot in most of 

5 these facilities. 

6 DR. NETON: We don't know whether 

7 the secretary had walked through the plant. 

8 CHAIRMAN ANDERSON: Yes, I mean, 

9 the practical reality --

10 DR. MAURO: We don't use it.

11 CHAIRMAN ANDERSON: It would be 

12 nice to know, when we argue over something 

13 like previously has never been used, if this 

14 is, if we are just kind of doing this for 

15 completeness sake, well --

16 MR. ALLEN: Honestly, I think 

17 that's the situation. I can't say as we had 

18 actually ever used that number but it is 

19 there.

20 CHAIRMAN ANDERSON: Okay. 

21 MR. THURBER: Observation six. The 

22 comment is that the document doesn't tell you 
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1 how the doses are apportioned from between the 

2 operators, laborers and supervisors and so 

3 forth. Now, I presume that if you read on to 

4 the next section of the document, it tells you 

5 how it's done there, which was the section on 

6 internal dose. So this is kind of perhaps kind 

7 of a cheeky comment, but it's just one of 

8 those things that makes the functionality of 

9 TBD-6001 a little troublesome.

10 You know, you don't tell me, 

11 anybody, a viewer, and this is a problem, some 

12 of these are problems more for the reviewer 

13 than the user. The information is not 

14 provided.

15 MR. ALLEN: Well, not conveniently 

16 anyway.

17 MR. THURBER: I mean, it's only 

18 provided by inference, you know, you tell me 

19 what you are going to do with the internal 

20 dose.

21 DR. MAURO: When I was looking at 

22 this, it seemed to me that how, the sorting 
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1 of, we're going to, supervisors we are going 

2 to assign this distribution, and laborers we 

3 are going to assign this distribution. It 

4 wasn't apparent how you got there from the 

5 Christifano and Harris data, the data behind 

6 that. How did you do it?

7 I mean I would like to be able to 

8 go in and say, here's the 20,000 measurements. 

9 I could reasonably sort them by people, say 

10 okay, you know, 1,000 of them were people that 

11 we could say were supervisors and we know 

12 that, pull them out, then I could say and look 

13 at that number, the numbers for the 

14 supervisors that are in that 20,000 

15 measurements and say, oh yes, that 

16 distribution, that is a sign you can use for 

17 supervisor, it looks pretty good. We can't do 

18 that. Right now, we can't do that and I think 

19 that's needed. That's the front end of the 

20 problem that clearly goes towards this report. 

21 And then of course the more difficult problem 

22 is when you eventually use -- let's say it 
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1 turns out that is good, let's say the numbers 

2 you have picked for supervisors, the 

3 distribution that's in there, the dust 

4 loading, is -- you go back and you check it 

5 and you find out yes, those are good numbers.

6 Then you have the headache of 

7 saying all right, now I have a real site, I 

8 know this guy worked at the site and he was a 

9 supervisor, sometimes you have them, yes, he 

10 was a supervisor. But we always run into this 

11 situation. The name of a person's job, for any 

12 given individual, is always troublesome 

13 because we find out when we interview workers 

14 that yes, I was a supervisor but I used to 

15 spend my time all over the place.

16 And it almost becomes, when we do 

17 -- I do a lot of dose reconstruction audits 

18 and I see that they took a guy, looked at what 

19 his job was and he described himself, and they 

20 might drop him into a category when it's not 

21 apparent that that's the most claimant 

22 favorable assumption.
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1 So you know, that's the back-end 

2 of the problem, that is, even if you have a 

3 good distribution for supervisors, when you 

4 get a real good case, do you use that or do 

5 you say no, I'm just going to give this guy 

6 the benefit of the doubt and assume that he 

7 also, he might have been exposed to something 

8 higher?

9 So I, this matrix, when it's time 

10 to implement it, is a problem, especially if 

11 you get a guy who ends up getting a 45 PoC and 

12 the reason he got a 45 PoC is because you 

13 assigned him as a supervisor and there's some 

14 question of well, how do we know he always was 

15 in that mode and maybe he spent a lot of time 

16 someplace else. And this is not unusual. You 

17 talk to these workers and you find out these 

18 labels, these designations mean very little. 

19 MR. THURBER: On that subject, I 

20 would mention that TBD-6000 specifically says 

21 if you have doubt as to what the worker's job 

22 description was, use the maximum values and 
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1 that is very good guidance and it would be 

2 nice if that same kind of guidance was in TBD3 6001 to kind of clarify, demystify that 

4 question.

5 MEMBER FIELD: That sounds like a 

6 different issue though, I mean, it's like, it 

7 sounds like you are sure but you question how 

8 reliable that category is, versus you are not 

9 very sure, I understand what you are saying 

10 but it seems like two different issues.

11 CHAIRMAN ANDERSON: Well, I mean, 

12 if this, as a generic guidance for surrogate 

13 data, the question is, okay, now you are at a 

14 facility where the guy -- it's a plant that 

15 would be a 6001 and he says he's a laborer but 

16 there's no data from the site. And now you are 

17 going to go to 6001 and say he's a laborer, go 

18 to the table and this is how we are going to 

19 assign his exposure.

20 So really the question is, how 

21 confident are you that a laborer in this 

22 facility is the same as a laborer, I mean, you 
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1 use the example of a supervisor, that's 

2 probably more problematic because somebody 

3 doesn't show, it's a small work force, 

4 supervisor steps in because he knows all the 

5 jobs, those kind of things, where once you are 

6 a mechanic or you are a whatever, you are 

7 shifting back and forth maybe not as much.

8 So, I mean, how confident are we 

9 that the variability between what a laborer is 

10 in one place versus another in a different 

11 part the country, in different unions, all of 

12 that. Is that something we can use or do we 

13 need a default, let's say, that if you don't 

14 have site-specific --

15 MR. ALLEN: I think people do get 

16 kind of hung up over the titles in this thing. 

17 But essentially what we try to do is the 

18 operator is somebody that's routinely 

19 operating with the material, or the equipment 

20 that is containing the material; supervisor or 

21 laborer is usually somebody that is routinely 

22 in the area but not necessarily hands-on 
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1 working with the material; the other --

2 CHAIRMAN ANDERSON: You will 

3 probably need to then have a definition -- you 

4 know that kind of a --

5 MR. ALLEN: Yes, I agree. I agree.

6 CHAIRMAN ANDERSON: Because I 

7 think, I mean, when they say it to me, I tend 

8 to place their job title into a union -- or 

9 something more, you know, what you're saying, 

10 it really isn't, you are looking at what the 

11 work was and now you are, instead of having 

12 everybody being unique, you are now saying 

13 this person fits this work profile, this 

14 exposure profile of a --

15 MR. ALLEN: Our dose reconstructors 

16 are well aware of that. The term I always use, 

17 the job title I always use is clerk. That can 

18 mean anywhere from a payroll clerk in an 

19 office building to a materials control and 

20 accountability clerk that is stamping numbers 

21 in uranium ingots.

22 So yes, we realize we have got to, 
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1 we do do a telephone interview on the 

2 individuals, as much information as we can get 

3 there, from what we know of the site, and job 

4 titles there, and we try to, you know, case5 by-case, put it all together and put them in 

6 the right category. That's, I think, way off 

7 the topic.

8 DR. MAURO: Our primary concern is 

9 that we could not track the distributions for 

10 supervisors, laborers and clerks, the data 

11 distribution that is in the look-up table back 

12 to the original 20,000 measurements and how 

13 they were created, you know, like -- this is 

14 what we could say, yes we looked at this. 

15 Because one of the things we try 

16 to do, especially when we are doing SEC17 related issues, I mean, you know, you are 

18 saying, wait a minute, let's look at the data, 

19 and right now, you know, that hasn't been done 

20 and I think it's important.

21 This is the rock you are going to 

22 stand on for many sites, at least five anyway, 
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1 and we have to look, we have to see that data 

2 and a case has to be made why that 

3 distribution is the right distribution for a 

4 person that you know was a supervisor. Whether 

5 or not you are going to assign it to that 

6 person, that's another question.

7 CHAIRMAN ANDERSON: Okay. So you 

8 know --

9 MR. ALLEN: I think I know what the 

10 question is.

11 CHAIRMAN ANDERSON: Whoever is 

12 going to be next filling out the matrix, they 

13 need to, you know, have we made what we want 

14 clear enough for you? Okay.

15 MR. THURBER: Are we okay? 

16 CHAIRMAN ANDERSON: Yes. 

17 MR. THURBER: All right. 

18 Observation seven. In using the Christifano 

19 and Harris data, what NIOSH does is they take 

20 the raw data by the various categories, like 

21 denitration, and they convert the raw data to 

22 an assumed log-normal distribution and they 
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1 calculate the geometric mean and the geometric 

standard deviation and the 95th 2 percentile, if 

3 it's appropriate, or whatever.

4 So for each of the data tables 

5 which come, the raw data tables which come 

6 directly from Christifano and Harris, NIOSH 

7 prepares a companion table where they show the 

8 log-normal statistics that they have derived 

9 from the raw data.

10 One of the problems is that in 

11 several cases, the tables show the geometric 

12 standard deviation as less than one, which it 

13 cannot be. 

14 CHAIRMAN ANDERSON: Well, we don't 

15 have statistician here, so -- we can't argue 

16 with you on that.

17 MR. ALLEN: That would be a tough 

18 argument anyway. 

19 DR. NETON: It's a calculation 

20 error.

21 CHAIRMAN ANDERSON: Or a typo.

22 MR. ALLEN: I think it's a typo. I 
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1 am still digging into the numbers.

2 MR. THURBER: The observation 

3 eight, as John mentioned, as we went through 

4 this, we just as an aside made a list of typos 

5 and fuzzy statements and things that might or 

6 might not be helpful to NIOSH when and if they 

7 do revise the document so I don't think that 

8 requires any further discussion.

9 CHAIRMAN ANDERSON: What is the 

10 process for fixing these kinds of things?

11 MR. ALLEN: Well, I mean, we can 

12 revise the document, ideally we would settle 

13 or come to a resolution on all the findings 

14 and issues and revise it one time rather than 

15 piecemeal put a whole bunch in there.

16 CHAIRMAN ANDERSON: I mean, when we 

17 do it, not on this kind of a thing, you fix it 

18 and now you put it up on your database as the 

19 revised and give it a new number and it's not 

20 as though you have to go through any kind of 

21 real laborious approval and 17 sign-offs.

22 DR. NETON: Well, we have our 
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1 review process but it's all internal. 

2 CHAIRMAN ANDERSON: Okay.

3 DR. NETON: We don't submit these 

4 for external review at this point. It's not 

5 that difficult, it would be Revision 1 at this 

6 time.

7 CHAIRMAN ANDERSON: Yes.

8 DR. NETON: And we keep the old 

9 revisions so there's a paper trail. But we 

10 would want to get some resolution on this 

11 issue.

12 CHAIRMAN ANDERSON: I mean, at some 

13 time, we'll have accumulated enough of these 

14 that, you know, rather than wait for final 

15 resolution, we got all of this stuff kind of 

16 rolling around there.

17 DR. NETON: The good news here 

18 though I think is not many dose 

19 reconstructions, if any, have been done 

20 against the findings that we are seeing.

21 CHAIRMAN ANDERSON: Well, that was 

22 going to be my next question.
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1 DR. NETON: And that's the good 

2 news, so when we revise it, we are probably 

3 not going to have to go back and redo a lot of 

4 dose reconstructions. That might not be true 

5 100 percent, but I think it's true as far as I 

6 can think.

7 CHAIRMAN ANDERSON: All right. 

8 Moving right along. 

9 MR. THURBER: All right. 

10 Observation nine, we noted what appeared to us 

11 to be a calculational error in calculating a 

12 specific geometric standard deviation.

13 MR. ALLEN: I don't disagree. It 

14 goes along with observation seven, there are 

15 some typos or calculational errors.

16 MR. THURBER: Yes, and actually 

17 there are a number of other ones and David and 

18 I have discussed some of these and we will get 

19 into a couple more of them but probably there 

20 ought to be an audit of the data, the data 

21 tables in general. As we have pointed out in 

22 our review, we did not go in and look at every 
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1 number in TBD-6001. We just did a few spot 

2 checks and some of these observations are 

3 really a result of things that we have been 

4 doing since then we have tried to use it or 

5 apply it to some other site-specific things.

6 DR. MAURO: I have to say that when 

7 both Bill and I looked at this, we felt that 

8 this document was rushed, that its errors, it 

9 is not -- it is as if they tried to rush it 

10 out real quick. Too many inconsistencies, too 

11 many typos, we have a whole list, two pages of 

12 it. And I think we could slow the train down, 

13 take a look at this thing and clean it up. 

14 This is not one of the better TBDs. There's a 

15 lot of problems.

16 MEMBER FIELD: Can I ask you a 

17 question? For the geometric standard 

18 deviation, did you have data to figure out if 

19 any of them are correct?

20 I am just curious if it is a 

21 systematic error in whoever calculated the 

22 GSDs or it's just anecdotal or just every now 
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1 and then you see one. I just wonder if you 

2 found any correct ones.

3 MR. ALLEN: They -- I have a 

4 spreadsheet on what they used for most of the 

5 -- actually, several spreadsheets and I am 

6 missing pieces of the data here and pieces of 

7 the data there and I am trying to get a hold 

8 of the original author to --

9 MEMBER FIELD: That would be 

10 interesting to see.

11 MR. ALLEN: Yes. Yes.

12 CHAIRMAN ANDERSON: But this is 

13 three, four years old?

14 MR. ALLEN: Yes. If it was a 

15 contractor who no longer works for us --

16 CHAIRMAN ANDERSON: You were 

17 dealing with this two-and-a-half years ago and 

18 probably took two years to put together so --

19 we are looking at history here at a time when 

20 the program was rushed and hurrying.

21 MR. ALLEN: The effective date is 

22 December `06.
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1 MR. THURBER: Procedurally, there 

2 is a companion document which we mentioned 

3 here called Strom 2006 or something, which is 

4 a statistical compendium as how to apply log5 normal statistics or whatever to various 

6 situations and presumably the authors of this 

7 document used that compendium, which gives you 

8 some straightforward cook-book procedures, if 

9 you will, on how to calculate these statistics 

10 from very limited data.

11 DR. NETON: This document is under 

12 contract with Battelle.

13 MR. THURBER: Okay? Again, probably 

14 a minor point, but some of the confusing 

15 instructions that TBD-6001 provides, it says 

16 in one sentence, it says, "Use the default 

17 values above" and then in the next sentence it 

18 says, "Don't use the default values above, use 

19 ICRP 66." 

20 And in looking further, we don't 

21 think that ICRP 66 is the correct reference. 

22 We think it should be ICRP 68.
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1 MR. ALLEN: Yes, I actually 

2 remember that one. It was the first three or 

3 four parameters are definitely 66 and then it 

4 mentions the solubility at F1 value which then 

5 comes from 68 and that is why somebody decided 

6 you cannot say use defaults from 66 and 

7 changed it to use the table above and 

8 apparently didn't get a sentence deleted.

9 MR. THURBER: Anything further on 

10 that?

11 CHAIRMAN ANDERSON: No. Pretty 

12 straightforward.

13 MR. THURBER: Observation eleven, I 

14 think we can pass on because that again 

15 relates to the settling assumption, which, as 

16 we have discussed earlier, has been resolved.

17 Observation twelve is virtually 

18 the same as the previous observation, dealing 

19 with the basis for the seven dpm per cubic 

20 meter air exposure in non-operation areas. I 

21 take it you covered that.

22 And observation thirteen. 
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1 CHAIRMAN ANDERSON: So back to 

2 seven, that's kind of a default value, but on 

3 a site-specific basis? Would you use the 

4 percentage issue or not?

5 I mean let's say you had a 

6 facility where this is based on the 700 value 

7 in an operational, now if you had one where 

8 the operational value was 1,000, would you now 

9 use the one percent increase from seven to 10 

10 or would you only use the seven or is it at 

11 all tied to any data at the site or is the 700 

12 the max at all of these facilities?

13 MR. ALLEN: It's kind of the catch14 22 question, you know, if you have the data at 

15 the site you generally don't use the default 

16 values in here that we are talking about so 

17 it's --

18 CHAIRMAN ANDERSON: Okay. But if 

19 you had, I mean you wouldn't have a non20 operational result typically in any facility, 

21 so would you then use a percentage basis 

22 thing?
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1 MR. ALLEN: Typically, we would use 

2 some percentage of the operational value then.

3 DR. NETON: I just looked up the 

4 pedigree of those values where they were high 

5 and that was a Mallinckrodt value data which I 

6 think are most suspect because of the radon.

7 There are hundreds of MAC radon 

8 air, hundreds of picocuries per liter of radon 

9 there and even if you are left with some decay 

10 you are going to get some high concentrations.

11 CHAIRMAN ANDERSON: Okay, sorry. 

12 MR. THURBER: No problem. Look the 

13 final point, I'm sorry there's a typo, it 

14 should refer to section 8.5.2, and section 

15 8.5.2 deals with resuspension of dust when 

16 operations are not going on, either they are 

17 suspended between campaigns or after the 

18 processing has been finished.

19 And the calculational approach in 

20 that section is different from the 

21 calculational approach in the prior section 

22 3.4.2 in the same packet. And in part, it 
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1 deals with the number of days that the 

2 deposition occurs, it appears in the section 

3 8.5.2 that the deposition occurred over some 

4 strange number of days and to your earlier 

5 section, it was over 365 days. So there's 

6 something that seems amiss there.

7 MR. ALLEN: I didn't think that was 

8 the case. I thought it was the starting air 

9 concentrations that was the difference. I am 

10 trying to look it up right now real quick 

11 while I am reading. I thought they both used 

12 365 days. Yes, I would also, rather than bore 

13 everybody here I need to respond to this 

14 particular point.

15 DR. MAURO: It is what it is.

16 MR. THURBER: And I would, I note 

17 that the same information is included in 

18 section 8.3 as in 8.5.2. This is the 

19 duplication one.

20 MR. ALLEN: Yes, I agree, I mean --

21 MR. THURBER: Okay I think that 

22 covers our comments on TBD-6001 except for 
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1 this other story on the transparency problem. 

2 DR. MAURO: The Hooker example?

3 MR. THURBER: Yes, the Hooker 

4 example. Do we want to go on to that or --

5 CHAIRMAN ANDERSON: Do you want to 

6 go back now to that one? Yes, I would like to 

7 kind of finish up on the 6001 and then decide 

8 on what our next steps are, all right? One is 

9 going to be in a time line of, you are going 

10 to put in the responses, there's going to be a 

11 White Paper. Those seem to be the main --

12 MR. ALLEN: Yes.

13 CHAIRMAN ANDERSON: Most of the 

14 responses are -- the next step will be to 

15 close those out.

16 MR. ALLEN: Yes and then we can 

17 probably start closing things out, narrow it 

18 down to --

19 CHAIRMAN ANDERSON: It seems that 

20 finding one is where we may have to have some 

21 more discussion. But we'll see on that.

22 MR. ALLEN: Do you have any 
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1 objection to a comfort break at this point?

2 CHAIRMAN ANDERSON: Oh, well, how 

3 much time do we think this next, to go back, 

4 and --

5 MR. THURBER: Fifteen minutes.

6 CHAIRMAN ANDERSON: Okay, let's 

7 take a quick --

8 MR. KATZ: Five-minute comfort 

9 break?

10 CHAIRMAN ANDERSON: Break, I would 

11 say, then break for lunch before we --

12 MR. KATZ: Twenty of? Twenty of, we 

13 will be back?

14 CHAIRMAN ANDERSON: Yes.

15 (Whereupon, the above-entitled 

16 matter went off the record at 11:34 a.m. and 

17 resumed at 11:42 a.m.)

18 CHAIRMAN ANDERSON: I think we lost 

19 Mark.

20 MR. THURBER: What I would like to 

21 do is give you of a real world example, if you 

22 will, of how TBD-6001 is used for a specific 
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1 site and in this case it's Hooker Chemical. We 

2 were recently tasked by the Board to do a 

3 review of Hooker Chemical. The review is in 

4 progress so I am not going to comment 

5 particularly on the review but I wanted to 

6 give you an example of how it interplays with 

7 the TBD-6001.

8 What went on at Hooker Chemical 

9 was they received some uranium-bearing slags, 

10 they treated the slag with hydrochloric acid 

11 to increase the grade of the uranium from 

12 about a pound per, I'm sorry, 0.2 percent up 

13 to two percent, on that order.

14 So, and the reason they did that 

15 at Hooker was that Hooker was engaged in some 

16 other work for the AEC and they had some 

17 excess hydrochloric acid and so they thought 

18 it was a good way to use that excess acid.

19 The specific example I am going to 

20 discuss is the external exposure during a 

21 residual period and, in particular, the 

22 exposure that a worker gets from standing on 
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1 the contaminated surface that we talked about 

2 earlier this morning.

3 And if you look at table AA-3 in 

4 the Hooker Appendix, and I will show you an 

5 excerpt from that table in just a second, you 

6 see that the external exposure is 0.376 

7 millirem per day per an operator and this is 

8 based on the scrap recovery operation from 

9 TBD-6001.

10 So, quickly, this is the excerpt 

11 from, this is what you would see if you looked 

12 at table AA-3 of Appendix A or a part of what 

13 you would see and we are talking about, as I 

14 say, an operator called in this case Plant 

15 Floor High. The period is the residual period 

16 from 1946 to `76, the whole body dose is 0.376 

17 mR per day and we are referred to table 7.3 of 

18 TBD-6001 and this is one of those big tables 

19 that I mentioned earlier and said we would 

20 come back to.

21 So let's go to table 7.3 of TBD22 6001. We have the scrap recovery operation. 
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1 Again this is an excerpt from a very large 

2 table. In this case, we are talking about the 

3 operator, the external dose pathways that are 

4 examined and you will see that this operator

5 is assigned that dose of 0.376 mR per day and 

6 that's based -- and that is his median 

7 exposure.

8 The assumed geometric standard 

9 deviation is five. This is a standard 

10 assumption that is provided in this other 

11 document I mentioned earlier, prepared by 

12 Battelle, Strom 2006. It is a default 

13 assumption when you don't have enough data to 

14 actually calculate the geometric standard 

15 deviation from the log-normal distribution.

16 One of the things that is very 

17 confusing is this table is, assumes a calendar 

18 day and a lot of the data is reduced to a 

19 calendar-day basis for the convenience of the 

20 dose reconstructor. But the problem is that 

21 TBD-6001 seldom tells you whether you are 

22 talking about the work day or a calendar day 
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1 so that adds to the difficulty in trying to 

2 understand what the document is purporting to 

3 tell you.

4 Here's what TBD-6001 says in terms 

5 of, well, the question is where does this 

6 number of 0.376 mR per calendar day come from? 

7 And the guidance here in TBD-6001 says we use 

8 the deposition velocity that we talked about 

9 this morning, 7.5 times 10 to the minus four 

10 meters per second. We allow it to deposit for 

11 365 days and then we multiply that number by 

12 the air concentration and then we get the 

13 floor concentration in terms of dpm per square 

14 meters.

15 So we need two things, then. We 

16 need to know what the air concentration is and 

17 we need to know what the dose conversion 

18 factor is, and really it's the exposure 

19 conversion factor because we are talking about 

20 exposure in terms of mR per day and not dose 

21 in terms of millirem per day.

22 So, and TBD-6001 says well, to do 
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1 this, use the dose factors in table 6.1 of 

2 TBD-6001. So let's look at what that -- oh, I 

3 am sorry, we will come to that in a second.

4 First of all, let's talk about the 

5 air concentration number. TBD-6001 doesn't 

6 tell you where the air concentration came 

7 from. I talked to David about this. He says 

8 you go to table 8.23, which is the scrap 

9 recovery table and you take the data for scrap 

10 recovery operators and you average those 

11 numbers and that's where you get the air 

12 concentration.

13 Again, here's an excerpt from the 

14 table in TBD-6001 and you can see that the 

15 general area samples for the furnace area are 

16 900 dpm per cubic meter and 200 dpm per cubic 

17 meter. Those numbers were averaged with an 

18 assumed geometric standard deviation of five.

19 The geometric mean of 151 dpm per 

20 cubic meter was calculated and using that and 

21 the deposition velocity, we get a value for 

22 the floor concentration. Again, none of this 
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1 is revealed in the document. You have to find 

2 a helpful person like David to get to this 

3 point.

4 Now, recall that the guidance we 

5 looked at says, "Go to table 6.1 to find the 

6 dose conversion factors." You go to table 6.1, 

7 you will find the dose conversion factors are 

8 in terms of millirem per day, not mR per day. 

9 The dose conversion factors in 

10 table 6.1 are based on seven dpm per cubic 

11 meter, not the 151 dpm per cubic meter that we 

12 calculated and the data in table 6.1 don't 

13 tell you whether you are dealing with calendar 

14 days or work days. So this is kind of useless.

15 So then we go further back into 

16 the document and we go to table 3.10 to seek 

17 out these exposure conversion factors. Table 

18 3.10 gives us a conversion factor and of 5.6 

19 times 10 to the minus 10 mR per day per dpm 

20 per square centimeter, the surface

21 concentration.

22 We had independently, in our 
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1 review of TBD-6000 commented on this 

2 conversion factor and provided some 

3 calculations that showed it was too low by, I 

4 forget, do you remember John? A factor of two 

5 or more?

6 Because it did not include 

7 Bremsstrahlung nor did it include the direct 

8 contribution from electrons, which would cause 

9 exposure in the skin and other organs close to 

10 the surface. So, that basic number has been 

11 questioned elsewhere, so let's, but let's just 

12 leave it at that for the moment. 

13 Now, if you do the calculation, 

14 then you find out that the exposure you 

15 calculate is 0.002 mR per hour. And again, in 

16 talking with David, David said well the 

17 spreadsheet shows 0.2 mR per hour, a factor of 

18 100 different and apparently there was an 

19 error in the spreadsheet and, which is 

20 propagated through the calculation.

21 So then what one needs to do is to 

22 take this value, and we will stick with the 
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1 0.2 mR per hour number, the number that is too 

2 high by a factor of 100, and see how that gets 

3 converted to this number of 0.376 mR per day.

4 So first thing we have to do is 

5 convert it to exposure per calendar day and 

6 for some reason, the calculation assumed that 

7 there were 350 days in a year. You know, it's 

8 not a big deal, is whether it's 365 or 350, 

9 but it just leaves the whole thing kind of 

10 suspect.

11 The second thing is that they then 

12 took this number, 1.37 mR per calendar day and 

13 said this is the geometric mean of a log14 normal distribution, which you will recall, 

15 that we had already assumed that the original 

16 data was for a log-normal distribution and so 

17 it's not clear why you take a log-normal of a 

18 log-normal, which obviously reduces the values 

19 you are dealing with.

20 So, to summarize, TBD-6001 doesn't 

21 contain enough information to trace the values 

22 to the summary tables. There are errors in 
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1 calculating the external exposure. It 

2 incorrectly converts exposures to a calendar 

3 day basis and for reasons not obvious, it then 

4 takes a value which is based on a geometric 

5 mean and further reduces it to another 

6 geometric mean.

7 So that kind of summarizes some of 

8 the practical problems that you get into when 

9 you try to apply the TBD-6001 data to a site10 specific situation. 

11 CHAIRMAN ANDERSON: Comments? It 

12 seems to follow. I didn't quickly do all this 

13 math to see if your math was off as well.

14 MR. THURBER: Yes, as I say, you 

15 now, we could never have sorted this out at 

16 all without David's help.

17 DR. MAURO: I mean that's the first 

18 problem. The problem is we sit down and read 

19 it and we can't figure it out so we call 

20 David, and say can you help us out. So now we 

21 understand -- problem one, is it shouldn't be 

22 like that. The document should be complete 
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1 enough that an independent reviewer should be 

2 able to go through it and not say -- in fact 

3 Bill called and he says, "John, I can't figure 

4 out what they did."

5 And I said, "Well, you now, call 

6 David." He says, well, you know, I don't know, 

7 should we doing that? I say, call David, you 

8 know, so we call, and because we, again --

9 CHAIRMAN ANDERSON: You block 

10 caller IDs.

11 DR. MAURO: The funny thing is that 

12 you know, we are allowed to get clarification. 

13 The ground rule is that as long as we are not 

14 resolving an issue and we just want to figure 

15 out, please explain to us what you did here, 

16 whereabouts did you do that, and we do that 

17 and, but it shouldn't come to that.

18 You know, we are often in this 

19 very uncomfortable position of saying, listen, 

20 are we stupid, maybe we should be able to 

21 figure this out. Why are we having so much 

22 trouble figuring this out? 
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1 And so, we keep digging to try to 

2 figure it out, you know, and then two or three 

3 days pass and we still can't figure it out and 

4 I said listen, you know, if we could put a 

5 couple of people on it for a couple of days 

6 and we can't figure out what they did, this is 

7 not our problem. It should not be that hard. 

8 So we call and we get help. The 

9 reality is it shouldn't be that way. It should 

10 be something where another health physicist 

11 with some experience should be able to figure 

12 out what was done and David explained it to 

13 us. Now, problem number one is just being 

14 transparent, and maybe even put an attachment 

15 to the report that walks you through this is 

16 how we got the numbers. 

17 The second problem of course is 

18 once you've understood what was done, you 

19 think it was done incorrectly. Well, we could 

20 never have known that if we didn't call David 

21 to find out what they did. 

22 So we think that, you now, as 
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1 applied to Hooker, and that this is -- now, 

2 so, in a way it applies to TBD-6000 in terms 

3 of being transparent. It also applies to TBD4 6000 in terms of we think there might be some 

5 problems here in the numbers and they need to 

6 be fixed, and of course it has some real-world 

7 implications for Hooker, which is right now 

8 before us as an SEC, what we are doing right 

9 now. 

10 So that becomes very important and 

11 I guess this is the example. I think there's a 

12 lot of problems with TBD-6001 that have to be 

13 cleaned up so that another -- to get errors 

14 corrected and once they're corrected, it 

15 should be transparent, exactly what was done 

16 so that another person can read it and check 

17 the numbers and say yes, everything was okay.

18 MR. KATZ: Just for the record, you 

19 should never spend a couple of days trying to 

20 figure out what was -- get on the horn and 

21 spare yourself two days of useless labor.

22 DR. MAURO: I agree.
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1 MR. KATZ: Even if it's useful at 

2 the end it's two days wasted.

3 DR. MAURO: Well, let me take it a 

4 step further and while we get a chance, let's 

5 -- I call it a couch trip. When we are doing a 

6 dose reconstruction audit, you folks haven't 

7 seen these, but they are very, very 

8 sophisticated.

9 They are at a point in the process 

10 where some very sophisticated spreadsheets and 

11 workbooks are being developed and it takes 

12 quite a bit of time to get to the point where 

13 we understand the mechanics and the rationale 

14 behind these workbooks. 

15 These are not self-evident and I 

16 believe you folks probably have a pretty 

17 extensive training program for your dose 

18 reconstructors to get to the point where they 

19 can function. 

20 So the reality is, this is, it 

21 does take time for independent reviewers to 

22 figure out what is going on and very often you 
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1 find out everything is fine. 

2 But it is not always apparent what 

3 was done and this goes, this is a longstanding 

4 issue, is that when you guys are putting 

5 together your products whereby your dose 

6 reconstructors for example are giving 

7 instructions on a spreadsheet or a workbook, 

8 the product that is used, the degree to which 

9 you can make it understandable to someone 

10 independent, like us, so we can figure it out 

11 and right now we are spending too much time 

12 trying to figure things out. 

13 This is one example where you're 

14 right, we shouldn't have spent two days. But 

15 it's not unusual for us to find ourselves in a 

16 position of trying to understand what was done 

17 here. We could certainly use a little help on 

18 these products that come out, a little bit 

19 more explanation so that, you know, we don't 

20 have to call.

21 CHAIRMAN ANDERSON: Just kind of a 

22 process question here. Is this kind of a, I 
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1 mean, you went through it and found this 

2 problem. Is this, is one of your risk 

3 assessors, when they are doing this, or dose 

4 reconstructors, would they have identified 

5 this problem or are they more rotely going to 

6 the, quickly going to a table, pulling out a 

7 number, putting it into the formula and 

8 calculating and not working this through? 

9 MR. ALLEN: A dose reconstructor 

10 normally wouldn't have seen this. They are 

11 going to with the appendix that says to assign 

12 this external dose per day and that is what 

13 they are going to assign. I mean, if they are 

14 curious and start digging into the basis they 

15 might see an issue, but that's something 

16 that's supposed to be caught during the review 

17 of the documents.

18 CHAIRMAN ANDERSON: Yes. Because 

19 I'm just wondering how much of this is because 

20 6001 has not been really applied that much so 

21 that a lot of these facets aren't picked up or 

22 is it simply that now that we have, somebody 
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1 really has gone through and reviewed it, we 

2 are finding these and the question then, 

3 really, as you raised, is you haven't done 

4 this exhaustively for all of the tables so 

5 what is your, what is the likelihood that this 

6 is --

7 MR. ALLEN: This particular error 

8 is essentially, is in the Hooker Appendix but 

9 it's carried forward from TBD-6001 so somebody 

10 reviewing the Hooker Appendix, you know, 

11 probably went as far as to say, okay, yes, 

12 that's the number that's in TBD-6001 and I 

13 mean that would have been -- the review of 

14 6001 is where that should have been caught but 

15 that's the point where it was missed and it's 

16 up to the reviewer. They could carry it back 

17 further if they wanted to or they could stop 

18 with an already-approved document, you know, 

19 and saying that's where it came from.

20 DR. MAURO: But if TBD-6001 had an 

21 appendix which held the reader's hand and 

22 listed, this is where we can go right back 
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1 through the original data, to the database of 

2 20,000 measurements sitting someplace on the 

3 site query database and it's explained that 

4 they sorted the data into a spreadsheet, which 

5 I'm sure they did, took the data and this is 

6 what they did and just walk the reader -- and 

7 what would happen if that type of description 

8 is provided as an appendix, you would have 

9 picked it up.

10 It's, you know, it would not have 

11 gotten to the point where we have a product 

12 out here that has some errors in it and 

13 contradictions in it. So in a funny sort of 

14 way, one of the things we find out when we are 

15 writing our reports, when we are writing our 

16 reports, we try to write it in a way that 

17 someone could read, say, oh okay, and all the 

18 calculations are there, and in the process of 

19 writing it, you catch your errors. That's when 

20 we catch our errors.

21 I think that in this case, this is 

22 just a recommendation that if the final 
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1 product contains a hand-holding description of 

2 exactly how we got the numbers that are in 

3 this report, the errors would have been caught 

4 and they wouldn't have to come to here to be 

5 caught.

6 CHAIRMAN ANDERSON: How many TBDs 

7 are there?

8 DR. NETON: Lots. 

9 CHAIRMAN ANDERSON: Well, I mean, 

10 to go back, it seems to be pretty massive.

11 DR. NETON: Well, I think this 

12 might, I am not going to say this is an 

13 isolated example but TBD-6001, I think was 

14 rocky. I will admit that. So, hopefully, you 

15 know, this is not --

16 CHAIRMAN ANDERSON: So I guess --

17 DR. NETON: -- indicative of a 

18 whole problem.

19 CHAIRMAN ANDERSON: I am looking 

20 for some reassurance.

21 DR. NETON: We have been through an 

22 in-depth review of many, many TBD documents.
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1 DR. MAURO: Oh, we've reviewed 

2 hundreds, hundreds of procedures, you know, 

3 literally hundreds of documents. 

4 CHAIRMAN ANDERSON: So, is the, the 

5 kind of the bottom line, is NIOSH going to go 

6 back through this and do another internal 

7 audit of all of this?

8 DR. NETON: We need to go back and 

9 refine it.

10 DR. MAURO: Six thousand is much 

11 better.

12 Well, 6000 is a simpler document 

13 since you're only dealing with uranium 

14 machining. In other words, this is a more 

15 complex document. You've got all these 

16 measurements that you're working with as, you 

17 know, so this is a tougher nut to crack but it 

18 shouldn't be that difficult for us to check 

19 numbers and you know --

20 DR. NETON: And you look at what 

21 happens here, I mean this is no excuse, but 

22 you know you are getting down into what I call 
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1 second-order dose assignments. You are talking 

2 about 0.3 mR per day exposure, millirem per 

3 day for a guy standing -- it doesn't make it 

4 right that it's wrong, but I'm saying when you 

5 get down into these --

6 CHAIRMAN ANDERSON: It's the 

7 impact.

8 DR. NETON: -- the impact of these 

9 very small, calculated doses, it doesn't make 

10 it right but possibly the attention to detail 

11 is not as great as if it is the big, big12 ticket exposure items and that is I think what 

13 has happened here.

14 MR. ALLEN: And in all honesty, 

15 with 6000 they were able to take the 

16 description that, you know, what we can claim 

17 we did, you know, run some numbers, verify 

18 that, you know. It might not have had the 

19 hand-holding as nice as you would want but you 

20 can verify the numbers from the description 

21 pretty much.

22 The reason they were not able to 
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1 in 6001 was there was calculational errors 

2 behind the scenes so you couldn't verify what 

3 they were saying. So it'd kind of indicative 

4 of this document not, you know, a systemic 

5 problem or anything.

6 CHAIRMAN ANDERSON: But it does 

7 seem to me, before we take up Hooker, this is 

8 probably going to need to be redone, or --

9 DR. NETON: I am not sure, I mean, 

10 Hooker is a very --

11 MR. ALLEN: It uses a very small 

12 piece of this. 

13 DR. NETON: I think you can sort of 

14 investigate the little piece we use in some 

15 detail and get your hands around it fairly 

16 quickly.

17 CHAIRMAN ANDERSON: Okay, well I, 

18 you know, I just --

19 DR. NETON: I would prefer not to 

20 wait until we resolve all these issues that 

21 are best taken up elsewhere. 

22 CHAIRMAN ANDERSON: Well, I mean, 
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1 that's kind of what my question is, is this 

2 sufficiently, that you know, we go back to the 

3 Board and somebody is going to raise, well, 

4 gee, until you have done that we have got to -

5 - or, and then, or can we basically --

6 MR. THURBER: No. I don't think 

7 that, from our perspective, we need to have 

8 these questions answered. They are adequately 

9 answered so that we understand them. As you 

10 say Jim, this is peanuts in terms of exposure. 

11 The question is how endemic the problem is 

12 from a TBD-6001 perspective.

13 But in terms of what we need to do 

14 for Hooker, I think we are okay with some, any 

15 clarifications here.

16 CHAIRMAN ANDERSON: So that's all I 

17 needed to hear.

18 DR. MAURO: The big issue on Hooker 

19 is going to be Hooker uses TBD-6001 as a 

20 surrogate. It's going to become a surrogate 

21 data issue and the heart of the matter is 

22 going to be, assuming that the numbers are 
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1 corrected, you know, see, I look at this as 

2 what I call a Site Profile issue. There's some 

3 bad numbers in the report; we've got some 

4 contradictory diagrams, all of which can be 

5 fixed, right?

6 Now, the real question is going to 

7 be, okay, once that's fixed, the question then 

8 becomes all right, at Hooker, and you brought 

9 this up before, at Hooker, let's say they used 

10 this particular number or distribution from 

11 TBD-6001 and we know what they did to get 

12 that.

13 And then the question is going to 

14 be, does that really, is that a good surrogate 

15 for this particular guy or any particular area 

16 at Hooker? And it becomes a surrogate data 

17 issue that's going to -- and that's where the 

18 SEC is going to comply.

19 In the end, the real, you know, 

20 the judgment calls, and this is the tough one 

21 and these are things that 16 Members of the 

22 Board are going to say, whether or not -- does 
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1 this represent a reasonable surrogate for the 

2 guys that worked in Hooker or not?

3 And you know that's going to be a 

4 difficult discussion to have but that's where 

5 it's going to end up, you know. The technical 

6 issues will be worked out. It's the judgment 

7 issues that are going to be the tough ones.

8 CHAIRMAN ANDERSON: Okay, so next 

9 steps on this.

10 MR. ALLEN: We owe responses on all 

11 these -- I think I can get you some short 

12 responses quickly and some others, we'll be 

13 saying, this will be addressed in a White 

14 Paper to come or I can wait until the whole 

15 White Paper is done and it will be a little 

16 longer.

17 CHAIRMAN ANDERSON: What, when we, 

18 what kind of a time line, holding your feet to 

19 the fire, when could, I mean a White Paper 

20 seems to be something that is really going to 

21 be helpful for us.

22 MR. ALLEN: Yes, I agree. I don't 
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1 know if you wanted the one-word answers, you 

2 know, the one-sentence, two-sentence answers 

3 first or just wait for the whole, you know --

4 CHAIRMAN ANDERSON: While it's sort 

5 of fresh in your mind I would like to try to 

6 fill in short things --

7 MR. ALLEN: That's what I was 

8 thinking.

9 CHAIRMAN ANDERSON: -- pretty 

10 quickly then --

11 MR. ALLEN: That's what I would 

12 like to do.

13 CHAIRMAN ANDERSON: I would like 

14 to, by, you know, the meeting out in Idaho, be 

15 able to at least report back when, what the 

16 time line for the --

17 MR. ALLEN: Okay.

18 CHAIRMAN ANDERSON: I would think 

19 by then we ought to have the short answers and 

20 hopefully in time for you to look at them and 

21 say, yes, well, it's kind of, we can look at 

22 it and say, yes, that's what we remember and 
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1 then what would be a time line for a White 

2 Paper and I don't have a sense of how much 

3 time and effort that will take.

4 MR. ALLEN: I don't think I have a 

5 good sense on that at this point but I can 

6 come up with short responses --

7 CHAIRMAN ANDERSON: Yes I would 

8 like to hear some kind of a target date you 

9 know, that we can begin to look at and again 

10 as the surrogate issues, I would like to be 

11 able to report back some confidence level on 

12 the -- some of the 6001 components so we are 

13 arguing more on the policy and the other 

14 issues than we are, oh well, this is still you 

15 know, I don't want to add any more uncertainty 

16 to the picture than we need.

17 DR. NETON: Can you put the date in 

18 the response, I mean, would a date for the 

19 White Paper, would that be in the response?

20 MR. ALLEN: Yes, that's what I was 

21 saying.

22 CHAIRMAN ANDERSON: Okay, that's 
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1 fine.

2 MR. ALLEN: I can give you the 

3 short responses --

4 CHAIRMAN ANDERSON: Yes. Great. 

5 Yes. Good.

6 MR. ALLEN: -- and in the email I 

7 am sending those I will give you a target date 

8 for White Papers.

9 DR. MAURO: And SC&A has no action 

10 item, so we are clean, right? So the only 

11 action item I guess, Ted, once that White 

12 Paper is issued, are we authorized to move 

13 immediately or do we wait until you authorize 

14 it? So the action item on our end is when the 

15 White Paper becomes available, we are 

16 authorized to immediately go ahead and take a 

17 look at it and get it back to you. 

18 CHAIRMAN ANDERSON: And you will, 

19 when you get the initial responses, you will 

20 fill in the --

21 MR. KATZ: Updated matrix.

22 CHAIRMAN ANDERSON: Yes. 
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1 MR. KATZ: There will be an updated 

2 matrix.

3 DR. MAURO: The first cut at the 

4 updated matrix is from the review folks.

5 MR. ALLEN: Yes, the short 

6 responses will be in the, essentially in the -

7 - 

8 DR. MAURO: And then we will look 

9 at that.

10 MR. KATZ: Is your matrix a PDF or 

11 a --

12 DR. NETON: It's in Excel, isn't 

13 it?

14 (Simultaneous speaking.)

15 MR. KATZ: A lot of your stuff is 

16 in PDF so you need to send it to them in a 

17 writeable file form.

18 DR. MAURO: Can we get them to send 

19 this -- this probably went out as a PDF. 

20 DR. NETON: But it's probably a 

21 Word table.

22 DR. MAURO: Certainly we could send
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1 it out as a Word version.

2 MR. THURBER: Okay, well, I am 

3 sorry, what do you want?

4 MR. KATZ: So, SC&A's item is just to 

5 send a writeable file.

6 MR. THURBER: A Word version of 

7 that.

8 (Simultaneous speaking.)

9 CHAIRMAN ANDERSON: Well, and there 

10 were a few typos which you identified too.

11 (Simultaneous speaking.)

12 DR. MAURO: Don't worry about it, 

13 Bill, they got it in Word.

14 MR. THURBER: Well, we will, in due 

15 course we will fix those typos.

16 DR. NETON: I mean normally I 

17 understand most people send PDFs because then 

18 you don't want people to start changing things 

19 around.

20 DR. MAURO: Right, but not in this 

21 case.

22 CHAIRMAN ANDERSON: Okay, do we 
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1 have anything else on overview 6001? Shall we 

2 take a lunch break and hustle back and then we 

3 can hopefully get through the other two, at 

4 least the start of it? How much --

5 MR. KATZ: Normally --

6 CHAIRMAN ANDERSON: I suppose this 

7 is where we eat. We could take the van over to 

8 the airport and eat at the airport, I suppose, 

9 otherwise. What is your plan?

10 MR. KATZ: Normally, we take an 

11 hour break.

12 CHAIRMAN ANDERSON: Okay. I have 

13 got to check out anyway. 

14 MR. KATZ: So it's 12:15 now, we'll 

15 break until 1:15 and then reconnect the phone.

16 CHAIRMAN ANDERSON: Anyone on the 

17 phone? 

18 DR. NETON: Mark is. 

19 DR. BEHLING: Yes, we are still on 

20 the phone. 

21 CHAIRMAN ANDERSON: Okay.

22 MR. KATZ: Okay so we will back at 
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1 1:15.

2 CHAIRMAN ANDERSON: Be back at 

3 1:15.

4 DR. BEHLING: Thank you.

5 MR. KATZ: Thank you for hanging in 

6 there.

7 (Whereupon, the above-entitled 

8 matter went off the record at 12:14 p.m. and 

9 resumed at 1:16 p.m.)

10 
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 

2 (1:16 p.m.)

3 MR. KATZ: This is the TBD-6001 

4 Work Group. We are just reconvening after a 

5 lunch break. Let me check on the line and see 

6 if we have Mark Griffon back. 

7 MEMBER GRIFFON: Yes, I am here, 

8 Ted.

9 MR. KATZ: Great. And then we can 

10 proceed. I think we are ready to address 

11 Electro Met. 

12 CHAIRMAN ANDERSON: Yes. 

13 MR. KATZ: So first on the agenda 

14 is a brief presentation by DCAS, by Sam Glover 

15 of the evaluation and petition.

16 DR. GLOVER: Does everybody have a 

17 copy of the Evaluation Report or -- it's a 

18 little different format than we have done in 

19 the past so it's sort of presenting the piece 

20 so --

21 CHAIRMAN ANDERSON: All I have is 

22 the --
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1 DR. GLOVER: You have the ER, do 

2 you have the presentation that we gave? I 

3 don't have the detailed --

4 CHAIRMAN ANDERSON: No.

5 DR. GLOVER: -- from you guys.

6 MR. KATZ: You don't have to re7 present it in its entirety the way you would 

8 have for the Board, but just to refresh 

9 everybody.

10 DR. GLOVER: Sure. 

11 MR. KATZ: And get the ball 

12 rolling.

13 DR. GLOVER: Let me just pull it 

14 up, though, because that is probably the 

15 simplest thing, to start where we left it at 

16 in 2009 when we presented it to the Board.

17 So this has not been taken up in 

18 front of the Committee yet, right? You got to 

19 realize, I picked this site up after it was 

20 initially presented so this is new to --

21 MR. KATZ: This Work Group has not 

22 met before --
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1 DR. GLOVER: This is brand new.

2 MR. KATZ: This is brand new.

3 DR. GLOVER: October 2009, we 

4 presented the Electro Metallurgical 

5 Corporation SEC Report. We concluded that we 

6 could do all aspects of dose at the facility. 

7 Just very quickly, they began in 1943. SC&A 

8 correctly points out we had some discrepancies 

9 in some start dates but in the very beginning 

10 the MED, the Manhattan Engineer District, they 

11 began producing uranium metal and so they ran 

12 through 53 intermittently, basically going 

13 from uranium tetrafluoride to uranium metal 

14 using a thermal reduction process that was 

15 done, I believe, at Iowa. Is it Iowa? What's 

16 that? Iowa State. Yes. Ames. Yes. It was 

17 developed there.

18 So it was basically a single 

19 facility that was carved out by the AEC to 

20 produce it all. It sounds like there was some 

21 preparatory work that may have been done at 

22 some other facilities ahead of that. They 
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1 have gone through a series of successions. 

2 They were acquired by Union Carbide. They had 

3 a couple of stand-by periods. Essentially, we 

4 concluded they only had one uranium, one 

5 nuclear component which was uranium but SC&A 

6 had some other concerns that they identified.

7 The petition was started on 

8 November 17, 2008. We qualified it in March of 

9 2009 and we issued the report July 23, 2009. 

10 The proposed Class was all workers that worked 

11 in any area of Electro Met from August 13, 

12 1942 through December 31, 53.

13 We evaluated the Class from April 

14 1, 43 through June 30, 53, in part I believe 

15 based on our premise that work did not 

16 actually start there until April 1, 1943. 

17 I won't go through all the 

18 different sources of information other than to 

19 say that we have continued to conduct searches 

20 of the facilities, including -- we have been 

21 working quite a bit with the Army Corps of 

22 Engineers, so we have gone up there and 
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1 conducted site research for all AWE facilities 

2 up there.

3 We have also realized that Hanford 

4 had not queried their full data sets, 

5 databases and so we searched on Electro Met

6 and all other AWE facilities that we have 

7 active and so we have even some classified 

8 reviews and some documents and I have shared 

9 those with Kathy Robertson so she has a 

10 complete listing of all of our Hanford terms 

11 that were searched. So those are in the 

12 process.

13 And also, as you guys participated 

14 in NARA, the National Archives, there have 

15 been a lot of ongoing data access, data 

16 retrieval. 

17 So just to give you an idea of the 

18 number of claims for the site, we have 98 

19 claims. This is back on August 1, 2009. 

20 Ninety-two of those were completed for dose 

21 reconstruction; 44 percent of with a PoC 

22 greater than 50 percent.
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1 So the petition basis was that a 

2 few workers were monitored for external 

3 exposure and also the efficacy of the health 

4 protection and industrial hygiene programs. 

5 It was evaluated. Our evaluation 

6 concluded that they intermittently monitored 

7 workers. They did issue some dosimeters in 44 

8 and then later, 48 through 49, for which we 

9 have results, and we only limited bioassay 

10 from 44 and 49.

11 Now we did have breathing zone and 

12 area monitoring from 44 and 47 through 49 and 

13 we had basically production processes. Now we 

14 concluded that the production processes were 

15 essentially the same for the entire MED in AEC 

16 period when we did this report. There are 

17 clearly documents in the thing that, in the 

18 SRDB, that we have that mention that health --

19 that changes were done to the health 

20 practices.

21 So we made a conclusion here that 

22 the production processes hadn't changed. So 
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1 that was the basis for how we did our review. 

2 We know that they were exposed to extremely 

3 high levels of internal -- there were some 

4 very high -- very high air concentration data 

5 from 1948. And it is not replicated in the 

6 earlier time frames, way back 600 MAC air. 

7 These are near 800, 900 MAC I think, very 

8 large, very very high. 

9 And the, basically, personal 

10 protection was, as we all agree, that it was 

11 much less than modern standards.

12 We conducted a number of sample 

13 dose reconstructions. The basis for these is 

14 that we essentially used the highest operating 

15 conditions for the worst-case person in 48 

16 through the whole time frame. 

17 And so we generated very, very, 

18 very high dose assessments for all the people 

19 who were evaluated and so the dose 

20 reconstructions are available to you guys but 

21 let's see if they summarized them on this 

22 piece here.
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1 Even if you look at the external 

2 photon dose to the skin, it's 25 rem, 126 rem 

3 electron, X-rays are almost -- are very small: 

4 15 rem of dose, rem from uranium, this would 

5 just be from the external standpoints. So very 

6 high doses are used to evaluate it. Not that 

7 very high is meaningful but I'm just trying to 

8 give you guys a feel for the magnitude of 

9 doses that were used at Electro Met. 

10 I am trying to see if we have the 

11 internal; from 43 to 53, we used 60,000 dpm 

12 per day intakes during operational periods and 

13 473 dpm per day for stand-by periods. In 

14 addition we used an ingestion of 1,178 dpm per 

15 day of natural uranium. 

16 So obviously with those kinds of 

17 intakes, respiratory tract cancers, unless 

18 it's something, you know, unless it's a 

19 latency issue, are going to be almost always 

20 paid. 

21 So, but very, very large intakes. 

22 However they also had very -- they had some 
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1 potential during the reduction operations for 

2 some very large airborne measurements that 

3 were taken. So anyway, based on our -- our 

4 feasibility conclusion was that we can do 

5 internal, gamma, beta, neutron and medical X6 rays. That's where we left the report and 

7 hopefully that's at least a little bit of an 

8 overview and a kick-off.

9 CHAIRMAN ANDERSON: How many staff 

10 -- you said you really only had measurements 

11 from 44 and 48, is that it? 

12 DR. GLOVER: There are, let's see, 

13 I would have to pull up the specifics in the 

14 report but it's --

15 CHAIRMAN ANDERSON: How many 

16 samples do they have?

17 DR. GLOVER: You mean for bioassay 

18 or for -- well actually the SC&A summarized 

19 that on table one. I'll just go ahead and use 

20 theirs because it's readily available right to 

21 me.

22 For bioassay, for air samples what 
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1 do you need? What are you asking me?

2 CHAIRMAN ANDERSON: It's just --

3 DR. GLOVER: Air samples --

4 CHAIRMAN ANDERSON: Just a sense of 

5 what's --

6 DR. GLOVER: Let's see, they 

7 mentioned having four air samples in 43, 15 in 

8 44, less than 10 in 47, a much larger, 

9 obviously, in 48 when the AEC begins 

10 operations, with 154 in 48 and 215 in 49.

11 CHAIRMAN ANDERSON: In the SEC?

12 DR. GLOVER: The AEC taking over. 

13 CHAIRMAN ANDERSON: Yes, I know, I 

14 know, but I mean these, there, the SEC 

15 petition ends when?

16 DR. GLOVER: Well, the building was 

17 actually destroyed, or what do you want to 

18 call it, it was removed. Let's see. 

19 MR. THURBER: Fifty-seven, I think, 

20 Sam.

21 DR. GLOVER: Fifty-seven?

22 MR. THURBER: I think that's when 
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1 the demolition was done.

2 CHAIRMAN ANDERSON: Okay.

3 DR. GLOVER: So.

4 CHAIRMAN ANDERSON: I got you. 

5 DR. GLOVER: Right, but the active 

6 period was, I think 53 is when all of the 

7 activity on site other than the demolition 

8 would have --

9 CHAIRMAN ANDERSON: And how much 

10 biomonitoring do you have?

11 DR. GLOVER: With the bioassay it 

12 looks like we had 67 in 44 and nothing again 

13 until 49. Now in our report, we only relied on 

14 air monitoring data. We did not use the 

15 bioassay to try to, we just took the air 

16 monitoring data and ignored any application of 

17 bioassay.

18 So that's where we came. 

19 CHAIRMAN ANDERSON: Okay. Okay. 

20 Shall we move on to the -- are there any other 

21 questions you have?

22 MEMBER FIELD: Yes, what was the 
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1 percent PoC again? 

2 CHAIRMAN ANDERSON: Forty-four 

3 percent.

4 DR. GLOVER: What do you mean, how 

5 many were above 50 percent? Forty-four 

6 percent.

7 CHAIRMAN ANDERSON: Which is higher 

8 than the overall --

9 DR. MAURO: You used the type M, 

10 type S, in other words, depending on the organ 

11 of your intakes, in other words did you use 

12 uranium intake, or did you automatically 

13 assume it was all S, or --? 

14 DR. GLOVER: It said S here. That 

15 does not necessarily make sense but it 

16 probably -- because, I mean --

17 CHAIRMAN ANDERSON: Is Mark on the 

18 phone?

19 MR. KATZ: Mark is on the phone.

20 DR. GLOVER: I would have to 

21 double-check to see what the reality is. 

22 Usually we use the most claimant favorable --
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1 DR. MAURO: That's what I was 

2 asking.

3 DR. GLOVER: We all -- and S is the 

4 standard default. It said type S in the ER 

5 evaluation. We always would have used the most 

6 favorable version. So --

7 CHAIRMAN ANDERSON: Mark, do you 

8 have any questions? 

9 MEMBER GRIFFON: Not right now, no.

10 CHAIRMAN ANDERSON: Okay.

11 MEMBER FIELD: I just have one 

12 question. You based it all on air monitoring, 

13 is that what you said?

14 DR. GLOVER: At this time it was 

15 all based on air monitoring, that is correct.

16 MEMBER FIELD: And you have 

17 bioassay data. I just wonder if the bioassay 

18 data would reflect what the air monitoring 

19 showed. Would you have already looked at that?

20 DR. GLOVER: That is something that 

21 I think NIOSH would -- partially because we 

22 would have back-extrapolated from 1948 into 
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1 the MED time frame. Tolerance levels and a 

2 number of things that were already discussed 

3 in TBD-6001, we need to see what --

4 So what we have done, just to give 

5 you a bit of a -- I know SC&A is going to 

6 provide a matrix on some of what they have 

7 done. But we are going through everything, all 

8 of the documents right now, all of the 

9 material we have, and getting a comprehensive 

10 listing of all of the data, external, 

11 internal, bioassay, air monitoring, so we can 

12 actually see, what do we have to fill in for 

13 gaps and so that's where we are.

14 CHAIRMAN ANDERSON: Okay. You're 

15 up. 

16 MR. THURBER: All right. Let me 

17 talk a little bit about what we understand to 

18 be the physical situation of Electro Met. 

19 Electro Met was a ferro-alloy 

20 manufacturing plant. They made ferrochrome, 

21 ferrosilicon, silico-manganese; products that 

22 they sold to the steel industry which were 
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1 used as alloy additions to make stainless 

2 steel for example, ferrochrome, whatever.

3 So that was their business. This 

4 business was done in large electric arc 

5 furnaces. When they undertook their contract 

6 with the Atomic Energy Commission, they built 

7 a small facility in one corner called the Area 

8 Plant and the Area Plant was basically where -

9 - well, the Area Plant was where all the 

10 uranium production was done.

11 Now there may have been done some 

12 work done in the laboratory. We'll get to 

13 that. It was probably small, but -- so they 

14 had this facility called the Area Plant, where 

15 they did the operations that Sam described. 

16 They got the green salt, the uranium 

17 tetrafluoride from Linde, they mixed it with 

18 magnesium, put it in a thermite reduction 

19 bomb, converted it to uranium metal, cleaned 

20 up the uranium metal, remelted it in a vacuum 

21 induction furnace and shipped the finished 

22 billets off to somebody else to be fabricated.
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1 So that was the operation that 

2 they did there. One of the concerns that we 

3 have, and it is reflected in finding one, is 

4 really the definition of the exposure cohort. 

5 You can see that, as Sam mentioned, the 

6 exposure cohort was designated to be all of 

7 the employees that worked at Electro Met. 

8 And we think that this needs to be 

9 examined further because there was a cadre 

10 that worked in the Area Plant, based on the 

11 interviews that we have conducted and some of 

12 the documentation that NIOSH originally 

13 uncovered, there was pretty significant 

14 separation between the Area Plant and the 

15 commercial facility.

16 There was a fence, it was guarded, 

17 people had to have badges to get in and out. 

18 There was some evidence that some maintenance 

19 workers might come in a couple of days a 

20 month, but it was basically a separate, self21 contained operation.

22 And so we think it is important to 
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1 determine whether it is appropriate to 

2 consider everybody at the plant as part of the 

3 exposure cohort when most of them didn't work 

4 in the Area Plant.

5 And so that is what this first 

6 finding speaks to and I would note that if you 

7 look at the original petition -- so there were 

8 actually were two petitions made to consider 

9 the possibility of a Special Exposure Cohort 

10 for Electro Met, and one of the petitioners 

11 said on behalf of her husband, I believe, that 

12 it should cover the Area Plant.

13 The other petitioner said that it 

14 should cover all of the employees at Electro 

15 Met. The two petitions were merged by NIOSH 

16 into a single petition which formed the basis 

17 of their Petition Evaluation Report.

18 Now if you look at the information 

19 available on the two petitioners, it's not 

20 clear that either of the petitioners worked in 

21 the Area Plant. In one case there is a letter 

22 that was provided to the petitioner who I 
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1 believe was the spouse of the deceased 

2 employee from Union Carbide and it said, on 

3 the basis of this -- what Union Carbide told 

4 the woman -- on the basis of our employment 

5 records, it looked like this man worked his 

6 entire career at the carbon products division 

7 of Union Carbide, which is a totally separate 

8 thing even from Electro Met. 

9 I mean Electro Met was a 

10 subsidiary of Union Carbide, the carbon 

11 products division was a subsidiary of Union 

12 Carbide. Linde was a subsidiary, but their 

13 records showed that this guy didn't even work 

14 for Electro Met. 

15 Now their records may be wrong. 

16 I'm not saying that all corporations keep good 

17 records, but that is the evidence that is 

18 available.

19 With regard to the second 

20 petitioner, if you look at the information 

21 provided, it's clear that he worked for 

22 Electro Met, it's reasonably clear that he did 
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1 not work in the Area Plant. So I just offer 

2 that as background.

3 But anyway, the stupid computer is 

4 gone. I talked too long.

5 DR. GLOVER: It may be worthwhile 

6 to just briefly discuss that because we 

7 obviously don't set the covered facility. And 

8 the Department of Labor, we can, if we find 

9 things we can offer them, you know, what we 

10 find. It's their job to determine if a person 

11 is at this facility and right now if you go to 

12 the covered facility, it says Electro Met

13 Corporation. Electro Metallurgical is the 

14 facility that is covered.

15 So clearly there is a building 

16 where this work was done at. We have 

17 intermittent records, you know, as far as 

18 occupational, we have to apply some kind of an 

19 analysis as to what kind of dose these guys 

20 could have received. So --

21 MR. KATZ: But you can specify, if 

22 there are no radiological exposures, you can 
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1 certainly, you don't have to define a Class 

2 for individuals who have no radiological 

3 exposure whatsoever, even if the covered 

4 facility includes that.

5 So, I mean, as they are saying --

6 DR. GLOVER: There is no record 

7 support that they have --

8 MR. KATZ: Whether they can 

9 implement such a Class is a whole other 

10 question --

11 MR. HINNEFELD: The issue would be 

12 whether the Class could be administered.

13 MR. KATZ: Right.

14 MR. HINNEFELD: And absent evidence 

15 that people were in one place or another.

16 MR. KATZ: Right.

17 MR. HINNEFELD: You know, if you 

18 have maybe the security clearance records, 

19 which apparently don't exist, they apparently 

20 had a destruction schedule shorter than 50 

21 years. 

22 And so, ask them for some piece of 
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1 information that would say this employee 

2 worked in this part of the plant, all we get 

3 is employment verification that they worked 

4 somewhere then. 

5 We don't know of any other record 

6 that provides a more precise placement of the 

7 employees. We don't know, we don't have a 

8 segregation of the work force, a record of the 

9 segregation of the work force that remain 

10 today.

11 MR. THURBER: But isn't it true, 

12 Stu, that there are records of who the 

13 monitored employees that worked in the Area 

14 Plant are, by name, by badge number?

15 MR. HINNEFELD: Well, there 

16 probably are, but it's always a little tricky 

17 from our standpoint to say that people who 

18 were not monitored were not exposed. Yes, 

19 there could have been, I mean, I would think 

20 that people were assigned there all the time. 

21 We have this discussion all the time. You 

22 know, people who were assigned there all the 
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1 time, well sure, they were probably monitored. 

2 But what about maintenance craftsmen who 

3 perhaps had the necessary requisites to get in 

4 but they didn't monitor them.

5 I mean we don't have -- unless we 

6 have the evidence of the monitoring program 

7 being sufficiently robust, that they always 

8 caught people, people were always monitored, 

9 you know, we have really been hesitant to try 

10 to delineate from that much, from monitored 

11 versus un-monitored. Anyone want to help me 

12 out here?

13 DR. NETON: I guess, I was 

14 distracted here for a second but I am not sure 

15 what the issue is. We are saying we can do 

16 dose reconstructions.

17 DR. GLOVER: We didn't offer a 

18 Class. The finding one, however, is that we 

19 didn't confine, I guess, our --

20 CHAIRMAN ANDERSON: But your dose 

21 reconstruction --

22 DR. NETON: But the point is that 
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1 we are saying we can dose reconstructions in 

2 the area where these exposures occurred. 

3 Right? That's what we are saying? So it 

4 doesn't really matter --

5 MR. THURBER: But no, you are 

6 saying more than that. You are saying we can 

7 do dose reconstructions for the entire Electro 

8 Met facility. 

9 DR. NETON: Right, and you are 

10 saying the exposure only occurred in a certain 

11 part of the facility.

12 MR. THURBER: Right. And we are 

13 further saying that the access to that 

14 facility was constrained by a fence and badges 

15 and so forth. 

16 DR. NETON: I mean, the question 

17 here is, where the exposures occurred, can we 

18 do those dose reconstructions with sufficient 

19 accuracy. And I guess what you are saying is 

20 we are assigning dose to everyone as if they 

21 all worked in that facility and Stu just 

22 chimed in, which was true, that this is very 
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1 typical of our abilities to administer, to 

2 define Classes.

3 We are hard-pressed, I don't think 

4 we have ever been able to go back, with some 

5 minor exceptions, and define Classes more 

6 narrowly than the entire facility, 

7 generically.

8 MR. KATZ: This almost, this 

9 predates the Class. You are saying you are 

10 doing dose reconstructions for individuals who 

11 worked outside of the area where there were 

12 radiological exposures. So you are saying you 

13 couldn't even, in their interviews and so on, 

14 place them in- or outside of the radiological 

15 area?

16 DR. NETON: This is an issue at 

17 General Electric Aircraft Engines at 

18 Cincinnati, this is a huge 8,000-person 

19 employer.

20 DR. GLOVER: Its exposure said in 

21 1942. This is 70 years ago and since it was 

22 classified -- 
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1 DR. NETON: Usually what happens is 

2 you have people, workers will say, actually, 

3 yes, they might have had access controls, but 

4 as you already alluded to, maintenance staff 

5 were common for those areas, they would go in 

6 there, administrative support services would 

7 go through those facilities. We typically end 

8 up taking a very expansive view of this.

9 MR. THURBER: Well, I point it out 

10 for the record, that's all, you know, I mean, 

11 it is not in a sense a technical question, but 

12 I think it's --

13 DR. NETON: Well, what I was trying 

14 to get out of this is, were you trying to say 

15 that, given that we don't know who went in 

16 there, it should be a Class because we are 

17 assigning these large doses to all members, 

18 because I think would that be --

19 MR. THURBER: No.

20 DR. NETON: If that's not your 

21 point then this --

22 MR. THURBER: No. I am not saying 
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1 that. That's not the point at all. No.

2 CHAIRMAN ANDERSON: Is there 

3 anything in the record that, when they did the 

4 biomonitoring, was everybody --

5 DR. GLOVER: It was very small. I 

6 mean, if you look at the --

7 CHAIRMAN ANDERSON: I mean, we had 

8 67 people --

9 DR. GLOVER: In 1948, there were 

10 1,156 external dosimetry results. There were 

11 164 bioassay results. So, and you know, we 

12 also, how do we know we have everything in 

13 these records? We would have to have a record 

14 to compare. 

15 I don't know if we have ever gone 

16 to Union Carbide and said, do you have a list 

17 of people who only worked in that facility. I 

18 would have to find that out. We would have to, 

19 that would be the only way it could be more 

20 restrictive. And the Department of Labor is 

21 really responsible for putting them in the 

22 building.
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1 MR. HINNEFELD: Well, the fact that 

2 they were employed in the covered facility --

3 DR. GLOVER: In the covered 

4 facility.

5 CHAIRMAN ANDERSON: The question is 

6 --

7 MEMBER GRIFFON: Henry.

8 CHAIRMAN ANDERSON: -- if it comes, 

9 is that -- 

10 MEMBER GRIFFON: I just wanted to 

11 ask you a question for clarification.

12 CHAIRMAN ANDERSON: Go ahead.

13 MEMBER GRIFFON: Is this for 42 

14 through 53 and is there another part from 53 

15 to 59 or something like that?

16 DR. GLOVER: There is a shut-down 

17 period from 1953 to 57.

18 MEMBER GRIFFON: Okay.

19 DR. GLOVER: That would be kind of 

20 a residual contamination time frame.

21 MEMBER GRIFFON: So there was 

22 another petition submitted for that later 
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1 period, is that correct, or -- because I am 

2 looking on the website. It looks like there 

3 were two.

4 DR. GLOVER: I will pull up our 

5 report. We actually would have described those 

6 in the summary.

7 MEMBER GRIFFON: Okay.

8 MR. THURBER: Both petitions were 

9 for the same period, I believe.

10 MEMBER GRIFFON: Oh they were? All 

11 right.

12 MR. THURBER: I think so.

13 MEMBER GRIFFON: Maybe I am 

14 misreading that. But it looked like two 

15 petitions and it looked one went up to 1959. 

16 The proposed covered period, anyway, by the 

17 petitioner.

18 MR. THURBER: Yes, and I believe 

19 that was modified.

20 MEMBER GRIFFON: Oh, okay. Okay.

21 MR. THURBER: But let me see if I 

22 can be more precise about that.
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1 MEMBER GRIFFON: Because that 

2 might, my other question would be, I guess, if 

3 it's only going up to 53, it's pretty easy to 

4 believe the assumption of no recycled uranium 

5 issues or anything like that.

6 MR. THURBER: Yes. 

7 MEMBER GRIFFON: If it goes to 59, 

8 then I guess I was wondering -- but it sounds 

9 like there were no, it wasn't operational; it 

10 was residual period after 53.

11 MR. THURBER: And what actually 

12 happened here is that the one petitioner who 

13 originally proposed that it cover the period 

14 from 1952 to 1959 but then NIOSH went back to 

15 her and she agreed that it was acceptable to 

16 change the covered period to be from 1942 to 

17 1953.

18 MEMBER GRIFFON: Well what is the 

19 covered period established by DOE?

20 MR. THURBER: That.

21 MEMBER GRIFFON: That is, okay, so 

22 she had, yes, it wasn't really NIOSH 
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1 determining that, it was, okay. Okay.

2 DR. GLOVER: The covered time 

3 period is 1942 through 53. So that is all we 

4 can evaluate.

5 MEMBER GRIFFON: Okay. And there 

6 was no thorium work done at this site at all, 

7 right, it was just --? 

8 MR. THURBER: No.

9 MEMBER GRIFFON: Okay. All right. 

10 Thank you.

11 MR. THURBER: Should we go on?

12 CHAIRMAN ANDERSON: Well, I mean, 

13 what kind of an answer are we looking to, to 

14 that first one?

15 DR. GLOVER: I think we can 

16 summarize --

17 CHAIRMAN ANDERSON: Is finding one 

18 an observation or is it a --

19 DR. NETON: No, I think we can 

20 provide a response --

21 CHAIRMAN ANDERSON: Okay.

22 DR. NETON: -- which I think we all 
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1 agreed to, is that this is a covered facility 

2 and this is no way to apportion that --

3 CHAIRMAN ANDERSON: Yes. Yes.

4 DR. NETON: -- that work at 

5 anything less than the whole facility.

6 MEMBER FIELD: At most, you could 

7 probably ask DOL to ask if they have 

8 information for who worked in that building. 

9 Is that something that is part of the process?

10 DR. NETON: That would be the 

11 process if we were deciding to add a Class, 

12 but we are saying that we could do the work, 

13 reconstruct exposures for all workers at the 

14 plant, we could.

15 MR. ALLEN: One technicality on 

16 this is it's labeled as a Department of Energy 

17 facility and it only goes through 53 and that 

18 usually means there's some proprietary 

19 interest, which would be that Area Plant you 

20 are talking about, the AEC built that plant or 

21 owned, had some ownership in it, and with that 

22 being the covered facility, I think that 
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1 essentially means the Area Plant is the 

2 covered facility.

3 So any claimants we are getting 

4 technically, DOL has decided are part of that 

5 Area Plant, not part of the commercial plant 

6 that is adjacent to it, whether they are doing 

7 this accurately or whether, you know, how they 

8 are doing that, I don't know.

9 MR. THURBER: As they say, one 

10 petitioner said the Area Plant, the other one 

11 said Electro Met and when the petitions were 

12 merged, it's my understanding that whoever 

13 makes those decisions said that it will be the 

14 entire Electro Met plant.

15 DR. GLOVER: I will commit to 

16 clarifying the covered facility definition, 

17 what they really are doing. How does that 

18 sound? I will make sure we respond to that.

19 CHAIRMAN ANDERSON: I mean, the 

20 issue, if there are so many workers that 

21 weren't even exposed there but you are going 

22 to -- it certainly could be viewed as claimant 
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1 favorable, but certainly is not an accurate 

2 reflection of what their exposure was for the 

3 rest of Electro Met. 

4 So you are way over.

5 DR. GLOVER: Only if I can put him 

6 there.

7 CHAIRMAN ANDERSON: I know, but I 

8 mean if the whole thing is, if you worked at 

9 Electro Met, even in their commercial 

10 facility, during this period of time, but they 

11 weren't -- see, that, --

12 MR. KATZ: You are not estimating 

13 those. You are not estimating doses beyond the 

14 AEC doses. So that's not --

15 DR. NETON: Dave Allen's point is a 

16 good one. By the time we get these, the 

17 Department of Labor has determined they worked 

18 at the covered facility. I mean, they worked 

19 at an AEC facility. That's what they are 

20 saying, and so that exposure is covered and so 

21 we reconstructed the exposure for the AEC 

22 period.
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1 CHAIRMAN ANDERSON: So you would 

2 only, you would have to put them into the --

3 MR. KATZ: DOL is putting them in. 

4 In effect, DOL is saying these people are part 

5 of that building, even whether they are 

6 accurately doing that or not, they are.

7 CHAIRMAN ANDERSON: And that 

8 building is not in that whole commercial 

9 plant.

10 MR. THURBER: No.

11 CHAIRMAN ANDERSON: That's where I 

12 am confused.

13 MR. THURBER: Yes. If an employee 

14 of Electro Met in this relevant time period 

15 applies for compensation, NIOSH will do a does 

16 reconstruction and decide on the basis of the 

17 procedures here, the guidance that 

18 the dose reconstructor uses, whether the man 

19 is compensated or not, regardless of where he 

20 worked within that facility. Is that correct, 

21 Jim?

22 MR. HINNEFELD: Well, there's one 
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1 step between their application and our dose 

2 reconstruction, and that is that the 

3 Department of Labor verifies that they were 

4 employed at the covered facility. And so --

5 at the end the Department of Labor sends it to 

6 us for dose reconstruction.

7 So what Dave's point was -- now, 

8 let me, here I am talking again. Dave's point 

9 was that this site is characterized as a DOE 

10 site, not as an Atomic Weapons Employer. What 

11 that means is that there was some piece of 

12 Electro Met that the DOE built. I think the 

13 contract even said they essentially had built 

14 or AEC had built, or MED, for this purpose.

15 And so it was essentially their 

16 building, their facility. And so 

17 realistically, then, the people who worked in 

18 the AEC part of Metallurgical are the ones who 

19 are the covered employees. And so, by 

20 extension, by the fact that it is in -- by 

21 considering it a DOE site, then our conclusion 

22 logically is that the Department of Labor, in 
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1 verifying the employment of that person, has 

2 essentially reached the decision that that 

3 person worked in the DOE site of Electro Met. 

4 Now, in reality, are they doing 

5 that? I doubt it. I imagine they are writing 

6 to Union Carbide, Union Carbide says, they 

7 worked at Electro Metallurgical and that's all 

8 we know. I don't know if that's the case or 

9 not, but it, very often that is what happens.

10 So I mean, we can ask DOL what 

11 they are getting, you know, what they are 

12 asking for and what they are getting, we can 

13 do things like that. But, you know, from our 

14 standpoint, in terms of the logic of the law, 

15 to the extent that there is logic in this law, 

16 the logic of the law is that the decision has 

17 been made, essentially, by the Department of 

18 Labor that these people work in the DOE site 

19 at Electro Met. 

20 And so we can proceed with, you 

21 know, we can, you know, it's to our advantage 

22 to just say, okay, then we are doing the dose 
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1 reconstruction. I mean, that's the logic of 

2 the process.

3 MR. KATZ: Right. The only 

4 distinction I would make to that though is 

5 when it comes to an SEC petition, I think, 

6 unless there's someone who has already been 

7 through a dose reconstruction process, it 

8 falls in our laps to determine that they are a 

9 qualified petitioner.

10 MR. HINNEFELD: A qualified 

11 petitioner.

12 MR. KATZ: Petitioner, right. So 

13 that we would then have to verify that they 

14 were employed by the proper AEC site. But if 

15 they already came through the dose 

16 reconstruction process and they are a 

17 petitioner, we would assume that DOL had done 

18 that.

19 MR. HINNEFELD: Okay. 

20 DR. MAURO: But, if the definition 

21 of the Class that's been qualified is Electro 

22 Met, not the Area Plant but Electro Met, by 
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1 definition, there is -- that's -- it's 

2 presumed that if you -- because by definition 

3 --

4 DR. NETON: But that's the 

5 definition of facility. You can't qualify 

6 anything else.

7 MR. HINNEFELD: All we did was --

8 DR. MAURO: And that is fine, I 

9 mean, all we are doing is pointing out that 

10 there's this very large facility with lots of 

11 people where clearly, based on the research we 

12 did, most of the people that worked at Electro 

13 Met were not involved in any of this activity. 

14 The degree to which that can be 

15 demonstrated, proven to be, to the 

16 satisfaction of, I guess, the Department of 

17 Labor, but the best we can tell, this was a 

18 very large facility involved primarily in 

19 metallurgical, commercial activities. A very 

20 small part of it was involved in this 

21 particular area. 

22 The way in which the Class is 
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1 defined is Electro Met. So by definition, if 

2 you just go by the Definition of the Class, 

3 anyone that worked at Electro Met --

4 DR. NETON: Well there is no other 

5 option to define the Class.

6 DR. MAURO: And that's fine. We 

7 are just letting everyone know that we've got 

8 the situation.

9 CHAIRMAN ANDERSON: And my point 

10 being is if 90 percent of the people working 

11 at Electro Met had no exposure, how reasonable 

12 -- I mean we have to look at it, is 

13 reasonable, are you --

14 DR. MAURO: That's the only reason 

15 we bring it up.

16 CHAIRMAN ANDERSON: -- dose 

17 reconstruction for those people. How, you 

18 know, can you really dose reconstruct for 

19 everybody at Electro Met? 

20 MR. KATZ: This is becoming 

21 circular. But, again, the facility definition 

22 is actually just the DOE portion of that --
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1 Electro Met. That is the facility definition 

2 is what I am hearing from David.

3 MR. HINNEFELD: Well, it depends 

4 on whether you are choosing the words or 

5 whether you are choosing the designation 

6 category. The words say Electro Met. 

7 CHAIRMAN ANDERSON: Yes. 

8 MR. HINNEFELD: The designated 

9 category says it's an AEC facility or DOE 

10 facility. So it's, you know, that's where the 

11 --

12 CHAIRMAN ANDERSON: I don't have 

13 any problem --

14 MR. HINNEFELD: -- departing from.

15 CHAIRMAN ANDERSON: -- with the 

16 facility where it was work. My concern is 

17 when you now open the Class far broader than -

18 - and is what -- if DOE is saying it's just 

19 the facility at Electro Met where they did, 

20 where they owned the building, whatever it is, 

21 that's quite different. Now how they, if they 

22 qualify everybody regardless of where they 
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1 worked, if their intent was just that 

2 facility, then the dose reconstruction for 

3 that facility --

4 MR. KATZ: What I am saying to you 

5 is if this were an AWE facility, you would 

6 then have concern because the entire facility 

7 would be covered and you would have concern 

8 about any radiological exposures anywhere in 

9 the facility. In this case, because this is a 

10 DOE facility, the only radiological exposures 

11 that DCAS has to be concerned about are those 

12 that occurred in the building of concern 

13 because those are the only covered 

14 radiological exposures.

15 MR. THURBER: In principle, but, 

16 as Stu said, in practice, it's not happening.

17 MR. KATZ: No, but you are missing 

18 my point. You are missing my point. The only 

19 radiological exposures that have to be 

20 reconstructed are the ones that occurred under 

21 the AEC operation. That's the only 

22 obligation.
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1 If people are pulled into the 

2 Class because they worked elsewhere in Electro 

3 Met by the way this is administered, it's not 

4 a concern for DCAS because they only have to 

5 accurately estimate with sufficient accuracy 

6 the radiological exposures that are covered. 

7 And those are the ones within the DOE 

8 facility.

9 It's not -- it's a non-issue 

10 whether they are capturing any other exposures 

11 because they are not covered under EEOICPA. 

12 CHAIRMAN ANDERSON: But you are 

13 assigning exposures.

14 MR. KATZ: But that's not the --

15 they don't have to be accurate for any 

16 exposure outside as long as they are capturing 

17 the exposures within -- that are covered, it 

18 does the job. And if DOL is funneling 

19 individuals in that didn't work in that 

20 building, that's not an issue for DCAS in 

21 terms of estimating doses with sufficient 

22 accuracy because they are not estimating any 
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1 other doses.

2 CHAIRMAN ANDERSON: But is the 

3 dose that you are estimating, based on your 

4 assumptions, accurate?

5 MR. KATZ: If DOL is saying we 

6 can't distinguish who worked inside the DOE 

7 facility so we are going to funnel everybody 

8 through this, that's sort of a given. You are 

9 given this individual, you have to assume this 

10 individual did work in the building because 

11 DOL cannot distinguish. So that is just a 

12 given assumption.

13 CHAIRMAN ANDERSON: Moving right 

14 along --

15 MEMBER FIELD: Is the next step to 

16 say you will clarify with DOL?

17 DR. GLOVER: I submit and I will 

18 clarify --

19 MR. HINNEFELD: -- we can find out 

20 what they are doing.

21 CHAIRMAN ANDERSON: I think that's 

22 all, that's really all I want because it 
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1 sounds like, you know, their intent is there, 

2 which is really what we are after.

3 MR. KATZ: Just, my point is, you 

4 could not -- the Board could not decide to 

5 create an SEC Class for the individuals who 

6 did not work in the building because these are 

7 too high exposures because there is no 

8 coverage, there's no other covered exposures 

9 to have an SEC Class outside of the people who 

10 worked in that building. There's no coverage. 

11 You can't create an SEC Class for people who 

12 aren't covered.

13 CHAIRMAN ANDERSON: Right. 

14 MR. KATZ: Or for operations that 

15 aren't covered. That's all I'm trying to say.

16 CHAIRMAN ANDERSON: Okay. Number 

17 two. We are going to check.

18 MR. THURBER: We do the hardest 

19 ones first. Okay. There is some evidence 

20 that a limited amount of work may have been 

21 done outside of the Area Plant, particularly 

22 in the research laboratory.
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1 I suspect that the amount of work 

2 was small, but I think it's important that 

3 this aspect be addressed and it be 

4 demonstrated that whatever went on in the 

5 laboratory doesn't really affect the ability 

6 to reconstruct the dosage, or it would change 

7 them in any way. That's all. Second finding 

8 in the process.

9 DR. GLOVER: I didn't re-read your 

10 piece when I re-read that but, so, since we 

11 just had a discussion of facilities, do you 

12 mean outside the covered building?

13 MR. THURBER: Outside the Area 

14 Plant. Everything is covered.

15 DR. GLOVER: Yes, well, outside 

16 the Area Plant.

17 MR. THURBER: Outside the Area 

18 Plant, yes, there's a research laboratory 

19 right next door, and there's some evidence 

20 that some work was done there prior to the 

21 start-up of the Area Plant.

22 DR. GLOVER: That would not be a 
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1 DOE facility, perhaps.

2 MR. KATZ: Not covered.

3 MR. ALLEN: You would have to go 

4 to DOL and get them to recognize that as an 

5 AWE.

6 DR. GLOVER: It would have to be a 

7 separate designation.

8 MR. THURBER: Okay. Fine.

9 DR. GLOVER: I am not, I am just -

10 - okay, I just want, since we are clear, to 

11 figure out, that's a, the finding two, I can -

12 - we can begin follow-up on that.

13 MR. THURBER: Yes. Sure.

14 CHAIRMAN ANDERSON: Did -- did 

15 they know about it?

16 DR. GLOVER: Well, I saw some of 

17 the things, we can look at that and see if 

18 there's a reason, we can give them what 

19 information; we do not create a covered 

20 facility.

21 CHAIRMAN ANDERSON: Right.

22 DR. GLOVER: We can give them the
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1 evidence, and it's their choice.

2 CHAIRMAN ANDERSON: No, I mean, if 

3 they are saying all of Electro Met, then it 

4 would be covered. If they're not, it isn't, 

5 that's really -- what would you do?

6 DR. GLOVER: Right.

7 CHAIRMAN ANDERSON: I assume you 

8 haven't gotten any lab techs who have applied 

9 yet, so they haven't made it through the 

10 clearance site. 

11 MR. HINNEFELD: I wouldn't 

12 guarantee we didn't.

13 CHAIRMAN ANDERSON: Well, I mean, 

14 if you did, then it would mean there's a 

15 moderate likelihood, but moving right along.

16 MR. THURBER: Good.

17 CHAIRMAN ANDERSON: Go ahead.

18 MR. THURBER: Finding three is 

19 kind of related. It says that there is some 

20 evidence that a little work was done prior to 

21 the start-up of the Area Plant. Was it 

22 significant and does it change the start date? 
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1 That's something that is given to you, you 

2 know, we understand.

3 But, and on the other end of that, 

4 there was no provision for residual exposure 

5 in your Evaluation Report, and there was 

6 several years, three or four years, I guess, 

7 between the time that the AEC contract ended 

8 and the building was demolished, so there is a 

9 question of whether there was residual 

10 exposure or not. And so that all ties in with 

11 being sure that the --

12 DR. GLOVER: We could only do the 

13 covered -- because DOL closes it in 1953, that 

14 ends when we can actually legally evaluate it 

15 so -- but anyway, that is why it had to be 

16 terminated at that point.

17 MR. THURBER: Okay.

18 DR. GLOVER: But the start date I 

19 think, you know, you mentioned the start date, 

20 and I think we may have started in April of 

21 `43, and there is discussion there about them 

22 doing work before that in November of --
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1 MR. THURBER: In the fall, 

2 November of `42, 

3 DR. GLOVER: `42.

4 MR. THURBER: You know, that sort 

5 of thing.

6 DR. MAURO: You lost me a little 

7 bit. So you are saying by definition, any 

8 exposure workers might have experienced after 

9 the covered period are not going to be 

10 included in the dose reconstruction?

11 DR. GLOVER: That is absolutely 

12 correct.

13 MR. HINNEFELD: For a DOE facility 

14 there is no residual aspect. The residual 

15 contamination part of the law --

16 DR. MAURO: I've been spending too 

17 much time working on AWEs.

18 MR. HINNEFELD: -- applies to AWEs

19 MR. THURBER: Okay. We kind of 

20 talked a little bit about this finding four 

21 this morning. And the basic assumption that 

22 NIOSH made regarding their ability to 
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1 reconstruct the doses was that even though 

2 there was very little information prior to 

3 1947 or 1948, that one was dealing with the 

4 same process the entire period and so it was 

5 not unreasonable to take the `47, `48-era data 

6 and back-extrapolate that, if you will, to the 

7 beginning of operations in 1943.

8 We provide a number of arguments 

9 in our review paper that both support and 

10 refute that position. One of the arguments is 

11 cited here. There was a report from the AEC 

12 to Congress, and it says that many changes 

13 were made in the end of 1947 to improve the 

14 process.

15 So if that is the case, is it 

16 reasonable to say 1942 through `47 were the 

17 same as `48 and on, and we think that that 

18 point needs to be addressed more vigorously. 

19 And we provide, as I say in our document, a 

20 number of other arguments that speak to both 

21 sides of that coin.

22 DR. GLOVER: I think we also 
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1 agreed back-extrapolating in that time frame. 

2 We are getting all the data together, as I 

3 previously mentioned. We will look at how 

4 bioassay affects our decision, how we best 

5 move forward, maybe we compare that event to 

6 the `48 data. 

7 I will say that we are, I believe, 

8 just off the top of my head -- 1,000 MAC 

9 numbers which are near what we consider the 

10 boundable, sustainable dust-loading from these 

11 operations, I think. So, because we need to 

12 look at all the different --

13 DR. NETON: I just talked to Sam, 

14 we have some 1948 bioassay data, and one could 

15 balance that against the intakes that were 

16 projected back in the 1,000-MAC era and sort 

17 of see if they make sense.

18 DR. GLOVER: If the same people 

19 work.

20 DR. NETON: If you have the same 

21 people working, if they had worked during the 

22 -- early years.
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1 DR. GLOVER: We will certainly 

2 pursue that.

3 MEMBER FIELD: The way I'm reading 

4 this comment here, this second part, it sounds 

5 like there are changes --

6 DR. GLOVER: Yes.

7 MEMBER FIELD: -- in, maybe, the 

8 amount of bioassay or other factors, but it 

9 doesn't look like process.

10 DR. GLOVER: It's unclear. They 

11 said that they made a survey and they made 

12 changes to the operations, if you read the 

13 full text, so it's possible that there may be 

14 some changes that occurred. I think most of 

15 it -- I believe they perhaps did more 

16 respiratory protection, and they, at a later 

17 time they do begin speaking about making these 

18 guys wear respirators in that bomb reduction 

19 room. So --

20 MR. THURBER: And on the subject 

21 of bioassays, we did an analysis in our review 

22 paper where we compared the bioassays from 
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1 1943 and, what was it, `48. Whichever, and we 

2 couldn't show that they were statistically 

3 different. So as I say, there are arguments 

4 on both sides of the question as to the 

5 reasonableness of this assumption.

6 CHAIRMAN ANDERSON: Why don't we 

7 just look it over, make a decision. 

8 DR. NETON: Thanks for helping 

9 out. 

10 (Laughter.)

11 CHAIRMAN ANDERSON: Which way do 

12 you come down?

13 MR. THURBER: -- job description.

14 DR. GLOVER: We did not fully 

15 scope that because we relied on late-term data 

16 and back-extrapolated. We are now fully 

17 scoping all the data and seeing what our best 

18 options are to evaluate our path forward, 

19 whether that's bioassay, whether that's -- so 

20 we have captured new documents since we left 

21 this so --

22 DR. NETON: Did you say there was 
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1 documents at NARA that you picked up recently 

2 or --

3 DR. GLOVER: There was NARA, there 

4 was also, there are a number of new reports by 

5 the, in the Buffalo Corps, so there's some new 

6 -- there's like, just 50 or 60 that we have 

7 seen just since -- I had Cheryl do a quick 

8 search. There's other documents. There's 

9 also some stuff at Hanford's. We want to make 

10 sure that nothing in that affects our 

11 decisions.

12 MR. THURBER: And we haven't 

13 looked at any of that documentation either, or 

14 not either, we haven't looked at that 

15 documentation.

16 CHAIRMAN ANDERSON: When do you 

17 expect this to be done?

18 DR. GLOVER: With the current 

19 documents we have in house, I guess, I should 

20 have a draft of what they put together by the 

21 end of July --

22 CHAIRMAN ANDERSON: Okay.
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1 DR. GLOVER: -- early August. And 

2 so we will if anything else comes with the 

3 other documentation. So, in August, I think we 

4 should have our hands around what data we 

5 have.

6 CHAIRMAN ANDERSON: Great. Okay. 

7 MR. THURBER: Finding number five 

8 is minor. There is an inconsistency in the 

9 report regarding whether there is some 

10 available data for the stand-by period or not, 

11 and there is some data, as we indicate here, 

12 that should be, that should be tidied up in 

13 the report.

14 MR. KATZ: So is that a 

15 clarification that needs to be made in the 

16 report, is that what you are saying?

17 MR. THURBER: Yes. It says 

18 original stand-by data -- we provided a 

19 reference, or we have cited the reference. 

20 It's one that we, everybody has, of x, that's 

21 the --

22 MR. KATZ: Thank you. 
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1 MR. THURBER: Finding number six 

2 speaks to basically a generic problem with 

3 sampling, air sampling, as to whether it is 

4 breathing zone samples, whether the device is 

5 attached to a worker's lapel, whether it's a 

6 general area sample away from the operation, 

7 or whether it's a general area sample that is 

8 quite close to the operation.

9 And in a lot of the sampling that 

10 was done, we believe that the sampling was --

11 the fixed head samplers that were probably 

12 fairly close to the operator but this -- it's 

13 important that this point be addressed because 

14 it does make a big difference.

15 DR. GLOVER: When we look at the 

16 date we will certainly make sure if we are 

17 using BZ process, GA --

18 DR. NETON: Were these the HASL,--

19 DR. GLOVER: Well, `43 would have 

20 been military, some of those guys, so we did 

21 have some HASL measurements, so it would be 

22 time-dependent. We will make sure that we --
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1 we will make sure, and I'll -- we'll respond 

2 to it, we will make sure we properly --

3 MR. THURBER: Because, you know, 

4 some of the `48 measurements, as you say, 

5 there is some very high measurements in the 

6 green room where the workers were exposed to 

7 the uranium -- where they are putting the bomb 

8 together, the uranium tetrafluoride being 

9 mixed with the magnesium, and that was 

10 terribly high -- there were terribly high 

11 exposures in that area.

12 It appears that a lot of those 

13 samples were taken four-and-a-half feet off 

14 the ground and presumably at a fixed-head 

15 sampler and it is important to establish 

16 whether that measurement is the kind of 

17 exposure the worker actually got or not. I 

18 think that's what kind of underlies that 

19 finding.

20 CHAIRMAN ANDERSON: Yes. Okay.

21 MR. THURBER: Finding seven, you 

22 know, relates to job titles and whether job 
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1 titles really relate to job descriptions or 

2 whether things were highly interchangeable, 

3 and it is important to provide guidance that 

4 if you, for example, if you don't know the job 

5 descriptions, you assumed worst case or 

6 whatever.

7 But it is a point that is not 

8 adequately -- we didn't feel it was adequately 

9 addressed within the Petition Evaluation 

10 Report.

11 CHAIRMAN ANDERSON: Are you using 

12 job titles though? I thought you were just 

13 assigning everyone basically the same --

14 DR. GLOVER: I didn't think we 

15 were --

16 CHAIRMAN ANDERSON: I didn't think 

17 --

18 DR. GLOVER: -- we weren't trying 

19 to break down this in my review. We were 

20 using a pretty maximizing addition to -- I 

21 won't say a maximizing addition -- we were 

22 using -- because we couldn't put people in 
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1 places, we took that exposure which represents 

2 the 95th percentile or whatever, this is the 

3 condition which would be bounding, and that's 

4 what people were evaluated against.

5 DR. NETON: If you look at what 

6 Sam said earlier, 90 claimants, if 44 of them 

7 were over 50 percent PC. Clearly we haven't 

8 been doing much in the way of triaging these 

9 people by job title.

10 CHAIRMAN ANDERSON: But that -- if 

11 it doesn't say that, that's a clarification 

12 you can just --

13 MR. THURBER: In Appendix C, you 

14 do provide job categories, so the answer is 

15 that --

16 DR. GLOVER: Appendix C has some 

17 information.

18 DR. NETON: We probably aren't 

19 using the -- or --

20 MR. THURBER: And they may not be, 

21 but it's a question that needs to be 

22 addressed.
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1 DR. NETON: That's a good point.

2 MR. THURBER: Yes, what the dose 

3 reconstructor does is different than what the 

4 review talks about in some cases.

5 DR. GLOVER: We will verify 

6 against what --

7 MR. THURBER: Okay. In doing our 

8 review of the Electro Met exposures and -- we 

9 found that the inhalation intakes were quite a 

10 bit higher than those in the generic document, 

11 TBD-6001, which then raises the question about 

12 TBD-6001 as to whether those numbers are 

13 appropriately conservative and claimant 

14 favorable or not.

15 DR. MAURO: So this is more a 

16 comment on TBD-6001 -- 

17 MR. THURBER: Yes.

18 DR. MAURO: -- than it is on 

19 Electro Met. 

20 MR. THURBER: Yes, it is. 

21 CHAIRMAN ANDERSON: Yes, does 6001 

22 represent all of the facilities when you have 
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1 Electro Met --

2 DR. MAURO: It almost begs the 

3 question, okay, if you are going to use TBD4 6001 and -- for some dose reconstructions at 

5 another facility, I guess there has to be some 

6 assurance that the conditions at this other 

7 facility are not such that, yes, that you have 

8 bounded it with 6001.

9 Clearly there are circumstances 

10 when even TBD-6001, which is designed to be 

11 bounding and trying to capture most AWE 

12 facilities, may not capture most -- some AWE 

13 facilities, and there's an example.

14 Obviously from this, if for some 

15 reason, Electro Met did not have the data, and 

16 you were going to assign a reconstructor --

17 you understand -- you would have missed the 

18 dose. You would have underestimated the dose 

19 for this person. So it goes toward TBD-6001.

20 MR. KATZ: So can we really re21 label this because this is really a finding 

22 for the TBD-6001?
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1 MR. THURBER: And we say that in 

2 the bottom line --

3 MR. KATZ: I just mean for future 

4 tracking, we should really shift this over to 

5 be a comment on 2001 TBD rather than Electro 

6 Met comment, that's all.

7 DR. MAURO: Matrix. 

8 MR. KATZ: So then David can knock 

9 it off with his White Paper or whatever. 

10 DR. GLOVER: How about we don't --

11 just don't re-number that because we can still 

12 use the same finding numbers, and we don't --

13 but they just move somewhere else.

14 MR. KATZ: Sure.

15 DR. GLOVER: Not Sam's problem.

16 (Laughter.)

17 MR. THURBER: We will, that's the 

18 initial response, this is moved to --

19 DR. MAURO: You transferred it. It 

20 sounds like --

21 DR. GLOVER: Transferred it, 

22 that's nice.
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1 MR. THURBER: Okay. Okay. 

2 Finding ten. One of the problems that people 

3 who were doing this bomb reduction experience 

4 was it's almost uncontrolled explosion of the 

5 bomb and a lot of contamination.

6 And so this was clearly an 

7 important issue which was examined in the 

8 Petition Evaluation Report. NIOSH concluded 

9 that they had no evidence that these had 

10 occurred at Electro Met. We looked at the 

11 same information, we said yes, that's what it 

12 says.

13 But we were troubled by the fact 

14 that these had occurred everywhere else that 

15 this process was practiced, and it was a 

16 fairly common occurrence. And so we felt that 

17 it needed further examination.

18 It wasn't clear to us what magic 

19 Electro Met had that they were avoiding this. 

20 Now when we prepared our review we said we 

21 are going to try and do some more interviews 

22 of people who worked there to see what we 
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1 could find. At the time we did the report, we 

2 had talked to one worker who said he had no 

3 knowledge that blow-outs occurred, supportive 

4 of what the Petition Evaluation Report says.

5 Since that time we have talked to, 

6 I believe, four more people, and three of them 

7 said blow-outs did not occur. One guy said 

8 well, sometimes we got a minor release but, 

9 you know, nothing kaboom. 

10 One of my concerns with the 

11 additional people that we have talked to was 

12 they were primarily chemists who would only go 

13 out into the production area sometimes. It 

14 wasn't clear that they were totally 

15 knowledgeable about this subject, not that it 

16 was a big place, because it wasn't, and you 

17 would think that if there was an explosion 

18 that everybody would know about it.

19 But we are trying to find some 

20 additional people who were actually working in 

21 production to see if we can put this to bed.

22 DR. GLOVER: Do we have your 
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1 interviews by the way, the additional 

2 interviews that you have conducted, the ones 

3 that you are discussing now?

4 MR. THURBER: I don't know. I 

5 will have to talk to Kathy about that. You 

6 should have them, yes.

7 DR. GLOVER: Because it's not 

8 automatic that we get them. Let us make sure 

9 that we --

10 MR. THURBER: I will take care of 

11 it.

12 DR. MAURO: It is part our 

13 procedure that you get everything we get, and 

14 I think it first goes through a DOE clearance 

15 and then it goes to you. If you haven't 

16 received it yet, you will.

17 MR. THURBER: But I will be sure 

18 that that happens.

19 DR. GLOVER: Because in certain 

20 time frames that is true and maybe more 

21 recent, because I like -- anyway, I appreciate 

22 it.
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1 MR. THURBER: Yes. We will take 

2 care of it.

3 DR. GLOVER: That would be good. 

4 Because I want to make sure we are not talking 

5 to the same people.

6 DR. MAURO: This is pretty recent, 

7 right?

8 DR. GLOVER: Because we may want 

9 to follow up on some stuff, so we will make 

10 sure we continue to talk to people and make 

11 sure we are both aware of what we are doing 

12 so, aggravate the same people, since they are 

13 very old. They are knowledgeable about this 

14 process.

15 MR. THURBER: Some of these 

16 interviews are really quite interesting, the 

17 people's attitudes about the situation. They 

18 are refreshing. Sorry.

19 MR. KATZ: So SC&A is still -- are

20 you still hunting down some --

21 MR. THURBER: We are trying to get 

22 somebody that was in the production area --
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1 MR. KATZ: Right.

2 MR. THURBER: -- rather than in 

3 the lab. Because most of the people were 

4 chemists, you know, and I think kind of one 

5 chemist says why don't you talk to this other 

6 chemist, but we do have some other names we 

7 are trying to locate.

8 DR. GLOVER: So is this still an -

9 - should we consider this an SC&A issue still 

10 at this time, rather than passing it on to me 

11 because we are still in, it sounds like you 

12 are still --

13 MR. KATZ: It sounds like they are 

14 still trying to confirm that, so yes, it 

15 sounds like it's still on your plate.

16 DR. MAURO: Yes, I mean, Kathy is 

17 trying to schedule interviews with selected 

18 people, yes.

19 MR. THURBER: I am quite happy to 

20 leave this on our plate.

21 DR. GLOVER: I mean, I would, I 

22 would love to be, you know, when an interview 
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1 happens, just so we could, you know, because 

2 that way I can hear what they --

3 DR. MAURO: Well, I mean, we --

4 DR. GLOVER: -- say.

5 DR. MAURO: -- when we do that, I 

6 mean, protocols require us to inform you that, 

7 you know, we are making certain -- we have 

8 identified certain people, we are scheduling 

9 certain interviews, and we are required by our 

10 procedures to inform you of that, that this 

11 process is moving forward.

12 DR. GLOVER: We had a change of 

13 people, so since now it's my site, we may have 

14 an -- so we just want to make sure that --

15 DR. MAURO: Okay.

16 DR. GLOVER: But that would be 

17 great.

18 MR. THURBER: I will take care of 

19 it. 

20 MEMBER FIELD: If we do some more 

21 interviews and everyone says no, what's the 

22 difference? Probably never know.
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1 DR. MAURO: In the end, we are in 

2 a situation where we are building a weight of 

3 evidence that in the end, again, becomes a 

4 judgment by the Work Group and then the Board, 

5 whether or not the weight of evidence is such 

6 that no, we can discount these explosions, 

7 these blow-outs.

8 MR. ALLEN: I was going to say the 

9 blow-outs happen when you build up a pressure 

10 in a sealed container, and based on the 

11 airborne you are seeing at Electro Met, I am 

12 not so sure it was that sealed.

13 (Laughter.)

14 CHAIRMAN ANDERSON: How much 

15 higher would it be if you had a blow-out? It 

16 was leaking all the time.

17 DR. NETON: It's a got 1,000 MAC 

18 air going all the time and in a blow-out --

19 it's an acute event. It happens; it generates 

20 some high airborne for --

21 DR. MAURO: For a short time.

22 DR. NETON: -- short period of 
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1 time.

2 MR. THURBER: But those, a lot of 

3 those measurements were made by HASL, and, you 

4 know, I would -- you would think they would 

5 have commented when they were making the 

6 measurements if this was an extraordinary 

7 occurrence rather than what they are just, 

8 what the sampler is sitting there sucking in. 

9 I don't know.

10 DR. MAURO: I mean, once the, you 

11 know, you have -- the way I always had it in 

12 my head was, you know, you have this bomb. 

13 That, when you reach that temperature, the 

14 conversion happens very abruptly, an extremely 

15 exothermic reaction. You know, and either the 

16 thing goes or it doesn't, and, you know, so, 

17 where you were saying that maybe it was 

18 leaking all along, I -- once that switch 

19 turns, that an exothermic reaction, either you 

20 have an explosion and the thing falls apart 

21 and you've got a real serious problem, I mean, 

22 walls comes down, or you don't.
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1 MEMBER FIELD: You would think a 

2 worker would remember that.

3 MR. THURBER: That's exactly the 

4 point, exactly the point, you know. Are we 

5 done with this finding? Okay.

6 Finding eleven, I think we have 

7 already talked about, and Ted advised that 

8 that is a definitional issue that is outside 

9 the scope of the technical review.

10 MR. KATZ: Right, it's not covered 

11 exposure --

12 DR. MAURO: Yes, I guess we should 

13 withdraw that since --

14 MR. THURBER: Yes, we will 

15 withdraw it on that basis, not covered 

16 exposure.

17 DR. GLOVER: By the time that this 

18 facility was -- I mean, it's not our call.

19 MR. ALLEN: Well, now when you are 

20 looking into, this is the residual one, it's -

21 - 

22 DR. GLOVER: Right, I mean, but it 
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1 closes in `53 though. It closed, you know, we 

2 could say, here's the information we have 

3 about `53 to `57. It's Department of Labor's 

4 call, though, if there's any covered activity 

5 there.

6 MR. ALLEN: You are digging into 

7 some of that --

8 DR. GLOVER: Yes.

9 MR. ALLEN: -- and you are going 

10 to find whatever you find and --

11 DR. GLOVER: Right. 

12 DR. NETON: -- contract, it's not 

13 covered.

14 DR. GLOVER: That's true.

15 MR. THURBER: Okay. Finding 

16 twelve. As Sam indicated, the bioassay data 

17 was not used, but they obviously looked at it, 

18 and they said that the calculated excretion of 

19 uranium was less than what you would calculate 

20 from the air samples so the air samples were 

21 bounding. And we did some calculations which 

22 we provided that suggested that might not be 
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1 the case, and so there's something that needs 

2 to be sorted out between NIOSH's calculations 

3 and ours.

4 DR. NETON: You used the same 

5 urinalysis data to conclude that it --

6 MR. THURBER: Yes, we took the 

7 same data, you know, there's the --

8 DR. NETON: Assuming what, acute 

9 exposure scenario, something of that nature?

10 MR. THURBER: Yes. Yes. 

11 DR. NETON: We will look at it.

12 MR. THURBER: Yes.

13 MR. KATZ: Sounds like you may 

14 need to share your actual calculations.

15 MR. THURBER: Yes, and I --

16 MR. KATZ: Yes.

17 DR. GLOVER: I mean it's here in 

18 the report, so --

19 MR. THURBER: I think that the 

20 detail is pretty much in the report, but if 

21 it's not, we can expand upon it, no question.

22 CHAIRMAN ANDERSON: How different 
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1 was it?

2 DR. NETON: It would be hard to 

3 imagine, given the high airborne intakes that 

4 we are finding that the urine data would show 

5 that it could have been higher than what we 

6 are finding. I just, it seems --

7 MR. THURBER: Well, let me see 

8 here.

9 DR. NETON: -- hard for me to 

10 fathom how that could happen. But, you know, 

11 it all depends on your assumptions, and I 

12 guess we'll just have to take a look. I 

13 haven't looked at those assumptions so I can't 

14 speak to that. 

15 MR. KATZ: So if you run through 

16 those and you have any problem identifying all 

17 the assumptions you need, you can just write -

18 - contact SC&A and get details to be able to 

19 confirm or refute the -- okay, so that's a 

20 DCAS follow-up.

21 DR. GLOVER: I think some of those 

22 are related to different exposure categories 
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1 like supervisors, if I'm reading your text 

2 here correctly. So, yes, we will be happy to 

3 -- we will make sure that we --

4 DR. NETON: That ties in with the 

5 previous finding which is what are we really 

6 using for exposure scenarios.

7 MR. THURBER: Right. We 

8 understand that it wasn't used, but, 

9 commenting on your comment.

10 DR. NETON: That makes some sense.

11 DR. GLOVER: I think that's right. 

12 Okay.

13 MR. THURBER: Finding thirteen. 

14 This in a sense relates to -- let me back up a 

15 second here. We were specifically tasked by 

16 the Board to review the Petition Evaluation 

17 Report for Electro Met. We were not tasked by 

18 the Board to review Appendix C, which is the 

19 Electro Met appendix to TBD-6001. But 

20 obviously, in the course of reviewing the 

21 Petition Evaluation Report we had to look at 

22 some parts of Appendix C to -- because they 
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1 tie together to a limited extent. 

2 And so this comment may relate 

3 more to Appendix C than to the Petition 

4 Evaluation Report, but we said that it's 

5 important to provide specific guidance in the 

6 Appendix C as to what to do if you don't know 

7 what the operator's description is. We talked 

8 about this this morning. There was excellent 

9 language in TBD-6000 providing that kind of 

10 guidance. We are suggesting that that kind of 

11 guidance would also be appropriate in Appendix 

12 C.

13 CHAIRMAN ANDERSON: Okay. 

14 MR. THURBER: The question of what you 

15 assume for the exposure from medical X-rays, 

16 we raised this before, and the document on 

17 medical X-rays suggests that you ought to use 

18 photofluorography, but the language in the 

19 document is a little hazy as to whether that 

20 guidance applies only to DOE sites or it 

21 applies to AWE sites as well.

22 And we think that point needs to 
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1 be clarified as to the intent, and if the 

2 intent is that it should be applied to 

3 everything, then the X-ray dose rates should 

4 be revised to assume that the technique was 

5 photofluorography rather than more 

6 conventional X-rays.

7 DR. MAURO: This is a DOE site. 

8 DR. GLOVER: This is DOE.

9 DR. MAURO: This is a DOE site. 

10 MR. THURBER: Well, okay, then --

11 DR. MAURO: Even more so.

12 MR. THURBER: Then the comment is 

13 that it should be photofluorography.

14 DR. MAURO: Unless you have 

15 evidence that the X-rays are -- the size, the 

16 small ones versus the big ones. 

17 DR. GLOVER: Five by sevens.

18 DR. NETON: I am not sure we have 

19 any evidence of that --

20 CHAIRMAN ANDERSON: One way --

21 DR. NETON: -- one way or the 

22 other.
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1 MR. THURBER: There is some 

2 language, I think, from one of the doctors 

3 talking about X-rays, but whether he is 

4 speaking generically or -- I don't know.

5 DR. NETON: My -- it's been a 

6 while since I've gone through this, but it 

7 seems the photofluorography was used when 

8 there was mass screens because it was cheap. 

9 You could take a picture, put the guy up 

10 there, take a picture, and move on.

11 And that's why we thought when we 

12 meant DOE sites I really think we meant to 

13 imply there the larger sites, where there 

14 would be a need for mass screening, where 

15 these smaller, mom and pop type AWEs would not 

16 benefit from that type of a procedure.

17 So I am not sure where Electro Met

18 falls. We will have to look into that a 

19 little closer, but that DOE guidance is a 

20 little misleading. What it really means was 

21 larger sites.

22 MR. THURBER: Okay.
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1 CHAIRMAN ANDERSON: It would 

2 depend on whether they had a program for the 

3 general plant. We are on the same -- these 

4 guys --

5 DR. GLOVER: The PFGs would be 

6 claimant favorable.

7 MR. THURBER: Oh yes, absolutely. 

8 And --

9 DR. GLOVER: Oh, we are not doing, 

10 okay.

11 MR. THURBER: No, they are not 

12 being done, and it is quite a big difference.

13 DR. GLOVER: Oh yes, it's very 

14 large.

15 DR. MAURO: Three rem --

16 DR. GLOVER: A couple rem. 

17 DR. MAURO: -- versus --

18 DR. NETON: As far as -- we have 

19 no idea whether they were even doing annual X20 rays as part of the condition of employment, 

21 and then you say okay, well not only do we not 

22 know they were getting them, we are going to 
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1 assign this photofluorography dose, I mean, 

2 it's sort of --

3 DR. MAURO: But that's what TBD 6, 

4 you know, Ron Kathren's TBD says that you 

5 should do for DOE sites.

6 DR. NETON: For DOE. I think the 

7 jury is still out on the AWE and the AWE-like 

8 DOE sites.

9 DR. MAURO: And you will see that 

10 comment on all our reviews on AWEs because 

11 really there is nothing right now in your 

12 guidance that says explicitly for AWE sites, 

13 you know, assume it's just X-rays.

14 DR. NETON: Well, see, we did have 

15 good evidence that it did occur at DOE sites.

16 DR. MAURO: Right.

17 DR. NETON: That's the key there. 

18 We have no evidence that it occurred at these 

19 smaller AWEs. 

20 MR. THURBER: I understand that. 

21 The language is ambiguous --

22 DR. NETON: You're talking --
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1 we'll address it.

2 MR. THURBER: Item fifteen --

3 finding fifteen. Again, this relates to 

4 Appendix C. We took what we thought was the 

5 same data set or what was close to the same 

6 data set and calculated the log-normal 

7 distribution parameters for the beta --

8 electron exposures, and we found good 

9 agreement with the values developed by NIOSH 

10 in table C5 of Appendix C.

11 We had not such good agreement for 

12 the supervisor labor category and the other 

13 category. Obviously these are less 

14 significant in terms of the total exposure 

15 that a person would receive, but we ought to 

16 try and reconcile why these differences --

17 DR. NETON: I am not clear, did 

18 you do a different type of analysis, like a 

19 rank order versus a curve fitting?

20 DR. MAURO: I don't know.

21 DR. NETON: That could be why 

22 there would be a difference if it's based on -
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1 - it's either a math error or a different 

2 technique. I am just trying to figure out 

3 which.

4 DR. GLOVER: We have got to see if 

5 these classes even exist in our current 

6 methodology. So we'll clean this up. We will 

7 look and see what the final number --

8 CHAIRMAN ANDERSON: It's kind of a 

9 --

10 DR. NETON: It would be 

11 interesting to know why there's a big 

12 difference like that because --

13 DR. MAURO: Did Harry do the work14 up on that?

15 MR. THURBER: Yes, Harry did it.

16 DR. MAURO: It's probably -- it 

17 may be a good idea to make sure that we did it 

18 the same way you did it. That might be the 

19 reason for the difference.

20 DR. NETON: I've got to -- well, I 

21 would think it might be.

22 DR. MAURO: And then --
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1 CHAIRMAN ANDERSON: Should agree 

2 at the fifth, at least. But the 95th, I mean 

3 --

4 DR. NETON: Again, I think if it's 

5 a rank order fit versus a linear fit for the 

6 data and then picking off the curve that could 

7 make a difference. We have seen that before.

8 DR. MAURO: But usually it's the 

9 95th where we really deviate, when you do a 

10 rank order versus --

11 DR. NETON: Not the fifth --

12 DR. MAURO: I know.

13 MR. THURBER: Yes, and I -- 

14 DR. NETON: I don't know how 

15 sparse this data is though.

16 MR. THURBER: I don't remember. I 

17 -- Harry typically uses the calculational 

18 method rather than the rank order graphical 

19 method, and that may be the cause. As we have 

20 pointed out in some other areas, you can get 

21 some fairly significant differences actually, 

22 depending on what the tails look like and 
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1 things.

2 DR. NETON: How you treat non3 detects.

4 DR. GLOVER: We are also making 

5 sure that we have as much data as we have 

6 available. I don't know if we had the same 

7 data set to work with so --

8 CHAIRMAN ANDERSON: And this is 

9 table C in the --

10 DR. GLOVER: Well, they compared 

11 the values that were generated, they didn't 

12 say whether they used the same data. They went 

13 and independently looked through the data.

14 MR. THURBER: Yes.

15 DR. GLOVER: So the numbers may, 

16 you know, they may have pulled additional data 

17 together since we put Appendix C together. 

18 Appendix C was not updated when we did the ER 

19 so that's several years old. So it could be a 

20 number of, you know, a number of years out of 

21 date.

22 MR. THURBER: Okay. Finding 
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1 sixteen again ties in with Appendix C and we 

2 note that table C5 and Appendix C, which deals 

3 with external exposure, has a category of 

4 "other skin" which is the skin other than the 

5 hands and arms.

6 But there is no information on 

7 hands and arms and we think the data should be 

8 added to specifically address the hands and 

9 arms.

10 DR. NETON: So this is the top crop 

11 issue with the surface contamination? Did 

12 Electro Met actually re-melt already cast 

13 ingots or derbies or did they --

14 MR. THURBER: Yes. They did vacuum 

15 induction melting of the bomb reduction 

16 derbies.

17 DR. NETON: That's only important 

18 issue if you have aged product, correct?

19 MR. HINNEFELD: Did they recast or 

20 did they just do bomb reduction?

21 MR. THURBER: No, they recast.

22 MR. HINNEFELD: They did recast?
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1 MR. THURBER: Yes. 

2 DR. NETON: Otherwise a freshly 

3 separated metal won't have this product.

4 MR. THURBER: Well, it depends on 

5 how long since, well, whether there was any 

6 time line. They also handled scrap. They 

7 recast scrap.

8 They did some scrap recasting 

9 where they did receive scrap from outside 

10 sources.

11 DR. NETON: And then it's a matter 

12 of what percentage of that versus the total. 

13 We will look into that.

14 MR. THURBER: We have really kind 

15 of discussed this question earlier. The 

16 question is if, how appropriate is the back17 extrapolation approach to the period prior to 

18 1948, when the bulk of the data is available. 

19 We have touched on that already -- did that 

20 again.

21 CHAIRMAN ANDERSON: Okay. Any, 

22 Bill? Mark are you there? So as far as the 
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1 whole Electro Metallurgical, you are still 

2 reviewing some of the data, right?

3 DR. GLOVER: I will be at Hanford, 

4 Sandia, probably Simonds Saw and Steel. I have 

5 three weeks of travel so in that time SC&A or 

6 ORAU will be completing putting the data 

7 together, hopefully end of this month, 

8 beginning of next. We will see what additional 

9 data captures flow out from Hanford.

10 So I would, hopefully in August we 

11 will have our hands around the data and then 

12 we can make some decisions about the best way 

13 to, you know, approach this.

14 CHAIRMAN ANDERSON: Okay. And we 

15 have some action items in terms of 

16 communicating some of the calculations we made 

17 --

18 DR. MAURO: Yes.

19 CHAIRMAN ANDERSON: And sharing 

20 them with you, so --

21 DR. MAURO: Yes.

22 MR. THURBER: And I think that to 
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1 the extent that what we have done is not 

2 transparent, we will do whatever we can to 

3 help you, provide you with whatever you need. 

4 If what's there is sufficient great, if it's 

5 not --

6 CHAIRMAN ANDERSON: Are we going to 

7 do a query to DOL? 

8 DR. GLOVER: That's certainly part 

9 of the -- we will have to -- I will, me and my 

10 boss, we will work --

11 DR. NETON: Are we going to fill in 

12 the matrix though, in the interim? Or are you 

13 guys, I mean what's the --

14 DR. GLOVER: We can certainly, 

15 because we both agreed, John and I, or 

16 whatever, we will list that through our thing 

17 and we will make sure who owns what action 

18 items and that will be on this. It will show 

19 who is doing what.

20 DR. NETON: I think it is important 

21 to get this matrix filled out.

22 (Simultaneous speaking.)
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1 DR. MAURO: Sometimes it is helpful 

2 to get the transcript, but right now I know 

3 that we have relatively little to do.

4 MR. KATZ: You really have only 

5 responsive things. 

6 DR. MAURO: Right.

7 MR. KATZ: If they need your help 

8 clarifying how you calculated certain things 

9 then they are going to come to you for that?

10 DR. NETON: Well, with the 

11 exception of the additional interview -- 

12 MR. KATZ: With the exception of 

13 the interviews --

14 (Simultaneous speaking.)

15 MR. THURBER: We will provide that 

16 information. I have that and --

17 DR. GLOVER: It may be as we talk 

18 about the areas up there, I'm likely to go to 

19 Simonds Saw and Steel again and if we, at the 

20 same time Steve Buskay of the Army Corps says, 

21 if it would be useful, I could actually get on 

22 site if I wanted to see what, you know, where 
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1 this place was and how it fits into the big 

2 operation --

3 DR. MAURO: They are close to each 

4 other?

5 DR. GLOVER: They are on Niagara 

6 Falls.

7 MR. THURBER: Yes, everything up 

8 there, cheap power, that's why everything --

9 DR. GLOVER: And if that is, if 

10 that turns out to be the case I will make sure 

11 you guys understand when we are going to do 

12 that.

13 MR. THURBER: One of the things I 

14 look for, and I couldn't find it, just for my 

15 own perspective on this, how big is Electro 

16 Met is compared to how big was the area plant? 

17 I couldn't find any information on how big the 

18 total work force was at Electro Met. 

19 DR. GLOVER: It may be worthwhile, 

20 if we got on site and talked to the folks 

21 there.

22 CHAIRMAN ANDERSON: That's why I 
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1 was asking about how many --

2 DR. GLOVER: to see if they could 

3 actually, you know, the guys at Union Carbide 

4 have a better feel for it, so --

5 DR. MAURO: And in the plot plan, 

6 is there, how, just like, the area was --

7 MR. THURBER: The plot plan was 

8 only, shows the corner of the facility. It 

9 doesn't show the furnace area or anything like 

10 that.

11 DR. MAURO: Oh, this is the one 

12 dealing with the residual period, in other 

13 words, we were not aware that the residual 

14 period is not within the scope of the dose 

15 reconstruction for DOE sites and that was one 

16 of our comments. I forget what number it is.

17 MR. THURBER: Yes

18 DR. MAURO: But we withdraw that.

19 DR. NETON: I would mark it closed.

20 DR. MAURO: Closed, yes. Closed is 

21 the right answer and we will put the reason. 

22 MR. KATZ: It was another one where 
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1 their work was outside of the covered facility 

2 possibly, but that depends on what they find 

3 out from DOL. 

4 MR. THURBER: And there was another 

5 one that is really assigned to TBD-6001.

6 DR. MAURO: Transferred to --

7 MR. THURBER: And that too.

8 DR. NETON: Well, my only concern 

9 was just closing them and then if they show up 

10 in these roll-offs of numbers --

11 CHAIRMAN ANDERSON: Yes. 

12 DR. NETON: And it inflates some of 

13 the magnitude of the issues that are -- I mean 

14 it's trivial in a way, I mean, very few --

15 DR. GLOVER: Usually when they're 

16 withdrawn though, it's with concurrence by the 

17 Board.

18 DR. NETON: Oh yes. Oh yes.

19 DR. GLOVER: So I don't know if you 

20 guys have to do anything formal, but you guys 

21 have to --

22 (Simultaneous speaking.)
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1 DR. GLOVER: -- the Working Group 

2 should, yes.

3 CHAIRMAN ANDERSON: Should we take 

4 a break?

5 (Whereupon, the above-entitled 

6 matter went off the record at 2:44 p.m. and 

7 resumed at 3:01 p.m.)

8 MR. KATZ: Okay, this is the TBD9 6001 Work Group and we are just reconvening 

10 after a short break. Let me check on the line 

11 just to make sure we have Hans because I think 

12 we need him for United Nuclear. 

13 DR. BEHLING: Yes, you have me.

14 MR. KATZ: Oh great. Thank you 

15 Hans. Happy to have you.

16 DR. BEHLING: Actually I was on the 

17 line when you asked before the break and I 

18 couldn't hit my mute button, I kept pushing 

19 the wrong button.

20 MR. KATZ: I was faster to hit this 

21 mute button than you were to hit yours, I 

22 guess.
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1 CHAIRMAN ANDERSON: Take it away.

2 DR. BEHLING: Okay. I was talking 

3 to John during the break and he said we will 

4 be working with the matrix so I will simply 

5 follow that but I hope that for any particular 

6 finding or discussion that may ensue you can 

7 ask questions that may divert from the limited 

8 discussion that we see on the matrix.

9 Let me just briefly go over the 

10 chronology of events here because they are 

11 somewhat unusual here. The first Appendix D, 

12 Revision 0 was issued by NIOSH on March 14, 

13 2008 and we in turn were asked to look at that 

14 Appendix D and our audit in our initial report 

15 regarding our review of Appendix D was issued 

16 somewhat about a year-and-a-half later, in 

17 September 2009.

18 Unfortunately we never received 

19 any actual response from NIOSH regarding our 

20 review of Appendix D and it wasn't I guess 

21 until early this spring that NIOSH elected to 

22 revise Appendix D with Revision 1 and at that 
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1 point I believe Ted had asked SC&A to forego 

2 any discussion of our initial review of 

3 Appendix D, Revision 0 and focus on Revision 1 

4 and basically roll up this audit into a final 

5 review.

6 And so what we ended up doing was 

7 we issued a supplemental report on June 11, 

8 2010, just a couple of weeks ago, a few weeks 

9 ago, that reiterates our initial findings and 

10 then looks at the Revision 1 of Appendix D to 

11 see to what extent our finding still stands.

12 And I think our matrix pretty much 

13 reflects that evolution of events, that is we 

14 identified the initial findings and then in 

15 our response -- now, again, it's anyone 

16 question as to whether or not NIOSH had 

17 actually looked at our original audit of 

18 Appendix D, Rev 0, in rewriting it, or whether 

19 these things independently came about.

20 But regardless I think they can 

21 comment on the issue if they choose. But we 

22 will simply identify each of the six findings. 
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1 In addition to the six findings we did have 

2 one single observation which was a generic one 

3 and I think we will understand what the issues 

4 are when we go through the findings.

5 So let me go through the findings. 

6 In our review of Rev 0, we had identified that 

7 our review of the medical dose was somewhat 

8 too brief. I think, in fact, let me just 

9 quickly read what it says so that we can get 

10 an understanding of the issue.

11 In the TBD, the guidance was that 

12 there are no diagnostic medical X-rays to 

13 which workers may have been exposed and there 

14 was no information regarding this. And so in 

15 essence, the recommendation was to look at the 

16 guidance in OTIB-0006 as a way of establishing 

17 medical exposure doses.

18 And my feeling was that that is 

19 somewhat overly brief because OTIB-0006 really 

20 provides various options and I think we need 

21 to be a little more definitive, not so much in 

22 a sense where this will potentially add a 
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1 significant dose to anyone.

2 But the fact is we need a certain 

3 amount of consistency. I think we've been 

4 adamant of consistency. So that when you have 

5 a half dozen dose reconstructors doing a dose 

6 reconstruction for UNC, you will hopefully not 

7 have one who will take liberty in using 

8 exposures that perhaps are within the 

9 framework of OTIB-0006 in a conservative way 

10 and another one using obviously the least 

11 conservative approach. 

12 And so this is our first finding, 

13 is to assume that we need a little bit 

14 additional guidance with regard to how to 

15 assign medical dose because of the fact that 

16 right now all they do is refer you to OTIB17 0006.

18 And I think this is something that 

19 reasonably easily be corrected because we all 

20 do need to give is either we will agree to 

21 assign only one PA X-ray per year or perhaps 

22 in a more liberal way, we can talk about 
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1 photofluorography perhaps, in the early years, 

2 or in addition to photofluorography, lumbar 

3 spine radiographs, all of which perhaps 

4 augment the assigned dose from medical X-rays.

5 So when I looked at one I looked 

6 at the issue of the medical dose and there was 

7 no additional changes, so apparently, from 

8 what I gather, that issue was not addressed in 

9 Rev 1, either because ORAU or NIOSH never 

10 really looked at the initial finding or 

11 decided that the guidance in OTIB-0006 was 

12 adequate.

13 Would it be appropriate to ask 

14 NIOSH to respond at this point, or --

15 MR. KATZ: Yes, Hans the way we 

16 have been doing it is going finding by finding 

17 so, thank you.

18 DR. BEHLING: You want me to just 

19 continue?

20 MR. KATZ: No, no, no, in other 

21 words so yes, in other words NIOSH will 

22 respond to finding one and then you will 
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1 present finding two and so on.

2 DR. BEHLING: Okay, so it's NIOSH's 

3 response that we are waiting for.

4 MR. KATZ: Yes.

5 MR. ALLEN: And we agree with you 

6 that the Appendix could benefit from a more 

7 clear discussion and as far as what the exact 

8 procedures are and stuff, I think we could 

9 have brought that up with Electro Met, too.

10 So I do apologize for not 

11 addressing it in the revision. The revision 

12 was undertaken when we wrote the Evaluation 

13 Report and we found some new data in looking 

14 for that and we decided to revise the Appendix 

15 to incorporate the new data and what was in 

16 the Evaluation Report and this initial review 

17 of the Appendix got lost in the shuffle 

18 somewhere.

19 CHAIRMAN ANDERSON: So for United 

20 Nuclear we have a Site Profile.

21 MR. ALLEN: Yes, it's an appendix 

22 to TBD-6001.
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1 CHAIRMAN ANDERSON: So the Site 

2 Profile, as far as documents, the only 

3 document we really have is Appendix D?

4 MR. ALLEN: Yes.

5 CHAIRMAN ANDERSON: It does both. 

6 There's no SEC petition --? 

7 MR. KATZ: No, there is SEC --

8 MR. ALLEN: Yes. There is an 

9 Evaluation Report.

10 MR. KATZ: And it is an Evaluation 

11 Report of the petition.

12 CHAIRMAN ANDERSON: Okay, I was 

13 just, because the matrix --

14 MR. KATZ: We sort of skipped over 

15 that because --

16 CHAIRMAN ANDERSON: Yes. Yes.

17 MR. KATZ: They were going to 

18 present --

19 CHAIRMAN ANDERSON: Yes.

20 MR. KATZ: -- something on the 

21 petition initially before Hans went --

22 CHAIRMAN ANDERSON: Yes, okay.
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1 DR. BEHLING: With regard to that, 

2 and I am sure that we will discuss or NIOSH 

3 will discuss the SEC petition and the ER that 

4 they have generated, just as a summary up 

5 front, I see none of the findings that I 

6 identified as SEC issues. So --

7 CHAIRMAN ANDERSON: Okay. 

8 DR. BEHLING: I might as well make 

9 that statement up front. I think all of the 

10 findings that I have are solvable with a 

11 certain amount of additional information or 

12 data or guidance.

13 So are we prepared to then discuss 

14 finding two?

15 CHAIRMAN ANDERSON: Yes.

16 DR. BEHLING: Yes. In Rev 1 of 

17 Appendix D, the initial assessment for dose 

18 reconstructing external exposure was really 

19 confined to a couple of summary reports that 

20 were generated by the Atomic Energy Commission 

21 in 1960 and from that data it was concluded 

22 that we could extrapolate for the full 
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1 duration of the operational period.

2 And I looked at the data and 

3 realized that that was probably not something 

4 that you would want to necessarily do, given 

5 the fact that there were so many process 

6 changes over the period of operational times 

7 and therefore the single summary data that 

8 were presented in the AEC report, the 1960 

9 report, would had a very limited, and 

10 questionable approach to satisfying all of the 

11 questions that we did have regarding latter 

12 years of operation and process changes.

13 And so that was my finding number 

14 two and in looking at Revision 1, as it turns 

15 out, NIOSH was able to identify a significant 

16 amount of additional data from various time 

17 frames, some of that data was external 

18 exposures defined units of dose as well as 

19 beta skin doses for some years. For other 

20 years, the data was lumped together so that a 

21 shallow dose and deep dose was combined.

22 But based on the fact that for 
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1 many years, or for a good number of years, 

2 doses were in fact separated, they used a 

3 fractionation process by which the data for 

4 the years where the photon and beta doses were 

5 segregated, they would apply that ratio to 

6 those years where the dose was combined.

7 And even though it was somewhat 

8 less than the most desirable form of data, I 

9 think the data are adequate for filling in the 

10 gaps for all the years during the operation. 

11 So as far as I am concerned the 

12 issue of finding two as being inadequate has 

13 been reasonably well resolved by the use of 

14 additional data that allows for both deep dose 

15 as well as skin dose, in addition to answering 

16 certain questions regarding the frequency of 

17 badge exchange which occurs early on, on a 

18 weekly basis and subsequently on a monthly 

19 basis.

20 DR. MAURO: Hans, this is John. On 

21 the matrix I noticed that it sounds like you 

22 did take a look at the new data to some degree 
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1 but on the matrix it indicates that we really 

2 haven't take a close look at it.

3 In other words, it sounds to me 

4 that, based on your preliminary review of the 

5 new data, it looks like that they have got 

6 quite a bit of data that fills in the gaps. Do 

7 you feel that SC&A needs to do a little bit 

8 more investigations into the completeness of 

9 that data, whether it covers all the workers 

10 necessary, all the time periods -- in other 

11 words, I guess what I am looking for is 

12 whether an action item here or not, because it 

13 does appear that there is an action item.

14 DR. BEHLING: Yes, you're 

15 absolutely right John and I wrote that into my 

16 supplement to the initial audit but as it 

17 turns out, because Ted had requested SC&A to 

18 do just a very initial review of the SEC 

19 petition and the ER report, as it turns out, 

20 it wasn't until I looked at the ER report that 

21 I actually identified the Site Research 

22 Database that was used to supplement that 
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1 data, which were not identified in the 

2 Revision 1.

3 So as it turns out, when I did a 

4 review of the SEC petition and the Evaluation 

5 Report, where the Site Research Database 

6 identified numerous documents, I was able to 

7 actually look at dosimetry data and conclude 

8 that on a fairly substantial review process, I 

9 don't say it was exhaustive but I looked at 

10 enough to convince myself that their 

11 evaluation of the supplemental data in 

12 question is a reasonable approach and I think 

13 they did a reasonably good assessment of that 

14 available data in filling in the gaps.

15 So as I said, it wasn't until I 

16 looked at the Evaluation Report that I had a 

17 chance to identify those documents that were 

18 used to fill in those gaps, and that occurred 

19 after I had actually submitted the audit for 

20 Revision 1.

21 DR. MAURO: So what I am hearing is 

22 we don't have an action item here. You have 
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1 reviewed the data to the extent that you are 

2 satisfied. Now the only thing I want to bring 

3 up, and this goes, really a question to the 

4 Work Group, to the Board Members, is when we 

5 do an SEC, the work we did here was what I 

6 call as Ted requested, let's take a look at it 

7 so that we could come to this meeting and 

8 inform you of what we did and where we are 

9 right now in the process. 

10 Our SEC reviews, when we do a 

11 formal review, is quite a bit more exhaustive. 

12 We will go, I mean, we will go into the data, 

13 download it all, load it into spreadsheets, do 

14 statistical analysis, look at the time 

15 covered, look at the different types of work 

16 activities, whether everyone was covered or 

17 not, everyone was not covered with the film 

18 badge. 

19 We will look at, is there a 

20 coworker model, is the coworker model robust? 

21 We will also include some interviews. I don't 

22 know whether or not any interviews have yet 
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1 been performed for United Nuclear to do some 

2 data capture.

3 So in other words what I am 

4 getting at is I don't want to leave the Work 

5 Group with the impression that we did what I 

6 would call a comprehensive review. We did 

7 clearly a review to the extent that Hans is 

8 feeling pretty good about it, but I think it 

9 would be inappropriate for me to say that we 

10 have done the things that we normally do in 

11 terms of, for example, for an SEC petition. 

12 Right. And that being said it's really up to 

13 the Work Group as to whether there's any more 

14 formality you would like.

15 Because right now you can see by 

16 the report itself, relatively brief, and you 

17 know, if you would like something more formal 

18 -- and also there's a cycle of reviews within 

19 the company, within our group, where two or 

20 three independent people will check the work 

21 also.

22 So I think you are getting sort of 
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1 like a preview of where I think we are right 

2 now in our understanding, but I think I would 

3 not refer to this as a complete, formal SEC 

4 review as we have done in the past for other 

5 sites.

6 DR. BEHLING: And I agree with you 

7 John, as I said, this was not an exhaustive 

8 review. I did review a whole series of Site 

9 Research Database references. One of the 

10 things that did strike me was that while there 

11 was a large number of people with nominal 

12 exposures, and they are consistent with the 

13 doses that will be assigned for non-monitored 

14 coworker model.

15 But there were instances, and I am 

16 looking right now at, especially for 1966 for 

17 individuals who were exposed. In one case I am 

18 looking at nearly six rem for the year, for 

19 1966 there was some, a couple of other people 

20 here, I highlight them, with 2.5 rem, another 

21 one at 6.3 rems and so on.

22 So it looks like a distribution of 
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1 doses that is marked with large numbers of 

2 people with modest doses, but then there were 

3 some people in perhaps selective job 

4 categories or locations, like at the red room, 

5 whose exposures were fairly high for the year.

6 And that might impact certain 

7 assumptions about the use of 95th percentile 

8 values, although I would assume obviously in 

9 these cases, where people had high exposures, 

10 these people were all monitored, obviously, 

11 otherwise we wouldn't know about it, and that 

12 those high exposures were, in fact, committed 

13 to people who were obviously identified as 

14 high-risk workers and therefore they were 

15 monitored, so we do have this data.

16 DR. MAURO: Is there a coworker 

17 model in the Rev 1? 

18 DR. BEHLING: Yes.

19 DR. MAURO: There is. And I guess, 

20 it sounds like you did take a look at that and 

21 you feel that it covered all the time periods 

22 and different -- the data that does exist, is, 
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1 cuts across the time periods and the job 

2 categories and locations to the extent that 

3 the coworker model can, you know, be used, to 

4 assign exposures, to workers who perhaps were 

5 not monitored but should have been?

6 DR. BEHLING: Well, to look at 

7 that, the external doses were defined in table 

8 D-2 and they were modified considerably 

9 between Rev 0 and Rev 1.

10 DR. MAURO: They went up by about a 

11 factor of 10 as I recall.

12 DR. BEHLING: Yes, they were 

13 substantially raised, yes.

14 DR. MAURO: Although, Hans, what I 

15 am trying to do is get a sense here of whether 

16 you feel that you, that SC&A, given what you 

17 have done so far, whether or not, you know, 

18 there is more to be done to make this a formal 

19 review.

20 I have to say, as SC&A project 

21 manager, I would like to do something where we 

22 can say we went through the full procedure. We 
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1 have a procedure. SC&A has a procedure to do 

2 SEC reviews, and there's a whole bunch of 

3 things that we do, which includes interviews 

4 and it includes data capture and site visits, 

5 all of which really haven't been done. So I --

6 MR. KATZ: Let me just also, 

7 though, explain, I mean, the Board has done 

8 several things with SECs and in some SECs it's 

9 done focused reviews where it has had 

10 particular issues that said SC&A go dog these 

11 issues down and in other cases it's had SC&A 

12 just sort of do, like John is saying, the 

13 whole A to Z review of an SEC petition and it 

14 really depends on what is in front of the 

15 Board and what the Board's concerns are, 

16 whether it unloads an entire review of all the 

17 issues comprehensively or it has particular 

18 concerns that it feels it needs buttoned up.

19 So that is a judgment that this 

20 Work Group will make as to how extensively you 

21 want to use SC&A to dig into issues, any 

22 issues that you may have concerns about.
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1 MR. THURBER: Well, John, do we 

2 need to separate the Appendix C issues as 

3 compared to the SEC issues? I mean, just, you 

4 know, fundamentally we started out here 

5 talking about Hans's review -- I'm sorry 

6 Appendix D, not Appendix C -- Appendix D 

7 issues, and then we have kind of deviated a 

8 little bit into the SEC issues and are they 

9 two separate things and should we be careful 

10 to keep them separate?

11 MR. KATZ: Hans' statement was that 

12 he didn't see any SEC issues among the TBD, 

13 above all the review that he has done at this 

14 point. 

15 But certainly if you, as you go 

16 through these findings, I think we are still 

17 on finding number two --

18 DR. MAURO: Well, maybe, put this 

19 issue in the parking lot for now. You have got 

20 a sense of what we did. Clearly, on this 

21 matter regarding external dosimetry, clearly 

22 going from Rev 0 to Rev 1, there was a 
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1 substantial improvement in the database, which 

2 gave us a good degree of comfort that yes, the 

3 problem that we had originally seems to be 

4 largely resolved because so much more data 

5 came in.

6 Now, I would be the first to say 

7 though, that to say that that data now is 

8 sufficient to build a robust coworker model 

9 that would meet all the criteria for 

10 sufficient accuracy as required by Part 83, 

11 that's a richer question.

12 And I think that maybe we put that 

13 in the parking lot for now. Let's go through 

14 the rest of these and then --

15 MR. THURBER: Well, is it 

16 appropriate then that we alter our response 

17 here to this finding based on what Hans is 

18 saying here?

19 DR. MAURO: Not now. I would say 

20 let's -- SEC reviews, as Ted pointed out, have 

21 evolved in a way that they take a form and a 

22 level of detail that is on a case-by-case 
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1 basis. In other words, we used to SEC reviews 

2 according to a very comprehensive procedure, 

3 there was a ton of stuff we did, and it was 

4 expensive and time-consuming.

5 And it became clear that a new 

6 culture developed -- this must be about two 

7 years ago -- where once the issues are 

8 discussed by the Work Group, a judgment is 

9 made by the Work Group which issues they would 

10 like us to look at a little more closely, so 

11 what I am saying is right now I can't answer 

12 your question. 

13 Really, we are going to look to 

14 the Work Group to direct us on whether or not 

15 there is more they would like us to do or not 

16 in light of what we are hearing from --

17 CHAIRMAN ANDERSON: Did the SEC 

18 petition come in before or after Rev 1?

19 MR. ALLEN: Before. The Rev 1 was a 

20 response to information we found when we were 

21 putting together that --

22 CHAIRMAN ANDERSON: Okay, I am 
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1 just, I mean the petitioner didn't know you 

2 had this data at the time?

3 MR. ALLEN: I am not positive we 

4 had it when the petition came in.

5 CHAIRMAN ANDERSON: Well, yes --

6 MR. ALLEN: We had it when the --

7 CHAIRMAN ANDERSON: Whatever, I 

8 mean, that is just a matter of their, they 

9 didn't look at it and say we looked at this 

10 data and they got problems with it, it was 

11 simply there isn't the data and then you found 

12 it. 

13 MR. ALLEN: Right.

14 CHAIRMAN ANDERSON: Okay. That's 

15 helpful.

16 DR. BEHLING: I would just like to 

17 perhaps make one comment. As I have mentioned, 

18 there was significant revisions to table D-2 

19 that needs to be used for the reconstruction 

20 of external doses. In the initial table D-2 it 

21 was really for the entire period because it 

22 was based on 1960 NRC survey report. 
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1 The Revision 1 incorporates new 

2 data and allows for assigned doses for every 

3 single year during this period and in addition 

4 it is segregated based on whether or not the 

5 person was an operator, a supervisor or other.

6 The recommended values are in fact 

7 geometric mean values and if I have to say one 

8 thing, it's that the data is pretty much 

9 comprehensive involving those people who were 

10 most likely exposed who were in fact part of 

11 that database and those data are to be used 

12 for dose reconstruction.

13 We have only a small minority of 

14 people who may not have been monitored or for 

15 whom the data is not available. Perhaps the 

16 values in table D-2 are adequate. But if it 

17 turns out there was a significant number of 

18 people who may have been operators who were in 

19 fact not monitored or whose exposures are not 

20 available, then perhaps the geometric mean, 

21 again, may indicate a recurring issue with 

22 SC&A and trying to come to grips with the fact 
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1 that a geometric mean may not always be 

2 claimant favorable if the person was not 

3 monitored but he was in a high exposure group.

4 And as I had mentioned I am 

5 looking at 1966 in table D-2 for operators the 

6 assigned dose is 382 millirem and as I had 

7 mentioned a few minutes ago, there were people 

8 whose 1966 exposures were upwards of six rem.

9 Now if among operators who may not 

10 have been monitored, the assignment of the 

11 default value would truly perhaps not be 

12 claimant favorable and so the assumption here 

13 is that if we can identify an operator for 

14 whom the data is not available, perhaps the 

15 geometric mean will not be claimant favorable 

16 and we should look at the 95th percentile 

17 value.

18 But that is something that only a 

19 careful review would indicate, whether or not 

20 people in the high dose area, such as 

21 operators, are people whose exposures we do 

22 not have for dose reconstruction, perhaps the 
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1 geometric mean may not be appropriate.

2 So this would be obviously 

3 something that John focused on and that is 

4 perhaps we need to look at data again a little 

5 more carefully that are now available in the 

6 Site Research Database to be sure that the 

7 doses that we do have access to are on cases 

8 of the most likely exposed individuals.

9 MR. KATZ: Finding number three, 

10 Hans?

11 DR. BEHLING: Okay, finding number 

12 three, potential exposures to neutrons are 

13 currently not addressed in Appendix D. 

14 And when I looked at, in fact, at 

15 the 1960 AEC compliance inspection report, 

16 there was a series of references about 

17 criticality issues and so forth, and it 

18 clearly was an indication that the quantities 

19 of UF6 at the facility would have given rise 

20 to neutron exposures which were not addressed 

21 in Rev 0. 

22 So in Rev 1, NIOSH elected to 
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1 include the approach and I looked at the model

2 and it does appear that it is claimant 

3 favorable in its basic assumptions.

4 So the issue of neutron assignment 

5 is something that can be resolved with the use 

6 of this model. 

7 DR. MAURO: Hans can you describe a 

8 little bit about how the neutron doses are 

9 assigned?

10 DR. BEHLING: Yes, let's see, it's 

11 a model, it's -- let's see which assumptions 

12 were used. They used a highly-enriched 

13 uranium, 93.1 percent enrichment, and -- I 

14 need to look at all these documents here that 

15 are in front of me, but it also, I don't have 

16 at my fingertips the quantities that were 

17 used.

18 But I think in all the, our model 

19 appears to be fairly --

20 DR. MAURO: So it is not based on 

21 NTA film. It's actually based on --

22 DR. BEHLING: No, no. No, no. It's 
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1 a modeled approach. 

2 DR. MAURO: Okay. I got it, so 

3 basically a source of neutron enrich --

4 neutron, ran appropriate codes, predicting the 

5 neutron flux and energy distribution --

6 DR. BEHLING: Yes. They used 93 

7 percent enriched uranium. They had the workers 

8 there at one foot for 1,000 hours per year and 

9 -- what is the quantity -- but it appears that 

10 -- a 50 kilogram quantity -- so given that all 

11 of the variables that they could have employed 

12 in coming up with a model dose, both in 

13 quantity, the time, the enrichment factors, it 

14 appears to be that the neutron exposures are 

15 fairly considerable. 

16 CHAIRMAN ANDERSON: Finding four.

17 MR. KATZ: So, no action on that.

18 CHAIRMAN ANDERSON: Well, that just 

19 sounds like it is --

20 MR. KATZ: That's one that is --

21 CHAIRMAN ANDERSON: -- good to go.

22 MR. KATZ: Closed.
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1 CHAIRMAN ANDERSON: Closed.

2 DR. BEHLING: Yes. Finding four. 

3 Inhalation intakes recommended by NIOSH may 

4 not correlate with empirical urinalysis data. 

5 Again, when I looked at all of the secondary 

6 reports in the Site Research Database, and I 

7 looked at it actually on behalf of Rev 1, I 

8 focused on a number of people and I looked at 

9 people who were exposed to fairly high air 

10 concentrations and for whom we also had 

11 urinalysis data and subsequently chest count 

12 data and sorted through the assigned doses 

13 from the coworker model that were initially 

14 identified in the Appendix D, table D-1 of 

15 Appendix D, are they claimant favorable.

16 And I can't, I found it too much 

17 of an effort to go through all the iterations 

18 that I went through. But I tracked several 

19 people who were probably outliers in this 

20 whole distribution. They were the people who 

21 were exposed during a very critical time 

22 period when it was realized that there were 
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1 high air concentrations and there were changes 

2 in processing, et cetera.

3 And what I ended up concluding was 

4 that at least in behalf of those individuals, 

5 the assigned default value from table D-1 was 

6 probably not necessarily claimant favorable. 

7 In fact in some cases they were off by factors 

8 of 15 to even greater values, depending on 

9 whether you, which solubility you assume.

10 Now, in the original Rev 0, the 

11 table D-1 really made no reference as to who 

12 these values should be applied, in other words 

13 they were to be used regardless of whether or 

14 not that person had bioassay data or not. 

15 And so I realized that in case of 

16 people who were clearly monitored, and for 

17 whom chest count data, urine data and air 

18 sampling data was available, that these values 

19 should be used.

20 So even though table D-1 between 

21 Rev 0 and Rev 1 remains the same, a major 

22 change was that in Rev 1, the option was to 
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1 obviously default to real data rather than the 

2 coworker model, which is really what we are 

3 dealing with.

4 There are a substantial number of 

5 bioassay data available for individuals who 

6 were likely to have been operators and for 

7 whom the exposure was maximal and of course, 

8 one should choose that data as the highest 

9 exposure to the target organ.

10 And that was, that stipulation was 

11 incorporated into the Revision 1. So as a 

12 minimum, the table, a default table of 

13 coworker internal exposures is no longer just 

14 a generic value that applies to all people, 

15 but it only applies to those people for whom 

16 the data either doesn't exist or it is 

17 insufficient for dose reconstruction.

18 For anyone who has read the 

19 original audit of Rev 1, you will see the 

20 effort I went to in trying to needs identify 

21 for outlier people, people whose exposures 

22 were clearly going to be high based on air 
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1 sampling data, urinalysis data and for chest 

2 count data, the default values in table D-1 

3 would not necessarily be claimant favorable.

4 DR. MAURO: So Hans, with regard to 

5 the new paradigm that's been adopted, what I 

6 am hearing is there is this internal dosimetry 

7 data for individual workers. You feel that the 

8 workers that do have data, whether it's chest 

9 count or bioassay, that those workers, it's 

10 fairly clear that those are the workers that 

11 had the highest potential for exposure.

12 DR. BEHLING: Yes.

13 DR. MAURO: Okay, that's important, 

14 because what that means is it puts NIOSH in 

15 the position to know what the high-end 

16 exposures are. So if there is a worker out 

17 there that does not have any bioassay data and 

18 needs to be assigned some exposure, NIOSH is 

19 in a position to assign an exposure that is at 

20 the upper end if they feel that's appropriate.

21 You see, usually you run into an 

22 SEC issue when you have bioassay data but you 
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1 don't really know whether you have captured 

2 the high-end individuals or not. And all of a 

3 sudden you have a coworker model that you are 

4 really not sure -- we have seen that before --

5 whether or not you have got the high-end 

6 individuals.

7 But in this -- and Hans has been 

8 quite frankly one of the strongest critics of 

9 other SECs when he felt that you have got a 

10 lot of data but it is not apparent that you 

11 caught the high-end people.

12 You are saying in this case 

13 however you feel pretty confident that the 

14 data that is available, does capture those 

15 people with the jobs that would place them at 

16 the high end.

17 DR. BEHLING: Yes, I believe they 

18 realize that during certain periods of 

19 operation, that they had a very, very high 

20 airborne level and they did monitor at work 

21 locations, particularly the work locations, 

22 and assigned specific airborne levels to 
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1 individual workers.

2 And then they had the option of 

3 also reviewing their urine data and in some 

4 cases chest data, and of course some of these 

5 individuals were tracked for a period of years 

6 because of the very, very high-end exposures 

7 that they received.

8 So it's reasonable to conclude 

9 that the highest exposed people were in fact 

10 identified. Now I have identified, in addition 

11 to the original issue, that says please use 

12 the real data when available because there 

13 were in some instances there was an assigned 

14 value from the default table.

15 But one of the things that I also 

16 have to say that I didn't really include was 

17 the likelihood that the uranium to which some 

18 of these people may have been exposed to, may 

19 qualify for solubility Super S.

20 And I say this because I looked at 

21 some of the Site Research Database documents 

22 that actually had hand-written notes and 
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1 extrapolated the actual chest burden as a 

2 function of time.

3 And there were some people who, in 

4 addition to having air monitoring data, in 

5 addition to having urine data, were chest 

6 counted at Y-12 over a period of time and 

7 several people were counted for a couple of 

8 years thereafter.

9 And I looked at the individual 

10 data and by simply looking at a couple of data 

11 points that were separated by six months or 

12 so, you come to the conclusion that the 

13 effective half-life of uranium in the chest 

14 for a couple of these people in one instance 

15 exceeded three-hundred-and-twenty-some days. 

16 And I believe that would qualify for perhaps a 

17 Super S status for uranium. 

18 DR. MAURO: Is the ER, the 

19 Evaluation Report and the Site Profile Rev 1 

20 silent on this matter or is this --

21 DR. BEHLING: Yes, they are. They 

22 give options for assigning either solubility 
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1 type S or M and again, as always, NIOSH 

2 usually says whichever yields the higher dose.

3 So clearly if it's an exposure 

4 that involves, or target tissue involving a

5 lung you would obviously go for type S. For 

6 others it might be type M. But Super S is not 

7 identified as a potential.

8 Now I don't know exactly where the 

9 dividing line between S and Super S comes in 

10 at, but when you have an effective half-life 

11 in the chest based on chest counting data from 

12 Y-12 that exceeds 300 days, I believe that 

13 would qualify for Super S.

14 I am waiting for comments from 

15 NIOSH.

16 DR. NETON: No. No, I don't think 

17 300 days would qualify that for Super S. I 

18 think the long-term compartment, even in the 

19 type Y was 500 days. So I don't know why 300 

20 days would qualify that as Super S. 

21 I mean we will certainly take a 

22 look at what you are pointing to but my first 
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1 blush is I don't think so.

2 MR. ALLEN: If the absorption half3 life for type S is 7,000 days half-life, 

4 that's only the absorption comment if the 

5 physical clearance is going to probably guide 

6 that down quite a bit.

7 But as I recall type M falls 

8 around 140 day half-life?

9 DR. NETON: I mean, we can 

10 certainly take a look at what the data set you 

11 are pointing to, but off the top of my head it 

12 doesn't seem like --

13 DR. MAURO: Is there anything, I 

14 guess, the type of operations that took place 

15 here, is there anything about those operations 

16 that would lead you to, I guess, to get a 

17 Super S out of the uranium, for some reason 

18 that's got pretty high temperatures. I am not 

19 even sure what they were going here, where 

20 there might have been -- in other words, you 

21 combine process knowledge with data, starts to 

22 build a case that no, maybe we don't have it, 
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1 or perhaps we do. 

2 But right now the report, it 

3 sounds like it's silent on this issue.

4 MR. ALLEN: Yes, I mean, as I 

5 remember, I might be getting my sites wrong, 

6 but I am thinking that the big exposures that 

7 they ended up sending people to Y-12 for the 

8 whole body count et cetera were from the red 

9 room, and if I remember right, the red room 

10 was reduction process with green salt, if I 

11 remember right, which would be a type M 

12 material.

13 DR. BEHLING: All I can say is that 

14 in some of the communications between the 

15 health physicists at UNC and Y-12, they talked 

16 about having common problems of a much longer 

17 half-life that they would have expected in a 

18 lung of 120 days.

19 DR. NETON: Well yes, that was the 

20 old ICRP-2 model, I mean that only allowed for 

21 a soluble inside 120 days, it was sort of like 

22 a default value. I --
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1 MR. ALLEN: That was Class W wasn't 

2 it?

3 DR. NETON: Yes, W. I think, you 

4 know, UO2 would be the most insoluble form of 

5 uranium, which is type S right now. I am not 

6 aware of anything out there right now that 

7 would qualify for Super S, although I never 

8 say never.

9 We will certainly be happy to take 

10 a look at the --

11 DR. BEHLING: I was looking at some 

12 of the ICRP documents and when they talk about 

13 it, they are very diffuse, and certainly when 

14 you look at the older documents that are still 

15 classified saying there's daily, weekly, 

16 yearly, what does clearance mean? Certainly in 

17 this case, and I counted it for one particular 

18 individual and the effective half-life in the 

19 lung was 327 days. 

20 Well, that's only one half-life. 

21 Okay, so it's less than one year, but what 

22 does clearance mean? Is it just one half-life 
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1 removed or multiple half-lives where you 

2 reduce it down to some nominal level?

3 DR. NETON: Well, it depends on 

4 where you are in the clearance curve. I mean, 

5 there's all kinds of compartments with the 

6 ICRP 66 lung model as you know and there is no 

7 such thing as one half-life in the lung, 

8 there's a --

9 DR. BEHLING: No, I realize that, 

10 but Jim, I took, they were, I have data here 

11 for a bunch of individuals who were exposed 

12 and they were assessed in August of 63, 

13 September of 63 and March of 64 and I ignored 

14 the first one and I looked at September 30, 

15 which is about six weeks thereafter the 

16 initial exposure, minimum, and then they were 

17 reassessed on March 16, 1964.

18 So we have at least about 100, 

19 well actually 177 days during this exposure 

20 where you have the initial clearance from the 

21 lung, obviously, and using those two data 

22 points, I set the effective half-life in the 
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1 lung and for one individual was 262 days, for 

2 another 327 days.

3 And I thought of not pushing the 

4 issue of Super S, but I am raising the 

5 question, where does the separation between S 

6 and Super S come in? I mean --

7 DR. NETON: It's a lot longer than 

8 300 days. We can look at it. Again, I, you 

9 know, I would like to look at the case but my 

10 first thought, it doesn't seem to be an issue 

11 but --

12 DR. MAURO: One more question 

13 before we move on to the next item. Hans, 

14 everything is uranium here. Any reason to 

15 believe there are other radionuclides?

16 DR. BEHLING: I didn't quite hear 

17 you John.

18 DR. MAURO: We have been talking 

19 uranium. Is there any reason, like I said, I 

20 am not familiar with the processes. Is it 

21 possible there's other radionuclides, thorium?

22 DR. BEHLING: Yes, in fact, one of 
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1 the things that was added in Rev 1 that one 

2 was the potential exposure to thorium, which 

3 was missing in Rev 0, and there was a single 

4 year in the process time period during which 

5 thorium was used, and so NIOSH added exposure 

6 to thorium. That is another change in Rev 1.

7 And when I initially reviewed Rev 

8 0 I was not aware that thorium was even an 

9 issue until it was independently raised by 

10 NIOSH in their Rev 1.

11 MR. THURBER: Next. 

12 CHAIRMAN ANDERSON: Fine.

13 MR. KATZ: Finding number five 

14 Hans?

15 DR. BEHLING: Okay, finding number 

16 five was doing -- and oh, one other thing that 

17 was changed. Initially the operational period 

18 was only extended to 1969 and apparently NIOSH 

19 reviewed some of the documents and realized 

20 that that date had to be extended to 1973. So 

21 that's another independent change that 

22 occurred from Rev 0 to Rev 1, an additional 
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1 four years during which operational exposures 

2 would have occurred and before the post3 operational exposure would have occurred.

4 So finding five starts with the 

5 issue of information regarding the inhalation 

6 intakes from residual contamination and NIOSH 

7 had stated that their default value is 10.34 

8 dpm per day with type S uranium. 

9 MR. KATZ: Hans, could you just 

10 speak up a little bit more. You are fading a 

11 little bit. 

12 DR. BEHLING: Okay. In Rev 1, and 

13 it remains unchanged, so it appears in Rev 1 

14 and 0, the assumed default value, 10.34 dpm 

15 per day for uranium is a default value for 

16 inhalational internal exposure and that starts 

17 in 1974.

18 And I looked at the actual 

19 guidance in the document and I can't really 

20 understand how that came to be and I am not 

21 sure I will necessarily go through the details 

22 as to -- but for those who have my report, you 
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1 can see what I did and I am hoping that if I 

2 am wrong, NIOSH can correct me.

3 But based on my assessment, the 

4 use of the maximum dose from table D-2 and the 

5 basic assumptions that were to be used for 

6 modeling the exposure, my value turns out to 

7 be 434 dpm per work day or 297 dpm per 

8 calendar day. That's 29 times higher than the 

9 value recommended by NIOSH. 

10 And I had applied a certain 

11 modeling approach to that value that I believe 

12 interprets their recommendation but I 

13 certainly could not come up with their value 

14 and I think I am going to ask NIOSH to tell me 

15 what method they used to come up with their 

16 10.34 dpm per day and why my number is perhaps 

17 not correct.

18 MR. ALLEN: We might have some 

19 difference of opinion as far as how you got 

20 your number, but as far as what is in the 

21 Appendix, I can verify there was a 

22 calculational error there. The Appendix is 
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1 going to need to be revised to change that 

2 value.

3 DR. BEHLING: It is basically a 

4 very simple calculation.

5 MR. ALLEN: Yes.

6 DR. BEHLING: You essentially 

7 define the air activity, the maximum air 

8 activity, and you need to apply a deposition 

9 velocity in terms of meters per second and you 

10 end up with a ground activity in terms of dpm 

11 per meter square and then I simply applied a 

12 resuspension factor that is defined by NIOSH 

13 and this is how I came up with my number that 

14 is, in fact, it's a very low resuspension 

15 factor, one to the minus six per meter, which 

16 we have questioned as part of OTIB-0077.

17 And so even using that un18 conservative number, at least my estimation is 

19 that that is an un-conservative number, I come 

20 with a value that is 29 times higher and I 

21 think NIOSH should look at their value and 

22 look at my value and see which number is 
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1 correct.

2 MR. ALLEN: Agreed.

3 CHAIRMAN ANDERSON: Yes, agreed. 

4 Okay. So there is a task. Yes. Six.

5 DR. BEHLING: Finding six. Again, 

6 here this was based on an external 

7 contamination residual, external contamination 

8 dose rate and I looked at the default values 

9 that are identified by NIOSH and I, their 

10 default values were 11.6 millirem per year 

11 whole body and 186 millirem for skin dose.

12 And again using the limited 

13 guidance that was identified in Rev 1 as well 

14 as Rev 0 --

15 MR. KATZ: Hans, your voice is 

16 fading again.

17 DR. BEHLING: Okay.

18 DR. MAURO: That's good. That's 

19 perfect. Okay.

20 DR. BEHLING: Am I coming through 

21 now?

22 MR. KATZ: Very clear.
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1 DR. BEHLING: I looked at the 

2 default values for external exposure cited by 

3 NIOSH in both Rev 0 and Rev 1 and used their 

4 recommended approach in terms of how that was 

5 defined. And although it was somewhat brief, I 

6 used federal guidance report 12, the EPA 

7 federal guidance report 12 and used the data 

8 that they had recommended to use for external 

9 exposure and they actually came up with 

10 numbers that were considerably lower than the 

11 values.

12 They had for external, as I said, 

13 for external they had identified 11 millirem 

14 per year, external whole body, and I ended up 

15 looking at a derived value of 2.8, 

16 approximately five-fold lower, or four-fold 

17 lower, and the 186 millirem for skin dose that 

18 NIOSH had projected, I ended up with only 10.2 

19 millirem, and that was using EPA federal 

20 guidance report 12 as my principle dose 

21 conversion values for residual contamination.

22 Again, I don't know what 
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1 methodology they used in order to be able to 

2 track their numbers, but I independently used 

3 at least the limited guidance they provided

4 and came up with these values, which are 

5 considerably lower than the default values 

6 recommended by NIOSH.

7 MR. ALLEN: Yes, we used the 

8 conversion factor we actually talked about 

9 earlier today in TBD-6001 for external dose 

10 from surface contamination and it was derived 

11 from a MicroShield run. Didn't realize it was 

12 that much higher than federal reg guide 12. 

13 But I am not sure, Hans, I don't 

14 think you included the thorium-234 and the 

15 protactinium?

16 DR. BEHLING: No I did not, since 

17 the values originally were identical in Rev 0, 

18 where thorium was not identified, I have to 

19 conclude that the values, the default values 

20 in Rev 0 and Rev 1 did not address thorium. 

21 MR. ALLEN: Yes, well, I am talking 

22 about the short-lived decay products of U-238. 
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1 You can get some reasonable beta and gamma 

2 from the protactinium-234m and the thorium3 234. 

4 I think to use federal reg guide 

5 12 they would have to include those two as 

6 well.

7 DR. BEHLING: Okay, I have to look 

8 to be sure that they weren't really 

9 incorporated. You may be correct, which may 

10 explain why my numbers were considerably 

11 lower. In any case, especially the external, 

12 penetrating dose of 11 versus three, we are 

13 not talking about the doses, even though there 

14 is a significant difference between two 

15 values, in absolute terms they are still 

16 nominal doses.

17 DR. MAURO: David, how did you 

18 derive the build-up of uranium on surfaces for 

19 the residual period?

20 MR. ALLEN: It was the same --

21 DR. MAURO: Same thing? 

22 MR. ALLEN: Technique that we --
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1 DR. MAURO: Using the airborne 

2 activity in the deposition and for a year?

3 MR. ALLEN: In this one, actually 

4 we used 2,000 hours. We used a work year.

5 DR. MAURO: One work year. It's 

6 above the number that would be 27 days?

7 MR. ALLEN: Yes, it's above that.

8 DR. MAURO: Okay. All right. So I 

9 guess the only issue we have, not so much with 

10 the external, whatever dose it is, is this 

11 resuspension factor. But again that is not 

12 necessarily an SEC issue. We do have a problem 

13 with the 10 to the minus six per meter number, 

14 it's a longstanding issue. 

15 MR. ALLEN: That's finding five 

16 anyway. That's --

17 DR. MAURO: Right. And, but that's 

18 not an SEC issue. 

19 MR. KATZ: So is there something 

20 remaining on the table on this?

21 DR. BEHLING: Yes, there's only an 

22 observation and --
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1 MR. KATZ: I mean for finding 

2 number six. Do we have anything, is there 

3 anything to do with finding six or is it 

4 something that could be closed?

5 DR. BEHLING: Well, I can go back 

6 and look at whether or not federal guidance 

7 report 12 incorporates some of the short-lived 

8 daughter products.

9 And whether or not that accounts 

10 for the differences between my calculated 

11 value and --

12 MR. ALLEN: Essentially, we are 

13 using two different models to model this and 

14 coming up within a factor of four and it might 

15 be closer by the time we reconcile some of 

16 this. I don't know if you want to explore it 

17 further or not.

18 DR. MAURO: Yes, federal guidance 

19 report 12 only includes the uranium you have 

20 got, so if you look at U-238, you get U-238. 

21 You have got to include thorium-234, and 

22 protactinium-234m so, and I think there is a 
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1 one percent photon on that order from the 

2 protactinium, which may be the major 

3 contributor plus of course there's the 

4 Bremsstrahlung issue.

5 But you are not going to get very 

6 Bremsstrahlung here, I would imagine. You are 

7 talking about just a little residual activity 

8 on the surface.

9 MR. ALLEN: You have a high-energy 

10 beta but not so much --

11 DR. MAURO: But nothing to knock 

12 into, yes.

13 DR. BEHLING: And John, now that 

14 Jim Neton mentioned the issue of short-lived 

15 daughters, as I have said, I took only U-234 

16 and 235 into consideration and you know, I 

17 said, I did not address the contribution, 

18 especially the beta component and that is very 

19 likely the reason why I ended up getting the 

20 much lower dose.

21 MR. KATZ: Okay. So do we need a 

22 report out on this?
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1 DR. MAURO: Yes, let's fix that. 

2 Yes, we should, you know what we can do? In 

3 our matrix, you know I guess we will go back, 

4 revisit that number and see, if we went back 

5 in light of this -- I guess it will be a note 

6 here, you know, in the matrix saying that SC&A 

7 will revisit the exposure and that will be 

8 what we put in and of course, I guess we will 

9 put a memo out subsequent to that, yes we did 

10 and you are right and whatever the answer is.

11 DR. BEHLING: Yes, I am writing 

12 myself a note here. I will do that.

13 CHAIRMAN ANDERSON: And then the 

14 observation?

15 DR. BEHLING: The observation that 

16 I mentioned was really a generic one and it 

17 was --

18 DR. MAURO: Could you get closer to 

19 the phone again Hans, you are fading away.

20 DR. BEHLING: Okay, I don't know 

21 why, this mic usually works very well, I don't 

22 know why it is not working. In my observation 
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1 one, I stated that UNC site description is 

2 insufficient and I think, based on my comments 

3 regarding the individual findings, I was 

4 really not able to review some of the numbers 

5 and I think that was really a reference to how 

6 these numbers were derived for certain 

7 instances such as the internal and external 

8 exposures that we just mentioned where they 

9 simply provide default values without 

10 necessarily providing new information which 

11 would allow you to track those numbers. 

12 So it's just a generic comment. 

13 But then again, the TBD-6001 and the 

14 appendices are not intended to be equivalent 

15 of a Site Profile in terms of the definitive 

16 information that is normally incorporated and 

17 so I understand why these documents are so 

18 much more brief.

19 But I still felt that perhaps we 

20 could have benefitted from additional data 

21 that would allow us to actually follow the 

22 methodology that was used to identify some of 
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1 the default values that NIOSH had incorporated 

2 in their tables.

3 CHAIRMAN ANDERSON: Okay. 

4 MR. ALLEN: Well, it sounds like 

5 you are basically saying we could use some 

6 more detail on how we did the calculations in 

7 the text of the Appendix.

8 DR. BEHLING: Yes, and -- what I 

9 had problems with initially, and this is what 

10 John picked up on, regarding the external 

11 exposures, there were no references to the 

12 various documents that were cited in the 

13 Evaluation Report to the SEC petition that 

14 would have allowed me to look at those numbers 

15 up front.

16 And so, sometimes even the 

17 bibliography would have perhaps benefitted 

18 from some of those particular SRDB references 

19 that were cited in the ER and include those 

20 into the actual Appendix D.

21 CHAIRMAN ANDERSON: Anything else?

22 MR. KATZ: There was only one 
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1 observation.

2 DR. MAURO: Yes, that's it, we're 

3 done.

4 CHAIRMAN ANDERSON: Anything on 

5 SEC? I mean, since this doesn't pertain too 

6 much, do we need to, you do have your report 

7 on that?

8 DR. MAURO: Well, this is a little 

9 bit unusual. What you have here is review of 

10 Rev 1 of the Site Profile with some 

11 consideration, limited consideration of is 

12 there anything in the ER that sort of raises a 

13 red flag. 

14 And what we are hearing is, based 

15 on, you know, a limited review of the ER, 

16 there's nothing there that really jumps out at 

17 you that looks like there's something that 

18 might be serious, a serious issue that could 

19 trigger an SEC concern.

20 It's unusual because we usually 

21 don't come to that conclusion that quickly, as 

22 you know. And you know, and if you feel as if 
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1 there's more to be done in terms of taking a 

2 closer look at the external data, downloading 

3 it, if you feel that, I mean --

4 DR. BEHLING: As I said, John, the 

5 biggest concern that I might have is the 

6 assignment of default values to unmonitored 

7 people if they turn out to be high-end exposed 

8 individuals, operators. As I said, you know, I 

9 looked at 1966 and the geometric mean is 380 

10 some millirem and yet for 1966 among a select 

11 group of people, exposures as high as six rem

12 are part of the record. And if it turns out 

13 that they were operators whose either exposure 

14 records are not available, who may have been 

15 monitored, but they are not available, or they 

16 may not have been monitored in spite of the 

17 fact that they were operators and high-end 

18 exposed individuals, then I would assume that 

19 the geometric mean may not necessarily be a 

20 very good number for those individuals.

21 DR. NETON: Well, but that in 

22 itself is not an SEC --
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1 DR. BEHLING: No, it's not an SEC 

2 issue.

3 CHAIRMAN ANDERSON: NIOSH said they 

4 can do dose reconstruction. Do we have any 

5 indication where you would be concerned that 

6 in fact there are some exposures at this 

7 facility that aren't covered here, that 

8 weren't identified, or you know, this really 

9 is, there are some coworker issues maybe, but 

10 doesn't seem to be any surrogate data, so this 

11 seems to be new data was found in response to 

12 the petition and that's, you know, are you 

13 comfortable that that in fact does fill 

14 sufficient gaps and you know, not -- we don't 

15 need to talk about how they go about doing the 

16 reconstruction, but can it be done?

17 Sounds like your conclusion so far 

18 is that yes, we ought to as a Work Group go 

19 back to the Board and say, you know, we have 

20 discussed it, hasn't been an in-depth review, 

21 but you know, if NIOSH will summarize more of 

22 what the new data is as part of a 
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1 presentation, we can recommend -- I don't 

2 know, Mark, are you still there?

3 MR. KATZ: We don't have Mark.

4 CHAIRMAN ANDERSON: I mean, I would 

5 want to query him but my sense is, you know 

6 other than -- this one doesn't have as 

7 comprehensive an evaluation but it seems to me 

8 the go, no-go kind of thing is this is very 

9 strong as it goes.

10 DR. MAURO: I mean, certainly the 

11 review that we just heard --

12 CHAIRMAN ANDERSON: Yes.

13 DR. MAURO: I mean, I am probing 

14 away to see if there is anything about it that 

15 gets me to gee, you better look at it. I don't 

16 see it. In other words, what Hans is saying 

17 regarding the -- for example, you always have 

18 a problem with neutron exposures, but what was 

19 just described to me, you say, okay where 

20 could there be a -- bottom line is SECs are 

21 triggered because of inadequate bioassay data 

22 and inability to reconstruct neutron doses. 
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1 All right, so what did we just 

2 hear? We just heard regarding neutron 

3 exposures that they used a very large, highly4 enriched uranium source. I am assuming that 

5 the quantity that was used was in fact an 

6 upper-end value and was -- I don't know that 

7 to be certain, but Hans feels comfortable with 

8 that, and then went ahead without any, 

9 assuming no attenuation, went ahead and 

10 calculated what the neutron flux and energy 

11 distribution would be and derived the doses.

12 Without any attenuation, and 

13 putting a person close for an extended period 

14 of time, certainly places an upper bound. Now 

15 I am not going to say now that I, myself, or 

16 there are other people who reviewed it, say 

17 yes I agree.

18 Because normally what would happen 

19 is that conclusion that you heard, regarding 

20 neutron, that would have to make the rounds. 

21 In other words, there would be other folks 

22 that would independently review it as part of 
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1 our required quality assurance process.

2 I have no doubt, working with 

3 Hans, that this is in fact the case, you know. 

4 But we are in strange territory. We are 

5 talking an SEC issue and I just, I am a little 

6 concerned that, given the importance of a 

7 decision like this, where you would deny an 

8 SEC, the, and not have gone through another, 

9 other eyes, doing, checking the numbers, 

10 convincing themselves that, you know -- 

11 I would like to be able to stand 

12 in front of the full Board and say Hans did 

13 the initial work, these were the issues we 

14 looked at that we thought were important and 

15 the big ones I can tell you right now is the 

16 neutron exposure, probably you would want to 

17 make sure that the -- 

18 It sounds like what he is saying 

19 is that the film badge data did in fact 

20 capture the high-end people and the bioassay 

21 chest count data did in fact capture the high22 end people, and be able to say once you have 
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1 that, you are in a position to assign high-end 

2 doses as necessary.

3 And that means all the major 

4 potential SEC issues don't -- there aren't 

5 any. It just becomes a Site Profile, how you 

6 implement that.

7 So, but I have to say right now, I 

8 would, you know, it would be unusual for SC&A 

9 to show up at a full Board meeting without 

10 having gone through a little bit more due 

11 process and -- Hans this is not, it doesn't 

12 bear on you, I am not questioning you.

13 But there is a process we are 

14 required to follow and especially when it 

15 comes to an SEC, I would not want to give 

16 anyone the impression that we, you know, we 

17 cavalierly came, you know, we did not follow 

18 our procedures.

19 I would like to, I think we have 

20 to have these analyses, have the independent 

21 checking process go forward.

22 DR. BEHLING: And, John, I didn't 
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1 want to come across having the last word, 

2 clearly, as I said, and I prefaced my comments 

3 by stating that it was Ted's recommendation 

4 that we only familiarize ourselves with the 

5 site, with the SEC petition and the Evaluation 

6 Report and so, this was at best, a very, very 

7 cursory assessment of the issues that might 

8 come into play here for an SEC. 

9 And our findings, at least the 

10 ones that I have identified, are probably 

11 resolvable at least, but not necessarily the 

12 final word in defining whether or not the 

13 issue is totally resolved.

14 And then you mention, obviously, 

15 the neutron exposure and maybe we need a 

16 second opinion. Is 50 kilograms a bounding 

17 value? Is one foot for 1,000 hours exposure a 

18 bounding value?

19 In my estimation, it appears to 

20 be, but I think I will defer to a second 

21 opinion on that.

22 MEMBER FIELD: John, I guess, my 
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1 thought was I guess reflective of what you 

2 have expressed a bit ago that you know, this 

3 process has been going on for a long time but 

4 what you would like is a consistent process 

5 throughout.

6 Didn't you say a little while ago 

7 that times have changed.

8 DR. MAURO: Well, you know --

9 MEMBER FIELD: And there's a new 

10 paradigm about how things should be reviewed. 

11 So I guess what, where do we go from here 

12 forward if there's a new paradigm? DR. 

13 MAURO: I will give you an example.

14 MEMBER FIELD: Okay.

15 DR. MAURO: I will give you an 

16 example. On the Mound Site -- that would be a 

17 very good way to think about it -- three or 

18 four issues emerged as being important: 

19 tritides, neutron exposures and radon, okay?

20 Now, we quickly zeroed in on 

21 those, so it's not that we did this big 

22 report, in fact we didn't. We didn't deliver 
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1 one of these 200-page reports where we 

2 exhaustively look, we did what Hans did, 

3 basically, and said, wait a minute, we think 

4 that when all is said and done, if there's 

5 going to be a place where there's going to be 

6 a problem, it's going to be the tritides, the 

7 radon or the neutrons, and that's what to zero 

8 on in.

9 Once the Board or the Work Group 

10 heard that, they said okay, we have got to go 

11 vertical on these. We have got to go do a data 

12 capture, we are going to find out everything 

13 we can about whether or not you really can 

14 reconstruct the doses from those three areas.

15 And a large effort, a very large 

16 effort, ended up going into those three days. 

17 So even though we constrained ourselves 

18 initially, once we constrained ourselves and 

19 then we hit it real hard and we are in the 

20 middle of that right now, I mean there's going 

21 to be a lot --

22 Now I am saying that what we just
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1 did is something even lighter than that here. 

2 What we really did here, quite frankly, is 

3 come to this meeting prepared to give you 

4 folks a sense of where we think we are on, you 

5 know --

6 Certainly we have completed our 

7 Site Profile review and it turns out we have 

8 some issues, as you heard, that need to be 

9 looked at, and they all sound like Site 

10 Profile issues that can be fixed.

11 But it did not, you know, we did 

12 not do some of the things that we always do. 

13 Like for example, the tritide issue at Mound. 

14 That issue has been hit by three or four 

15 people within our group and checked and re16 checked, there's been site visits to find out 

17 more about it --

18 So, listen, I am ready to stop on 

19 this one if you are comfortable with it. But I 

20 don't know if that is in the best interests of 

21 this process. I think that those -- we now 

22 know what the three issues are, that probably 
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1 we want to make sure we got this right.

2 And we have to be able to tell the 

3 full Board that we identified these three 

4 issues that were in our original scoping 

5 analysis, presented our story to the Work 

6 Group and in my mind, we have got to check 

7 those a little more deeply and confirm that 

8 either through additional data capture, 

9 perhaps through some interviews, that in fact 

10 the approach adopted by NIOSH with regard to 

11 these three issues is in fact the rock we can 

12 stand on and those doses can be reconstructed 

13 with sufficient accuracy.

14 MEMBER FIELD: Okay. I guess my 

15 thinking is that without doing further review 

16 of this, if this comes to the Board for 

17 further consideration, say even for an SEC 

18 vote, that the Board will say possibly, well 

19 you didn't do due diligence.

20 DR. MAURO: And I am afraid of 

21 that.

22 MEMBER FIELD: For the initial 
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1 review and make a vote based on what was known 

2 rather than at that time asking for further 

3 review.

4 Well, going back and doing a full 

5 review.

6 DR. MAURO: I am not saying a full 

7 review. I am saying that right now -- see, 

8 what we did was --

9 CHAIRMAN ANDERSON: What can you 

10 done between now and Idaho?

11 MR. KATZ: I mean this won't be 

12 ready for Idaho anyway. It is not on the 

13 agenda for Idaho. 

14 CHAIRMAN ANDERSON: Well, we could 

15 still put it on the --

16 MR. KATZ: I guess it could go on 

17 the agenda for Idaho. I mean, I -- just to 

18 throw in my two cents for you to consider, I 

19 mean this is different than Mound in that they 

20 had concerns about the issues they went deep 

21 on with Mound --

22 DR. MAURO: Right.
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1 MR. KATZ: From the get-go. 

2 DR. MAURO: Yes, that's true.

3 MR. KATZ: And so here they are 

4 saying they don't think they have concerns 

5 about the three issues. But I do think that it 

6 makes sense for SC&A to do its QA on these 

7 three concerns. 

8 I don't know whether it 

9 necessarily means doing a bunch of 

10 interviewing and going out and doing field 

11 research, but having a down-the-table review 

12 of Hans's work.

13 DR. MAURO: Well, let's go with an 

14 example. Let's say we want to convince 

15 ourselves that the neutron model that was 

16 adopted, is bounding. All right, now, what do 

17 you do when you do that?

18 You go in and you see, okay, the 

19 source. What was the source? And go into the 

20 literature, go into your site query database, 

21 and look at the history and see if there is 

22 enough information in there that leaves you 
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1 with a warm and fuzzy feeling that yes, 

2 whatever the number was that was assumed, and 

3 the enrichment level, quite frankly, 50 

4 kilograms of 96 percent enriched uranium? I 

5 can't even imagine you could have that in the 

6 same place. That's --

7 MR. ALLEN: We used 100 kilograms 

8 for the 20 percent and cut it down to 50 

9 because this is just --

10 DR. MAURO: So I mean, we are 

11 starting to solve -- see, I would like to be 

12 able to say yes, that particular scenario is 

13 certainly bounding because you would never 

14 have that, quite frankly you are saying that 

15 is bounding because you have a criticality 

16 situation which is not going to -- you didn't 

17 have it.

18 And then you say, okay, good. The 

19 source is that hotbed. Next. How close are 

20 they to it? And for how long? And also, I 

21 would say the dosimetry itself. Neutron 

22 dosimetry is not straightforward.
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1 You know, make sure that the 

2 energy flux, it's basically neutron energy 

3 distribution at the receptor location and --

4 DR. NETON: See John, I think those 

5 are Site Profile issues that you are 

6 describing. Those are refinements. I think --

7 DR. MAURO: Yes.

8 DR. NETON: an SEC review would be 

9 is the model appropriate? I mean, can the 

10 model appropriately be --

11 DR. MAURO: Can you bound it?

12 DR. NETON: Bound those things, and 

13 do you now the source-term is sufficient. You 

14 know that, that is my opinion, I mean, 

15 otherwise you are doing refinements of a 

16 calculation that you already actually agree is 

17 okay, you know?

18 DR. MAURO: I mean, yes.

19 CHAIRMAN ANDERSON: I guess I would 

20 say let's --

21 DR. MAURO: Maybe you are right.

22 CHAIRMAN ANDERSON: Go forward with 
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1 doing -- I guess I just don't want to -- we 

2 have got so many things --

3 DR. MAURO: Yes.

4 CHAIRMAN ANDERSON: On the table. 

5 We have got Hooker coming up and I don't want 

6 to, you know, if there is one that we can move 

7 forward on pretty quickly, I would just as 

8 soon try to do that, but I do want to be 

9 confident that we have done enough and I don't 

10 want to, as a first-time Chair --

11 MR. KATZ: I don't think you want 

12 to --

13 (Simultaneous speaking.)

14 DR. MAURO: It's just that this is 

15 a little bit unusual, that's all. We haven't 

16 come, we haven't achieved closure on an SEC 

17 issue in two hours in a long time.

18 CHAIRMAN ANDERSON: Well, I mean --

19 MR. ALLEN: The bottom line is you 

20 are the one that has to give some kind of 

21 report to the Board and what you feel 

22 comfortable with and what you want us to do in 
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1 order to --

2 CHAIRMAN ANDERSON: Given what they 

3 will ask you and you will go through this, I 

4 would say we have got to move -- you need to 

5 do more.

6 DR. MAURO: And I think that, what 

7 I could do is work with Hans, lay out 

8 something that would represent okay, we are 

9 going to do the following, put that in, send 

10 them an email out, I mean there's an action 

11 item on us, of exactly what it is we think we 

12 need to do --

13 CHAIRMAN ANDERSON: Yes. Okay 

14 that's good.

15 DR. MAURO: and a time period. And 

16 I can tell you now, from what I heard, you 

17 know, it's really a matter of touching the 

18 bases that need to be touched so that we can 

19 stand up and look everyone in the eye and say, 

20 listen we checked these numbers. Here's the --

21 and you know, and more than one person look at 

22 it.
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1 We are required to do that, quite 

2 frankly, so we have got to go through this QA 

3 process. I don't think it's going to be big. I 

4 don't think we are talking about months of 

5 work. We are talking a month, you know --

6 CHAIRMAN ANDERSON: Let's do that.

7 MR. KATZ: Let's do that.

8 CHAIRMAN ANDERSON: And if you can 

9 kind of give what your proposal is.

10 MR. KATZ: He will do that in a 

11 memo.

12 CHAIRMAN ANDERSON: And then before 

13 Idaho, an update on where we are, I can give 

14 people some sense --

15 DR. MAURO: It will be my action 

16 item. I will put out a memo, which will be, 

17 have a list of five action items that I wrote 

18 down, and I will put it out. 

19 But in this particular one, I will 

20 also give you an indication of when we will be 

21 able to deliver a report.

22 CHAIRMAN ANDERSON: Good. Don't we 
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1 usually deal with, denial things only at face2 to-face, not on the phone?

3 DR. NETON: Pretty much. 

4 MR. KATZ: Yes.

5 CHAIRMAN ANDERSON: So we are 

6 really looking at --

7 MR. KATZ: So we are really looking 

8 at November.

9 CHAIRMAN ANDERSON: Yes.

10 MR. KATZ: Because it is not going 

11 to get done in -- I mean we really have only 

12 about, I don't know how quickly you will do 

13 this, but otherwise, we only have four-and-a14 half weeks or whatever before the Board 

15 meeting and I don't think that is going to 

16 happen.

17 So we are talking about November. 

18 We are talking about November here, which is 

19 fine.

20 CHAIRMAN ANDERSON: Yes. That's 

21 good. Okay.

22 MR. KATZ: I guess if it does end 
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1 up going to a denial, of course, no one is 

2 hurt by the delay, I mean --

3 CHAIRMAN ANDERSON: Right. Yes. 

4 Yes. 

5 DR. MAURO: The process, quite 

6 frankly, let's say we were to put this on a 

7 fast track, the process would be a month of 

8 SC&A work and then it would have to go to DOE. 

9 That's usually two weeks or so, to get 

10 approval.

11 So even if we want, you know, full 

12 press, it's six weeks. 

13 MR. KATZ: We are looking at 

14 November, but just an indication from you 

15 that, a time line.

16 DR. MAURO: Yes, what that looks 

17 like. 

18 MR. KATZ: What you will do and

19 when. 

20 CHAIRMAN ANDERSON: Do we have any 

21 other issues? Now that I have got 20 minutes 

22 to make my flight, I am going to push you 
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1 harder but I will -- I will have a nice, quiet 

2 dinner tonight.

3 MR. KATZ: Me too.

4 CHAIRMAN ANDERSON: Go at 7 o'clock 

5 to the airport, the rest of you who are 

6 waiting over, you can go into town, party up 

7 and --

8 Anything, so, we have pretty well 

9 got three different items.

10 MR. KATZ: Yes, oh, the other thing 

11 that you want to, that is on the agenda to 

12 discuss, is just the status of DCAS and SC&A 

13 work on Hooker Electrochemical, to have a 

14 sense of where we are going forward.

15 DR. MAURO: Bill, could you give us 

16 the low-down on where you are on Hooker? 

17 Because you have been working Hooker, right?

18 MR. THURBER: Yes. You know, we are 

19 moving along. It's, we are well along. I think 

20 that the conversation we had this morning 

21 about how Hooker and TBD-6001 interplay is 

22 illustrative of some of the problems we have 
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1 had in sorting out things.

2 But our report is reasonably far 

3 along.

4 MR. KATZ: So, sort of a time 

5 frame? Maybe when you reply on the other 

6 things, you can give us a -- because we are 

7 going to need to plan another Work Group 

8 meeting. The time frames for these kind of 

9 relate to when all these deliverables will be 

10 coming in.

11 DR. MAURO: Once we have finished 

12 the technical analysis of Hooker, which it 

13 sounds like is pretty far along, we have to 

14 do, we are going to have a section dealing 

15 with surrogate data. Hooker makes quite 

16 extensive use of surrogate data. It uses TBD17 6001. 

18 And we are going to have -- and 

19 there are -- the Board has a surrogate data 

20 criteria document.

21 MR. THURBER: I thought we put that 

22 --
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1 DR. MAURO: For Hooker?

2 MR. THURBER: I thought that the 

3 issue of including discussions of surrogate 

4 data in all of these appendices was kind of in 

5 abeyance. Wasn't that the guidance from you 

6 Ted?

7 DR. MAURO: I thought that was just 

8 the opposite.

9 MR. THURBER: No, because -- you 

10 recall that I had originally advised everybody 

11 who was working on these appendices that a 

12 discussion of surrogate data, and given that 

13 the Bethlehem model was appropriate and then I 

14 thought that based on a conversation that you 

15 all had, that that was not going to be a 

16 requirement of these appendices at this time.

17 DR. MAURO: I have to say, just to 

18 be --

19 MR. KATZ: I have not had any 

20 discussion one way or the other on this 

21 subject.

22 DR. MAURO: I have been operating 
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1 on the premise that the most important --

2 MR. THURBER: Hans? Are you still 

3 there?

4 DR. BEHLING: Yes?

5 MR. THURBER: Can you shed any

6 light on that comment?

7 DR. BEHLING: You know, I was just 

8 looking at something else. 

9 MR. THURBER: I understand.

10 DR. MAURO: No, we know where you 

11 were. Hans, we have a number of SEC petition 

12 reviews and Site Profile reviews that deal 

13 with a lot of AWE facilities right now and 

14 Bill is very much involved in that work.

15 What I had in my direction, which 

16 I believe I gave everyone was, one of the 

17 chapters of this report has got to be the 

18 degree to which the use of surrogate data 

19 meets the five criteria -- I think it's five -

20 - laid out in the Board's guidelines, just 

21 like we did in Texas City, Bethlehem Steel, 

22 Dow and others.
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1 You are saying, now I have got to 

2 tell you --

3 MR. THURBER: Well I have got to go 

4 back and review my emails. I don't, I can't do 

5 it here because they're on my other computer.

6 DR. MAURO: I mean, to me that's 

7 the biggest and most important question. 

8 That's what turned Bethlehem Steel, that 

9 judgment, you know.

10 MR. THURBER: Well, I know that. 

11 DR. MAURO: Yes.

12 MR. THURBER: But I thought that we 

13 had a change in marching orders, but I will 

14 check my emails when I get home.

15 MR. KATZ: Yes remind me when you 

16 find what you find because I don't recall 

17 giving any guidelines about that question.

18 CHAIRMAN ANDERSON: For our next 

19 meeting, we probably need to do that before, 

20 what is it, December?

21 MR. KATZ: The next meeting face22 to-face is in November.
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1 CHAIRMAN ANDERSON: November. So, 

2 we probably, hopefully, will get your review 

3 on --

4 MR. KATZ: Hooker.

5 CHAIRMAN ANDERSON: Hooker and 

6 United whatever.

7 MR. KATZ: Oh, that, well in 

8 advance.

9 CHAIRMAN ANDERSON: But I would 

10 think at that meeting is where we would want 

11 you to, as a Committee we would make that 

12 decision so it needs to be far enough advance 

13 of the meeting so that you have got time for 

14 your agenda.

15 MR. KATZ: Does DCAS have anything 

16 ongoing related to Hooker? Is Hooker, are you 

17 --

18 MR. ALLEN: No.

19 MR. KATZ: Okay.

20 DR. MAURO: You gave a presentation 

21 and --

22 CHAIRMAN ANDERSON: You've got 6001 
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1 issues you're going to, and I don't know, will 

2 you have a White Paper in that time frame?

3 MR. ALLEN: Before which time, 

4 before November?

5 CHAIRMAN ANDERSON: Yes.

6 MR. ALLEN: I would think so, yes.

7 MR. KATZ: But we'll need a Work 

8 Group meeting in advance of the Board meeting.

9 CHAIRMAN ANDERSON: Oh yes, that's 

10 what I mean.

11 MR. KATZ: Absolutely.

12 CHAIRMAN ANDERSON: And what I was 

13 looking at is when. It would be nice it would 

14 seem, if we have your White Paper to look at.

15 MR. KATZ: Right.

16 CHAIRMAN ANDERSON: And we will 

17 have your little notes.

18 MR. KATZ: So we will get time 

19 lines from, both from Dave and from John for 

20 all of this work so we will know, and that's 

21 the point of the time line, so we can figure 

22 out when to have another Work Group meeting. 
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1 Because so far it is -- as soon as possible, 

2 of course in advance of November, because you 

3 never know what comes up with the review --

4 that's the work that gets done.

5 But new issues get unearthed or 

6 whatever.

7 CHAIRMAN ANDERSON: I just want to, 

8 we got a window we can start looking at

9 people's schedules.

10 MR. KATZ: I think until we hear 

11 back from them, until we hear back from them 

12 though, if we pull out our calendars now we 

13 have no sense of when we --

14 CHAIRMAN ANDERSON: Yes, no, no, 

15 but if we --

16 DR. MAURO: When is the, there's 

17 the August, and then what's the next meeting?

18 MR. KATZ: After August there will 

19 be another teleconference but the next face20 to-face is in November, some time before 

21 Thanksgiving, maybe a week before Thanksgiving 

22 or so.
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1 DR. MAURO: We will be finished 

2 with every --in fact our fiscal year will be 

3 over by then almost I mean, end of December.

4 MR. KATZ: Well December.

5 DR. MAURO: The end of December, so 

6 we are a month away from the end and in 

7 principal, for all of our missions, tasks, 

8 should be close to being done by the end of 

9 December, so I mean we are going to be done 

10 with almost everything unless you give us new 

11 work by that time.

12 That's way out, yes, we will have 

13 it well before that.

14 CHAIRMAN ANDERSON: Okay. Good. Any 

15 other questions, issues? 

16 MR. KATZ: For the good of the 

17 order.

18 CHAIRMAN ANDERSON: For the good of 

19 the order. Adjourned.

20 MR. KATZ: Adjourned. Thank you 

21 everybody for a lot of hard work today.

22 (Whereupon, the above-entitled 
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1 matter went off the record at 4:24 p.m.)

2