This transcript of the Advisory Board on Radiation and Worker Health, Santa Susana Work Group, has 

been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed and 

certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change.

1 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

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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 

+ + + + +

AREA IV OF THE SANTA SUSANA FIELD LABORATORY

WORK GROUP

+ + + + +

MONDAY

DECEMBER 4, 2017

+ + + + +

The Subcommittee convened via

teleconference at 10:30 a.m. Eastern Time, 

Phillip Schofield, Chair, presiding.

PRESENT:

PHILLIP SCHOFIELD, Chair

HENRY A. ANDERSON, Member

JOSIE BEACH, Member

WANDA I. MUNN, Member
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2 

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ALSO PRESENT:

TED KATZ, Designated Federal Official

TERRIE BARRIE

BOB BARTON, SC&A

D'LANIE BLAZE

DOUG FARVER, SC&A

MONICA HARRISON, ORAU Team

LARA HUGHES, DCAS

BONNIE KLEE

JIM NETON, DCAS

JOHN STIVER, SC&A

DENNIS STRENGE, ORAU Team
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Table of Contents 

Welcome and Roll Call .................................................................................... 4

SC&A Review of NIOSH Evaluation Report for ............................................. 6

Area IV SSFL SEC Petition 235 (1991-1993) ................................................. 6

Petitioner Comments ...................................................................................... 85

Path Forward and/or Work Group SEC .......................................................... 97

Recommendations .......................................................................................... 97

Plans for ABRWH December 2017 Meeting ................................................. 98

Adjourn ......................................................................................................... 104
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P-R-O-C-E-E-D-I-N-G-S 

10:32 a.m.

Welcome and Roll Call 

MR. KATZ: Okay, while we're waiting 

for them let's go through first some 

preliminaries and then we'll go through the rest 

of the roll call.

This is the Advisory Board on 

Radiation Worker Health. This is the Area IV 

Santa Susana Field Laboratory Work Group. 

Welcome, everyone. 

The agenda for today is very simple 

and the material for today we're discussing was 

reviewed by SC&A, the Evaluation Report of the 

petition.

They're published on the NIOSH website 

under the Board section schedule of meetings, 

today's date. So you can go there and get the 

agenda and review that.

Roll call. 

(Roll call)
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MR. KATZ: Okay, let me just remind 

you again to mute your phones, *6 to mute your 

phones if you don't have a mute on your phone. 

And then pressing *6 again will take your phone 

off of mute.

Let me now return to Board members and 

see who's joined us since we started the roll 

call.

(Roll call)

MR. KATZ: Okay, I would just suggest 

it's almost 10 minutes now. Let's get started. 

Hopefully Wanda and John will join us, but in any 

event we can start.

So Phil, it's your meeting.

CHAIR SCHOFIELD: Okay. It's Phil 

Schofield, Work Group Chair, no conflict.

MR. KATZ: Right. None of our Board 

Members on the Work Group have conflicts.

CHAIR SCHOFIELD: So we'll go ahead 

and turn it over to SC&A.
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SC&A Review of NIOSH Evaluation Report for 

Area IV SSFL SEC Petition 235 (1991-1993) 

MR. STIVER: This is John. When I was 

checking, it's been over three months since we 

talked about this petition at the last Board 

meeting. I thought maybe somebody from NIOSH 

would want to give a thumbnail sketch of the 

Evaluation Report and then SC&A could kind of 

segue into our review of it, if that would be 

acceptable.

DR. HUGHES: This is Lara. So you 

want me to just go over the entire presentation 

and you jump in when you think --

MR. STIVER: Just kind of give sort of 

a background.

DR. HUGHES: Okay. All right. We're 

here to discuss the SEC Petition Evaluation 

Report for SEC 235 Area IV for Santa Susana Field 

Laboratory.

This is the fourth SEC petition that 

NIOSH has completed. There are three prior ones: 
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SEC 93, 156 and 234. 

Combined those three petitions 

encompass the entire operational period. So when 

235 came along, what really was left for NIOSH to 

consider was the residual period which runs from 

the beginning of 1989, I believe, to the present.

So when we look to evaluate this 

petition, whether or not it would qualify, we 

were looking for the usual petition reasons for 

qualification.

What we came up with, what we found 

during the residual period was that there was an 

issue with the bioassay contractor that was used 

by Area IV, Boeing at the time -- or no, it wasn't 

Boeing at the time. North American Aviation.

So this bioassay contractor, it was 

controlled for environmental pollution, CEP for 

short. That was used from --

MS. BLAZE: Rockwell International.

DR. HUGHES: Yes. Sorry. August 1, 

1991 through June 30, 1993. 
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This was the period we considered for 

the evaluation because NIOSH does not use this 

bioassay data because the contractor CEP was 

cited for data falsification at a different site.

I may add, however, NIOSH is just not 

using any of this data because it's been 

compromised. 

So CEP, based on contract information 

that we found and the Santa Susana data, we could 

pin down the date as August '91 to June '93.

We looked at a number of claims. We 

looked at, in the SEC Evaluation Report, we 

present what facilities are still operating at 

the time.

There's the -- okay, let me look at my 

chart here -- the fuel storage facility was still 

operating. The radioactive materials disposal 

facility was still operating. And the radiation 

instrument calibration lab.

We're not so much looking at the 

facilities that were still operating but also at 
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the facilities that were undergoing active 

decommissioning and decontamination at the time 

because those would potentially produce the 

highest exposure potential.

So based on the facilities that were 

undergoing D&D and also based on some interviews 

with radiation protection professionals that were 

involved in this process, we identified 

radionuclides of concern as well as the sources.

So the radionuclides of concern we're 

looking at is transuranic activation products, 

uranium compounds and some limited thorium and 

plutonium products.

The sources obviously are dust from 

demolition operations, removal of the reactor 

activator concrete, the decontamination of the 

hot cell facility and any unencapsulated 

radioactive material that's handled, stored, 

transported.

There's internal monitoring data 

available for the workers that were classified as 
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radiation workers. Not everybody was monitored 

at the time.

So there's data available before the 

CEP period as well as after. 

We have internal bioassay monitoring 

for uranium, plutonium and mixed fission 

products. There's also a coworker model that is 

available. The coworker data analysis ended just 

prior to the CEP period.

There's also whole body count data 

available. Air sample data is available although 

it hasn't been analyzed in depth for this 

petition.

So what we did, we compared the 

available uranium mixed fission products, 

plutonium and gross alpha bioassay results that 

are available before the CEP period and after the 

CEP period.

The data after the CEP period is 

somewhat limited. So what we resorted to was 

mostly a graphical presentation just indicating 
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that there is no indication that the data after 

the CEP period was higher in any way than the 

data that we've seen before.

So there's no reason to assume that 

there would be any spikes and occurrences of high 

-- or incidents of high bioassay during the CEP 

period.

In addition the CEP period also has a 

fairly good amount of whole body count available 

and none of those showed any kind of unusual, 

high exposure in the workers.

So it was NIOSH's conclusion that 

despite the lack of CEP bioassay data for a little 

over two years, that we can do dose 

reconstruction for that period as well as dose 

reconstruction for external and medical. That's 

the findings of SEC 235 in a nutshell, if you 

have any questions.

MR. BARTON: Hi, Lara, this is Bob 

Barton. I guess -- before we sort of dive into 

our review, I guess my question kind of centers 
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around the implementation question.

DR. HUGHES: Okay.

MR. BARTON: So there are coworker 

models and soon we'll get into -- we still have 

some outstanding findings on, I know, OTIB-80 but 

how exactly would those coworker models be 

applied or what's NIOSH's intention there?

I mean would it be applied to 

essentially all workers or how would that work? 

For workers in this SEC period, what is NIOSH's 

intention? I mean, are we only applying this to 

radiological workers? Are we applying it to 

everybody? 

I guess I wasn't quite clear. We do 

have these coworker models in place, but how 

would that actually be applied in practice?

DR. HUGHES: I would pretty much 

follow our procedure similarly that would be done 

at other sites. So in this case it would -- it 

often is a judgment call. 

I think typically what we assign, 
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depending on what the worker did or what 

information is available as far as I know.

We don't have actually any claims that 

currently use the coworker model because it's 

only been implemented in 2014.

MR. BARTON: I understand. I don't 

want to get too ahead of the game here. I was 

just curious about that.

DR. NETON: Bob, this is Jim. I think 

Lara hit the nail on the head. We would use very 

much an approach like we used at other sites. If 

a person appeared to have been a worker engaged 

in direct activity, in activities that involve 

direct contact with airborne particulate 

material, they would get the 95th percentile 

distribution, and lacking that connection, they 

would get the 50th percentile with a full 

distribution. 

And if they clearly didn't work in 

radiological areas at all, I'm not sure what we 

have in the environmental area for Santa Susana 
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but if we have environmental data that would be 

applied as well.

So it's not unique to Santa Susana, 

that approach. 

MR. BARTON: Okay. So essentially 

it's the same where if you could be considered a 

radiological worker, you're at the 95th 

percentile.

DR. NETON: Correct.

MR. BARTON: You may be somewhere in 

between, intermittently exposed, that kind of 

category, then you're at the 50th.

And then if there's really definitive 

proof that you probably weren't exposed, then 

we're talking about environmental ambient.

DR. NETON: That's correct.

MR. BARTON: Okay. Thank you. 

MEMBER BEACH: So this is Josie. So 

I have a question. Lara, we talked about the 

SECs or you talked about them covering up until 

1988. 
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And it's pretty clear from '89 to '91, 

July of '91. How do you intend to reconstruct 

dose during that period? Those couple of years 

there.

DR. HUGHES: Right. We'd just be 

assigning doses based on available bioassay, 

available external data and then cases where 

that's not available, it would be a non-rad 

worker we would assign ambient and then cases 

where there is data unavailable just like we just 

talked about, there is the option of assigning 

coworker model in cases where we would feel like 

the worker should have been monitored but wasn't. 

It would be an individual dose 

reconstruction. 

MR. BARTON: So I need to clarify what 

we just talked about, that sort of framework of 

implementation would apply not just to the SEC 

period but essentially the entire residual period 

for Area IV. Do I have that clear?

DR. HUGHES: We have not identified an 
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infeasibility so the dose reconstruction would 

just follow our general procedures based on 

available data. 

CHAIR SCHOFIELD: This is Phil. I've 

got a question on that. 

One problem we've had with Santa 

Susana is the fact that we do know people from -

- were staged out of Area I to work in Area IV. 

We have people coming from Canoga and De Soto 

facilities back and forth.

I really want to know how you can 

narrow that down and how you can feel good about 

the methodology that you're using to narrow it to 

those people that you really think were covered 

or should be covered.

DR. HUGHES: It's not really what 

NIOSH does. NIOSH does not determine eligibility 

for employment of Area IV. 

When we get the claim, that means it's 

an Area IV, or it has been determined by the 

Department of Labor that this claimant worked in 
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Area IV. So we will assign doses or reconstruct 

doses based on the methodologies that we have 

available for Area IV.

We don't get any claims where a worker 

worked in Area I and so we would not assign doses. 

We only get claims for workers that have verified 

employment in Area IV. Does that answer your 

question?

CHAIR SCHOFIELD: Yes and no. I'm 

sorry to be kind of vague on that. 

But we do know that there are people 

staged out of -- they had offices or whatever in 

Area I but yet they did most of their work in 

Area IV.

DR. HUGHES: Right. I'm aware of the 

issue. NIOSH can't do anything with that. 

MR. KATZ: This is Ted. So that's 

just not a NIOSH issue, it's not an SEC issue. 

If they have verified employment, work in Area IV 

credited by DOL, we do it. But otherwise it's a 

non-issue. It's not even within the law for us 
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to do anything about any other case.

And we would never get it to deal with 

it. So it's really just a non-issue for the 

program here at NIOSH. 

CHAIR SCHOFIELD: Okay, thanks.

MR. STIVER: If there are no more 

questions I guess, Doug, do you want to go ahead 

and take over and talk about our ideas for the 

Evaluation Report? 

MR. FARVER: Okay. I'm going to be 

going through the -- I believe it's the same one 

that's on the website, the Evaluation Report 

starting on page 5.

And a lot of this Lara covered so I'll 

proceed kind of quickly and get into the more 

important information.

Beginning on page 5 we just give a 

little background of the issue about when the 

petition was received, when NIOSH qualified the 

petition, what NIOSH qualified the petition as.

The petitioners were asking for 
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qualification under several different areas. 

That's what NIOSH looked at. Looked at 

qualifying it under several different areas.

The only area that NIOSH found was 

relevant for qualification was under data 

falsification and which brings in touch the CEP 

data that NIOSH had previously identified as not 

being usable.

And as such that's what they 

determined and that's what it qualified under. 

And that's the question NIOSH evaluated as shown 

at the bottom of page 5, all employees and 

contractors from August '91 to '93. So that was 

the time period.

MEMBER BEACH: Can you speak up just 

a little bit, please? I'm sorry for 

interrupting.

MR. FARVER: I'm trying to position my 

phone so I've got the microphone and the speaker.

Okay. And then at the Advisory Board 

meeting in August, the Board tasked SC&A to look 
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at specifically the feasibility of reconstructing 

the doses without using the CEP data from 1991 to 

'93. So that was the focus of our task.

Page 6 is just a brief overview of 

what went on at Santa Susana Field Laboratory 

Area IV. Nothing new.

Page 7 we go through the previous 

petitions. Like Lara mentioned Petitions 93, 156 

and 234. SC&A was tasked to review 93 and there's 

a report issued on that. We were not tasked to 

review 156 or 234.

The time frame: Petition 93, you're 

looking at 2009, 156 is 2010 and 234, you're 

looking at the beginning of 2017.

That brings us up to the current 

Petition SEC 235. And section 3.2 we just give 

an overview of NIOSH's Evaluation Report.

We discuss that they disqualified the 

CEP data. They determined that they could 

reconstruct the doses for 1991 to '93. And they 

based their determination on the following.
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They had a coworker model in OTIB-80 

that they could use. The intake rates assigned 

at the end of the operation period were -- how 

should I put this -- most likely did not increase 

over the '91 to '93 period. And I think that's 

a good way to put that.

Now, there are some issues with OTIB80 that we're going to get into later, but that 

was one of their determinations, that they could 

use the coworker model in OTIB-80.

Also NIOSH looked at the D&D and the 

waste handling operations during the remediation 

period, the post-'88 period.

They determined that the work remained 

consistent to procedures and PPE and exposure 

risk, and there were no major radiological 

projects that would not have been monitored with 

workplace monitoring or personnel monitoring.

And their determination was that, also 

during this period of '91 to '93, they were doing 

whole body counts using Helgeson and they showed 
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no measurable exposures for the fission products.

So this is kind of a synopsis of what 

they base their determination on.

Then we go into the issues that were 

discussed in the Evaluation Report. And these 

are the issues that were specifically raised by 

the petitioner. 

I go through these one by one but it's 

pretty much just taken directly from the 

Evaluation Report. I'm not sure that that's 

entirely necessary. Do you want me just to move 

on a little bit? 

MEMBER MUNN: That's questionable.

MR. STIVER: You might want to go 

through, just kind of give -- you don't have to 

do it in detail but just talk about each one and 

kind of what our position is related to it.

MR. FARVER: Okay. Well, this is what 

they used to -- I believe what they used to 

qualify the petition. 

The first issue was general covered 
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employee status that the petitioner claimed that 

they could not reliably and accurately determine 

for all DOE workers their job location.

In the report, NIOSH states that it's 

not -- the petitions are qualified for evaluation 

on circumstances related to an entire class of 

employees that prevent the reconstruction of 

potential radiation exposure for the class.

So that did not receive qualification. 

Petitioner claimed that the Site 

Profile lacks specific information. NIOSH 

reviewed the documentation provided by the 

petitioner and will evaluate the need to update 

the Profile as needed.

And then we have the quote from NIOSH 

that our general working documents, the Site 

Profile and they will be updated as more 

information becomes available.

Issue three, radiological incidents. 

The petitioner claimed that the Boeing incident 

database contains incident reports that were 
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either not assigned to a radiological location or 

not equipped with appropriate radiation 

protection or were involved in an exposure 

incident.

NIOSH reviewed the incident database 

and did not find any evidence of routine 

radiological processes at the non-radiological 

facilities or incident summaries indicating that 

unauthorized subcontractor employees had access 

to the locations with radioactive material.

Issue four, employment records. The 

petitioner described an incident from 1963 as an 

example of the contractor withholding worker 

records based on the worker being unmonitored and 

presumably not the designated radiation worker.

NIOSH responded in the petition ER 

that the administrative policies of Rocketdyne 

created those empty records, and until the late 

seventies the site policy was to prepare an 

exposure record folder with employee 

identification information for every new 
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employee.

And that's kind of what created the 

empty folders.

Number five issue, lack of monitoring. 

Petitioner asserted that the radiation exposures 

and radiation doses potentially incurred from the 

members of a proposed Class that relate to this 

petition were not monitored either through 

personnel monitoring or through area monitoring.

NIOSH reviewed the documentation 

provided and found that there was insufficient 

evidence to support the claim of lack of 

monitoring to Area IV workers.

NIOSH stated it had access to 

personnel monitoring work data, BZA monitoring 

data, contamination and radiation survey reports 

and bioassay data for Area IV workers including 

examples throughout the period evaluated: 1991 to 

'93.

Issue six, falsified documents or 

statements. The petitioner claimed that the 
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radiation monitoring records had been lost, 

falsified or destroyed and there is no 

information about monitoring source terms or 

process from the site where the employees were.

The petitioner attached documents to 

support the claim.

NIOSH did not find any of the 

petitioner's supplied documents to support the 

basis that the monitoring records were lost, 

falsified or destroyed for the period after 1988.

However, NIOSH considers the bioassay 

data processed by CEP from '91 to '93 to be 

unreliable unless the results are also verified. 

NIOSH qualified the petition for 

evaluation under this basis alone.

Top of page 11, SC&A reviewed the 

petition, the Petition Evaluation Report and also 

the petition qualification statement. 

Attachment A, this includes about 50 

documents that were reviewed by NIOSH and 

included in their Evaluation Report.
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I'll make it clear SC&A did not review 

all of those documents. If you look at those 

documents most, many do not fall within the time 

period of 1991 to '93. So it would not be a good 

use of time to go back and look at a lot of 

documents from 1958.

NIOSH qualified the petition in 

February of 2017 and completed the Petition ER in 

May of 2017.

So that's just a summary of the 

qualification and the ER report.

Section 4, page 12. This is where we 

kind of start looking at the data from the ER 

report. We look at the external data for the 

monitored workers.

Well, as was pointed out in previous 

SECs, NIOSH has access to the beta gamma neutron 

dosimetry results as well as more supporting data 

for the operations at the site. 

A lot of this is presented in the TBD0038-6 for Santa Susana. The NIOSH external 
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database for Area IV contains dosimetry data for 

penetrating dose including gamma and fast neutron 

dose. So that's the data available.

For unmonitored workers, NIOSH has 

released OTIB-77 which is external coworker 

dosimetry data for the Area IV workers. The 

current evaluation SEC 00235 dealing with the 

disqualification of internal bioassay data has 

identified no concerns with the external coworker 

dose distribution models for OTIB-77.

SC&A did conduct a review of OTIB-77 

and issued a paper on its findings.

Ambient environmental dose. Go back 

to the TBD number 4 and it presents the ambient 

external dose for Area IV for the period of '77 

through '99 which covers the evaluation period of 

'91 through '93.

And then the occupational medical 

data. The SEC Petition ER found no evidence to 

contradict previous information that they cannot 

reconstruct the medical dose for the workers from 
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'91 to '93 using information in OTIB-6 and site 

documents.

The medical information hasn't 

changed for this petition. So overall the 

external dose reconstruction feasibility really 

hasn't changed because this petition is really 

not based on external data, and therefore NIOSH 

concluded they could reconstruct the external 

doses.

Now we go on to our review of the 

internal dosimetry data available. Section 

4.2.1, air monitoring data. 

NIOSH determined that the principal 

source of the data from '91 to '93 would be from 

airborne particulate generated during D&D 

activity. 

The air samples resultant from onsite 

D&D work are contained in the quarterly documents 

from '91 to '93 and quarterly reports also from 

that time period.

SC&A reviewed the air monitoring 
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results in Rockwell 1993 and find them to be 

incomplete. There's some gaps in the data. 

And granted these are summary reports 

and these are not all-inclusive air sampling 

reports.

This is one of the issues that we've 

got some questions about. And Bob, I'm going to 

let you take over because you have more 

information on the air sampling than I do.

MR. BARTON: Sure. Thank you, Doug. 

So what we're talking about here, and as we talked 

about at the outset, what's on the table 

currently as proposed for dose reconstruction, it 

essentially applies a coworker model based on the 

operational data to -- I don't think residual 

period is necessarily the right term, but 

certainly a D&D period.

So since essentially this is a 

surrogate-data question, there's a couple of 

different ways to go about figuring out whether 

you're on solid ground as far as applying data 
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from the operational period to this other period 

where it's D&D activities by and large.

I don't think I've ever run up against 

this particular situation before where we're 

talking about this period after operations and in 

order to bound the dose, we're going to apply 

essentially the dose model to operational 

personnel to this other period.

It essentially falls under the 

surrogate-data criteria which is the whole reason 

we bring up the air sampling question in our 

review.

If I could try to simplify it 

essentially the argument put forth so far is 

that, well, we looked at the bioassay data during 

this operational period and we have samples 

before and after the SEC evaluation period, 

samples that were not done by CEP so they're good 

samples, we can trust those results.

And we look at the bioassay samples on 

either side and said, hey, they're a lot lower 
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than what's in the operational period. So even 

though operations might not directly reflect what 

was happening during the D&D period, we feel 

confident that we can bound the doses using those 

operational bioassay results and which I think is 

a very solid argument.

What we're talking about here is you 

also have this air sampling data. And we took a 

look at what was referenced in the SEC. 

You have, to some extent or another, 

air sampling data for the hot laboratory, the 

radiological materials disposal facility and the 

SNAP facility. That's the Systems for Nuclear 

Auxiliary Power facility which are really your 

three I guess areas of concern with respect to 

Area IV at Santa Susana.

So we look at that data and there's 

actually air sampling including breathing zone, 

general air. The site is well characterized for 

the hot laboratory all the way through the period 

and then limited for the other two major 
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facilities. 

That was for a reason. You guys can 

look at the documentation and you can see that 

the regulators came in and said you really don't 

need to be simply sampling this area anymore.

So the question, we say, and this is 

really a recommendation, it's not -- I wouldn't 

characterize it as a finding, but I think it would 

be very beneficial if NIOSH went and looked at 

that air sampling data. Again, breathing zone, 

general area.

And just compare it to what's 

available during the operational period. Because 

then you have sort of a direct link between 

operational-period data that we're trying to use 

as a surrogate to this D&D period and we can say, 

listen, look at the bioassay results and they're 

higher for the operational period so we're 

confident that they bound them.

And we also compare that to the air 

sampling data that we have. And so we have this 
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actual meaningful connection between the period 

where we don't have bioassay data that's usable 

and the period we're trying to use as a surrogate 

for the SEC evaluation period.

So that's where we're really coming 

from with our comments regarding the air 

sampling. I think it would really be beneficial.

It kind of fits in with the Board 

criteria for using surrogate data. Now obviously 

we're talking about the same site so we're not 

trying to apply data from a different site to 

Santa Susana.

But again, I think since we are 

talking about essentially a surrogate-data 

question here making that meaningful connection 

between the radiological conditions, I think, 

would be a very powerful argument insofar as that 

data is available to NIOSH to do.

I believe I did see at least some 

summary data from the operational period that 

could be used to make such comparisons. 
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So I guess I'll turn it over to NIOSH 

and ORAU and see what their thoughts are on that.

DR. NETON: Bob, this is Jim. I just 

have a general comment. 

I think we should be careful about 

what we call surrogate data here. The 

implementation guide IG-004 specifically defines 

surrogate data as use of data from one facility 

at another.

We really honed in on that aspect in 

that document. This is not so much a surrogatedata issue I think as what I call a nearby data 

interpretation issue. There's other terms for 

this.

But surrogate data I think implies a 

lot more than what we've done here. And we're 

trying to fill in a two-year gap using data that 

is on either side of that time period. So I guess 

I'd just be careful of using the word surrogate 

here.

MR. BARTON: Okay, I understand that. 
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That word comes with -- I understand.

DR. NETON: I have a question about 

your suggestion to use the comparison, the air 

data.

You say to do a direct comparison of 

the air concentration before and during the 

periods. I mean, like. 

MR. BARTON: What I would suggest is, 

since we are using essentially bioassay data 

during the operational period we want to try to 

make some sort of connection between that, the 

radiological conditions during that period and to 

assure that we're actually bounding the two-year 

period we're trying to apply them to.

Again, this is sort of a situation I 

don't think I've come up with before where we're 

using operational data to bound essentially the 

D&D period. 

So what our suggestion is, and again 

it is a suggestion and I leave it to the Work 

Group here to discuss and do with as they please 
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is that we don't really have a way to make that 

connection between -- I won't use the word 

surrogate but between a period that we're using 

the exposure info for to cover the period for 

which essentially we have unusable bioassay data.

DR. NETON: Well, but we do have data 

on the other side during the remediation period 

starting in '93, do we not? I mean that is 

remediation data.

MR. BARTON: Yes. Right.

DR. NETON: I guess I'm a little bit 

concerned about the comparison of the air sample 

data only because in these areas you sort of get 

involved in the use of respiratory protection and 

how that weighs in.

I guess I would argue that what's 

coming out in the urine is really the exposure 

experience of the workers, not so much what was 

in the air at that point. 

Because again, in D&D operations you 

tend to have some respiratory protection maybe 
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even in the early periods. I don't know how a 

direct comparison would really pan out.

MR. BARTON: Well, I think the air 

sampling data that we have during the actual twoyear period that we're talking about actually has 

some discussion about respiratory protection 

factors. 

So I'm not sure that necessarily has 

to be left out. 

Again, the suggestion is just trying 

to make a meaningful connection between the 

period that we don't have any data and the period 

that we do have data and we're trying to apply.

We're not using the data that happened 

after this period we're talking about. That does 

not figure -- as far as I know does not figure 

into any coworker calculations. 

DR. NETON: Right. We do a direct 

comparison of the data we do have on the workers 

in that era. As you indicated in your review 

there's no substantive difference between the 
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pre-1991 and post-1993 excretion patterns of the 

workers during those periods. That's what we're 

hanging our hat on.

I don't know that going the extra step 

to look at the air data is, you know, would prove 

anything.

MR. STIVER: Jim, this is John Stiver. 

Let me just jump in for a second.

What we're trying to say is you could 

use it as a way to possibly corroborate that 

position if you could show that the radiological 

conditions during the period for which you're 

going to be using that data to bridge the gap, 

that two-year period, also fall in line with the 

bioassay data.

We provide -- it's an extra way to 

kind of triangulate on a position just to show 

that look, we've got two different sources, both 

the bioassay and the air sampling data that 

demonstrate our position.

Now granted there's a lot more 
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uncertainty in the air sampling data because of 

the respiratory factors and just local 

variations. You might have, during the D&D 

operation, you've got a backhoe or something 

that's stirring up a lot of material. In that 

one little area you might have a really high 

concentration but 10 meters away, it would be 

much lower. So yes, there is that aspect 

involved.

That's why we didn't make it a finding 

so much as a suggestion to kind of bolster the 

position.

DR. NETON: Okay.

MR. STIVER: Anyway, Bob, go ahead.

MR. BARTON: Well, no, I think that 

kind of sums up where we're coming with that. I 

leave it to some Work Group discussion.

I can certainly answer any questions 

on it but I think you put it very succinctly, 

John. I mean essentially what we're suggesting 

is this might be a way to sort of buttress the 
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position of, listen, nothing really changed as 

far as we can tell from the documentation.

And maybe it's as simple as looking at 

maybe not even the air sampling during the 

operations but air sampling that occurred just 

like you look at the bioassay before and after 

the period maybe that's where we should look, is 

the air sampling that occurred during D&D 

operations before and after that period.

I mean, essentially the other half of 

that argument is that, well, there weren't any 

major radiological operations that were 

distinctly different during that period than 

before or after which we don't disagree with.

But again this is just another way to 

try to -- again, we have bad bioassay data during 

that two-year period. And we want to apply 

different data to that period. So why don't we

try to find ways to really convince ourselves 

that yes, this is -- nothing changed during that 

SEC period.
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There's no reason to think that the 

doses were for some reason different during that 

SEC period, and that we're confident that the 

data that we are going to apply is going to bound 

what we don't know about that period.

MEMBER BEACH: Bob, this is Josie. 

Are you looking for just a memo or how are you 

looking to get that information from NIOSH?

MR. BARTON: Well, I guess it depends 

on what -- to the extent of what information we 

have that's available to be able to make such 

comparisons. 

It could be a memo. It could be --

really whatever the Work Group desires. It could 

be an email or what have you.

Again, this was not made a finding 

very specifically because it's a suggestion. 

Once we're going to apply data from one period to 

another, I think it's very beneficial to sort of 

turn over every rock so yes, we're confident 

nothing changed during that period and look, even 
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our air sampling data is very indicative of the 

period before and after and we're going to apply 

the operational period data to bound it.

I don't think, for at least uranium 

and plutonium, I don't believe we have data 

before the SEC period that actually went into 

formulating the coworker model. 

So again we're trying to apply 

essentially the data from the operational period 

in the 1980s essentially to this period in the 

90s when the bioassay results are suspect.

CHAIR SCHOFIELD: This is Phil. I've 

got a question. Like John Stiver just said, when 

you're doing D&D you've got these backhoes in 

there, jackhammers, whatever method they're using 

to deconstruct some of these facilities and 

things.

You do have -- tend to generate a lot 

of airborne stuff. And any facility that's been 

in use for many years is going to have hot spots 

in there that weren't cleaned up on those 
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occasions you had an excursion.

That being said, I have concern about 

the lack -- that this bioassay data cannot be 

really used. Do we know exactly, were they all 

required to wear -- have on face masks and stuff 

or were they just using the little paper masks 

for filtration purposes.

How confident are we that they were 

not getting any of this dust and contamination 

sucked in because of the lack of proper personal 

protection equipment? I mean, maybe there is 

something, a document there that indicates that 

no, when they were doing this they were required 

to wear face masks.

If that's the case then that's what we 

go with. 

MEMBER MUNN: Conversely, if there's 

no indication -- I'm sorry, this is Wanda -- if 

there's no indication of any kind in the records 

of undue exposure or of any incident of any kind, 

why would we assume that there was?
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MEMBER BEACH: It's the nature of D&D 

generally. This is Josie.

MEMBER MUNN: Yes.

DR. NETON: This is Jim again. If you 

look at Figure 7-2 and 7-3 in our Evaluation 

Report, we portrayed that exposure experience of 

the bioassay, the non-zero bioassay samples for 

uranium and plutonium and mixed fission 

activation product. 

And in general, the samples taken 

after 1991, during the remediation period, were 

lower than samples that were taken during the 

operations period.

And so that to me is an indication 

that exposures were not occurring that were large 

and undetected. The whole point here is that 

remediation period bioassay samples are equal if 

not lower than the samples taken prior to 1991.

And that's pretty good proof in my 

mind rather than going back and trying to 

speculate about who wore respirators, who didn't 
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wear respirators.

The proof is in what's coming out in 

the urine samples. That's our position anyway.

MEMBER MUNN: The only logical one.

MEMBER ANDERSON: This is Andy. I 

guess the question is, so how challenging would 

it be to look at the air data, because there could 

be things going on there. 

I mean, to just ignore data that's 

there and come to a conclusion without 

considering it, I think you can do that but I 

think unless it's -- I'm not sure what your 

concern is that if you look at the data, what do 

you think you might find that would be 

problematic.

DR. NETON: Lara, do you have a feel 

for how much data we have?

DR. HUGHES: No. All I know is --

well, we do have some data. We have not analyzed 

it in depth.

What I know is, especially for the 
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remediation period, we did not do an overly 

targeted data capture for air data.

Now, any data capture would look at 

air data but our focus has mainly been on the 

bioassay and available health physics procedures. 

So it would definitely require additional data 

capture. It would require data coding.

So from an effort and time standpoint 

we're looking at a quite significant effort here. 

So we're talking months to a year, I would think. 

Any kind of air data coding, it takes 

a long time.

MR. BARTON: What I saw when we were 

reviewing what was cited in the ER, you have --

it's actually not that much. Essentially summary 

reports or monthly.

DR. HUGHES: Right.

MR. BARTON: So we're not looking at 

every day air samples.

DR. HUGHES: But you stated that it's 

not complete. So that would mean -- we have not 
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done due diligence with regards to the air data, 

I guess, is what I'm getting at. Because it has 

not been a focus.

So before we could draw any 

conclusion, we would want to make sure that we 

have everything that we think would be necessary 

to look at.

So I have not extensively researched 

the available air data at this point. But any 

kind of air-data comparison coding is quite 

labor-intensive. It's certainly possible.

MR. BARTON: The data that we have in 

hand currently would not be sufficient to really 

analyze and gain anything useful from, is that 

what you're saying, Lara?

DR. HUGHES: Well, isn't your report 

stating that it's found to be incomplete, if I'm 

not mistaken? 

(Simultaneous speaking.)

MR. BARTON: -- hot laboratory.

DR. HUGHES: Yes. If you're talking 
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about going back to the operational period, I 

have not done a review of the air data. 

So I'm not sure. I really cannot 

speak to what kind of effort we would be looking 

at. If there's additional data capture it would 

be a significant effort. 

We can certainly look what's there and 

analyze that and then decide whether or not we 

need to do additional data capture.

Generally the air data has not been as 

much a focus for the residual period, or for the 

operational period because we have mostly relied 

on the bioassay data. 

MR. STIVER: This is John, if I can 

jump in. What I'm kind of hearing in general is 

that going after the air data probably -- the 

benefits you derive from that might not justify 

the effort required.

But maybe a scoping, kind of a pilot 

scoping type exercise to determine how big of a 

job it is going to be. Something that might take 
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a couple of months or it's going to be a year of 

intensive effort.

You get a better handle, then, on 

whether it would be worth pursuing.

DR. HUGHES: Yes, it's probably in 

between those two. But yes, that's certainly an 

option. It would be up to the Work Group to 

decide what should be done.

I'm pretty confident that the air data 

is there or there is a significant amount there. 

I don't expect to see any big gaps.

The location of the data would have to 

be determined because, during the evaluation, the 

data wasn't translated from the site to various 

record centers.

But based on the experience on finding 

bioassay data, I don't see any problem overall 

with obtaining data that we don't have.

I just can't speak to the effort at 

this point.

MEMBER MUNN: I'm not sure anyone can, 
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can they? That seems to be an unknown quantity.

MEMBER BEACH: So the urinalysis data, 

how much of that do we have? That's on Figure 

7.5, is it not? 

DR. HUGHES: I don't have the numbers 

handy. You have the graphs presented in the ER 

or the --

DR. NETON: Well, the graphs that we 

presented in 7.4 and 7.5 -- or 7.2, 7.3, 7.4 and 

7.5 I think are non-zero. Those are positive 

results.

There were a number of non-positives. 

And Tables 7.1 and 7.2 of the ER provide the 

numbers of urinalysis results prior to and after 

the CEP period.

There are like 22 results reported. 

Twenty-nine total results for uranium, 113 

plutonium, 65 strontium and 36 of gross alpha. 

That's all after the CEP period.

And there are substantially greater 

numbers before because it spans a larger number 
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of years.

But there were very few positives, I 

might add. I mean there were 2 positive uranium 

results, zero plutonium positives out of 113 

samples taken after CEP period, 7 positive 

strontiums out of 65 and 2 positive gross alphas 

out of 36.

MEMBER MUNN: None of those were 

large.

DR. NETON: Again, the results 

indicate a very low exposure potential during 

that period.

(Simultaneous speaking.)

MR. BARTON: Do we know if those were 

by and large incident-based sampling results or 

were they operating a routine program? Or are we 

talking about really a targeted program based on 

the discretion of the health physics staff at the 

time?

DR. HUGHES: It was routine for people 

that would have hands on. It would also be 
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incident follow-up, if there was such a thing. 

They did not monitor everybody. It 

was targeted. But for routine purposes.

MR. BARTON: Well, again, I don't want 

to really belabor this or beat it into the ground. 

Again it was a suggestion that if we had the data, 

then we could take a look at it and see what it 

tells us, then I thought that that would be a 

beneficial thing to do.

What it sounds like is that we don't 

have that in hand, though it may exist. And so 

I guess it's really up to the Work Group whether 

that's something that you all would like to see 

fleshed out or if we can go on the bioassay 

comparison for the bioassay samples that we have, 

the comparison of positives which do show and we 

certainly don't disagree there that the 

urinalysis results that you see during the 

operational period are understandably higher than 

the period when what was happening -- or likely 

what was happening during the evaluation period 
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we're talking about.

Again that's why it's really a 

suggestion, not any sort of deficiency certainly. 

But again we felt that in this type of situation, 

the more you can make a comparison or actually 

relate the period in question to both the 

surrounding D&D activities and of course applying 

operational data to this period, the more we can 

say about the radiological conditions during that 

two-year gap where we have bad data, the better.

If it's really not a feasible thing to 

do or really wouldn't add enough to the 

discussion to warrant performing those data 

captures, I can certainly understand that as 

well.

MEMBER MUNN: Well, I still have not 

heard or seen anything that would lead me to 

believe that any untoward activities or any 

unexpected exposures that were higher than what 

the operating period showed from the bioassay 

that we have, I can't see any reason why we would 
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be moved to make any assertion at all that the 

information we have wasn't adequate to assume 

that.

Although we don't have the kind of 

coverage we'd like, we don't have any evidence of 

anything of major consequence occurred either.

MR. BARTON: Well, I certainly don't 

disagree with that, Wanda. But again that type 

of evidence might be in the air sampling data 

which is why we brought it up as something that 

would be beneficial to look at.

So you are absolutely correct: we 

don't have any evidence that anything untoward 

happened. But again we were making a suggestion 

that if that data was in hand and available that 

we could take a look at it and really verify and 

say listen, we looked at -- specifically looked 

at the radiological conditions that were 

occurring during this period when we have bad 

data and were able to verify that. Nothing was 

different, nothing exceptional happened that 
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would lead us down a path to say we have a real 

problem during this two-year period again where 

we don't have adequate -- or the bioassay data is 

tainted and we have to make some assertions about 

what the conditions were and how we're going to 

appropriately bound those.

MEMBER MUNN: It's a perfectly 

reasonable approach. The only question I have 

is, we've already said we can't even make a wild 

stab at how expensive such a review would be. 

That seems strange to me. We ought to be able to 

-- at least we know what data is there.

I haven't seen it but certainly the 

folks who have been looking at this material have 

seen it so we must have some understanding about 

how expensive such a review would be. Can't we 

get any guesstimate at all?

What I heard earlier was it might take 

a couple of months to look at it, but did I miss 

some inference there that it might be a really 

expensive job?
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DR. HUGHES: This is Lara. I'm not 

sure. We have not coded any of this data. We 

have not done a complete analysis that we have 

all the data from the relevant facilities. 

So we'd have to do a review of the 

Site Research Database to see what's available. 

Then if there's any significant gaps that we 

needed to fill, we'd have to do data capture. 

And then after the data capture to try to fill in 

the gaps and then I'm sure data coding would be 

involved. So yes, we're looking at months I would 

say.

CHAIR SCHOFIELD: This is Phil. I've 

got a question. If you were looking at this data 

was there a quarterly report summarized during 

the D&D or not that you know of? I'm just asking 

if you know if there were or were not.

Rather than having to look on a daily 

basis, I'm assuming a lot of these filters were 

counted at the end of each work day or whatever 

it is. Or were these once-a-week filters, or was 
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there a synopsis there at the end of each month 

that said here's kind of in general what we had 

this last month or this last quarter.

Are you aware of any records like 

that?

DR. HUGHES: I do believe there are 

quarterly reports, yes. And there are weekly 

general air type of data. But often they are 

presented in a summary style table in the 

reports. 

So we wouldn't necessarily have all 

the data but we would have some data points that 

are above a certain limit or something like that.

MR. BARTON: This is Bob. I'm not 

sure that -- and we're talking a lot about 

completeness and things like that. We're not 

really proposing that air sampling data be used 

as an actual dose reconstruction tool.

But I mean even comparing monthly and 

quarterly summaries, to some extent, I think 

would have some value in establishing what the 
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conditions were during this two-year period. 

What the conditions were before and after that 

would back up and verify that what we're seeing 

in bioassay data is exactly that. That doses and 

exposure potential were lower during the 

evaluation period and thus we can bound them 

using the coworker model approach that's on the 

table.

So I'm not sure that we would really 

need to vigorously go into each and every air 

sample. I assume we don't think that's 

reasonable. 

But to the extent we can use sort of 

a summary report that I believe they have the 

maximum breathing zone observed and they also 

talk about whether that involved a respiratory 

protection factor. 

And then you have certainly some 

summary data about the general air samples. At 

least this is what we've seen definitely for the 

hot laboratory and the other two major 
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radiological facilities. At least early on for 

the first few months of the SEC period, you can 

see data for those other two facilities as well.

So I'm not sure it would need to be, 

if we decide to go down this road, a huge effort 

to code every single air sample result we have. 

But I think even from the bird's-eye 

view just looking at what summary data we have, 

I think we might be able to make some statements 

about what the conditions were.

MEMBER MUNN: I certainly agree.

MEMBER ANDERSON: I'm looking at it as 

an assurance function, not a quantitative 

structure, kind of. 

So I think it's just helpful in 

thinking of it from a petitioner's standpoint to 

ignore data that might be there that would 

provide greater confidence that what we're doing 

is correct. That's my only thing. 

I think it would be worth, not 

extensively, but if there's some anomalies that 
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in looking at the quarterly or whatever the data 

is, you may need to go further.

But I suspect we'll find that, if you 

look at it and it's consistent with the before 

and the after data. 

MS. BLAZE: Excuse me, guys. This is 

D'Lanie, the petitioner. Have we moved now into 

speaking about the path forward and the Work 

Group's SEC recommendation?

MR. KATZ: No, D'Lanie, we'll get to 

that.

MS. BLAZE: Okay, thank you.

MR. KATZ: You're welcome. 

MEMBER BEACH: So I agree, I think 

that we should request NIOSH to go in and at least 

give us an overview of what's available.

MEMBER MUNN: Well, certainly if 

summary reports exist and we have not 

incorporated them into our review, then we 

certainly need to do that.

CHAIR SCHOFIELD: I agree with that 
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too. I think let's take a look. Hopefully those 

documents do exist.

MEMBER MUNN: Do we have any knowledge 

of, not extensive as you said before, but do we 

have any knowledge -- did I hear anyone say yes 

we do or do not know that we have summary reports?

DR. HUGHES: Yes, we do. We do have 

summary reports.

MEMBER MUNN: Then that seems to me to 

be the most straightforward and rational thing to 

do. Take a look at them and see if there's any 

evidence at all in them that there are unusual 

occurrences or higher exposures than the current 

data that we have indicates. It's just an 

assurance factor it seems to me.

Right. It can eliminate any question.

DR. NETON: This is Jim. As long as 

the Work Group understands the granularity of the 

data is going to be pretty granular.

MEMBER MUNN: Yes. Very large grains.

DR. NETON: There may be two samples 
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out of the facts taken that exceeded -- you know, 

that kind of stuff.

MEMBER MUNN: Yes.

DR. NETON: Certainly not going to be 

able to generate any distributions or do any 

statistical comparisons.

MEMBER MUNN: No, I don't think anyone 

is expecting that. I'm certainly not. I just 

can't see any reason why we can't say there's 

nothing in the information, in the summary data 

that we have that would indicate that the 

assumptions that are being made are not accurate.

CHAIR SCHOFIELD: And maybe just flag 

the data that tell us do we need to take a more 

in-depth look at this. Give us a little 

confidence about where we are and where we're 

going.

These quarterly or monthly reports, 

however they reported them there, I don't know. 

But I mean like Lara says, you hate to go back in 

and have to look at a daily log of these different
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ones when we can look at the quarterly report and 

it says, well you know, we only had out of so 

many samples there was only three or four that 

were above what we're expecting.

Unless anybody else has heartburn with 

that, I'm kind of in agreement that let's go back 

and take a look at those reports.

MEMBER MUNN: It can't hurt us. And 

as Jim said, I don't think anyone -- I haven't 

heard anyone say anything that would lead me to 

believe that you really and truly want to get 

actual analytical data here.

This is just reassurance that there's 

no evidence that the assumptions we made are not 

accurate. It doesn't look like anything 

happened.

We have no evidence that anything that 

would be different during that period than it is 

in the following, after 1993.

So can we ask that that be done? Can 

NIOSH do that for us?
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DR. HUGHES: Yes, absolutely. 

DR. NETON: Yes, we can do that.

MEMBER MUNN: All right, let's do it.

MR. BARTON: Okay. That concludes our 

little chat on air sampling. Doug, did you want 

to continue, or?

MR. FARVER: You might as well go 

ahead and finish up, Bob.

MR. BARTON: Okay. So the other -- I 

guess there were sort of two other items. The 

next one would essentially be the issue of the 

coworker model which is OTIB-80 that is being 

proposed for this period.

OTIB-80 came out in March of 2014. It 

contains the intake values for plutonium and 

uranium fission products. 

And SC&A actually reviewed that report 

back in November of 2014 and there were 15 total 

findings from that report. 

So the question is now which of those 

findings -- obviously they're relevant in a Site 
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Profile context, but which of those findings are 

actually relevant to this SEC period we're

talking about.

A couple of them are obviated by the 

presence of SEC 234. Trying to walk these back, 

and it's 94 and 11 that really aren't relevant to 

this period.

Other ones were not relevant because 

at the time that coworker model was put together, 

we didn't have the time-weighted, one person one 

statistic method which was adopted later on. 

So kind of like how Findings 5, 8 and 

10 kind of related to how that was being 

calculated which really wouldn't be relevant 

anymore since -- if that TIB were to be updated 

to current methodology, the whole calculation 

would change anyway because of the time 

weighting.

The remaining findings really 

centered around how you combine years of bioassay 

to analyze. Part of the implementation guide 
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talks about if you're going to combine multiple 

years of bioassay data for calculating the 

intakes, you have to make a meaningful 

comparison.

This is where it gets a little strange 

for me because a lot of these findings are about 

how you calculate coworker intakes during the 

operational period.

So some of them are findings related 

to, well, can you back-extrapolate data to these 

previous years and can you combine these years 

without justifying what the operations were.

This is where it gets a little strange 

because, while certainly relevant to assigning 

any intakes during the operational period, now 

we're essentially using this data for the D&D 

period or the remediation period.

So there's a little bit of gray area 

there but these findings are -- currently have 

not been really discussed.

Another finding is related to what we 
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call inclusion criteria. Essentially this gets 

down to how the bioassay samples were labeled, 

whether mixed fission products or just fission 

products and which ones were used. And we had 

some questions about how those were combined.

So again these are sort of the 

technical aspects of how you get from the 

bioassay data during the operational period to 

that final intake value.

So again these sort of seem more like 

Site Profile type issues but they should be 

resolved if we're going to apply this data in the 

SEC context.

Now Finding 15 which is the last one 

dealt with the intakes from other potential 

radionuclides.

Now if you recall SEC 234 was 

essentially based on the inability to reconstruct 

doses to thorium and americium. And as far as we 

know or as far as we can tell, the current method 

is silent on how intakes to those contaminants 
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during the D&D period might be handled.

We've already established that we 

cannot reconstruct those doses during the 

operational period, but we really need to either 

come up with a method to reconstruct thorium and 

americium from D&D activities or provide cause 

for why that source term did not exist anymore. 

Maybe those facilities were remediated.

I really don't have direct knowledge 

on that. So I would be very interested to hear 

NIOSH's thoughts for, again, those two 

contaminants were sort of the basis for SEC 234. 

How will those potential intakes be handled in 

the post-1988 period?

DR. HUGHES: We've kind of looked for 

the -- trying to nail down the source term and we 

haven't really been able to come up with much 

regarding the thorium. Based on the available 

data that we found at the site, all the thorium 

material had been moved offsite years before the 

end of the operational period. Same with the 
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americium. Americium, there would be some 

transuranic residual, there's a potential for 

some thorium residual but this is not a very large 

source term so from what we have been -- we 

actually did go and looked at every single 

facility that was previously listed as handling 

thorium and looked at the status of the facility 

during that period and just haven't been able to 

get hold of it. 

Either the D&D is gone, completely 

gone, or it's in the material that handled the 

thorium that had been decontaminated in the 

meantime such as the hot laboratory. There's 

actually some indication that when they processed 

or decladded the thorium fuel that it was cleaned 

up afterwards before it was used for something 

else.

So we haven't really found -- to turn 

the issue around, we have not been able to make 

a case that there was a source term left. And 

it's kind of reflected in the health physics 
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documentation that is available for the '91 to 

'93 period.

So we cannot use the CEP data. 

However, we can see what the site ordered the 

vendor to analyze for. So let's assume that they 

had a solid health physics program in place at 

the time.

I think we do not necessarily doubt 

that. Just because the vendor lost its 

credibility doesn't mean that the site wasn't 

doing what was required.

So there is no indication that they 

analyzed for thorium or americium. Americium 

would have been picked up with the whole-body 

count to some extent. But there's no indication 

that they analyzed for thorium which kind of 

leads us to believe that there really wasn't a 

source term that we could nail down.

So in the end we do not really have 

an approach in place for this period.

MR. BARTON: So is the position then, 
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NIOSH's position that there was no exposure 

potential to those contaminants?

DR. HUGHES: That is correct. We have 

not been able to find a source term for thorium.

MEMBER BEACH: This is Josie. Do you 

have any documentation on when they stopped using 

thorium and when it was cleaned up?

I know in the ER report, it shows when 

the different buildings were D&Ded but I'm not 

really clear where those source terms --

DR. HUGHES: We don't really lay it 

out in much detail. It actually has not been 

done for the Evaluation Report mostly because of 

a lack of time.

I have some handwritten notes that I 

have pulled out of various documents indicates 

what site, what buildings were still there, what 

buildings were still operating when they were --

what buildings handled the thorium and what state 

they were in.

That's certainly something we could 
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write up in a White Paper of some sort. But yes, 

I don't have anything handy right now.

MEMBER BEACH: I think that would be 

important for us to see based on the last SEC 

that was passed just to verify we don't have that 

issue moving forward. At least for me.

DR. HUGHES: The thorium operations 

were fairly limited, keeping in mind that even 

for the inability to do thorium for the 234 

report, it's a fairly small operation compared to 

the remaining of the site operations.

We could not do it for -- in the end 

it affects the entire site. But yes, we have not 

-- it was a fairly small source term to begin 

with and during the residual period, we just have 

not been able to see where it's at.

MR. BARTON: I think you've made a lot 

of very good arguments just then. And I think 

that fleshing it out with references and what 

buildings actually handled the thorium 

operations, and when did they get actually 
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remediated or demolished. That sort of 

information will at least -- I think would give 

everyone confidence that it's a non-issue.

Or you may find that, as you're 

putting it together that well, maybe you need to 

come up with some sort of a whether it's a source 

term ratio or something like that to deal with 

those contaminants.

But as it stands right now the 

evaluation doesn't quite deal with those and I 

don't think it's been quite established that it's 

-- at least it hasn't been established officially 

that those aren't an issue that we need to 

reconstruct.

DR. HUGHES: Okay.

MEMBER BEACH: And then, Phil, if I 

might. This is Josie. I have another question. 

We talked about the OTIB-80. And the report was 

written sometime ago back in 2014. 

I was just curious, and in my notes 

it's something that maybe SC&A needs to go back 
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through in light of this new petition and where 

we stand with the coworker model and NIOSH's plan 

to use the coworker model for those later years, 

the ones under discussion.

Would it be beneficial for NIOSH to go 

back through their report and re-review those 

findings and put something out for the Work Group 

for what's relevant now based on that coworker 

model? Or that OTIB, excuse me.

MR. BARTON: Josie, this is Bob. I 

might be able to comment a little bit on it.

In preparation for this meeting, we 

did, or I did anyway kind of walk back and see 

which of these findings would really affect an 

SEC deliberation for the period we're talking 

about now.

Now, all those findings are currently 

open and essentially they'd be considered, I 

think, Site Profile issues just for the fact that 

it hasn't been established that you can't 

reconstruct doses during the operational period 
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for uranium, plutonium and fission products.

So reconstructing those doses is 

obviously still relevant, just not in an SEC 

context.

For my mind, the only one that was 

really still relevant to the period we're talking 

about today was what we just discussed.

MEMBER BEACH: Just 15, okay.

MR. BARTON: Yes. That's my feeling 

on it, certainly.

MEMBER BEACH: Okay.

MR. BARTON: If there's no -- I can 

move forward if there's no more questions or 

comments on -- again the main issue was what 

source term are we really talking about during 

this two-year period, and are americium and 

thorium still a concern, and do we need to develop 

some sort of method to deal with them, or is there 

ample evidence to believe it's not a concern and 

so we don't have to really deal with it?

I just think, as it currently stands, 
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the evaluation was a little silent on that 

particular subject and I can certainly understand 

time constraints or what have you.

But I think, again, whether it's a 

White Paper or what have you, I think it needs to 

be fleshed out so that we can convince ourselves 

that those two source terms which form the basis 

of SEC 234 are really not a concern because the 

buildings had already been cleaned up or 

demolished and obviously there were no operations 

going on that used those source terms.

I think that argument just needs to be 

made.

DR. HUGHES: Okay, that certainly can 

be done.

MR. BARTON: Okay, if there's no other 

discussion on that particular thing, the last 

thing we really wanted to talk about was as part 

of our process we take a look at the claimant 

population just like NIOSH did.

At the time of the ER there were 29 
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claimants that were employed at Area IV during 

this two-year period. There's been one more 

claimant added but we have not yet received the 

DOE monitoring file for that person.

So essentially the staff has remained 

pretty much unchanged.

So we really looked at the CATI 

reports and the statements that were made therein 

to see well, do we have any incidents or any 

indication that the conditions might have been 

different.

And anyone who's really kind of waded 

into the CATI process knows they often aren't all 

that specific, but at least one of the claimants 

mentioned an incident. So it was worthwhile 

mentioning.

However, it really involved what was 

more of a -- what appeared to be a medical 

incident, required first aid, that kind of thing, 

and there was really no indication of 

radiological hazard associated with it. So there 
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was really nothing we could go beyond that.

But again in those 30 claims, we did 

not find any indication of something that would 

really pique our interest about this two-year 

period that would really give us pause.

So again that's another piece of 

evidence sort of as we build this case on whether 

dose reconstruction is feasible or not.

And the other thing we kind of looked 

at was how had these claims been reconstructed in 

the past and how does that comport with what we're 

talking about now.

So we looked at that. And as Lara 

mentioned, none of these claims really have used 

the coworker model thus far because I think 

that's really kind of a new approach. 

So just to simplify this a great deal 

what we suggested is if it's determined that 

reconstruction is feasible then these other 

issues regarding sort of the broad view air 

sampling analysis, I don't want to say analysis 
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because that implies we're looking for a 

numerical result there, but look at the air 

sampling data. There's a question of source 

terms.

If we can get past all that what we 

recommend is that NIOSH provide essentially 

examples of dose reconstruction to demonstrate 

their approach which kind of circles back to my 

comments at the start of the meeting that we have 

this sort of new framework that we're going to be 

applying to some claims here.

And it doesn't have to be an actual 

dose reconstruction. Let me give an example. 

Hypothetical worker A has this job title, worked 

from this time to this time. Here's how we're 

going to apply the coworker model to that 

individual.

And I think that kind of an exercise 

in the past has been very helpful in sort of 

bridging the gap between the sort of overarching 

policy discussions and how it's actually going to 
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work when you're looking at an individual.

So again that's sort of, again, once 

we get past the other two hurdles we talked about, 

I think that's very helpful in illustrating 

exactly what would happen in a real dose 

reconstruction context.

MEMBER BEACH: Yes, and that's usually 

part of a Site Profile discussion, isn't it, at 

that point?

MR. BARTON: That certainly would be 

because at that point we're talking about dose 

reconstruction is feasible.

MEMBER BEACH: Right.

MR. BARTON: Let's see how it works. 

So that was all I really had. Doug, do you have 

anything else you wanted to add to this?

MR. FARVER: No additional 

information. That's pretty much what it comes 

down to.

MR. STIVER: Bob, this is John. I 

don't have anything to add. You did a really 
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good job presenting.

MEMBER BEACH: This is Josie. I don't 

have anything else on what we've been discussing. 

However, we did get a document this 

morning. I know it was from the Petitioner and 

I know there's a time on our schedule for her to 

present some things.

But I really think that document 

should be reviewed by SC&A, if the Work Group 

agrees with that also, before we move forward. 

Anyway, that's just my thought on that. That's 

all I have.

MR. KATZ: Yes, Josie, I've already 

shared it with SC&A.

MEMBER BEACH: There's just a lot of 

points in here that they might want to take some 

time to review and then let us know.

MR. KATZ: Absolutely, that's fine. 

MR. STIVER: Okay, so Ted, do you want 

us to take a look at that?

MR. KATZ: Yes, absolutely. I'm sure 
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NIOSH will look at it, too.

MR. STIVER: Okay. So I'll go ahead 

and take that as a task.

MR. FARVER: This is Doug. I just 

want to let you know the document that is 

referenced in the Petitioner's document, 

operation, the proprietary interest in Area I and 

IV, I could not find that document in the Site 

Research Database. So I don't know if it's 

available or not.

MR. KATZ: Doug, after this meeting, 

I think you can confer with Lara about what you 

can or can't find in the Site Research Database.

MS. BLAZE: I'm happy to provide the 

document again to anyone who needs it.

DR. HUGHES: Thank you. I just 

reviewed this report half an hour before the call 

started. I'm sorry, I have not had a chance to 

go through it in detail. 

So if you send me an email, this is 

Lara, I'll be happy to try to find that for you.
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MS. BLAZE: It was submitted August 

15, 2017 at the Santa Fe Work Group meeting.

DR. HUGHES: Oh, okay. Then it's most 

certainly in the Site Research Database. 

MEMBER BEACH: I think it was Doug 

that couldn't find it. Maybe a number is all we 

need there.

MR. KATZ: Yes, that was Doug.

MR. FARVER: I searched the words and 

it did not come back with anything.

MR. BARTON: I'm sure we can take care 

of that offline.

MR. KATZ: Yes.

CHAIR SCHOFIELD: So this one --

MEMBER MUNN: Will that be available 

in our minutes, our procedure information from 

the Santa Fe meeting.

MR. KATZ: I'm sorry, Wanda, what are 

you looking for?

MEMBER MUNN: I was asking -- we were 

just talking about difficulty finding the 
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comments that were provided -- were referred to 

by the Petitioner. And I was just asking -- no?

MR. KATZ: The comments from the 

Petitioner were sent to you by email. We're just 

talking about a reference document.

MEMBER MUNN: The reference document, 

yes. My question was, is the reference document 

a part of the proceedings from the Santa Fe 

meeting. Did I understand correctly that it was 

submitted at that time?

MR. KATZ: They were submitted at that 

time but they would be in the Site Research 

Database. 

MEMBER MUNN: Okay. Thank you.

CHAIR SCHOFIELD: Would the Petitioner 

like to make any comments at this time?

Petitioner Comments 

MS. BLAZE: Yes, I would. Thank you. 

Hi, this is D'Lanie Blaze. I really want to thank 

everyone for all of your hard work on a clearly 

complex site.
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I did submit my written responses to 

the SC&A review to address NIOSH's position in 

the ER. That response contained examples of nonradiological facilities that were routinely used 

for radiological purposes.

It also contains reports showing 

unauthorized and unmonitored subcontractor 

personnel present and accessibility in a covered 

area.

Also I provided some information on 

air sampling data that was never included in the 

environmental analysis. The contaminated air 

sampling media was found in file cabinets with 

historical records in the mid-1990s.

The EPA Area IV radiological 

characterization study that was released in 2012 

provides radionuclides of concern for every Area 

IV location. And it may be very helpful in 

establishing which facilities had americium and 

thorium and also provide information on the 

radiological surveys for those locations and tell 
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us when they were demolished.

So I would highly recommend that you 

guys review the EPA Area IV radiological 

characterization study.

There are ongoing issues with Area IV 

site remediation workers who lost their radiation 

protection programs when they were switched over 

to a subcontract status.

Currently most of these guys remain 

unmonitored although they're still engaged in 

D&D. And Boeing is unresponsive to employment 

verification requests for all subcontractor 

employees onsite.

Current site remediation workers are 

sending photographs of themselves showing that 

they're wearing Boeing-issued work gear and work 

badges at the radioactive material handling 

facility and it is not considered good enough to 

prove that they are eligible for EEOICPA. 

They're just automatically disqualified.

And Boeing is telling them that 
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EEOICPA was never meant for them anyway and they 

shouldn't even bother applying.

All Santa Susana Field Lab employees, 

regardless of job title, work location or 

administrative area were employed by a Department 

of Energy contractor or subcontractor.

They had access to Area IV and 

routinely rotated into Area IV, in the Canoga and 

De Soto facilities during covered and SEC time 

periods.

There is actually no basis to exclude 

them from the SEC Class. And we have established

that we cannot track worker movements throughout 

the site.

Area IV employees who are clearly 

eligible for EEOICPA and who may even qualify for 

an existing SEC are routinely misrepresented by 

Boeing as workers who do not qualify.

For example, Area IV site remediation 

workers with radiation data have been represented 

by Boeing as employees of the Canoga facility. 
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This is data falsification.

This is an attempt to limit and 

control the eligibility by providing false and 

misleading information, and it is keeping workers 

who meet the qualification standards from being 

recognized.

These guys should easily qualify for 

this program and even under an SEC. But instead 

they're mostly turned away.

Even those who actually do qualify for 

the SEC can mistakenly be sent into dose 

reconstruction based on only a fraction of their 

covered employment. 

This predictably leads to an 

incomplete evaluation and a lower probability 

outcome. 

There's no way to tell how many 

legitimate claimants have been turned away 

because of this problem, but the existing SECs 

are only helping a fraction of the workers that 

they were intended to cover.
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So the original Class that I proposed 

in my SEC petition can correct this.

We do have contracts showing 

Department of Energy operated in Area I and that 

those operations supported Area IV programs. 

But regardless of whether or not Area 

I is ever a covered facility, the evidence shows 

that the DOE operations there were related to 

Area IV work. 

And that further supports Area IV 

accessibility and undocumented worker rotation 

among DOE contractor and subcontractor employees 

who are affiliated with every administrative area 

of the work site.

NIOSH considers data falsification an 

SEC qualifying factor. When an eligible employee 

is intentionally kept from establishing the full 

scope of his covered employment due to misleading 

information created by the contractor and 

provided instead of authentic employment records, 

that's grounds for an SEC Class.
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Now that this issue has been 

discovered and we've actually been seeing some 

wrongfully denied claims reopened because of it, 

DOE and Boeing are trying to change the rules. 

According to DOE it has now modified Boeing's 

contract so that Boeing no longer has to provide 

comprehensive, complete, authentic employment 

records.

As we've all seen, DOE and Boeing are 

unresponsive to requests for information to 

evaluate this petition, to requests for 

employment verification and radiation records and 

to requests for information to verify Area IV 

site remediation subcontractors. 

The inability to obtain authentic 

employment records is grounds for an SEC Class.

New information that I am preparing to 

submit includes employment records showing that 

in vivo whole body scan results were routinely 

omitted from worker radiation data. Apparently 

this was a common administrative practice and the 
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records show that it applied to Helgeson data 

too.

I'll also submit new information 

showing visitor badges were issued quarterly and 

consistently monitored workers wore several of 

the visitor badges along with their standard 

issue radiation badges.

This discovery raises some questions 

about workers whose job titles required 

consistent monitoring but whose records lack any 

personal radiation data.

In a growing number of cases, it looks 

like Boeing only provided the visitor logs. 

There are indications that this 

problem is most common among the workers who 

clocked in outside Area IV but who performed job 

duties for DOE inside Area IV.

Although their employment records 

often show established work rotations in Area IV, 

it appears that there's been an effort to 

misrepresent these guys as only occasional 
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visitors by withholding personal radiation data 

and only submitting the visitor logs.

These workers represent the original 

work group that Boeing tried to exclude from 

EEOICPA at the inception of the program during 

the eligibility disagreement with Department of 

Labor that effectively pended all the claims 

associated with Santa Susana between 2002 to 

2005.

Boeing states it is not in possession 

of site remediation subcontractor employee 

records and therefore they cannot verify 

subcontractor employment. 

I have obtained copies of Boeing's 

subcontractor agreements specifying the types of 

subcontractor employee information that Boeing 

requires for every subcontract worker onsite.

This establishes that Boeing is in 

possession of subcontractor employment records 

that are subject to the Privacy Act and EEOICPA 

and further substantiates apparent attempts by 
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the contractor to interfere with EEOICPA 

eligibility for Area IV site remediation and 

subcontractor employees who already meet the 

established criteria.

And I believe this issue is also a 

qualifying basis for the SEC. 

At GE Evendale and other sites, NIOSH 

acknowledged all DOE contractor and subcontractor 

employees onsite as a class of workers eligible 

for the SEC.

And when necessary NIOSH questioned 

site boundaries between work areas and held 

outreach meetings to give those workers a chance 

to provide information about working conditions 

onsite.

NIOSH has yet to respond to the 300 

former worker interviews that I provided on two 

separate occasions in 2014 and has not 

acknowledged that, according to DOE, out of 132 

workers interviewed only 7 stated that they had 

never worked in Area IV.
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At Santa Susana we cannot determine 

that a specific work group was not potentially 

exposed to radioactive materials during covered 

DOE operations. 

We cannot define potential radiation 

exposure conditions based on job titles or 

presumed work locations. And we cannot reliably 

identify work locations or track worker movements 

throughout the entire site.

All workers had accessibility to 

covered areas and SEC facilities, Area IV, Canoga 

and De Soto.

I thank you for your review of the 

information and your continued efforts on behalf 

of Santa Susana workers and I look forward to 

seeing you guys in Albuquerque. And that's it 

for my comments today.

MR. KATZ: Thank you, D'Lanie.

MS. BLAZE: Thank you.

MR. KATZ: Phil, are you still on?

CHAIR SCHOFIELD: Yes. I was 
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wondering if SC&A or NIOSH has any comments 

they'd like to make at this point.

MR. BARTON: This is Bob. Not 

initially. We certainly got the document this 

morning. It's responsive to our review. We'll 

be taking a look at that certainly. I guess 

that's all at this point.

MR. STIVER: This is John. I've got 

nothing to add to that. We're going to take a 

look at D'Lanie's report and her comments and do 

our evaluation on that.

DR. HUGHES: This is Lara. I'd just 

like to add that anything that is submitted 

including the EPA report, the interviews that Ms. 

Blaze has referred to, this is all reviewed by 

NIOSH. I'm not sure what avenue there would be 

for formal response because we typically respond 

in the form of -- like Evaluation Reports or 

anything, but anything that is submitted along 

with a petition, it is reviewed and is filed by 

NIOSH.
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There isn't always an avenue to 

provide a formal response.

Regarding the issue with the various 

areas, we're very well aware of it but at this 

point NIOSH does not have an avenue to resolve 

this in any way. This is not under our 

jurisdiction as far as I'm aware.

Regarding data-falsification issues 

that we consider for SEC petitions, this solely 

refers to dosimetry data that we use for our dose 

reconstruction. 

I can't really add anything else at 

this point.

CHAIR SCHOFIELD: Ted, do you have any 

comments?

Path Forward and/or Work Group SEC 

Recommendations 

MR. KATZ: No, I don't have any 

comments, but if other Work Group Members have 

any comments. And if not I guess we could talk 

about the upcoming Board meeting and the path 
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forward. You guys laid out several matters that 

are going to be followed through on.

CHAIR SCHOFIELD: Okay. Anybody else 

have any comments before we get into our 

suggestions for the meeting in Albuquerque?

MEMBER MUNN: No. This is Wanda. 

Nothing here.

MEMBER BEACH: I don't have anything 

else, Phil.

MEMBER ANDERSON: I don't either. 

This is Andy.

MEMBER BEACH: Other than maybe going 

over, I think the actions and the taskings to 

make sure we're clear on that.

Plans for ABRWH December 2017 Meeting 

MR. KATZ: I think we can do that. 

Those were really laid out pretty extensively and 

clearly and committed to follow ups for NIOSH. 

And then everyone is going to look at the new 

report that D'Lanie just submitted, the response 

to the SC&A review.
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So I think those three items are 

follow-up matters. For the Board meeting, it's 

quite clear that it's not time to make a 

recommendation to the Board, I would say.

You've all said yourselves in so many 

words because of these follow-up matters. So I 

think we need a presentation to summarize.

The Board will have the SC&A review 

and they will have D'Lanie's response to it as 

well. I've already sent that to the whole Board. 

I didn't just send that to the Work Group.

But then we need a presentation to 

bring everybody up to date with what was 

discussed, and put to bed, and not put to bed at 

this meeting and what the follow-up actions are.

And we're on a very short leash in 

terms of time to get that presentation done. 

So I would suggest the Work Group 

report, John, that I think -- John and I talked 

before this meeting last week about getting going 

on a presentation knowing that we would need some 
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sort of presentation. So that's under way, 

right, John?

MR. STIVER: Yes, it is. It's 

underway now.

MR. KATZ: So that presentation will 

probably come quite late because we are just 

getting rolling on it but we'll get that. We'll 

share that with the Work Group Members in draft 

assuming that it's in draft and then get posted 

and to D'Lanie as quickly as possible in advance 

of the meeting next week.

Does that make sense to everybody, the 

Work Group Members?

MEMBER MUNN: Yes.

CHAIR SCHOFIELD: It does to me.

MS. BLAZE: Can I make one more 

recommendation? Just something if it's possible.

I know NIOSH can question site 

boundaries when it's required and they can also 

change their position in ER which they did with 

Rocky Flats.
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Perhaps it's time to engage Department 

of Labor on some of these topics since we do have 

DOE contracts in Area I that they've been 

reviewing.

Maybe we need to talk to them about 

their position with data falsification because 

essentially when it happens, regardless at 

whatever phase of the claims process it occurred, 

it impacts our ability to accurately reconstruct 

radiation dose.

Maybe it's time we bring someone in 

from their end of things to get everybody at the 

same table. Just a thought.

MR. KATZ: Okay. Thank you, D'Lanie. 

I think that's something to pass on to Stu as 

well as to whether there should be some sort of 

meeting to discuss the matter further with DOL. 

DR. NETON: Ted, this is Jim. Who's 

going to provide the presentation? Is SC&A going 

to deliver it?

MR. KATZ: Jim, SC&A is going to draft 
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the presentation for the Board.

DR. NETON: Will Phil present it or 

John Stiver?

MR. KATZ: No, I think John Stiver 

probably will present it or Bob Barton, one or 

the other, or both. They'll both be at the 

meeting.

DR. NETON: Are you expecting any 

response from NIOSH at that meeting then or no?

MR. KATZ: Well, I certainly think you 

folks should contribute to just fleshing out the 

discussion and so on to the extent that that's 

needed.

I don't think you need to prepare a 

separate presentation unless you already have 

done that.

DR. NETON: No, no, I just want to 

make clear that we're not scheduled to do 

anything formal at the meeting.

MR. KATZ: Right, right. And for that 

matter, as background reading, I will 
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been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed and 

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redistribute Lara's presentation from the last 

meeting so they have that as background reading 

as well as of course they have the SEC Evaluation 

Report. 

Does that make sense, Jim?

DR. NETON: Yes, that's fine.

MR. KATZ: Okay. Phil?

CHAIR SCHOFIELD: I don't have 

anything else to add. I think we're pretty clear 

where we're going at this point.

MR. KATZ: If we just get a little 

email just confirming what it is we're doing. It 

doesn't really matter. It will be captured in 

the presentation. So I think we're all set.

DR. HUGHES: Ted, I usually send out 

a synopsis and whatever action items NIOSH has 

committed to.

MR. KATZ: Well, that's okay. If you 

want to do that that's great. And if you get 

that out quickly then Bob or John, can you -- 

(Telephonic interference)
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MR. STIVER: Excuse me, I didn't catch 

that.

MR. KATZ: Lara's going to send out a 

memo with what they've committed to. So I just 

was saying if she gets it out quickly then you 

guys can use that in your presentation. Not the 

memo but the description of the follow-up 

activities. 

MR. BARTON: That presentation is 

already in the works. Lara, what you provide 

will just be essentially the path forward slide.

MR. KATZ: Exactly. 

CHAIR SCHOFIELD: Well, if we don't 

have anything else to discuss, I think we're 

done.

Adjourn 

MR. KATZ: We can adjourn. Well, 

thank you everybody very much.

(Whereupon, the above-entitled matter 

went off the record at 12:29 p.m.)
This transcript of the Advisory Board on Radiation and Worker Health, Santa Susana Work Group, has 

been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed and 

certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader should be 

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COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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