1 

This transcript of the Advisory Board on Radiation and Worker Health, Procedures Subcommittee, 

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 Procedures Subcommittee for accuracy at this time. The reader should 

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

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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 

+ + + + +

SUBCOMMITTEE ON PROCEDURES REVIEW

+ + + + +

WEDNESDAY

OCTOBER 13, 2010

+ + + + +

 The Subcommittee convened in the 

Zurich Room of the Cincinnati Airport 

Marriott, 2395 Progress Drive, Hebron, 

Kentucky, at 9:00 a.m., Wanda Munn, Chair, 

presiding.

PRESENT:

WANDA I. MUNN, Chair

MICHAEL GIBSON, Member

MARK GRIFFON, Member*

RICHARD LEMEN, Member*

PAUL ZIEMER, Member
2 

This transcript of the Advisory Board on Radiation and Worker Health, Procedures Subcommittee, 

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 Procedures Subcommittee for accuracy at this time. The reader should 

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

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ALSO PRESENT:

TED KATZ, Designated Federal Official

NANCY ADAMS, NIOSH Contractor*

ISAF AL-NABULSI, DOE*

HANS BEHLING, SC&A*

ROBERT BURNS, ORAU*

STUART HINNEFELD, DCAS

JENNY LIN, HHS

JOHN MAURO, SC&A

STEPHEN MARSCHKE, SC&A

STEVE OSTROW, SC&A

MICHAEL RAFKY, HHS*

MUTTY SHARFI, ORAU*

ELYSE THOMAS, ORAU*

TOM TOMES, DCAS

BRANT ULSH, DCAS

*Participating via telephone
3 

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

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

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

2 9:00 a.m.

3 MR. KATZ: So good morning, 

4 everyone in the room and on the line. This is 

5 Ted Katz with the Advisory Board on Radiation 

6 and Worker Health. This is the Subcommittee 

7 on Procedures Review, and we are just getting 

8 started here. We will begin with roll call. 

9 Board Members in the room?

10 CHAIR MUNN: Wanda Munn, Board 

11 Member, Chair of the Subcommittee on 

12 Procedures.

13 MEMBER ZIEMER: Paul Ziemer, Board 

14 Member.

15 MR. KATZ: And Board Members on 

16 the line?

17 MEMBER LEMEN: Richard Lemen, 

18 Board Member.

19 CHAIR MUNN: Good morning, 

20 Richard.

21 MEMBER LEMEN: Good morning.
4 

This transcript of the Advisory Board on Radiation and Worker Health, Procedures Subcommittee, 

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1 MEMBER GRIFFON: Mark Griffon, 

2 Board Member.

3 CHAIR MUNN: Good morning, Mark.

4 MEMBER GRIFFON: Hi.

5 MR. KATZ: Okay, and do we have 

6 Bob Presley?

7 Okay, NIOSH, ORAU Team in the 

8 room.

9 MR. HINNEFELD: Stu Hinnefeld, 

10 DCAS.

11 DR. ULSH: Brant Ulsh with DCAS.

12 MR. KATZ: And on the line.

13 MS. THOMAS: Elyse Thomas with the 

14 ORAU Team.

15 MR. SHARFI: Mutty Sharfi, ORAU 

16 Team.

17 MR. KATZ: SC&A Team in the room.

18 DR. MAURO: John Mauro, SC&A.

19 MR. MARSCHKE: Steve Marschke, 

20 SC&A.

21 MR. KATZ: And anyone from SC&A on 
5 

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

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1 the line?

2 DR. BEHLING: Hans Behling.

3 CHAIR MUNN: Good morning, Hans.

4 MR. KATZ: Good morning.

5 DR. BEHLING: Good morning.

6 MR. KATZ: And now HHS, other 

7 federal officials, or contractors in the room.

8 MS. LIN: Jenny Lin with HHS.

9 MR. KATZ: And on the line.

10 MR. RAFKY: Michael Rafky, HHS.

11 MR. KATZ: Welcome, Michael.

12 DR. AL-NABULSI: Isaf Al-Nabulsi, 

13 DOE.

14 MR. KATZ: Hi, Isaf. Very good. 

15 And then are there any members of the public 

16 on the line? 

17 Okay. Remind everyone to mute 

18 your phones when you're not speaking on the 

19 phone. *6 if you don't have a mute button; *6 

20 to take it off. Wanda, it is your agenda.

21 CHAIR MUNN: Thank you so much, 
6 

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1 Ted. I trust that everyone who's on line -- 

2 hold on just a moment. We need to make sure 

3 that everyone online who needs a copy of the 

4 agenda has it, and if you have not checked 

5 your email, I sent a draft markup of some of 

6 the documents we will be dealing with this 

7 afternoon out very late last night.

8 Especially Richard and Mark, do 

9 you have all of those items?

10 MEMBER GRIFFON: I think I have 

11 everything, Wanda, yes.

12 CHAIR MUNN: All right.

13 MEMBER LEMEN: This is Richard. I 

14 do.

15 CHAIR MUNN: Good. All right.

16 We're going to try very hard to 

17 not take up as much of your time as we did 

18 during our last meeting dealing with the 

19 problems we have with our electronic database. 

20 But since we are still having some problems, 

21 and we have one of the database experts here 
7 

This transcript of the Advisory Board on Radiation and Worker Health, Procedures Subcommittee, 

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 

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1 today, we're going to ask if Steve will start 

2 by outlining some of the major problems we 

3 have with the document list as we currently 

4 have it, what we need to do that we have not 

5 been able to do so far. We don't intend to 

6 spend more than about a half-hour on that. 

7 But if you will bear with us and 

8 if you can bring that database up on your 

9 screens, perhaps you can follow along with us 

10 as we go through some of our major issues.

11 Steve?

12 MR. MARSCHKE: Okay. The first 

13 problem that we have been having is we don't 

14 know how to add -- right now, we have a list 

15 of 91 documents that are in the database, but 

16 it's not a complete list. There are documents 

17 that SC&A has reviewed or is in the process of 

18 reviewing which are not included in this 91. 

19 And we don't know how to add those documents 

20 or if those documents can be added to the 

21 database. So maybe it's a problem with us not 
8 

This transcript of the Advisory Board on Radiation and Worker Health, Procedures Subcommittee, 

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

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certified by the Chair of the Procedures Subcommittee for accuracy at this time. The reader should 

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1 being familiar with the database or 

2 knowledgeable in the database. Right now, we 

3 don't know how to add those documents.

4 Examples are what would be PER 

5 documents, IG documents, report documents, 

6 which are not available to SC&A to add our 

7 issues that we have associated with them or 

8 not.

9 Now one of the interesting facts 

10 is if you click on the SC&A Finding Status 

11 Report, some of these documents do show up in 

12 this one page. Like IGs, PERs, they do show 

13 up on this particular page. But then when you 

14 go back to the main page of the report here 

15 and you do a document search for IGs, for 

16 example, and you go look for IGs, they don't 

17 show up. They don't show up here in the list. 

18 So I don't know what is going on there.

19 And the same is true with the 

20 PERs. You saw the PERs that were on that one 

21 table. But when you look for PERs on this 
9 

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

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1 main list, PERs don't show up.

2 So we would like to be able to 

3 access these other documents because in some 

4 cases we have issues on these documents, and 

5 we would like to add those issues to the 

6 database, in particular, PER-009, PER-0012, 

7 and all the ones that you saw in that table 

8 that were existing issues.

9 MEMBER ZIEMER: And the flip side 

10 of that, you are getting some documents that 

11 don't appear to be PERs. So why are those 

12 showing up?

13 MR. MARSCHKE: When we did this, I 

14 don't know what it is searching for when you 

15 do the document search. It could be searching 

16 into the text or something. I don't know --

17 MEMBER ZIEMER: Why those showed 

18 up?

19 MR. MARSCHKE: -- why these show 

20 up.

21 MEMBER ZIEMER: Maybe they mention 
10 

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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 

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1 PER.

2 MR. MARSCHKE: Maybe they mention 

3 PER somewhere in the text or something 

4 someplace along the line or what. That I 

5 don't know. But, usually, when you put in 

6 document search and you put in something like 

7 OTIB up here --

8 MEMBER ZIEMER: Is it really going 

9 into the text when it does that?

10 MR. MARSCHKE: I have no idea. I 

11 don't know.

12 MR. TOMES: It is not going into 

13 the text of the actual document. It is going 

14 into the text of the details of the record. 

15 So for the first one, the OTIB-70, if you 

16 clicked inside there and you looked at the 

17 details for that, that's where it's searching. 

18 It's not actually searching through the 

19 actual OTIB itself.

20 MEMBER ZIEMER: Right. Yes.

21 MR. TOMES: In here, there's going 
11 

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

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1 to be periods. Yes, periods is why PER shows 

2 on that one. I mean it's in the document 

3 title.

4 MEMBER ZIEMER: So it found that, 

5 but it didn't find the actual document 

6 identity?

7 MR. TOMES: Well, it doesn't look 

8 like we're searching on document number.

9 MR. MARSCHKE: You are searching 

10 on document -- well, that I don't know. 

11 Because when you look in an OTIB, when you do 

12 a document search on OTIB, all the OTIBs show 

13 up. It must search on the number and the 

14 title.

15 MR. HINNEFELD: If you would put 

16 your document status filter on completed 

17 documents, the document filter is all the way 

18 to the left, and there's a dropdown. Then, if 

19 you filter on document type, document type 

20 filter, which is the next one over, and put 

21 implementation guides --
12 

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1 MR. TOMES: Right, they're not 

2 there.

3 MR. HINNEFELD: I guess I've got 

4 different rights or something.

5 MR. TOMES: Yes.

6 CHAIR MUNN: And if you click on 

7 Add New Document, what happens?

8 MR. MARSCHKE: Add New Document, 

9 I'm afraid to touch that because, basically, 

10 it's something that it puts me in as -- it's a 

11 brand new document. I'm not looking for a 

12 brand new document. I'm looking for an OTIB 

13 or a PER-009 or IG-4 or something --

14 CHAIR MUNN: Yes.

15 MR. MARSCHKE: -- an existing 

16 document. It's not really a new document. 

17 You know, I'm not creating a new document 

18 here.

19 CHAIR MUNN: No.

20 MR. MARSCHKE: I'm just looking to 

21 add one, an existing document, and make it 
13 

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1 available to this database.

2 MR. TOMES: Okay. But you would 

3 have to add it to the database.

4 MR. MARSCHKE: I don't know. Is 

5 that what this is doing?

6 MR. TOMES: Because there's a 

7 difference between the documents and the 

8 database. So PER-009 does exist as a 

9 document, but if it doesn't exist in the 

10 database - 

11 MR. MARSCHKE: So is this adding 

12 it to the database, or is this adding a new 

13 document in total?

14 MR. TOMES: This does nothing with 

15 documents.

16 MR. MARSCHKE: Oh, okay.

17 MR. TOMES: This is all just 

18 database entries that allows the tracking of 

19 the documents.

20 MR. MARSCHKE: Okay. So I can 

21 put, if I put in PER-009 here --
14 

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1 MR. TOMES: Yes.

2 DR. MAURO: Do I understand what 

3 you're saying? So our review of PER-009, 

4 which has been completed and delivered --

5 MR. TOMES: Right.

6 DR. MAURO: -- this is the way we 

7 would load that?

8 MR. TOMES: This is the way you 

9 would load it in.

10 MR. MARSCHKE: So I could load it 

11 in here, and then I'd have to type in the 

12 title and every --

13 MR. HINNEFELD: For consistency, 

14 those are OCAS.

15 MR. MARSCHKE: OCAS? Okay. Maybe 

16 that's why I can't find it. OCAS PER-009. 

17 Will it go out and find, does it --

18 MR. TOMES: It's all based on what 

19 you enter in.

20 MR. MARSCHKE: What I enter in?

21 MR. TOMES: Yes.
15 

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

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1 MR. MARSCHKE: Okay. So I don't 

2 know what -- I would have to get the title and 

3 everything from someplace. Okay, we can use 

4 that, I guess.

5 MR. KATZ: Is there any way to 

6 have a complete document inventory on a 

7 dropdown and then add things, find them and 

8 add them, as opposed to having to remember all 

9 those details?

10 MR. TOMES: Well, we don't know 

11 what the documents are. I mean because --

12 MR. KATZ: Oh, I see.

13 MR. TOMES: -- if we don't create 

14 the documents -- this is just tracking the 

15 documents that have been created. So this is 

16 what that's going to eventually be.

17 MR. HINNEFELD: The complication 

18 there is that although this system is designed 

19 to be the system by which we begin and prepare 

20 a document de novo, it's not been utilized 

21 that way.
16 

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1 MR. TOMES: Right. I understand.

2 MR. HINNEFELD: And so there are a 

3 lot of documents because of that that were 

4 generated outside this tracking system that 

5 have not been entered.

6 MR. TOMES: Yes.

7 MR. HINNEFELD: Now we're going to 

8 have a little bit of a complication here 

9 because this is designed to deal with all of 

10 our groups and subcommittees, as well as to 

11 deal with our internal document preparation. 

12 So various users have different rights in 

13 terms of what they see when they bring this 

14 thing up.

15 Part of this might be some of that 

16 because I can see the IGs in the findings 

17 because I've got like -- so I can see them. 

18 So before we go too far with adding new today, 

19 I think we need to have our design meeting and 

20 sort out a few more questions like that.

21 You know, our design so far has 
17 

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1 been my best estimates on who would do what, 

2 who would enter what, how many people need 

3 write authority, how many people need read 

4 authority.

5 So this Work Group -- and there 

6 might be a good -- well, I'll worry about 

7 design at the design meeting. There are many 

8 people who will be in multiple Work Groups and 

9 therefore should be able to specify which Work 

10 Group are they going in under so that they can 

11 see that Work Group's stuff. So anyway, there 

12 are some things to deal with there.

13 MR. TOMES: Ideally, what's going 

14 to happen is if PER-009 started with this, it 

15 would be created, it would go through our 

16 internal reviews. Once it got approved, then 

17 it would be available to the Board and to the 

18 Work Group.

19 MR. HINNEFELD: Available to the 

20 Work Group to review, and that review would 

21 move it into this Work Group's section of the 
18 

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1 database.

2 MR. TOMES: But we're kind of 

3 hopping in the middle here.

4 MR. HINNEFELD: Yes.

5 MR. TOMES: And so if a document 

6 doesn't exist, it just needs to get added.

7 MR. MARSCHKE: Well, the document 

8 doesn't exist in this tracking system, but it 

9 does exist --

10 MR. TOMES: Right. No. Right. 

11 As far as this tracking system is concerned, 

12 it doesn't exist.

13 MR. MARSCHKE: It does not exist.

14 DR. MAURO: Well, that's a 

15 convenience to be able to immediately access 

16 the original document that we reviewed.

17 CHAIR MUNN: Yes, that's great. 

18 That's marvelous.

19 DR. MAURO: That's wonderful, but 

20 more importantly, though, is being able to 

21 access the tracking of the review process for 
19 

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1 that document.

2 CHAIR MUNN: Yes.

3 DR. MAURO: And that's where we're 

4 struggling.

5 CHAIR MUNN: And there are 

6 interesting glitches. For example, Steve just 

7 was able to pull up IG documents on his list, 

8 but mine doesn't. And it's probably something 

9 I'm doing wrong.

10 MR. MARSCHKE: The IG documents?

11 CHAIR MUNN: Yes.

12 MR. MARSCHKE: If you go up here 

13 and click on this reports, the only way I can 

14 get them is click on this reports. Then you 

15 have this SC&A Finding Status Report. If you 

16 click on that, that is how I can see the IG 

17 documents. I see they are there in some form, 

18 but I can't access them from the other menu.

19 CHAIR MUNN: Yes, and we should be 

20 able to.

21 MR. MARSCHKE: And we should be 
20 

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1 able to.

2 CHAIR MUNN: Absolutely. So are 

3 we going to be able to work with this at all 

4 today?

5 MR. MARSCHKE: Yes. Well, we can 

6 work with it the way we have -- I think we can 

7 work with it.

8 Now the second problem that I was 

9 having last week was kind of a new issue. I 

10 was not able to add responses. Now I have 

11 been told that that's been corrected.

12 What I was trying to do, after the 

13 last meeting, we made a lot of status changes 

14 to OTIB-70 issues, and I was supposed to go 

15 back in and add a response explaining why we 

16 made these changes. We made all these changes 

17 to in progress. And I was supposed to add a 

18 response stating that, to the effect that, in 

19 July, that the status was changed at the July 

20 26th meeting by the Subcommittee. And when I 

21 tried to do that, I was getting error 
21 

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1 messages.

2 So let's just give it a try now.

3 CHAIR MUNN: Well, yes, let's give 

4 it a try with the first item that we're going 

5 to have under discussion anyhow, the TIB-14 

6 review status. I can get to TIB-14 on the 

7 document title, and then if I check the 

8 findings, or active findings, whichever the 

9 case may be -- active findings, I suppose --

10 if we click on active findings, then what I 

11 get is the document title and Board comments, 

12 the document history.

13 DR. MAURO: So right now we're 

14 functional, at least with respect to that.

15 MR. MARSCHKE: I can do that, yes.

16 CHAIR MUNN: That part is 

17 functional.

18 DR. MAURO: Good. Good.

19 MR. MARSCHKE: Now Wanda has gone 

20 to TIB-14?

21 CHAIR MUNN: Yes. Then I went to 
22 

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1 the active findings. And now I'm looking down 

2 in document history, where we have a lot of 

3 ORAU and SC&A activities, comments, actions.

4 And the last thing I see is an 

5 SC&A response saying they're going to review 

6 the TBD to ensure the issue has been addressed 

7 and the status has been changed to in 

8 progress.

9 So this is this status -- where do 

10 I see that this status is now in progress?

11 MR. MARSCHKE: Under the findings. 

12 Click on the Board Review Comments admin. 

13 You see the status, in progress.

14 CHAIR MUNN: Here we are, yes. 

15 Okay.

16 MR. MARSCHKE: That was one of the 

17 other things that we had talked about at one 

18 of the other meetings, was getting rid of this 

19 screen, basically jumping immediately from the 

20 main menu, jumping immediately from this menu 

21 to the issues menu, just cutting out this 
23 

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1 screen here because it's of no interest to 

2 this --

3 MR. TOMES: Right. Right. That 

4 is still on our list of enhancements we need 

5 to -- at the last meeting in July, we walked 

6 out with about 18 different features and 

7 requests. We currently have five that we 

8 still need to enhance, and those are more 

9 long-term, more time-intensive.

10 MR. MARSCHKE: What we would like 

11 to be able to do, again, the way SC&A works is 

12 I'm in charge, basically, of this database. 

13 And we have other SC&A scientists who are 

14 reviewing the documents, reviewing the 

15 responses, and finding the issues and finding 

16 the findings, and so on and so forth.

17 So when NIOSH gives us a response, 

18 I kind of funnel it back to the people who are 

19 actually doing the reviews, and they look it 

20 over and see whether or not they agree with 

21 the response and then make a recommendation as 
24 

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1 to the change. Then what I would do is I 

2 would enter that information into the 

3 database.

4 But not all these people who are 

5 doing the reviews have access to this 

6 database. They don't know how to, you know, 

7 some of them probably don't even know it 

8 exists.

9 So what we would like to be able 

10 to do is be able to look for a particular 

11 document, TIB-14 in this example, we would 

12 like to be able to take and print out all the 

13 issues and the history to all the issues, 

14 maybe from this screen here. Basically, we 

15 could have a button here that says, create a 

16 PDF file that has --

17 MR. TOMES: Is there a reason why 

18 we can't give them read-only access to the 

19 database? That way, they have the most 

20 current information on the responses or 

21 anything with that document when they are on 
25 

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1 the review. Because as soon as you print 

2 something out, it becomes outdated. There 

3 could be a new response added by somebody.

4 MR. MARSCHKE: Well, again, we 

5 have a lot of people who are not computer 

6 really savvy. It's like I guess we could do 

7 it; we could try it, but --

8 MR. KATZ: There needs to be some 

9 capacity, I think, in any event because I mean 

10 not only they may have some people that are 

11 not computer savvy, they also may have some 

12 people that they may not be able to put 

13 through the whole clearance process, if 

14 they're not cleared. There are a lot of 

15 people that are not through the whole -- and 

16 that clearance process is enormous, as you 

17 know, to get individuals through to have IT 

18 rights.

19 So if this can be done, it would 

20 be much easier than clearing people --

21 MR. MARSCHKE: There's also other 
26 

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1 purposes why we probably need, from time to 

2 time we will need to get hard copies off of 

3 this thing.

4 DR. MAURO: Well, do both. I 

5 mean, can we do both?

6 MR. MARSCHKE: Well, yes, if we 

7 can get hard copies, then we can do both.

8 DR. MAURO: And electronic.

9 MR. MARSCHKE: If they want it, 

10 right.

11 DR. MAURO: Yes, it would make 

12 life easier for you if you could 

13 electronically say --

14 MR. KATZ: Oh, it's better, yes.

15 MR. MARSCHKE: Electronic PDF is 

16 the way --

17 MR. KATZ: Yes, I mean that would 

18 be perfect, right?

19 MR. MARSCHKE: That's what we used 

20 to do with the other database. I would send 

21 it off to them, and they would make a 
27 

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1 response. Then, basically, I could just 

2 block/copy/paste their response right into the 

3 database.

4 CHAIR MUNN: Yes, that served us 

5 very well for a number of months.

6 MR. MARSCHKE: Yes, it served us 

7 very well. So if we could just get back to 

8 that?

9 Because right now what we had to 

10 do was I had to go in here and I had to pull 

11 up each one of these issues, for example, and 

12 block/copy/paste each one of these issues into 

13 a Word file, and then send the Word file off 

14 to Joyce. So it was just really cumbersome.

15 So we need to have some way to 

16 take all the information which is on this 

17 screen, but not only for Issue 1, but also 

18 for --

19 CHAIR MUNN: Each of the other 

20 issues.

21 MR. MARSCHKE: -- each of the 
28 

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1 other issues, all the issues associated with 

2 this particular document.

3 One of the complaints was we 

4 didn't have finding numbers before, but now I 

5 see we do have finding numbers associated with 

6 each one.

7 CHAIR MUNN: That's good.

8 MR. MARSCHKE: So that's good. 

9 We've got the finding numbers over here on the 

10 lefthand side. So that's good.

11 CHAIR MUNN: Okay. You think 

12 we're pretty firm on what needs to be done 

13 that hasn't been done yet, right? So with any 

14 luck at all, Steve, you can get with these 

15 folks, and can you stick around tomorrow and 

16 do that with them tomorrow?

17 MR. MARSCHKE: I have a commitment 

18 tomorrow right now. I don't know if we want 

19 to --

20 CHAIR MUNN: Well, a lot of other 

21 folks are busy tomorrow, too. But if you can 
29 

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1 work out an early date with Brant or others --

2 MR. MARSCHKE: It does seem like 

3 they have been making some -- I mean, to be 

4 honest with you, perhaps the reason why I 

5 wasn't able to update responses last week was 

6 because they were in the midst of revising the 

7 database.

8 CHAIR MUNN: Yes.

9 MR. MARSCHKE: When I look at it 

10 right now, I can't see. The last time I 

11 looked at it, there were no finding numbers, 

12 and now there are finding numbers, and so on 

13 and so forth. So I would like to really go 

14 back and play with the version that is up here 

15 now to see exactly the enhancements that have 

16 been made to it since the last meeting.

17 CHAIR MUNN: Well, we can give it 

18 another shot today to find out whether it's 

19 going to be entirely impossible to deal with 

20 or if we're going to get most of the detail 

21 that we need worked out today. We will try 
30 

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1 it.

2 MR. MARSCHKE: The biggest thing 

3 was if we can know how to add documents -- and 

4 we have just been following the instructions 

5 that were just given -- we can add documents. 

6 And then the other thing would be to be able 

7 to make some kind of a hard copy or a PDF copy 

8 of the information that is contained within 

9 the database.

10 CHAIR MUNN: Right.

11 MR. MARSCHKE: Those are really 

12 the two major things that are hanging up at 

13 this point.

14 DR. MAURO: How about live-time 

15 editing, like the way we used to do where we 

16 would go into, okay, we're up to Issue No. 1 

17 on OTIB-14 --

18 MR. MARSCHKE: Yes, I don't know 

19 if they have changed that. Basically, one of 

20 the questions that John is asking is maybe 

21 some of these, like maybe, okay, we find that 
31 

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1 we have some typos or something in here 

2 someplace, and we don't want to add a new 

3 response. We just want to go in and edit this 

4 response and say, okay, instead of the 

5 reference -- we've got the wrong document 

6 number in here. We just want to go back here 

7 and, instead of 5, it should be a 4, or 

8 something like that. So we don't really want 

9 to add a new response, but we just want to 

10 edit an existing response. That was one of 

11 the things that was also brought up.

12 CHAIR MUNN: Yes. We couldn't do 

13 that last time.

14 MR. MARSCHKE: Yes, every time you 

15 clicked on it, basically, you got a new --

16 CHAIR MUNN: A new entry.

17 MR. MARSCHKE: -- new entry.

18 CHAIR MUNN: So we have several 

19 double entries which are essentially the same 

20 thing.

21 MR. MARSCHKE: Right.
32 

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1 MR. TOMES: That is on our list of 

2 stuff to do from last time. It's assigned to 

3 be more intensive, more commitment.

4 MR. MARSCHKE: And I guess maybe 

5 the thing is that if we know that the list 

6 exists --

7 MR. TOMES: Right.

8 MR. MARSCHKE: -- and it's being 

9 worked off, then that would go a long way 

10 towards resolving our concerns.

11 MR. TOMES: Right.

12 MR. KATZ: So Tom said that there 

13 were 18 enhancements that came out last 

14 meeting, and all but five are done. So maybe, 

15 Tom, after this meeting, if you could just 

16 send Steve the list of the five that are 

17 remaining, then he'll know that those are 

18 already sort of on the docket waiting to get 

19 done. And then if he has other issues as he 

20 goes when he's home and he's working through 

21 them, he will identify those, and then he will 
33 

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1 know whether he needs to come and what there 

2 will be to get --

3 DR. MAURO: Yes, let's hold off on 

4 the face-to-face until you regroup.

5 MR. MARSCHKE: For the record, Tom 

6 has provided me with a list of the short-term 

7 changes that have already been done and the 

8 longer-term changes which are still in the 

9 works.

10 MR. KATZ: Okay. Okay. And if 

11 there's very little, of course, he could deal 

12 with it on the phone.

13 MR. MARSCHKE: Right.

14 DR. MAURO: I've got a question. 

15 Now in addition to the functionality to 

16 support this meeting and, of course, the 

17 follow-up activities that are necessary to 

18 keep things current, we will be talking about 

19 it this afternoon, about these two-pagers.

20 CHAIR MUNN: Yes.

21 DR. MAURO: The two-pagers require 
34 

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1 us to download the entire file for a given 

2 PROC review. Let's say there's an OTIB or a 

3 PROC or a PER that has a history where the 

4 various issues that are associated with it 

5 were discussed over four or five Work Group 

6 meetings or Subcommittee meetings. All of 

7 that has to be captured and handed over to the 

8 person who is going to have responsibility to 

9 write a two-pager so the person could 

10 understand the entire history of it and how it 

11 matured over perhaps a year.

12 CHAIR MUNN: Or more.

13 DR. MAURO: Or more. And then 

14 capture it in two pages. So right now, how 

15 were you able to do the first five we did? I 

16 mean, what was the mechanics? I know you 

17 ended up getting it done, but was it a big --

18 MR. MARSCHKE: We went back to the 

19 old database.

20 DR. MAURO: Oh, okay.

21 MR. MARSCHKE: We did a dump of 
35 

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1 the old database.

2 DR. MAURO: Yes, we were lucky 

3 enough that we had that.

4 MR. MARSCHKE: Well, it was, 

5 basically, so what we're working from on the 

6 two-pagers is not necessarily a complete list 

7 of all the procedures that have been -- have 

8 all their statuses --

9 DR. MAURO: So we got lucky. It 

10 just so happens the five we picked --

11 MR. MARSCHKE: We have enough that 

12 we can --

13 DR. MAURO: Yes.

14 MR. MARSCHKE: Well, we picked the 

15 five that were already on that list.

16 DR. MAURO: I got it. Okay. It 

17 made --

18 MR. MARSCHKE: So we made our own 

19 luck.

20 DR. MAURO: Okay.

21 MR. MARSCHKE: But what we want to 
36 

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1 do is when we get to this screen here, we want 

2 to be able to dump not only this screen, but 

3 what is behind this screen to a PDF file.

4 MR. TOMES: Right. That's what 

5 you were asking for.

6 MR. MARSCHKE: That's the same as 

7 what we were asking before.

8 MR. TOMES: All right.

9 MR. MARSCHKE: But we just want to 

10 be able to -- when I say what's behind this 

11 screen, John, it's when you click on this OTIB 

12 finding No. 1, basically the whole history is 

13 behind this page.

14 DR. MAURO: Oh, that's beautiful.

15 MR. MARSCHKE: So when he prints 

16 out that previous screen and everything that 

17 is behind it, you will print out all this as 

18 well. And this has all the history from when 

19 it was first entered back in 2007 up until 

20 July 26th of 2010. So the whole history is 

21 here.
37 

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1 DR. MAURO: We're in the red zone. 

2 You know, we're getting there.

3 CHAIR MUNN: Yes, we're close. 

4 That's good. All right.

5 MR. HINNEFELD: With respect to 

6 the design meeting, my schedule until the 

7 Board meeting gives me the following two 

8 Mondays, and the 25th is better than the 18th, 

9 but I can do the 18th, and Election Day. 

10 Those are the days I have available for design 

11 meetings. They're not Friday between now and 

12 the Board.

13 MR. KATZ: Which ones?

14 MR. HINNEFELD: The following two 

15 Mondays, next week, Monday, it would be that 

16 and the next Monday, and Election Day.

17 MR. KATZ: And Election Day is one 

18 of the days that Dr. Melius is looking at for 

19 one of his two Work Groups for the 

20 teleconferences.

21 CHAIR MUNN: Good.
38 

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1 MR. KATZ: And for the record, 

2 Mike Gibson has joined us.

3 CHAIR MUNN: Welcome, Mike.

4 MEMBER GIBSON: Thanks.

5 CHAIR MUNN: So we're not going to 

6 have any problem adding responses today and 

7 changing status today? Those are the two 

8 things --

9 MR. MARSCHKE: It doesn't look 

10 like we're going to have any problem doing 

11 that.

12 CHAIR MUNN: All right.

13 MR. MARSCHKE: I guess the only

14 other thing, this is a real simple thing. The 

15 defaults for showing the statuses is all 

16 except closed. I think we would like -- I 

17 personally would like to have it all messages, 

18 so we show the complete list.

19 CHAIR MUNN: Yes.

20 MR. MARSCHKE: I know that's a 

21 very simple fix to do. Because sometimes if 
39 

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1 we close, if we have 10 issues and we close 

2 number 10, when we're looking at the screen, 

3 we don't know that there were 10 issues and 

4 that one of them has been closed.

5 It's a little easier now that we 

6 do have the finding numbers to identify which 

7 ones. If we have skips in the finding 

8 numbers, then we can assume that the skips are 

9 due to the fact that something closed. But I 

10 think it is just better if we just print out 

11 all the messages and not try to edit them, not 

12 try to anticipate any edits for the user.

13 CHAIR MUNN: Yes, I agree. We can 

14 always filter it.

15 MR. TOMES: Are you talking the 

16 interface --

17 MR. MARSCHKE: Both, both.

18 MR. TOMES: Okay.

19 MR. MARSCHKE: Definitely the 

20 printout, definitely. 

21 MR. TOMES: Right, the printout we 
40 

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1 would want to filter it.

2 MR. MARSCHKE: Definitely we're 

3 talking both.

4 CHAIR MUNN: All right. I think 

5 those are the biggies. Anybody else have any 

6 major griefs that we need to talk to before we 

7 move into our real agenda?

8 (No response.)

9 If not, then with great thanks, we 

10 appreciate your coming. Thanks.

11 MR. KATZ: Thank you, Tom.

12 MR. TOMES: You're welcome. 

13 Anytime.

14 CHAIR MUNN: And we'll just move 

15 on from there. Since we're already on 

16 OTIB-14, we can stay on OTIB-14. As my list 

17 has it, it's SC&A's ball game, right?

18 Where are we with OTIB-14?

19 MR. MARSCHKE: Basically, there 

20 are three issues that still need to be 

21 addressed, is that correct?
41 

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1 CHAIR MUNN: That's what the list 

2 says.

3 MR. MARSCHKE: And we sent it to 

4 Joyce. I sent it to Joyce very recently. So 

5 I was a little late in getting it to Joyce. 

6 She did take a look at it, but we still don't 

7 have a formal response to NIOSH's latest 

8 response.

9 Basically, she said that some of 

10 the information requested was included -- the 

11 intake rates from 1988 to 2005 were included 

12 in TKBS 11-5. NIOSH is using the 95th 

13 percentile for all periods, including 1988 to 

14 2005, and NIOSH is using the americium lung 

15 data to calculate lung doses.

16 So it looks like NIOSH is doing 

17 some good things, in her opinion. Now she 

18 hasn't made any recommendations as to whether 

19 or not she feels that these good things are 

20 enough to close the issues or she still has 

21 additional problems with the issues. So right 
42 

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1 now, SC&A needs to provide the Subcommittee 

2 with our recommendation as to what the status 

3 changes, if any, should be to these three 

4 TIB-14 issues.

5 CHAIR MUNN: So, essentially, it 

6 remains SC&A's action, right?

7 MR. MARSCHKE: Right.

8 MS. THOMAS: Yes, and this is 

9 Elyse.

10 I just wanted to mention, while 

11 we're on this particular document, that from 

12 the last meeting I was supposed to add a 

13 statement as to why the document was 

14 cancelled. As soon as I get edit capability, 

15 I'll be able to do that. So that's still on 

16 the list of things that need to be done for 

17 this document.

18 CHAIR MUNN: Thank you, Elyse.

19 MS. THOMAS: Okay.

20 CHAIR MUNN: Anyone else have 

21 anything to say about TIB-14?
43 

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1 (No response.)

2 All right, then RPRT-0044, issues 

3 and adding it to the database, SC&A. 

4 MR. MARSCHKE: Well, we have not 

5 added it to the database because, as we spoke 

6 earlier, we didn't know how to add documents.

7 CHAIR MUNN: Right.

8 MR. MARSCHKE: And report 

9 documents were one of the documents we did not 

10 know how to add. When I get home, tomorrow I 

11 will try to add Report 44 and let you know my 

12 success or not.

13 Then if we are able to add it, 

14 then we -- well, the flip side of this is we 

15 have not officially sent out our review of 

16 Report 44. We have a version of it here which 

17 is still basically not quite in the final SC&A 

18 format form. So it's not Subcommittee-ready 

19 at this point.

20 We kind of, I guess, it slipped 

21 through the cracks sometime in August. We 
44 

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1 were working on it up through August, and then 

2 the last version we have of it was an internal 

3 working version that came out in August, and 

4 it has not been formally issued.

5 We have to go through. Again, if 

6 you scroll through here, you will see that 

7 there are still some editorial comments in 

8 here that have to be resolved internally 

9 within SC&A before it can go out.

10 So the status of Report 44 is it's 

11 still in internal SC&A review. We do have, if 

12 you go up to the beginning, about four issues, 

13 four findings that will eventually make its 

14 way to the Subcommittee associated with it.

15 Now this is -- Report 44 is kind 

16 of being reviewed, a dual review, if you will. 

17 It's being reviewed not only for the 

18 Procedures Subcommittee, but also for the SRS 

19 Work Group.

20 And I'm not sure -- we would have 

21 to go through and look at these findings and 
45 

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1 see. Some of them may be appropriate for this 

2 Subcommittee, may be more geared towards this 

3 Subcommittee, which would be more generic-type 

4 findings. Others of the findings may be more 

5 specific for the Savannah River Work Group.

6 So I'm not sure how the 

7 Subcommittee and the Work Group want to handle 

8 that.

9 CHAIR MUNN: Well, in the past, 

10 lacking any clear definition, and before we 

11 sort of have gotten ourselves to the position 

12 where we felt we knew how we were going to 

13 handle these things, what we have done is had 

14 the document come here, and then the decision 

15 is made here to transfer specific findings 

16 that are applicable to the Work Group to the 

17 Work Group. That would seem to be the logical 

18 process to me because that immediately puts 

19 the entire report on the database and gives us 

20 the tracking capability that we need.

21 Does anyone see it differently 
46 

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1 than that? That seems the logical process to 

2 me.

3 MR. MARSCHKE: I agree with that, 

4 Wanda. The only thing was, the review of 44 

5 was assigned twice, to SC&A twice. Let's put 

6 it that way. But I think that what you 

7 propose is a good way to resolve it.

8 CHAIR MUNN: We can make sure we 

9 have everything that we need in the tracking 

10 system, if we do it that way.

11 MR. MARSCHKE: Right.

12 CHAIR MUNN: Okay, we'll just 

13 carry that over. So I'm assuming that by the 

14 time we have our next meeting, probably what 

15 -- October. We're not going to do anything in 

16 November for sure, or we certainly won't meet 

17 again before possible early December, but, 

18 more likely, early January.

19 Can we make the assumption we will 

20 probably have an addition to the database by 

21 then with this?
47 

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1 MR. MARSCHKE: We will -- yes.

2 CHAIR MUNN: Reasonable 

3 commitment?

4 MR. MARSCHKE: A reasonable 

5 commitment. I am appalled that we haven't 

6 gotten it out already. Let's put it that way. 

7 I would have thought we could have gotten 

8 this out by this time.

9 DR. MAURO: There's a two-step 

10 process, Joyce and then Harry.

11 MR. MARSCHKE: Joyce and then 

12 Harry have been working on this. And again, 

13 Arjun has been kind of also involved because 

14 of the involvement with the Savannah River 

15 Site.

16 DR. MAURO: Yes, it's unfortunate 

17 they got confounded. The reality is I see 

18 certainly a standalone document has universal 

19 applicability and it should come here, of 

20 course, then to be dealt with on a case-by21 case basis separately, like Savannah River. 
48 

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1 So I could see the break being clean, even 

2 though the same people will be involved. So, 

3 I mean, I don't see solving both problems 

4 before we come here is necessary.

5 CHAIR MUNN: Anything else on 44?

6 If not, let's move on to the 

7 status and action plan for open items report, 

8 NIOSH.

9 MR. HINNEFELD: Well, of course, 

10 we saw this agenda for the first time a couple 

11 of days ago. Were we planning to do this? 

12 Did we know we were going to do it? Because I 

13 didn't know I was going to do it.

14 CHAIR MUNN: It wasn't on your 

15 action list? It was a carryover from last 

16 time.

17 MR. HINNEFELD: Well, I'm looking 

18 at my scribe over there.

19 Now you're looking for here -- are 

20 you talking about open items -- do you mean 

21 items we have not yet provided any response 
49 

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1 to?

2 CHAIR MUNN: We had quite a 

3 discussion at our last meeting about the fact 

4 that we have a long list of items on our 

5 database which are open, meaning we have never 

6 touched them. We have never even brought them 

7 up for conversation.

8 And at that time, what we were 

9 hearing from NIOSH, if my memory serves me 

10 correctly, is that one of the reasons there 

11 are so many of these open items is that a 

12 significant number of the documents that are

13 involved were early documents that are no 

14 longer in use, and you felt the time had been 

15 better served by addressing the current 

16 documents and current issues, rather than 

17 documents which have been closed or something 

18 of that sort.

19 But what we're looking for is a 

20 way to get those items that are shown as open, 

21 which they are, into a closed position, so 
50 

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1 that we can essentially get them off of our --

2 list of what's open.

3 The fact that they are all out 

4 there is misleading to the casual observer. 

5 Someone who hasn't followed the workings of 

6 the Subcommittee would have the mistaken 

7 notion that we're not working on things we 

8 need to work on. That's really what it boils 

9 down to.

10 So we had, I thought, received a 

11 tentative verbal commitment from NIOSH to take 

12 a look at those, see if many of them could 

13 just simply be closed by a straightforward 

14 statement and dispose of them.

15 If reference needs to be made to 

16 other later documents which cover this and, 

17 therefore, the finding is no longer pertinent, 

18 then that needs to be included in the 

19 database, so that we can shift the status of 

20 those items.

21 DR. ULSH: It seems to me that 
51 

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1 what you're asking for is a two-step process, 

2 where we go through and look at the open items 

3 and identify those that pertain to outdated 

4 documents. That's step one.

5 And then to look at those ones 

6 that have been identified and say either this 

7 is no longer a relevant finding or this 

8 finding now applies to a new document, and 

9 here's our response to it.

10 CHAIR MUNN: That's correct. And 

11 of course, not all of the open items to which 

12 we refer are open items because they have been 

13 superseded. There are viable issues still on 

14 the table, some of which are listed as open 

15 items, and we have not addressed them at all. 

16 So perhaps it is a three-step process.

17 MR. HINNEFELD: Yes, the other 

18 category of open items can be items where an 

19 initial response has been provided in the 

20 database, but the Subcommittee hasn't talked 

21 about it yet.
52 

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1 MR. MARSCHKE: Definitely. I 

2 think that was one of the things that was 

3 brought up at the last meeting.

4 MR. HINNEFELD: That could be a 

5 category. Well, I don't know how many, if 

6 there are any of those or not, but that could 

7 happen because the status doesn't change when 

8 we enter the initial response. The status 

9 changes when the Subcommittee talks about it.

10 So that is our third thing, is to 

11 come up with that universe of things, because, 

12 then, those are things that can be talked 

13 about, essentially, right away. We would have 

14 to identify what they are. SC&A could look at 

15 the initial responses and have some thought 

16 about them for the Board or for that 

17 Subcommittee.

18 MR. MARSCHKE: Now the database 

19 may be helpful in you trying to go through, at 

20 least the first step of this response because 

21 you can look. If you go to this SC&A Findings 
53 

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1 Status Report, you can see, basically, this 

2 column here is the open column. And you can 

3 see we have 62 open issues. And if you just 

4 kind of scroll up, you can see OTIB-54 has --

5 almost half of the open issues are associated 

6 with OTIB-54. Twenty-six of the 62 open 

7 issues are associated with that OTIB.

8 So I don't know; I have no idea 

9 what OTIB-54 is, but if we were to attack that 

10 OTIB, we would go a long ways towards moving 

11 or reducing the number of open issues.

12 MR. KATZ: I thought we had this 

13 discussion -- I'm sorry, Brant. Go ahead.

14 DR. ULSH: OTIB-54 is on the 

15 agenda.

16 MR. KATZ: Right. I thought that 

17 was the path forward, actually. I thought we 

18 had this discussion, and the real action here, 

19 I mean this is new, this discussion we just 

20 had about this other strategy, but the real 

21 action was let's bite off 54 as our next major 
54 

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1 procedure for which NIOSH would produce 

2 responses, right?

3 MR. HINNEFELD: That sounds 

4 familiar. That's what we have done.

5 CHAIR MUNN: We had both those 

6 discussions.

7 MR. HINNEFELD: Don't we have the 

8 54 responses now?

9 MR. MARSCHKE: And they have done 

10 that. They have done that.

11 MR. KATZ: Yes. Yes.

12 DR. MAURO: Now, mechanistically, 

13 in theory, then, in writing for each issue on 

14 54 you may have some text right now.

15 MR. MARSCHKE: They have that.

16 DR. MAURO: Yes, but it's not in 

17 the --

18 MR. MARSCHKE: It's in the 

19 database. It's in the database.

20 DR. MAURO: So are we in a 

21 position where we could act on that?
55 

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1 MR. MARSCHKE: Steve Ostrow, it's 

2 been given to Steve Ostrow, and he's been 

3 looking at it.

4 DR. MAURO: Okay. So let's talk 

5 about the mechanics of it. In principal, 

6 could we do it right now? Let's see your 

7 answer to Issue No. 1, Issue No. 2. If we 

8 have the right people on the line or here from 

9 SC&A, couldn't we put that one to bed? Or do 

10 we want to wait until we give our people some 

11 opportunity to read it --

12 MR. MARSCHKE: There are some of 

13 them that you can basically do that on because 

14 there are a number of these issues which are 

15 no response required. And there's another 

16 group of issues where NIOSH agrees with the 

17 issue.

18 So those two categories are no19 brainers. We can go through and we can move 

20 those from the open to the closed column 

21 almost immediately. Some of the other ones, 
56 

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1 for example, as I speak, OTIB-54, Issue No. 2, 

2 no response needed.

3 DR. ULSH: Well, before we get too 

4 deep into OTIB-54, since that is on the agenda 

5 as one of the next items, part of the review 

6 of carryover items, I would just like to be 

7 clear on what we're committing to provide 

8 under the Report on Status and Action Plan for 

9 Open Items.

10 We're still on the fly here. I 

11 think perhaps by our next meeting in December 

12 and January we could at least have a 

13 categorization of -- 

14 (Phone noise.) 

15 -- that's Elyse trying to 

16 frantically tell me to be quiet.

17 (Laughter.)

18 I think we could at least commit 

19 to providing that list of findings which 

20 pertain to what are now outdated documents, 

21 and maybe we could even identify those ones 
57 

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1 that we would -- I'd say are candidates for 

2 closure because they have gone away. I don't 

3 know that we could commit to providing a 

4 technical response on each of the remaining 

5 ones.

6 CHAIR MUNN: No, I don't believe 

7 we ever had that discussion. The discussion 

8 that we had bears more directly on your 

9 earlier comment.

10 DR. ULSH: Okay.

11 CHAIR MUNN: We wanted to get a 

12 handle on how many we're carrying that really 

13 are not applicable to anything anymore and to, 

14 therefore, have a better handle on how much 

15 needs to be done. We don't know how much work 

16 needs to be done on the open items because 

17 we're not clear on precisely what the status 

18 of each of those is.

19 DR. ULSH: So would that be 

20 acceptable, then, if we commit to provide that 

21 for the next meeting?
58 

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1 CHAIR MUNN: It certainly will be,

2 especially in the light of the fact that we're 

3 going to be talking about half of them, 

4 assumedly, when we talk about OTIB-54.

5 Is Steve Ostrow going to be the 

6 guy on that? Because Steve told me he would 

7 not be here this morning; he will be here this 

8 afternoon.

9 DR. MAURO: He will be here this 

10 afternoon for the two-pagers. Now you 

11 referred to OTIB-54. I'm not sure what that's 

12 about.

13 MR. MARSCHKE: OTIB-54 is Steve 

14 actually did the -- it's fission and 

15 activation product assignment for internal 

16 dose.

17 DR. MAURO: Oh, this is where you 

18 had the gross beta-gamma in the urine and you 

19 have all those different categories of 

20 reactors. We had some comments, but I didn't 

21 think -- well, let's take a look, but I 
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1 remember that going to --

2 MR. MARSCHKE: Well, we have a 

3 couple more -- on the agenda we have a couple 

4 more items before we get to OTIB-54.

5 DR. MAURO: Oh, okay. Sorry. I 

6 don't want to shortcircuit it.

7 CHAIR MUNN: No, no.

8 DR. MAURO: But I think we're 

9 poised to go after that one.

10 CHAIR MUNN: Oh, fine. You don't 

11 have to wait for Steve?

12 DR. MAURO: I'm pretty familiar. 

13 Now Steve I guess led, he led the --

14 MR. MARSCHKE: Steve was basically 

15 the author of the OTIB-54 report.

16 DR. MAURO: Right, right.

17 MR. MARSCHKE: Now if you want 

18 to -- 

19 DR. MAURO: Let's wait until he 

20 gets here. I don't want to jump the gun.

21 MR. MARSCHKE: And I forwarded the 
60 

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1 comments. NIOSH gave me a hard copy of the 

2 comments, and I forwarded them to Steve, and 

3 he looked at them, and he has not gotten back 

4 formally.

5 DR. MAURO: If it's what I believe 

6 it is, the issue has to do with it's a generic 

7 approach saying, listen, we have a lot of 

8 workers out here where we have gross beta9 gamma activity because they were working at 

10 some reactors, okay, and they're different 

11 kinds of reactors. How do you go from gross 

12 beta-gamma in urine and reconstruct a person's 

13 dose? What assumptions do you make regarding 

14 the mix of isotopes that he might have inhaled 

15 to give you that gross beta-gamma?

16 So it is an internal dosimetry 

17 question. When you really lack specific data 

18 for a given facility, all you have is gross 

19 beta-gamma, not isotopic mix.

20 So we went to Joyce and said, 

21 "Joyce, listen, this is the approach they plan 
61 

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1 to use." And as we used it, in other words, 

2 if you're working with this class of reactor, 

3 this is the mix you assume it is, if you have 

4 this gross beta-gamma. Oh, but if it's this 

5 class of reactor, you use this mix. So the 

6 mix is really selected based on, I think, four 

7 or five different categories of reactors. 

8 And my recollection is that we had 

9 a pretty favorable response. But I don't want 

10 to take the wind out of the sails of the folks 

11 who did the work because there might have been 

12 some, if this is the one --

13 MR. MARSCHKE: There were 26 

14 comments.

15 DR. MAURO: We had 26? Okay.

16 MR. MARSCHKE: Twenty-six 

17 comments. Not all of them were -- some of 

18 them were positive comments, I believe, and 

19 they had no response required.

20 DR. MAURO: Yes, okay, and Steve 

21 was -- I mean I worked with Steve when we 
62 

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1 first sort of set it up to get this thing 

2 launched. But when Steve gets back, he will 

3 be in a position to do a much better job than 

4 I can.

5 CHAIR MUNN: Are you recommending 

6 that we wait until this afternoon when Steve 

7 is here?

8 DR. MAURO: Why don't we wait for 

9 Steve to get here?

10 MR. MARSCHKE: Well, why don't we 

11 work down the list, and when we can pull up 

12 OTIB-54 on the screen here, we can look and 

13 see what the issues are, and whether or not we 

14 want to wait for Steve.

15 MR. HINNEFELD: I mean if there 

16 are some things that can be closed and if it's 

17 a no response needed, we can close those.

18 DR. MAURO: Let's move on those. 

19 Let's move. Let's make some progress.

20 CHAIR MUNN: Let's do it now. 

21 Let's do it now because I had set aside a 
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1 significant amount of time. I thought NIOSH 

2 would have a report on their action plan, the 

3 open items. Since that has not occurred, and 

4 since, obviously, this OTIB is a major part of 

5 that issue anyway, let's just move it up a 

6 little bit and go ahead and look at it right 

7 now.

8 DR. ULSH: Now do you also want to 

9 reserve some time this afternoon to have Steve 

10 involved for those issues that we can't close 

11 immediately or are we just --

12 CHAIR MUNN: Sure. There's no 

13 reason why we can't go back to that.

14 MEMBER ZIEMER: You're just going 

15 to focus on the easy ones here, is that it?

16 DR. MAURO: Yes, let's do what we 

17 can.

18 CHAIR MUNN: Let's do it.

19 MR. MARSCHKE: Okay. Again, 

20 looking at the way the issues have been 

21 structured here, we have kind of like two 
64 

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1 levels of issues. We have observations, which 

2 the first six issues are observations, and 

3 then we have some findings. Issue 7 is a 

4 finding. Issue 8, again, is an observation. 

5 So I'm not sure whether or not there's a 

6 difference between observation and a finding 

7 in the severity. Some of the observations I 

8 think are positive findings.

9 CHAIR MUNN: Require no action?

10 MR. MARSCHKE: Require no action.

11 DR. MAURO: If that's the case, 

12 let's put it down, no action required.

13 MR. MARSCHKE: So that's what 

14 basically -- that's what NIOSH has done for 

15 issues. If you want to go through and do the 

16 no action, no response needed first --

17 DR. MAURO: Let's just go top to 

18 bottom. Let's just march through them and say 

19 we can hit it now or we can't; it has to wait 

20 for Steve. And if we can hit it now, let's 

21 hit it now and start to knock things off. I'm 
65 

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1 big for let's move the chains.

2 CHAIR MUNN: Let's do. 

3 Absolutely.

4 DR. MAURO: Let me get up closer 

5 so I can read that with you.

6 CHAIR MUNN: So we can go for it.

7 MR. MARSCHKE: The first issue is 

8 the TBD does not specify what version of 

9 ORIGEN2 NIOSH used to inform the calculations 

10 underlying the guidance given to dose 

11 reconstructors, nor does the OTIB justify its 

12 use.

13 And the NIOSH response was 

14 "Information on the code version, V2.1, will 

15 be added. ORIGEN2 is an industry standard 

16 tool for predicting the content of irradiated 

17 nuclear fuels. OTIB-54 includes some 

18 description of ORIGEN2 in Section 5.1, page 

19 11. Further elaboration can be added if 

20 desired. Later versions, for example, ORIGEN21 ARP, do not have established data libraries 
66 

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1 for older reactor designs. ORIGEN-ARP has 

2 pre-existing libraries developed specifically 

3 for the ART and the fast flux test facility.

4 "It would take a significant 

5 effort to develop data libraries, especially 

6 for the reactors considered in OTIB-54, but 

7 this can be done, if desired, using the TRITON 

8 code that is part of Scale 6

9 CHAIR MUNN: Now let me read this -

10 - last two sentences. "ORIGEN2, pre-existing 

11 librarie developed specifically for the ATR --

12 it would take significant effort to develop 

13 data libraries specifically for the reactors 

14 considered in OTIB-54, but it can be done, if 

15 desired, using the TRITON code that is part of 

16 Scale 6."

17 So what this is telling me is two 

18 things. One, we have a portion of this that 

19 should be in abeyance. It's in progress, 

20 right?

21 DR. MAURO: They answered the 
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1 question. In other words, the question we 

2 posed, we need to know a little bit more about 

3 ORIGEN and what you did. And they gave us 

4 what we needed.

5 Now the question is, obviously, 

6 ORIGEN and its pedigree and its history is 

7 dynamic. It's changing. There's always 

8 improvements. But does that really mean that 

9 it's -- to me, taking it any further is 

10 gilding the lily.

11 There's no doubt that the folks in 

12 charge are very aware of ORIGEN and its 

13 pedigree and its changes. I am perfectly 

14 satisfied with this answer. They have 

15 answered the question.

16 Now justification, my guess is 

17 justification is asking for a Ph.D. thesis.

18 MR. MARSCHKE: They've answered

19 the question, but they have also asked a 

20 couple of questions. Basically, they have 

21 said that they are going to add information on 
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1 the code version in the first sentence.

2 CHAIR MUNN: It's in abeyance.

3 DR. MAURO: That's why it's in 

4 abeyance. Yes.

5 MR. MARSCHKE: But then in this 

6 sentence here they have said, "Further 

7 elaboration can be added, if desired." Do we 

8 want further elaboration or is just the code 

9 version enough?

10 And then they also want to know 

11 whether or not they need to develop specific

12 libraries. I think your answer to that, John, 

13 was, no, they don't.

14 MR. HINNEFELD: The question is is 

15 the additional value of a later version of 

16 ORIGEN worth the effort it would take to 

17 regenerate the libraries, nuclide libraries 

18 for those reactors, when those libraries 

19 already exist in Version 2.1?

20 To my mind, you know, the 

21 incremental value you get from these versions 
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1 of software isn't that much of an incremental 

2 value that you would want to take on that 

3 other task

4 DR. MAURO: And I would leave it

5 to the wisdom of NIOSH and your contractors 

6 when such changes occur, say something of 

7 substance happens, and the way in which ORIGEN 

8 derives the fission products, which is, you 

9 know, we're actually at the edge. No, there's 

10 no need to carry this further. Otherwise, we 

11 would be agonizing over supplying structure.

12 You could imagine people are 

13 always looking at the physics of --

14 interactions in ORIGEN. You don't want to 

15 operate at that level. You don't need that.

16 CHAIR MUNN: No, no. No, I don't 

17 think we do.

18 Mark and Dick, I'm a little 

19 concerned about whether you are able to follow 

20 this discussion on the telephone. Have you 

21 been able to pull this database up, so that 
70 

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1 you see where we are and what we're talking 

2 about?

3 MR. HINNEFELD: Our responses are 

4 also in a Word file.

5 MEMBER LEMEN: This is Dick. I am 

6 following you as best I can. If I have 

7 questions, I'll let you know.

8 CHAIR MUNN: Thank you.

9 Mark, how are you?

10 MEMBER GRIFFON: I'm following 

11 along, Wanda. Thanks.

12 CHAIR MUNN: Okay. Fine. Do both 

13 of you agree that we're in abeyance here, that 

14 we really don't have any further action until 

15 -- all NIOSH needs to do is just incorporate 

16 ORIGEN?

17 MEMBER ZIEMER: Well, they've 

18 already done that, haven't they?

19 MR. HINNEFELD: If you're talking 

20 about some wording changes in the --

21 DR. MAURO: Committing to wording 
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1 changes in the actual OTIB.

2 MR. HINNEFELD: To specify in --

3 MEMBER ZIEMER: Oh, in the OTIB, 

4 yes.

5 MR. HINNEFELD: And we could even 

6 add --

7 MEMBER ZIEMER: I mean, they have 

8 agreed --

9 MR. HINNEFELD: That was already -

10 - those are pre-existing libraries --

11 DR. MAURO: Bear in mind when 

12 Steve gets here, the marriage of a given mix 

13 and that mix selected for a given class of 

14 reactor, as laid out in the protocol, the 

15 OTIB, that's a different question. In other 

16 words, did you marry, for a given class of 

17 reactor, we're going to use this mix, and they 

18 give the rationale for it in the OTIB. I 

19 remember it. That's certainly going to be a 

20 subject of discussion.

21 But right now I do not think --
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1 the very fact that they have described that 

2 they have used ORIGEN or a given version of it 

3 to come up with the mix -- and that's what 

4 ORIGEN does for you, it gives you the reactor 

5 core inventory and mix -- you know, I think 

6 that answers the question. That doesn't mean 

7 we have no problems with the way they used 

8 that information to say, well, we'll apply 

9 that mix to this reactor and this mix to that 

10 reactor. So, I mean, to me this issue has 

11 been resolved.

12 CHAIR MUNN: So you're fine? From 

13 your point of view, we could actually close 

14 this?

15 DR. MAURO: Well, in abeyance, if 

16 you want, because there are some wording 

17 changes that are needed in the OTIB to commit 

18 to that.

19 CHAIR MUNN: That was my 

20 interpretation of what Elyse had to say.

21 DR. MAURO: Yes.
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1 CHAIR MUNN: Richard, are you all 

2 right with an in abeyance status for this 

3 item?

4 MEMBER LEMEN: Yes.

5 CHAIR MUNN: Mark?

6 MEMBER GRIFFON: Yes.

7 CHAIR MUNN: Any problem here?

8 MEMBER ZIEMER: No. No, we're 

9 good.

10 CHAIR MUNN: All right. Let's 

11 just wait just a moment and give Steve a 

12 chance to see if our new magic is going to 

13 work.

14 MR. MARSCHKE: Okay, the response 

15 I propose to add is, "NIOSH should identify 

16 that Version 2.1 should be added -- NIOSH 

17 should identify --

18 DR. MAURO: Explain that that was 

19 what was used.

20 MR. MARSCHKE: "Was used to 

21 identify in the OTIB -- that Version 2.1 was 
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1 used, but do not -- related -- of ORIGEN. 

2 Change the status to in abeyance."

3 Now I'm going to press the magic 

4 button here and see if it works. It worked, 

5 and now we have to change the status to in 

6 abeyance. Change status.

7 CHAIR MUNN: Marvelous. It did 

8 work.

9 DR. MAURO: Break out the 

10 champagne.

11 (Laughter.)

12 MR. MARSCHKE: Celebrate the small 

13 victories.

14 CHAIR MUNN: Very good. Yes, 

15 that's actually a large victory, considering 

16 how long it took us to get here.

17 Item 2?

18 MR. MARSCHKE: Now it's in 

19 abeyance.

20 Item 2 is basically OTIB's advice 

21 to select decay times most appropriate to the 
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1 claimants, and accompanying guidance are 

2 helpful."

3 The NIOSH response is no response 

4 needed.

5 DR. MAURO: We agree.

6 CHAIR MUNN: Change status to 

7 closed.

8 DR. MAURO: Yes.

9 MR. MARSCHKE: Do we need to add a 

10 response to why we're changing --

11 CHAIR MUNN: I don't believe so. 

12 I think "no response is needed" is adequate.

13 I had hoped to see the status 

14 change on my screen.

15 MR. MARSCHKE: It's still working. 

16 It's still working, Wanda. We've got to 

17 watch this little box that is down here.

18 CHAIR MUNN: Yes, we'll give it a 

19 few minutes.

20 DR. ULSH: Once that is done, you 

21 might have to hit refresh.
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1 CHAIR MUNN: Yes, yes.

2 MR. MARSCHKE: And it might 

3 disappear because, basically, we have the 

4 filter on "all but closed."

5 DR. MAURO: Oh, we closed one. 

6 So, therefore, you are not going to see it?

7 MR. MARSCHKE: It may go away.

8 DR. MAURO: Oh, no.

9 MR. KATZ: Magic.

10 MR. MARSCHKE: So if we change the 

11 filter to all messages, then it should come 

12 back.

13 MEMBER ZIEMER: I want to ask a 

14 question. Why was that a finding, that second 

15 one?

16 MR. MARSCHKE: It was an 

17 observation.

18 MEMBER ZIEMER: Well, but it's 

19 listed as a finding.

20 CHAIR MUNN: Well it's -- an 

21 observation.
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1 MR. MARSCHKE: I think at one 

2 point we had a discussion whether or not 

3 observation should be included in the database 

4 or not, and the decision was include 

5 observations and findings in the database.

6 CHAIR MUNN: Because it's an 

7 archive. This is the history.

8 Some of the observations really 

9 should have some action attached to them, not 

10 always, but some really should have.

11 MR. MARSCHKE: You can see, well, 

12 even the first one, the first one was an 

13 observation, and NIOSH did feel a 

14 responsibility to provide a response to the 

15 first one.

16 DR. MAURO: The distinction we 

17 originally made between observations and 

18 findings, observation is that, listen, this is 

19 an improvement that would help clarify. It 

20 would just make for a better product. 

21 However, it doesn't really have a fundamental 
78 

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1 -- on how you are going to do the dose 

2 reconstruction, which would be a finding. So 

3 we made that distinction to try to be helpful.

4 Of course, we have gone a step 

5 further now, and the degree to which we have a 

6 positive statement, it's always a nice thing 

7 to say this looks really good. Obviously, we 

8 don't always do that, but in this case we did.

9 CHAIR MUNN: No, but that is fine. 

10 Yes, that is good. All right, we are closed.

11 We are on to Item 3.

12 MR. MARSCHKE: Item 3 is another 

13 observation on reactor modeling. "The OTIB 

14 currently notes that overestimation of 

15 activity ratios for short-lived 

16 radionuclides." Is that the end of it?

17 CHAIR MUNN: Yes.

18 MR. MARSCHKE: Observation, "The 

19 OTIB correctly notes that overestimation of 

20 activity ratios for short-lived 

21 radionuclides."
79 

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1 CHAIR MUNN: No response. Closed.

2 DR. MAURO: But it's good to know 

3 that it does that, have that on the record.

4 CHAIR MUNN: Yes, it is.

5 MR. HINNEFELD: This works better 

6 when you are actually on our computer system. 

7 We are using wireless, going through Citrix 

8 to Atlanta and then back.

9 MR. MARSCHKE: Well, this is the 

10 way it works on my computer.

11 MR. HINNEFELD: Works for you all 

12 the time this way because you're always going 

13 through Citrix.

14 MR. MARSCHKE: Exactly.

15 Issue 4 is another observation. 

16 "Methodologies, assumptions, and data sources 

17 are reasonable." And obviously, there's no 

18 response needed from NIOSH on that.

19 DR. MAURO: I knew I remembered we 

20 had a positive reaction to this.

21 MR. MARSCHKE: Yes. Typically, 
80 

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1 Steve Ostrow is apt to give out --

2 DR. MAURO: He will.

3 MR. MARSCHKE: -- positive 

4 feedback.

5 DR. MAURO: You want Steve to 

6 review all the OTIBs.

7 (Laughter.)

8 MR. MARSCHKE: Again, I assume 

9 that the Subcommittee wants to close this one.

10 CHAIR MUNN: Yes, please.

11 Richard, is closed okay?

12 MEMBER LEMEN: Yes. This is 

13 Richard. I'm fine.

14 CHAIR MUNN: Thank you.

15 MEMBER LEMEN: I'm not asleep. 

16 I'm listening.

17 (Laughter.)

18 CHAIR MUNN: Mark, closed?

19 MEMBER GRIFFON: Yes, that is 

20 fine.

21 CHAIR MUNN: Thank you.
81 

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1 MR. MARSCHKE: Finding 5, finding 

2 -- Fast Flux Test Facility. "Methodologies 

3 and data sources are reasonable. SC&A 

4 questions the chosen burnup value."

5 And then the NIOSH response is, 

6 "The 80,000-megawatt days per metric -- heavy 

7 metal burnup was selected -- was from DOE 

8 2003," which states, "Most of the standard 

9 Fast Flux Test Facility driver assemblies were 

10 irradiated from 70,000 to 90,000-megawatt days 

11 per metric ton heavy metal."

12 From the same reference, it 

13 appears the maximum burnup was 152,230-

14 megawatt days per metric ton of heavy metal.

15 As a check, the FFTF case was run 

16 to a burnup of 152,230-megawatt days per 

17 metric ton of heavy metal, which equates to 

18 5,011.1-megawatt days per assembly or 928 days 

19 at a specific power of 5.4 megawatts.

20 The strontium-90 to cesium-137 

21 ratio at discharge for the maximum burnup case 
82 

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1 was identical to that for the nominal burnup, 

2 80,000-megawatt days per metric ton heavy 

3 metal case. Ratio equals 0.365 in both cases.

4 CHAIR MUNN: I need to call 

5 attention to the fact that I am conflicted on 

6 this particular point. If you want to hear 

7 what I have to say, I can tell you the numbers 

8 are right.

9 DR. MAURO: That is the only thing 

10 I was going to say. That is, the answer says 

11 that, even if you were to change the burnup 

12 rate, it doesn't change the strontium/cesium 

13 ratios, which is the important fission product 

14 mix that you are concerned about. That being 

15 the case, as far as I'm concerned, the 

16 question is answered, but I don't want to --

17 we know Joyce looked at this, and our folks, 

18 and Steve as a nuclear engineer. They may 

19 say, yes, we agree.

20 So from SC&A's perspective, I 

21 cannot speak to whether or not that is, in 
83 

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1 fact, true. But if that is, in fact, true, it 

2 has answered the question in an affirmative 

3 value -- manner.

4 MR. MARSCHKE: Well, again, this 

5 is the first time I've read this, but it's not 

6 surprising that the ratio hasn't changed 

7 because both the strontium-90 and the cesium 

8 probably have reached equilibrium in the core 

9 at 80,000-megawatt days. So, going further, 

10 having additional burnup is not going to 

11 change the equilibrium activities.

12 MEMBER ZIEMER: So if you're at 

13 equilibrium, you're at equilibrium.

14 DR. MAURO: At equilibrium. Thank 

15 you.

16 MR. MARSCHKE: That would probably 

17 be the reason why it doesn't change. Once you 

18 reach a certain burnup, it stays at that rate.

19 CHAIR MUNN: I'll not say anything 

20 else about --

21 DR. MAURO: If you folks are 
84 

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1 happy, I'm happy.

2 MEMBER ZIEMER: Well, I think the 

3 physics of it are independent of where it was 

4 done. But I'm assuming from what you said 

5 this is based on some work done at that 

6 facility, but the basic physics are what they 

7 are.

8 DR. ULSH: In terms of a status, 

9 do we want to wait for Steve to weigh in or do 

10 you want to act on it now?

11 DR. MAURO: No, I think the fact 

12 that Steve Marschke is our nuclear engineer 

13 also. And certainly the feedback of Paul 

14 confirming his perspective on it also. It's 

15 good enough for me. From SC&A's perspective, 

16 we would recommend that. I have no problem 

17 with that.

18 CHAIR MUNN: And I won't speak to 

19 that any further. But other Members of this 

20 Subcommittee?

21 Richard, any heartburn with that, 
85 

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1 closing it?

2 MEMBER LEMEN: No, I don't.

3 CHAIR MUNN: Mark?

4 MEMBER GRIFFON: No, it's okay to 

5 close.

6 CHAIR MUNN: All right.

7 MR. KATZ: Closed.

8 CHAIR MUNN: Closed.

9 MR. MARSCHKE: Do we need to add a 

10 response? We have a response. This one's not 

11 intuitively obvious.

12 CHAIR MUNN: No.

13 DR. MAURO: Only if you have a 

14 Ph.D. in nuclear engineering.

15 MR. MARSCHKE: By the way, it's 

16 doing something now. I have to wait before I 

17 can ask it to do something else.

18 CHAIR MUNN: You can't say 

19 anything about the ratios of anything else, 

20 but I know that's not --

21 MR. MARSCHKE: Well, I can't do 
86 

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1 something else. When it's closed, you 

2 can't --

3 MR. HINNEFELD: You can't add a 

4 response when it's closed.

5 MR. MARSCHKE: You can't add a 

6 response to it when it's closed.

7 MR. HINNEFELD: That's right. You 

8 have to add the response first.

9 CHAIR MUNN: While Steve is typing 

10 away, this seems like a good time for us to 

11 take a short break in any case. Let's take 15 

12 minutes. Be back at 20 until 11:00.

13 (Whereupon, the above-entitled 

14 matter went off the record at 10:18 a.m. and 

15 went back on the record at 10:35 a.m.)

16 MR. KATZ: Okay, this is the 

17 Procedures Subcommittee. We're reconvening 

18 after a short break.

19 Dick and Mark, are you back with 

20 us?

21 MEMBER LEMEN: This is Dick. I'm 
87 

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1 back.

2 MR. KATZ: Hi, Dick.

3 MEMBER LEMEN: Hello.

4 MR. KATZ: Mark, are you back with 

5 us, too?

6 Not yet.

7 CHAIR MUNN: Let's give him 

8 another 30 seconds.

9 MR. KATZ: Okay.

10 CHAIR MUNN: And my screen has 

11 updated. I hope everyone else's has. So that 

12 Items 2, 3, 4, and 5 are now gone.

13 We're on Item 6, and I think it's 

14 time for us, with or without Mark, to take 

15 up --

16 MEMBER GRIFFON: I'm here, Wanda.

17 CHAIR MUNN: Oh, good. Great.

18 We're on ORAUT OTIB-54-6.

19 MR. MARSCHKE: This is an 

20 observation. It's for the N Reactor. It 

21 reads, "The OTIB appears to have taken all of 
88 

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1 its data for the N Reactor from authoritative 

2 sources and reasonably simulated the actual 

3 isotopic composition after irradiation by 

4 considering two different data sets."

5 The NIOSH response was no response 

6 needed.

7 CHAIR MUNN: Correct. Closed.

8 MEMBER ZIEMER: Closed.

9 CHAIR MUNN: Any objection?

10 MEMBER ZIEMER: Closed.

11 CHAIR MUNN: The next item, after 

12 Steve has finished typing, will be Item No. 7, 

13 finding on single pass reactors.

14 MR. MARSCHKE: This is a finding 

15 for the single pass reactors. "The fuel 

16 dimensions, compositions, and typical burnup 

17 values apply to the Manhattan Project era. 

18 Since the reactors continued to operate well 

19 after that period, the OTIB should provide 

20 some justification for the assumption that 

21 these data did not change significantly."
89 

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1 And the NIOSH response is, "The 

2 single pass reactors were designed for natural 

3 uranium fuel. Slightly enriched uranium slugs 

4 were introduced in later years for use in the 

5 outer core regions to flatten out the flux. 

6 Hollow fuel slugs were also used at some point 

7 to increase power by increasing the coolant 

8 flow rate. These changes marked the evolution 

9 of the Hanford fuel slugs from the Manhattan 

10 era to those adopted for use in the N Reactor. 

11 The intention was to capture the Manhattan 

12 era fuel in the modeling for the single pass 

13 reactors and the later fuel would be N 

14 Reactor model.

15 "The evolution of the solid core 

16 fuel slugs, which were used until the mid17 1950s, will not affect the fissions/activation 

18 product results vis-a-vis the purpose/scope of 

19 OTIB-54. The fuel was still natural uranium 

20 canned in aluminum and bonded with aluminum 

21 silicone irradiated to low burnup."
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1 DR. MAURO: Well, I'll let the 

2 nuclear engineers in the room speak. 

3 Certainly they answered the question. In 

4 other words, there's an answer there. Is that 

5 answer satisfactory from a purely technical 

6 perspective? I'll leave it to the --

7 MR. HINNEFELD: Yes, you might 

8 want to go back and comment.

9 DR. MAURO: Yes, but if Steve and 

10 Paul feel that that answer is satisfactory --

11 MEMBER ZIEMER: I can't answer 

12 that.

13 DR. MAURO: Okay. So we're going 

14 to wait for the --

15 MR. MARSCHKE: I think this one we 

16 have to wait for Steve Ostrow.

17 MR. HINNEFELD: So this one goes 

18 in abeyance, or not in abeyance, in progress.

19 DR. MAURO: It's in progress.

20 MR. HINNEFELD: In progress.

21 DR. MAURO: We have got an answer, 
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1 and we have to -- so the ball is in our court.

2 MR. KATZ: You probably don't have 

3 to change it to in progress right now, if we 

4 just mark that, because Steve will be here 

5 this afternoon.

6 MEMBER ZIEMER: Leave it open.

7 MR. MARSCHKE: Leave it open until 

8 Steve gets here.

9 MR. HINNEFELD: Oh, okay.

10 DR. MAURO: Yes.

11 MR. MARSCHKE: And maybe we can 

12 come back to it this afternoon.

13 That brings us to 8.

14 CHAIR MUNN: Correct.

15 MR. MARSCHKE: Eight is an 

16 observation for the single pass reactors.

17 "SC&A questions the OTIB 

18 referencing Robert Burns, Jr., CHP, Senior 

19 Health Physicist, Soka Research Associates" --

20 MEMBER ZIEMER: No, Shonka.

21 MR. MARSCHKE: Shonka?
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1 DR. MAURO: Yes, Joe Shonka.

2 MR. MARSCHKE: Research 

3 Associates.

4 "Rather than citing the original 

5 source material directly and including a 

6 discussion of assumptions and effects."

7 The NIOSH response was, "The 

8 discussion of the basis for the data used in 

9 the W slugs will be expanded to include 

10 appropriate reference citations. Initially, 

11 the W slug data were taken from calculations 

12 the author had performed years prior for the 

13 Oak Ridge dose reconstruction project. (Fuel 

14 slugs from Hanford were used in radium 

15 production at X10.)

16 "Since then historical Manhattan17 era documents from Hanford have been reviewed 

18 in more detail and better information has been 

19 obtained for the Manhattan-era fuel slugs. 

20 The fuel design was a work-in-progress as they 

21 gained experience operating the original 
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1 piles. But we feel the uranium content used 

2 in the OTIB-54 calculations was appropriate.

3 "We also believe the aluminum 

4 content should be revised upward. This is not 

5 expected to have any appreciable impact on the 

6 data provided in OTIB-54.

7 "The aluminum used in the Hanford 

8 slugs was high purity. So increasing the 

9 amount should not impact the activity ratios 

10 for the predominant radionuclides."

11 It sounds to me like NIOSH has 

12 proposed doing some additional work here.

13 DR. MAURO: Well, it sounds like 

14 they've answered the question. They have 

15 proposed to answer the question. And it 

16 sounds like an in abeyance. In other -- an 

17 answer to the question is provided here, and 

18 that they plan to provide that answer in the 

19 next revision as appropriate.

20 CHAIR MUNN: Yes.

21 DR. MAURO: So I would recommend 
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1 in abeyance, if you folks agree.

2 CHAIR MUNN: I have no objection 

3 to that. It's what I would --

4 MEMBER GRIFFON: John, I don't --

5 Wanda, I'm sorry. I don't understand why that 

6 would be in abeyance. They haven't told us 

7 how they are going to answer it. They intend 

8 to answer it, but we haven't seen any kind of 

9 text or rationale.

10 CHAIR MUNN: Because it says, "The 

11 discussion of the bases will be expanded to 

12 include appropriate reference citations."

13 DR. MAURO: Yes, Mark, the only 

14 reason I said that is because it's an 

15 observation. It sounds like --

16 MEMBER GRIFFON: Yes.

17 DR. MAURO: Yes, if it was a 

18 finding, I would agree with you, as if 

19 whatever the answer might be might change some 

20 of our conclusions. But being that it's an 

21 observation, it means --
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1 MEMBER GRIFFON: That's okay. So, 

2 mainly, it's going to expand the references. 

3 Okay. I can accept that. I'm sorry.

4 DR. MAURO: Yes, you got it.

5 MR. KATZ: There's two things. 

6 The references, expand the references, and the 

7 aluminum content, it says, should be revised 

8 upward. But that's not expected to have an 

9 impact.

10 MR. MARSCHKE: Yes, I mean the 

11 last sentence there says, basically, whatever 

12 the results that they come up with are not 

13 expected to impact the activity ratios. Now 

14 the question is what happens if the unexpected 

15 occurs and they do impact the activity ratios?

16 DR. BURNS: This is Bob Burns. I 

17 can jump in at this point.

18 Those revised ORIGEN runs have 

19 been done, and the activity ratios did not 

20 change.

21 CHAIR MUNN: Thank you, Robert.
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1 DR. BURNS: You're welcome.

2 MR. MARSCHKE: With that 

3 information, does the Subcommittee want to 

4 change it to in abeyance?

5 CHAIR MUNN: In abeyance.

6 MEMBER ZIEMER: I just have one 

7 question.

8 CHAIR MUNN: Yes.

9 MEMBER ZIEMER: It asks for the 

10 references, and it asks for the assumptions. 

11 Are the assumptions -- well, I guess these are 

12 the assumptions here. So this would be what 

13 they would include in the expanded text, 

14 basically, what they have written.

15 DR. MAURO: Do we wait for that to 

16 happen in the actual OTIB, or do we accept it 

17 on face value at this time? The difference 

18 between closing it now or putting it in 

19 abeyance, that's --

20 MEMBER ZIEMER: I think it goes 

21 into abeyance because they haven't put it in 
97 

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1 yet, right? Isn't that correct?

2 CHAIR MUNN: Correct.

3 MEMBER ZIEMER: Otherwise, I think 

4 it's agreeable.

5 CHAIR MUNN: Any objection on the 

6 phone? Otherwise, it's going into abeyance.

7 (No response.)

8 Thank you.

9 MR. MARSCHKE: The response that I 

10 propose to add is, "NIOSH, Bob Burns, 

11 indicated that the additional ORIGEN runs were 

12 made and no changes to the activity ratios 

13 were observed." Change the status to in 

14 abeyance.

15 MEMBER ZIEMER: What was the first 

16 part of that?

17 MR. MARSCHKE: "NIOSH --

18 MEMBER ZIEMER: Well, yes, but 

19 that only addresses the --

20 DR. MAURO: Half the problem.

21 MEMBER ZIEMER: Yes. The other 
98 

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1 part is that -- well, I guess we agree that 

2 there's discussion there and the expanded 

3 references meet the concerns. In addition --

4 MR. MARSCHKE: In addition --

5 DR. MAURO: NIOSH has committed to 

6 edit the document to provide the information. 

7 To provide, I guess, references.

8 MR. MARSCHKE: Provide the 

9 references?

10 DR. MAURO: That's the way the 

11 wording is right now.

12 MR. MARSCHKE: "In addition, NIOSH 

13 has committed to provide the references --

14 CHAIR MUNN: I thought they had 

15 committed to --

16 DR. MAURO: Incorporate. How 

17 about "incorporate?"

18 CHAIR MUNN: To incorporate, to 

19 revise the procedures. It's going to revise 

20 the procedure.

21 DR. MAURO: Incorporate the 
99 

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1 references into this.

2 MEMBER ZIEMER: You know, one sort 

3 of format question on this, this column we're 

4 putting it in is called an SC&A follow-up 

5 column, when in reality it's a Work Group. Is 

6 that what we mean when we say that?

7 MR. MARSCHKE: That was one of the 

8 other changes we had talked about, giving 

9 myself two hats. One hat being --

10 MEMBER ZIEMER: Right.

11 MR. MARSCHKE: -- when I'm here at 

12 the Subcommittee identifying it as 

13 Subcommittee input, and the other hat -- let 

14 me look and see on the list of --

15 MEMBER ZIEMER: I mean let's say 

16 that NIOSH had a challenge to what you guys 

17 said. Then you would have to go back or 

18 something and have --

19 DR. MAURO: Well, no matter what, 

20 this would be a Work Group directive.

21 MEMBER ZIEMER: It's always a Work 
100 

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1 Group session, though.

2 DR. MAURO: So, really, the title 

3 of this is the conclusions or recommendations 

4 by the Work Group. Isn't that what this is?

5 MEMBER ZIEMER: Well, I'm just 

6 saying I don't think that this is just an SC&A 

7 followup.

8 DR. MAURO: I agree with you, yes.

9 MEMBER ZIEMER: It's a Work Group 

10 followup, which involves all parties.

11 DR. MAURO: Right.

12 CHAIR MUNN: But that's not going 

13 in the SC&A followup.

14 MEMBER ZIEMER: Well, isn't that 

15 where it's dumping into it?

16 CHAIR MUNN: Oh, it shouldn't be. 

17 It should be going into that --

18 MR. MARSCHKE: It's going into 

19 SC&A because I'm SC&A -- I'm identified as 

20 SC&A, and I'm identified as the one that is 

21 entering it.
101 

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1 CHAIR MUNN: Oh, I thought you 

2 were typing in the column that is beyond 

3 the --

4 MEMBER ZIEMER: Well, that's the 

5 box, but it dumps it into the SC&A followup.

6 MR. MARSCHKE: When I hit "Add 

7 Response" here, Wanda, it goes over --

8 CHAIR MUNN: I see that now.

9 MR. MARSCHKE: Yes. The only 

10 thing you can look at, it does give a date 

11 stamp. And when you see the date stamp 

12 corresponds with a Subcommittee meeting date, 

13 then it's got my initials --

14 MEMBER ZIEMER: Right.

15 MR. MARSCHKE: -- and the 

16 Subcommittee meeting date, then that would be 

17 the indication that it was done at the request 

18 of the Subcommittee.

19 MEMBER ZIEMER: Right, right.

20 CHAIR MUNN: Either that or we 

21 will need to head each of those with --
102 

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1 DR. MAURO: The Work Group 

2 directed.

3 CHAIR MUNN: The Subcommittee --

4 DR. MAURO: "The Subcommittee 

5 directed SC&A," or something to that effect.

6 MEMBER ZIEMER: You have the SC&A 

7 finding, NIOSH initial response, SC&A 

8 followup, NIOSH followup. I mean those could 

9 go on and on.

10 CHAIR MUNN: Yes.

11 MEMBER ZIEMER: But somewhere in 

12 there, and sometimes intermittently, you would 

13 have the Work Group input. So I don't think 

14 we need to solve that today, but it seems to 

15 me there is a formatting issue that we might 

16 want to consider so we could distinguish 

17 between comments that you guys formally 

18 prepare, comments that NIOSH prepares. 

19 Because if we weren't closing these, if we 

20 needed something more, if they weren't in 

21 abeyance, then the next step is NIOSH again.
103 

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1 MR. MARSCHKE: I don't know, 

2 again, what would happen if Paul or Wanda were 

3 to type in an "Add Response." I don't know 

4 where that would end up.

5 MEMBER ZIEMER: Well, I'm not 

6 objecting to who's typing it in at all. I'm 

7 just saying that the heading of the column 

8 seems inappropriate. I mean, are you saying 

9 that it won't let you enter something unless 

10 SC&A is in the column?

11 MR. MARSCHKE: It identifies 

12 anything that I enter as an SC&A response.

13 MEMBER ZIEMER: I got you.

14 MR. MARSCHKE: So the fact that 

15 I'm entering it means it goes into the SC&A. 

16 Now I don't know, again, if you scroll up to 

17 the top here, looking at the headings on the 

18 columns, there doesn't seem to be a column 

19 heading for the Subcommittee.

20 MEMBER ZIEMER: That was the point 

21 I was making. It seems to me that you could 
104 

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1 be the designated entry person on behalf of 

2 the Work Group or the Subcommittee.

3 MR. MARSCHKE: Yes, we have talked 

4 about that.

5 MEMBER ZIEMER: Yes. Yes. I just 

6 wanted to raise the point, and I don't 

7 necessarily think we have to get into the IT 

8 part here, but --

9 CHAIR MUNN: Well, I think we need 

10 to resolve the issue because I was unaware, 

11 until you called it to my attention, of the 

12 fact that it is going into an SC&A column 

13 because that's the way Steve is signed in. 

14 However, it makes sense to me that where he 

15 was typing it, in the blank column following 

16 the findings status column, if that heading 

17 were Subcommittee Comments or Subcommittee 

18 Actions --

19 MEMBER ZIEMER: Something like 

20 that.

21 CHAIR MUNN: -- then that's where 
105 

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1 that information needs to go --

2 MEMBER ZIEMER: Right, right.

3 CHAIR MUNN: -- as a clear 

4 indication that the change in status is taking 

5 place as a result of action of the 

6 Subcommittee, rather than an SC&A response.

7 MEMBER ZIEMER: Right. And then, 

8 I assume the IT people could work it out so 

9 that it would let Steve enter stuff into that 

10 column on behalf of, really on behalf of the 

11 group, which is SC&A and NIOSH and the 

12 Subcommittee. I mean we're resolving and it's 

13 just input, who's going to input it.

14 CHAIR MUNN: And since it's taking 

15 place here -- oh, would you add that to your 

16 list, please, Steve? When you're talking with 

17 the IT people, tell them that it's our desire 

18 that the blank column that's shown on the 

19 current display be headed Subcommittee Actions 

20 and that you be permitted on Subcommittee 

21 dates, if no other time, to sign in in some 
106 

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1 way that will allow you to populate that 

2 column.

3 MEMBER ZIEMER: One other comment 

4 I'll make here. It seems to me that it's 

5 possible that there just be a column added 

6 after those latest follow-up things. Those 

7 latest follow-up things may not get populated. 

8 I mean you've got to have initial finding, 

9 followup, and then you jump to closure. Or 

10 they may get populated.

11 CHAIR MUNN: Dozens of them may 

12 get populated anyway.

13 MEMBER ZIEMER: Right. So one of 

14 the questions, where would the Work 

15 Group/Subcommittee column be?

16 CHAIR MUNN: Right after the 

17 finding status.

18 MR. MARSCHKE: I think what you 

19 could do, Paul, actually, you could maybe move 

20 something like the status to over here and 

21 double up this because you have a lot of white 
107 

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1 space here.

2 MEMBER ZIEMER: Right.

3 MR. MARSCHKE: And just add a 

4 column here as --

5 MEMBER ZIEMER: Right.

6 MR. MARSCHKE: -- for Subcommittee 

7 actions column, something like that.

8 MEMBER ZIEMER: Right.

9 MR. MARSCHKE: You know, that's 

10 the design of what the thing is going to look 

11 like.

12 MEMBER ZIEMER: Right.

13 MR. MARSCHKE: This column, I 

14 think when you click, this blank column, I 

15 think is when you click on the Add Response, 

16 that's when this box pops up. Alternatively, 

17 if you click on the Add Response here, you 

18 could have that response box pop up into this 

19 column and then use this blank column, as 

20 Wanda suggested, as the Subcommittee action 

21 column.
108 

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1 MEMBER ZIEMER: Right. I mean the 

2 Add Response is more like all those boxes 

3 that --

4 CHAIR MUNN: So it's an active 

5 box.

6 MEMBER ZIEMER: Yes. Yes. 

7 Anyway, well, you can work that with the IT 

8 people.

9 CHAIR MUNN: So we're now down to 

10 09, correct?

11 MEMBER ZIEMER: Right.

12 MR. MARSCHKE: So 09 is a finding 

13 for the TRIGA reactors.

14 "TRIGAs ranged in power from 20 

15 kilowatts to 16 megawatts, and in U-235 

16 enrichment from about 20 percent to 70 

17 percent. In addition, several special purpose 

18 models were produced. The OTIB chooses 20 

19 percent enrichment, but did not justify its 

20 choice. Early TRIGA models which may have 

21 been present at the facilities considered in 
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1 this project may have operated at higher than 

2 20 percent enrichment, and this may have 

3 affected the potential exposures that 

4 personnel could have received. Also, it is 

5 not clear what reactor power level is 

6 selected."

7 The NIOSH response, "The intent 

8 was to represent TRIGA reactors used within 

9 the DOE complex that operated with moderate 

10 enrichment and burnup. High enrichment is 

11 represented by the ATR, which also represents 

12 very high burnup. The TRIGA fuel composition 

13 used in OTIB-54 represents standard fuel 

14 elements. Variation from these standards 

15 should be encompassed by other reactor types 

16 considered.

17 "The uranium content of the fuel 

18 was based on assays of fuel elements from the 

19 TRIGA reactors operated in the Hanford Neutron 

20 Radiography Facility, NRF, from the late 1970s 

21 until March of 1989. A power level of 3 
110 

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1 kilowatts was used, pages 18 and 19 of the 

2 OTIB, which was the average power level for an 

3 NRF assembly. TRIGA reactors typically 

4 operated sporadically, rarely for extended 

5 periods at steady-state, and fuel elements can 

6 stay in core for 10 years or more." 

7 Sterbentz, S-T-E-R --

8 DR. MAURO: Sterbentz.

9 MR. MARSCHKE: Sterbentz 1997. 

10 "The 11 percent burnup selected came from 

11 Sterbentz, pages 12, tables 3 and 4."

12 DR. MAURO: As a non-nuclear 

13 engineer, what I read here is a couple of 

14 things, and maybe you guys could help me out 

15 with it.

16 The first thing I read is that, 

17 well, given some of the more extreme 

18 circumstances that you postulate might occur, 

19 as in our question, there is provision in the 

20 OTIB to deal with that by going to a different 

21 category of reactor where that type of 
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1 circumstance could be accommodated. And 

2 that's what I read.

3 But, however, I would say that, 

4 well, that direction, if that is, in fact, the 

5 intent here, should be in the OTIB. In other 

6 words, a little bit more direction is needed 

7 to the dose reconstructor to make sure he 

8 doesn't fall into the wrong bin when he is 

9 doing a given reactor that maybe does not fall 

10 within the envelope that we think it falls in. 

11 I mean, that is what I read when I read this.

12 And then the other material at the 

13 end, I really can't comment on. I'm not quite 

14 sure what he is trying to tell me.

15 CHAIR MUNN: The statements that 

16 were made in the original finding are 

17 certainly correct. I'm not sure how all of 

18 the TRIGAs were used throughout the complex, 

19 but my guess is that in almost all cases they 

20 were identical to the NRF, which means they 

21 were used primarily for radiography and for 
112 

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1 not anything else.

2 The high enrichment fuel that was 

3 used in the early TRIGAs was used primarily as 

4 a training mechanism for students and was 

5 normally found at university reactors, where 

6 the high enrichment gave them an opportunity 

7 to practice different kinds of controls on 

8 reactors with the different capabilities for 

9 sudden peaks in energy.

10 So the response from NIOSH appears 

11 to be reasonable if one makes the assumption 

12 that the use for the entire complex was almost 

13 always non-destructive testing -- I know it to 

14 be the case for the referenced reactor here.

15 I can't imagine why TRIGAs would 

16 be used with high enrichment in the complex. 

17 Can you, Paul or Mark?

18 MEMBER ZIEMER: Well, I don't know 

19 the answer to that. I do note that he answers

20 the power question that apparently is in the 

21 OTIB. They said that it wasn't clear what was 
113 

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1 used, and he does clear that one up.

2 DR. MAURO: Oh, good. Thank you.

3 MEMBER ZIEMER: I think I would be 

4 more comfortable to wait on this one.

5 CHAIR MUNN: Okay.

6 MEMBER ZIEMER: It seems 

7 reasonable, but I don't know what was in the 

8 complex in terms of enrichments. Clearly, if 

9 they went to high enrichment, as John 

10 suggested, it was not used -- the TRIGA model.

11 DR. MAURO: You see, in the end, 

12 it really comes to be very simple. There's a 

13 set of instructions given. Where do you go, 

14 once you know your gross beta-gamma, what 

15 table do you use in the OTIB to determine what 

16 the mix is?

17 CHAIR MUNN: Yes.

18 DR. MAURO: And with this point, 

19 this is saying, well, listen, for TRIGAs, it's 

20 more complicated than that and you need a 

21 little bit more guidance on how to find your 
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1 way, navigate your way through the various 

2 tables.

3 CHAIR MUNN: But it's correct, the 

4 ATR is probably the better one for high 

5 enrichment and burnup, logically speaking, 

6 better.

7 MEMBER ZIEMER: Now this is in a 

8 document that's dealing with internal --

9 DR. MAURO: Internal dose.

10 MEMBER ZIEMER: -- dose. And I 

11 guess their concern here is fuel elements that 

12 may be leaking --

13 DR. MAURO: Yes.

14 MEMBER ZIEMER: -- which is a 

15 particular problem if you're changing out 

16 elements, and so on. Well, it can be a 

17 problem even if they're in the system, but I 

18 think his point in the slow turnover and usage 

19 is because they don't get much burnup.

20 CHAIR MUNN: No, they really 

21 don't.
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1 MEMBER ZIEMER: You don't get a 

2 lot of contribution to internal dose by 

3 handling because you're not handling it.

4 CHAIR MUNN: I just can't 

5 imagine --

6 MEMBER ZIEMER: But I think I 

7 would like to hear what --

8 CHAIR MUNN: What Steve is 

9 probably doing.

10 MEMBER ZIEMER: -- Steve has to 

11 say this afternoon on that.

12 CHAIR MUNN: So this is the second 

13 item. What was the first item?

14 MR. KATZ: Item 7.

15 CHAIR MUNN: Item 7? All right.

16 MEMBER ZIEMER: I do know what 

17 Wanda said is very correct. Almost all the 

18 university reactors add high enrichment. This 

19 was true at our campus, where we have a very 

20 small reactor with 93 percent enrichment.

21 CHAIR MUNN: Right, yes.
116 

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1 MEMBER ZIEMER: Yes, and that's 

2 why all these university reactors have had to 

3 change over in recent years. They're 

4 concerned about this high enrichment stuff 

5 being around on campuses.

6 CHAIR MUNN: All right. We will 

7 keep that one in abeyance for --

8 MR. MARSCHKE: Abeyance or keep it 

9 open?

10 CHAIR MUNN: Well, we'll keep it 

11 open. Keep it open for the moment.

12 MEMBER ZIEMER: Just leave it 

13 until this afternoon.

14 CHAIR MUNN: Yes. Correct. We're 

15 just leaving it for Steve Ostrow this 

16 afternoon.

17 MEMBER ZIEMER: We don't have to 

18 enter anything until we're done later today.

19 CHAIR MUNN: All right. Then our 

20 next item will be item No. 10.

21 MR. MARSCHKE: And 10 is an 
117 

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1 observation.

2 "SC&A finds that the OTIB 

3 rationale for selecting the four 

4 representative reactor cases and the seven 

5 decay times to be reasonable."

6 The NIOSH response is no response 

7 needed.

8 DR. MAURO: Closed?

9 CHAIR MUNN: Closed.

10 MEMBER ZIEMER: Closed.

11 CHAIR MUNN: Any objection on the 

12 phone?

13 MEMBER LEMEN: Dick.

14 CHAIR MUNN: Item 11 is a finding.

15 MR. MARSCHKE: We needed the 

16 source terms, reactor source term.

17 "SC&A notes that the number of 

18 nuclides included in table A3 for the ATR is 

19 234, table A4 for the FFTF, 242, table A5 for 

20 the N Reactor, 268. Then, in table A6, for 

21 the TRIGA, 273. The majority of these 
118 

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1 nuclides are common to all reactor types, and 

2 the total number of different radionuclides 

3 listed in these tables is 277. SC&A would 

4 like to see a listing of 738 radionuclides for 

5 which the OTIB states dose conversion factors 

6 were obtained."

7 The NIOSH response, "The text will 

8 be revised to clarify that nuclides that 

9 showed zero activity as of 10 days decay were 

10 not included in table A3 through A6. A list 

11 of the 738 nuclides can be provided."

12 CHAIR MUNN: Can we ask that they 

13 will be provided in the document?

14 MEMBER ZIEMER: Well, I would 

15 raise a question as to why we need to provide 

16 the list of nuclides for which the activity is 

17 zero. Is that just to confirm that --

18 CHAIR MUNN: That they have 

19 touched all the bases; they know it is there.

20 MEMBER ZIEMER: Or they have 

21 considered it? It seems a little superfluous 
119 

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1 on the surface, but maybe there is a reason 

2 that maybe we should --

3 MR. HINNEFELD: If we're going to 

4 edit the document anyway, we can add text to 

5 say here's a list of all 738 radionuclides 

6 that were analyzed.

7 MEMBER ZIEMER: That are 

8 considered, and the ones with zero activity --

9 MR. HINNEFELD: I mean it's 

10 essentially the same edit.

11 MEMBER ZIEMER: Yes.

12 MR. HINNEFELD: If you're going to 

13 say that you're going to edit the document to 

14 specify the document reflects less than zero 

15 after 10-day decay -- weren't included in 

16 these tables.

17 DR. MAURO: And here's a table 

18 that shows it.

19 MR. HINNEFELD: The appendix shows 

20 all the radionuclides analyzed.

21 MEMBER ZIEMER: I was just 
120 

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1 thinking you have got an appendix with 500 

2 nuclides that aren't included.

3 MR. MARSCHKE: What's the 

4 definition of zero? Because when you do the 

5 decay equation, you go down to 10 to the 

6 minus --

7 MR. HINNEFELD: Well, I don't 

8 know. I suppose there's --

9 MEMBER ZIEMER: Well, this is for 

10 all practical purposes, isn't it?

11 DR. MAURO: Well, the table is 

12 there. It ought to probably be put in.

13 MEMBER ZIEMER: All right.

14 DR. MAURO: There will be a little 

15 asterisk next to the zero.

16 MEMBER ZIEMER: Less than.

17 MR. HINNEFELD: Yes, we could put 

18 a less than some value, if there's some 

19 value --

20 DR. MAURO: That is the easiest 

21 way to close this. It's not burdensome, I 
121 

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1 mean.

2 MR. HINNEFELD: You can provide 

3 the list of nuclides. You can make that an 

4 appendix to the document.

5 DR. MAURO: Recommend in abeyance 

6 until that list is provided?

7 CHAIR MUNN: In abeyance, yes.

8 MEMBER ZIEMER: The response is 

9 certainly adequate, yes.

10 CHAIR MUNN: Yes.

11 In abeyance, awaiting revision, 

12 ought to be adequate for it, shouldn't it?

13 Will it help or will it be a 

14 distraction if, while Steve is typing, we go 

15 ahead and read the next item? Is that 

16 acceptable to everybody? While Steve's 

17 typing, let's go on. Will that bother you, 

18 Steve, if I'm reading?

19 MR. MARSCHKE: No.

20 CHAIR MUNN: All right. Then 

21 let's go to item 12, finding -- observation. 
122 

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1 Oh, it's an observation. Sorry. Reactor 

2 source term.

3 "Based on an independent 

4 assessment, SC&A agrees with the list of 

5 radionuclides presented by NIOSH in table D1, 

6 although NIOSH does not provide an explanation 

7 for the derivation of the relative exposure 

8 activity fractions at that table."

9 NIOSH response, "We will elaborate 

10 on the method used to calculate the values in 

11 table D1. The nuclides that contributed at 

12 least 1 percent of dose to any organ or to 

13 effective dose for at least one of the three 

14 solubility categories retained the 

15 dosimetrically-significant nuclides. The --

16 results for each reactor and decay time were 

17 then compiled for each set of dosimetric --

18 nuclides, and the values renormalized. The 

19 data in table D1 are those renormalized values 

20 multiplied by the exposure fractions found in 

21 DOE Standard 1027. The exposure fractions are 
123 

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1 provided in table D1."

2 I read the first sentence to mean 

3 that there will be an addition, an elaboration 

4 to the table, to the methods in this table, 

5 which would put it in abeyance. Am I reading 

6 that correctly?

7 DR. ULSH: Well, it would be as 

8 long as that response is agreeable.

9 CHAIR MUNN: Yes.

10 MEMBER ZIEMER: Yes -- provided an 

11 explanation of the derivation of the fraction, 

12 and then I think that does it.

13 CHAIR MUNN: I can't see any 

14 problem.

15 On the phone, any feedback? In 

16 abeyance all right, awaiting revision?

17 MEMBER ZIEMER: It sounds like a 

18 yes to me.

19 (Laughter.)

20 CHAIR MUNN: Yes, I think I'll 

21 take that as a yes.
124 

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1 MEMBER ZIEMER: Nodding their 

2 heads vigorously.

3 (Laughter.)

4 CHAIR MUNN: Yes, I think so. 

5 Let's hope.

6 And while Steve is typing 12, we 

7 will go to 13, finding, reactor source term.

8 "SC&A reviewed the list of 17 

9 radionuclides in table E1 and believes that 

10 four radionuclides, Pr-143 and cobalt-60, 

11 Te-132, and Nd-147 should be added using a 

12 quantitative criterion. Effective doses 

13 greater than 1 percent sum of the effective 

14 doses for all radionuclides instead of the 

15 unjustified qualitative criteria used by 

16 NIOSH."

17 NIOSH response, "We will agree and 

18 we will make this change."

19 MEMBER ZIEMER: That sounds to me 

20 like it's resolved.

21 DR. MAURO: In abeyance.
125 

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1 CHAIR MUNN: In abeyance, awaiting 

2 revision.

3 The next item 14, finding, reactor 

4 source term.

5 "SC&A questions averaging the 

6 source terms over the four reactor types to 

7 produce the `default source terms' in table 

8 E1, since it is expected that in most cases 

9 the dose reconstructor would know which type

10 of reactor or reactor fuel produced the 

11 claimant's exposure."

12 The NIOSH response, "The data in 

13 table E1 are not averaged across the four 

14 reactors. The comment pertains to table E2. 

15 We do not agree that DRs will know what 

16 reactor to select in most cases. The purpose 

17 for averaging across the four representative 

18 reactors was to create a single hypothetical 

19 representative reactor appropriate for all 

20 sites. The four representative reactors were 

21 selected because they encompass the wider 
126 

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1 range of reactor types, themselves selected to 

2 cover a wide range of fuel types, enrichment, 

3 and burnup."

4 DR. MAURO: Do you want me to take 

5 the first shot at this one? I think we have 

6 an issue.

7 CHAIR MUNN: You may, or we can 

8 wait for Steve.

9 DR. MAURO: Yes, okay. My sense 

10 is whenever you are in a circumstance like 

11 this in the past, you always go with the 

12 limiting one. If you don`t know which reactor 

13 type you're dealing with, and you have four 

14 different mixes, you pick the mix that is most 

15 limiting to your particular cancer.

16 CHAIR MUNN: Right.

17 DR. MAURO: That would be the way 

18 I would have expected it, but it was not. 

19 There may be more to the story, and certainly 

20 we will hear from Steve on that. But my first 

21 reaction would be you don't go with the 
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1 average. You go with the one that is limited.

2 MEMBER ZIEMER: Well, the other 

3 thing, though, you may get different, for each 

4 reactor by itself may not give the limiting 

5 thing. It looks like they're taking the 

6 average of the fuel types and enrichments and 

7 burnups, but any subcombination of that may 

8 not give you the limiting dose. So I think we 

9 need to ask that. Do you know what I'm 

10 saying?

11 DR. MAURO: Okay.

12 MEMBER ZIEMER: Do you know what 

13 I'm saying? In other words, by putting them 

14 together, you may be -- let's say you have one 

15 by itself, and maybe it has the maximum 

16 enrichment, but its other parameters are such 

17 that it wouldn't give you a limiting dose.

18 DR. MAURO: Right.

19 MEMBER ZIEMER: Do you see what 

20 I'm saying?

21 DR. MAURO: So in effect, what 
128 

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1 you're really saying, listen, whenever this 

2 particular strategy, is that the bounding 

3 strategy, given the --

4 MEMBER ZIEMER: Yes, right. In 

5 other words, maybe putting them together pulls 

6 up other -- you know, here's one that is 

7 higher power, but it is a lower enrichment.

8 DR. MAURO: Right. And when you 

9 combine them all --

10 MEMBER ZIEMER: Right.

11 DR. MAURO: -- you come up with 

12 the most limiting.

13 MEMBER ZIEMER: So I think we need 

14 to hear from Steve on how he understood that 

15 to be.

16 DR. MAURO: Okay.

17 MEMBER ZIEMER: That would be one, 

18 I think, that is certainly open to debate. I 

19 don't think a priori picking one in my mind 

20 would necessarily give you the maximum dose.

21 DR. MAURO: But I would argue 
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1 that --

2 CHAIR MUNN: Or the appropriate 

3 dose.

4 DR. MAURO: Let's say it turns out 

5 that there's some kind of amalgam that creates 

6 a set that will be more limiting than any one 

7 set by itself.

8 MEMBER ZIEMER: Yes.

9 DR. MAURO: But that would not be 

10 reality. See I would argue that you could do 

11 that, but that's not a real situation. A real 

12 situation is it's one of those four; we just 

13 don't know which one. So in my mind, if you 

14 have four that it might be, but you don't know 

15 which one; you pick the one that is limiting 

16 for that cancer.

17 MEMBER ZIEMER: And maybe NIOSH 

18 would have to come back on that because you 

19 might find that the average gives you a 

20 greater dose than any of the single ones by 

21 themselves. I don't think we know in advance 
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1 that that wouldn't be the case. I think we 

2 need to hear the debate on this one.

3 DR. MAURO: Yes.

4 CHAIR MUNN: Yes, that's a 

5 possibility that there's more to it than meets 

6 the eye.

7 DR. ULSH: Well, we had Bob Burns 

8 on the line earlier.

9 Bob, are you still out there?

10 DR. BURNS: I am.

11 DR. ULSH: Now do you want to hear 

12 from Bob now or do you want to wait for Steve?

13 MEMBER ZIEMER: Well, I think 

14 both, but maybe Steve needs to hear the 

15 debate, though.

16 DR. ULSH: So wait until the 

17 afternoon?

18 MEMBER ZIEMER: Maybe we can get a 

19 preliminary understanding. Bob, on the 

20 averaging, does that tend to take care of 

21 extremes that -- well, tell us what it does.
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1 DR. BURNS: Well, I guess a couple 

2 of things. One, there were several persons 

3 involved in compiling this OTIB. I am just 

4 one of them, and I am not the internal 

5 dosimetrist of the group.

6 But I would comment that, in 

7 addition to averaging across the four 

8 reactors, there were other issues at play here 

9 that result in the representative ratios 

10 being, in our view -- we have to be careful 

11 using words like conservative and bounding, 

12 but the way the data are normalized, the way 

13 we did not account for power history, et 

14 cetera, the numbers are so conservative to 

15 begin with that that was part of the rationale 

16 for choosing to average across the reactors, 

17 rather than try to pursue what's being 

18 discussed here, which is select the limiting 

19 case, besides the fact of the complexity of 

20 doing that, trying to look at all the 

21 different organs and all the different 
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1 cancers, et cetera.

2 DR. MAURO: Okay, I understand 

3 what I think -- so it was not what you 

4 suspected it might be, where they went and 

5 picked the worst mix.

6 CHAIR MUNN: Right.

7 MEMBER ZIEMER: Well, I don't 

8 think they did pick the worst mix, but they 

9 averaged them.

10 DR. MAURO: They averaged them.

11 DR. BURNS: Right.

12 MEMBER ZIEMER: Some other factors 

13 that come into the dose --

14 DR. MAURO: Well, I guess, in the 

15 end, what you're saying, what I'm hearing is, 

16 to simplify the problem --

17 DR. BURNS: Right. We didn't want 

18 to make it so complex that the DRs would just 

19 throw their hands up and say, "Give me a 

20 break."

21 DR. MAURO: I understand. At the 
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1 same time, though, the fact that you don't 

2 know what reactor it is, you also want to be 

3 pretty confident that you're not selling the 

4 guy short.

5 DR. BURNS: Exactly. We had a lot 

6 of discussion on that topic, and some of the 

7 later comments speak to it as well. Just the 

8 way the data are normalized and renormalized, 

9 each time you do that, you are just -- I hate 

10 to say we're overstating things, without 

11 something quantitative to fall back on, but we 

12 didn't believe for a minute we were 

13 understating any doses.

14 DR. MAURO: Yes.

15 DR. ULSH: So the crux of the 

16 issue is going to be to Steve and SC&A, except 

17 that the way they are proposing to do it is, 

18 in fact, conservative and you won't be 

19 shortchanging the DRs.

20 DR. MAURO: There is enough built 

21 in. There's enough built in to the overall 
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1 process where, even though they are not 

2 picking the -- because it's -- I could 

3 understand the dilemma. You've got four 

4 different mixes, and you don't know which one 

5 to use. And let's say you're dealing with a 

6 particular type of cancer. Which mix is going 

7 to be limiting is going to be a process that 

8 could be pretty -- although I have seen you 

9 guys make workbooks that do things much more 

10 complicated than this.

11 (Laughter.)

12 But, fine. We will wait for Steve 

13 and see what he has to say.

14 MEMBER ZIEMER: Well, the only 

15 other comment I was just going to make is that 

16 this may be one of those where you guys would 

17 have to study in more detail what the impact 

18 of that approach is. I mean they have 

19 explained now why they did it, but we need to 

20 hear from Steve also, I think.

21 DR. MAURO: One way to achieve 
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1 closure on something like this, in principle, 

2 is, okay, here's the mix you're going to use 

3 for this person who has a particular cancer. 

4 The question becomes, if I were to not use 

5 that, but use type 1 or type 2 or type 3 or 

6 type 4 mix, as opposed to this amalgamated 

7 mix, is it possible to come up with a higher 

8 dose for that person who got cancer? If the 

9 answer to that is yes, we've got a problem.

10 MR. KATZ: The bottom line is, is 

11 their answer conservative still? You are not 

12 trying to maximize conservatism. You just 

13 have to be --

14 DR. MAURO: Well, no, no, what I 

15 am saying is the fact that you don't have a 

16 particular piece of information what reactor 

17 this guy was working at, for some reason you 

18 don't have that information, then he is 

19 penalized because you lack that information. 

20 If you did have that information and it turned 

21 out to be that reactor, he would get a higher 
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1 dose. And I'm troubled by that.

2 Do you see my logic?

3 MEMBER ZIEMER: Well, I don't 

4 think we know that a priori. The other thing, 

5 it appears to me, I may not have a complete 

6 feel for this, but if you're the claimant and 

7 let's say we know what reactor it is, you 

8 still have the issues of that reactor when, in 

9 the course of, you know, when you have the 

10 whole power history thing, which they are not 

11 using, and by not using the power history, 

12 that changes, but even getting the power 

13 history itself and applying it to an 

14 individual, so every time they do this, 

15 they've got to go back and get the power 

16 history of a reactor and at some point --

17 DR. MAURO: But what I heard from 

18 the earlier answer is you are at a point --

19 power history where you have reached an 

20 equilibrium for a --

21 MEMBER ZIEMER: Well, I don't know 
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1 that a priori for a given claim, do I?

2 DR. MAURO: No, I guess I thought 

3 he said lookup tables with --

4 MEMBER ZIEMER: Oh, yes, those 

5 might be.

6 DR. MAURO: -- were insensitive to 

7 the power level or the power history. At some 

8 point, the strontium-90 and the cesium-137 

9 concentration in the core and in the coolant 

10 are going to not change because they have 

11 achieved equilibrium.

12 MEMBER ZIEMER: Right, right, but 

13 if you do the individual case, you may find 

14 that -- in other words, they are using a 

15 maximizing assumption in that case. Do you 

16 see what I'm saying?

17 DR. MAURO: Yes.

18 MEMBER ZIEMER: If I have your 

19 case, and you worked on this reactor, and I 

20 looked and I said, well, you know, that 

21 reactor has only been going for one month or 
138 

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1 something --

2 DR. MAURO: That short a time 

3 period may create a ratio which is more 

4 conservative than, let's say, the one they are 

5 using.

6 MEMBER ZIEMER: Oh, yes, because 

7 the fission products build -- I mean, if 

8 you're at equilibrium, if that's what they 

9 did, then you have maximized something like 

10 that --

11 DR. MAURO: Well, you maximize the 

12 concentrations, but as you create a ratio, 

13 that's the worst. Do you see? Remember, 

14 you're measuring the gross beta-gamma in the 

15 urine. You're going to say, well, what's the 

16 mix? Well, we are going to assume the mix is 

17 the mix that's in the reactor at equilibrium 

18 for that kind of reactor. That's what I 

19 understand.

20 Now what I just heard is that that 

21 mix may -- it changes as a function of time.
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1 MEMBER ZIEMER: Oh, it changes, 

2 yes, of course.

3 DR. MAURO: Maybe the mix, though 

4 you may have the max inventory, that doesn't 

5 mean you have the most limiting ratio.

6 MEMBER ZIEMER: Right, and then 

7 the exposure may occur at some different time 

8 after that, yes.

9 DR. MAURO: Yes.

10 MEMBER ZIEMER: So there's a lot 

11 of --

12 DR. MAURO: Yes. Well, now you 

13 just tied my brain into a knot, and I don't 

14 know.

15 MEMBER ZIEMER: Yes, and I'm just 

16 talking in the dark here because I don't know 

17 exactly what --

18 DR. MAURO: Yes, and I'm a 

19 biologist, so leave me alone, okay?

20 (Laughter.)

21 MEMBER ZIEMER: We don't even know 
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1 if we're talking about the right stuff.

2 (Laughter.)

3 CHAIR MUNN: All right. We'll 

4 dump all this on Steve when he gets here.

5 MEMBER ZIEMER: I think Steve has 

6 to look at this. Just on the surface, it just 

7 looks to me like it may be something that, 

8 even knowing Steve's -- or having Steve's 

9 reaction, we may want to formalize it.

10 DR. MAURO: We had better look at 

11 this.

12 MEMBER ZIEMER: Yes, yes.

13 CHAIR MUNN: Good. All right. We 

14 are ready to move on to 15.

15 MR. KATZ: So we're going to 

16 revisit this 14 with Steve?

17 CHAIR MUNN: Yes, we will revisit 

18 14 --

19 MEMBER ZIEMER: He's going to come 

20 back this afternoon.

21 CHAIR MUNN: -- when Ostrow is 
141 

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1 here.

2 MR. MARSCHKE: That's the third 

3 one?

4 MR. KATZ: Yes.

5 CHAIR MUNN: It is.

6 Now item No. 15, finding, reactor 

7 source term.

8 "Some radionuclides were not 

9 released in significant quantities from all 

10 four reactor types. The average source term 

11 for those radionuclides is listed in table E2. 

12 The default source terms underestimates the 

13 values given in table E1, simplified source 

14 terms."

15 NIOSH response, "See comment 14. 

16 The data in table E1 are not averaged across 

17 the four reactors. The comment pertains to 

18 table E2. We do not agree that DRs will know 

19 what reactor to select in most cases. The 

20 purpose for averaging across the four 

21 representative reactors was to create a single 
142 

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1 hypothetical representative reactor 

2 appropriate for all sites."

3 There's no reason to read that all 

4 over again. It's the same answer as No. 14. 

5 And I'm assuming that we will, therefore, add 

6 that to the list that we are going to include 

7 in our discussion with Ostrow.

8 MR. MARSCHKE: Wanda, do you want 

9 to add it to the list or do you want to have 

10 it addressed in, change the status to 

11 addressed in comment 15 or comment 14? We 

12 could change the status and say that this is 

13 actually a duplicate of 14, and the response 

14 will be addressed in the response for comment 

15 14.

16 DR. ULSH: Well, do you agree that 

17 if we come to closure on comment 14, that 

18 would necessarily address this one?

19 CHAIR MUNN: Well, source term is 

20 -- are we assuming that the only source term 

21 are the releases that are referenced in 15? 
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1 Fourteen says source term. Fifteen says, 

2 "Some radionuclides were not released in 

3 significant quantities from all four reactor 

4 types."

5 MR. MARSCHKE: These are the two 

6 tables that they're talking about, by the way, 

7 tables E1 and E2. But, see, basically, table 

8 E1 has data for four different types of 

9 reactors, the ATR, the FFTF, the N Reactor, 

10 and TRIGAs; whereas, table E2, basically, just 

11 goes through and adds all those values up and 

12 divides by four, which I don't know is the 

13 appropriate way to do that because if you look 

14 at, for example, iron-55, there's only one 

15 value in iron-55. And it appears what they 

16 did was they took that one value and divided 

17 it by four and came up with a value for table 

18 E2, which I don't know if that's really a 

19 claimant-favorable way to do that.

20 But these are the two tables that 

21 are in discussion.
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1 CHAIR MUNN: It's difficult for me 

2 to identify whether there is -- there was a 

3 difference in the thinking process of the 

4 original reviewers with respect to source 

5 terms or released radionuclides. Since we're 

6 talking about internal dose here, one would 

7 seem that that source terms would all be, 

8 quote, "released radionuclides." So it is 

9 difficult to identify, in my mind, what the 

10 difference in the two findings is.

11 MEMBER ZIEMER: Well, one is that 

12 they have indicated that there are some 

13 nuclides that are missing, it appears. Or 

14 what does it say?

15 CHAIR MUNN: They are not released 

16 in significant quantities from all four 

17 reactor types.

18 MR. MARSCHKE: I think that, 

19 Wanda, to me, that refers to the fact that, 

20 for example, U-155, for the ATR, there's no 

21 value here.
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1 CHAIR MUNN: Yes.

2 MR. MARSCHKE: For the FFTF, there 

3 is a value. Iron-55 triggers the only one 

4 that has a value for it. So it's saying that 

5 for ATR, the FFTF and the N Reactor, iron-55 

6 is not released in any significant quantities.

7 DR. ULSH: It seems to me that we 

8 don't necessarily have to demonstrate that 

9 each cell here is conservative. In other 

10 words, for each radionuclide, this provides a

11 conservative case. What we have to show is 

12 that sum total, treating people this way, will 

13 not result in a lower internal dose than sum 

14 total for each of these different reactor 

15 types.

16 DR. MAURO: I have got a problem. 

17 This is the core inventory, right? What are 

18 we looking at? What is that?

19 MR. MARSCHKE: This is source 

20 term. This is released.

21 DR. MAURO: Oh, this is released 
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1 to the coolant? Is that what we're talking 

2 about?

3 MR. MARSCHKE: This is release for 

4 intake calculation.

5 DR. MAURO: Yes, I just wonder, 

6 what are the units of the numbers that we're 

7 looking at?

8 DR. BURNS: Where they're 

9 dimensional, it's because they're normalized, 

10 but that's the product of activity and the DOE 

11 standard release fractions. Those are being 

12 treated as intake fractions.

13 DR. MAURO: Okay. Let me tell you 

14 what I'm thinking.

15 DR. BURNS: Okay.

16 DR. MAURO: Whenever I used to do 

17 dose calculations from radionuclides released 

18 from a reactor, my starting point was always 

19 the primary coolant, and the mix of 

20 radionuclides in the primary coolant was 

21 dramatically different than the mix of 
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1 radionuclides that were in the core because 

2 some radionuclides leave much more rapidly. 

3 Cesium leaves more rapidly than strontium.

4 Now that being the case, how is 

5 that -- and the reality is, of course, any 

6 workers that are exposed are going to be 

7 exposed to what is in the primary coolant. 

8 That leaks out, and somehow they inhale it. I 

9 presume that is the process we are in now.

10 Maybe you could just help me out 

11 because I sort have taken some steps backward. 

12 But how is that taken into consideration? 

13 The reality of the situation is it's the 

14 primary coolant and the mix that is in the 

15 primary coolant that is at play here. How is 

16 that sort of captured in the process here?

17 DR. BURNS: The short answer is 

18 that was the intent when we applied the 

19 release fractions, I believe they're called, 

20 from the DOE 1027 standard. We were trying to 

21 address those mechanisms.
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1 DR. MAURO: Oh, so the release 

2 fraction is this multiplier on the core 

3 inventory that says, what fraction that's --

4 has the potential to escape?

5 DR. BURNS: That's correct. 

6 What's available --

7 DR. MAURO: Thank you.

8 DR. BURNS: Right.

9 DR. MAURO: I'm okay again.

10 DR. BURNS: Okay. Then, again, we 

11 treated those as intake fractions.

12 DR. MAURO: I got you. Okay. I'm 

13 sorry for the little --

14 MEMBER ZIEMER: Well, let me ask 

15 one additional question as a followup. The 

16 primary coolant also, typically, contains 

17 activation products which are not from the 

18 fuel but are from components. Is that in the 

19 mix?

20 DR. BURNS: The short answer would 

21 be, I guess the short answer would be no, 
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1 since there's no good way to model that. 

2 What's modeled is the fuel and the cladding 

3 and any associated impurities. But if there's 

4 other stuff, if you've got makeup water that's 

5 mineralized or something like that, I've got 

6 no good way to account for that other than 

7 attempting to do it through the impurities I 

8 included in the fuel and cladding 

9 compositions.

10 MEMBER ZIEMER: Yes. Well, that's 

11 kind of a separate question.

12 I think, John, what I was 

13 understanding from your earlier question was 

14 why wouldn't you take the highest value, let's 

15 say, barium, look at everything, and pick the 

16 highest value, and put that in the default?

17 DR. MAURO: No, I was saying --

18 MEMBER ZIEMER: Wasn't that what 

19 you were saying originally?

20 DR. MAURO: No. I was saying that 

21 this is sort of like some kind of hybrid.
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1 MEMBER ZIEMER: No, I understand 

2 that, but --

3 DR. MAURO: And this doesn't 

4 really exist in reality.

5 MEMBER ZIEMER: Right, and your 

6 original question was -- it sounded like it 

7 was why wouldn't you just take any nuclide and 

8 say, okay, what's the highest that you get 

9 from anything, and put that in --

10 DR. MAURO: No, no, I was saying 

11 that, no, what you would do is, if you have a 

12 guy, and you've got his gross beta-gamma, and 

13 you know he works at an ATR, well, of course, 

14 you would use this mix. And, of course, we 

15 have the burnup.

16 MEMBER ZIEMER: But if you don't 

17 know where he works --

18 DR. MAURO: If you don't know, you 

19 wouldn't know here. Why don't you, if you 

20 don't know, which is the one that is the worst 

21 one.
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1 MEMBER ZIEMER: That's what I was 

2 just saying.

3 DR. MAURO: Not the single isotope 

4 which --

5 MEMBER ZIEMER: No, no.

6 MR. HINNEFELD: So you're saying 

7 run the calculation four times?

8 DR. MAURO: Yes.

9 MR. HINNEFELD: Essentially, as if 

10 he worked at ATR; run it as if he worked at 

11 FFTF, and --

12 DR. MAURO: Right, and which is 

13 the worst one?

14 MR. HINNEFELD: Run the ones four 

15 times, and whichever one comes out the best 

16 for the claim, you do that?

17 DR. MAURO: That's what I had in 

18 mind. I'm not saying I can tell. There may 

19 be good reason not to do that, but that seems 

20 to be -- I realize that you have been in a lot 

21 more complex situations than this and done 
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1 that, where you have say, just like you have 

2 different forms of the isotopes. You run 

3 every isotope and figure out which is the one 

4 that is most limiting for that cancer.

5 So, yes, it would mean, if you 

6 didn't know, you would have to do it four 

7 times. But take this. It's not apparent to 

8 me why the average of them all is, in fact, 

9 claimant favorable, in fact, it may not be 

10 claimant favorable if one of them really is a 

11 bad actor.

12 DR. ULSH: If we could demonstrate 

13 one time, if we could take this table and run 

14 it -- I don't know; I'm thinking on the fly 

15 here, which is always dangerous -- demonstrate 

16 that for each cancer this mix would give you a 

17 better result than any of the individual ones, 

18 then you would be okay with that? 

19 DR. MAURO: Then you've got it, 

20 sure.

21 DR. ULSH: I mean I think the 
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1 reason that we are doing this is so that we 

2 don't have to run every case four times, 

3 right, Bob?

4 DR. BURNS: Right. And again, it 

5 was keep, since we felt we were conservative 

6 to begin with, we just didn't want to keep 

7 piling on and create a document that was just 

8 overly complex.

9 DR. ULSH: So the question it 

10 seems that you have here is does this table E2 

11 give you a result that is always conservative, 

12 given the plausible alternatives here?

13 DR. MAURO: Yes.

14 DR. ULSH: That's the question?

15 DR. MAURO: Yes.

16 CHAIR MUNN: That it is reasonably 

17 conservative, not necessarily the most 

18 conservative.

19 DR. ULSH: Well, by "reasonable," 

20 what I think we could say is, is it better 

21 than an ATR or an FFTF or any of the other 
154 

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1 choices, not necessarily each individual 

2 radionuclide, but as a group?

3 DR. MAURO: As a group, of course.

4 DR. ULSH: Right?

5 CHAIR MUNN: Yes.

6 MR. MARSCHKE: Wouldn't the 

7 selection, another way to do it, I mean 

8 couldn't you make one run-through and look and 

9 see which type cancer is associated with which 

10 of the four reactor types, and wouldn't that 

11 always hold? Like if -- I don't know -- bone 

12 cancer was always, or ATR was always the 

13 reactor you picked, but you had bone cancer, 

14 or --

15 DR. MAURO: If you don't know the 

16 reactor. But you know the reactor.

17 MR. MARSCHKE: If you know the 

18 reactor, yes, you can pick the reactor. But 

19 if you know the cancer type, couldn't you 

20 basically go backwards and look and see, okay, 

21 this cancer type, and have that as 
155 

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1 basically -- I mean would that change? 

2 Wouldn't that change? Wouldn't that stay the 

3 same from claimant to claimant and just be 

4 dependent upon the type of cancer that they 

5 had?

6 MR. HINNEFELD: It could 

7 theoretically change based on time since 

8 exposure to diagnosis.

9 DR. ULSH: It's probably not as 

10 sensitive as I'm talking about here, but --

11 MR. HINNEFELD: And, in fact, if 

12 it changes, if any of these comparisons change 

13 based on exposure time, time from exposure to

14 diagnosis, theoretically, you almost can't do 

15 any comparisons ahead of time.

16 DR. MAURO: Let me show you an 

17 example. In general, strontium-90 is an 

18 important contributor to bone cancer. So in 

19 this situation, now, of course, this ratio is 

20 indexed of intake for the trigger SS power is 

21 7.9 minus 2 while your strontium-90 number at 
156 

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1 1 meter is 4 minus 2. It's about 32 -- so, I 

2 mean, just my intuition says it seems that you 

3 would get a better deal if you assumed this 

4 for the guy you didn't know. That's just 

5 looking at strontium-90, of course. 

6 Strontium-90 is an important contributor to 

7 the bone dose, as you know.

8 DR. ULSH: Right. Exactly. But 

9 what we have to show is that, for each of 

10 these things, added up together --

11 DR. MAURO: Yes.

12 DR. ULSH: -- you get the worst 

13 deal here than if you took --

14 DR. MAURO: But would you agree it 

15 gets a better deal if you defaulted to this in 

16 that case? A fellow with bone cancer and just 

17 looking at these numbers, this is the highest 

18 one of all, the high strontium, this one for 

19 this one because of that.

20 Now if it turns out you did it 

21 this way and he did it this way, he gets a 
157 

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1 better deal out of this, don't you think we 

2 should use this?

3 DR. ULSH: If we find a case 

4 where, say, bone cancer, where a TRIGA is a 

5 plausible alternative and this gives him a 

6 lower number than a TRIGA, then we've got a 

7 problem.

8 DR. MAURO: That is all I'm 

9 saying.

10 DR. ULSH: Right.

11 MR. HINNEFELD: Well, I don't know 

12 that I want to sign up to saying necessarily.

13 PUBLIC PARTICIPANT: I heard the 

14 number of radionuclides has already been 

15 reduced and simplifying assumptions have 

16 maximized the numbers already.

17 DR. BURNS: Right. That's the 

18 issue. I suspect if you picked one of the 

19 reactors individually, you could get a bigger 

20 number than you would from the average, but 

21 that doesn't mean the average still isn't 
158 

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1 sufficiently conservative.

2 MR. HINNEFELD: The 

3 transcriptionist needs to know who commented 

4 before Bob.

5 DR. BURNS: Oh, I'm sorry.

6 MR. HINNEFELD: Would the person 

7 who commented before Bob please identify 

8 yourself for the transcriptionist?

9 CHAIR MUNN: Who was the woman --

10 MR. KATZ: The woman who 

11 commented, can you please let us know who you 

12 are?

13 (No response.)

14 A ghost in the system.

15 MR. HINNEFELD: Apparently. We're 

16 going to have to fix that. Elyse, you're 

17 going to have to let us know.

18 I'm not ready to sign up to just 

19 saying here in this meeting that in this 

20 instance that selection would have to be made 

21 for that one reactor. I think the question is 
159 

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1 is the dose reconstruction sufficiently 

2 conservative so that no one is shortchanged?

3 CHAIR MUNN: Yes.

4 MR. HINNEFELD: And if that is the 

5 case, based on the way these things were 

6 developed in the first place and the 

7 assumptions made in dose reconstruction, 

8 because, let's face it, you know, a mixed 

9 fission product internal dosimetry question. 

10 It's just abominably complex.

11 So if you make enough simplifying 

12 assumptions at the start to arrive at these 

13 ratios, so that you're confident, no matter 

14 what happened, you have a bounding dose for 

15 these people, then I don't think you have to 

16 choose individual reactors.

17 DR. MAURO: Okay. I'll take it a 

18 step further then. Then just forget about the 

19 -- see, what you just said is --

20 MR. HINNEFELD: The bad thing is 

21 the visual -- I understand completely what 
160 

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1 you're saying. I understand that part.

2 DR. MAURO: If this wasn't so 

3 conservative already, but you're going to use 

4 it when you know it's that, then later you're 

5 going to say, well, listen, this is good 

6 enough. Then this should be good enough 

7 always.

8 MR. HINNEFELD: If the argument I 

9 just made is a good argument, then it should 

10 be your only option.

11 DR. MAURO: The only option.

12 MR. HINNEFELD: That should be 

13 your only option.

14 DR. MAURO: We're in agreement 

15 with that, too. Because once you make that 

16 case, that that --

17 MR. HINNEFELD: Once you provide 

18 the option of doing one or the other, I think 

19 you've done --

20 DR. MAURO: You're going to put 

21 yourself in the situation --
161 

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1 MR. HINNEFELD: Then your argument 

2 is hard to speak against.

3 DR. MAURO: We understand each 

4 other.

5 MEMBER ZIEMER: And you have to be 

6 careful not to select one isotope because the 

7 other ones --

8 MR. HINNEFELD: Right.

9 DR. ULSH: I just got a -- Elyse 

10 doesn't know who that speaker was.

11 MR. HINNEFELD: Well, that's 

12 interesting.

13 MEMBER ZIEMER: It sounded like it 

14 was one of your staff people at ORAU, but 

15 apparently not.

16 MR. HINNEFELD: No one who 

17 identified themselves earlier.

18 MR. KATZ: I hope she's okay if 

19 she's not able to respond now.

20 MR. HINNEFELD: I hope she's just 

21 shy.
162 

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1 MEMBER ZIEMER: So we're going to 

2 hold this?

3 CHAIR MUNN: We're going to hold 

4 this one --

5 DR. MAURO: Absolutely.

6 CHAIR MUNN: -- to discuss, both 

7 14 and 15 will be discussed with Ostrow when 

8 he arrives.

9 All right. Then that takes us 

10 down to 16. Finding, source term 

11 verification.

12 "SC&A agrees that the use of 17 

13 radionuclides with adjusted relative activity 

14 fractions has an increasing effect on the 50-

15 year committed effective doses and organ doses 

16 in relation to the original list. SC&A also 

17 agrees that this increasing effect does not 

18 include the uncertainties listed in OTIB 

19 Section 6.3. As the OTIB does not provide the 

20 quantitative effect of the uncertainties cited 

21 in Section 6.3, SC&A cannot agree with the 
163 

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1 conclusion that the default source term 

2 produces an upper-bound to doses from a non3 specific radioanalysis."

4 And NIOSH responds, "We are in the 

5 process of establishing appropriate methods to 

6 assess the sources of uncertainty identified 

7 in Section 6.3. Response to this comment is 

8 forthcoming."

9 That puts it in abeyance, awaiting 

10 response.

11 MR. MARSCHKE: In abeyance -- in 

12 progress?

13 DR. MAURO: Because we don't 

14 really know what the answer -- if they gave 

15 the answer, and we'd agree with it, I would 

16 say it would be in abeyance. But we don't 

17 really --

18 CHAIR MUNN: So we're in process.

19 DR. MAURO: We are in process, 

20 yes.

21 MEMBER ZIEMER: Right.
164 

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1 MR. MARSCHKE: This was 16?

2 DR. MAURO: Yes.

3 CHAIR MUNN: That's 16.

4 Seventeen, a finding, urinalysis.

5 "SC&A believes that NIOSH did not 

6 present sufficient data to justify the 

7 derivations of values given for the beta 

8 yield, and counting adjustment factors in 

9 table F1. NIOSH should demonstrate using 

10 measurement information that those factors are 

11 acceptable and the best ones to be used."

12 NIOSH responds, "The adjustment 

13 factors are applied as multipliers. So having 

14 factors that are too large is favorable to the 

15 claimant, as long as this is done consistently 

16 across the nuclide mix. (Since everything is 

17 on a normalized basis.) Further, if most of 

18 the nuclides in the mix have similar beta 

19 energies, then the choice of the adjustment 

20 factor becomes largely arbitrary."

21 "We evaluated the importance of 
165 

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1 the values selected for the beta adjustment 

2 factors by using beta efficiency data for a 

3 Protean gas flow counter to assign adjustment 

4 factors to each nuclide. This evaluation 

5 showed trivial differences for the beta 

6 activity fractions for cesium-137 and 

7 strontium-90 given in table 7-1. Thus the 

8 activity fractions for the indicator nuclides 

9 are not highly dependent on the choice of the 

10 beta adjustment factors. This is due to the 

11 similar beta energies from the nuclides in the 

12 mix.

13 "The same logic can be applied to 

14 the gamma calculation. The data in table 7-2 

15 are equally unaffected by the choice of the 

16 beta adjustment factor given in the same 

17 chemical yield for the elements carried 

18 through the mixed fission product separation 

19 method."

20 "Further, since the activity in 

21 the processed samples is nearly all 
166 

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1 strontium-89 plus strontium-90, the choice of 

2 adjustment factor becomes even less of an 

3 issue. The factor would only have a 

4 significant impact if it differed 

5 significantly for the two."

6 Does SC&A have a response to this?

7 DR. MAURO: This may sound 

8 strange, but I think I understand the answer.

9 (Laughter.)

10 DR. BURNS: From both of them at 

11 once.

12 CHAIR MUNN: That sounds good to 

13 me.

14 DR. MAURO: And I sort of 

15 understand that this is driven by 

16 strontium-90, and as long as there isn't a big 

17 -- if that wasn't the case, and there were 

18 other beta-emitters that needed a 

19 substantially different adjustment factor, 

20 yes, there would be a problem. But that's not 

21 the case. I mean, in principle, I understand 
167 

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1 what they are saying, and I agree, but I'm 

2 reaching.

3 MR. MARSCHKE: So we want Joyce or 

4 Steve to look at this?

5 DR. MAURO: Yes, I would feel a 

6 little better.

7 CHAIR MUNN: Do we hold it for 

8 Steve?

9 MR. MARSCHKE: Let me just add 

10 that Steve has only had these for a few days.

11 DR. MAURO: Well, Joyce is going 

12 to be on the line, isn't she?

13 MR. MARSCHKE: No.

14 DR. MAURO: No? Okay.

15 MR. MARSCHKE: Joyce is at the 

16 ICRP meeting. She's not available.

17 And Steve, when he gets here, he 

18 may or may not be able to solve any of these.

19 DR. MAURO: Yes.

20 MR. MARSCHKE: I mean he may just 

21 want more time to look at them himself.
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1 DR. MAURO: Yes.

2 MEMBER ZIEMER: This is a bioassay 

3 issue rather than --

4 DR. MAURO: Yes, that's a Joyce 

5 issue.

6 MEMBER ZIEMER: Yes.

7 DR. MAURO: Yes. The nuclear 

8 engineering side of things maybe, but this is 

9 clearly a Joyce question.

10 MR. MARSCHKE: I think this one, 

11 you know, we can just leave it as open, but it 

12 probably won't be, when Steve gets here, it 

13 probably will still be open.

14 DR. MAURO: Yes.

15 MR. HINNEFELD: Well, I would like 

16 to move it to in progress.

17 DR. MAURO: Yes, that's the way it 

18 should be.

19 MR. HINNEFELD: Because it has 

20 been here.

21 DR. MAURO: That's the way it 
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1 should be. Oh, was it --

2 MR. HINNEFELD: It was open.

3 MR. MARSCHKE: It is open now.

4 DR. MAURO: So now it is in 

5 progress, absolutely. Absolutely.

6 MR. MARSCHKE: And, Wanda, this is 

7 in progress?

8 CHAIR MUNN: Yes.

9 MR. KATZ: We can do that after 

10 Steve, though. At the end of the day, we can 

11 change these all to in progress.

12 MEMBER ZIEMER: But if Steve isn't 

13 able to answer that, it sounds like we need a 

14 response --

15 DR. MAURO: Yes.

16 MEMBER ZIEMER: -- from NIOSH. Or 

17 from SC&A.

18 DR. MAURO: No, no, from SC&A. 

19 Yes. Yes, why this answer is good or not.

20 CHAIR MUNN: We'll see.

21 Item 18, observation, urinalysis.
170 

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1 "SC&A verified the intake 

2 retention factor, IRF, values of table F1 with 

3 a different software package than IMBA. The 

4 only nuclide with a difference is iodine, for 

5 which the IRF is 23 percent higher than the 

6 one derived by SC&A."

7 NIOSH responds, "SC&A did not 

8 document the software or assumptions used to 

9 determine its IRF value for iodine. The value 

10 used in OTIB-54 reflects type F vapor. The 23 

11 percent difference for iodine has no effect on 

12 the indicator nuclide activity fractions given 

13 in table 7-1 and 7-2, as iodines were not 

14 considered through those calculations. This 

15 is favorable to the claimant since including 

16 the iodines would decrease the activity 

17 fractions for the indicator nuclides with a 

18 shorter decay time. It has no effect for the 

19 longer decay times since the iodines have 

20 decayed away."

21 DR. MAURO: I will speak. I feel 
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1 comfortable with this one.

2 First of all, you're using IMBA, 

3 we checked it using some other software 

4 package. IMBA has been validated and proved, 

5 even though Joyce clearly knows there's more 

6 to the story because ICRP is always 

7 researching issues. And the conclusion is, 

8 notwithstanding all that, the approach used is 

9 claimant-favorable. If anything, it is an 

10 error on the high side. I think we close 

11 this.

12 CHAIR MUNN: Is there any 

13 objection from anyone on the telephone to 

14 closing this?

15 Steve, would you --

16 MEMBER LEMEN: No. 

17 CHAIR MUNN: Steve, would you 

18 please say, "SC&A agrees. The Subcommittee --

19 closure."

20 MR. MARSCHKE: Okay. I will.

21 CHAIR MUNN: Next, item No. 19 --
172 

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1 this is finding, urinalysis.

2 "SC&A agrees with NIOSH on the way 

3 the percentage of each radionuclide's 

4 contribution to beta and/or gamma urine counts 

5 should be calculated. SC&A does not agree, 

6 however, that results should be averaged for 

7 the four reactors in order to obtain the data 

8 in tables G1 to G4. For some radionuclides, 

9 such as strontium-90, the relative exposure 

10 activity fractions given in table D1 may 

11 differ by an order of magnitude among reactor 

12 types."

13 The response from NIOSH, "The 

14 Attachment G data are of an interim nature and 

15 serve as the basis for the tables in Section 

16 7. The issue of whether or not to average 

17 across the four reactors is discussed under 

18 comment 14."

19 DR. MAURO: When we resolve 14, 

20 this will be resolved. In other words, there 

21 is complete overlap here.
173 

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1 DR. ULSH: Well, obviously, it's 

2 going to be wait for Steve, right?

3 CHAIR MUNN: This is a wait for 

4 Steve.

5 DR. MAURO: This is still a wait 

6 for Steve, but, I mean, in a way, once we take 

7 care of that, we will take care of this.

8 CHAIR MUNN: More of the same.

9 DR. MAURO: Yes.

10 DR. ULSH: Is that one of those 

11 situations that Marschke mentioned earlier --

12 addressed in or --

13 MR. KATZ: Yes. It is similar to 

14 15.

15 MR. MARSCHKE: We could change the 

16 status of this one right now to "addressed in 

17 14," if we wanted to.

18 CHAIR MUNN: Well, we haven't 

19 changed the other --

20 MR. MARSCHKE: We haven't changed 

21 the other one, exactly.
174 

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1 CHAIR MUNN: We are just waiting 

2 for Steve.

3 MR. MARSCHKE: Okay.

4 CHAIR MUNN: But we may do that 

5 later this afternoon after we've had that 

6 discussion with him.

7 Now we are on item No. 20, 

8 finding, urinalysis.

9 "SC&A has not reproduced" -- did I 

10 get the wrong one? Did we just do this? No.

11 "SC&A could not reproduce all the 

12 percentages listed in tables G1 to G4 

13 following the procedure described by NIOSH, 

14 with the values listed for strontium-90 

15 presenting the greatest difference. On the 

16 other hand, table 7-1 values for strontium-90 

17 were reproduced using SC&A-derived values, but 

18 not using table G2 values."

19 NIOSH responds, "We, too, noted 

20 the issue with the Attachment G data, and the 

21 revision is in progress to correct it. This 
175 

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1 will also affect the values in table 7-2. In 

2 addition, some of the IRF values used will 

3 also be revised."

4 Can we change this to in progress?

5 MR. MARSCHKE: I was going to 

6 change it -- what about in abeyance?

7 MEMBER ZIEMER: Yes, they have 

8 agreed to change it.

9 DR. MAURO: They have agreed to 

10 change it, but we would like to see that 

11 change. So, in other words, I think it is 

12 more in progress than in abeyance. It's not 

13 that they gave the answer.

14 CHAIR MUNN: Yes. That's why I 

15 say in progress.

16 MR. MARSCHKE: In progress?

17 CHAIR MUNN: In progress.

18 Okay on the phone?

19 (No response.)

20 All right, I'll take that as yes.

21 MEMBER LEMEN: Yes.
176 

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1 CHAIR MUNN: Item No. 21, 

2 observation, urinalysis.

3 "The radionuclides listed in 

4 tables G1 to G4 are the ones taken from table 

5 D1, and the simplifications introduced in 

6 tables E1 and E2 were not used."

7 NIOSH response, "That is correct. 

8 The simplified source terms given in 

9 Attachment E are the basis for tables 7-3 and 

10 7-4. Attachment G and tables 7-1 and 7-2 are 

11 based on the nuclide mix given in table D1."

12 MR. HINNEFELD: Is there anything 

13 wrong in the finding?

14 CHAIR MUNN: I don't see that 

15 there is.

16 MR. HINNEFELD: Just making a 

17 comment --

18 CHAIR MUNN: It was an observation 

19 --

20 DR. ULSH: Our response seemed to 

21 be, yes, there was.
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1 (Laughter.)

2 CHAIR MUNN: Yes, it was an 

3 observation. It didn't ask for action. And 

4 the answer is it doesn't look like anything is 

5 being asked for other than agreement.

6 MEMBER ZIEMER: I'm trying to 

7 understand the implication of saying that the 

8 simplification introduced in the tables were 

9 not used. Is this Joyce's comment?

10 DR. MAURO: Yes, I can't speak to 

11 this.

12 MEMBER ZIEMER: I guess I would 

13 like to understand what her point is, why did 

14 she raise that issue.

15 DR. MAURO: I don't know. I can't 

16 speak to it.

17 MR. HINNEFELD: Well, on the face 

18 of it, there are quite a few more 

19 radionuclides in the E table than there are --

20 so that accounts for the simplification. The 

21 simplification is that -- and that may be 
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1 where radionuclides contributing less than one 

2 percent or something like that. We had heard 

3 about that earlier. I don't know if that was 

4 just some -- but I haven't tracked this 

5 document well enough to know where we are. I 

6 mean one of the simplifications is D has more 

7 radionuclides than E.

8 CHAIR MUNN: Well, since this is 

9 an observation, it does not appear to have 

10 been a major issue. It's more of a 

11 observation.

12 DR. MAURO: The very fact that we 

13 read this and we don't quite understand the 

14 point -- so maybe what Joyce was asking for is 

15 a little clarification between, I guess, the G 

16 tables and table D1, and why these differences 

17 exist. There doesn't seem to be any criticism 

18 of it. It just means -- just to explain a 

19 little better what this is all about.

20 And just from looking at this, I 

21 don't understand what's going on.
179 

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1 DR. ULSH: You assign it --

2 whatever status it is, where we say it's still 

3 open, but it's in SC&A's court to respond now?

4 DR. MAURO: Yes, we'll take it 

5 from here. We may have to explain further 

6 what the nature of our concerns are, if there 

7 is a concern. It may just be requesting 

8 clarification.

9 MR. KATZ: So this is another 

10 Steve.

11 DR. MAURO: Okay.

12 CHAIR MUNN: All right, we'll wait 

13 for Steve.

14 The next item numbered -- 

15 MEMBER ZIEMER: Well, is this 

16 going to be a Steve one anyway?

17 CHAIR MUNN: Or is it going to be 

18 a Joyce?

19 MEMBER ZIEMER: I think it would.

20 DR. MAURO: Well, I think 

21 everything -- most of these questions are 
180 

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1 probably going to go back to Joyce.

2 MEMBER ZIEMER: This is 

3 urinalysis, I'm not sure we can do this this 

4 afternoon. I'm thinking that maybe, to my 

5 mind, we need a response from SC&A to clarify 

6 --

7 DR. MAURO: What's up. Yes.

8 MEMBER ZIEMER: -- whether or not 

9 the observation was intended to raise an issue 

10 or not.

11 DR. MAURO: I agree with you. 

12 Yes.

13 MR. MARSCHKE: If we're waiting 

14 for Steve, Paul, he might just have some 

15 insight.

16 MEMBER ZIEMER: Maybe he would 

17 know, sure.

18 MR. MARSCHKE: Not necessarily 

19 that he's going to -- one way or the other, 

20 but --

21 DR. MAURO: The ball's in SC&A's 
181 

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1 court on this --

2 MEMBER ZIEMER: Right, right.

3 MR. MARSCHKE: He may give some 

4 insight.

5 DR. MAURO: -- to clear up exactly 

6 what are we talking about here now.

7 MEMBER ZIEMER: Yes.

8 CHAIR MUNN: If he has some 

9 information for us this afternoon, fine. 

10 Otherwise, we will call it in process, ask for 

11 more.

12 Item No. 22, finding, urinalysis.

13 "Looking at tables G1 to G4, SC&A 

14 does not agree with NIOSH that the trends are 

15 similar for all solubility categories. SC&A 

16 does not agree with NIOSH averaging the 

17 results for each solubility category. SC&A 

18 notes that the most conservative approach 

19 (most claimant-favorable) would be to use the 

20 percentages for insoluble radionuclides in 

21 tables G2 and G4 instead of averaging. As the 
182 

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1 two indicator radionuclides are type F, their 

2 concentrations are maximized and considered 

3 the most insoluble form of the other 

4 radionuclides."

5 Comment from -- response from 

6 NIOSH, "OTIB-54 will be revised to use just 

7 the most insoluble forms, as recommended."

8 Does SC&A accept that?

9 DR. MAURO: Yes, I like that 

10 answer. I think it's in abeyance.

11 CHAIR MUNN: Accept that? It's in 

12 process.

13 DR. ULSH: It's in abeyance.

14 DR. MAURO: I say in abeyance 

15 because they gave the answer.

16 MR. HINNEFELD: We said we're 

17 going to change it.

18 DR. MAURO: And it's the right --

19 in other words --

20 CHAIR MUNN: In abeyance. 

21 Absolutely. Sorry. That's 22.
183 

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1 No. 23, finding, urinalysis.

2 "SC&A notes that the 

3 oversimplification results creates reference 

4 numbers that do not relate with the real 

5 exposure of the workers. As a result, tables 

6 7-1 and 7-2, although perhaps conservative, 

7 cannot really be used as representatives of 

8 the workers' exposure."

9 NIOSH response, "OTIB-54 was never 

10 intended to provide anything more than a 

11 favorable overestimate. The document states 

12 doses determined by OTIB-54 should be assigned 

13 as upper bounds."

14 DR. ULSH: So basically agree it's 

15 not representative, but what we're saying is 

16 that wasn't the purpose of it in the first 

17 place.

18 DR. MAURO: Is that the table we 

19 were looking at before?

20 DR. ULSH: I don't know.

21 CHAIR MUNN: No. No. Different 
184 

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1 tables.

2 DR. ULSH: Maybe I'm reading too 

3 much into SC&A's comment. It looked like in 

4 the comment you agreed that it's conservative. 

5 Am I reading too much into that?

6 MR. HINNEFELD: Well, they say it 

7 may be. I don't know if they agree --

8 CHAIR MUNN: "Although perhaps 

9 conservative --

10 DR. ULSH: Perhaps?

11 DR. MAURO: Okay.

12 CHAIR MUNN: -- "cannot really be 

13 used as representatives of the workers' 

14 exposure."

15 DR. MAURO: Interesting situation. 

16 There is a lookup table that doesn't really 

17 represent anything in particular by way of 

18 reality, but it represents a surrogate --

19 CHAIR MUNN: Overexposure.

20 DR. MAURO: -- which is an 

21 overexposure. Now in situations like this in 
185 

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1 the past, we've run into circumstances where, 

2 when you're doing a plausible upper bound for 

3 the purpose of granting or denial, that's 

4 fine. But if you are assigning a dose which 

5 is not plausible, but certainly is upper, then 

6 it can only be used for denial.

7 So the question becomes have you 

8 created a table that is not plausible, and 

9 therefore -- and granting people their claim 

10 using a methodology that is not plausible. We 

11 have run into this with OTIB-4. Remember 

12 that? That's the classic one where that 

13 happened.

14 I guess my only concern is that 

15 given that it is true that this table is, in 

16 fact, bounding, as long as it represents -- 

17 but we also all agree that it really doesn't 

18 exist in reality, that mix, you know. Is it 

19 appropriate to use this for the sake of 

20 granting? Denial, I understand, but granting, 

21 and that's really a tough question.
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1 Do you see where I am on that?

2 MR. KATZ: You can always do that 

3 if you lack better information. Then it's 

4 fine for granting. So that's the limiting 

5 factor actually.

6 You can use simplified 

7 information, what have you, when you don't 

8 have better information for granting a DR.

9 DR. MAURO: Well, as long as it's 

10 plausible. In other words, if you have a 

11 construct that really cannot exist, and it 

12 assigns a dose that is unrealistically high 

13 and could not occur in reality, and then you 

14 compensate, I don't know. That's a 

15 regulatory, I guess, interpretation of what 

16 the intent is of the rule, but it seems to me 

17 kind of strange that you would do that.

18 MR. KATZ: The rule says that you 

19 can do a maximizing assumption in a case where 

20 you lack better information, where there's no 

21 more research to do and there's no way to put 
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1 a better number on it.

2 MEMBER ZIEMER: Well, I think the 

3 question here is are you using assumptions --

4 I mean there are assumptions and there are 

5 assumptions. A reasonable assumption I think 

6 is what you're saying.

7 DR. MAURO: When you're confronted 

8 with a circumstance where you certainly do not 

9 want to end up underestimating this person's 

10 dose, and you have -- and you really don't --

11 but you do know it can't be higher than this, 

12 but it is plausible it could have been as high 

13 as that, that's the appropriate protocol. And 

14 that's what I interpret maximizing to be.

15 Now to pick a number -- and we've 

16 been through this before -- that it is not 

17 plausible to be that high, a dust load, just 

18 couldn't happen.

19 MEMBER ZIEMER: That you couldn't 

20 breath in or something.

21 DR. MAURO: Now one could say that 
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1 certainly is maximizing, but then I think it 

2 does challenge other aspects of the rule.

3 MR. HINNEFELD: Well, I think 

4 we're putting a pretty fine point on not 

5 plausible here because the not plausible was 

6 sort of like -- the idea when it was written 

7 was you can't say, well, we know the external 

8 doses assigned here were less than 500 rem 

9 because nobody died from acute radiation 

10 syndrome. So we'll bound it at 500 rem.

11 That's kind of what was thought 

12 about, is to avoid clearly a hypothetical. 

13 Well, we know that they didn't get 500 rem 

14 because nobody died. 

15 DR. MAURO: Well, you know, how 

16 would I deal with this circumstance? I have 

17 got a guy that has got a gross beta-gamma 

18 reading --

19 MR. HINNEFELD: Well, I think look 

20 at the dose numbers. I mean the dose numbers 

21 that this thing has generated from bioassay I 
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1 don't think are going to be anything like out 

2 of this world. You know, they're going to be 

3 sort of realistic sort of dose numbers that 

4 you would get from an intake of mixed fission 

5 products.

6 I mean I'd look at the actual 

7 number as opposed to start worrying about, 

8 well, since we have a composite, we know that 

9 didn't exist. Is that an implausible thing? 

10 I think you have to look at the dose and the 

11 magnitude of the dose before you start talking 

12 about that.

13 DR. MAURO: But you understand 

14 what I'm thinking about?

15 MR. HINNEFELD: Yes. Well, I 

16 understand, but I just feel antsy at this 

17 implausibility and taking it too many places. 

18 To me, it's a magnitude sort of thing -- the 

19 doses -- we know it wasn't that high because 

20 nobody died, so --

21 DR. MAURO: I mean, in theory, if 
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1 one wants to look for a shortcut when you lack 

2 information, I've got gross beta-gamma; I've 

3 got a person with a particular type of cancer; 

4 I'm going to assume all strontium-90. We've 

5 done that in the past, way back -- listen, we 

6 know that would be the worst-case scenario, 

7 assuming if it's lung cancer. If it was some 

8 other, you know, if it was some soft tissue 

9 cancer, it might be cesium.

10 MR. HINNEFELD: Yes.

11 DR. MAURO: In other words, we 

12 know those are the radionuclides that find 

13 their way in varying degrees in coolant, and 

14 they're going to constitute a very important 

15 contributor to the dose. So you should look 

16 at all this.

17 MR. MARSCHKE: But you can make 

18 the argument that that's not a plausible 

19 comment -- that's not a plausible assumption 

20 either because you know that it's not going to 

21 be all cesium-137.
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1 MR. KATZ: Let me give you another 

2 example that's written into the reg. You can 

3 choose the most claimant-favorable solubility 

4 factor when you don't know anything. There 

5 may be circumstances where it is not plausible 

6 that it would be entirely that solubility 

7 factor, but that's written in the reg as 

8 absolutely kosher.

9 So I think what Stu is trying to 

10 say is taking plausibility to every nitpicking 

11 detail is taking it beyond sort of the 

12 intended parameters.

13 I mean the plausibility, where it 

14 is discussed, is discussed about you need to 

15 only consider plausible circumstances of 

16 exposure. You don't all of a sudden put them 

17 in an implausible exposure scenario and say, 

18 what if that happens?

19 MR. HINNEFELD: Correct.

20 DR. MAURO: We needed to have this 

21 conversation.
192 

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1 MR. MARSCHKE: So back to issue 

2 23?

3 DR. ULSH: What's the status of 

4 23?

5 CHAIR MUNN: Does SC&A accept that 

6 response?

7 MR. HINNEFELD: I think there 

8 might be more discussion here.

9 DR. MAURO: I will be the first to 

10 admit this issue of plausibility and trying to 

11 navigate your way through the regulations, 

12 find a way to deal with the fact that we lack 

13 complete information, and we always lack 

14 complete information, and we have to make 

15 certain assumptions to simplify the problem, 

16 and in so doing, you, by definition, are 

17 creating circumstances which may not 

18 necessarily be plausible.

19 Does that mean you have done 

20 anything inappropriate? I would be the first 

21 to admit no. But it's almost a judgment. And 
193 

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1 you know, if you go back to a judgment and 

2 this is reasonable, this is almost a personal 

3 judgment, unfortunately.

4 CHAIR MUNN: This is the stickiest 

5 of the wickets that we have to deal with 

6 without a doubt.

7 DR. MAURO: The stickiest.

8 DR. ULSH: Well, does the 

9 Subcommittee need more input from NIOSH or 

10 SC&A to opine on this question?

11 CHAIR MUNN: I don't think the 

12 Subcommittee needs any more input until SC&A 

13 has come to a conclusion with respect to this 

14 response. I don't know that we, as a 

15 Subcommittee, can do anything without an 

16 agreement that this approach is acceptable, 

17 conservative, plausible.

18 DR. MAURO: Plausible 

19 circumstances puts us in a difficult spot. I 

20 would be much more comfortable saying, listen,

21 these are the four mixes of radionuclides that 
194 

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1 we believe represent the range of reactor 

2 mixes that all the different workers might 

3 have experienced.

4 Coming up with a construct that 

5 doesn't really exist in reality brings us to 

6 this conversation, which I think is a 

7 difficult conservation to have.

8 CHAIR MUNN: It is.

9 MR. MARSCHKE: John?

10 DR. MAURO: Yes.

11 MR. MARSCHKE: We're not talking -

12 - four mixes -- we're not -- this is table 7-1 

13 and 7-2.

14 DR. MAURO: Okay, yes. I guess 

15 I'm --

16 MR. MARSCHKE: These are the two 

17 tables that this particular issue is 

18 addressing.

19 DR. MAURO: Okay.

20 MR. MARSCHKE: Table 7-1 and 7-2 

21 are conservative, cannot be really used as 
195 

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1 representative.

2 DR. MAURO: Yes.

3 MR. MARSCHKE: So we're not 

4 talking about those tables, those previous 

5 tables.

6 DR. MAURO: Okay. Good.

7 MR. MARSCHKE: This is two 

8 different tables.

9 DR. MAURO: What brings us here as 

10 opposed to the other tables then?

11 MR. MARSCHKE: I don't know --

12 DR. MAURO: All right.

13 MR. MARSCHKE: -- OTIB-54.

14 DR. MAURO: Okay.

15 MR. MARSCHKE: We have to look 

16 into the details of --

17 DR. MAURO: I'm overreaching. 

18 Let's wait until Steve gets back, so we get 

19 context. Okay.

20 MR. KATZ: So we want this one for 

21 Steve, 23?
196 

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1 MR. MARSCHKE: Steve or Joyce or -

2 - yes.

3 MR. KATZ: Discuss with Steve.

4 MEMBER ZIEMER: Ultimately, it 

5 might be Joyce, but Steve can weigh in on it.

6 DR. MAURO: But I'm sorry, but the 

7 philosophy is the same. If you are going to 

8 try to assign something to someone with lack 

9 of information, try to assign something that 

10 represents a plausible circumstance that could 

11 have existed and would be bounding as applied 

12 to this worker.

13 MEMBER ZIEMER: But we don't know 

14 whether she is claiming it was not plausible. 

15 She's saying it's not representative. So I 

16 think we need some clarity on that. I mean, 

17 yes, if it's beyond the realm of you can't 

18 conceive of some concentration that could 

19 possibly arise -- you know, I'm not sure we 

20 know the parameters here.

21 CHAIR MUNN: You know, there's a 
197 

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1 big difference in representative and 

2 plausible.

3 MEMBER ZIEMER: Yes.

4 CHAIR MUNN: A big difference.

5 All right, item No. 24, finding, 

6 air/surface contamination.

7 "SC&A notes that the same 

8 oversimplifications as discussed in comment 23 

9 is creating reference numbers in tables 7-4 

10 that do not relate to the real exposure of the 

11 workers."

12 This sounds very similar to the 

13 preceding one.

14 The NIOSH response, "Same as 

15 comment 23, OTIB-54 was never intended to 

16 provide anything more than a favorable 

17 overestimate. The document states doses 

18 determined by way of OTIB-54 should be 

19 assigned as upper bounds."

20 So do we leave that also on --

21 MEMBER ZIEMER: The same thing.
198 

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1 CHAIR MUNN: -- because it will be 

2 the same, essentially the same concern to be 

3 addressed?

4 I know it is lunchtime, but we are 

5 only two strokes away of getting through this.

6 Twenty-five is finding summary.

7 "SC&A finds that the urine 

8 activity fraction used for the indicator 

9 radionuclides is somewhat arbitrary and, 

10 consequently, intake and dose calculations are 

11 somewhat arbitrary as well. The 

12 overestimation of doses due to simplification 

13 of the source term is not a valid reason to 

14 use excretion rates of the indicator 

15 radionuclide and intake values of the 

16 dosimetrically significant radionuclides that 

17 do not relate to the real intakes and 

18 excretion rates.

19 "In addition, NIOSH does not show 

20 how much of the dose might be underestimated 

21 due to the scenario that was assumed, the 
199 

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1 reactor averaging, the solubility averaging, 

2 and by all other assumptions taken to derive 

3 tables 7-1 and 7-2."

4 And the NIOSH response is, "See 

5 comments 16, 23, and 26."

6 We haven't seen 26 yet, but we 

7 know 23 and 24 are the same. So essentially, 

8 NIOSH's response is the same.

9 We'll add 25 to this list and go 

10 on to the final finding for the moment -- for 

11 the morning, finding summary.

12 "SC&A questions the validity of 

13 the guidance provided in ORAUT OTIB-54 on the 

14 assignment of radionuclide-specific intakes of 

15 mixed fission and activation products when air 

16 sampling or urinalysis data associated with 

17 reactors or reactor fuels are available only 

18 as gross or total beta activity or gross or 

19 total gamma activity.

20 "The methods described in the OTIB 

21 will provide intakes and doses not correlated 
200 

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1 with the real ones. The differences between 

2 the intakes provided through the use of the 

3 document and the real ones are unknown and 

4 depend heavily on the scenario (periods of 

5 fuel irradiation and decay), the reactor type, 

6 and the detection methods."

7 NIOSH responds, "Because of the 

8 large number of nuclides potentially present 

9 in the fission and activation product mixture, 

10 it's not feasible to account for all 

11 possibilities. The approach was designed as 

12 an upper bound method for approximating the 

13 dose, which is the quantity of interest from 

14 mixed fission and activation products.

15 "Doses are input to IREP by 

16 radiation type rather than specific 

17 radionuclides. So an accurate accounting of 

18 the radionuclides is not important if the dose 

19 for the mixture can be closely approximated.

20 "All of the nuclides in the 

21 mixture fall into the categories of photons E 
201 

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1 greater than 250 keV and electrons E greater 

2 than 15 keV, both of which are the referenced 

3 radiations in IREP and have a point value 

4 radiation effectiveness factor, REF, of unity. 

5 So the total doses can be assigned as a 

6 single value per year. See also comments 16 

7 and 23."

8 Is this a Steve one?

9 DR. MAURO: Yes. We have 

10 basically entered into a realm of 

11 constructs --

12 CHAIR MUNN: Yes.

13 DR. MAURO: -- for the purpose of 

14 simplifying a very complicated analysis.

15 CHAIR MUNN: Right.

16 DR. MAURO: And I can see the 

17 virtue of trying to do that. I can also see 

18 the dilemma you find yourself in. So I 

19 understand this, and I don't know how much we 

20 can -- you know, the reality is what we have 

21 as a circumstance where I'm sure that the 
202 

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1 construct is reasonable, if not bounding. 

2 Does it exist in reality? No. It's a 

3 construct that crosses different domains for 

4 the intention of simplifying the process.

5 You know, I'm saying this for like 

6 five of the things we're talking about now. 

7 In some cases, it's clear that -- it might be 

8 shown to be clear that it is bounding. In 

9 this case, it's not apparent to Joyce that 

10 it's necessarily bounding, when taking all of 

11 the different facets of the problem, 

12 everything from mix to solubility type, to the 

13 amount of time it's operated, you know, burnup 

14 time. You know, it's not apparent that 

15 necessarily your default has, in fact, 

16 captured the bounding circumstance.

17 So it's two levels here. The 

18 simpler level is did your default really 

19 capture the bounding scenario, given the lack 

20 of information. The second one is, even if 

21 your default does capture the bounding 
203 

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1 scenario, if it doesn't really exist in 

2 reality, is that something that is appropriate 

3 to do. Your argument will be yes, as long as 

4 you know it's bounding, that's fine. And that 

5 becomes a regulatory interpretation.

6 So that's the place we're in right 

7 now. And we're going to have to -- SC&A is 

8 going to have to struggle with this as best we 

9 can.

10 CHAIR MUNN: All right, then, for 

11 the moment, we will leave this as one of the 

12 11 that we will dump on Steve when he arrives.

13 (Laughter.)

14 DR. MAURO: And Steve is going to 

15 love this.

16 (Laughter.)

17 CHAIR MUNN: Oh, yes, I know. I 

18 know he has no idea this is going to be --

19 is that -- unless someone has objection, I 

20 would like for us to recess for lunch.

21 Any objections?
204 

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1 MEMBER ZIEMER: No.

2 CHAIR MUNN: Otherwise, let's take 

3 until 1:15, 1:20.

4 MR. KATZ: Thanks on the phone, 

5 everybody. 1:20.

6 (Whereupon, the above-entitled 

7 matter went off the record at 12:19 p.m. and 

8 went back on the record at 1:28 p.m.)

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 
205 

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1 

2 

3 

4 
206 

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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 

2 1:28 p.m.

3 MR. KATZ: Let me just check in 

4 again. I know we have Dr. Lemen on the line. 

5 Do we have Mark Griffon, too?

6 (No response.)

7 Okay.

8 CHAIR MUNN: Apparently not.

9 All right, we have added to our 

10 number here in the room Steve Ostrow, for whom 

11 we have postponed a number of items from this 

12 morning. We can go ahead and pick those up. 

13 We might desire to allow Steve to 

14 get an idea of what we have looked at quickly, 

15 and then give him perhaps a few minutes to 

16 assimilate some of that before we ask him to 

17 make any comment much one way or the other, 

18 before we initiate any real discussion.

19 If it's all right with all 

20 concerned, let me run through, if Steve will 

21 help me, Steve Marschke is going to place the 
207 

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1 information up on the board, so that Steve 

2 Ostrow can take a look at it.

3 The first item that we postponed 

4 for him to look at was Item 7. Item 7.

5 MR. MARSCHKE: There it is.

6 CHAIR MUNN: And I don't know, 

7 Steve Ostrow, you don't have your own laptop 

8 there, do you?

9 DR. OSTROW: No, but I can read it 

10 off the screen at this point.

11 CHAIR MUNN: Okay, fine.

12 Item 7. And then -- I'll tell you 

13 what. Instead of our holding up the whole 

14 process while you do this, perhaps you might 

15 get over by Marschke for a little bit and read 

16 through those. I will give you the numbers of 

17 the items that we have --

18 MR. KATZ: Well, really, I think 

19 you need to let Steve know what the 

20 conversation was around the item for Steve to 

21 sort of be brought up-to-speed. If he just 
208 

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1 looks at these on the screen, he won't know 

2 what's happened in here.

3 CHAIR MUNN: All right, if you 

4 would rather.

5 MR. KATZ: I'm just saying, if you 

6 want --

7 DR. OSTROW: Yes, that would 

8 probably be a good idea.

9 MR. KATZ: If you want to get 

10 Steve up-to-speed so he can in some of these 

11 cases either make a contribution, in others 

12 say that that situation looks to be an issue, 

13 whatever it might be.

14 CHAIR MUNN: Okay. We'll start 

15 with Item No. 7. The finding there, Steve, 

16 has to do with fuel dimensions, compositions, 

17 and burnup values. The OTIB was asked by our 

18 contractor to provide some justification for 

19 the assumption that the data did not change 

20 significantly. And you can read the NIOSH 

21 response there about the single pass reactors.
209 

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1 DR. OSTROW: Well, Wanda, you 

2 know, I really can't make comment on this as I 

3 think about it a lot. You know, I can't make 

4 offhand comments on this.

5 CHAIR MUNN: Okay. That's true.

6 Does anyone want to enrich the 

7 discussion any for Steve before we show him 

8 the next one?

9 DR. ULSH: Well, what status are 

10 we going to assign to this? Is that an in 

11 progress where it's in SC&A's court to 

12 consider and respond to that or --

13 CHAIR MUNN: It is in progress 

14 when we are awaiting some action.

15 MR. KATZ: John, could you remind 

16 Steve of what -- you thought of this --

17 DR. MAURO: Yes. After going 

18 through the ones that are in progress now, 

19 because we really -- although it looks like 

20 about half of them we were able to put to bed, 

21 either close or put them in abeyance.
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1 CHAIR MUNN: Yes.

2 DR. MAURO: But the other half we 

3 couldn't. And of the half that we -- out of 

4 the what? What was it? How many, 26?

5 CHAIR MUNN: We had 26 --

6 MR. MARSCHKE: Eleven that are 

7 still basically open.

8 DR. MAURO: Okay. So we had 11 

9 out of 26 are still alive, which is good, a 

10 lot of progress.

11 Out of the 11 that are still at 

12 issue, maybe half of them are what I would 

13 call more biochemistry, radiochemistry, 

14 internal dosimetry questions, which I think 

15 really Joyce needs to look at. I know no one 

16 at the time this morning felt comfortable in 

17 being able to say whether or not it has been 

18 resolved.

19 And the other half are more 

20 nuclear engineering. And we did try our best 

21 here to explore whether it seems like it was a 
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1 good answer or not. But, at the same time, we 

2 felt that we didn't want to rush to any 

3 judgment.

4 I know, Steve, you may also want 

5 to weigh-in on the nuclear engineering issues, 

6 such as the very first one we just looked at, 

7 No. 7. But if you're not comfortable, you 

8 know, you would like to give it a chance to 

9 look at it, maybe we just say, okay, Steve and 

10 Joyce and us could get together after we go 

11 home and take those on.

12 DR. OSTROW: I mean I made all the 

13 nuclear engineering comments on this.

14 DR. MAURO: Okay.

15 DR. OSTROW: But I can't really 

16 answer them thoughtfully offhand.

17 CHAIR MUNN: After No. 7, we have 

18 No. 9.

19 MR. HINNEFELD: So No. 7 is going 

20 to in progress? Is that it?

21 CHAIR MUNN: Yes.
212 

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1 Which had to do with the TRIGA 

2 reactors and whether or not the use of 20 

3 percent enrichment in this particular document 

4 was appropriate for the purposes stated. And 

5 there is, as you can see, a NIOSH response to 

6 that.

7 The next one that we kept in 

8 abeyance, I mean kept in process for you, was 

9 Nos. 14, 15, and 19. Almost all have --

10 MR. KATZ: Fourteen, 15, and 17.

11 CHAIR MUNN: Fourteen, 15, 17, and 

12 19, but 14, 15, and 19 were pretty closely 

13 related.

14 MR. KATZ: Yes.

15 CHAIR MUNN: They had to do with 

16 reactor source terms and how four reactor 

17 types had been chosen to produce a default 

18 source term. He has a NIOSH answer to one of 

19 them -- to all of them, actually.

20 Fourteen is the first of them.

21 The second of them was concerning 
213 

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1 the fact that some radionuclides weren't 

2 released in significant quantities when you 

3 are reviewing those four reactor types. NIOSH 

4 had a response to that as well.

5 And Item 17 had to do with 

6 urinalyses, questioning NIOSH's data 

7 sufficiency for the derivation of the values 

8 that they had -- that was used. There's a 

9 significant NIOSH response to that one.

10 And then Item No. 19 was, again, 

11 urinalysis issues with respect to the 

12 percentage of each radionuclide's contribution 

13 to both beta and gamma urine counts. And they 

14 all seemed to bear on the same general 

15 assumptions in those tables.

16 Item 21, also with respect to 

17 urinalysis. We looked at this, tables G-1 and 

18 G-4, and the simplifications that were used. 

19 That was an observation, but it was difficult 

20 for those of us here to come to some real 

21 understanding of what the actual issue was 
214 

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1 with No. 21.

2 MR. KATZ: Well, Steve may be able 

3 to clarify that.

4 CHAIR MUNN: Oh, okay. That might 

5 be --

6 DR. OSTROW: Okay, which one is 

7 this now?

8 CHAIR MUNN: Item 21. The 

9 finding, the SC&A finding said, observation 

10 urinalysis, that "radionuclides listed in 

11 tables G1 to G4 are the ones taken from table 

12 D1, and the simplifications introduced in 

13 tables E1 and E2 were not used."

14 The NIOSH response was, "That is 

15 correct. The simplified source terms given in 

16 Attachment E are the basis for tables 7-3 and 

17 7-4. Attachment G and tables 7-1 and 7-2 are 

18 based on the nuclide mix given in table D1."

19 We were not sure what the real 

20 concern was here, if there was concern, and 

21 whether that concern had been answered 
215 

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1 properly or not to the satisfaction of anyone.

2 DR. OSTROW: You have to ask Joyce 

3 about this one.

4 CHAIR MUNN: Very good.

5 The last ones are also fairly 

6 well-associated, and I believe most of them 

7 are urinalysis and surface contamination.

8 No. 23 was a finding of 

9 urinalysis. "SC&A notes the 

10 oversimplification of results creates 

11 reference numbers that do not relate with the 

12 real exposure of the workers. As a result, 

13 tables 7-1 and 7-2, although perhaps 

14 conservative, cannot really be used as 

15 representative of the workers' exposure."

16 And NIOSH's response said, "OTIB 

17 was never intended to provide anything more 

18 than a favorable overestimate."

19 So this is -- our discussion 

20 focused around the fact that this is our 

21 continually-recurring problem of whether or 
216 

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1 not the overestimates are plausible, and that 

2 continues through to some degree in No. 24, 

3 which was the finding of air and surface 

4 contamination.

5 "SC&A notes the same 

6 oversimplifications as discussed in the 

7 previous comment was creating reference 

8 numbers to table 7-4 that do not relate to 

9 real exposure of workers."

10 And the response of NIOSH was the 

11 same as the previous one.

12 No. 25 has to do, again, with 

13 urinalyses, and the finding summary was, "SC&A 

14 finds that the urine activity fraction used 

15 for the indicator radionuclide is somewhat 

16 arbitrary, and, consequently, intake and dose 

17 calculations are somewhat arbitrary as well. 

18 The overestimation of doses due to 

19 simplification of the source term is not a

20 valid reason to use the excretion rates of the 

21 indicator radionuclide and intake values of 
217 

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1 the dosimetrically-significant radionuclides 

2 that do not relate to real intakes and 

3 excretion rates."

4 And the same response, 

5 essentially, was at play there.

6 And the final one is the final 

7 item that we had to deal with, which was No. 

8 26. And the finding summary was, "SC&A 

9 questions the validity of the guidance 

10 provided by the procedure on the assignment of 

11 radionuclide-specific intakes of mixed fission 

12 and activation products when air sampling and 

13 urinalysis data associated with reactors or 

14 reactor fuels are available only as gross or 

15 total beta activity or gross or total gamma."

16 That is questioning, again, the 

17 reality with respect to what is actually seen. 

18 There is a longer and more involved response 

19 from NIOSH on that one, but the issue appears 

20 to be pretty much the same.

21 Is there anything anyone wants to 
218 

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1 say about what I just said that would help 

2 Steve in his machinations when he goes over 

3 the list?

4 DR. MAURO: Yes. Steve, while we 

5 were going over a number of these, there was a 

6 recurring theme related to plausibility, 

7 bounding assumptions, maximizing assumptions. 

8 You know, when is it reasonable to construct 

9 a lookup table that simplifies the problem? 

10 Do you use, under default circumstances, which 

11 may not really represent any one particular 

12 real circumstance, but is more of a construct?

13 And Ted did a very nice job in 

14 explaining the intent of the rule with respect 

15 to this matter, and it will go toward, I

16 think, our -- I think it will be important 

17 that we read the transcript, which will be 

18 ready in about a month in raw form. And 

19 perhaps together with Steve and Joyce, we will 

20 sort of share all this and put our heads 

21 together and come up with a response that not 
219 

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1 only is from a technical perspective, but also 

2 the interpretation of the term "plausibility" 

3 for some of these constructs I think is going 

4 to be important.

5 CHAIR MUNN: Okay. Can we leave 

6 that item now?

7 MEMBER ZIEMER: So all of these 

8 are going to be --

9 MR. HINNEFELD: Are all those 

10 going to be marked in progress now?

11 MR. MARSCHKE: I have marked them 

12 all in progress at this point. I have not 

13 added the response because it is just too 

14 slow.

15 DR. MAURO: They're all the same. 

16 I would imagine they're fundamentally close 

17 to the same, anyway.

18 MR. MARSCHKE: I will add the 

19 response to all those ones similar to the 

20 response that I have added to 9, which 

21 basically states, "SC&A will review the NIOSH 
220 

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1 response. The Subcommittee changed the issue 

2 status to in progress."

3 When I get home, I will add that 

4 response to each one of the --

5 CHAIR MUNN: That should be fine.

6 All right. Let's see if we have 

7 any action on the carryover items that we had 

8 from last time.

9 The first one that we have listed 

10 on our agenda for this morning was response 

11 from SC&A on TIB-13. Do we have anything on 

12 that?

13 MR. MARSCHKE: I think I looked at 

14 the response that NIOSH provided. My 

15 recollection was that I thought they could be 

16 changed to in abeyance.

17 Let's see, the first finding was, 

18 "Important parameters, such as averaging 

19 worker geometry, in particular, worker height 

20 and assumed dosimeter position, are not 

21 indicated in the description."
221 

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1 The NIOSH response was, "First, 

2 Attila is not a point kernel shielding code. 

3 Attila is a multi-group deterministic 

4 radiation transport program that is capable of 

5 modeling complex geometries efficiently and 

6 accurately to solve large 3D problems. This 

7 is stated in Section 2.2 on the software. The 

8 worker geometry is shown in the figures for 

9 each scenario, and a list of the distances and 

10 dimensions were provided to SC&A.

11 "The geometry factors obtained in 

12 the Attila glovebox worker TIB-10 provide a 

13 reasonable idea of the spread of ratio values 

14 between upper and lower torso in this TIB. 

15 The geometric mean and standard deviation of 

16 the glovebox are as follows, 2.19 and 1.34, 

17 respectively. This spread is based on a 

18 Crystal Ball Monte Carlo analysis of 30 

19 different upper and lower torso points.

20 "Since this is only geometry21 dependent, I would expect it to hold for this 
222 

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1 TIB as well. More discussion can be added to 

2 avoid any confusion on the part of the reader 

3 as well as the dimensions."

4 And I read that response, and I 

5 said, basically, I agreed with it, and I --

6 add more discussion to the TIB. And if they 

7 do that, then change the status to in 

8 abeyance. That would be our recommendation.

9 CHAIR MUNN: Any objection? Any 

10 further discussion?

11 (No response.)

12 Anyone on the phone have any 

13 problem with taking this in abeyance and 

14 awaiting NIOSH's --

15 MEMBER LEMEN: No, I don't. This 

16 is Richard.

17 CHAIR MUNN: All right.

18 MEMBER ZIEMER: What's the date on 

19 that particular one? I think I missed that.

20 CHAIR MUNN: The most recent one?

21 MR. MARSCHKE: This one --
223 

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1 basically, you won't have this. This was not 

2 emailed out. This was, because I was not able 

3 to add the responses to the database last week 

4 when I was looking at this, I had to pull this 

5 information off from the database and put it 

6 into this little Word file. Otherwise, I 

7 would have normally, you know, if the database 

8 had been working the way it is working today, 

9 I would have just added this response right 

10 directly into the database. Unfortunately, it 

11 was not. So I did this as a stopgap.

12 CHAIR MUNN: But the next time we 

13 see it, this will be on the database.

14 MEMBER ZIEMER: Scroll it up then. 

15 What's the last entry there at the bottom? 

16 Scroll down, I should have said.

17 DR. ULSH: That's finding 4 there.

18 MR. MARSCHKE: This is finding 4.

19 MEMBER ZIEMER: I'm sorry. Okay. 

20 Yes, then, go back. Okay.

21 MR. MARSCHKE: Right now, we're 
224 

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1 just looking at finding 3 there.

2 And let's see, I think I can pull 

3 up the -- this is OCAS TIB-13.

4 DR. MAURO: Three.

5 MR. MARSCHKE: Yes.

6 CHAIR MUNN: Thirteen, 3. You're 

7 looking at 3, I think?

8 DR. MAURO: Yes.

9 MR. MARSCHKE: OCAS TIB-13.

10 CHAIR MUNN: No. 3.

11 MR. MARSCHKE: No. 3 was basically 

12 -- here you can see what was in there 

13 initially. This is what is in the database.

14 CHAIR MUNN: Yes, everything 

15 except the most recent response is there.

16 MR. MARSCHKE: And then what I 

17 proposed to add was what I just read there.

18 MEMBER ZIEMER: Can you put that 

19 back up once again, what you just read?

20 MR. MARSCHKE: Which one?

21 MEMBER ZIEMER: What you just 
225 

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1 read.

2 DR. MAURO: I don't know if you 

3 have that.

4 CHAIR MUNN: No.

5 DR. MAURO: This is a hard copy 

6 that Steve gave you.

7 CHAIR MUNN: Yes.

8 MR. MARSCHKE: I just added the 

9 one sentence. "Adding more discussion would 

10 avoid confusion. Recommend changing the 

11 status to in abeyance."

12 MEMBER ZIEMER: So NIOSH is saying 

13 that they're going to put this discussion in? 

14 That's the discussion, right? Got you.

15 CHAIR MUNN: Our next --

16 MR. MARSCHKE: What did we decide?

17 CHAIR MUNN: We decided that you 

18 would make that addition to the database and 

19 that it would be in progress.

20 DR. MAURO: In abeyance.

21 CHAIR MUNN: In abeyance, awaiting 
226 

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1 the additional comment that has been proposed.

2 Then we have --

3 MR. MARSCHKE: Issue 4, currently 

4 in progress, and the issue was, "The procedure 

5 underestimates the maximum correction factor 

6 to be applied to the badge readings. 

7 Therefore, the procedure does not provide 

8 adequate guidance for defining the claimant9 favorable assumptions."

10 The NIOSH response was, "The basis 

11 for the supposed underestimate is the 

12 calculation of dose made by SC&A with MCNP. 

13 The TIB is vague on the issue of dose 

14 calculation and must be updated.

15 "The correction factor is 

16 completely determined by geometry. Photon 

17 fluence was determined at the surface of the 

18 dosimeter on the upper torso and at the 

19 surface of the person on the lower torso and 

20 head in each scenario. That is why 

21 Bremsstrahlung is not taken account in the 
227 

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1 TIB.

2 "The geometry consideration is the 

3 same. Much of the difference between TIB-13 

4 and the review appears to relate to angular 

5 dependence on dosimeters. This is a broader 

6 issue not affecting just Mallinckrodt cases 

7 and should be addressed as an overriding 

8 issue."

9 So what did I say?

10 CHAIR MUNN: We then instructed 

11 SC&A, did we not? We instructed SC&A to 

12 review the NIOSH response. And the question 

13 now is has SC&A reviewed that?

14 MR. MARSCHKE: Our response was, 

15 basically, "NIOSH indicates that the TIB must 

16 be updated to address this issue. And after 

17 the TIB-13 has been updated, SC&A proposes a 

18 review of the update to determine whether the 

19 issue has been addressed. And we recommend 

20 maintaining the status of this issue in 

21 progress."
228 

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1 DR. MAURO: The only concern I 

2 have with this is we did bring up the issue of 

3 angular. In other words, beside the location, 

4 you know, let's say the lapel versus down 

5 here, whatever adjustment, an inverse square, 

6 I guess, is also the issue that the angle of 

7 incidence of a weak photon, let's say it is 

8 Bremsstrahlung, coming in at an angle, there 

9 is an additional correction.

10 I remember Bob Anigstein's 

11 analysis of the two factors and how they 

12 affect -- or it might have been Hans. And it 

13 does make a big difference to take both 

14 factors into account, not only the inverse 

15 square law. Let's say the film badge is worn 

16 on the lapel, but you are concerned about the 

17 bladder. But there is also a change in the 

18 angle of incidence.

19 Now is there a commitment being 

20 made here to look into that aspect of the 

21 correction factor also?
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1 MR. HINNEFELD: I think what our 

2 thought was that to take that up, that affects 

3 things more broadly than just the Mallinckrodt 

4 data.

5 DR. MAURO: It does. Absolutely.

6 MR. HINNEFELD: That's a more 

7 broad thing to discuss, and we would rather 

8 deal with that as an overarching issue kind of 

9 discussion because it is going to affect a lot 

10 of things.

11 DR. MAURO: Is there a home for 

12 that? I mean, is there like --

13 MR. HINNEFELD: Well, I mean --

14 CHAIR MUNN: I think it is 

15 overarching.

16 MR. HINNEFELD: Theoretically, we 

17 will have to form, you know, whether that is 

18 going to come to this group as a special 

19 meeting to deal with overarching issues or 

20 what, that's where those will have to be 

21 discussed. There are a few of them out there, 
230 

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1 and they wouldn't be site-specific. They 

2 would be overarching, so you wouldn't give 

3 them to a site Work Group. I suspect they 

4 would come here. But it sounds -- it would 

5 almost be a separate agenda, and we would have 

6 to give some thought to collecting them all 

7 because we have had a few.

8 DR. MAURO: Yes, that's the 

9 question I have. Do we have --

10 MR. HINNEFELD: Well, Jim kept a 

11 list for a while.

12 DR. MAURO: So Jim has a list?

13 MR. HINNEFELD: He kept a list for 

14 a while.

15 DR. MAURO: I agree that is where 

16 this would go.

17 CHAIR MUNN: Would that pass to 

18 you or whether we are still going to deal with 

19 it --

20 MR. HINNEFELD: Oh, no, I mean 

21 it's not coming to me. That would be 
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1 delegating up.

2 CHAIR MUNN: Somebody's got to 

3 take it. I thought Jim was going to take --

4 MR. HINNEFELD: We will see what's 

5 -- we will have to just come back another 

6 time. For this purpose and for the purpose of 

7 this agenda item and this document, we just 

8 felt like it shouldn't be discussed under this 

9 document because it affects life more broadly.

10 DR. MAURO: Do we have a category 

11 to say this has been transferred to global or 

12 something like that? That is, do we have a 

13 category for this kind of thing?

14 MR. HINNEFELD: Boy, I don't know.

15 DR. MAURO: What are the options 

16 for designation of this?

17 MR. MARSCHKE: Well, right now, I 

18 mean, basically right now, if you look at what 

19 they said, NIOSH is updating the dose 

20 calculation. So they're updating the TIB. So 

21 I would not move it to anywhere until we see 
232 

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1 what the update looks like.

2 DR. MAURO: Yes, but I got the 

3 sense that the updated TIB is to explain the 

4 basis for the correction factor between the 

5 lapel and the bowel.

6 MR. HINNEFELD: I suspect that's 

7 what it is going to do. I don't think --

8 DR. MAURO: But not the angle of 

9 incidence.

10 MR. MARSCHKE: Well, let's wait 

11 until we see what the update is --

12 DR. MAURO: Okay.

13 MR. MARSCHKE: -- before we --

14 DR. MAURO: Okay.

15 MR. HINNEFELD: Yes, we have 

16 committed to a change. We have committed to a 

17 change of some sort where you put it in 

18 abeyance, and at that point it could then be -

19 - if that's okay, then you could transfer it 

20 to overarching.

21 DR. MAURO: Well, you see, what 
233 

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1 that correction factor is going to be and the 

2 description of it is something that we really 

3 don't have in front of us, right?

4 MR. MARSCHKE: Correct.

5 DR. MAURO: So we really can't say 

6 it's in abeyance.

7 MR. MARSCHKE: No. That is why we 

8 basically recommended maintaining it in 

9 progress.

10 DR. MAURO: In progress, yes. But 

11 any chance we could capture -- see, I don't 

12 want to lose this angle-of-incidence issue in 

13 terms of status. You know, is there any way 

14 just to make sure of that? Because, if, 

15 ultimately, that aspect of this response is 

16 going to be a global issue, and it is 

17 appropriately a global issue --

18 CHAIR MUNN: It is.

19 DR. MAURO: -- I just don't want 

20 to lose that. That's all.

21 MR. MARSCHKE: Let's add a 
234 

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1 response here, basically, we can add something 

2 in here. We can add some words to 

3 instructions that NIOSH, when they do the 

4 update, or suggestions to NIOSH when they do 

5 the update about angle of incidence. What do 

6 you want to say, I guess, is the question.

7 MEMBER ZIEMER: Well, let me 

8 insert here sort of a question, and then you 

9 can remind me if I have forgotten. But do we 

10 have an overarching document that deals with 

11 personnel dosimetry methodologies, or 

12 something like that, where it would be the 

13 natural place to discuss film badge response 

14 and the variables that affect it, or something 

15 like that?

16 MR. HINNEFELD: As far as I know, 

17 it's a list that we keep in our office, and I 

18 don't know that it's got a formal category on 

19 the thing.

20 MEMBER ZIEMER: But I'm thinking 

21 of a document, sort of like the contamination 
235 

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1 resuspension document.

2 DR. MAURO: Yes, like resuspension 

3 factor. That's a global issue that's on the 

4 list. So it goes on that list, evidently.

5 MEMBER ZIEMER: Right.

6 CHAIR MUNN: But this issue has 

7 come up in several other Work Groups.

8 DR. MAURO: Yes, it has.

9 MEMBER ZIEMER: Yes, yes.

10 CHAIR MUNN: And inevitably, it --

11 MEMBER ZIEMER: Well, I think SC&A 

12 raises it as a regular thing. As you say, 

13 it's an overarching issue.

14 But you have the issue of energy 

15 response of film badges. You have the issue 

16 of angular dependence. You have the issue of 

17 fading.

18 DR. MAURO: Yes.

19 MEMBER ZIEMER: You have the issue 

20 of minimum detectable limits which varies from 

21 site to site. But at least the fading, 
236 

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1 angular dependence, and energy dependence are 

2 certainly three parameters that you have to 

3 come to grips with sort of across the board, 

4 irrespective of the site.

5 DR. MAURO: Right. That's true.

6 Well, and the only reason why I 

7 was saying that, that point that you just 

8 made, it needs to be captured somewhere. 

9 Certainly, it's in the transcript. Do we want 

10 to capture it in any way in the matrix?

11 MR. HINNEFELD: Well, I would 

12 suggest that we would have to go back and find 

13 out from the design of the database where --

14 how to do that. Because right now, the 

15 database is structured along -- our part of 

16 the database is structured along Subcommittees 

17 and Work Groups. That is sort of the big 

18 chunk, and it's set up that way, so that any 

19 of the Subcommittees and Work Groups, this is 

20 available to them, and just be some -- 

21 designating authorities and things like that, 
237 

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1 putting names on them.

2 MEMBER ZIEMER: Well, I would 

3 think it could even still be addressed in this 

4 Work Group, but you would say it was a TIB5 something-or-other issue. I mean, we have 

6 done that on a couple of others where we keep 

7 it as being discussed in a different --

8 DR. MAURO: Sure, like TIB-9 for 

9 ingestion and --

10 MEMBER ZIEMER: Yes.

11 DR. MAURO: -- TIB-70 for the 

12 residual periods.

13 MEMBER ZIEMER: Right.

14 DR. MAURO: Absolutely. We have 

15 transferred many issues. Now, unfortunately, 

16 this particular issue does not have a TIB that 

17 I'm familiar with.

18 MEMBER ZIEMER: It doesn't have a 

19 home right now.

20 DR. MAURO: A home. That's why I 

21 said that it needs a home, right.
238 

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1 MEMBER ZIEMER: But it might be 

2 possible to think in terms of identifying -- 

3 well, it's part of the overarching issues, 

4 sort of, topic, and how are we addressing 

5 overarching issues in terms of the procedures, 

6 or something like that?

7 You know, I could even imagine 

8 setting aside, putting in reserve some future 

9 TIBs that we know are going to have to be 

10 developed.

11 DR. MAURO: I know this may be --

12 well, this is a suggestion. We are going to 

13 come across these things from time to time, 

14 and we want to make sure here, within our own 

15 -- the thing we do have control over, that we 

16 capture that.

17 Now we could do that by simply 

18 leaving this in progress, and in the write-up 

19 say the things we just said, that this is an 

20 issue that is overarching and needs to be 

21 addressed eventually somewhere, in some 
239 

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1 capacity.

2 We could also create -- now this 

3 would be changing the format of the structure 

4 -- but actually create a subdivision -- maybe 

5 we want to drop something -- which would be 

6 called overarching issues. And there will be 

7 a list here. In other words, rather than 

8 someplace in your office, we could actually 

9 have a list that's here where we would list --

10 this would be the home of where the 

11 overarching issues list is kept.

12 And then, maybe at the next 

13 meeting, you could bring your list. Here's 

14 what we have right now on our list, and load 

15 it up. And this way, you will actually have a 

16 formal home in the database for this 

17 Subcommittee.

18 CHAIR MUNN: Actually, John, that 

19 is exactly what I was going to suggest. I was 

20 going to ask Stu and Brant if they can work 

21 with Jim to get his list of the overarching 
240 

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1 issues we have identified that have not yet 

2 found a procedural home, so that at least we 

3 will have a better opportunity to view exactly 

4 how much work needs to be done.

5 My memory is that there are less 

6 than a half dozen of these. I think there are 

7 only four or five.

8 MR. HINNEFELD: Yes, that's my 

9 recollection.

10 CHAIR MUNN: But we need to get 

11 them formalized. We have not had them 

12 formalized in any way. But we have done quite 

13 a bit of work around them, on the assumption 

14 that something magical was going to happen.

15 So if we could request that you 

16 bring us that list the next time we meet, then 

17 we will include that on our expectations and 

18 have some discussion then about whether it is 

19 timely for this particular body to be doing 

20 anything with it at this moment or whether it 

21 is a future item.
241 

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1 DR. ULSH: So the current --

2 CHAIR MUNN: And --

3 DR. ULSH: I'm sorry. Go ahead.

4 CHAIR MUNN: No, go ahead.

5 DR. ULSH: So the current status 

6 is in progress? Is that it?

7 CHAIR MUNN: Yes.

8 DR. ULSH: Okay.

9 MR. MARSCHKE: Do you want to add 

10 any response to this or just basically leave 

11 it as in progress?

12 CHAIR MUNN: You had a one-liner 

13 response, didn't you? Or did you?

14 MR. MARSCHKE: Well, I was toying 

15 around as we were talking as to whether or not 

16 we wanted to add something along the lines of 

17 what I had here, about the three topics I 

18 think that Paul talked about, in my 

19 understanding of what was discussed, is that 

20 the calculation of the dose from badge 

21 readings needs to capture the issue of energy 
242 

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1 response, angular dependence, and fading, if I 

2 was hearing the discussion correctly.

3 And I don't know if somehow we 

4 want to incorporate that into the database 

5 record or if we just want to just cancel this 

6 response and just leave it as in progress.

7 MEMBER ZIEMER: What about a 

8 sentence to the effect that this appears to be 

9 an overarching issue or a global issue that 

10 probably should be dealt with under a separate 

11 -- would you call it a separate TIB or --

12 MR. HINNEFELD: Or agenda item 

13 or --

14 CHAIR MUNN: Document, a separate 

15 a document.

16 MEMBER ZIEMER: A separate 

17 document or a separate --

18 MR. HINNEFELD: Yes.

19 MEMBER ZIEMER: I'm not even sure 

20 of the procedure at the point you do that. 

21 You are looking at -- it's sort of like high-
243 

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1 fired oxide, you're looking at how to handle 

2 them, but you may have a specific procedure 

3 for a specific site, but it is more of an 

4 issue approach where you address how you come 

5 to this issue and deal with it.

6 DR. MAURO: There may already be 

7 an OTIB out there. I don't know. If Kathy 

8 Behling is on the phone, she probably has all 

9 the OTIBs memorized. Whether or not there 

10 would be a home for this, that is, is there an 

11 OTIB out there, just like OTIB-70 has a home 

12 for all this residual period issues, is there 

13 an OTIB out there that would be the proper 

14 home for film badge correction factors related 

15 to all the matters we are discussing? If that 

16 is the case, then all it is a matter of is 

17 basically transferring it.

18 MR. MARSCHKE: Well, what we did 

19 on some of the earlier issues about, well, 

20 again, on resuspension, we changed the status. 

21 We had a status where we basically said, this 
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1 has been transferred to global issues. And we 

2 kind of never really defined what global 

3 issues are or is.

4 CHAIR MUNN: I think I suggested a 

5 course for moving forward. Is that acceptable 

6 with everyone? Then let's --

7 MR. HINNEFELD: Was it?

8 CHAIR MUNN: Yes.

9 MR. HINNEFELD: What was it?

10 CHAIR MUNN: The course for moving 

11 forward was that you were going to bring us 

12 the list of what we have already identified as 

13 overarching issues, and we will discuss at our 

14 next meeting how to address what might be the 

15 most expedient method for addressing those and 

16 getting them moving.

17 Yes, Ted?

18 MR. KATZ: No, I was just going to 

19 say, just to add on to what Wanda just said, 

20 one element of that may be that DCAS wants to 

21 consider whether any of these overarching 
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1 issues are an appropriate subject for an OTIB, 

2 or whatever, some sort of document. So that 

3 when we have that discussion --

4 DR. MAURO: Maybe all this needs 

5 to say is transferred to, like you did with 

6 the others, transferred to -- it is a global 

7 issue, and the way that ends up being handled 

8 right now, I guess we don't know.

9 MEMBER ZIEMER: Yes, I'm not even 

10 sure you need to put --

11 DR. MAURO: No, I was going to 

12 say, you don't need that. You can just say 

13 transferred to a global issue.

14 DR. BEHLING: Well, John, this is 

15 Hans Behling. Can I just make a comment?

16 DR. MAURO: Sure.

17 CHAIR MUNN: Please.

18 DR. BEHLING: Because the question 

19 was whether or not there is an OTIB. The 

20 issue of angular dependence was heavily 

21 discussed during the time that I reviewed 
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1 Implementation Guide 1. And I think I 

2 provided some strong documentation from 

3 various texts that talked about angular 

4 dependence of photo -- film dosimeters as a 

5 function of energy and angle. And I think we 

6 had some fairly extensive discussions back in 

7 the very early days when we were reviewing the 

8 basic documents, including Implementation 

9 Guide 1 and 2. So there is a significant 

10 amount of information that had been submitted 

11 and discussed several years ago on this issue.

12 DR. MAURO: And interestingly 

13 enough, when we were looking at OTIB -- OCAS 

14 IG-001, which is the document that -- as being 

15 one of the ones we were going to do a two16 pager for, we ended up not doing a two-pager 

17 because all of the issues have not been 

18 resolved. So, in principle, this issue that 

19 we are talking about right now has a home, and 

20 that home, as Hans has pointed out, is OCAS 

21 IG-001.
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1 CHAIR MUNN: Is an IG.

2 DR. MAURO: Now the question is, 

3 has that issue been resolved in the issues 

4 resolution process for OCAS IG-001?

5 DR. OSTROW: John, the only open 

6 issue for 001 -- is a mislabeling of one of 

7 the findings.

8 DR. MAURO: So this has been 

9 resolved?

10 DR. OSTROW: Everything has been 

11 resolved.

12 DR. MAURO: Oh, so this may have 

13 already been resolved. Any way we could find 

14 that out? You know, the degree to which 

15 issues resolution related to OCAS IG-001 did, 

16 in fact, resolve angular dependence, fading, 

17 and whatever?

18 DR. BEHLING: They were really 

19 never resolved, John, because the simple fact 

20 is this. When we calibrate a film dosimeter, 

21 the standard protocol is to use, obviously, 
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1 some source of radiation, and then the film 

2 badges are exposed to that point source 

3 usually at right angles or normal to the 

4 incidence of the film. And that, of course, 

5 is the optimum position of a dosimeter to 

6 respond to the imparted energy.

7 And if I look, for instance -- and 

8 again, I just opened up my old trustworthy 

9 radiation dosimetry book that was issued by 

10 Heine and Brunell many, many years ago, and 

11 I'm looking at, for instance, the energy of 

12 photons at 200 keV, which is a very, very 

13 common central value associated with human 

14 exposures in the various environments that we 

15 are dealing with; namely, the 30 to 250 keV.

16 I can just simply recite the 

17 reduced response on a film dosimeter at zero 

18 degrees, it's 1.0 or normalized, then, 

19 therefore, to all the other values. At 22.5 

20 degrees, it's .92. At a 45-degree angle, it's 

21 .73. At 67.5, it's 45, and at 90 degrees, 
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1 it's .41.

2 So if you actually average those 

3 values out, a dosimeter that is uniformly 

4 exposed from a source term that is rotational 

5 or omnidirectional or 2 pi geometry, you would 

6 expect a response that is, in essence, around 

7 70 percent of what that response should be. 

8 In other words, you are underestimating the 

9 true exposure that individual received by 

10 about 30 percent.

11 DR. MAURO: Okay. Has that been 

12 adopted?

13 MEMBER ZIEMER: Well, I don't know 

14 if that's been adopted. I mean, you don't 

15 have to adopt that. I mean, those are 

16 physical facts, and I don't think that has 

17 ever been disputed.

18 The issue really is, in practice, 

19 it would be very rare, maybe impossible, to 

20 always have normalized beams hitting you --

21 even though it is a beam, you would get 
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1 scatter, and so on -- in a particular case.

2 Unless you knew that the exposure 

3 was always from, you know, a 1-degree angle or 

4 something where you have a terrific miss of 

5 the dose, you end up integrating. And then, 

6 in the sort of general case, you do what Hans 

7 said, you say, well, you assume that it is 

8 distributed over all angles over sort of an 

9 even period of time. Then your dosimeter has 

10 missed about 30 percent of the total, and you 

11 can adjust for that.

12 So all you have to really do is 

13 say, okay, here's the correction factors we 

14 would normally use in a typical field.

15 DR. MAURO: Yes.

16 MEMBER ZIEMER: Here's the 

17 correction factors we would -- you do have 

18 some workers that are always head-on into a 

19 beam, maybe a glovebox worker, or so on, 

20 although it's not always that direct and it is 

21 scattered. But I think you could come up with 
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1 a scheme where you said, here's the conditions 

2 under which you would use the actual reading 

3 or here are the conditions under which you 

4 would correct it by 1.3 or some value. And 

5 that's what you're talking about, I guess.

6 DR. MAURO: Yes.

7 MEMBER ZIEMER: Yes. And I guess 

8 what they're talking about here.

9 DR. MAURO: Yes. The thing is 

10 this was an issue raised related to OCAS 

11 IG-001.

12 CHAIR MUNN: And it's been raised 

13 again and again and again, and unless we are 

14 prepared to discuss IG-001 right here, which I 

15 am not -- I have not seen it, and it isn't 

16 even on my list anymore. We used to have 

17 IG-004 on there.

18 But I would like to suggest that 

19 we ask, that we be prepared to take a look at 

20 existing documentation which may cover any 

21 question that is being raised here. Since we 
252 

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1 know it has been discussed earlier before, may 

2 we ask NIOSH and/or SC&A or both to please 

3 verify what is contained in the IG document 

4 that might or might not bear on that?

5 MR. KATZ: I think if you consult 

6 Jim Neton, I think he was on the other end of 

7 this discussion, this extensive discussion.

8 MEMBER ZIEMER: Right.

9 MR. KATZ: There were a series of 

10 discussions, as it might have been actually 

11 with Hans and others, and he probably can

12 recollect where to look for exactly how this 

13 was resolved.

14 MEMBER ZIEMER: You see, some of 

15 it is also taken care of in other ways, like 

16 the film badges. Sure, there's energy 

17 dependence, but, typically, they have several 

18 filters and the film badge company can make a 

19 correction within reason, unless you're using 

20 an extremely different energy that they don't 

21 know because they calibrate it at certain 
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1 energies, too. They can, to some extent, 

2 bracket the energy based on the film badge 

3 response and the filters.

4 But, anyway, we don't need to get 

5 into that detail here, but I guess the 

6 question is is there -- there must be some 

7 standard ways that we can do this, if we need 

8 to have a methodology defined.

9 MR. HINNEFELD: I would believe 

10 so. I think that the suggestion to go back to 

11 IG-001 -- well, IG-001 sounds like it should 

12 be the home for the global issues.

13 MEMBER ZIEMER: Right.

14 MR. HINNEFELD: That's one thing.

15 MEMBER ZIEMER: See what it 

16 already says about it.

17 MR. HINNEFELD: And then go back 

18 and refresh our memories on that discussion. 

19 I remember the discussions. I just don't 

20 remember resolutions very well.

21 MR. KATZ: So IG-001 is not in 
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1 this database?

2 IG-001 is not in this database?

3 MR. MARSCHKE: No.

4 MR. HINNEFELD: No, it's not.

5 MR. MARSCHKE: No, I can't reach 

6 it. No, it's not reachable in this database. 

7 You may be able to bring it up, Stu, but I 

8 can't bring it up.

9 MR. HINNEFELD: So you can't see 

10 it?

11 MR. MARSCHKE: I can't see it.

12 CHAIR MUNN: The only thing that 

13 is in this database is information --

14 MR. MARSCHKE: No IGs, no PERs.

15 DR. MAURO: Well, when we reviewed 

16 them, that was the first one we --

17 MR. HINNEFELD: Yes, but I think 

18 we may have gotten done with it before --

19 DR. MAURO: But it's not in this 

20 database?

21 MR. HINNEFELD: -- before we got 
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1 the database going. That's the only thing I 

2 can think of, back when we were using tables 

3 and matrices.

4 MR. MARSCHKE: It's one of those 

5 things that we talked about this morning when 

6 we talked about the database.

7 MR. HINNEFELD: Yes.

8 MR. MARSCHKE: It's one of the 

9 deficiencies of the database, in that it does 

10 not --

11 DR. MAURO: Have everything?

12 MR. MARSCHKE: In some ways, we 

13 can see how many issues were raised in IG-001, 

14 how many of them have been resolved, but we 

15 can't see what the issues were. We can't see 

16 what the resolutions were.

17 DR. MAURO: Yes, I have the sense 

18 from this morning's discussion that there were 

19 a number of new PERs, for example, PER 9, 

20 12 --

21 MR. MARSCHKE: That is true, too.
256 

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1 DR. MAURO: -- that we would like 

2 to load now because we have recently completed 

3 our work. But I'm hearing that there are also 

4 some that we did five years ago, reviews of 

5 procedures, such as --

6 MR. MARSCHKE: That was discussed 

7 this morning as well.

8 DR. MAURO: Oh, I didn't hear 

9 that. My apologies.

10 MR. MARSCHKE: We talked about 

11 that.

12 DR. MAURO: And we have to load 

13 those, also.

14 MR. MARSCHKE: We have to somehow 

15 access them. I don't know. They may be 

16 already loaded somewhere. I don't know how 

17 this database works.

18 MR. HINNEFELD: Yes, I'll have to 

19 figure that out with the guys back in the 

20 office, but --

21 MR. MARSCHKE: So you can, 
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1 basically, again, it's like -- I've got it 

2 here.

3 CHAIR MUNN: This brings up 

4 another item which this particular format also 

5 has robbed us of, and that is the ability to 

6 tell when these items came to us. Our earlier 

7 database had them grouped by -- we could tell 

8 by date. We received groups of procedures by 

9 certain dates. And this does not give us a 

10 feel for whether we are dealing with a group 

11 1, a group 2, group 3, or --

12 DR. MAURO: Yes, I remember that. 

13 Right.

14 CHAIR MUNN: -- additional 

15 findings.

16 And there are times when that 

17 information is very useful to us. Certainly, 

18 the next time we make a report to the 

19 Secretary, it will be enormously useful, and 

20 I'm not quite sure how to parse that out of 

21 this.
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1 MR. HINNEFELD: And also, 

2 everybody should remember IG-001 was reviewed 

3 twice. There's a Rev. 1 review and there's a 

4 Rev 2. review. The Rev. 2 review still has, 

5 according to the database -- it comes up for 

6 me because of -- rights, I guess -- there were 

7 24 findings, and I believe 11 are still open.

8 CHAIR MUNN: And you see, if 

9 they're open, then why am I not seeing them on 

10 this database?

11 MR. MARSCHKE: Basically, if you 

12 pull up, like we talked this morning, if you 

13 pull up the reports file, Wanda, if you go up 

14 to the top of the database, under the Reports 

15 button, and you click on the SC&A Finding 

16 Status Report, you will see IG-1, 2, 3, or 1, 

17 2, and 4 up there.

18 Like Stu said, there were 24 

19 issues for IG-1, seven for the Rev. 2, and 17 

20 for Rev. 1.

21 Now this database will pull up 
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1 this information, but it will not -- let me go 

2 back to the documents screen. None of the IGs 

3 are in these 91 documents. If you go and look 

4 for IG in one of these documents, you don't 

5 find any. None of the IGs. So it's there, 

6 but it's not there.

7 DR. MAURO: I think this is very 

8 important. IG-1 and 2 are the rock we stand 

9 on. They are the starting point in this whole 

10 process.

11 CHAIR MUNN: Yes.

12 DR. MAURO: We've got to get that 

13 into the system.

14 CHAIR MUNN: Yes, we need to be 

15 able to reference them easily, and I am still 

16 not getting them, but there is no point in our 

17 dealing with that. That is a mechanical 

18 thing.

19 I think our request of NIOSH now 

20 is fairly clear, and we can probably move on 

21 from there.
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1 Do we have anything? What's our 

2 next item in 13 that we need to look at?

3 MR. MARSCHKE: That was basically 

4 -- so that was just left as in progress?

5 CHAIR MUNN: Yes.

6 MR. MARSCHKE: Item 13-5 was some 

7 discussion as to how the assumed worker height 

8 and placement of the dosimeter on the worker 

9 was obtained as well as verification that it 

10 creates a plausible upper bound for the 

11 claimant would benefit the analysis.

12 And NIOSH says, "Will be added. 

13 See also response to finding 3."

14 And, again, since NIOSH has agreed 

15 that it will be added, my recommendation was 

16 to change the status to in abeyance.

17 CHAIR MUNN: Reasonable. Any 

18 objection to in abeyance?

19 (No response.)

20 All right. 

21 DR. MAURO: I hate to do this, but 
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1 we don't know what those adjustment factors 

2 are, do we? They are saying that they will be 

3 provided. What does it say again? I guess it 

4 sounds a lot like what we just worked on.

5 MR. MARSCHKE: "Some discussion as

6 to how the assumed worker height and placement 

7 of the dosimeter on the worker was obtained as 

8 well as verification that it creates plausible 

9 upper bounds will benefit the analysis."

10 So, it's basically they want, we 

11 said we wanted a discussion.

12 DR. MAURO: Yes, that's true.

13 MR. MARSCHKE: And basically, 

14 NIOSH said that they will provide the 

15 discussion.

16 DR. MAURO: Okay. You're right. 

17 It does not say we want to see what the 

18 adjustment factors are. That's the other one, 

19 I guess, the one we just talked about.

20 MR. MARSCHKE: Yes.

21 DR. MAURO: Okay.
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1 MR. MARSCHKE: And the last one 

2 was 13-6. "TIB-13 does not represent a 

3 scientifically valid or claimant-favorable 

4 approach to developing a correction factor for 

5 organs in the lower torso. The TIB 

6 underestimates the DCF by a factor of almost 

7 five. This appears to be essentially a 

8 restatement of finding 4. So see response to 

9 finding 4."

10 And since finding 4 was left as in 

11 progress, I believe that we should probably 

12 leave this -- I think the recommendation was 

13 to leave this one as in progress.

14 DR. ULSH: What's the difference 

15 between and that --

16 MR. MARSCHKE: Part --

17 DR. ULSH: What was it, addressed 

18 in?

19 MR. MARSCHKE: That's what --

20 again, either we can change it to addressed in 

21 OCAS TIB-44 -- or 13-4 or we can just leave it 
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1 as standalone, as in progress.

2 DR. MAURO: I vote for addressed 

3 in because for all intents and purposes -- I 

4 hate to make it appear that there are two 

5 issues here when there really is one.

6 MR. KATZ: I agree.

7 MR. MARSCHKE: So we change this?

8 CHAIR MUNN: Addressed in, that's 

9 better.

10 Okay, excellent. Anything else on 

11 TIB-13?

12 (No response.)

13 If not, the next item we have on 

14 our list is OTIB-49-01 and 02.

15 There was going to be some 

16 technical conversation between NIOSH and SC&A 

17 relative to plutonium retained in the lung. 

18 Has that discussion occurred?

19 DR. ULSH: I'm not aware that it 

20 has occurred.

21 MR. MARSCHKE: I'm not, either.
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1 DR. MAURO: But can you hear a 

2 little bit about what that's about? In other 

3 words, what's that discussion as to context? 

4 Do you know what that is? This is the high5 fired plutonium one, isn't it, the 49?

6 DR. ULSH: I think that's the 49.

7 DR. MAURO: So there was some 

8 reason why we felt -- because I know that we 

9 reviewed that, and we approved it. We found 

10 it fine. I was surprised to hear there's more 

11 discussion regarding it, and I just wanted to 

12 get the context.

13 CHAIR MUNN: We have had these 

14 items, we have carried these forward for a 

15 long time.

16 MEMBER ZIEMER: Notes from last 

17 time on 01 and 02, the note I wrote to myself 

18 was, "NIOSH and SC&A are both going back to 

19 review and clarify these issues." That must 

20 have been -- we'd have to go back to the 

21 earlier one then.
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1 CHAIR MUNN: This is estimating 

2 doses of plutonium strongly retained in the 

3 lung.

4 MEMBER ZIEMER: It looks like 

5 there was some lack of clarity on what the 

6 issues were.

7 MR. MARSCHKE: I believe that was 

8 -- Stu, did you send an email way back?

9 MR. HINNEFELD: Oh, is this that 

10 thing?

11 MR. MARSCHKE: I think this is 

12 that thing; it's your email, because that's 

13 what my notes say. "Look for Stu's email last 

14 fall." So that's what I have in my notes from 

15 the last meeting.

16 MR. HINNEFELD: Okay. The general 

17 context of this is that there were two 

18 findings written on this, at least two 

19 findings. And we provided responses to both. 

20 And SC&A came back with essentially a non21 assent, you know, additional discussion sort 
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1 of thing on one of the findings. And on the 

2 other findings, they came back with 

3 essentially, again, a non-consent, additional 

4 findings.

5 But, in the second finding, they 

6 were not consenting with our first response. 

7 It was unrelated to our response to the second 

8 finding. It was additional response to the 

9 first finding, as I read it.

10 MR. MARSCHKE: Okay.

11 MR. HINNEFELD: And I guess that's 

12 what we were trying to clarify, and that will 

13 require Joyce on the phone to do that.

14 Because I wrote a fairly long 

15 thing of trying to piece all this together and 

16 how did we get where we are. That's what I 

17 arrived at. As far as I know, there was one 

18 finding that I thought should have been closed 

19 from our first response -- or previous 

20 response. I don't know if it was our first or 

21 not.
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1 But the dissenting opinion didn't 

2 reflect that finding, but it reflected the 

3 first finding. So that's what the issue was 

4 and that's what we were going to talk about, 

5 is to see if Joyce, (a) agreed with my 

6 interpretation, okay, it really is the one 

7 finding. And that's what I wanted to continue 

8 discussion about. That's what I thought.

9 CHAIR MUNN: Well, we have been 

10 carrying it forward for a year.

11 MR. HINNEFELD: I'm tempted not to 

12 change anything in it.

13 DR. MAURO: Just leave it? The 

14 ball's in our court, though. Clearly, Joyce 

15 is center-stage on an awful lot of stuff we're 

16 doing here. We've got to get her involved. 

17 She is very busy with other matters, but it is 

18 important that we schedule her in for the next 

19 time we get together.

20 CHAIR MUNN: Well, this technical 

21 discussion thing is really hanging us up on 
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1 this particular issue.

2 DR. MAURO: We have Rich Leggett 

3 and Dunstana Melo, also, who have very, very 

4 strong backgrounds in the very same subject 

5 areas. I'm thinking that what I could do to 

6 have more depth here, so that folks are on 

7 travel, we can still cover these. I hate to 

8 see us, you know, go through the whole day and 

9 have to leave behind so many items. I will 

10 see what I can do to have available to us a 

11 little bit of a fallback position, so that we 

12 don't have to have so much stuff on hold.

13 CHAIR MUNN: Yes, that would be 

14 most helpful, John. Thank you very much.

15 The next item that I have is 

16 Procedure 42, scaling factor, finding 06. Is 

17 there a status change?

18 DR. ULSH: Elyse, do you have 

19 anything to add or to contribute on that one?

20 MS. THOMAS: Let's see, I think 

21 the only thing or the last thing that I have 
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1 is that there was a response added to the 

2 database for finding 06. So let me get there.

3 So it may be that SC&A needed to 

4 just verify that they were okay with that 

5 additional information, and then --

6 CHAIR MUNN: Elyse, the database 

7 shows your response on July 16th. "While it's 

8 possible for the scaling methodology to be 

9 used to reduce the doses shown in table 5.1, 

10 DCAS staff directed ORAU staff not to apply a 

11 negative scaling factor, as part of an email 

12 communication and personal discussion in 2004. 

13 Therefore, the values in table 5.1 are either 

14 used as is or scaled upward, when appropriate, 

15 as described by the procedure. The procedure 

16 will be revised to incorporate this guidance."

17 So, apparently, there's been no 

18 status change on that, and this is essentially 

19 in abeyance, is that correct? Am I reading 

20 that properly?

21 MS. THOMAS: Yes, that sounds 
270 

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1 right. I mean, we modified the response, but 

2 we have not modified the document.

3 CHAIR MUNN: So we already have it 

4 listed as in abeyance. There is no change on 

5 it.

6 And I'm going to take that off the 

7 list of carrying because we will see something 

8 when you have changed it, right?

9 MS. THOMAS: Yes.

10 CHAIR MUNN: Good.

11 Now we have a continuation of 

12 carryover items that include quite a number of 

13 things. I'm a little concerned about 

14 undertaking them until we have made sure that 

15 we have covered the business of the two-page 

16 summaries, because that's something I really 

17 do want to ensure that we get in front of the 

18 Board, if we possibly can.

19 Let's put our database on hold for 

20 just a moment, and, if you have before you the 

21 four documents that have been provided to you 
271 

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1 as two-pagers --

2 DR. OSTROW: Excuse me, Wanda. We 

3 actually sent five of them.

4 CHAIR MUNN: We sent five, but we 

5 haven't had an opportunity, the fifth one just 

6 got here.

7 DR. OSTROW: Yes, about two weeks 

8 ago, I think, something like that.

9 CHAIR MUNN: Oh.

10 DR. OSTROW: Actually, no, on 

11 September 29th we sent it out.

12 CHAIR MUNN: Oh, I haven't 

13 addressed that, and I haven't heard back from 

14 anybody else.

15 MEMBER ZIEMER: Well, the fifth 

16 one was the tritium one that we did before. 

17 Didn't you just redo that?

18 DR. OSTROW: No, the fifth one we 

19 sent with OCAS-IG-002.

20 CHAIR MUNN: Yes.

21 MEMBER ZIEMER: Oh, I did get 
272 

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1 that.

2 CHAIR MUNN: Yes. It's a brand3 new one.

4 But we have the four that are 

5 done. At least I have messed them up pretty 

6 nicely. And if you can pull those up, let's 

7 take a look at them and see if we can go 

8 through them numerically, I suppose.

9 OCAS-PR-003. The only changes 

10 that I made in any of these when I was editing 

11 them was to try to simplify them, frankly. No 

12 matter how hard we try, technical people have 

13 a tendency to write in a technical format, and 

14 we have to try to overcome that when we're 

15 aiming for easily-understood documentation 

16 that's going to be a permanent part of the 

17 public record.

18 So, as kind of a rule of thumb, 

19 what the subgroup of your Subcommittee who 

20 worked on the initial document, which we were 

21 using as our straw man from the last couple of 
273 

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1 sessions, and has been approved by the Board, 

2 is now ready to go up.

3 For your information, we will be 

4 working with Brant over the next few weeks, 

5 probably following the Santa Fe meeting, to 

6 try to get together with the IT folks and 

7 agree on a format and how and where to put 

8 those up on our web page, so that they will be 

9 available to everybody.

10 One of the things that I hope will 

11 happen, and I would like to get the agreement 

12 of the Subcommittee to that, I see these 

13 documents as documents that SC&A is putting 

14 together for us, but I see them as Board 

15 documents. They require approval of the Board 

16 in order for us to release them to be placed 

17 on the site. I think they are the kind of 

18 thing to which we will refer in our next 

19 report to the Secretary.

20 That being the case, as we go 

21 through here, there are one or two minor 
274 

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1 things that we will need to change. For 

2 example, we will need to, instead of just 

3 referring to SC&A from time to time, we will 

4 need to say something like "The Board's 

5 current practice" or something to that effect.

6 Yes?

7 MEMBER ZIEMER: I would like to 

8 reinforce that. I have exactly the same idea. 

9 Because unlike the SC&A reports, which we 

10 deal with the findings, but that's still your 

11 report, we don't change the report.

12 DR. MAURO: Right. Right. You're 

13 taking ownership of it.

14 MEMBER ZIEMER: But here we are 

15 adopting them. To some extent, they are like, 

16 you know, we only have a couple of products. 

17 One product is letters to the Secretary which 

18 come out of our process and reports to the 

19 Secretary. I think these are like that.

20 DR. MAURO: Okay.

21 MEMBER ZIEMER: So, John, you'll 
275 

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1 notice my markup.

2 DR. MAURO: Yes, yes.

3 MEMBER ZIEMER: I changed the 

4 authorship.

5 DR. MAURO: Right.

6 MEMBER ZIEMER: And it's exactly 

7 what you said. This is a document of the 

8 Advisory Board, and then I would have it 

9 footnoted somewhere saying this document was 

10 developed with the assistance of the Board's 

11 contractor, S. Cohen & Associates, or 

12 something, because we've got to acknowledge 

13 that they really did a lot of the work, but it 

14 becomes our document.

15 That also affects how some of the 

16 things are stated in terms of --

17 DR. MAURO: Sure. Absolutely.

18 Well, could I change the optics up 

19 a little bit? As your contractor, we deliver 

20 the draft to you that is a work product of 

21 SC&A.
276 

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1 MEMBER ZIEMER: Right.

2 DR. MAURO: Now you are in the 

3 process, you have to decide whether we think 

4 that this work product as delivered met the 

5 intent of the mandate you gave us.

6 MEMBER ZIEMER: Right.

7 DR. MAURO: And if it basically 

8 meets some threshold of acceptability, then 

9 you're going to take it, and we're not 

10 involved anymore.

11 MEMBER ZIEMER: Right.

12 CHAIR MUNN: Correct.

13 DR. MAURO: Unless you want us to 

14 help, you know, make the edits that you would 

15 like to make. So it's no longer ours.

16 MEMBER ZIEMER: Right. Right. I 

17 think that's the concept.

18 CHAIR MUNN: That is my intent.

19 DR. OSTROW: Let me understand, 

20 then. What you would like to do is that we 

21 deliver as best we can these summaries, and 
277 

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1 then you'll do the final edit and get it into 

2 the system?

3 MEMBER ZIEMER: Well --

4 MR. KATZ: Let me just jump in on 

5 this final point.

6 MEMBER ZIEMER: Yes.

7 MR. KATZ: I think SC&A should go 

8 ahead and do the edits and so on because 

9 they're your contractor.

10 DR. MAURO: Which brings me to a 

11 different question. Really, there are two 

12 parts.

13 We could deliver to you a product 

14 that will read as if it's yours.

15 MEMBER ZIEMER: Right, right.

16 MR. KATZ: Yes, I think that's 

17 easier.

18 DR. MAURO: Okay. Fine.

19 MR. KATZ: Yes.

20 MEMBER ZIEMER: Right.

21 MR. KATZ: Does that work for the 
278 

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1 Board?

2 DR. MAURO: Yes. Fine. And we'll 

3 refine it.

4 MEMBER ZIEMER: Not unlike ORAU 

5 assisting NIOSH in developing a NIOSH 

6 document.

7 MR. KATZ: Exactly right.

8 DR. MAURO: Okay. Good. That 

9 changes what we have to do. So, in effect, 

10 right now there are a number of comments that 

11 you have here which are both editorial, you 

12 know, substance, and also of the way in which 

13 it is presented to the world, that you are 

14 going to communicate to us in some way, and we 

15 will go ahead and make all those edits, which 

16 include making it a Board document --

17 CHAIR MUNN: Right.

18 DR. MAURO: -- and get that back 

19 to you.

20 CHAIR MUNN: Let me repeat before 

21 we start these. Some of the obvious things 
279 

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1 that the subgroup worked on with the straw man 

2 in determining exactly what we were going to 

3 aim for in terms of level of 

4 understandability, we agreed that any time you 

5 see -- we agreed that we would not use 

6 acronyms if we could avoid it.

7 We agreed that in cases where we 

8 were addressing a procedure, we would put the 

9 title of the procedure before the procedure 

10 nomenclature that we usually use because 

11 seeing something like OCAS-PR-003 turns people 

12 off and their minds just simply jump over 

13 that. So we want them to see the titles 

14 rather than this sort of thing.

15 We want not to use a complicated 

16 word if there are simpler ways to say it, even 

17 if it requires more words to say it. We want 

18 to use sentences that are as short as 

19 possible.

20 And we want to try to make sure 

21 that a reasonable person could pick this up 
280 

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1 and read through it and not have any major 

2 questions outstanding about what did that 

3 mean?

4 So those were basically the 

5 guidelines that we sort of set out for 

6 ourselves.

7 DR. MAURO: And you did. I guess 

8 it was our intent to try to meet that.

9 CHAIR MUNN: Right.

10 DR. MAURO: But clearly, we didn't 

11 entirely do that.

12 CHAIR MUNN: Well, as I said, it's 

13 very difficult for technical people to write 

14 in a simplistic, non-technical manner because 

15 all of us write some other way.

16 But, with OCAS PR-003, how would 

17 you prefer that we address this? Would you 

18 like me to simply read through, so that it 

19 reads the way my markup reads or would you 

20 like to address things in a different way?

21 DR. OSTROW: Well, Wanda, I read 
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1 through the four procedures that you commented 

2 on, and I accept all your comments in all the 

3 documents with the reservation of maybe an 

4 occasional edit, a typo here or there. But I 

5 accept all your comments. I don't think that 

6 we have to go through them all; I mean, unless 

7 you want to.

8 DR. MAURO: Well, certainly, 

9 between the Work Group Members, you may want 

10 to.

11 CHAIR MUNN: Yes.

12 DR. MAURO: But we are prepared to 

13 receive your direction to make the editing 

14 that you folks together agreed to.

15 CHAIR MUNN: Thank you, John. 

16 Thank you.

17 DR. MAURO: So, really, we're not 

18 part -- we're sort of outside, on the 

19 sideline.

20 DR. OSTROW: I understand your 

21 comments, and I agree with them all, as I 
282 

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1 said, just with the exception of a few minor 

2 edits on what you did, mainly for typo sort of 

3 things.

4 CHAIR MUNN: Yes, very possibly 

5 so. I certainly didn't check my work very 

6 thoroughly after I had done it.

7 On the telephone, Mark or Richard, 

8 do you have any comments to make before we 

9 sort of take our first little stab at PR-003?

10 MEMBER LEMEN: I don't. Just go 

11 ahead, and I'll comment if I have any.

12 CHAIR MUNN: Thank you, Richard.

13 Mark?

14 (No response.)

15 Mark still hasn't joined us.

16 As you will notice, just glancing 

17 at this page, you will see that I highlighted 

18 a parenthetical statement down under finding 

19 4. That was --

20 MEMBER ZIEMER: Hang on. Is there 

21 a new version of this that is marked up -- or 
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1 what are you looking at?

2 CHAIR MUNN: There is a marked-up 

3 one. We are looking at the email that I sent 

4 last night.

5 MEMBER ZIEMER: Oh, okay.

6 CHAIR MUNN: With enormous 

7 apologies to all concerned for the lateness of 

8 it.

9 MEMBER ZIEMER: So I should check 

10 my email, that's what I should do. 

11 (Laughter.)

12 MR. MARSCHKE: Paul, it's up on 

13 the screen up here.

14 DR. MAURO: Oh, that's great. 

15 That's the way to do it. Way to go.

16 MEMBER ZIEMER: I should be able 

17 to pull it up.

18 CHAIR MUNN: I was having -- my 

19 laptop does not have Acrobat on it, and so I 

20 was having a hard time manipulating the files.

21 MEMBER ZIEMER: Did you send that 
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1 to my CDC address or to --

2 CHAIR MUNN: No. No.

3 MEMBER ZIEMER: Oh, that's why I 

4 don't have it. Okay.

5 DR. OSTROW: You may want these as 

6 Word documents.

7 MEMBER ZIEMER: I'll just look up 

8 here.

9 CHAIR MUNN: Yes. All I really 

10 needed to do was to --

11 DR. OSTROW: How did we send these 

12 to you, in Word or with Adobe Acrobat?

13 CHAIR MUNN: Well, these were PDF 

14 files.

15 DR. OSTROW: Okay. That's our 

16 fault, then. In the future, I'll send them to 

17 you as Word files.

18 CHAIR MUNN: As long as I have a 

19 Word file, I have no problem.

20 DR. MAURO: Yes, that's just, you 

21 know, we're in such a habit of delivering our 
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1 products in PDF because they're ours, but this 

2 is a different circumstance.

3 CHAIR MUNN: Yes, it is, and I can 

4 understand how, when you're dealing with a 

5 file, you don't want anybody to have anything 

6 but read-only capability. Then that's fine. 

7 And I really should have called Nancy, but I 

8 was arrogant and believed that I could have a 

9 PDF without any problem.

10 DR. OSTROW: It's tough to do a 

11 markup like this in PDF.

12 CHAIR MUNN: It really -- well, I 

13 changed it.

14 DR. MAURO: All you had to do was 

15 call Nancy, and she would have sent you one.

16 DR. OSTROW: Yes, I gave it to 

17 Nancy in Word. She converted it to PDF.

18 CHAIR MUNN: Do you have it now, 

19 Paul?

20 MEMBER ZIEMER: No, but I'm 

21 looking at the screen.
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1 CHAIR MUNN: Oh.

2 MR. KATZ: It's on the screen.

3 CHAIR MUNN: All right. Would you 

4 like -- would anyone like a read-through?

5 MEMBER ZIEMER: No.

6 CHAIR MUNN: All right. Then I 

7 will draw your attention again to the 

8 parenthetical comment that's highlighted under 

9 finding 4.

10 MEMBER ZIEMER: Hold it there a 

11 minute.

12 DR. MAURO: Could I -- because I 

13 have a perspective on this, also. Originally, 

14 when we were conceptualizing this, I know that 

15 you put your format out, but the idea of 

16 putting the findings in, the findings, 

17 sometimes it's three; sometimes it's a dozen, 

18 and sometimes they're burdensome.

19 This is certainly for the Work 

20 Group's consideration. Perhaps we don't do it 

21 that way. Perhaps we just describe in 
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1 layman's terms the essence of what the 

2 findings were and get away from delineating 

3 the findings because that, to me, is 

4 burdensome on the reader. I would rather just 

5 tell a story.

6 CHAIR MUNN: It is burdensome on 

7 the reader. And as a matter of fact, I think 

8 the findings need to be listed individually, 

9 but not in the same language that they were 

10 originally presented.

11 DR. MAURO: Oh, okay.

12 MEMBER ZIEMER: They don't 

13 necessarily have to be word-for-word.

14 CHAIR MUNN: That's what I have 

15 done here.

16 DR. MAURO: Okay.

17 CHAIR MUNN: I have changed what 

18 the findings say in several instances, and 

19 certainly in a couple of the documents the 

20 technical verbiage was so thick that you 

21 really would have had to have been sitting 
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1 around this table for a good many years to be 

2 able to absorb it.

3 DR. MAURO: Right, I agree with 

4 you. Yes.

5 Toward that end, if we are in the 

6 process of doing a future one where it's our 

7 judgment, you know, that these three or four 

8 readings really could be collected into a 

9 descriptive material that collapses it to a 

10 much simpler statement regarding them, or do 

11 you want to not lose that there were 11 

12 findings?

13 CHAIR MUNN: I think we would 

14 prefer at this juncture not to lose that there 

15 were 11 findings.

16 DR. MAURO: Okay. Good.

17 CHAIR MUNN: That seems logical to 

18 me.

19 DR. MAURO: Okay. That's fine.

20 CHAIR MUNN: But we may find a way 

21 to circumvent that later or find it necessary 
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1 to circumvent that later down the road.

2 DR. OSTROW: Excuse me, Wanda. In 

3 cases like John is talking about, if we have, 

4 let's say, a bunch of findings, and three of 

5 them are essentially the same issue, we can 

6 still list them, but have an additional 

7 comment that Issues 5, 7, and 12 are 

8 essentially the same or deal with the same 

9 issue, something, a little bit of guidance in 

10 addition.

11 MEMBER ZIEMER: But you wouldn't 

12 lose the number.

13 DR. OSTROW: Yes. Have a little 

14 commentary on the findings.

15 CHAIR MUNN: I am quite sure that 

16 we will find -- you have done such a good job 

17 of selecting a very broad difference of 

18 procedures here to look at.

19 DR. MAURO: Well, I would say, if 

20 you want to communicate that there were 37 

21 findings here, 12 findings, or whatever the 
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1 number, we can say that, and then go on to 

2 conceptually describe what they were about, 

3 without actually having every finding.

4 CHAIR MUNN: Certainly, if we have 

5 37 findings, that's going to be pretty much 

6 necessary.

7 DR. MAURO: I like that. Because 

8 I think that's what burdening us, is those 

9 findings.

10 CHAIR MUNN: We haven't counted 

11 that too much yet. But, certainly, in this 

12 case, for example, we had 11 findings.

13 DR. MAURO: Yes.

14 CHAIR MUNN: That's fine. They 

15 came through just fine in a brief enough 

16 manner that they can be comprehended.

17 DR. MAURO: Okay.

18 CHAIR MUNN: But I think we're 

19 going to have to do this on an individual 

20 procedure-by-procedure basis.

21 I just wanted to know what, "the 
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1 reviewer questions the need for OCAS PR-003," 

2 meant and why it was still in there. I don't 

3 know what reviewer. Was that a part of the 

4 finding?

5 DR. MAURO: Yes. That was part of 

6 the finding, I believe.

7 Steve, am I correct, in the 

8 findings list, they were just lifted directly 

9 from the original findings? We didn't do any 

10 editing to that?

11 DR. OSTROW: No. That's why it's, 

12 as Wanda points out, sometimes obscure because 

13 we tried to keep the same language. We just 

14 changed it slightly in a couple of cases where 

15 it wasn't written correctly to begin with and 

16 adequately.

17 DR. MAURO: What I'm hearing, 

18 though, is right now the marching orders --

19 this is only for the path going forward -- is 

20 that we keep the list of findings. If there 

21 are five, there's going to be five findings. 
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1 But we do have the, I guess, discretion to try 

2 to rewrite the findings in a way that makes it 

3 a little easier for the reader?

4 DR. OSTROW: Paraphrasing.

5 DR. MAURO: Okay. Fine.

6 CHAIR MUNN: Exactly. Yes.

7 DR. MAURO: Okay. Very good.

8 MR. MARSCHKE: Can I? I mean, 

9 just looking at this list of findings, a lot 

10 of them, three of them out of the six 

11 reference specific sections in the PR. And I 

12 question the usefulness. To somebody reading 

13 just a two-pager, who just has the two-pager 

14 in front of them, "subsection of Section 6," 

15 they're not going to know what you're talking 

16 about. "Guidance provided in Section 6.9 and 

17 6.10," they're not going to know what --

18 MEMBER ZIEMER: We could just say 

19 certain subsections of the document, 

20 generalize it.

21 MR. MARSCHKE: I would try to get 
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1 rid of specifics, references to specific 

2 sections or subsections of the document. I 

3 mean, that would be my contribution to this.

4 CHAIR MUNN: We can certainly do 

5 that.

6 MEMBER ZIEMER: Can I make a 

7 couple of suggestions on this?

8 CHAIR MUNN: Please.

9 MEMBER ZIEMER: One of the first 

10 places to eliminate acronyms is SC&A. I would 

11 suggest that we start, and you would probably 

12 start all of the documents somewhat similarly 

13 and say something like, "The Board's 

14 contractor, S. Cohen & Associates, reviewed 

15 the procedures and produced x findings as 

16 follows," or something like that.

17 CHAIR MUNN: Well, haven't we 

18 covered that in our -- remember when we did 

19 our first one, we had an introductory --

20 MEMBER ZIEMER: Yes. Oh, that's 

21 going to be in each one, isn't it?
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1 CHAIR MUNN: Well, it's not going 

2 to be in each one. It's going to be the first 

3 thing you see when you pull up this site.

4 MEMBER ZIEMER: Right. Right. 

5 Okay.

6 CHAIR MUNN: You'll see that 

7 business about --

8 DR. MAURO: That's right. You 

9 have the front paragraph.

10 CHAIR MUNN: Yes.

11 DR. MAURO: Now that's a good 

12 question.

13 CHAIR MUNN: Below that is the 

14 heading that you can click on for any one of 

15 the --

16 DR. MAURO: So on the website --

17 CHAIR MUNN: So you will have to 

18 have -- you at least will have had an 

19 opportunity to read that whole first section 

20 before you ever start this.

21 MEMBER ZIEMER: Okay. Then let me 
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1 offer an alternative, if we are going to use 

2 "SC&A" because I don't think you can guarantee 

3 that someone is going to have read that, which 

4 is dis-attached from the report.

5 Suppose you said, "Summary of the 

6 findings," "Results of the findings by the 

7 Board's contractor resulting from technical 

8 review," or something like that?

9 DR. OSTROW: I think that's good. 

10 In general, we'll change "SC&A" to "the 

11 Board's contractor."

12 MEMBER ZIEMER: Well, no. I was 

13 going to say put that in the title, and then 

14 you say, "SC&A reviewed the procedure." That 

15 links the two.

16 Otherwise, if someone comes in 

17 cold, just looking at the documents, you know, 

18 what's the "SC&A" part?

19 DR. MAURO: Right.

20 CHAIR MUNN: Well, yes, I don't 

21 think we should ever say "SC&A" in the body of 
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1 any of these. And that's one of the changes 

2 that we will make.

3 MEMBER ZIEMER: Well, yes, so 

4 right there in the sentence, then, you could 

5 say, "The Board's contractor reviewed the 

6 procedures."

7 CHAIR MUNN: Yes. Correct.

8 MEMBER ZIEMER: And actually, 

9 "made a number of comments" or -- are they 

10 just comments or do we call them findings

11 here?

12 CHAIR MUNN: "And had a number of 

13 findings," actually.

14 MEMBER ZIEMER: Okay.

15 CHAIR MUNN: Yes.

16 MEMBER ZIEMER: And then, just a 

17 fine edit, the first finding I think should 

18 say, "The procedure," not just "Procedure is," 

19 right? "The procedure?" Make a sentence?

20 CHAIR MUNN: Or "This procedure."

21 MEMBER ZIEMER: Or "This 
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1 procedure."

2 And likewise, in finding 4, 

3 "Procedure contains."

4 DR. MAURO: Okay.

5 CHAIR MUNN: Yes.

6 MEMBER ZIEMER: And then, I guess 

7 I had the same note you did. I was going to 

8 say, rather than "Lacks the level of detailed 

9 guidance provided in guidance documents 

10 utilized by NIOSH's contractor." I don't 

11 think we need to even mention Oak Ridge or 

12 ORAU, right?

13 CHAIR MUNN: Well, the only reason 

14 that I --

15 MEMBER ZIEMER: No, I think we can 

16 still mention the titles, but do we need the 

17 -- perhaps we give the titles first.

18 CHAIR MUNN: We do give -- well, I 

19 changed it around so the titles were first. 

20 Originally, they were not.

21 MEMBER ZIEMER: Okay, but these 
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1 are -- what I was trying to do is to link 

2 that. "These are guidance documents that are 

3 utilized by NIOSH's contractor," isn't that 

4 correct?

5 DR. MAURO: Some are; some aren't.

6 MR. HINNEFELD: Some are used by 

7 them; some are used by us.

8 MEMBER ZIEMER: Okay. So these 

9 two are not --

10 DR. MAURO: How about "program?"

11 MEMBER ZIEMER: Okay.

12 DR. MAURO: Yes, "used by the 

13 program."

14 MEMBER ZIEMER: No, no. If you're 

15 both using them, we don't need -- I was trying 

16 to differentiate between --

17 MR. HINNEFELD: Well, some are 

18 primarily theirs and some are primarily ours, 

19 but to us it's the program uses it all.

20 MEMBER ZIEMER: The program, okay.

21 MR. HINNEFELD: Because we 
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1 essentially sign off on it.

2 CHAIR MUNN: So you're suggesting 

3 that we take --

4 MEMBER ZIEMER: No, I think it's 

5 okay then. "This procedure contains some 

6 inconsistencies" --

7 CHAIR MUNN: Comma.

8 MEMBER ZIEMER: "Does not 

9 provide" --

10 DR. MAURO: Unless you're 

11 itemizing something here.

12 MEMBER ZIEMER: "And does not 

13 provide the level of detailed guidance 

14 given" --

15 MR. MARSCHKE: Other documents?

16 MEMBER ZIEMER: -- "in other 

17 guidance documents."

18 DR. MAURO: See, this is the 

19 problem we have with just listing the 

20 findings.

21 MEMBER ZIEMER: Right.
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1 DR. MAURO: You see why I tripped

2 over that.

3 MEMBER ZIEMER: "In other guidance 

4 documents used in the program, such as -- " 

5 DR. MAURO: Yes. Yes, yes. We 

6 weren't sure where we had the liberty to go 

7 ahead and fool with the findings.

8 CHAIR MUNN: Yes.

9 DR. MAURO: And now you're saying, 

10 yes, we do.

11 CHAIR MUNN: Yes, you do.

12 DR. OSTROW: Then we can write it 

13 in much clearer English.

14 MEMBER ZIEMER: Then, my 

15 suggestion here was just to leave out that 

16 parenthetical. I want to know why we need 

17 that in there.

18 CHAIR MUNN: Well, the only 

19 question is whether we could -- I asked the 

20 question earlier, was that a part of the 

21 original finding? And Steve said, yes, it 
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1 was, that a part of the finding was we 

2 questioned whether we even need this 

3 procedure. And so, the question before us, as 

4 the reviewer, I think, becomes, then, do we 

5 want to incorporate that thought? Do we need 

6 to capture that thought in this? Or is that 

7 truly a parenthetical expression just for our 

8 information and we can delete the entire 

9 thing? That's the real question.

10 DR. OSTROW: I believe the 

11 layperson doesn't need to know that at all. 

12 What are they going to do with that 

13 information?

14 CHAIR MUNN: Yes, it doesn't seem 

15 relevant to me. I'm going to delete it unless 

16 I hear to the contrary.

17 MEMBER ZIEMER: No, I would delete 

18 it.

19 Finding 6, again, we need the word 

20 "the" before "procedure" in finding 6 and 6.3 

21 of the procedure.
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1 Again, do we need the section 

2 numbers in there? The same in No. 5.

3 MR. MARSCHKE: I would take section 

4 numbers out because --

5 MEMBER ZIEMER: "Guidance provided 

6 is limited regarding connecting" -- you could 

7 leave out the sections, I would think.

8 MR. MARSCHKE: What about, if you're 

9 taking out section numbers, what about No. 2?

10 DR. OSTROW: Well, I think, in 

11 general, we have section numbers all over the 

12 place. We should take those out.

13 CHAIR MUNN: We have changed No. 2 

14 to read, "Some subsections of the procedure 

15 could be organized in a more logical format."

16 You had something in No. 6?

17 MEMBER ZIEMER: Well, the sixth one 

18 there, again, we can remove the section. And 

19 I guess it's guidance given for "conducting 

20 claimant interviews." Or "the claimant 

21 interview" or what? Is that "claimant 
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1 interviews?" Well, let's see.

2 DR. MAURO: It needs to be further 

3 developed or something like that.

4 CHAIR MUNN: Well, very brief is 

5 fine.

6 DR. MAURO: Okay.

7 CHAIR MUNN: It's fine.

8 MEMBER ZIEMER: Well, right now, it 

9 says, "claimant interview in the procedure." 

10 I guess we don't need to have the words "in 

11 the procedure," do we?

12 CHAIR MUNN: No. So all it really 

13 needs to say is, "Guidance given for 

14 conducting claimant interviews is very brief."

15 DR. OSTROW: Well, I think we 

16 changed "very" to "too brief," or "very brief" 

17 could be good.

18 MEMBER ZIEMER: Yes. I think the 

19 implication is it's too brief.

20 DR. OSTROW: Too brief.

21 MEMBER ZIEMER: And Nos. 7, 8, 9, 
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1 and 10, you need the word "the" in front of 

2 the "procedures" in every one of those.

3 MR. MARSCHKE: And the section 

4 number, take it out?

5 CHAIR MUNN: Yes. So it just says, 

6 "Guidance given for conducting claimant 

7 interviews is too brief."

8 MEMBER GIBSON: Since you are 

9 taking a lot of the words out in a lot of 

10 these findings, couldn't we further refine 

11 finding 4, cut a few more words out of it?

12 CHAIR MUNN: We probably could.

13 MEMBER ZIEMER: Probably.

14 MEMBER GIBSON: Something like, 

15 "Inconsistencies" -- "given in other procedure 

16 documents," period.

17 MEMBER ZIEMER: Or just "the 

18 program guidance." Yes, in other words, do 

19 you need to name them is what you are saying?

20 MEMBER GIBSON: Examples here --

21 because we took out all the subsections, so 
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1 they couldn't --

2 CHAIR MUNN: So you would like to 

3 say, "This procedure contains some 

4 inconsistencies and does not provide the level 

5 of detailed guidance given in other" --

6 MEMBER ZIEMER: "Program guidance."

7 MEMBER GIBSON: "Program guidance."

8 CHAIR MUNN: -- "other program 

9 documents?"

10 MEMBER GIBSON: Period. I mean, 

11 doesn't that say the same thing?

12 MEMBER ZIEMER: I think it's a good 

13 suggestion, Mike.

14 CHAIR MUNN: I like it when we make 

15 it shorter.

16 Now, finding 7. We'll remove 

17 "Section 6.1." We'll remove that.

18 And we will remove Subsections 

19 6.2.8 through 6.2.15. We'll just end with 

20 "identified." "Many types of information that 

21 are likely to be used are not properly 
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1 identified." Period.

2 Now the next one I think is one of 

3 those where you do want to leave the title 

4 there because you want to get the point across 

5 that this is a federal regulation, not just 

6 another procedure.

7 MEMBER ZIEMER: Do we need, though, 

8 the title and part number?

9 CHAIR MUNN: We don't necessarily 

10 need --

11 MEMBER ZIEMER: Can we say it's 

12 prescribed in the U.S. Code of Federal 

13 Regulations?

14 CHAIR MUNN: "Required by the Code 

15 of Federal Regulations" is fine.

16 MR. MARSCHKE: The Code of Federal 

17 Regs is a big document.

18 (Laughter.)

19 MEMBER ZIEMER: Well, I understand 

20 that.

21 MS. LIN: Actually, I think if you 
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1 can hold up on that, I'm checking with the 

2 guidance tracking office, if you can hold on.

3 MEMBER ZIEMER: Well, if we do, we 

4 can put in parentheses "Title 42, Part 82."

5 MS. LIN: For the dose 

6 reconstruction guidelines, something like 

7 that. As of now, we agree that the title and 

8 the part number should be kept in. I'll be 

9 happy to --

10 CHAIR MUNN: Okay.

11 MEMBER ZIEMER: Shall we say, "As 

12 prescribed in Title 42 of the Code of Federal 

13 Regulations"?

14 CHAIR MUNN: Yes. Well, that's the 

15 way you would prefer to have that, the way it 

16 was originally?

17 MS. LIN: Right.

18 MEMBER ZIEMER: I think she is 

19 saying we can leave out the part number maybe, 

20 right?

21 MS. LIN: Oh, no. No. We will 
308 

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1 keep the part number. So the entire citation 

2 of it, as of now, Title 42, Part 82, Code of 

3 Federal Regulation.

4 MR. MARSCHKE: You want not 

5 "regulations," but "regulation?"

6 DR. OSTROW: No, it's "regulation."

7 MS. LIN: It's "regulations."

8 CHAIR MUNN: So there's no s?

9 MS. LIN: No, there is.

10 MEMBER ZIEMER: No, there is. Code 

11 of Federal Regulations; I think it's plural.

12 CHAIR MUNN: I thought so, too. 

13 There's certainly more than one.

14 MR. MARSCHKE: We're streamlining 

15 the government.

16 CHAIR MUNN: I would put it back 

17 the way it was.

18 No. 9, "The procedure does not make 

19 it clear whether the worst-case assumptions 

20 are used for efficiency or used because of 

21 unknowns."
309 

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1 MEMBER ZIEMER: Oh, okay, that's 

2 better, I think. I didn't know what that 

3 meant, "Are used."

4 CHAIR MUNN: Do you use the worst5 case assumption for -- to increase efficiency 

6 or because it isn't known?

7 MEMBER ZIEMER: The procedure does 

8 not make it clear whether worst-case 

9 assumptions are used -- okay, I see it.

10 MR. MARSCHKE: "Efficiency or used 

11 because of" --

12 CHAIR MUNN: Well, we can say, "for 

13 reasons of efficiency," if you would like. 

14 "For reasons of efficiency or used because of 

15 unknowns."

16 MR. MARSCHKE: I just don't like 

17 the word "unknowns." Unknown what? Unknown --

18 you kind of leave me hanging there.

19 MEMBER ZIEMER: Yes, I didn't know 

20 what that meant. As opposed to what?

21 DR. ULSH: Lack of documents, lack 
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1 of --

2 MR. MARSCHKE: Lack of parameters, 

3 lack of data, lack of --

4 CHAIR MUNN: Lack of data. A lack 

5 of information. "The procedure does not make 

6 it clear whether worst-case assumptions are 

7 used for reasons of efficiency or used because 

8 of lack of information."

9 DR. MAURO: I just thought of 

10 something. Someplace in the introductory 

11 section -- I know we're not going there right 

12 now -- but the very fact that -- I don't want 

13 to mislead a reader to think that these 

14 findings repeat verbatim the findings that 

15 were in the original reports. One could 

16 incorrectly jump to that conclusion, if you 

17 were a layperson reading, going online and 

18 reading this. They might think these were the 

19 findings. Somewhere they should be apprised 

20 of the fact that these findings really are 

21 paraphrases.
311 

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1 In other words, I could see someone 

2 just looking at these and saying, "Yes, those 

3 are the findings," and it would be misleading.

4 MEMBER ZIEMER: That could be 

5 handled in the opening sentence just ahead of 

6 No. 1 --

7 CHAIR MUNN: Yes.

8 MEMBER ZIEMER: -- where it says, 

9 "The Board's contractor reviewed the 

10 procedures and made a number of findings that 

11 are" --

12 DR. OSTROW: "Which are paraphrased 

13 below."

14 MEMBER ZIEMER: "Which are 

15 summarized" --

16 CHAIR MUNN: I was going to say, 

17 "summarized below."

18 DR. MAURO: "Summarized."

19 MEMBER ZIEMER: "Which are 

20 summarized below." It sort of suggests not 

21 the detail. Would that do it, do you think?
312 

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1 DR. OSTROW: And then use the same 

2 formula in all the write-ups?

3 MS. LIN: So, while we're here, we 

4 would also like to make a recommendation about 

5 the Board's contractor. We recommend revising 

6 that to, "The CDC's contractor assigned to 

7 provide technical assistance to the Board."

8 (Laughter.)

9 MEMBER ZIEMER: This is exactly 

10 what we're trying to avoid, Jenny.

11 MS. LIN: I know.

12 MEMBER ZIEMER: And I think what we 

13 can do, I understand what you're saying 

14 because they are technically the Board's 

15 contractor. Suppose we say something like, 

16 "The contractor that the Board uses?"

17 MS. LIN: Or even just adding a 

18 footnote would be sufficient. If you just 

19 say, "The Board's contractor" and had a 

20 footnote there --

21 MEMBER ZIEMER: If it's footnoted, 
313 

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1 because that's what we're trying to - 

2 MS. LIN: I mean, our concern is 

3 that this document specifically provides to 

4 the public --

5 MEMBER ZIEMER: Yes, understood. 

6 Understood.

7 MR. MARSCHKE: Do you want to state 

8 it?

9 CHAIR MUNN: We've already 

10 footnoted what DCAS is, as well as what OCAS 

11 stands for. So we can certainly --

12 MEMBER ZIEMER: Yes, how about if 

13 we footnoted that? What's the terminology 

14 that they like?

15 MS. LIN: "The CDC contractor 

16 assigned to provide technical assistance to 

17 the Board."

18 MEMBER ZIEMER: Okay. "The 

19 contractor assigned by the Centers for Disease 

20 Control."

21 MR. MARSCHKE: Do you want to add 
314 

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1 "Prevention?"

2 CHAIR MUNN: Do we need to put the 

3 entire "Centers for Disease Control" in 

4 anything else they do in here?

5 "The contractor assigned by the 

6 Centers for Disease Control" and what?

7 DR. OSTROW: "Prevention."

8 MEMBER ZIEMER: "Prevention."

9 CHAIR MUNN: Thank you.

10 MR. MARSCHKE: You could put "SC&A" 

11 in there, if you wanted to.

12 CHAIR MUNN: Well, I don't think we 

13 need to. You know, we're getting back into 

14 what we were trying to avoid by making a 

15 separate paragraph upfront that points all 

16 this out, which I can read to you, if you need 

17 me to read that to you again.

18 MEMBER LEMEN: When you get to the 

19 resolution of findings, I have got a comment.

20 CHAIR MUNN: Okay. Hold on just a 

21 moment. We're still, I'm still dithering away 
315 

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1 here, Richard.

2 MEMBER LEMEN: I agree with John's 

3 comments that you need to take all the section 

4 stuff out, and I'm glad you're doing that.

5 CHAIR MUNN: Yes, we're doing that.

6 Now that introductory paragraph 

7 actually doesn't say -- yes, it does. The 

8 introductory paragraph -- it's not a 

9 paragraph; it's three paragraphs.

10 The introductory section says, 

11 "Under the Energy Employees Occupational 

12 Illness Compensation Act of 2000, atomic 

13 weapons workers who developed cancer may be 

14 compensated if it can be determined that their 

15 radiation dose from working with nuclear 

16 materials was more likely than not to have 

17 caused the cancer. The Department of Health 

18 and Human Services was given the 

19 responsibility to establish ways to determine 

20 radiation doses for people who had worked for 

21 employers covered by the law. This so-called 
316 

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1 `dose reconstruction' is the requirement for 

2 individuals with cancer who apply for 

3 compensation under the Act.

4 "The Act also established an 

5 independent body known as the Advisory Board 

6 on Radiation and Worker Health to evaluate the 

7 scientific validity of the methods used for 

8 dose reconstruction. In carrying out this 

9 responsibility, the Board conducts technical 

10 reviews" -- bolded -- "of the various guidance 

11 documents that pertain to dose reconstruction. 

12 The Board utilizes the services of a 

13 technical support contractor, S. Cohen & 

14 Associates (SC&A), to assist in the review 

15 process of these guidance documents. The 

16 reviews are intended not only to assess the 

17 scientific and technical quality of the 

18 methods used in dose reconstruction, but also 

19 to identify any deficiencies that could have a 

20 negative effect on the results of the dose 

21 reconstruction process.
317 

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1 "When the technical reviews are 

2 complete and all deficiencies have been 

3 resolved, a brief summary of what has 

4 transpired in the resolution process is 

5 prepared for Board approval. The report is 

6 subsequently added to the Advisory Board's 

7 permanent archives. These summary reports are 

8 maintained in electronic format at" --

9 wherever we're going to address it -- "and 

10 include the individual procedure reviews 

11 listed below. More details may be found in 

12 the technical documents themselves."

13 Then there's a list of completed 

14 NIOSH radiation procedures listed 

15 alphabetically by title, which consists 

16 currently of OTIB-3, Savannah River Site 

17 Tritium Doses.

18 So our concerns with respect to 

19 SC&A and identifying them as contributors I 

20 think is addressed there.

21 MEMBER ZIEMER: Well, if that's the 
318 

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1 case, I think in that first sentence just 

2 before the findings we probably don't have to

3 say, "the Board's contractor." Just say, "the 

4 technical support contractor." Then that 

5 doesn't sort of -- I think they are concerned 

6 about who owns the contractor. That's my 

7 contractor, you know.

8 (Laughter.)

9 Or go to the highest bidder.

10 (Laughter.)

11 MR. MARSCHKE: We can give it as a 

12 footnote?

13 MS. LIN: I think so.

14 CHAIR MUNN: Is that because of the 

15 contractor --

16 MEMBER ZIEMER: Well, I was going 

17 to ask Jenny, the other thing doesn't identify 

18 the Centers for Disease Control.

19 DR. MAURO: Yes, there's a 

20 distinction between you and us.

21 MS. LIN: How do you plan to post 
319 

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1 the introduction together with the summary? I 

2 mean, are they going to be posted together or 

3 as one document?

4 CHAIR MUNN: Yes, that's what I was 

5 just saying.

6 MEMBER ZIEMER: No, there's one 

7 document.

8 CHAIR MUNN: We will be working to 

9 identify where on our website this is going to 

10 go. It's going to go somewhere in with all of 

11 the technical documents, and it will be an 

12 archive. What I just read will be the first 

13 thing people see when they bring it up.

14 MS. LIN: On the website or on the 

15 document?

16 CHAIR MUNN: On the website.

17 MS. LIN: Okay.

18 CHAIR MUNN: When they click on the 

19 document, they will have those three 

20 paragraphs in front of them. Below that will 

21 be the index that they will click on in order 
320 

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1 to pull one of these up.

2 MS. LIN: If that's the case, I 

3 would recommend keeping the footnote because, 

4 obviously, the introduction isn't part of the 

5 same document that they will be reading. So I 

6 think it should be saved in three places.

7 CHAIR MUNN: Okay, we'll keep it 

8 there.

9 We were down to --

10 MEMBER ZIEMER: I do have one other 

11 question before -- for the staff. We talked 

12 earlier on No. 5 about probability of 

13 causation, and one of the things we bumped 

14 into in the earlier one, even the tritium 

15 document, we said, well, people may not even 

16 know what tritium is. So we had a little 

17 section explaining that.

18 And then there's something in here 

19 in your introduction that talks about the 

20 process, and so on. But I don't recall if it 

21 talked about probability of causation.
321 

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1 CHAIR MUNN: Yes. It said it 

2 didn't -- well, hold on.

3 The words "probability of 

4 causation" do not appear, as I recall. It 

5 says that, "The Department of Health and Human 

6 Services was given the responsibility to 

7 establish ways to determine radiation doses 

8 for people who have worked for employers 

9 covered by the law. This so-called `dose 

10 reconstruction' is the requirement" -- whoa, 

11 whoa, back, back.

12 The first sentence, under EEOICPA 

13 of 2000, "atomic weapons workers who developed 

14 cancer may be compensated if it can be 

15 determined that their radiation dose from 

16 working with nuclear materials was more likely 

17 than not to have caused the cancer. The 

18 Department of Health and Human Services was 

19 given the responsibility to establish ways to 

20 determine radiation doses for people who have 

21 worked for employers covered by the law. This 
322 

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1 so-called `dose reconstruction' is a 

2 requirement for individuals with cancer who 

3 apply for compensation under the Act."

4 It does not specifically say 

5 "probability of causation."

6 MEMBER ZIEMER: But then finding 5, 

7 then we have a concept in reduced --

8 CHAIR MUNN: Right.

9 MEMBER ZIEMER: -- which is 

10 undefined at this point. But if we could link 

11 it to that, link it to -- and maybe we don't 

12 even use the words here. Maybe we say -- what 

13 words were used there? The words were? Is it 

14 "the likelihood?"

15 CHAIR MUNN: "Are usually more 

16 likely than not."

17 MEMBER ZIEMER: "More likely than 

18 not."

19 MR. KATZ: I believe it says, "at 

20 least as likely as not." It's not "more 

21 likely than not."
323 

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1 MEMBER ZIEMER: "At least as" --

2 MR. HINNEFELD: "At least as likely 

3 as not."

4 MEMBER ZIEMER: What if you said in 

5 No. 5, on top of the head now -- I haven't 

6 thought about this -- "The guidance is limited 

7 regarding conducting dose assessments for 

8 determining likelihood of" --

9 DR. MAURO: Don't use lingo. Just 

10 "the likelihood of the radiation responsible" 

11 or something like that.

12 MEMBER ZIEMER: Well, I was trying 

13 to link it to what was said in the 

14 introduction. In other words, either that or 

15 we say --

16 MR. KATZ: I think it would stand 

17 alone here. I wouldn't worry about it. 

18 Because then you're assuming that they'll go 

19 back to this. I would just make it stand 

20 alone --

21 CHAIR MUNN: I think you are right.
324 

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1 MR. KATZ: -- as clearly as 

2 possible.

3 CHAIR MUNN: And actually, 

4 probability of causation is, you know, many 

5 people think that is an oxymoron to begin 

6 with.

7 MEMBER ZIEMER: Well, what if you 

8 said, "potentially high or low likelihood of 

9 causing cancer?"

10 MR. KATZ: Yes.

11 DR. MAURO: Yes, regular words.

12 CHAIR MUNN: That's what it says. 

13 "Guidance provided in Section 6.5" -- no, take 

14 out the sections --

15 MEMBER ZIEMER: Or maybe you don't 

16 even say high or low, just potential 

17 likelihood or something.

18 DR. MAURO: Yes. That's good, too.

19 CHAIR MUNN: "Guidance provided is 

20 limited on how to conduct dose assessments for 

21 the potential likelihood of causing cancer."
325 

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1 MEMBER ZIEMER: Or "potential 

2 determination of the likelihood," right?

3 DR. MAURO: Well, I would get rid 

4 of the word "potential." Just "determination 

5 of the likelihood."

6 CHAIR MUNN: Yes. Yes.

7 MEMBER ZIEMER: "The likelihood." I 

8 like that.

9 DR. OSTROW: "The likelihood of 

10 causing cancer."

11 MEMBER ZIEMER: On the first one, 

12 we did, Dick Lemen was real good at the 

13 wording.

14 Dick, are you still with us?

15 CHAIR MUNN: Yes, he said he --

16 MEMBER ZIEMER: Are you tracking 

17 this?

18 CHAIR MUNN: He said he had some 

19 comments.

20 MEMBER ZIEMER: Yes.

21 MEMBER LEMEN: I was just waiting 
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1 for resolution on the findings.

2 MEMBER ZIEMER: Seeing what we have 

3 done so far, does this look good to you?

4 MEMBER LEMEN: Yes, I'm happy with 

5 it so far. I'm glad we took the numbers out 

6 and made it more specific.

7 But I do have some ideas about the 

8 resolution of the findings area, that they get 

9 simplified.

10 CHAIR MUNN: Okay. I think we had 

11 gotten down to No. 10. No. 10, "Procedure 

12 provides no guidance on calculating the 

13 uncertainty of dose estimate." And I think 

14 that's pretty straightforward.

15 Finding 11, "An extensive list of 

16 potential sources of data is provided, but the 

17 conditions for using them" -- we can take out 

18 the parenthetical phrase -- "limits their 

19 value."

20 Then, resolution of findings, "In 

21 response to the findings" --
327 

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1 MEMBER LEMEN: This is Dick. Can I 

2 make a comment here?

3 CHAIR MUNN: You certainly may.

4 MEMBER LEMEN: I don't know why we 

5 have to say 1, 2, 3. Could we just say, under 

6 resolution of findings, that "In response to 

7 the findings identified above, the Advisory 

8 Board agreed with all findings and, thus, 

9 recognized that this procedure has been 

10 replaced with more specific procedures 

11 elsewhere, and therefore, closes all issues 

12 associated with this procedure," "cancelling 

13 this procedure," or something like that?

14 MEMBER ZIEMER: I think it's a good 

15 point that we don't have to go through the 

16 numbers here, particularly agreed with them 

17 all.

18 MEMBER LEMEN: Just make it very 

19 simple. Just say, "We have agreed with them 

20 all." I mean we can wordsmith it, but, 

21 basically, say that the Board agrees with it 
328 

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1 all, and because there's other procedures that 

2 have been recognized, we're cancelling this 

3 procedure.

4 MEMBER ZIEMER: Actually, I guess 

5 it is still NIOSH that agrees with the 

6 findings, right?

7 MEMBER LEMEN: Well, NIOSH then.

8 MEMBER ZIEMER: Yes.

9 CHAIR MUNN: And then we can say, 

10 "The Advisory Board" --

11 MEMBER ZIEMER: And then the Board 

12 --

13 CHAIR MUNN: The last sentence, 

14 then, would just follow. "The Advisory Board 

15 recognized" --

16 MEMBER LEMEN: I would change the 

17 tense on that then. "The Advisory Board 

18 recognizes that this procedure" -- instead of 

19 "was replaced" -- "has been replaced with more 

20 specific procedures elsewhere and, thus" -- do 

21 we recommend or do we say, "thus, closes all 
329 

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1 issues associated with this procedure?"

2 CHAIR MUNN: I think we just say 

3 just "closes."

4 MEMBER LEMEN: That's fine.

5 MEMBER ZIEMER: Or "closed all" --

6 CHAIR MUNN: "With more specific 

7 procedures elsewhere," period.

8 MEMBER LEMEN: Fine.

9 MEMBER ZIEMER: The question, the 

10 new procedures have not yet been reviewed.

11 MR. HINNEFELD: I don't know. 

12 Let's see.

13 CHAIR MUNN: No.

14 MEMBER ZIEMER: Because, if not, 

15 there's a loose end here that we don't know, 

16 in a sense, what they are. And if so, we 

17 could add, "The new, revised procedures will 

18 be reviewed separately" or something.

19 MR. HINNEFELD: I think it's going 

20 to be a mixture. Some of them have been. I 

21 won't guarantee that they all have been.
330 

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1 MEMBER LEMEN: In theory, you have 

2 to put that in, quite frankly, but --

3 CHAIR MUNN: Well, remember, we 

4 here around this table are not going to review 

5 all procedures.

6 MEMBER LEMEN: Right.

7 CHAIR MUNN: We are only going to 

8 review certain procedures under any 

9 circumstance.

10 MEMBER ZIEMER: Right.

11 MEMBER LEMEN: I think the point 

12 around this table is that we have closed this 

13 out.

14 CHAIR MUNN: Yes. So this closes 

15 all the issues associated with it, from my 

16 view.

17 MEMBER LEMEN: And we don't really 

18 need to say anything further than that.

19 CHAIR MUNN: Then I --

20 MEMBER GIBSON: So how are we 

21 certain that the issues have been addressed if 
331 

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1 we haven't reviewed them in other procedures?

2 MR. MARSCHKE: Well, the --

3 MEMBER LEMEN: We haven't said they 

4 have been addressed. We have said they have 

5 been replaced with more specific procedures.

6 MR. MARSCHKE: The way we have been 

7 working, the Subcommittee has given SC&A the 

8 authority to basically track the procedures, 

9 track the findings, even if the findings go to 

10 another procedure. So, you know, if we make a 

11 finding on a procedure A, and NIOSH takes the 

12 information from A and basically cancels A and 

13 puts that information in procedure B, the 

14 Subcommittee has given us the authority to go 

15 to procedure B and make sure that that 

16 procedure addresses the original issue, even 

17 though that original issue was not procedure 

18 A. We don't have the authority to review all 

19 of the second procedure, but we do have the 

20 authority to track the issue to its closure.

21 DR. MAURO: I've got a question. 
332 

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1 When we say an issue is closed, I guess, does 

2 that mean not transfers or not in abeyance? 

3 It's closed?

4 The reason it's closed is the issue 

5 is closed because we have followed it to its 

6 logical conclusion, wherever that brought us, 

7 and agreed with the solution. And it is 

8 genuinely closed.

9 MR. MARSCHKE: What you say is true 

10 except for one thing. Basically, it can 

11 either be closed or in abeyance.

12 MEMBER ZIEMER: But my point was 

13 this thing currently says we've closed all 

14 issues associated with this document that's 

15 disappearing. And I'm really asking you if 

16 that's the case. If not, if those issues have 

17 just moved into a new document --

18 MR. MARSCHKE: In theory, they 

19 should be closed. In theory, they should be 

20 closed because the issues have been identified 

21 as being closed. If it was moved to another 
333 

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1 document and still was an issue, it should 

2 still be carried through as an open issue or 

3 an issue that's in progress.

4 Now I'm not familiar enough with 

5 PR-003 to be specific on PR-003, but this is 

6 the philosophy that we have been operating 

7 under, is that we track the issue until it's 

8 closed. Whether it's closed in the original 

9 procedure or in a subsequent procedure, we 

10 still track it.

11 MEMBER ZIEMER: I understand that --

12 MEMBER GIBSON: I guess my issue, 

13 then, is isn't it maybe premature of this 

14 Subcommittee to put this out to the Board 

15 until we know that that has been done?

16 MR. MARSCHKE: Well, in theory, if 

17 they are all shown as being closed, then it 

18 has been done. We can double-check it and 

19 make sure, but that's the --

20 MEMBER GIBSON: That's a slippery 

21 slope for me --
334 

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1 DR. MAURO: Yes, I think we have 

2 to --

3 MEMBER GIBSON: -- when you have 

4 things in theory.

5 DR. MAURO: -- be careful of the 

6 procedures that we prepare these two-pagers 

7 for. What I just heard is that if it is 

8 designated as closed, that issue has been 

9 resolved to everyone's satisfaction. If it's 

10 in abeyance, it's been resolved to everyone's 

11 satisfaction, except we really haven't seen it 

12 written up. But we have seen, and we have 

13 agreed, and it's on the record that we have, 

14 in fact, addressed and resolved this issue. 

15 It just hasn't made it into a procedure 

16 anywhere.

17 So I would tend to argue that any 

18 issue that is either designated as closed or 

19 in abeyance, you can prepare one of these two20 pagers and feel confident that everyone is 

21 satisfied that the technical issue has been 
335 

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1 resolved.

2 MR. HINNEFELD: If it would help, I 

3 found Procedure 3 in our archive. It was 

4 written in 2002. Okay, it's before I worked 

5 for the government, and I think about the time 

6 -- it's actually dated before the contract was 

7 let to ORAU. This was prepared by a handful 

8 of OCAS people who were there at the time. 

9 And it describes, the table of contents is 

10 just the process. One is claim receipt. 

11 Evaluate available data/information. Claimant 

12 interview. Document claimant interview. 

13 Provide interview report to claimant. Claim 

14 evaluation. Internal dose calculation 

15 methodology. External dose calculation 

16 methodology.

17 It's just sort of a road map of 

18 what is going to happen to claim that was 

19 written in 2002, before we really knew how we 

20 were going to do anything specific. All the 

21 specifics for all these things are written 
336 

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1 somewhere else.

2 MEMBER ZIEMER: Okay, but not 

3 necessarily in one document?

4 MR. HINNEFELD: No, not in one 

5 document.

6 MEMBER ZIEMER: The implication 

7 here is that there is a new document that 

8 replaces this.

9 CHAIR MUNN: Let me read my wording 

10 that I have mashed around here, under 

11 resolution of findings.

12 Dick, see if this meets the 

13 criterion you would like to see.

14 "In response to the findings 

15 identified above, NIOSH agreed with all 

16 findings, cancelled this procedure, and 

17 provided improved guidance. The Advisory 

18 Board recognized that this procedure has been 

19 replaced with more specific guidance 

20 elsewhere. This closes all issues associated 

21 with it."
337 

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1 MEMBER LEMEN: I like it.

2 CHAIR MUNN: Will that do?

3 MEMBER LEMEN: I like it.

4 CHAIR MUNN: Okay. Thank you.

5 That gets rid of all the steps in 

6 the middle.

7 MEMBER ZIEMER: So it says, "This 

8 closes all issues associated with this 

9 document."

10 CHAIR MUNN: I just said, "with 

11 it." Because we had said, "The Advisory Board 

12 recognizes that this procedure has been 

13 replaced with more specific guidance 

14 elsewhere. This closes all issues associated 

15 with it."

16 Okay, I think I can provide you 

17 with a cleaned-up copy before very long.

18 MR. KATZ: Can we go back to 

19 finding 5, which I really think lost the 

20 point? I've rewritten it, if I am correct.

21 CHAIR MUNN: All right.
338 

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1 MR. KATZ: It says right now, what 

2 you have up there, "Guidance provided and 

3 limited on how to conduct dose assessments for 

4 determining the likelihood of causing cancer."

5 That really misses the point 

6 completely. The finding was that for very 

7 high or very low, in other words, efficiency 

8 process cases, that the guidance given is 

9 limited on how to do that. So it completely 

10 misses, actually, the substance of the 

11 finding.

12 MEMBER ZIEMER: Oh, it is the 

13 high/low --

14 MR. KATZ: Yes, it's the high/low. 

15 So let me tell you what I wrote as a 

16 possibility.

17 "Limited guidance is provided on 

18 methods to be used for dose reconstruction 

19 cases in which the likelihood that radiation 

20 caused the cancer is either very high or very 

21 low."
339 

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1 DR. OSTROW: That is a lot clearer.

2 MR. KATZ: Do you want me to read 

3 it more slowly?

4 (Laughter.)

5 MR. MARSCHKE: You think I'm a 

6 typist or something.

7 (Laughter.)

8 MR. KATZ: "Limited guidance is 

9 provided" --

10 MR. MARSCHKE: Ok, I got that.

11 MR. KATZ: -- "on methods to be 

12 used for dose reconstruction cases in which 

13 the likelihood that the radiation caused the 

14 cancer" --

15 MEMBER ZIEMER: Ted, where it says, 

16 "limited guidance," the implication is that it 

17 is inadequate guidance, right?

18 MR. KATZ: Yes. That's actually 

19 -- yes.

20 MEMBER ZIEMER: Limited guidance in 

21 itself is not insufficient --
340 

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1 MR. KATZ: Insufficient guidance 

2 would be a better way to put it, yes.

3 MEMBER ZIEMER: I think that is the 

4 thrust of what they mean.

5 MR. KATZ: I agree.

6 MEMBER ZIEMER: "Insufficient 

7 guidance is provided."

8 MR. KATZ: "The likelihood that the 

9 radiation caused the cancer is either very 

10 high or very low."

11 DR. MAURO: And don't forget the 

12 "is" after "insufficient guidance is 

13 provided."

14 CHAIR MUNN: "Insufficient" or 

15 "inadequate," which?

16 MR. KATZ: "Insufficient guidance 

17 is provided."

18 DR. MAURO: The wrong place. Yes, 

19 now you've got it.

20 CHAIR MUNN: Can we say, "This 

21 procedure provides insufficient" --
341 

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1 MR. KATZ: Insufficient guidance? 

2 Yes.

3 CHAIR MUNN: -- "guidance?"

4 MR. KATZ: Yes.

5 CHAIR MUNN: And make it --

6 DR. MAURO: Stu said something very 

7 important before.

8 MR. HINNEFELD: The first time, 

9 right?

10 (Laughter.)

11 DR. MAURO: Do we have in the 

12 beginning -- I mean, really, what we have 

13 here, if this is a procedure that was really 

14 an overview of a process which has matured 

15 dramatically over the years and, as a result, 

16 is really no longer needed because, you 

17 know --

18 MR. HINNEFELD: Right.

19 DR. MAURO: Could we have some kind 

20 of introductory spiel that sort of sets the 

21 stage for that? I forgot how we opened this 
342 

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1 up right in the beginning.

2 DR. OSTROW: No, there isn't any.

3 DR. MAURO: There's nothing like 

4 that?

5 DR. OSTROW: No.

6 DR. MAURO: That's good 

7 perspective. This is a procedure that was 

8 originally prepared early in the program, you 

9 know, that kind of blah-blah, blah-blah, blah10 blah. I think we could do something like 

11 that.

12 CHAIR MUNN: I'm getting around 

13 what places go where.

14 "This procedure provides 

15 insufficient guidance on methods to be used 

16 for dose reconstruction cases where the 

17 likelihood is either very high or very low 

18 that radiation caused the cancer."

19 Is there any objection to moving 

20 that last phrase back up in front of 

21 "radiation?"
343 

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1 MEMBER ZIEMER: You're trying to 

2 get the likelihood high and low together?

3 CHAIR MUNN: Yes, right.

4 "That the likelihood is either very 

5 high or very low that radiation caused the 

6 cancer." Because the "very high or very low" 

7 hung up on ending the sentence this time.

8 MEMBER ZIEMER: Yes.

9 In response to your comment, John, 

10 I suppose at the beginning of this in the 

11 overview you could say something like, "This 

12 procedure was developed early in the OCAS 

13 program for the purpose of administering the 

14 process for dose reconstruction for claimants" 

15 or something like that.

16 DR. MAURO: Yes.

17 MEMBER ZIEMER: You know, you're 

18 saying this -- well, I don't know.

19 CHAIR MUNN: Well, I'll tell you 

20 what, folks, I think most of us have physical 

21 requirements that are keeping our brains from 
344 

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1 functioning very well at this moment.

2 Let's take a 15-minute break and be 

3 back at 15 minutes from now.

4 (Whereupon, the above-entitled 

5 matter went off the record at 3:37 p.m. and 

6 went back on the record at 3:50 p.m.)

7 MR. KATZ: Do I have you with us, 

8 Dick and Mark?

9 MEMBER LEMEN: You do have me with 

10 you.

11 Can you hear me?

12 MR. KATZ: Yes, thank you.

13 CHAIR MUNN: Yes.

14 All right, one last thing before we 

15 leave this procedure and go on to the next 

16 one. Let's read what I have written now for 

17 finding No. 5.

18 "This procedure provides 

19 insufficient guidance for methods to be used 

20 for dose reconstruction cases where the 

21 likelihood is either very high or very low 
345 

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1 that radiation has caused the cancer."

2 Is that okay with everybody?

3 If you, in retrospect, suddenly 

4 discover that you can't stand that, please let 

5 me know and we are going to have one last 

6 round of these procedures. I'll send them out 

7 so that everybody is happy with them before we 

8 go to press in Santa Fe.

9 Now the next document --

10 MR. KATZ: Can I just understand, 

11 Wanda?

12 CHAIR MUNN: Yes.

13 MR. KATZ: So you're going to re14 review this that you just went through?

15 CHAIR MUNN: Well, I'm just going 

16 to send it out. I'm going to clean up the 

17 copy and send it out to everybody on the 

18 Subcommittee to both assure that we have, 

19 indeed, done what we said we were doing.

20 DR. OSTROW: Excuse me, Wanda. 

21 Have you been keeping track for this document 
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1 of all the changes that we made?

2 CHAIR MUNN: Well, I have that 

3 terrible-looking thing that you just saw up 

4 there. Yes, I have that.

5 DR. OSTROW: Of what we have been 

6 discussing today because Steve has been typing 

7 it.

8 MR. MARSCHKE: I can send it to 

9 Wanda. I can send what -- I don't have 

10 everything because I did not --

11 CHAIR MUNN: I have it.

12 DR. OSTROW: You do have it? All 

13 right. Okay.

14 CHAIR MUNN: Oh, yes. Yes.

15 DR. OSTROW: Good.

16 CHAIR MUNN: That's what I was 

17 doing over here.

18 DR. OSTROW: You type well then.

19 CHAIR MUNN: Once upon a time, I 

20 made my living that way.

21 Now I have completely lost the 
347 

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1 files that I want. So just a moment.

2 The next one that we had was TIB-8, 

3 use of ICRP-66 to calculate respiratory track 

4 doses.

5 Do we all have it up?

6 Are you with us, Dick? Do you have 

7 it up?

8 (No response.)

9 Let's just sit still for a minute 

10 and let everybody who hasn't read through it 

11 read through.

12 (Pause.)

13 All right. I have added one thing 

14 that I did not have on what you're looking at. 

15 That's when we first say, in the second 

16 paragraph, when we introduce International 

17 Commission on Radiological Protection, I have 

18 bolded that, which I think is appropriate, 

19 given the fact that we refer to ICRP-66 in the 

20 title, but don't mention it until the end of 

21 the second paragraph. And as per our request 
348 

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1 earlier, I placed the full name prior to the 

2 parenthetical acronym.

3 Also, under "summary of findings

4 resulting from the technical review," I have 

5 replaced "SC&A" with the "technical 

6 contractor's review of this procedure produced 

7 three findings."

8 Now down in "resolution of the 

9 findings," it's my instinct to write out 

10 "gastrointestinal" in item No. 1 rather that 

11 "GI." I know that's not the title of the 

12 ICRP, but --

13 MEMBER ZIEMER: Where are you?

14 CHAIR MUNN: Under "resolution of 

15 findings," No. 1.

16 MEMBER ZIEMER: Oh.

17 CHAIR MUNN: "Evaluated the human 

18 GI tract model." It's my instinct to want to 

19 write out "gastrointestinal."

20 MEMBER ZIEMER: I agree with that, 

21 but I have some comments before we get there, 
349 

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1 if we can go back.

2 CHAIR MUNN: Yes.

3 MEMBER ZIEMER: Well, back in the 

4 early paragraphs -- can you back that up, 

5 Steve, also?

6 CHAIR MUNN: All right.

7 MEMBER ZIEMER: Get it on your 

8 screen here.

9 CHAIR MUNN: The first one?

10 MEMBER ZIEMER: Okay. Now one 

11 thing, I'm focusing on the third paragraph. 

12 Let me preface this by telling you that, when 

13 I was lecturing on lung models to students, 

14 and I showed them diagrams of the boxes and 

15 the various things, finally, a student raised 

16 their hand and said, "Well, is the model made 

17 of plastic or what?"

18 (Laughter.)

19 And then I realized that when you 

20 talk about models to people, they're thinking 

21 about airplanes and cars and some 28-year-old 
350 

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1 guys are thinking about women.

2 (Laughter.)

3 So I'm wondering if it would help, 

4 under ICRP Publication 66, "Human Respiratory 

5 Tract Model," in the next sentence is a 

6 document provided by the ICRP that provides 

7 "mathematical models."

8 CHAIR MUNN: Absolutely.

9 MR. MARSCHKE: My suggestion is, 

10 basically, to just get rid of everything that 

11 I highlighted and just say, basically, "the 

12 document developed by the ICRP that provides 

13 guidance on how to calculate doses to the 

14 respiratory tract," because you've got a lot 

15 of respiratory tracts in there. You've got 

16 the --

17 MEMBER ZIEMER: "Mathematical 

18 model" and then delete all the rest of that? 

19 Yes.

20 MR. MARSCHKE: I would just start 

21 with "provides guidance." I would just go 
351 

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1 from, just say, "provides guidance" or 

2 "provides mathematical models on how to 

3 calculate the respiratory," But, you know, I 

4 think there's a little duplication there.

5 CHAIR MUNN: You can go from 

6 "mathematical models" on how to calculate, 

7 yes, you can take that out. But I do think 

8 "mathematical models" needs to be in there 

9 because we do refer to models several places 

10 following that. We talk about models a lot, 

11 and, clearly, "mathematical models" needs to 

12 be in there.

13 MR. KATZ: So where you just did 

14 it, but, Wanda, in that place, I think 

15 "guidance" is much clearer than saying 

16 "mathematical models" in paragraph 3.

17 CHAIR MUNN: Well --

18 MR. KATZ: "Mathematical models" is 

19 just --

20 MEMBER ZIEMER: Well, it's kind of 

21 redundant, but somewhere we've got to point 
352 

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1 out that we're talking about mathematical 

2 models.

3 MR. KATZ: Yes, we'll do that, but 

4 --

5 CHAIR MUNN: What is your first 

6 model?

7 MR. MARSCHKE: I think either that 

8 or down here, where basically this is where 

9 models -- where does models appear first?

10 CHAIR MUNN: Well, I thought that 

11 was the first time it appeared in No. 3. 

12 Then, below that, it refers to it many times.

13 MEMBER ZIEMER: I'm thinking maybe 

14 the last sentence, ICRP, "dose reconstructors 

15 use mathematical models like ICRP." You can 

16 do it there. It's a little bit later, but 

17 that would do it.

18 I think, Ted, you're trying to 

19 prevent the redundancy of using math models 

20 twice in the previous sentence, right?

21 MR. KATZ: Yes. Also, it's just 
353 

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1 much easier, then, to understand a sentence 

2 with "guidance" than it is "mathematical 

3 models." It's just that is going to miss them 

4 completely. Do you just want to use 

5 "mathematical models" -- well, that --

6 CHAIR MUNN: Okay. Then what I 

7 have is a sentence that reads, "ICRP 

8 Publication 66, Human Respiratory Tract Model 

9 for Radiological Protection. ICRP-66 is a 

10 document developed by the ICRP that provides 

11 guidance on how to calculate dose to the 

12 respiratory tract after breathing in airborne 

13 radionuclides." Right?

14 MEMBER ZIEMER: Right.

15 CHAIR MUNN: Then the following 

16 sentence says, "Dose reconstructors use 

17 mathematical models like ICRP-66 in order to 

18 accurately estimate the dose received by an 

19 organ."

20 MR. KATZ: Yes, but I think you 

21 could actually get rid of "mathematical 
354 

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1 models" everywhere in here. But I think you 

2 could just stick with "guidance," not get into 

3 talking about mathematical models, which is, 

4 again, it's a totally alien construct for --

5 MEMBER ZIEMER: Do we need the 

6 title of the --

7 DR. MAURO: I was going to say you 

8 don't need that, either.

9 MR. KATZ: Okay.

10 DR. MAURO: Explain to a 12-year11 old.

12 MR. KATZ: Yes.

13 MEMBER ZIEMER: Okay. So don't 

14 give the title of ICRP-66 then?

15 CHAIR MUNN: I don't think you can 

16 avoid that. The title of the document is used 

17 for ICRP-66.

18 DR. MAURO: Oh, I see, the title --

19 is that all right?

20 MR. KATZ: Right. I mean it's in 

21 the title. You don't have to reiterate 
355 

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1 "model" anywhere beyond -- it's in the title. 

2 You're stuck with it in the title.

3 MR. MARSCHKE: You have to have it 

4 in the title.

5 MR. KATZ: Yes.

6 MR. MARSCHKE: And I think you have 

7 to -- title of ICRP-66.

8 MR. KATZ: Yes. Oh, no, I'm not 

9 quibbling that. I think you have it in the 

10 title, but you don't have to talk about models 

11 in here. You can talk about guidance and 

12 never talk about models because, again, you're 

13 never going to convey to a normal person what 

14 you mean. "Mathematical model" doesn't mean 

15 any more to them than "model."

16 DR. OSTROW: Get rid of that entire 

17 sentence. Why do we need that sentence? 

18 "Provides guidance on how to calculate dose to 

19 the respiratory tract after breathing airborne 

20 radionuclides." You don't need that last 

21 sentence of dose reconstructors.
356 

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1 CHAIR MUNN: Well, I don't know. 

2 The whole point is we are telling -- well, we 

3 have actually said earlier that the people who 

4 do dose reconstruction "are required by 

5 regulations that govern their work to use the 

6 best available science to perform dose 

7 reconstruction. This includes guidance 

8 provided by the International Commission on 

9 Radiological Protection." We have said that.

10 MEMBER ZIEMER: Yes, you have said 

11 that, that the people who do it, who do dose 

12 reconstruction use that.

13 CHAIR MUNN: So I'm hearing remove 

14 the last sentence, right? "Dose 

15 reconstructors use mathematical models." We're 

16 taking that out?

17 Okay with you, Dick?

18 MEMBER LEMEN: Good idea.

19 MEMBER ZIEMER: Then it says, 

20 "using models in assumptions," you would just 

21 say, "using ICRP-66 guidance" or something 
357 

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1 like that?

2 MEMBER LEMEN: Can you hear me, 

3 Wanda? 

4 CHAIR MUNN: Yes, I did.

5 MEMBER LEMEN: Okay.

6 CHAIR MUNN: It's okay with you, 

7 right?

8 MEMBER LEMEN: Yes.

9 CHAIR MUNN: We can just say, 

10 "using the assumptions recommended by 

11 ICRP-66." "NIOSH uses the computer code 

12 called IMBA" --

13 MR. MARSCHKE: That's not 

14 assumptions. That's not assumptions; that's 

15 guidance.

16 CHAIR MUNN: Okay. Then "uses the 

17 guidance." Change "assumptions" to 

18 "guidance?"

19 MEMBER ZIEMER: Well, guess what? 

20 We actually have a dangling participle in 

21 there, finally.
358 

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1 (Laughter.)

2 MR. KATZ: It feels good, doesn't 

3 it?

4 (Laughter.)

5 MR. HINNEFELD: We had to throw it 

6 in just for you, Paul.

7 MEMBER ZIEMER: "Using the 

8 guidance," that sentence literally says the 

9 organ uses the guidance.

10 CHAIR MUNN: Yes, it does.

11 MEMBER ZIEMER: Yes, it does.

12 CHAIR MUNN: We can change "using" 

13 to "under."

14 MEMBER ZIEMER: That would work.

15 CHAIR MUNN: "In order to 

16 facilitate the calculation of the internal 

17 doses to a particular organ under the guidance 

18 recommended in ICRP-66, NIOSH uses the 

19 computer code called IMBA, Integrated Models 

20 for Bioassay Analysis. The specific organs to 

21 be modeled using IMBA and the assumptions used 
359 

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1 in the model used to model doses" --

2 MR. MARSCHKE: Do you want to get 

3 rid of all those "models?"

4 CHAIR MUNN: What?

5 MR. MARSCHKE: Do we want to try to 

6 get rid of all those "models?"

7 MEMBER ZIEMER: I don't even see 

8 why we have to name it IMBA or anything like 

9 that. "Uses a computer code."

10 MR. KATZ: I agree with you. They 

11 won't care. It's off-putting.

12 MEMBER ZIEMER: Or "NIOSH uses a 

13 special computer code."

14 CHAIR MUNN: "Specialized" or 

15 "special?"

16 MEMBER ZIEMER: "Specialized."

17 DR. OSTROW: And I would put that 

18 at the beginning of the sentence. "NIOSH uses 

19 a specialized computer code in order to 

20 facilitate the calculation" --

21 MR. KATZ: And it's a computer 
360 

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1 program, I think is what people are familiar 

2 with in terms of verbiage.

3 MEMBER GIBSON: Let's just put 

4 "computer code" instead of "specialized."

5 MR. KATZ: Yes, but "program," not 

6 "code."

7 CHAIR MUNN: "Computer program." 

8 "NIOSH uses a computer program in order to 

9 facilitate the calculation of the internal 

10 doses to a particular organ under the guidance 

11 recommended in ICRP-66" --

12 MEMBER ZIEMER: Well, now the 

13 organs are under the guidance.

14 (Laughter.)

15 How about, "Following ICRP-66 

16 guidance, NIOSH uses a computer" -- and there, 

17 I think you could say it's a specialized 

18 computer program.

19 MEMBER GIBSON: Now my thoughts 

20 there, Paul, are people don't trust a program 

21 anyway. They know about computer programs, 
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1 and they would say, "Oh, a special program?" 

2 Well, you know --

3 MEMBER ZIEMER: I don't know. 

4 They're doing it by computer. Is that enough? 

5 Is that what you mean, Mike?

6 MEMBER GIBSON: Yes.

7 MEMBER ZIEMER: Okay.

8 CHAIR MUNN: "Following the 

9 ICRP-66, NIOSH uses a computer program to 

10 facilitate the calculation" --

11 MEMBER ZIEMER: Leave the "in 

12 order" out.

13 CHAIR MUNN: Yes. "To facilitate 

14 the calculation of the internal doses to a 

15 particular organ," period. Right?

16 MEMBER ZIEMER: Now the next 

17 sentence, again, we can get rid of the "IMBA" 

18 and --

19 CHAIR MUNN: The whole thing.

20 MEMBER ZIEMER: -- the modeling. 

21 Do we need to mention the table? "The results 
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1 for specific organs are provided in a table in 

2 the procedure," or something like that, is 

3 what you want to say, right?

4 CHAIR MUNN: Yes.

5 MEMBER ZIEMER: "However, not all 

6 organs are included" or something. The point 

7 is that there's this table of organs, but that 

8 not everything is covered.

9 CHAIR MUNN: Yes. "The specific 

10 organs" -- let's say, "organs of concern," 

11 okay? Take out "using IMBA." "And the 

12 assumptions used" --

13 MEMBER ZIEMER: "To calculate the 

14 doses."

15 CHAIR MUNN: "Doses" --

16 MEMBER ZIEMER: "To the organs."

17 MR. KATZ: We don't need to cut out 

18 "to the organs?"

19 CHAIR MUNN: We said "organs" 

20 before.

21 MR. KATZ: Yes.
363 

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1 CHAIR MUNN: "The specific organs 

2 of concern and the assumptions used to 

3 calculate the doses to them" --

4 MEMBER ZIEMER: "Are shown in a 

5 table in the procedure."

6 CHAIR MUNN: "Are shown in a table 

7 in the procedure," yes.

8 MEMBER ZIEMER: However, you can 

9 eliminate "it turns out."

10 CHAIR MUNN: I thought that was 

11 real folksy myself.

12 (Laughter.)

13 MEMBER ZIEMER: Yes, you betcha.

14 (Laughter.)

15 CHAIR MUNN: Yes, that's what I 

16 thought.

17 "Not all organs are" --

18 MEMBER ZIEMER: "Included."

19 MR. KATZ: Or "covered by the 

20 guidance."

21 CHAIR MUNN: No. "Not all 
364 

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1 organs" -- "However, the dose to all organs 

2 cannot be calculated."

3 MEMBER ZIEMER: Well, no, that's 

4 not the case.

5 CHAIR MUNN: No.

6 MEMBER ZIEMER: It can be, but you 

7 have to do it a different --

8 CHAIR MUNN: Yes.

9 MEMBER ZIEMER: Let's see, Stu, do 

10 you remember ICRP-66 simply doesn't include 

11 all the organs? That goes back to 66, right? 

12 Or is it to the Code itself?

13 MR. HINNEFELD: ICRP-66 -- or what 

14 are we talking about, IMBA?

15 MEMBER ZIEMER: Well, not all the 

16 organs are covered by IMBA, but is that 

17 because there's not a model for all of them in 

18 ICRP-66?

19 MR. HINNEFELD: Yes, ICRP-66 

20 identifies particular organs and fractions of 

21 intake.
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1 MEMBER ZIEMER: Right, and --

2 MR. HINNEFELD: They end up in 

3 those organs, and then --

4 MEMBER ZIEMER: And IMBA uses that.

5 MR. HINNEFELD: And IMBA uses that.

6 MEMBER ZIEMER: Right.

7 MR. HINNEFELD: ICRP-66 doesn't 

8 include that for --

9 MEMBER ZIEMER: Right.

10 MR. HINNEFELD: -- unless --

11 MEMBER ZIEMER: So that would be 

12 the way to handle it. "Not all the organs are 

13 included in the ICRP-66 guidance" or 

14 something.

15 CHAIR MUNN: Well, they're not 

16 included in the table, either, are they?

17 MEMBER ZIEMER: That's why they're 

18 not in the table.

19 CHAIR MUNN: "However, not all 

20 organs are included in the table." We just 

21 have been talking about the table.
366 

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1 MEMBER ZIEMER: Right.

2 CHAIR MUNN: "The specific organs 

3 of concern and the assumptions used to 

4 calculate the doses to them are shown in a 

5 table in the procedure. However, not all 

6 organs are listed in the table." Right?

7 MEMBER ZIEMER: Yes, but it's not 

8 just the idea that they forgot to put some in. 

9 There's a reason. You know, the guidance in 

10 the ICRP-66 isn't there supporting it.

11 MR. KATZ: Yes. So Steve had that 

12 there. "Not all organs are included in the 

13 ICRP-66 guidance."

14 MEMBER ZIEMER: "And thus, do not 

15 appear in the table."

16 MR. MARSCHKE: Okay. Do you need 

17 to say that?

18 MR. KATZ: I don't think so, but --

19 MEMBER ZIEMER: Well, maybe not. 

20 Maybe, "In order to deal with this limitation, 

21 surrogate tissue models" -- now there's the 
367 

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1 "models" --

2 MR. MARSCHKE: Do you want to get 

3 rid of "surrogate?" I mean I wouldn't put 

4 "surrogate" and then "that is a substitute." 

5 Pick one word. I mean we're trying to get 

6 this -- I mean maybe "substitute" is the word 

7 that you want to use in here?

8 MS. LIN: Better use "surrogate." 

9 We'll have to get terminology that will match 

10 what we use in terms of -- "surrogate" or the 

11 word "substitute."

12 MR. HINNEFELD: Well, 

13 "surrogate" --

14 CHAIR MUNN: What's another word 

15 than "surrogate" or "substitute" that will say 

16 the same thing?

17 MR. HINNEFELD: We use "surrogate."

18 CHAIR MUNN: I know.

19 DR. OSTROW: Was that a question --

20 MR. MARSCHKE: You could have 

21 "stands for" rather than "surrogate." Or 
368 

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1 "represent."

2 CHAIR MUNN: "Other representative 

3 tissue?" "Other representative tissue" or 

4 "other representative organs are used."

5 MEMBER ZIEMER: That would be fine. 

6 Yes, that would work because "other 

7 substitute tissues or organs are used," and 

8 then you say, "The procedure provides guidance 

9 on which tissues and organs to use as 

10 surrogates." Leave out the rest of that.

11 CHAIR MUNN: Okay. "However, not 

12 all organs are included in the ICRP guidance." 

13 Period. "In order to deal with this 

14 limitation, other representative organs or 

15 tissues are used." The procedure and the 

16 review are used for what?

17 MEMBER ZIEMER: To provide 

18 guidance.

19 CHAIR MUNN: Yes, but hold on. 

20 "Are used for dose reconstruction."

21 MEMBER ZIEMER: "Are used" -- 
369 

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1 CHAIR MUNN: "To calculate doses?"

2 MR. MARSCHKE: "To represent the 

3 missing organs."

4 MEMBER ZIEMER: Yes. "Are used to 

5 represent the" --

6 CHAIR MUNN: No, I don't think so.

7 MEMBER ZIEMER: No?

8 CHAIR MUNN: No. "Other 

9 representative organs or tissues are used" --

10 MEMBER ZIEMER: Oh, yes, we have 

11 "representative."

12 MR. MARSCHKE: Or get rid of the 

13 first "representative."

14 MR. KATZ: "To calculate the 

15 doses," I would say.

16 CHAIR MUNN: "For dose calculation," 

17 right?

18 MR. KATZ: "To calculate the 

19 doses."

20 CHAIR MUNN: "To calculate the 

21 doses" --
370 

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1 MEMBER ZIEMER: "To calculate doses 

2 to the organ" --

3 MR. KATZ: I wouldn't get back into 

4 organs. I'm mean, it's implicit in -- I mean, 

5 if they start from the beginning of the 

6 paragraph, they understand what this means.

7 CHAIR MUNN: Yes. "The procedure 

8 under review provides guidance on which 

9 tissues and organs" --

10 MEMBER ZIEMER: "The procedure 

11 under review provides guidance on which 

12 tissues and organs" --

13 MR. KATZ: "Covered by the ICRP-66" 

14 --

15 MEMBER ZIEMER: "Can be used as 

16 substitutes for the organs." That would work, 

17 right?

18 CHAIR MUNN: Do we want to say, 

19 "and other programs" or just ICRP-66 only?

20 DR. MAURO: I think it's ICRP-66 

21 only.
371 

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1 CHAIR MUNN: Since we're taking 

2 IMBA out?

3 MR. MARSCHKE: Are we getting rid 

4 of "these models?"

5 CHAIR MUNN: So it reads, "The 

6 procedure under review provides guidance on 

7 which tissues and organs covered by ICRP-66 

8 can be used as surrogates for those organs and 

9 tissues that are not specifically" --

10 MEMBER ZIEMER: "Included" or "not 

11 specifically" --

12 CHAIR MUNN: "Shown?"

13 MEMBER ZIEMER: We might have to 

14 wordsmith it further. I think that's the 

15 idea.

16 CHAIR MUNN: "Are not specifically 

17 used?"

18 MR. MARSCHKE: We already said 

19 they're not covered by ICRP-66. I would end 

20 it. Maybe if you end the sentence?

21 MR. KATZ: Yes. Wait. Yes.
372 

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1 MR. MARSCHKE: With "tissue."

2 MR. KATZ: Yes. No, you could end 

3 it with "substitutes" actually, and it should 

4 say "not covered" instead of "covered."

5 MEMBER ZIEMER: It's "tissues and 

6 organs" --

7 MR. KATZ: "Not covered."

8 MEMBER ZIEMER: -- "not covered by 

9 ICRP-66" --

10 MR. KATZ: Period. Period.

11 MR. MARSCHKE: No.

12 MEMBER ZIEMER: "Which organs not 

13 covered can be used as substitutes."

14 MR. KATZ: Right. "On which tissues 

15 and organs" --

16 MR. MARSCHKE: You can't use it as 

17 a substitute if it's not there.

18 MEMBER ZIEMER: It's the other way 

19 around. Which organs that are covered by it 

20 can be used as substitutes to the ones that 

21 aren't. You've got it reversed.
373 

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1 MR. KATZ: Yes. Right.

2 MEMBER ZIEMER: Yes.

3 MR. KATZ: Right.

4 MEMBER ZIEMER: Yes, "which organs 

5 covered by ICRP" --

6 MR. KATZ: Yes, yes, you're right.

7 MEMBER ZIEMER: "Can be substituted 

8 for those organs that are not specifically 

9 included." I think that's the concept right 

10 there.

11 MR. KATZ: "That are not covered," 

12 I would just say.

13 MEMBER ZIEMER: "Not specifically 

14 covered." We've got "covered" twice, but 

15 that's all right probably.

16 MR. KATZ: The only other thing I 

17 would say is I would be consistent about 

18 "included" or "covered." I mean, use the same 

19 term everywhere.

20 MEMBER ZIEMER: Yes.

21 MR. KATZ: We start off saying, 
374 

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1 "included," "included," and then we say, 

2 "covered," "covered," but I would be 

3 consistent.

4 CHAIR MUNN: "The procedure under 

5 review provides guidance on which tissues and 

6 organs covered by ICRP-66 can be used as 

7 substitutes for those organs not specifically 

8 covered."

9 MEMBER ZIEMER: Yes, but up above 

10 we used "included."

11 MR. KATZ: Above we used the term 

12 "included." So Steve is just changing it all 

13 to "included?"

14 MR. MARSCHKE: I might have to 

15 change it to all "covered."

16 (Laughter.)

17 MR. KATZ: You got there first.

18 MEMBER ZIEMER: Then we have to 

19 change the wording on the first thing because 

20 we eliminated "surrogates," right?

21 MR. MARSCHKE: I eliminated 
375 

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1 "surrogates." I don't know --

2 MR. KATZ: Yes, we did.

3 MEMBER ZIEMER: Well, I think we 

4 did.

5 MR. KATZ: We did.

6 MEMBER ZIEMER: We used -- what did 

7 we substitute?

8 MR. MARSCHKE: "Substitutes."

9 MEMBER ZIEMER: On the first 

10 finding, explanations on the use of organs as 

11 substitutes are not always clear, right?

12 We've got to get rid of the non13 modeled stuff in the second one.

14 CHAIR MUNN: Yes, I think we have 

15 made a mistake, actually. "The procedure 

16 under review provides guidance on which 

17 tissues and organs are included in" -- instead 

18 of "by"

19 "Which should be used as 

20 substitutes for those organs not specifically" 

21 -- oh, but that's a clumsy sentence.
376 

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1 MEMBER ZIEMER: Which one?

2 CHAIR MUNN: The last one.

3 "The procedure under review 

4 provides guidance on which tissues and organs 

5 included in the ICRP can be used as 

6 substitutes for those organs not specifically 

7 covered."

8 MEMBER ZIEMER: "Guidance on 

9 tissues" --

10 CHAIR MUNN: Are we going to use 

11 "substitutes" always instead of "surrogates?" 

12 If so, then finding 1 gets "substitutes," 

13 right?

14 MR. KATZ: Now, I would rewrite 

15 finding 1 anyway. I would say, "Guidance on 

16 which organs to use as substitutes is not 

17 always clear," or something along those lines.

18 MEMBER ZIEMER: That's too long.

19 MR. KATZ: Okay. That's no longer 

20 than what's there, though.

21 MEMBER ZIEMER: "Which organs to 
377 

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1 use as substitutes." Period.

2 DR. OSTROW: I agree with Ted that 

3 the word "explanation" is not very clear 

4 itself.

5 DR. MAURO: That's right. Is the 

6 problem with "guidance" or is it 

7 "explanation?"

8 DR. OSTROW: "Guidance" is not 

9 clear.

10 DR. MAURO: On the selection of 

11 substitutes, right?

12 DR. OSTROW: Yes.

13 CHAIR MUNN: You want "guidance" 

14 there instead of "explanation?"

15 DR. OSTROW: Yes.

16 CHAIR MUNN: So it's going to read, 

17 "Guidance over the use of which organs to use 

18 as substitutes is not always clear."

19 MR. KATZ: Or "Guidance on the 

20 selection of substitutes is not always clear."

21 DR. OSTROW: That's better.
378 

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1 CHAIR MUNN: Still not much better.

2 DR. OSTROW: "Guidance on the 

3 selection of substitutes."

4 MEMBER ZIEMER: "Substitutes."

5 DR. MAURO: What's the new wordage?

6 CHAIR MUNN: Okay. Again, 

7 "Guidance on the selection of substitutes is 

8 not always clear. Having been preceded by the 

9 technical contractor's review of this 

10 procedure for these three findings. See 

11 finding No. 2."

12 What are we going to call non13 modeled dose? I tell you we made a mistake.

14 MEMBER ZIEMER: "The section on 

15 non-modeled dose" -- what did we call those 

16 organs?

17 CHAIR MUNN: Substitutes.

18 MEMBER ZIEMER: No. The 

19 substitutes are the ones that you do use.

20 DR. MAURO: It's going downhill 

21 fast.
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1 (Laughter.)

2 MEMBER ZIEMER: It's late in the 

3 day. We'll save this one for another day and 

4 get an easier one.

5 Well, how about this. "The section 

6 does not provide clear instructions on what to 

7 do if there are large differences in the" --

8 it's differences in what, the dose 

9 calculations?

10 DR. MAURO: There can't be -- this 

11 doesn't make sense.

12 MEMBER ZIEMER: Large differences 

13 of what?

14 DR. MAURO: Yes.

15 MR. MARSCHKE: I don't understand 

16 the finding, maybe.

17 DR. MAURO: Yes, that's our 

18 problem. We didn't write the finding very 

19 well. I mean, I'll just state that. What 

20 were we trying to say here?

21 MR. MARSCHKE: I don't know what 
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1 the finding is trying to tell us.

2 DR. MAURO: Yes.

3 MEMBER ZIEMER: Well, I thought it 

4 had to do with the fact that, let's see, non5 modeled organs. Does it have to do with 

6 physiological differences in the non-modeled? 

7 I mean, obviously, you can't talk about dose 

8 differences between the two because you're

9 using the dose that --

10 DR. MAURO: I know. That's what 

11 I'm trying to say.

12 MEMBER ZIEMER: Right.

13 MR. MARSCHKE: We'll have to come 

14 back and read --

15 MEMBER ZIEMER: It's almost got to 

16 do with physiological differences.

17 CHAIR MUNN: Large structural 

18 differences.

19 MEMBER ZIEMER: Yes, large 

20 biological differences or something like that. 

21 We need to know what the finding really is.
381 

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1 DR. MAURO: Yes, I agree with you.

2 MEMBER ZIEMER: It's hard to put it 

3 into layman's use if you don't know --

4 DR. MAURO: If you don't know what 

5 you're talking about.

6 (Laughter.)

7 MEMBER ZIEMER: We don't even 

8 understand the section.

9 In the non-modeled organ dose --

10 non-modeled dose? Do we have to say it's non11 modeled dose?

12 CHAIR MUNN: It's a non-modeled 

13 organ, not a non-modeled dose.

14 MEMBER ZIEMER: Oh, it's the dose, 

15 but it's --

16 DR. MAURO: Organs are never 

17 modeled because they are not part of the 

18 table. That's the problem. We don't have any 

19 doses for it, so we're picking some other 

20 organ that we do have dose for --

21 MEMBER ZIEMER: Right.
382 

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1 DR. MAURO: -- and saying we're 

2 going to use that as a substitute. Now I 

3 don't understand what the finding is.

4 CHAIR MUNN: Because it's a modeled 

5 organ.

6 MEMBER ZIEMER: Well, what if you 

7 simply, on this last one, what if you just 

8 said, "The method described to assign the 

9 highest dose to mouth, nose, and throat 

10 doesn't follow the recommendations?" It 

11 doesn't really matter here whether you say 

12 it's modeled, right?

13 CHAIR MUNN: Take out "non-modeled 

14 organ."

15 MEMBER ZIEMER: "To assign the" --

16 CHAIR MUNN: "Highest dose."

17 MEMBER ZIEMER: -- "the highest 

18 dose to the mouth, nose, and throat does not 

19 follow the recommendations."

20 CHAIR MUNN: And is there no way 

21 that we can quickly pull up the original 
383 

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1 finding?

2 MR. KATZ: See what Steve's doing? 

3 That's what he's doing.

4 MR. MARSCHKE: "Technical issues," 

5 that might be where it's at.

6 MR. KATZ: It's right there, 3.3.5.

7 MEMBER ZIEMER: Those are the 

8 objectives.

9 CHAIR MUNN: This is not a finding. 

10 We're looking for what the finding says.

11 MEMBER ZIEMER: 4.1 is the one 

12 finding on this.

13 CHAIR MUNN: You're considering the 

14 review objectives as a finding?

15 MEMBER ZIEMER: Well, it's word16 for-word what's in here.

17 MR. HINNEFELD: And the word-for18 word finding out of the database is "Section 

19 4.1, Non-Modeled Organs, does not provide 

20 clear instructions on which organ to use in 

21 cases involving large differences among non-
384 

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1 modeled organs."

2 CHAIR MUNN: So let's go to 

3 Section -- what did you say?

4 MR. HINNEFELD: Section 4.1 of the 

5 -- well, that would be of the TIB.

6 MEMBER ZIEMER: Now is there an 

7 expansion of that somewhere?

8 MR. MARSCHKE: No. This is all 

9 we've got.

10 CHAIR MUNN: This says the 

11 objective, but that's not Section 4 -- is that 

12 what --

13 MR. MARSCHKE: It's Section 4.1 of 

14 the table, Wanda, of the checklist table. 

15 See, basically, up here it says 4.1, "Does the 

16 procedure support a prescriptive approach to 

17 dose reconstruction?" And we gave it a four. 

18 And then it says, "See review comments."

19 And then you go down and see the 

20 review comments. "Review objective 4.1." 

21 "Highest non-modeled dose of OCAS-TIB-8 does 
385 

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1 not clearly" -- well, we've got to look at 

2 OCAS-TIB-8.

3 MR. HINNEFELD: Getting there.

4 CHAIR MUNN: Page 3, Section 4.1 of 

5 the document. "And doses delivered to" --

6 right above it there. "It is conceivable that 

7 a situation could arise where a photon8 emitting radionuclide causes a large 

9 difference in doses delivered to non-modeled 

10 organs. The dose based on an organ that is 

11 not the highest non-modeled organ."

12 MEMBER ZIEMER: So is that saying 

13 that they, then, if there's a couple of 

14 neighboring organs that get different doses, 

15 that they need guidance on which one to use or 

16 -- what is it?

17 MR. HINNEFELD: Well, in response 

18 to the comment, he wrote that, "Okay, but the 

19 last paragraph of Section 4.1 addresses SC&A's 

20 concern, but the preceding paragraph suggests 

21 that one or more claimant-favorable selections 
386 

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1 is required."

2 So, in other words, it's saying, 

3 well, yes, we didn't really -- it kind of 

4 agrees with the finding. And this is in 

5 abeyance? Is that the status on this or is 

6 this finally closed? We revised the document. 

7 Is that what happened?

8 DR. MAURO: I like that.

9 MR. HINNEFELD: Okay, there is a 

10 Rev. 1. Okay.

11 DR. MAURO: I just was starting to 

12 read that.

13 MR. HINNEFELD: Rev. 1 took care of 

14 it. Okay?

15 MEMBER ZIEMER: "Radionuclide 

16 causes a large difference in doses in non17 modeled organs." Yes, it is acceptable in the 

18 situations that you base the dose on an organ 

19 that is not the highest non-modeled organ.

20 CHAIR MUNN: I have a hard time 

21 understanding that.
387 

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1 MEMBER ZIEMER: Okay. So you've 

2 got some non-modeled organs in the general 

3 vicinity of the organ of interest.

4 MR. HINNEFELD: Well, the fact of 

5 the matter is this never happens.

6 MEMBER ZIEMER: Okay.

7 MR. HINNEFELD: A photon, the 

8 photon emissions are never a significant 

9 fraction of the internal dose from the 

10 nuclides we encounter. Okay. If the deposit 

11 in the spleen, for instance, and the liver 

12 were adjacent, theoretically, I guess, it 

13 could be higher. You know, you would have 

14 enough penetration of the photons that you --

15 I don't know how you would do that much of a 

16 buildup factor to build up electrons. I don't 

17 know how this ever happens. And, in reality, 

18 it never does because the particular radiation 

19 is always an overwhelming amount of energy 

20 delivered, you know, radiation that is 

21 delivered. So we're kind of jousting at 
388 

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1 windmills with the whole deal.

2 But we revised the OTIB, and now 

3 the final two paragraphs of Section 4.1, 

4 apparently, based on the re-review by SC&A, 

5 which is also recorded in the database, felt 

6 like this is now rewritten correctly, and it 

7 addresses that. It just says check the organs 

8 in the proximity to see -- radiation of the 

9 organs in the proximity to see if any were 

10 higher.

11 MR. KATZ: So they select the 

12 highest one?

13 MR. HINNEFELD: Select the highest 

14 one. You know, check the organ along with 

15 organs in the proximity to make sure you're 

16 getting the highest -- it's non-metabolic, it 

17 just really has the highest dose.

18 MEMBER ZIEMER: Because there may 

19 be one closer, but it's a lower dose for some 

20 reason?

21 MR. HINNEFELD: There may be, well, 
389 

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1 there may be a close-by one that from some 

2 instance would have a higher dose than --

3 you're calculating the organ, the dose to the 

4 cancer organ. And if that is a non-modeled 

5 organ, you use highest non-metabolic because 

6 it just is the circulating blood that 

7 irradiates it.

8 However, in the case -- which never 

9 happens -- that the radionuclides, most of --

10 or the predominant or even a significant 

11 fraction of its energy came from photons, it 

12 would probably have to be more than half at 

13 least, then you can't just stop at the highest 

14 non-metabolic. You have to see if there is a 

15 modeled organ close by that may, in fact, have 

16 a higher dose. I don't think I have ever seen 

17 it happen.

18 DR. MAURO: Any photon emitter also 

19 has a beta, and the beta is going to deliver 

20 the organ dose, not the photon.

21 MR. HINNEFELD: Yes.
390 

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1 DR. MAURO: This is an issue that 

2 is a non-issue.

3 MR. HINNEFELD: Yes. But it doesn't 

4 make it any easier to explain to the public.

5 CHAIR MUNN: No, it doesn't.

6 DR. MAURO: Let's try to find a 

7 very general statement we could place here 

8 that sort of fits the essence of it because we 

9 can't get into this. We can't get into this.

10 MR. HINNEFELD: I'm just wondering 

11 if it occurred to anybody that maybe we should 

12 edit it at home and send it in to Wanda and 

13 then have a final one to look at.

14 CHAIR MUNN: Well, that's why I 

15 sent the original out such a long time ago. 

16 This one of mine, this marked one of mine, 

17 granted, that's a new one, but we had the 

18 other one a long time ago. The original went 

19 out.

20 MEMBER ZIEMER: Well, I think we 

21 only have to fix that second one, and the 
391 

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1 resolution has to be dealt with because we've 

2 got to get rid of some words there.

3 CHAIR MUNN: Well, I don't know 

4 whether this catches the essence of what we 

5 have to say or not, but "The procedure does 

6 not provide clear instructions regarding what 

7 to do when there are large differences in dose 

8 calculations between organs included in the 

9 table and others that are not."

10 It makes more sense than what we 

11 had.

12 DR. MAURO: I like it. At least I 

13 understand what you just said.

14 DR. OSTROW: What does it mean, 

15 "large differences in dose calculations?"

16 MEMBER ZIEMER: Read it again, 

17 Wanda.

18 CHAIR MUNN: "The procedure does 

19 not provide clear instructions regarding what 

20 to do when there are large differences in dose 

21 calculations between organs included in the 
392 

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1 table and others that are not."

2 MR. MARSCHKE: If it is not 

3 included in the table, how does it have a dose 

4 calculation?

5 DR. MAURO: How about "doses," just 

6 "doses?"

7 CHAIR MUNN: Then it's a 

8 substitute. You're using a substitute or --

9 between organs included in the table and 

10 substitutes.

11 DR. MAURO: But it's not dose 

12 calculations because you're not calculating --

13 it's the doses. And was there a real dose?

14 CHAIR MUNN: Yes.

15 DR. MAURO: And certainly there are 

16 going to be differences in those organs, some 

17 of which are going to be ones that we can 

18 model and some of which we cannot model. I 

19 wouldn't say dose is calculated. I would just 

20 say not calculated doses, but the doses. It's 

21 unclear that, when you have that circumstance, 
393 

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1 how do you go about picking the right 

2 substitute?

3 CHAIR MUNN: So the question is, 

4 large differences in what?

5 DR. MAURO: In the doses between 

6 various organs, both listed, both included and 

7 not included.

8 CHAIR MUNN: Okay. So if we did 

9 the calculation --

10 MEMBER ZIEMER: Yes, but you can 

11 always have large differences in the doses to 

12 organs. Maybe the lung has a big dose and the 

13 other organs are low. But that's not what 

14 we're talking about.

15 DR. MAURO: Well, then, how do you 

16 pick a substitute? That's the problem.

17 MEMBER ZIEMER: Yes, that's the 

18 issue. It's where there's large differences 

19 in doses to organs that are possible 

20 substitute organs, is the concept, right?

21 DR. MAURO: No, I think it's the 
394 

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1 opposite. I think it's the doses, the real 

2 doses to organs that you didn't calculate 

3 doses for.

4 MEMBER ZIEMER: Right, the 

5 substitute -- or, yes, okay.

6 DR. MAURO: Right. What substitute 

7 do you pick when you're in that circumstance?

8 MEMBER ZIEMER: Right.

9 MR. KATZ: Why not just dump this 

10 completely and use finding 1 to cover this one 

11 as well in a general sense?

12 DR. MAURO: That's the truth.

13 MR. KATZ: Wanda, let's do that 

14 because these people aren't going to --

15 MEMBER ZIEMER: Actually, that's 

16 exactly, that answers it.

17 DR. MAURO: You've got it.

18 MEMBER ZIEMER: One and two, "The 

19 guidance on selection of substitute organs is 

20 not clear."

21 DR. MAURO: That's it.
395 

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1 MEMBER ZIEMER: One and two.

2 CHAIR MUNN: Okay. So we're going 

3 to say findings 1 and 2 --

4 MEMBER ZIEMER: And two. Both deal 

5 with details on -- 

6 CHAIR MUNN: Well, we will just 

7 say, "Guidance for selection of substitutes is 

8 not always clear." We can just leave it at 

9 that.

10 And then finding 3 because --

11 DR. MAURO: What a great fix.

12 (Laughter.)

13 MEMBER ZIEMER: How about both deal 

14 with aspects on --

15 CHAIR MUNN: I think you're going 

16 to get wordier.

17 MEMBER ZIEMER: Okay.

18 CHAIR MUNN: So then, finding No. 

19 3, "The method described to assign the highest 

20 dose to the mouth, nose, and throat does not 

21 follow ICRP-66 recommendations." That's 
396 

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1 straightforward.

2 DR. OSTROW: Yes.

3 CHAIR MUNN: And the findings, "In 

4 response to the findings identified above, 

5 NIOSH did three things. One, evaluated the 

6 human gastrointestinal tract model ICRP-100 to 

7 determine how the mouth should be" -- "how the 

8 mouth should be" --

9 MEMBER ZIEMER: "How dose to the 

10 mouth should be determined."

11 CHAIR MUNN: Okay.

12 MEMBER ZIEMER: Well, you evaluated 

13 that model or did they adopt it or what?

14 MR. HINNEFELD: As I recall, we 

15 needed to find out, sort through some sort of 

16 backup information behind the ICRP documents 

17 because they don't speak to the mouth. We 

18 have to figure out, and it's really the 

19 respiratory tract. We have to figure out 

20 which, E1 or E2, relates to the mouth.

21 MEMBER LEMEN: The bottom line on 
397 

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1 this whole thing on the resolution of the 

2 findings is No. 3.

3 CHAIR MUNN: Yes, it is.

4 MEMBER LEMEN: Why don't you say 

5 that and get on with it?

6 MEMBER ZIEMER: Good point.

7 MEMBER LEMEN: We're making a 

8 mountain out of a molehill.

9 MEMBER ZIEMER: Yes, a good point.

10 CHAIR MUNN: And it's not a very 

11 pleasant molehill even.

12 MEMBER ZIEMER: "In response, NIOSH 

13 issued Revision 1 and satisfactorily addressed 

14 all the considerations." How's that?

15 (Laughter.)

16 MR. KATZ: That's getting to the 

17 punch.

18 MEMBER ZIEMER: Thank you.

19 MR. KATZ: And let me just say that 

20 this discussion took about 55 minutes, and if 

21 we do some little, simple arithmetic here 
398 

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1 about the number of procedures that will be 

2 delivered by SC&A --

3 DR. OSTROW: About 55 all together.

4 MR. KATZ: If we do it, we don't 

5 have the time to do it this way.

6 MEMBER ZIEMER: Yes, see, these are 

7 learning experiences.

8 MR. KATZ: But these are 

9 prototypes, right. I know. No, I'm not 

10 criticizing doing this for these initial ones. 

11 The thing I wanted to suggest is, going 

12 forward, we will need a process that is more 

13 efficient that using the Committee in real 

14 time to head up these --

15 MEMBER ZIEMER: Right, but this is 

16 helpful, so we get a feel for it.

17 MR. KATZ: Yes. Yes. No, it is 

18 good for coming up with the prototypes, but --

19 MEMBER LEMEN: I would suggest that 

20 maybe on the next two we just relook at those 

21 instead of spending another hour on each one 
399 

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1 of them.

2 CHAIR MUNN: Yes. I think the mere 

3 suggestion of spending another hour on them 

4 would probably serve the purposes of all 

5 mental health experts in this immediate area.

6 (Laughter.)

7 So may I suggest that I will send 

8 to all of you my capture of what I think we 

9 have said here in the ones we covered. If you 

10 will look at the other two and send back to me 

11 any additions, deletions, corrections, 

12 suggestions that you might have, then I will 

13 try to incorporate them and we will, by email, 

14 hopefully, resolve what we are going to 

15 produce for the Board. Is that satisfactory 

16 with all those aboard? 

17 MEMBER LEMEN: Are you going to 

18 send all of the first two, now that we've done 

19 all the wordsmithing --

20 CHAIR MUNN: Yes. Yes.

21 MEMBER LEMEN: -- back to us to 
400 

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1 read?

2 CHAIR MUNN: I will send you what I 

3 believe we did here today.

4 MEMBER LEMEN: And then you will 

5 send us a clean copy of 3 and 4?

6 CHAIR MUNN: Yes, I will send you a 

7 clean copy of 3 and 4 that we have --

8 MEMBER LEMEN: What timeframe do 

9 you want us to get back to you?

10 CHAIR MUNN: Well, in view of the 

11 fact I'll be back here all next week, let's 

12 say by the end of the month.

13 MEMBER LEMEN: Okay.

14 CHAIR MUNN: Actually, certainly, 

15 if you could get it to me by -- what? The 

16 25th, something like that?

17 MEMBER LEMEN: That's fine.

18 CHAIR MUNN: Is that doable? If 

19 you'll get them to me by the 25th, then I will 

20 get cleaned-up copies back out to everybody of 

21 what I think --
401 

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1 MEMBER LEMEN: But you're going to 

2 send us something before, and then we'll get 

3 back to you on what you're sending us --

4 CHAIR MUNN: Correct.

5 MEMBER LEMEN: -- after today's 

6 meeting?

7 CHAIR MUNN: Correct.

8 MR. KATZ: And what about the one 

9 additional one? There's actually three, not 

10 two.

11 DR. OSTROW: The fifth one, yes.

12 MEMBER LEMEN: Wanda is going to 

13 send all of those to us.

14 MR. KATZ: Right. She said two, 

15 but there's actually three that had some 

16 review.

17 CHAIR MUNN: I sent four.

18 MEMBER LEMEN: She's going to be 

19 sending us five things, as I understand it.

20 CHAIR MUNN: Yes.

21 MEMBER LEMEN: The two that we have 
402 

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1 already worked on and the three that we 

2 haven't worked on.

3 CHAIR MUNN: Yes, we have worked on 

4 four. I've worked on four, and you have my 

5 comments on all four of those. And I will now 

6 send you what I think is the correct result of 

7 our machinations here today. The other two 

8 will still be the way they were. And I will 

9 send you my comments on the fifth one as well. 

10 Okay? Is that satisfactory?

11 MR. KATZ: Yes. I would just say, 

12 for SC&A, though, too, you're welcome to, 

13 based on this experience --

14 DR. MAURO: No, not a chance.

15 (Laughter.)

16 MEMBER LEMEN: Based upon this 

17 experience, you may want to provide nitrous 

18 oxide.

19 (Laughter.)

20 CHAIR MUNN: Yes. But what we do 

21 need to do before we go is take one last quick 
403 

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1 look at calendars to see when we're going to 

2 try to address this again. Bear in mind that 

3 we have a significant number of carryovers 

4 that we did not even touch on today.

5 And one thing that I'm concerned 

6 that we didn't spend a lot of time with is we 

7 did not get to the PER-12 and 9 issues. We 

8 had expected to spend a significant amount of 

9 time on that, or at least a half-hour or so.

10 DR. MAURO: Or OTIB-70.

11 CHAIR MUNN: Yes, OTIB-70.

12 DR. MAURO: So Hans has been on the 

13 line for eight hours. Thank you, Hans.

14 MR. MARSCHKE: On PER-9, I talked 

15 to Hans a little bit about this, and if he's 

16 still on, he can chime in. But we don't 

17 believe that we owe you anything at this 

18 particular point in time. At the last 

19 meeting, John presented kind of a summary of 

20 the status of where we were on that.

21 I think it was more for Dr. Lemen, 
404 

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1 to bring him up to speed as to what had been 

2 done on it. And it is our understanding that 

3 he was going to, then, go back and read the 

4 history on this, and the Subcommittee was 

5 going to make a determination as to whether or 

6 not to bring this forward to the full Board 

7 and potentially to DOL, the Department of 

8 Labor.

9 Because this issue, I think we 

10 agree that it is not really -- it is the 

11 assignment of what is it, the ICD-9, and it's 

12 not strictly a NIOSH issue. If it goes 

13 anywhere, it is going to go to DOL.

14 So, right now, we think actually 

15 Dr. Lemen has the action item, as opposed to 

16 SC&A.

17 DR. BEHLING: And, Steve, this is 

18 Hans.

19 I did review some of the comments 

20 that have been submitted by Brant Ulsh, and I 

21 was going to have a few comments, not that 
405 

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1 that would take an extensive amount of time. 

2 But when we do discuss PER-9, I did want to 

3 make some comments that relate to the paper or 

4 the response that Brant Ulsh had forwarded to 

5 us very recently.

6 MR. MARSCHKE: Sure. Sure.

7 CHAIR MUNN: Richard, are you still 

8 on the line?

9 MEMBER LEMEN: Yes, I am, and I 

10 actually think this is an issue that needs to 

11 be brought up to the Board at some point in 

12 time because I think that Dr. Richardson has 

13 some comments about this that he expressed, 

14 and I think we should talk about it with the 

15 other epidemiologists on the Board because I 

16 think this paper that was provided certainly 

17 puts a position forth that NIOSH clearly has 

18 stated, which is in contrast to the discussion 

19 we had at the last meeting. I think maybe at 

20 this point in time it's ready to go to the 

21 Board and just have a discussion on this issue 
406 

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1 as a Board item.

2 CHAIR MUNN: Well, it would be 

3 helpful for us in the Subcommittee here to get 

4 all our ducks in a row, so that we would be 

5 very clear about what we were, in fact, 

6 bringing to the Board. It's certainly not 

7 clear to me what issues are foremost and what 

8 needs to be our agenda when we go there.

9 MEMBER LEMEN: Isn't the issue very 

10 clearly whether or not the ICD-9 code as deals 

11 with Hodgkin's lymphoma the issue that we're 

12 talking about?

13 CHAIR MUNN: Yes, I believe so.

14 DR. BEHLING: Well, it's actually 

15 more likely to affect the non-Hodgkin's 

16 lymphoma as well.

17 MEMBER LEMEN: Right, and that's 

18 not clear in the paper that NIOSH put 

19 together, but it's very clear that, from what 

20 I read on NIOSH's reply here, that probably 

21 there's little evidence that Hodgkin's is 
407 

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1 related. But there is that difference of 

2 opinion that we need to talk about. I'm not 

3 sure who the right players are, but I think 

4 that there are other players on the Board that 

5 need to be brought into this discussion.

6 DR. ULSH: If I could offer perhaps 

7 a suggestion?

8 CHAIR MUNN: Please do, Brant.

9 DR. ULSH: If the Subcommittee 

10 wants to take that issue up, perhaps you could 

11 invite those other Members of the Board to 

12 listen in, to participate, and David 

13 Richardson or whoever else is on the Board.

14 MEMBER LEMEN: Well, what do you 

15 want to accomplish on this?

16 DR. ULSH: Who was that directed 

17 to?

18 MEMBER LEMEN: That's directed to 

19 NIOSH.

20 MR. HINNEFELD: Well, we're trying 

21 to resolve, I guess, findings from the Board 
408 

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1 about how we treat, how our PER treated 

2 lymphoma. The PER that we wrote, you know, 

3 the change that we adopted, and that gave rise 

4 to the PER, was to change the target organ for 

5 non-Hodgkin's lymphoma from the site of origin 

6 to essentially the highest irradiated site of 

7 lymphocytes for that, consistent with the 

8 diagnosis.

9 So that was the change we made. It 

10 prompted us to go back and reconsider a bunch 

11 of non-Hodgkin's lymphomas, and so quite a 

12 number of those, then, went from originally 

13 non-compensable in their first dose 

14 reconstruction to compensable when we used the 

15 highest lymphoma.

16 Now the findings, when SC&A 

17 reviewed that PER, they wrote additional 

18 findings. Particularly, I think one, in 

19 particular, was, are we really confident that 

20 the medical diagnoses were such that Hodgkin's 

21 lymphoma and non-Hodgkin's lymphoma were 
409 

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1 suitably distinguished? I think that's the 

2 nut of at least part of the finding.

3 DR. BEHLING: Yes, it is. And I 

4 did want to make some comments. I don't know 

5 if today it's really out of the question to go 

6 and take this discussion any further, but I 

7 did have some comments regarding that.

8 MR. HINNEFELD: I would like to 

9 finish this one more thought along that part 

10 of the finding, about Hodgkin's and non11 Hodgkin's being non-differentiated, and the 

12 statute itself differentiates because it puts 

13 Hodgkin's lymphoma out of the SEC class and 

14 non-Hodgkin's lymphoma in the SEC class.

15 So the precedent for saying that 

16 Hodgkin's lymphoma is different from non17 Hodgkin's lymphoma, at least for this program, 

18 was established by the law. And so we are, by 

19 treating non-Hodgkin's as its own disease and 

20 Hodgkin's --

21 (Whereupon, the above-entitled 
410 

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1 matter went off the record at 4:55 p.m., and 

2 went back on the record at 4:56 p.m.)

3 MR. KATZ: Sorry. We had a problem 

4 technically here and disconnected ourselves 

5 from the line.

6 MR. HINNEFELD: From everything, 

7 yes.

8 MEMBER LEMEN: Well, we resolved it 

9 all while you were gone.

10 (Laughter.)

11 MR. KATZ: Oh, very good. Very 

12 good.

13 MR. HINNEFELD: Okay. I'll be 

14 quiet.

15 I was just making a point that that 

16 distinction was made, essentially, by the law, 

17 by saying Hodgkin's is not in the SEC and non18 Hodgkin's is in the SEC.

19 MEMBER LEMEN: Right.

20 MR. HINNEFELD: And so we're 

21 comporting, essentially, with that division at 
411 

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1 that point. Now if there is a part of the 

2 finding that reflects how we are approaching 

3 target organs for non-Hodgkin's, then I guess 

4 there might be some discussion on that, but I 

5 don't remember that. I just remember the 

6 finding being about Hodgkin's versus non7 Hodgkin's.

8 DR. BEHLING: Yes, that is one of 

9 the key issues.

10 MR. HINNEFELD: So I'm just saying, 

11 well --

12 MEMBER LEMEN: Where do you want to 

13 go with this? Do you want to bring it up 

14 later or do you want to --

15 MR. HINNEFELD: I mean, I'll be 

16 glad to talk about it later. I don't think 

17 anybody is willing to have a conversation 

18 today.

19 I just don't know that the agency 

20 is going to be interested in going down a path 

21 that essentially says, you know, that's 
412 

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1 inconsistent with what was established when 

2 the law was established.

3 MEMBER LEMEN: Yes. I'm ready to 

4 talk about it, but I think that it's going to 

5 take some time to iron it out. So maybe we 

6 need to either set up a conference call, 

7 Wanda, with the appropriate people to just 

8 talk about this issue or wait until the next 

9 meeting.

10 MR. KATZ: Well, Dick, we can have 

11 this as an agenda item for the next meeting.

12 MEMBER LEMEN: Then let's do that.

13 MR. KATZ: Yes.

14 MEMBER LEMEN: If it will wait that 

15 long.

16 MR. KATZ: There's nothing keeping 

17 us --

18 MR. HINNEFELD: I don't know 

19 anything that's driving it.

20 MEMBER LEMEN: If it will wait that 

21 long, let's make it up at the beginning next 
413 

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COURT REPORTERS AND TRANSCRIBERS

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1 time, so we don't come to the end.

2 CHAIR MUNN: Well, I will make a 

3 note of that.

4 MEMBER LEMEN: And I will be ready 

5 to talk, and maybe I could talk to SC&A a 

6 little bit more about this before that time.

7 CHAIR MUNN: That's a good idea.

8 MR. KATZ: Absolutely.

9 CHAIR MUNN: Well, looking at 

10 calendars, please, if you would. November is 

11 out of the question for anything, as far as I 

12 can see. It's pretty thoroughly jammed up.

13 What -- we're continuing on 

14 Resolution until Hanukkah or what? Do we have 

15 any problem with scheduling something 

16 Thursday, December the 2nd?

17 MEMBER LEMEN: I'm actually out of 

18 the country all of the month of December.

19 CHAIR MUNN: Well, I guess that 

20 takes care of that.

21 MEMBER LEMEN: You can go without 
414 

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1 me.

2 CHAIR MUNN: No. 

3 MR. HINNEFELD: Not with that on 

4 the agenda items.

5 CHAIR MUNN: No, I don't think so.

6 MEMBER LEMEN: My wife and I are 

7 going to celebrate our 25th wedding 

8 anniversary, and I'm going to be in Tahiti.

9 MR. KATZ: We can go to Tahiti.

10 MR. HINNEFELD: Why don't we have a 

11 meeting in Tahiti?

12 CHAIR MUNN: Yes, we can do that. 

13 I'm for that.

14 MR. KATZ: We'll come to you.

15 CHAIR MUNN: Oh, will you be back 

16 after New Year's?

17 MEMBER LEMEN: Yes.

18 CHAIR MUNN: Will you be on board 

19 something like the 5th of January?

20 MEMBER LEMEN: I will be around 

21 that week, yes.
415 

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1 CHAIR MUNN: What about the other 

2 Board Members? Is January 5, which is a 

3 Wednesday, a good time for you?

4 MEMBER ZIEMER: If you guarantee no 

5 snow in Cincinnati, we might.

6 MR. HINNEFELD: We can make it 

7 subject to the weather.

8 CHAIR MUNN: Can we do January 5? 

9 Will that give both the contractor and the 

10 agency an opportunity to address some of these 

11 issues?

12 MR. HINNEFELD: Well, yes, we'll 

13 try to make some additional progress.

14 DR. MAURO: Could there be any 

15 informational discussion with Brant and Hans 

16 and whoever else wants to talk before that 

17 meeting? It sounds like maybe a little bit of 

18 communication to clarify -- I'm not sure if 

19 that is appropriate or not.

20 DR. ULSH: Well, we have already 

21 had that.
416 

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1 DR. MAURO: We have had it? Okay. 

2 So you feel that -- okay, never mind.

3 CHAIR MUNN: Well, we had the one 

4 technical, supposedly, where we had OTIB-49 

5 discussion on --

6 DR. ULSH: No. No, what I mean is 

7 on this particular issue, the lymphoma PER.

8 CHAIR MUNN: Oh.

9 DR. ULSH: SC&A and NIOSH have had 

10 a conference call on this where we put our 

11 various opinions on the table.

12 DR. MAURO: But Dr. Lemen was never 

13 a party to that.

14 DR. ULSH: That's correct.

15 DR. MAURO: The first time he was 

16 introduced to this was when I did an 

17 abbreviated summary before the end of the last 

18 meeting.

19 MEMBER LEMEN: Right, that's all 

20 I've had.

21 DR. MAURO: And I just -- as best I 
417 

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1 could because Hans was on vacation at that 

2 time --

3 MR. MARSCHKE: But I think he has 

4 also read the transcript. I mean, he has had 

5 access -- the transcript is out there. I mean 

6 that was all done and recorded. So there is a 

7 transcript on that. That's like April 2008, I 

8 believe it was.

9 DR. MAURO: Okay.

10 MR. MARSCHKE: There is a 

11 transcript available, if you want to read up 

12 and --

13 DR. MAURO: Okay.

14 CHAIR MUNN: Are you okay with 

15 that, Dick?

16 MEMBER LEMEN: Yes, but I might 

17 call SC&A between -- for the meeting, if 

18 that's all right.

19 MR. KATZ: You're welcome to do 

20 that, Dick.

21 CHAIR MUNN: Absolutely.
418 

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1 Hearing no objection, Wednesday, 

2 the 5th of January, nine o'clock, Cincinnati, 

3 the Procedures Subcommittee.

4 MEMBER LEMEN: And if there's a 

5 blizzard, we'll do it by phone?

6 CHAIR MUNN: Or go to Tampa or 

7 something.

8 MEMBER LEMEN: All right.

9 CHAIR MUNN: Is there anything else 

10 for the good of the order?

11 (No response.)

12 Otherwise, we stand adjourned.

13 Thank you all, ladies and 

14 gentlemen. I do appreciate your perseverance.

15 MR. KATZ: Thank you, everybody, 

16 for all the hard work. We got a lot done.

17 (Whereupon, at 5:01 p.m., the 

18 proceedings in the above-entitled matter were 

19 adjourned.)

20 

21 
419 

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