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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 

+ + + + +

WORK GROUP ON MOUND

+ + + + +

WEDNESDAY

JANUARY 6, 2010

+ + + + +

The Work Group convened in the 

Zurich Room of the Cincinnati Airport 

Marriott, 2395 Progress Drive, Hebron, 

Kentucky, at 9:30 a.m., Josie Beach, Chair, 

presiding.

MEMBERS PRESENT:

JOSIE BEACH, Chair

BRADLEY P. CLAWSON, Member

ROBERT W. PRESLEY, Member

PHILLIP SCHOFIELD, Member

PAUL L. ZIEMER, Member
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ALSO PRESENT:

TED KATZ, Designated Federal Official

NANCY ADAMS, NIOSH Contractor*

ISAF AL-NABULSI, DOE*

BOB BISTLINE, SC&A

LIZ BRACKETT, ORAU Team*

RON BUCHANAN, SC&A

MEL CHEW, ORAU Team

JOE FITZGERALD, SC&A

STU HINNEFELD, OCAS

EMILY HOWELL, HHS

KARIN JESSEN, ORAU Team

JENNY LIN, HHS

JOYCE LIPSZTEIN, SC&A*

ARJUN MAKHIJANI, SC&A

JOHN MAURO, SC&A

JIM NETON, OCAS

EUGENE POTTER, ORAU Team*

KATHY ROBERTSON-DEMERS, SC&A

WARREN SHEEHAN, Mound worker*

DON STEWART, ORAU Team

BRANT ULSH, OCAS

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

Call to Order 5

Roll Call 5

Stable Tritium Compounds 9

 Bob Bistline

 Brant Ulsh 13

 Discussion 15

Data Adequacy and Completeness of 60

Internal Dose Records

 Brant Ulsh 61, 66, 75, 126, 146, 192

 Bob Bistline 62, 124, 138, 188

 Warren Sheehan 72

 Discussion 69, 77, 128, 150, 193, 200

 Action Item - SC&A 104

 Action Item - Brant Ulsh 134

 Don Stewart 143

 Action Item - Brant Ulsh 181

 Action Item - SC&A 182

Shallow Dose 240

 Ron Buchanan

 Discussion 243

High-Fired Pu-238 246

 Brant Ulsh

 Joe Fitzgerald 248

 Discussion 251
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C-O-N-T-E-N-T-S (CONTINUED)

Road Map" Integrated: 268

Issues 1,3,4,7 & 8

 Kathryn Robertson-DeMers

 Discussion 269

PAAA Violations: Issue 21 284

 Kathryn Robertson-DeMers

 Brant Ulsh 286

D&D: issue 10 300

 Joe Fitzgerald

 Brant Ulsh 303

 Action Item - Brant Ulsh 330

Unfinished Issues 332

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

2 9:30 a.m.

3 MR. KATZ: Good morning, everyone 

4 in the room and on the line.

5 This is the Advisory Board on 

6 Radiation and Worker Health, the Mound Working 

7 Group. We are just getting started on our 

8 second day of this meeting.

9 We are going to begin again with 

10 roll call. Please, for everyone affiliated 

11 with the agencies and the contractors, speak 

12 to whether you have a conflict of interest as 

13 well.

14 So, beginning with Board members 

15 in the room.

16 CHAIR BEACH: Josie Beach, Mound 

17 Chair. No conflicts.

18 MEMBER CLAWSON: Brad Clawson, 

19 Work Group. No conflicts.

20 MEMBER ZIEMER: Paul Ziemer, Work 

21 Group. No conflict.

22 MEMBER SCHOFIELD: Phil Schofield, 
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1 Board member. No conflicts.

2 MEMBER PRESLEY: Robert Presley, 

3 Work Group. No conflict.

4 MR. KATZ: And do we have any 

5 Board members on the line?

6 (No response.)

7 Okay. Then the NIOSH ORAU team in 

8 the room?

9 MR. HINNEFELD: Stu Hinnefeld, 

10 Interim Director of OCAS.

11 MR. KATZ: No conflict?

12 MR. HINNEFELD: No conflict. 

13 Sorry. I always forget that part.

14 (Laughter.)

15 DR. NETON: Jim Neton, OCAS. No 

16 conflict.

17 DR. ULSH: Brant Ulsh, OCAS. No 

18 conflict.

19 MS. JESSEN: Karin Jessen, ORAU 

20 team. No conflicts.

21 MR. CHEW: Mel Chew, ORAU team. 

22 No conflict.
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1 MR. STEWART: Don Stewart, ORAU 

2 team. No conflict with Mound.

3 MR. KATZ: And on the line, NIOSH 

4 ORAU team?

5 (No response.)

6 Are you expecting any folks on the 

7 line?

8 Bob Morris, are you on the line?

9 DR. ULSH: He would only have been 

10 on for the neutron discussion.

11 MR. KATZ: Okay, right.

12 Then SC&A in the room?

13 DR. MAURO: John Mauro, SC&A. No 

14 conflict.

15 DR. BISTLINE: Bob Bistline, SC&A. 

16 No conflict.

17 MS. ROBERTSON-DEMERS: Kathy 

18 Robertson-DeMers. Conflicted.

19 MR. FITZGERALD: Joe Fitzgerald. 

20 No conflict.

21 DR. MAKHIJANI: Arjun Makhijani. 

22 No conflict.
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1 DR. BUCHANAN: Ron Buchanan, SC&A. 

2 No conflict.

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

4 DR. LIPSZTEIN: Joyce Lipsztein, 

5 SC&A. No conflict.

6 MR. KATZ: Okay. Then HHS or 

7 other government employees or contractors in 

8 the room?

9 MS. HOWELL: Emily Howell, HHS.

10 MS. LIN: Jenny Lin, HHS.

11 MR. KATZ: And on the line?

12 MS. ADAMS: Nancy Adams, NIOSH 

13 contractor. No conflict.

14 MS. AL-NABULSI: Isaf Al-Nabulsi, 

15 DOE. No conflict.

16 MR. KATZ: Okay. Then, at this 

17 point, we don't have any members of the public 

18 in the room. But on the line, any members of 

19 the public or staff of congressional offices 

20 who want to identify themselves?

21 (No response.)

22 All right, then, Josie?
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1 For everyone on the line, please 

2 mute your phone. Use *6 if you don't have a 

3 mute button. You can use *6 again to come off 

4 mute, and please do not use hold, but 

5 disconnect and call back in, if you need to 

6 leave at some point.

7 Thank you.

8 CHAIR BEACH: Okay. Thanks, Ted.

9 The agenda is posted on the web. 

10 We are going to make a slight change to the 

11 agenda. I know we said we were going to start 

12 with data adequacy this morning from 

13 yesterday's schedule, but we are going to go 

14 back. There's some discussion on the stable 

15 tritium compounds that we didn't finish with 

16 yesterday. So we will start that discussion 

17 this morning, and then go into the data 

18 adequacy and completeness.

19 SC&A I believe is going to tee off 

20 the tritium discussion this morning. Bob, if 

21 you're ready?

22 DR. BISTLINE: Yes, okay. I just 
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1 want to go on record for SC&A in terms of some 

2 of the discussion yesterday with regard to 

3 stable metal tritides.

4 I got the impression from the 

5 discussions yesterday that we are looking at 

6 hafnium as being the most insoluble tritide, 

7 which there is still some discussion, if you 

8 look at Zhou and Cheng's 2004 paper.

9 But, be that as it may, the big 

10 issue is I got the impression that NIOSH is 

11 treating hafnium as the most insoluble. Then, 

12 on the other end of the spectrum is HTO and 

13 gaseous tritium, and that everything else, 

14 basically, is being handled as an 

15 intermediate.

16 I want to make sure that it is 

17 understood that there are other stable metal 

18 tritides which really are in the literature 

19 that have been studied that are listed as S 

20 type tritides. If a person is doing dose 

21 reconstruction, that they should be treated as 

22 insoluble tritides and not as intermediate or 
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1 M type tritides.

2 There are at least a half a dozen 

3 or more that, if you look at the information, 

4 are of a stable form, insoluble forms, and 

5 need to be handled as stable insoluble S type 

6 tritides. For instance, zirconium in Zhou's 

7 paper is treated, it says, estimates of the 

8 effective dose coefficient based on data for 

9 rats receiving zirconium, halnium, and tritium 

10 by intratracheal instillation decreased in the 

11 order of zirconium greatest, hafnium next, and 

12 titanium after that. And overall, the results 

13 show that these should be treated as S and not 

14 M.

15 And the same thing goes for carbon 

16 tritide, titanium tritide. So there are other 

17 tritides out there that have been used 

18 throughout the complex. As I say, there are 

19 at least a half dozen or more that are well20 known that are being used.

21 I want to make sure that you 

22 realize, and we realize, that uranium is not 
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1 in that classification. Uranium tritide is

2 fairly soluble and probably is more of the 

3 soluble form. But some of these others that 

4 are used throughout the DOE complex are of an 

5 insoluble nature, and I just want to go on 

6 record that SC&A, when we start talking --

7 Mound is not the end of the trail as far as 

8 stable metal tritides is concerned. We are 

9 going to be facing this in dose reconstruction 

10 when you get into Savannah River, Pantex, 

11 Sandia, and other DOE sites.

12 So I just want to make sure that 

13 people understand that this is not the end of 

14 the trail, that Mound is not the only one, but 

15 there are other facilities where stable metal 

16 tritides, and I should also hasten to add that 

17 the OBTs, there are a number of those which 

18 are also classified as stable and very 

19 insoluble forms, and that we can't just treat 

20 hafnium as being the only one in the S 

21 category, but there are a number of others 

22 that also fit into that category.
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1 I think that explains my position 

2 on this issue. I just wanted to go on record 

3 and make sure that this is understood.

4 CHAIR BEACH: Okay. Thank you.

5 Okay, go ahead, Brant.

6 DR. ULSH: I have Zhou and Cheng 

7 Health Physics 2004 right here, and I'm 

8 reading from the conclusion on page 5 of 6. 

9 It says, "Among these three" okay, first of 

10 all, the three tritides that are looked at in 

11 this study are hafnium tritide, titanium 

12 tritide, zirconium tritide.

13 "Among these three tritides, 

14 hafnium tritide was classified as a type S, 

15 slow, material, whereas, titanium tritide and 

16 zirconium tritide ranked between type M, 

17 moderate, and type F, fast, materials, 

18 according to ICRP 66."

19 That's a direct quote, Zhou and 

20 Cheng, 2004.

21 DR. BISTLINE: Yes, but that is 

22 saying from ICRP 66. But if you read in that 
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1 same paper, it talks about the effective dose 

2 coefficient.

3 DR. ULSH: Okay. From the 

4 abstract, "The doses were on the same order 

5 of" -- okay, hold on now. Let me make sure 

6 here.

7 "The doses calculated by ICRP 66 

8 model for all materials were approximately two 

9 orders smaller than the doses obtained by the 

10 animal studies. This bias was caused by the 

11 different intake methods of the ICRP 66 model, 

12 inhalation, and in the animal study, 

13 instillation. The doses were on the same 

14 order while correcting for deposition 

15 fractions. The effective doses for hafnium, 

16 titanium, and zirconium tritides were" -- I 

17 can give you the numbers, but on the order of 

18 5 times 10 to the negative 10, 9 times 10 to 

19 the negative 11, and 6.5 times 10 to the 

20 negative 10 sieverts per Becquerel, 

21 respectively, according to the animal studies.

22 The bottom line is, even if you
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1 want to call it that, we have information here 

2 that gives you exactly how to estimate, how to 

3 reconstruct doses from hafnium tritide. At 

4 worst, this is a TBD issue. It is not an SEC 

5 issue.

6 DR. LIPSZTEIN: May I? This is 

7 Joyce.

8 I got a Road Map with 75 different 

9 forms of stable tritides that people could be 

10 exposed at Mound. I don't know which ones are 

11 more relevant or which ones were workers 

12 exposed to, but only about a dozen of them we 

13 have papers that talk about their 

14 solubilities. What do we do with the other 60 

15 that we don't know anything about?

16 DR. ULSH: I think what we do, 

17 Joyce, is we go to the literature and we talk 

18 to the people who were involved with this. If 

19 you look at the publications by Zhou and Cheng 

20 and by Yang --

21 DR. LIPSZTEIN: So Zhou and Cheng 

22 have a limited number of papers.
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1 DR. ULSH: Exactly correct.

2 DR. LIPSZTEIN: And they have 

3 studied a limited number of nuclides.

4 DR. ULSH: Right. They studied 

5 the ones were there was actual exposure 

6 potential.

7 DR. LIPSZTEIN: But if you only go 

8 by Zhou and Cheng, I think they did a very, 

9 very good study. I don't doubt that. But 

10 they only have studied a limited number of 

11 nuclides, and we have 60 more that we don't 

12 know anything about. There is nothing in the 

13 literature.

14 And also, there are some papers 

15 that don't agree too much with the place of 

16 titanium tritides. I have a paper by Balanov 

17 that says it should be type F, while if you 

18 read the Cheng, et al., paper, it would be 

19 type S, but I'm not discussing this one.

20 I am more worried about the ones 

21 that we don't have papers to assign. So we 

22 don't have any solubility studies to assign 
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1 anything. So what are you going to do with 

2 these radionuclides that you don't have any 

3 solubility studies?

4 DR. ULSH: Well, I would again say 

5 you have to consider the exposure potential. 

6 The Road Map was built --

7 DR. LIPSZTEIN: Yes.

8 DR. ULSH: -- from the 

9 [identifying information redacted] document. 

10 The [identifying information redacted]

11 document was meant to be, I don't want to use 

12 the word "biased", but inclusive, over13 inclusive of everything that could have 

14 possibly been in any location.

15 The piece that SC&A continues to 

16 not consider from the [identifying information 

17 redacted] document is it lists major 

18 radionuclides of concern, and the mere fact 

19 that a material might or might not have been 

20 present, just the possibility that it might 

21 have been present in a particular room does 

22 not, in and of itself, demonstrate an exposure 
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1 potential.

2 For example, if I take a sample of 

3 hafnium tritide from a doubly-contained glove 

4 box and I put it in a sealed glass ampule, and 

5 I walk it into the next room, that doesn't 

6 constitute an exposure potential.

7 The whole purpose of this program 

8 was to identify and manufacture an effective 

9 storage mechanism for tritium. In other 

10 words, you are looking for a stable compound 

11 that will grab the tritium and hold it. And 

12 hafnium tritide has repeatedly been told to us 

13 by the workers and in the literature that it 

14 was the most stable compound. I can't prove a 

15 negative. If there are --

16 DR. LIPSZTEIN: I'll mention one 

17 thing --

18 DR. ULSH: No, let me finish, 

19 Joyce. I let you finish.

20 DR. LIPSZTEIN: Yes, okay.

21 DR. ULSH: Let me go through --

22 DR. LIPSZTEIN: Okay.
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1 DR. ULSH: If you could go through 

2 the entire periodic table and look at every 

3 metal and speculate about the solubility of a 

4 particular tritide formed with that metal, I 

5 can't prove a negative. All I can tell you is 

6 these are the tritides that were used at 

7 Mound. There were several that were 

8 investigated on a bench scale that does not 

9 equate to an exposure potential.

10 The reason that Zhou and Cheng and 

11 others -- and Cheng at least is from Lovelace, 

12 so it is part of the DOE complex -- the 

13 reasons they focused on the particular 

14 tritides that they did is because these are 

15 the ones that were in wide-scale use and 

16 presented a significant exposure potential.

17 We investigated a couple that were 

18 listed in [identifying information redacted], 

19 as suggested by the Working Group and SC&A 

20 from our meeting in Germantown, and we 

21 confirmed that they were, indeed, simply 

22 science fair experiment-type scale.
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1 So, if you guys have evidence that 

2 there was widespread exposure potential for 

3 some other tritide and that it is less soluble 

4 than hafnium tritide, I would gladly evaluate 

5 it, but I haven't seen it.

6 DR. LIPSZTEIN: We have to divide 

7 this thing in two fractions. Do we have 

8 evidence that there is something more 

9 insoluble than the hafnium tritide? Hafnium 

10 tritide was treated as type S. We know that 

11 its halftime in the lung is longer than the 

12 one predicted by type S. But it is okay to 

13 treat it as type S because you are not taking 

14 into consideration the self-absorption of the 

15 particle within itself. So it is okay. You 

16 are being very claimant-favorable not to take 

17 into account the self-absorption.

18 So, this way, I don't have any 

19 question that hafnium would be assigned a type 

20 S. It is okay. It is claimant-favorable to 

21 assign to hafnium type S. I'm okay with that.

22 What I am saying is not that there 
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1 are others that could be more insoluble. I 

2 think the type S is the maximum you can assign 

3 because of the self-absorption. So, if you 

4 assign type S, you are being claimant5 favorable.

6 What I am saying is that I got a 

7 list of 76, not 75, 76 stable nuclides, and I 

8 don't know, and I would like NIOSH to tell me 

9 from this list, from the Road Map of 76 stable 

10 tritides, which ones were often used at Mound 

11 and which ones should we consider also an 

12 exposure to type S.

13 For example, europium tritide, is 

14 a possibility of people being exposed at 

15 Mound? The DOE, Zhou and Cheng did the work 

16 on this one, but the DOE classifies it as type 

17 S. Carbon tritide, Cheng and Zhou, they 

18 worked with it, and they classified it as type 

19 S. Is it a real possibility that the Mound 

20 people could have been exposed to carbon 

21 tritide? I heard yesterday no.

22 But what I mean is that Zhou and 
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1 Cheng, they worked with some stable tritides 

2 and not with everybody, and not with all of 

3 them.

4 I have a list of 60 that there is 

5 no study. Some, like scandium tritide, I have 

6 a paper by Potter saying that there's type F.

7 So, the scandium tritide, for 

8 example, the in vivo study from Zhou and Cheng 

9 should be classified as type S. The in vitro 

10 study from Zhou and Cheng, it should be 

11 classified as type M. The list from DOE 2004, 

12 it should be classified as type S.

13 So I don't know what was the 

14 exposure to this kind of tritide. Is this 

15 important? This is something that you have to 

16 give us and tell us which from the Road Map 

17 are the important stable metal tritides. And 

18 what are we going to do if there is no paper 

19 on how to assign a solubility to them? Are 

20 you going to be claimant-favorable and treat 

21 all of them as type S? Are you going to treat 

22 them as type M because you don't know? I 
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1 don't have this position from you.

2 DR. ULSH: Okay. To the best of 

3 my knowledge, I have no indication that there 

4 was any exposure potential at Mound to 

5 europium tritide or carbon tritide.

6 Okay. Let's agree on a definition 

7 here before we go further, just so no one gets

8 confused.

9 DR. LIPSZTEIN: Okay.

10 DR. ULSH: Stable metal tritide, I 

11 am not necessarily equating with only type S. 

12 So, for instance, uranium tritide, I think we 

13 would all agree is not type S, but I would say 

14 that that is a somewhat stable metal tritide.

15 DR. LIPSZTEIN: Yes.

16 DR. ULSH: So that is the way I'm 

17 going to use the term here for the next couple 

18 of minutes. Okay?

19 DR. BISTLINE: Yes, I agree.

20 DR. LIPSZTEIN: Okay.

21 DR. ULSH: So, in that category of 

22 stable metal tritides at Mound, off the top of 
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1 my head, the ones that I know about, the most 

2 widespread are uranium tritide and lithium 

3 tritide. Hafnium tritide, as we have 

4 discussed ad nauseam here, was very discrete, 

5 very small, but not zero.

6 Mel, am I missing any other major 

7 ones? There might be some very minor players.

8 MR. CHEW: No.

9 DR. ULSH: But those are the big 

10 ones.

11 MS. ROBERTSON-DEMERS: Yes, you 

12 are missing one. You're missing palladium.

13 DR. ULSH: Okay, correct.

14 DR. LIPSZTEIN: Do you have 

15 anything on lithium tritides in fact? Do you 

16 have any papers on lithium tritide or about 

17 the solubility of it?

18 DR. ULSH: Two points. First of 

19 all, I don't know if you could hear Kathy. 

20 Her voice is not at normal. But she mentioned 

21 that I am missing one, and that's palladium 

22 tritide, and that's possible. Yes, I do 
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1 recall hearing that that was at Mound. I 

2 can't recall exactly to what extent, but we 

3 could look at that.

4 DR. LIPSZTEIN: Palladium tritide.

5 DR. ULSH: Yes.

6 DR. LIPSZTEIN: Okay, that would 

7 be a type S.

8 DR. ULSH: What was the other one 

9 you asked about? Lithium, lithium tritide, 

10 yes.

11 DR. LIPSZTEIN: Yes.

12 DR. ULSH: It is definitely less 

13 soluble than hafnium. I don't know if it's 

14 type M or F off the top of my head.

15 MR. CHEW: It is much more 

16 soluble.

17 DR. ULSH: More soluble, yes.

18 And then, with regard to your 

19 larger question, what are we going to do in a 

20 situation where, if there was a tritide with 

21 an exposure potential that we didn't know how 

22 to handle it?
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1 Let's assume, just for the sake of 

2 discussion -- and again, I'm not proposing 

3 this, but just to make this clear in terms of 

4 an SEC context -- let's assume that there are 

5 other tritides out there that are type S. 

6 Well, so what? That's not an SEC issue.

7 So we treat all tritium as type S. 

8 I'm not saying we are going to do that, but 

9 what I'm saying is that demonstrates to you 

10 that it is not an SEC issue. We can argue 

11 about it under a TBD context or even under a 

12 dose reconstruction context.

13 For instance, if we've got a 

14 claimant where we do a dose reconstruction and 

15 he's got tritium exposure, I mean the 

16 mechanisms are in place for SC&A to review 

17 these dose reconstructions, and you could come 

18 up with a possible finding, "Hey, NIOSH, you 

19 didn't give this guy potential exposure to 

20 uranium tritide or even hafnium tritide." And 

21 we could discuss that under the context of a 

22 dose reconstruction review. We have an entire 
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1 subcommittee dedicated to that.

2 But even under the worst 

3 circumstances, if we accept everything that 

4 you say, it's not an SEC issue. We're going 

5 round and round in circles on this, and it's 

6 just not an SEC issue under any scenario.

7 DR. LIPSZTEIN: No, it's an SEC 

8 issue if you don't know what solubility the 

9 tritium compound is.

10 DR. ULSH: How about type S?

11 DR. LIPSZTEIN: If you are telling 

12 me that, if you don't know, you are going to 

13 treat it as type S, then we have to go into 

14 the problem of the dose being too high and the 

15 source term being too high. That's what you 

16 discuss on OTIB-0066.

17 DR. NETON: I'm confused, Joyce.

18 DR. MAURO: Maybe I can help out.

19 DR. NETON: Yes.

20 DR. MAURO: It goes, again, toward 

21 plausibility. Interestingly enough, during 

22 the course of this meeting we ran into the 
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1 duality of the problem. We noticed when we 

2 were talking about radon that there was some 

3 discussion that it would be implausible to 

4 assume that the doses could have been as high 

5 as 10,000 rem associated with some of the 

6 measurements that were made.

7 Now it's my understanding that 

8 some of these assumptions regarding tritides, 

9 we could talk about those and going from the 

10 bioassay data to the respiratory tract dose. 

11 If you assume it's type S, it may be on that 

12 order of doses of that magnitude.

13 So we have a very interesting --

14 and, listen, I'm sympathetic. This business 

15 of plausibility, the bounding, sufficient 

16 accuracy, and finding that place where you 

17 strike that right balance is not an easy thing 

18 to do.

19 Now what we are hearing right now 

20 is a strategy that, for this particular 

21 application, certainly it is claimant22 favorable. It is claimant-favorable off the 
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1 charts. But, unfortunately, it is so 

2 claimant-favorable that it starts to bring us 

3 into the world of plausibility.

4 I think it is important that we 

5 talk about this. It's only fair that we share 

6 it with the Work Group that we know that this 

7 is a difficult question. When and where and 

8 under what circumstances does the issue of 

9 plausibility rise and needs to be dealt with? 

10 I guess I could put that on the table.

11 MEMBER ZIEMER: But, John, is it 

12 implausible, if you're unsure of the 

13 solubility class, to select the higher one?

14 DR. MAURO: No.

15 MEMBER ZIEMER: Why is that 

16 implausible?

17 DR. MAURO: It's that the person 

18 was always -- here's where I think 

19 implausibility comes in, in my view. We have 

20 a person that worked there for many years. We 

21 know that probably most of the time he's 

22 working with tritiated water. But there's 
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1 also the very real possibility that, by the 

2 nature of his job responsibilities, that from 

3 time to time he may have found himself in the 

4 situation where he's dealing with one of the 

5 intermediary or possibly even the type S, even 

6 for a short period of time.

7 Now we know with type S we're 

8 talking about a difference in lung dose of a 

9 factor of 10,000. In other words, going from 

10 the urine sample to the dose, a 10,000-fold 

11 difference.

12 So it doesn't take very much 

13 assumption of how long was the person exposed 

14 to hafnium type to deliver a substantially 

15 higher dose, even if it was only for a few 

16 days. I believe, even if it were only a few 

17 days.

18 So what I'm getting at is that, 

19 where I'm heading is, in the end, you may have 

20 a person that worked there for five years, 

21 where you really don't know when and under 

22 what circumstances he might have been exposed 
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1 to hafnium, but you agree that, yes, that was 

2 possible that some period of time he may have 

3 encountered and had to work with hafnium, and 

4 some of his intake may have been hafnium, 

5 which leads us to a place where, from what I'm 

6 hearing, you will assign the entire duration 

7 of his exposure, which could be several years, 

8 every one of those bioassay samples collected 

9 every two weeks are going to be assumed to be 

10 due to the intake of hafnium. As a result, 

11 you are going to assign to him a dose that is 

12 going to be tens of thousands of rads to the 

13 respiratory tract, as opposed to 1 rad.

14 MEMBER ZIEMER: I assume you 

15 wouldn't start that assignment until the 

16 hafnium work started.

17 DR. MAURO: Yes, and that would be 

18 fairly reasonable.

19 DR. NETON: But let's back up a 

20 little bit, though. I mean you are kind of 

21 making a couple of arguments here.

22 One is that these doses are going 
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1 to be extremely large. I think I would like 

2 to clarify, yesterday, I mean, it was stated 

3 in this meeting that these radon doses from 

4 ET1 and ET2 were going to be large. I don't 

5 necessarily believe that it was the doses that 

6 are implausibly large. I think the exposures 

7 have ended up being these huge exposures. 

8 That's a different issue.

9 I think any time you have a valid 

10 dose model and it comes out large, it is what 

11 it is. I mean on face value we can argue all 

12 we want about the technical adequacy of the 

13 models. But if it's accepted, then it is a 

14 valid model, end of story.

15 When you get into these tritium 

16 tritide exposures, though, what you are 

17 arguing is that it's not plausible to give the 

18 guy 18,000 rem. Well, in fact, we may or may 

19 not do that. If it only takes, like you're 

20 suggesting, a couple of days, then it truly is 

21 plausible. If two days' exposure puts the guy 

22 over 50 percent, we'd probably stop the dose 
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1 reconstruction. That is how we do it. These 

2 dose calculations are done to the point where 

3 you don't waste time reconstructing exposures 

4 over 50 years if a very small exposure will 

5 put the guy over 50 percent. I mean that's 

6 the way the program is set up.

7 So, by your very argument saying 

8 it is implausible he worked five years, but on 

9 the other side of the coin you're saying only 

10 two days' possible exposure could put that guy 

11 into the 50 percent.

12 DR. MAURO: Oh, no, it's good.

13 DR. NETON: I'm missing your point 

14 here.

15 DR. MAURO: No, I hear what you're 

16 saying.

17 DR. ULSH: And here's another 

18 point that we haven't discussed in turn that 

19 is specific to Mound. People who were working 

20 with tritium at Mound, as similar to other 

21 tritium-type facilities, were giving 

22 urinalysis samples, I want to say, at least 
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1 twice a week, maybe more frequently, but I 

2 would have to look to be sure, so very, very 

3 frequently.

4 If you're talking about a highly 

5 insoluble tritium compound, there is a 

6 distinctive pattern that you would see in the 

7 excretion curve from these people. That is 

8 explained in McConville and Woods, 1995.

9 McConville, we interviewed him. 

10 He explained to us that, when the concern 

11 about hafnium tritide surfaced in the nineties 

12 because of the DOE order that I can never 

13 remember the number of and the technology 

14 shortfall that existed, he went back through 

15 the bioassay records and looked for any 

16 possible evidence of exposure to insoluble 

17 tritium compounds. He found three.

18 So I think that needs to be 

19 brought to bear here, too, to give you context 

20 of how big an issue we're talking about here.

21 DR. MAURO: I have a problem with 

22 the concept you just described. The reality 
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1 of the situation is, if a person is 

2 simultaneously being exposed to tritiated 

3 water and hafnium tritide, and let's say 90 

4 percent of the intake is tritiated water and 

5 10 percent of the intake is tritide, the 

6 tritide contribution to what you are going to 

7 see in the urine is going to be invisible. It 

8 is going to be completely dwarfed.

9 So, therefore, you would never 

10 know. I mean there's going to be an excretion 

11 pattern associated with the hafnium 

12 contribution that is going to be completely 

13 hidden by the excretion from the tritium. So 

14 the fact that you don't see patterns in the 

15 urine of individuals who are sampled on a 

16 weekly basis that would be indicative of 

17 hafnium is not surprising because we all know 

18 that it is likely that the person, if he was 

19 exposed to some hafnium, he probably was also 

20 exposed to some tritiated water, and it is 

21 going to be completely hidden.

22 So I don't think you can make your 
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1 case that you are not seeing very much because 

2 only when he is only exposed to hafnium by 

3 itself would you observe the kinds of patterns 

4 that you would see. Once you get a little bit 

5 of tritium, it's gone; you can't see it.

6 DR. LIPSZTEIN: Yes, that's very 

7 right. You can't see it because it is going 

8 to be covered by the other exposures. So you 

9 really can't distinguish.

10 Jim, there is a paragraph in 

11 OTIB-0066 that describes our problem. It 

12 says, if the metal substrate of the SMT is not 

13 known, type S solubility should be assumed. 

14 However, fairly modest tritium urine 

15 concentration can imply extremely large type S 

16 SMT exposures that might be quite implausible, 

17 and it gives an example of a urine excretion 

18 of 1 microcuries per liter of tritium that 

19 would result -- begin 30 days after the 

20 exposure, would mean 300 millicuries, assuming 

21 a fraction of 10 to the minus 6 escaping from 

22 the source term. So that is from OTIB-0066.
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1 CHAIR BEACH: Kathy has been 

2 trying to come in for -- sorry.

3 MS. ROBERTSON-DEMERS: Can I say 

4 something, too, to add to that? The Mound 

5 special tritium compound Technical Basis 

6 Document also re-emphasizes this. From this 

7 perspective, what they are doing is they are 

8 using the standard bioassay procedure, which 

9 is designed to detect soluble tritium 

10 compounds in applying the model.

11 It says, because the identity of 

12 all tritiated materials encountered in the 

13 workplace is not well known, and the 

14 dissolution rates applicable to the 

15 encountered tritium materials are not well 

16 known, uncertainty in dissolution rates to be 

17 applied to the deconvolution of the urine 

18 bioassay excretion curves ranges over three to 

19 four orders of magnitude, conservative 

20 assumptions for identities in dissolution can 

21 lead to greatly overestimated doses of three 

22 to four orders of magnitude.
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1 Because, in addition, urine data 

2 for particulate intake is readily obscured for 

3 extended periods of time by small intakes of 

4 readily assimilated HTO, urine bioassay is 

5 considered to have substantial shortfalls for 

6 assigning intake in dose from stable tritiated 

7 particulates.

8 DR. ULSH: And again, I would 

9 remind you to consider the context of that 

10 document. Yes, there is a technology 

11 shortfall because you can't, with bioassay, 

12 detect doses as low as 100 millirem per year, 

13 as required by the DOE order. That is totally 

14 different from what we do in this program.

15 MS. ROBERTSON-DEMERS: Could you 

16 explain to me why you think that that is based 

17 upon the 100-millirem limit?

18 DR. ULSH: Because that's the 

19 order that was in place at the time that 

20 document was written, and that was the nature 

21 of --

22 MS. ROBERTSON-DEMERS: But this is 
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1 not the order itself. This is a different 

2 document.

3 DR. ULSH: I know that, but that 

4 was in response to the requirement placed on 

5 Mound, and every other site in the DOE 

6 complex, to be able to detect exposures as low 

7 as 100 millirem per year. They were concerned 

8 because they couldn't do that in this case.

9 DR. NETON: What date is that 

10 document that you're reading from?

11 MS. ROBERTSON-DEMERS: 2001.

12 DR. NETON: Yes, I believe the 

13 order became effective in 1994, I think, or 

14 thereabouts. So anything after 1994 would 

15 have to be in compliance with 10 CFR 835, 

16 which had a 100 millirem AEDE requirement, 

17 CEDE requirement.

18 MS. ROBERTSON-DEMERS: Well, I 

19 guess the document is not calling that out. 

20 This document is not calling that out.

21 DR. NETON: What's the genesis of 

22 the document? Who wrote the document?
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1 MR. HINNEFELD: This is Stu 

2 Hinnefeld.

3 If I could offer a comment, it 

4 would sound to me that this was the Technical 

5 Basis Document from the Mound internal 

6 dosimetry program. That's what you're reading 

7 from? Is that right?

8 MS. ROBERTSON-DEMERS: This is the 

9 Mound Technical Basis Document --

10 MR. HINNEFELD: I think this was 

11 the DOE one.

12 MS. ROBERTSON-DEMERS: -- for 

13 stable tritiated particulate and in 

14 organic compounds--

15 MR. HINNEFELD: All right, so it 

16 is a portion of the internal dosimetry. So 

17 this document was instructing essentially the 

18 dosimetrists at Mound and writing for the sake 

19 of reviewers, because that's what those were 

20 written for, so reviewers could come and make 

21 sure you had technically evaluated your 

22 program.
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1 It was describing to them, it was 

2 telling the dosimetrist do not assign a dose 

3 based on type S stable metal tritides from all 

4 tritium doses because we don't want to record 

5 doses that high because we don't really think 

6 they're that high.

7 I mean that's what they did that 

8 for. That's certainly the way it sounds to 

9 me. That's why I would write something like 

10 that that way.

11 So they would say don't just 

12 assume that you have this type S material, to 

13 record the dose, you know, the dose of record, 

14 which in generating the dose of record, we all 

15 know sites generating dose of record, some of 

16 them did a good job and some of them maybe 

17 were a little shady. And for that reason, we 

18 don't rely on dose of records in the program, 

19 and we have developed approaches that we will 

20 not underestimate people's dose.

21 So the fact that it was not 

22 appropriate for Mound to do dosimetry from 
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1 bioassay because of the mixed exposure, which 

2 is certainly a decision I would have made, had 

3 I been in their position, I don't see how that 

4 really pertains to the decision of the 

5 suitability of this, using this for dose 

6 reconstruction in this program, which is, of 

7 course, the subject of debate.

8 So I am just listening to the 

9 debate today.

10 MS. ROBERTSON-DEMERS: Can I ask 

11 you, then --

12 MR. HINNEFELD: Sure.

13 MS. ROBERTSON-DEMERS: -- when Tom 

14 Lebone wrote OTIB-0066, and he made the 

15 statement that Joyce just read, what was his 

16 intention there? Was it for 100 millirem?

17 MR. HINNEFELD: I don't know. I 

18 don't know what that was about, and I didn't 

19 know the statement was there.

20 DR. NETON: Right, Tom's statement 

21 stands. I mean it is true that if you have a 

22 large tritium output in the urine and you 
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1 apply blindly type S to it, you will come up 

2 with some very extremely high intakes that are 

3 implausible. That's true.

4 But underlying in there is the 

5 assumption that there may have been some type 

6 S material. It doesn't take much in there to 

7 put you over the 50 percent PC calculation.

8 DR. MAKHIJANI: Jim, wouldn't the 

9 same argument apply to radon? Because you've 

10 got this person sitting there. You could say, 

11 well, you could assume that he sat there for 

12 two days, and it put him over the 50 percent. 

13 Then why go to -- it seems to be exactly the 

14 same thing.

15 I mean you've measured high --

16 DR. NETON: You are talking about 

17 like the Mound radon situation?

18 DR. MAKHIJANI: Yes. Yes, exactly 

19 the --

20 DR. NETON: No, we have one 

21 measurement taken over, one series of 

22 measurements taken over a couple of days over 
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1 a 20-year period, trying to reconstruct the 

2 doses back in time 20 years, that's the big 

3 issue there, in my opinion.

4 With different building 

5 ventilation rates, patterns, unknown cracks, 

6 ventings, that is really the problem there.

7 DR. MAKHIJANI: In doing the 

8 calculation that you did, you know, going back 

9 and extrapolating, and so on, there are 

10 certain reasonable assumptions that you can 

11 make, possibly reconstruct ventilation, you 

12 can't do the cracks, and so on.

13 But you have a measurement that --

14 I'm just throwing this out for argument, as to 

15 whether there's a consistency in the 

16 discussion. You have the measurement that is 

17 made near a hole in the ground, as I 

18 understood the discussion. So you're going to 

19 have an inlet of radon that --

20 DR. NETON: We don't know what 

21 that measurement really means, Arjun.

22 MEMBER ZIEMER: Well, that was the 
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1 same question I asked yesterday. Can you 

2 really not reconstruct that? And you have not 

3 only the measurement issue, I guess, but you 

4 have all the other parameters and the time 

5 issues and the nature of these, but it is kind 

6 of a separate --

7 DR. NETON: You have no direct 

8 measurements of the three different gases that 

9 were coming out of that hole. They were 

10 measuring, they were trying to measure 

11 radon-222 with something like a diffusion 

12 barrier device. Then the concentration came 

13 out something like 200 picocuries per liter. 

14 No one knows what that really was because it 

15 was calibrated to measure radon diffusion 

16 through a permeable barrier.

17 DR. MAKHIJANI: But you have a 

18 parallel situation here, I would argue, just 

19 listening to the discussion, at least possibly 

20 parallel situation, that should be considered 

21 before the issues get settled, which is that 

22 seems highly unlikely that anyone is exposed 
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1 to hafnium tritide as the principal exposure 

2 over a long period of time.

3 And you're going to assume that 

4 they were exposed to hafnium tritide over 

5 possibly a much longer period of time than 

6 they were. I mean where it goes over 50 

7 percent is not a relevant consideration 

8 because you could talk about other cancers. I 

9 mean this is not just about lung cancer. 

10 You're going to compensate lung cancers 

11 probably just on the basis of plutonium.

12 So you can say, well, you never 

13 even go to the tritide. You've got the 

14 plutonium-238. They are going to compensate 

15 all the lung cancers. So the tritide argument 

16 doesn't even enter the cancer, lung cancer, 

17 argument for the most part, I would say. 

18 Right?

19 But if the situation at Mound is 

20 that you are confronted with a mixture, and 

21 the typical mixture is mostly soluble stuff, 

22 then you don't really have a model for the 
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1 situation at Mound.

2 I think it is at least arguably a 

3 very similar situation in that you can't model 

4 the radon because you don't have the 

5 measurements. In this case, you have no 

6 measurements for what metals, what kinds of 

7 tritides were in the air, just like you don't 

8 have measurements for what kind of radon was

9 in the air.

10 DR. NETON: But let's go back, I 

11 mean, again, Super S issue, though, I think is 

12 analogous to this. We're doing exactly the 

13 same thing for Super S complex-wide. There's 

14 a huge difference in dose per unit intake to 

15 the lung. And why is that different? Why is 

16 that acceptable and this one is not?

17 I'm not sure if it's because the 

18 population is potentially smaller. I'm not 

19 sure that --

20 DR. MAKHIJANI: No, no, that's 

21 different because you actually know that 

22 people were exposed to Super S plutonium, and 
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1 a lot, for protracted periods of time.

2 DR. NETON: Everybody? Not 

3 everybody. Well, that's my point. So how do 

4 you know which ones are getting the over5 assigned doses that are implausibly large?

6 DR. MAURO: Yes, I think that is 

7 where it comes down to. If you could say that 

8 here we have a person -- let's take one person 

9 at a time. Is it plausible that he was 

10 exposed for protracted periods of time to 

11 Super S at Rocky? And the answer might very 

12 well be, yes, it is possible because he was 

13 working at this location and during this time 

14 period. So it is plausible that that could 

15 have happened.

16 This also goes toward uranium type 

17 M and S. Is it plausible that this facility 

18 person was consistently exposed to this 

19 particular form of uranium? And the answer, 

20 for that person, the answer is, yes, it could 

21 very easily be yes. And therefore, you 

22 always, whatever the form is -- so you're in a 
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1 situation where plausibility is manageable. 

2 And you can say, because of the magnitude of 

3 the amount of material and the time period 

4 over which the amount of material was handled, 

5 for any given individual, it is not out of the 

6 question that he could have gotten a worst7 case situation.

8 I guess what we are asking here 

9 is, is it plausible that there's anyone who

10 was exposed to hafnium tritides exclusively 

11 over long periods of time? And if the answer 

12 is no to that, we have a plausibility issue.

13 DR. ULSH: The answer to your 

14 question is, yes, there were a couple of 

15 people who were exposed to hafnium tritide. 

16 We know who they were. There are very well17 documented incidents.

18 Over long periods of time, no. 

19 These are discrete incidents, accidental.

20 DR. MAURO: There's where I think 

21 the different concepts, and how they're 

22 applied and their decisions were made, put us 
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1 in a different arena. I think the arena with 

2 regard to Rocky and high-fired plutonium in 

3 general, this is a fairly widespread, large 

4 quantity situation.

5 We're in a different arena. It is 

6 very unusual, very, very small quantities with 

7 the potential, though, to have doses that are 

8 10,000 times higher, if you use that 

9 assumption. This is a very challenging 

10 situation.

11 DR. NETON: I still think we need 

12 to look at the individual dose reconstructions 

13 that were done, as Brant started off at the 

14 beginning of the session. Take an individual 

15 dose reconstruction and do an evaluation. Was 

16 this reasonable to assume that this person was 

17 or was not exposed to hafnium, you know, some 

18 very insoluble tritides?

19 I think that is based on a 

20 composite, looking at his file, his exposure 

21 history, what buildings he might have worked 

22 in, the job category. All kinds of things go 
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1 into these dose calculations. These are not 

2 aggregate. We just don't take 300 cases and 

3 say, okay, all these lung cases are going to 

4 get hafnium tritide. That's not the way it 

5 works in dose reconstruction.

6 So we have to make some value 

7 judgments about the potential exposures.

8 MR. FITZGERALD: I think my 

9 reaction yesterday, when you were, I think, 

10 citing or referencing, we were sort of saying, 

11 you know, by extension, one couldn't define 

12 these worker cohorts. We're, obviously, still 

13 in the process of doing that.

14 I think your reaction was, well, 

15 you know, it doesn't really matter. I mean 

16 you might end up not being -- it might be a 

17 much more expansive group of workers, but that 

18 doesn't bother us because, if we don't have 

19 definitive information, we'll default to 

20 applying a type S.

21 MEMBER ZIEMER: It still has to be 

22 plausible, though.
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1 DR. NETON: Yes, if it were truly 

2 plausible that that cohort of workers were 

3 exposed.

4 MR. FITZGERALD: Well, I'm just 

5 saying, if you're in SW and R, and you can't 

6 come up with a roster, that I think Brant has 

7 brought to us for the 10 workers, but you come 

8 up with sort of we don't really know. We 

9 don't know if maintenance workers went in and 

10 out, say it's scrap metal, whatever it is 

11 going to be. So it becomes sort of an 

12 undefined class in those buildings. It then 

13 becomes a little more analogous to the radon 

14 issue, where you are not going to have that 

15 information to make that judgment.

16 I think you even alluded to this 

17 yesterday. Well, you know, you might end up 

18 assigning everybody to type S because you 

19 can't do that. That's where I think we end up 

20 moving from the couple of folks that Brant was 

21 referring to, which is a plausible situation, 

22 to one where the plausibility comes into 
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1 question because you know there wasn't a long2 term exposure to hafnium.

3 But, nonetheless, since you can't 

4 define by worker category or location those 

5 who might have been likely exposed, then 

6 everybody is going to get this assignment. 

7 That assignment is, by definition, going to be 

8 extremely high.

9 In the tritium areas, particularly 

10 in the earlier years, these exposures were 

11 high. They exposed them right up to the 

12 limit. That's what we got from the people at 

13 Mound, that, basically, in the early days, the 

14 production era, they had extremely high 

15 tritium exposures. So this is not trivial.

16 If you, in fact, apply that factor 

17 for some of these workers, it is just going to 

18 be implausibly high.

19 DR. ULSH: What do you mean by 

20 early days, ballpark?

21 MR. FITZGERALD: Well, I am just 

22 saying --
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1 DR. ULSH: Fifties?

2 MR. FITZGERALD: No, even the 

3 seventies, sixties and seventies, the tritium 

4 levels were pretty, I mean the exposure levels 

5 were fairly high.

6 This multiplication factor I think 

7 would put you in that realm of just --

8 DR. MAURO: Yes, tens of thousands 

9 of rem.

10 MR. FITZGERALD: Tens of thousands 

11 of rem. So I think it is analogous to the 

12 radon issue from that standpoint. Once you 

13 end up having to default in applying this to a 

14 larger population, many of whom already have 

15 high tritium HTO exposures, I think that's 

16 where it becomes -- and this is what I think 

17 one sentence was trying to convey in that 

18 piece -- but, in a sense, I think it puts you 

19 in that realm.

20 DR. ULSH: Well, what you're 

21 talking about here, as Jim has said, number 

22 one, Super S is not just at Rocky. We're 
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1 applying it complex-wide. We are applying it 

2 to people who there is no evidence to suggest 

3 that they were ever exposed to Super S 

4 plutonium, but we're doing that.

5 And you don't even have to go to 

6 Super S. Look at uranium. That's type S. 

7 Hafnium tritide is type S.

8 We're applying, if we don't know 

9 the solubility class of the uranium, we're 

10 applying type S. I don't understand why 

11 that's acceptable everywhere else, but at 

12 Mound, doing exactly the same thing only with 

13 a different element, is not acceptable.

14 DR. NETON: That is very 

15 reasonable. Eighty-plus percent of the lung 

16 cancers in this program are compensated.

17 MR. FITZGERALD: I think the 

18 difference goes back to John's comment, which 

19 is, if the likely exposure pathway -- and I 

20 think Brant alluded to it -- was limited to a 

21 small number of workers, but by virtue of lack 

22 of measurements and the ability to measure, 
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1 you by default have to apply it to everybody, 

2 then I think you get into this question, is 

3 that plausible to do so?

4 We've already acknowledged that, 

5 whether it's two, three, four, ten that are 

6 clearly exposed, if on a maximizing strategy 

7 one assigns it to everybody, and that is a 

8 tremendous dose, I don't see how -- I don't 

9 know if that is directly analogous to the 

10 high-fired Pu.

11 DR. NETON: Well, let's back off 

12 from everybody. I mean let's, again, confine 

13 it to people who work with tritium --

14 MR. FITZGERALD: Right.

15 DR. NETON: -- had lung cancer. 

16 Okay? Because it is only going to really --

17 lung cancer may be --

18 MR. FITZGERALD: That's the 

19 universe.

20 DR. NETON: That's the universe. 

21 So it is much more confined. Those who are 

22 not monitored, such as administrative staff, 
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1 secretarial staff, professional staff who 

2 didn't work with tritium, are not going to be 

3 assigned this. So it's not everybody, all 

4 claimants. Okay? It is a much smaller subset 

5 of the population.

6 MEMBER ZIEMER: Well, the other 

7 comment I would make on this thing is that, if 

8 you can't delineate specifically that they 

9 were not in that area, you have made the 

10 statement it's plausible that they were. I 

11 mean you can't say it's not plausible and yet 

12 say they could have been in there.

13 It seems to me, logically, I mean 

14 I don't personally think it's likely, but the 

15 statement that says, "I can't show that they 

16 weren't in there," you are, in essence, saying 

17 it's plausible that they were.

18 I think if you get to that point, 

19 you are not assigning a lifetime dose. You 

20 are only saying they have to be there a couple 

21 of days, or whatever it is, right? And that 

22 is the dose you are assigning, and then you 
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1 are stopping. So you are never saying that 

2 they got 10,000 rem. I don't know, whatever 

3 it is.

4 But I'm having trouble with, I 

5 mean I don't like the idea of that sort of a 

6 big group, because we have this everywhere, 

7 and our gut feeling is it can't be.

8 But if you can't show that it's 

9 not plausible for them to be in there, you are 

10 saying it's plausible. Right? Think about 

11 that.

12 MR. FITZGERALD: Yes, I understand 

13 what you're saying and I don't disagree.

14 DR. MAURO: The reason we reopened 

15 this is I felt it was important to get this on 

16 the record. I understand it is a tough one. 

17 But now I believe we have a nice, complete 

18 record, and how it's dealt with --

19 DR. NETON: For the third time.

20 (Laughter.)

21 DR. MAURO: Is that right --

22 MR. FITZGERALD: Well, we had the 
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1 radon discussion after the tritide, and that 

2 kind of, you know, brought some of these 

3 things in focus.

4 Your questioning yesterday 

5 certainly, you know, some of these, I guess, 

6 criterion for probing this thing struck a cord 

7 as far as --

8 MEMBER ZIEMER: Well, I'm as 

9 uncomfortable as Arjun was on the radon issue, 

10 simply because your gut feeling is, well, you 

11 have some information; why can't you 

12 reconstruct? But I guess it gets to a point 

13 where --

14 DR. NETON: There's too many 

15 unknowns, especially going back 20 years.

16 MEMBER ZIEMER: Yes.

17 DR. NETON: That, to me, we've 

18 never been successful at taking 

19 contemporaneous measurements and going back 20 

20 years. I can't recall when we've ever been 

21 able to do that, I think, convince folks that 

22 it is sufficiently accurate.
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1 MR. FITZGERALD: Well, this is 

2 helpful. I think just comparing the two 

3 issues and making sure that there is a 

4 rationale between the two is helpful.

5 CHAIR BEACH: So are there any 

6 action items that came out of the earlier 

7 discussion with Joyce? I know Joyce asked for 

8 some information. I just want to make sure. 

9 So we're okay there? I don't need to -- okay, 

10 I just wanted to make sure I didn't miss 

11 anything.

12 DR. LIPSZTEIN: I want to know 

13 from the Road Map which were the important 

14 tritides.

15 DR. ULSH: Does that mean that you 

16 are just going to answer that again or --

17 CHAIR BEACH: No, I just wanted to 

18 make sure Joyce was okay --

19 DR. ULSH: No? Okay.

20 CHAIR BEACH: -- and didn't need 

21 anything in writing or anything from you on 

22 that.
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1 So the next item on the agenda is 

2 data adequacy and completeness of internal 

3 dose records.

4 So is NIOSH -- Brant, are you 

5 prepared to start on that? I have it down as 

6 NIOSH, but --

7 DR. ULSH: Yes. Well, I can just 

8 kind of go over the sequence of events, and 

9 then just open it up to discussion.

10 This has been an ongoing topic of 

11 discussion. The latest development, I think, 

12 is our issuance of our response to SC&A's 

13 latest White Paper.

14 Our response came out in November 

15 of 2009. That builds on the iterative cycle 

16 that we go through typically on these issues.

17 It originally started as a matrix 

18 issue listed in SC&A's issues matrix in 

19 February of 2008. We discussed it at a number 

20 of work groups. I list that in the White 

21 Paper.

22 SC&A, the significant event is 
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1 probably us issuing our responses to the 

2 matrix items. That occurred in July of 2008.

3 That was followed by SC&A issuing 

4 their reports in April of 2009 on this issue. 

5 And then we again discussed it at a Working 

6 Group meeting in May of 2009. Then we issued 

7 our response in November.

8 There were a number of issues 

9 raised by SC&A. I feel like we have addressed 

10 them thoroughly in the November release and 

11 many times previously.

12 So I guess I would just open it up 

13 to anything else that SC&A wants to discuss or 

14 the Working Group.

15 CHAIR BEACH: Bob?

16 DR. BISTLINE: Well, I'll go ahead 

17 and try to kick off a few points of concern 

18 that still exist as far as SC&A.

19 The first of which gets back to 

20 the discussion of gross alpha bioassay 

21 methodology that was used and the rapid gross 

22 alpha bioassay radiochemistry methods that 
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1 were referred to as plutonium analysis in the 

2 procedures; that it was sufficient to cover 

3 actinides, including plutonium, uranium, 

4 protactinium, americium, and possibly curium, 

5 but that radium is not brought down by this 

6 method. So the process is missing the radium. 

7 So it is sort of a misnomer here.

8 The recovery of the gross alpha 

9 technique was usually quoted at 90 percent, 

10 but ranged from 60 to 90 percent by 

11 [identifying information redacted], and equal 

12 chemical recovery yield, there's a real 

13 question, again, as to whether the recovery 

14 was equal for all of the components. If the 

15 recovery for thorium, protactinium, uranium, 

16 plutonium, and other radionuclides are 

17 recovered at the same or comparable 

18 percentages, this wouldn't be an issue. But 

19 the question is whether they are coming down 

20 in the same recovery.

21 Mound bioassay personnel did not 

22 specifically evaluate whether there was a 
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1 differential in recovery for particular 

2 actinides recovered with the gross alpha 

3 procedure, nor has NIOSH provided the 

4 differential recoveries of alpha emitters.

5 Another point is, with the 

6 implementation of the anion exchange, specific 

7 rate of nuclides were eluted from the column. 

8 This was primarily done for plutonium. Then, 

9 unless the field of health physicists 

10 communicated to the bioassay group that 

11 workers were exposed to other radionuclides, 

12 it wasn't done.

13 So the question is whether there 

14 was consistency in routine. Whenever it was 

15 an incident involved, the field person in 

16 general was communicating this, it appears. 

17 But the question is whether this was done on a 

18 routine basis, that it would not be specific 

19 after the anion, they went to the anion, that 

20 it was only pulling -- they were only looking 

21 at one specific isotope. That would be your 

22 plutonium.
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1 [identifying information 

2 redacted], in 1992, indicates this rapid gross 

3 alpha determination was used through 1977, and 

4 the bioassay supervisor indicates that anion 

5 exchange was implemented earlier than this. 

6 MESH indicates a bioassay type of gross alpha 

7 or total alpha up through 1970, and we know 

8 the procedure was in place in the mid-'66 and 

9 mid-'67 and started.

10 And with the anion exchange, there 

11 is now a gap of radionuclides other than 

12 plutonium and specific radionuclides. At this 

13 point, the bioassay is radionuclide-specific, 

14 and other alpha emitters were not covered. It 

15 kind of gets back to the point earlier.

16 NIOSH has made two assumptions 

17 with respect to the rapid gross alpha. First, 

18 for the purpose of monitoring other alpha 

19 emitters, the bioassay represents a gross 

20 outflow result. Two, for the high-fired 

21 plutonium-238 modeling, the same bioassay 

22 represents plutonium-238 results. It is not 
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1 clear how the use of these two different 

2 guiding assumptions on NIOSH's part can be 

3 rationalized.

4 The next point, dealing --

5 MEMBER ZIEMER: Could I interrupt 

6 just a minute?

7 DR. BISTLINE: Yes.

8 MEMBER ZIEMER: Just to help us 

9 out, can you kind of tell us where you are in 

10 either the tables or the NIOSH paper, so I can 

11 track?

12 MS. ROBERTSON-DEMERS: We're 

13 working off our own list.

14 MS. JESSEN: Yes, I think it's 

15 comment 1-3.

16 DR. ULSH: Actually, I was going 

17 to cover that in my response, Paul, if you can 

18 wait that long.

19 MEMBER ZIEMER: Oh, okay.

20 CHAIR BEACH: Well, before you 

21 start again, let's break this down into the 

22 issues, too, and we will just have you 
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1 respond.

2 DR. BISTLINE: Okay.

3 CHAIR BEACH: So, the first one 

4 with the gross alpha.

5 DR. BISTLINE: Okay.

6 CHAIR BEACH: But go ahead.

7 DR. BISTLINE: Go ahead? Well, 

8 that completes the gross alpha, I think, that 

9 I have.

10 CHAIR BEACH: I think, that way, 

11 we all won't get lost in that --

12 DR. BISTLINE: Yes, that's a good 

13 idea.

14 CHAIR BEACH: -- if that's okay.

15 DR. BISTLINE: I think that is a 

16 good idea.

17 DR. ULSH: Okay. So you want to 

18 start with gross alpha?

19 DR. BISTLINE: Yes.

20 DR. ULSH: That was responded to 

21 by NIOSH in Response 1-3. I want to quote a 

22 paper that was written, of his own accord, by 
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1 Warren Sheehan recently. It is in the SRDB. 

2 And here's what it says:

3 Mound's primary need was detecting 

4 plutonium uptake, although there were other 

5 radioactive materials being handled in small 

6 quantities. The adopted procedure was, in 

7 fact, a gross alpha method. This was 

8 considered an asset in meeting Mound's needs.

9 Mound was aware that other 

10 radionuclides, such as thorium and 

11 protactinium, also carried through in this 

12 method. As such, it was a catch-all for the 

13 many minor projects going on in Mound in the 

14 late fifties and early sixties.

15 I would ask you to remember that

16 time frame.

17 Mound's position was that training 

18 laboratory technicians to run one non-specific 

19 procedure was preferable to having a host of 

20 procedures applying various chemical 

21 separations. This practice -- and I emphasize 

22 this -- This practice also reduced the chance 
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1 of using the wrong procedure for a particular 

2 individual's analysis.

3 Individual employee results were 

4 associated with employee work assignments and 

5 recorded into the records accordingly. 

6 Specific chemistry could always be applied 

7 when the situation called for it.

8 Plutonium was, by far, the most 

9 potentially harmful isotope at Mound. 

10 Therefore, if an analysis result was 

11 erroneously assigned as plutonium, results 

12 would have been overstated favoring the 

13 employee.

14 Now that was written -- I was 

15 surprised when Warren sent this in. He was 

16 the guy in the bioassay section doing this.

17 MS. ROBERTSON-DEMERS: May I say 

18 something?

19 DR. ULSH: Yes.

20 MS. ROBERTSON-DEMERS: I believe 

21 that what we have said is that the rapid alpha 

22 technique does bring down the alpha emitters.
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1 DR. ULSH: Yes.

2 MS. ROBERTSON-DEMERS: Okay. 

3 Except for radium. Where I was able to obtain 

4 that information was from the same person who 

5 wrote that document.

6 We did a subsequent interview with 

7 him asking very detailed questions about the 

8 radiochemistry procedures, to the point of, 

9 what radionuclides are you bringing down when 

10 you add the cerium --

11 DR. ULSH: Kathy, sorry. Have you 

12 made those notes available? Do we have those 

13 notes?

14 MS. ROBERTSON-DEMERS: This has

15 just been done. Okay? So, yes, we can make 

16 them available.

17 Our problem is not so much the 

18 rapid gross alpha, but when you implement the 

19 anion exchange, you have a column. By 

20 adjusting the pH, you can move various 

21 radionuclides off that column. Okay?

22 What this individual was telling 
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1 us is, as a routine practice, they pulled off 

2 plutonium only, even though they could, by the 

3 procedure, if they wanted to, pull out thorium 

4 or uranium or americium. But that was very 

5 time-consuming. So they pulled plutonium. 

6 Okay?

7 DR. ULSH: Okay.

8 MS. ROBERTSON-DEMERS: Only.

9 DR. ULSH: Okay.

10 MS. ROBERTSON-DEMERS: Unless the 

11 field HP came to them and said, Joe Smith is 

12 working on a thorium project. You need to 

13 pull off the thorium also. Okay?

14 DR. ULSH: Okay.

15 DR. NETON: That seems counter to 

16 what Brant just read.

17 DR. ULSH: No, it doesn't. I can 

18 explain that.

19 DR. NETON: Oh, okay. I'm sorry.

20 DR. ULSH: But I don't want to 

21 interrupt. Go ahead.

22 DR. NETON: Sorry about that.
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1 MS. ROBERTSON-DEMERS: I will make 

2 this information available to you. Okay? 

3 This is what I have been told, and it is not 

4 counter to what he read because, if their 

5 primary concern was plutonium, they would only 

6 elute the plutonium.

7 DR. NETON: That's not the way I 

8 understood that to be.

9 DR. ULSH: Okay. Shall I respond? 

10 Are you done? I mean I don't want to cut you 

11 off.

12 MS. ROBERTSON-DEMERS: Right.

13 DR. ULSH: Okay. Was there 

14 someone else on the line that wanted to say 

15 something? I thought I heard someone.

16 MR. SHEEHAN: Yes, this is Warren.

17 DR. ULSH: Hello, Warren.

18 MR. SHEEHAN: Brant? Is this 

19 Brant? Hello, Brant.

20 DR. ULSH: Yes, yes. Hello, 

21 Warren. Go ahead.

22 MR. SHEEHAN: Okay, I want to say 
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1 something about not pulling the radium down. 

2 By the time that we dropped that step of the 

3 procedure, the radium was no more concern. 

4 This was like '59-60. So I don't see where 

5 that's a problem, period.

6 That was brought up, was it not, 

7 earlier?

8 DR. ULSH: Yes, it was.

9 MR. SHEEHAN: No, I don't see that 

10 as being -- in other words, the last of the 

11 radium samples were run probably in the '59-60 

12 time frame. Beyond that point in time, the 

13 cave was already old history, and there was no 

14 reason to be offering surveillance there.

15 Now the other issue about the 

16 column and the manipulation of the column, I 

17 don't frankly remember what year we started 

18 using the column, but, again, I think this is 

19 beyond the period when we had all these little 

20 small ionium, protactiniums, whatever. 

21 Programs were already history by this time.

22 When we went to the column, then 
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1 we were primarily -- we really had only one 

2 concern, and that was plutonium. I don't know 

3 if this clears that up or not.

4 DR. ULSH: Let me get something 

5 clear in my head. When you say, "the column," 

6 are you talking the anion exchange procedure 

7 or is that a separate issue?

8 MR. SHEEHAN: No, to add the 

9 column was just an adjunct that you could 

10 insert into the normal procedure, the gross 

11 alpha procedure. Instead of mounding the 

12 cerium fluoride, you actually dissolved it and 

13 put it through a column.

14 So the chemistry up to that point 

15 would be identical whether you went through 

16 the column or whether you didn't. So, when 

17 you went through the column, now you could 

18 perform specific chemistry, as the lady 

19 pointed out, you know, by altering the 

20 normality, the acid to which you did the 

21 elution off the column.

22 So she's perfectly right. If you 
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1 went on to the column and eluted only with 8 

2 normal nitric acid, you probably are only 

3 going to see the plutonium. You're not going 

4 to see some of those other isotopes, but we 

5 weren't looking for them at that point.

6 DR. ULSH: And that's why I asked 

7 you, when I read that statement from Warren's 

8 document, to remember the time frame. Because 

9 the programs that you are talking about, off 

10 the top of my head, the reactor waste program, 

11 the uranium program, the ionium program, those 

12 were all concluded in the fifties, at latest 

13 the early sixties.

14 MR. SHEEHAN: Right. Yes. 

15 Actually, we were still doing gross alpha 

16 primarily clear up into probably '63. I don't 

17 know. These dates kind of elude me right now, 

18 but maybe we should have maybe kept a better 

19 count of that, but we didn't. We didn't go 

20 into column chemistry until we had passed that 

21 phase. Let's put it that way.

22 DR. ULSH: I would like to read to 
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1 you another comment. Anion exchange was used 

2 in 1966 and 1967.

3 SC&A made this comment in our 

4 response. It is designated as Comment 1-8. 

5 And our response says, SC&A seems to be 

6 implying that, during the '66-67, that the 

7 Mound bioassay program lacked the capability 

8 to detect alpha emitters other than plutonium 

9 or uranium because the anion exchange 

10 procedure was selected for these two 

11 radionuclides, the fundamental mistake being 

12 made is SC&A's assumption that only the anion 

13 exchange procedure was used during this time 

14 frame. This is inaccurate.

15 Though the anion exchange 

16 procedure was conducted for most of the work 

17 in this time frame, when the primary exposure 

18 was to plutonium, in fact, the gross alpha 

19 procedure was conducted during this time as 

20 well.

21 [identifying information 

22 redacted], 1992, page 336, reports that, on 
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1 February 11th, 1966, a memo was issued -- and 

2 this is a quote -- urine results would be 

3 reported as plutonium or uranium since they 

4 were then using anion exchange separation.

5 Here's the important part, It is 

6 to be noted, however, that for certain work 

7 areas they continued to report a small number 

8 of gross alpha as well as a few radium and 

9 thorium extractions, they were not just doing 

10 anion exchange.

11 As you would expect, I mean it's 

12 logical, if there was potential exposure to 

13 other radionuclides, they used the appropriate 

14 bioassay method.

15 MS. ROBERTSON-DEMERS: Can I say 

16 something about your quote?

17 DR. ULSH: Sure.

18 MS. ROBERTSON-DEMERS: That is a 

19 quote from the [identifying information 

20 redacted] document.

21 DR. ULSH: Right.

22 MS. ROBERTSON-DEMERS: And I 
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1 actually went back to the memo, and I would 

2 like to read the quote from the memo.

3 Starting with this report, all 24-

4 hour urinalysis results are being reported as 

5 plutonium and uranium, as we are now using 

6 anion exchange separation, which is selective.

7 DR. ULSH: I believe that's what I 

8 said.

9 MS. ROBERTSON-DEMERS: That is not 

10 exactly what you said.

11 MR. STEWART: That was 

12 [identifying information redacted] memo, 

13 Kathy?

14 MS. ROBERTSON-DEMERS: That was 

15 the radiochemist.

16 DR. ULSH: Right. We are not 

17 denying the anion exchange procedure is 

18 selective for plutonium. What we are saying 

19 is, in situations where there was a potential 

20 exposure to other radionuclides, and they were 

21 very far and few between at this point in 

22 time, they had the capability to do the non-
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1 specific gross alpha, and, in fact, they did.

2 MS. ROBERTSON-DEMERS: We are 

3 not -- okay. When I looked at the plutonium 

4 bioassay data in MESH, okay, and I looked at 

5 the type, okay, I can see the radionuclides 

6 that they did the analysis for. Okay?

7 And through 1970, you will see 

8 gross alpha or total alpha. After that point, 

9 they start listing either thorium or 

10 plutonium-238, or whatever they eluted from 

11 the column.

12 I realize these procedures were 

13 available, but that does not necessarily mean 

14 that there is a bioassay result available, 

15 that they actually pulled off all these items.

16 MR. KATZ: Warren, this may be 

17 your phone, actually. I think it is a cell 

18 phone, but we are hearing cut-ins from the 

19 phone, and I think it is because someone is 

20 not on mute. If you could mute your phone? 

21 Use *6 if you don't have a mute button. 

22 Someone on the phone, again, whoever doesn't 
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1 have their phone on mute, can you try muting 

2 your phone? Use *6, if you don't have a mute 

3 button.

4 Thank you.

5 MS. ROBERTSON-DEMERS: The 

6 question comes down to, were the radionuclides 

7 present when anion exchange was being used, 

8 and was bioassay sampling actually collected? 

9 And was the field effectively communicating 

10 with the bioassay group when they needed to be 

11 eluting other radionuclides or performing 

12 special analysis?

13 Then, also, how are you going to 

14 differentiate a result that is labeled as 

15 plutonium-238? How are you going to 

16 differentiate whether that was done by anion 

17 exchange or rapid gross alpha?

18 DR. ULSH: I am probably not 

19 because what it says here is that they 

20 recorded the results as appropriate. So, for 

21 instance, if they did this procedure and did 

22 the specific chemistry to pull off uranium, it 
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1 was recorded as uranium. If it was recorded 

2 as gross alpha, we will assume that it was 

3 plutonium-238, unless we have indications 

4 otherwise, because, by and large, the work 

5 that they were doing at Mound was 

6 plutonium-238 at that time.

7 Again, during the time they had 

8 anion exchange, '66 to '67, specific to 

9 plutonium, they also had gross alpha. In 

10 fact, they did do a small number of gross 

11 alpha commensurate with the size of the 

12 programs involving these other radionuclides.

13 Yes, of course, we have to assume 

14 that the field communicated with the bioassay 

15 laboratory. We have no evidence to suggest 

16 that they didn't. In fact, to the contrary, 

17 that's not what [identifying information 

18 redacted] indicates and it's not what -- well, 

19 I don't want to speak for Warren. Warren can 

20 speak for himself.

21 But I just don't see what the SEC 

22 issue is here. They had the bioassay 
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1 capabilities to detect the elements that they 

2 were working with.

3 MS. ROBERTSON-DEMERS: Bioassay 

4 capabilities do not equate to actually 

5 collecting samples.

6 DR. ULSH: So you're saying that 

7 there were situations where they should have 

8 collected samples and they didn't?

9 MS. ROBERTSON-DEMERS: Yes.

10 DR. ULSH: Okay. Let's talk about 

11 those. Give me some examples.

12 MS. ROBERTSON-DEMERS: I've given 

13 you an entire table where these things were 

14 noted as being handled in the Road Map, and 

15 there's no coverage of bioassay.

16 DR. ULSH: Okay. So we're talking 

17 about the Road Map now. Again, as we 

18 discussed earlier, the Road Map lists any 

19 element, any radionuclide that could have 

20 possibly been in a particular room, not that 

21 there was a confirmed presence of it, but just 

22 that it was possible.
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1 And again, the piece that you are 

2 not considering is the exposure potential. If 

3 I walk through -- I'll use the same example 

4 again -- if I walk through a room, if I even 

5 stored in a room sealed sources, that does not 

6 equate to an exposure potential and it does 

7 not equate to a need to do bioassay.

8 If the Road Map is your basis, you 

9 are misinterpreting the Road Map.

10 MS. ROBERTSON-DEMERS: Well, then, 

11 in that case, the Road Map is not valid 

12 because you haven't fine tuned it to such a 

13 level that we know when the radionuclides were 

14 actually at Mound.

15 DR. ULSH: What radionuclides do 

16 you want to talk about, Kathy? We'll go 

17 through them. I can tell you when the uranium 

18 program was. I can tell you when the ionium 

19 program was, protactinium.

20 MS. ROBERTSON-DEMERS: Well, let's 

21 just throw out actinium.

22 DR. ULSH: Obviously, actinium was 
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1 present at Mound from 1949 to '59. That was 

2 the basis of the SEC. They had a small where 

3 they opened an ampule of it in the SW new cave 

4 in the early 1960s, '64 I think.

5 After that, as far as I am aware, 

6 the only actinium activities that presented an 

7 exposure potential, even a theoretical 

8 exposure potential, would have been residual 

9 contamination. Of course, the most notable of 

10 that is during D&D that resulted in the Price11 Anderson Act violations, which we have 

12 discussed at length in other situations.

13 What else do you want to talk 

14 about?

15 MS. ROBERTSON-DEMERS: Well, I'm 

16 going to give you some data that you probably 

17 ought to consult --

18 DR. ULSH: Okay.

19 MS. ROBERTSON-DEMERS: -- about 

20 varied actinium drawings in counting soil in 

21 an outside area in the 1990s.

22 DR. ULSH: Okay.
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1 MS. ROBERTSON-DEMERS: There was 

2 actinium, for example, in the soil, and that 

3 would indicate to me that it was not a sealed 

4 source.

5 DR. ULSH: Well, I'm not saying it 

6 was a sealed source.

7 MS. ROBERTSON-DEMERS: What I'm 

8 saying is there's a lot of contamination that 

9 has been identified that indicates a lot of 

10 what you have said are encapsulated sources 

11 were, indeed, not encapsulated.

12 DR. ULSH: I used that as a 

13 specific example. I'm not saying -- I did, I 

14 believe, say residual contamination.

15 MS. ROBERTSON-DEMERS: And I guess 

16 we need to get to the bottom line on the Road 

17 Map because that Road Map answers several 

18 matrix items, and if it is, indeed, just kind 

19 of a pie in the sky, and not really giving us 

20 the information on when and where items were 

21 handled, then we don't have an answer to 

22 several matrix items.
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1 DR. ULSH: No, I never said that 

2 it was pie in the sky. I never said that it 

3 was -- I forget what other term you used.

4 What I said was it was built off

5 of the [identifying information redacted]

6 document. So it is a visual representation of 

7 what you find in the [identifying information 

8 redacted] document. That's all it is. It is 

9 not meant to be a categorical list of every 

10 exposure situation.

11 You can imagine that Mound had an 

12 operating history from 1940ish up through 

13 ultimate D&D. You can't capture that in one 

14 particular document.

15 If there are particular situations 

16 that you are concerned about, we will be happy 

17 to discuss those. But in terms of -- I can't 

18 talk about generalities here.

19 MS. ROBERTSON-DEMERS: Well, if I 

20 go to the Road Map, and I look up, you know, 

21 when actinium was handled, it gives me a very 

22 long period of time. Okay? It stems from the 
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1 forties through closure. If you were to take 

2 it was handled at some building at some 

3 location --

4 DR. ULSH: No, it was present at 

5 the site potentially in -- the Road Map is 

6 meant to indicate the possible universe of 

7 places where, if you were going in to do D&D, 

8 you want to be conservative. You want to take 

9 samples, workplace characterization for even 

10 the potential elements that might have been 

11 there. It's not to say that they were. It is 

12 just this is kind of, well, it's a Road Map 

13 for people who are doing D&D to go in and say, 

14 okay, what kind of a bioassay program should I 

15 establish here? What should I look for?

16 It doesn't mean that it was there. 

17 It just means that that is what you should 

18 probably look for during D&D. That was the 

19 purpose of the [identifying information 

20 redacted] document, and then, consequently, 

21 the Road Map.

22 MS. ROBERTSON-DEMERS: So it 
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1 doesn't really answer those matrix items 

2 because you haven't adequately characterized 

3 when radionuclides were present.

4 DR. ULSH: No, I just told you --

5 sure we have when radionuclides were 

6 potentially present. Now, if you're 

7 interested in particular ones, of course, I 

8 would refer you, start with the Road Map as to 

9 what's possible. If you're interested in 

10 actinium, go look at the reports on the 

11 radium, actinium, thorium program primarily. 

12 Whatever the guy -- I'm not going to say his 

13 name for Privacy Act reasons -- interview him, 

14 which we did on the actinium issue. The 

15 thorium program, the same thing. You know, 

16 the re-drumming program, we talked to the 

17 people involved in that.

18 So, no, I wouldn't say you stop 

19 with the Road Map. That is not a shortcut to 

20 doing any more research.

21 MS. ROBERTSON-DEMERS: How is the 

22 dose reconstruction supposed to use this?
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1 DR. ULSH: To use what?

2 MS. ROBERTSON-DEMERS: The Road 

3 Map.

4 DR. ULSH: The Road Map was not 

5 constructed for dose reconstructors. It was 

6 constructed for this Working Group to evaluate 

7 the SEC petition. We never presented the Road 

8 Map as an addition to the TBD or an addition 

9 to instructions for dose reconstructors.

10 The way that a dose reconstructor 

11 would evaluate for a particular claimant what 

12 internal doses do I need to reconstruct is the 

13 same way you would do it for the 30,000 other 

14 cases that we have in the complex. You would 

15 look, first of all, at their bioassay record. 

16 You would look at their job history to see 

17 what radionuclides they might have been 

18 exposed to. You would look at their CATI, 

19 where we specifically asked, "What 

20 radionuclides were you exposed to?" And they 

21 can have the opportunity to tell us that.

22 So those are the kinds of things 
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1 that you would do, similar to any other dose 

2 reconstruction. Yes, you might even pick up 

3 the Road Map and have a look, but I wouldn't 

4 say that that is an essential dose 

5 reconstruction document. That's not what it 

6 was designed for.

7 MS. ROBERTSON-DEMERS: In that 

8 case, I would say that you need to go back and 

9 fine-tune and tell us when those radionuclides 

10 were really there, so we can determine whether 

11 there is a bioassay method applicable to 

12 those.

13 DR. ULSH: Well, that is certainly 

14 a topic that the Working Group can discuss, 

15 and if you want to task us to do that, at this 

16 point in time we could do it. Keep in mind, 

17 we have discussed specific radionuclides over 

18 the course of this investigation for the past 

19 two years. If there are particular ones you 

20 are concerned about, ask us. We will go look.

21 DR. NETON: Yes, let's talk about 

22 actinium maybe, because that seems to be what 
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1 the current issue here is. I mean it seems to 

2 me that Brant has put forth the idea that 

3 actinium production in any types of quantities 

4 ended in the late 1950s, early sixties, 

5 something like that.

6 DR. ULSH: Well, the old cave 

7 operations ended in 1959.

8 DR. NETON: Okay. So the cave was 

9 D&Ded, and then, as far as you know, no 

10 subsequent research activities occurred with 

11 actinium, except for maybe this couple of 

12 little source --

13 DR. ULSH: Yes, they did some 

14 calorimetry, but nothing that would present --

15 DR. NETON: But, in the interim, 

16 somehow all that material got buried on site, 

17 and Kathy is talking about this actinium found 

18 in drums in the 1990s. So, presumably, this 

19 material was on site, but I guess the question 

20 I have is, what is the potential for exposure 

21 to these drums that were there in contaminated 

22 soil discovered in the 1990s? Were the 
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1 workers out there romping around in these 

2 burial grounds, digging them up? So is there 

3 any potential for exposure?

4 MS. ROBERTSON-DEMERS: In that 

5 particular case, when we identified actinium 

6 in the soil, it was remediation --

7 DR. NETON: That is what I am

8 saying.

9 MS. ROBERTSON-DEMERS: There was a 

10 remediation program.

11 DR. NETON: So there is a big gap 

12 here between the 1960s, when everything was 

13 dug up and buried, and you're speculating 

14 maybe that in those 30 interim years something 

15 occurred to expose these workers anew to this 

16 actinium source. I'm missing --

17 MS. ROBERTSON-DEMERS: Let me do 

18 this in a little bit different way. 

19 Actinium-227 bioassay specific is available 

20 through determination by radium-223 for 53 

21 through 59. There's actinium in sample in 64, 

22 in 89, in 94 through 2005. Okay?
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1 I'm going to turn the question 

2 around on you. Okay? Demonstrate to me that 

3 actinium was not present in the years where I 

4 don't have any bioassay.

5 DR. NETON: Well, wait a minute, 

6 Kathy.

7 DR. ULSH: Well, go ahead.

8 DR. NETON: No, go ahead.

9 DR. ULSH: The time frame was 40 

10 to 59, 64 --

11 MS. ROBERTSON-DEMERS: No.

12 DR. ULSH: I'm sorry.

13 MS. ROBERTSON-DEMERS: The 

14 bioassay data, there is data available for 53 

15 through 59, 64, 89, and 94 through 05.

16 DR. ULSH: Okay, 53 through --

17 MS. ROBERTSON-DEMERS: Okay. Now 

18 let me add one other thing. Okay? Your own 

19 Road Map says it was there from 1948 to 

20 present.

21 DR. ULSH: Okay. Again, first of 

22 all, let me start with your first question. 
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1 53 to 59, that's the basis of the SEC. Sixty2 four, that's I think probably the operation in 

3 the SW new cave. If you want the name of the 

4 guy, I can give it to you under the right 

5 circumstances. Eighty-nine, I'm not sure. I 

6 don't know. I know that they were starting 

7 D&D then. Ninety-four through 05, that gets 

8 into the heavy-duty site D&D. That's why you 

9 see actinium bioassay there.

10 Yes, the Road Map says actinium 

11 was present on site from 48 to present. It 

12 sounds about right to me, but that does not 

13 indicate an exposure potential.

14 Let me give you an example. R 

15 corridor 5, which I assume -- this is an 

16 assumption on my part -- there was specific, 

17 small, discrete spots of actinium 

18 contamination related to the old cave 

19 operation. Those were identified. Those were 

20 painted over.

21 Fast forward to 1994, and they go 

22 in and start D&Ding. I don't know if they 
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1 demolished that. I think there was a 

2 demolition project. Certainly, they were 

3 doing sandblasting.

4 Now you re-expose that actinium 

5 because you blast off that paint that was put 

6 on. There's an exposure potential again.

7 In the intervening years, no. 

8 That's why you do the D&D. That's why you 

9 immobilize it.

10 Was it present? Yes. That does 

11 not indicate an exposure potential.

12 MS. ROBERTSON-DEMERS: All I'm 

13 asking you to do is to tell me there was no 

14 actinium present from 60 to 63, from 65 to 

15 88 --

16 DR. NETON: Kathy, I don't think 

17 anybody is saying there was no actinium 

18 present.

19 DR. ULSH: I'm not saying it.

20 DR. NETON: I think what people 

21 are saying is there was no exposure potential. 

22 There were no ongoing activities to generate 
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1 airborne or exposure potential activities.

2 MS. ROBERTSON-DEMERS: But I 

3 cannot determine that from the Road Map.

4 DR. NETON: Well, you have access 

5 to the same documents we have, Kathy. We have 

6 not identified any operations or activities 

7 that would generate a potential for actinium.

8 You are free to look at those as 

9 well and see if we have missed something. But 

10 you have heard Brant say that we know of none. 

11 So I don't know what else we could provide 

12 you. I really don't.

13 If you want us to put it in 

14 writing --

15 MS. ROBERTSON-DEMERS: It seems to 

16 me that --

17 DR. NETON: -- we have identified 

18 no actinium --

19 MS. ROBERTSON-DEMERS: It seems to 

20 me that you've got a document, [identifying 

21 information redacted], that says dates are 

22 present. Yet --
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1 DR. NETON: Present versus 

2 exposure is a different story, Kathy.

3 DR. ULSH: It doesn't even say 

4 present. It says potentially here in a 

5 particular location.

6 MS. ROBERTSON-DEMERS: Okay. Now 

7 prove to me that it isn't.

8 DR. NETON: I think we're done 

9 talking. I think our position --

10 MR. HINNEFELD: I don't know how 

11 we would ever prove a negative. How would we 

12 prove something is not somewhere?

13 MS. ROBERTSON-DEMERS: You revise 

14 your Road Map to be more accurate.

15 MEMBER ZIEMER: Well, the Road Map 

16 is the [identifying information redacted]

17 document summarized. You can't revise what 

18 the [identifying information redacted]

19 document -- I don't follow the logic at all.

20 MS. ROBERTSON-DEMERS: What I'm 

21 saying is, if actinium wasn't really there 

22 from 1948 to present --
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1 MEMBER ZIEMER: Nobody has said 

2 that.

3 MS. ROBERTSON-DEMERS: The 

4 [identifying information redacted] document 

5 says that.

6 MEMBER ZIEMER: It says it wasn't 

7 there?

8 MS. ROBERTSON-DEMERS: It was.

9 MEMBER ZIEMER: Yes.

10 MS. ROBERTSON-DEMERS: It was.

11 MEMBER ZIEMER: Nobody is saying 

12 that that's wrong.

13 MS. ROBERTSON-DEMERS: Okay. No, 

14 what I'm saying --

15 MEMBER ZIEMER: I don't understand 

16 the argument, even, that you're making. It 

17 doesn't --

18 MS. ROBERTSON-DEMERS: What I'm 

19 saying is, what the [identifying information 

20 redacted] document says, that it was there 

21 from 49 to present, and it was not available 

22 in the form where individuals could have an 
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1 uptake, then we need to know during which 

2 specific years. Because that's what we're 

3 hearing, there's only specific years from 48 

4 to present that it was available for uptake.

5 MEMBER ZIEMER: That's what we 

6 just said.

7 MR. HINNEFELD: What you are 

8 asking for is another document like the Road 

9 Map, but rather than just show presence, show 

10 the exposure potential? During what time 

11 there was an exposure potential?

12 MR. FITZGERALD: Can I jump in 

13 just a little bit?

14 I think let's just go back and I 

15 think Brant summarized where this all came 

16 from. I think in the very beginning we looked 

17 at the Site Profile and brought some issues 

18 forward to the ER review, which spoke to 

19 whether or not there was bioassay capability 

20 for, I think for other sites we called it 

21 other nuclides, but, you know, these very 

22 specific nuclides, and we identified and there 
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1 were probably five or six issues where we 

2 asked the specific question, and that did get 

3 discussed, I think, on the table.

4 Because of this sort of collection 

5 of various and sundry nuclides, I think the 

6 response was to roll these up into a Road Map 

7 based on the [identifying information 

8 redacted] report, just to have an easier way 

9 to look at all these nuclides.

10 What we are, I think, establishing 

11 not the first time, but maybe establishing in 

12 a more firm way is that the Road Map just 

13 reflects the [identifying information 

14 redacted] report, and the [identifying 

15 information redacted] report just reflects the 

16 potential presence of these nuclides, but it 

17 doesn't really speak to maybe the original 

18 question that we had for some of these 

19 nuclides, whether or not both exposure 

20 potential existed and a bioassay capability 

21 was available.

22 So I think there is a gap there. 
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1 I think we are maybe talking past each other a 

2 little bit on this one.

3 But, in terms of the exchanges of 

4 White Papers, I think we are sort of down to 

5 the point, okay, the Road Map helps, but it 

6 didn't necessarily add any new information 

7 that we couldn't get from the [identifying 

8 information redacted] report. We still have 

9 some questions on specific nuclides, you know, 

10 issues. You know, we did lay these out.

11 I think what we could do, just to 

12 bring this to a close, is just identify what 

13 specific nuclides remain in terms of whether 

14 or not there was an exposure potential, then, 

15 in fact, whether there was a bioassay 

16 capability at the site in that time frame for 

17 that exposure.

18 I think we could nail that down a 

19 little better, but get away from deciding 

20 whether or not the Road Map does the trick or 

21 not, because the Road Map really is a mapping 

22 of the [identifying information redacted]
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1 report. So we are arguing over something that 

2 won't get us where we need to go anyway.

3 So what we can do that would be 

4 helpful, and if it is agreeable to the Work 

5 Group, is just simply -- it sounds like we 

6 started doing it for actinium, but just kind 

7 of nail down some specific examples. Go back 

8 to the nuclides that we identified in the 

9 original matrix and pull some of those and 

10 say, you know, can we, for those time periods 

11 where we do have an identified presence, can 

12 we establish whether, 1) exposure potential 

13 existed. And we can look at the same 

14 documents as Jim has suggested. And if, in 

15 fact, we can establish that exposure 

16 potential, then can we nail down whether the 

17 bioassay capability existed or not? And just 

18 kind of nail this thing down, rather than deal 

19 with it in a very broad sense.

20 DR. ULSH: And as you do that, 

21 Joe, I would refer you to our White Paper. 

22 Look at Attachment A, which starts on page 18, 
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1 and then look, also, at page 24, which is 

2 another table that talks about specific 

3 radionuclides that SC&A has raised a concern 

4 about.

5 MR. FITZGERALD: I'm sorry, what 

6 was the second one, Brant?

7 DR. ULSH: It's page 24. 

8 Unfortunately, it's not numbered.

9 MR. FITZGERALD: Okay. Do you 

10 have --

11 DR. ULSH: But, to give you a 

12 summary, I'll start with the second one first. 

13 It has three columns, radionuclides and era, 

14 summary of SC&A-identified issues -- that's 

15 our summary, by the way, I think -- and, also, 

16 our response, our NIOSH evaluation of these 

17 issues.

18 Some of the radionuclides listed 

19 are actinium-227, bismuth-210, cobalt, cesium, 

20 a number of others.

21 Stop me if you need me to. So 24 

22 there.
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1 Now, to go back to the first one, 

2 page 18, this list, this is called Attachment 

3 A. The first column is informal source term 

4 and title. It gives a description loosely of 

5 the program involved. The second column is 

6 the constituent radionuclides, and it lists 

7 the major radionuclides of concern.

8 So I agree the approach that you 

9 have suggested would be very helpful, so that 

10 we can talk specifically and not generally. 

11 But I would also say that we are pretty far a 

12 ways down the road here, taking in mind what's 

13 already been done. And if there are 

14 additional questions or remainder issues --

15 MR. FITZGERALD: Well, I think 

16 that's what I want to get to, rather than sort 

17 of keep this in a broad discussion, which we 

18 have had, but get down to specific examples 

19 and let those examples pretty much settle the 

20 question of whether to present gaps or 

21 questions that remain. But get it very 

22 specific, so that we are talking in 
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1 generalities now, if that's agreeable.

2 CHAIR BEACH: I am agreeable to 

3 that. It just takes us back to the matrix.

4 MR. FITZGERALD: Well, to some 

5 extent, but there has been a lot of work done 

6 since then. I don't think we're going back to 

7 the matrix --

8 CHAIR BEACH: Right, right.

9 MR. FITZGERALD: -- as a starting 

10 point. I agree with Brant, we just build on 

11 what we have done already and what NIOSH has 

12 presented, but getting a lot more specific and 

13 come up with specific examples to present.

14 So we will take that action and 

15 provide you those specifics, and then see 

16 where that settles.

17 DR. ULSH: And, hey, if you've got 

18 names of people, that would make it real easy, 

19 but I suspect you probably don't.

20 MEMBER ZIEMER: Well, whose action 

21 is this?

22 MR. FITZGERALD: Names of people, 
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1 I mean in terms of --

2 DR. ULSH: If you are concerned 

3 about a particular program or exposure 

4 incident --

5 MR. FITZGERALD: Oh, no, I think 

6 we've got to be as explicit as possible. If 

7 we can nail it down --

8 MR. CHEW: Brant, could I ask SC&A 

9 a question?

10 Joe, what would you consider 

11 evidence to you that that particular 

12 radionuclide in that particular area on the 

13 Road Map was an exposure potential or not an 

14 exposure potential?

15 MR. FITZGERALD: Well, I think I 

16 go back to Jim's comment that we have access 

17 to the same operational documentation that 

18 NIOSH does, plus interviews. I mean the same 

19 body of information. If we can select two or 

20 three areas where I think -- well, the first 

21 question is to reach some agreement there was 

22 an exposure potential. I mean, if we can't 
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1 get there, then discussing whether or not 

2 bioassay capability was available doesn't make 

3 any sense.

4 So we would present what we think 

5 is an argument that there was an exposure 

6 potential for that time period. Then, 

7 basically, ask, since we probably don't have 

8 that specific information, whether or not we 

9 can establish bioassay capability.

10 MEMBER ZIEMER: Well, I would like 

11 to ask why this isn't a NIOSH activity. NIOSH 

12 is stating that they believe they know the 

13 periods where there was exposure potential. 

14 They believe they have the information about 

15 when bioassay was done and what the particular 

16 projects were and the locations as well. Why 

17 isn't this just a table that they put together 

18 and then you say we agree or we don't?

19 I have my usual problem with 

20 having SC&A do it. In my mind, it is a task 

21 of the agency.

22 DR. NETON: Well, I think the 
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1 question is a little different, Paul. I think 

2 the question is, where we have bioassay data, 

3 I think SC&A would agree that, well, there was 

4 something going on and it was monitored. What 

5 they are saying is, how do you know something 

6 didn't happen -- something happened that 

7 wasn't monitored in those intervening years.

8 And we see no evidence of that. 

9 So it would be hard for us to put together a 

10 list and say we looked at the list and nothing 

11 happened.

12 MR. FITZGERALD: What I heard was 

13 sort of this, if you can show us or give us 

14 some indication of where that gap or that 

15 question is, then we could at least have that 

16 to go by.

17 DR. NETON: Well, but Kathy has 

18 clearly enumerated that. I mean she's posited 

19 these years where there was no bioassay, and 

20 she is suggesting show us. She is saying to 

21 us, show SC&A why there was no bioassay 

22 program. We're saying because we see no 
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1 evidence of any activity occurring.

2 MR. FITZGERALD: Right.

3 DR. NETON: So that's all we can 

4 say.

5 MR. FITZGERALD: Right. And I 

6 think what we are trying to supply is, okay, 

7 we owe you --

8 DR. NETON: Right.

9 MR. FITZGERALD: -- not only the 

10 nuclides, but we also need to give you some 

11 indication of why we think there's --

12 DR. NETON: That's the question.

13 DR. MAURO: I think the burden, if 

14 you folks have laid out a network of scenarios 

15 over time and bioassay programs, and there are 

16 windows of time where the judgment was made at 

17 that time that there was no need to look 

18 specifically at those radionuclides -- and 

19 obviously, in the words you read, that was the 

20 judgment.

21 What we just said is that, well, 

22 but there were these windows of time that 
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1 maybe there was something going on. I think 

2 that if we are going to make that statement, 

3 we have to show why we believe that might have 

4 happened.

5 I don't think we default to the 

6 assumption that, just because it was 

7 unsoluble, that automatically increases your 

8 exposure potential.

9 Now the only reason I say that is 

10 that, because there are other time periods 

11 where exposure potential was admitted to, 

12 engaged and dealt with. So it wasn't as if it 

13 was something that the administration of the 

14 program was blind to right up to the nineties.

15 So, I mean, I'm thinking about it 

16 as, clearly, you've made a case that the 

17 people in charge who were collecting the data 

18 were well aware that actinium was a problem 

19 when it was being handled, even up to the D&D 

20 operation, so I'm hearing. But there were 

21 time periods where some judgment, obviously, 

22 was made that it wasn't necessary to 
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1 explicitly look for that.

2 Now your position is, well, you 

3 trust that judgment, that --

4 DR. NETON: Well, not only do we 

5 trust that judgment, but we see no evidence --

6 DR. MAURO: Now we are saying 

7 that, and this is an interesting question now, 

8 if we are going to raise this as an issue, I 

9 guess we have to offer up some evidence that 

10 we think, wait a minute, we might have had a 

11 window where you missed something important.

12 I think that's my read of this, 

13 and this, certainly, -- ground rules --

14 MEMBER ZIEMER: Well, it seems to 

15 me it's got to be more than presence on the 

16 site.

17 DR. MAURO: And I would agree with 

18 you that it has to be more than presence on 

19 the site.

20 MEMBER ZIEMER: I thought the 

21 question was whether or not bioassay 

22 capabilities corresponded to the use periods 
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1 in question, that that was not --

2 MR. FITZGERALD: Well, I don't 

3 think you get to that issue until you answer 

4 the exposure --

5 MEMBER ZIEMER: Well, I thought 

6 that's what Kathy was asking, whether or 

7 not --

8 MS. ROBERTSON-DEMERS: The use 

9 periods, as I guess, not defined by 

10 [identifying information redacted], but 

11 defined by national use of the radionuclide on 

12 site.

13 MEMBER ZIEMER: Right. As I 

14 understand it, the Road Map isn't defining 

15 use. It is defining presence, pretty much.

16 DR. ULSH: Potential presence.

17 MEMBER ZIEMER: That is the reason 

18 I was asking whose job it is. If it is only 

19 an issue of whether or not there's a 

20 coincidence between bioassay capabilities and 

21 actual use periods, I think you have that 

22 information; what use periods you are 
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1 defining, you already have that. If you're 

2 asking, is there evidence of use outside of 

3 those values, that's a different question.

4 DR. MAURO: Yes, I would say, and 

5 I will defer to the Work Group in terms of 

6 interpretation of, how far does SC&A go when 

7 we present the case. Now, in my mind, if 

8 there's a window of time where there were no 

9 bioassays collected for a particular 

10 radionuclide, but there were before because 

11 they knew certain things were going on, and 

12 they were after because they knew certain 

13 things were going on, I would say, obviously, 

14 the program had the wherewithal to make those 

15 judgments.

16 Now, if we're going to come in and 

17 say there's a window of time where it wasn't 

18 collected, I think the onus is on us to show 

19 that there was a judgment made that was 

20 incorrect at that time.

21 MEMBER ZIEMER: Or, yes, you find 

22 that there is some --
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1 DR. MAURO: Yes.

2 MEMBER ZIEMER: -- work going on.

3 DR. MAURO: Yes, and as opposed to 

4 imposing that on NIOSH, it seems to me that we 

5 have to have affirmative evidence that there 

6 was something wrong that they didn't do it 

7 here.

8 I don't know whether or not the 

9 Work Group agrees with that or not, but, in my 

10 opinion, in this particular circumstance, if 

11 we are going to say there's a window of time 

12 where the material was present but there was 

13 no bioassay, but at the same time we know that 

14 there was the wherewithal to deal with the 

15 problem, then we have to say that, uh oh, I 

16 think there were certain things going on in 

17 this time period where the bioassay wasn't 

18 collected, and that's a problem. Obviously, 

19 we haven't done that.

20 MEMBER ZIEMER: Well, I just have 

21 two other comments. One is that I want to 

22 make sure that there is a match-up or that you 
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1 guys have provided for Kathy the match-up 

2 between what you say the existing programs 

3 are, I mean the active -- if SC&A needs that, 

4 it seems to me you could provide that pretty 

5 easily.

6 The other concern that I have is 

7 that, if you go on the path you are talking 

8 about, you may be in the position of trying to 

9 prove the negative, also. It may be an 

10 unending task to show, to say, well, I haven't 

11 found anything yet, but give me another five 

12 years and I'll find something.

13 (Laughter.)

14 No, I --

15 DR. MAURO: And I agree with you 

16 100 percent. When do you stop?

17 MEMBER ZIEMER: If there's some 

18 obvious regime or some obvious activity that 

19 jumps out, but, otherwise, you're searching 

20 for an unknown.

21 But I want to make sure that I 

22 understood whether you, Kathy, have what you 
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1 were asking for originally.

2 MS. ROBERTSON-DEMERS: I would 

3 propose that they take Attachment A and add

4 the years to it.

5 MEMBER ZIEMER: That would be 

6 helpful then, and see how that matches up with 

7 the bioassay. It seems to me that just 

8 integrating some data you already have, is 

9 that right?

10 MR. CHEW: John, I just want to 

11 make one other comment. I think it would be 

12 important to also see what you are going to 

13 define as exposure potential. Okay? I think 

14 that's important. Because if you are going 

15 and doing D&D, and it's only 100 d per m per 

16 hundred square centimeter, is that exposure 

17 potential?

18 DR. MAURO: It is certainly a 

19 reasonable question.

20 MR. CHEW: Good. Okay.

21 MR. STEWART: I just have one 

22 observation. It was mentioned earlier that we 
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1 should look in the record and find negative 

2 judgments for when bioassay was required. We 

3 don't see that in record. What we see is we 

4 decided we needed a bioassay for X. We need a 

5 bioassay for X. They don't say, we determined 

6 today again that we don't need the bioassay 

7 and for Y. We don't see those judgments on 

8 the record. So that is going to be difficult 

9 for us to base any decisions on.

10 Then, the other thing is, when we 

11 do see a problem with the bioassay, typically, 

12 in the record, what, in fact, happened is, 

13 [identifying information redacted] at one 

14 point said we didn't really have a program for 

15 actinium, radium, and thorium in the fifties, 

16 in the early fifties, until their procedure 

17 came out in 54, I believe.

18 So they owned up to that. So this 

19 is an example of how they have handled the 

20 negative judgments, but that's all we've got, 

21 as far as I know.

22 MEMBER CLAWSON: Well, I guess I 
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1 kind of need to have it cleared up, too, 

2 because my understanding of this [identifying 

3 information redacted] document was the Holy 

4 Grail of all. My understanding was that there 

5 was potential for that in these areas for all 

6 this time. And now I'm hearing that, no, it's 

7 only for this time.

8 My question, too, is, Brant, you 

9 have put that they had certain projects going 

10 on from this date to this date, and then they 

11 stopped like this. I don't really think that 

12 they would just throw everything into a barrel 

13 and clean it up and walk away.

14 I am kind of wondering how long it 

15 took them to get rid of the process, how long 

16 it took them to clean this up and get it out 

17 and where did they store it and what did they 

18 do with it? Because in my experience, we may 

19 have stopped a project six years ago, but in a 

20 lot of our cells it was still sitting there 

21 for years. We never cleaned it up until years 

22 down the road, but we were off the bioassay 
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1 programs.

2 DR. ULSH: Right.

3 MEMBER CLAWSON: But it was still 

4 there.

5 DR. ULSH: Okay.

6 MEMBER CLAWSON: I was really 

7 under the impression this [identifying 

8 information redacted] document was not -- I 

9 was under the impression that there was a 

10 potential for these.

11 DR. ULSH: Okay. I can maybe 

12 clarify that, Brad. The purpose of the

13 [identifying information redacted] document, I 

14 think it was written in 95-ish, give or take, 

15 and revised maybe after that. The purpose of 

16 it was, okay, we're now facing a large-scale 

17 D&D of the site.

18 MEMBER CLAWSON: Right.

19 DR. ULSH: Before I send workers 

20 into D&D, I want to know what potential 

21 nasties they might encounter while they are 

22 there. So you can imagine, if you were in 
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1 that position, you would take the position 

2 that, if there's any indication at all that 

3 actinium, for instance, might have been there, 

4 we're putting it on this table, so that they 

5 do the appropriate monitoring for it or, 

6 similarly, for thorium, uranium, plutonium, 

7 whatever.

8 So it's meant to be all-inclusive 

9 in terms of what might have potentially been 

10 there, enough that you would say, as a D&D 

11 manager, I had better be doing some monitoring 

12 for this. That was the purpose of the 

13 [identifying information redacted] document.

14 MEMBER CLAWSON: And I understand 

15 that now, but previously I did not understand 

16 that that's what this document was for. I 

17 thought this was going back in time and 

18 showing the potentials that were in these 

19 rooms for all these years.

20 DR. ULSH: Okay.

21 MEMBER CLAWSON: That's what I 

22 took as this document.
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1 But, also, the thing is that you 

2 cut off at 64, or whatever, that there was no 

3 more exposure. I hope that there's something 

4 there that can prove, yes, that operation may 

5 have stopped, but, again, I know from my 

6 experience that it takes years to take care of 

7 a lot of these problems.

8 DR. ULSH: Let me give you an 

9 example of exactly what you're talking about. 

10 The radium, actinium, thorium separations in 

11 the old cave were the basis for the SEC. That 

12 program operated, I think, 1954 or 1955. So 

13 you might ask, well, why, then, do we extend 

14 the SEC period up to 59.

15 MEMBER CLAWSON: We know why.

16 DR. ULSH: Well, it's because 

17 there were several iterations of trying to D&D 

18 the place. Starting in, I think, 57, they 

19 tried, went in and characterized afterwards, 

20 and decided this isn't clean enough. That 

21 effort extended all the way up to 1959, when 

22 they concreted in the whole place. Well, was 
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1 it done there? No. That's why we have a 

2 radon problem in the next 20 years.

3 MEMBER CLAWSON: Right.

4 DR. ULSH: Let me give you another 

5 example. The thorium refinery program, they 

6 had planned to do a thorium-232 refinery, and 

7 in anticipation of that, they received a large 

8 quantity of thorium-resilient oxides, among 

9 other material.

10 MEMBER CLAWSON: The K-65 stuff.

11 DR. ULSH: No, monazite, not K-65.

12 MEMBER CLAWSON: I see some 

13 K-65 --

14 DR. ULSH: That's a different one. 

15 That's different. The example I'm talking 

16 about is only thorium refinery.

17 Shortly after they planned to do 

18 that and received the material, they canceled 

19 the project. The thorium refinery, I think 

20 they did a couple of runs, but shut it down 

21 before it ever operated.

22 Now I'm left sitting here with 
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1 these drums of thorium-232. What am I going 

2 to do with it?

3 Well, they stored it onsite. It 

4 is the subject of numerous re-drumming because 

5 it was corrosive. That happened in the 

6 summertime, the summer months, because it was 

7 stored outside, and that's when you want to do 

8 it, when it is warm.

9 Again, a perfect example of 

10 presence onsite, but they were only doing

11 active operations in the summer months. It is 

12 an intermittent project.

13 Eventually, they dumped it into 

14 Building 21, which is located on the south 

15 boundary, one of the boundaries of the site. 

16 I think it's south. I might be wrong on that. 

17 Anyway, it is towards the unoccupied side of 

18 the site.

19 It sat in Building 21 up until 

20 1970-something, when they contracted with a 

21 company to come in, haul it away.

22 That is exactly the kind of 
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1 situation I think that you are talking about, 

2 and it makes it a good point that I think I'm 

3 trying to make. That is, yes, the material is 

4 present onsite, but that is not the end of the 

5 story. You have to consider what was done 

6 with it and when. Was it an intermittent 

7 operation? And what was the exposure 

8 potential during that time?

9 CHAIR BEACH: Can I jump in?

10 DR. ULSH: Sure.

11 CHAIR BEACH: Is it time for a 

12 break?

13 (Chorus of yeses.)

14 (Laughter.)

15 CHAIR BEACH: 11:35, does that 

16 work for everybody?

17 MR. KATZ: Okay. So I am just 

18 going to put the phone line on mute until 

19 11:35.

20 (Whereupon, the above-entitled 

21 matter went off the record at 11:18 a.m. and 

22 resumed at 11:36 a.m.)
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1 MR. KATZ: This is the Mound 

2 Working Group and we are reconvening after a 

3 short break.

4 CHAIR BEACH: We are still 

5 discussing the adequacy and completeness of 

6 data. I believe, Bob, you are ready for 

7 the --

8 DR. BISTLINE: Yes, let me key up 

9 one other issue. That is just to make a point 

10 of it, and that is the issue that we kind of 

11 slid over in the process here that dealt with 

12 the recovery in the gross alpha, that when 

13 they are bringing down all of this, eluting 

14 this down, the question that Mound bioassay 

15 personnel did not specifically evaluate 

16 whether there was a differential in recovery 

17 for particular actinides recovered with the 

18 gross alpha procedure, nor has NIOSH provided 

19 the differential recoveries of alpha emitters.

20 I think this is a serious 

21 question, because if you had an instance 

22 where, for instance, thorium-232 and 
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1 palladium-231 had only 10 percent recovery, it 

2 is going to make a big difference. If they 

3 are not coming down equally, you don't have an 

4 equilibrium situation. So this is a concern 

5 on the part of SC&A.

6 There is nothing that we have been 

7 able to find dealing with this issue, with the 

8 efficiency, whether there was equal

9 efficiency.

10 DR. NETON: Are you talking about 

11 the anion exchange column, Bob?

12 DR. BISTLINE: Yes, yes.

13 DR. NETON: When we did the 

14 stripping off --

15 DR. MAURO: No, no, no, the gross. 

16 The gross, right?

17 DR. BISTLINE: Oh, the gross, yes. 

18 This is on the gross.

19 DR. NETON: It is alpha with 

20 cerium precipitations?

21 DR. BISTLINE: Yes.

22 DR. ULSH: I would direct you to 
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1 SC&A Comment 1-7 in our Response. The comment 

2 was, it is important to validate the ER's 

3 assumption that the chemical recovery is 

4 equivalent for all alpha emitters in the 

5 generic gross alpha procedures.

6 DR. BISTLINE: Yes.

7 DR. ULSH: So our response, 

8 Response 1-7 says that, the ER makes no 

9 statement, the Evaluation Report makes no 

10 statement that the chemical recovery for all 

11 alpha emitters is equivalent. However, for 

12 the MLM1-003 procedure, radium recovery 

13 averaged 94.3 percent. The actinium/thorium 

14 fraction recovered an average of 96.3 percent. 

15 The reference for that is [identifying 

16 information redacted] and [identifying 

17 information redacted], 1954, pages 10 and 8, 

18 respectively.

19 Plutonium also carried through in 

20 the thorium fraction, as did protactinium. 

21 For this reason, Mound considered this a gross 

22 alpha procedure. The reference for that is 
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1 Sheehan, 2009.

2 MS. ROBERTSON-DEMERS: Excuse me, 

3 but the [identifying information redacted]

4 documents are a different procedure than the 

5 rapid gross alpha procedure for plutonium. 

6 They are relevant to the radium procedure, as 

7 I understand it, and were modified for 

8 plutonium.

9 DR. ULSH: Well, I believe we 

10 called it the MLM1-003 procedure. You're 

11 right, we are talking about MLM1-003, which is 

12 what they used for actinium, thorium, and 

13 radium.

14 So what we are saying here is I 

15 don't think the gross alpha was used 

16 necessarily for radium, actinium, and thorium. 

17 Just MLM1-003 is used for that.

18 Then, to finish the response, 

19 recoveries for plutonium bounds primary 

20 bioassay need in the late 1950s, according to 

21 Sheehan, 2009, when monitored and 

22 investigated, as documented in Sheehan, Woods, 
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1 and [identifying information redacted], 1963.

2 So we have at least addressed, 

3 prepared a response to SC&A on this issue. 

4 So, if the Working Group has further concerns, 

5 we would be happy to follow up, if you want to 

6 task us with a follow-up item, but that's our 

7 response that is on the table.

8 MS. ROBERTSON-DEMERS: I just want 

9 to make it clear that the procedure from 1954 

10 that you are talking about is not the same as 

11 the rapid gross alpha procedure for plutonium.

12 DR. ULSH: I understand, Kathy, 

13 and I'm not saying that MLM1-003, which is 

14 what is clearly referenced here, is the same 

15 as the rapid gross alpha procedure. What I'm 

16 saying is the recovery for the technique that 

17 was used for actinium, thorium was as 

18 specified here, and that's MLM1-003.

19 MS. ROBERTSON-DEMERS: And that's 

20 only applicable to the radium, actinium, and 

21 thorium era.

22 DR. ULSH: Well, if you use the 
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1 same technique in a different year and do it 

2 the same way --

3 MR. HINNEFELD: Can I ask kind of 

4 a process question here? What Brant has read 

5 from is something that we prepared and 

6 submitted to the Work Group some time ago.

7 DR. ULSH: November 2009.

8 MR. HINNEFELD: Okay. So what we 

9 are hearing today is that that response did 

10 not satisfy the question. That's what we're 

11 hearing today.

12 DR. ULSH: I don't know. I guess 

13 that's what I'm asking.

14 MR. HINNEFELD: Okay. Well, I'm 

15 just trying to sort out where we are.

16 DR. ULSH: Yes.

17 MR. HINNEFELD: But we have not 

18 yet seen a description of the deficiencies in 

19 our response. So wouldn't that be the next 

20 step in the process?

21 MR. FITZGERALD: Yes, this is a 

22 recent dialog, yes. It is a recent dialog. 
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1 There has not been an opportunity for 

2 exchange. I mean we're talking a little over 

3 a month. So this is real-time in a sense.

4 MR. HINNEFELD: I mean we can do 

5 that today, if you want, but it sounds to me 

6 like an additional response. I mean, if this 

7 response is not adequate, and as I understand 

8 it, there was a procedure called the gross 

9 alpha procedure --

10 MS. ROBERTSON-DEMERS: Actually, 

11 it was called the plutonium bioassay.

12 MR. HINNEFELD: Okay, it was 

13 called the plutonium bioassay.

14 MS. ROBERTSON-DEMERS: To confuse 

15 everybody.

16 MR. HINNEFELD: Okay. That 

17 doesn't help. But they considered it gross 

18 alpha because it brought down things in 

19 addition to plutonium.

20 MS. ROBERTSON-DEMERS: Right.

21 MR. HINNEFELD: It brought down 

22 everything but radium, is what I heard a while 
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1 ago. Is that right?

2 MS. ROBERTSON-DEMERS: Right.

3 MR. HINNEFELD: Okay. And there 

4 is a state of recovery for that procedure, and 

5 the comment here is that, well, this recovery 

6 was stated to be that, but they never really 

7 evaluated bringing down thorium or uranium or 

8 americium, or whatever the other alphas were 

9 that they were bringing down. So they didn't 

10 really evaluate that. So how do we really 

11 know recovery is 60 percent? And how do we 

12 know that that is a suitable -- in order to 

13 interpret this gross alpha result for non14 plutonium intake? So, essentially, that is 

15 the issue.

16 I don't know. I don't know if we 

17 need to research more or if we can answer that 

18 today or not.

19 MS. ROBERTSON-DEMERS: The 

20 recovery that they used was 90 percent.

21 MR. HINNEFELD: Okay.

22 MS. ROBERTSON-DEMERS: All we want 
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1 to know is that the thorium came down at 90 

2 percent, the uranium came down at 90 percent.

3 MR. HINNEFELD: Right. So, to the 

4 extent that a gross alpha analysis is used for 

5 non-plutonium, then there is this open 

6 question there of, is this 90 percent recovery 

7 really appropriate for these other 

8 radionuclides? That's the question. Okay.

9 So I think we understand the 

10 question. I don't know if we can talk about 

11 that today or not.

12 DR. ULSH: What radionuclides are 

13 you concerned about? I assume uranium is on 

14 that list.

15 MS. ROBERTSON-DEMERS: Uranium, 

16 thorium, americium, protactinium.

17 MR. FITZGERALD: Weren't these 

18 identified in the original White Paper?

19 DR. BISTLINE: Yes. Thorium, 

20 protactinium, uranium, plutonium, and other 

21 radionuclides.

22 DR. ULSH: I have got thorium, 
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1 uranium, protactinium. What am I missing? 

2 There were more of these --

3 DR. BISTLINE: Thorium, 

4 protactinium, uranium, plutonium --

5 MS. ROBERTSON-DEMERS: Yes, and 

6 there's a couple of others that he said came 

7 down, americium --

8 CHAIR BEACH: But they're in your 

9 White Paper.

10 MR. FITZGERALD: Those were 

11 identified in the White Paper that went over 

12 in April, it would have been.

13 DR. ULSH: Well, basically, what I 

14 did in our response document is that I went 

15 through piece by piece.

16 MR. FITZGERALD: That is what I'm 

17 just wondering. You know --

18 DR. ULSH: It may be in here, 

19 but --

20 MR. FITZGERALD: It may be in 

21 there. I don't have it. We can check.

22 DR. ULSH: Okay. How about this? 
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1 I've got thorium, uranium, protactinium, 

2 plutonium, and americium. If we're missing 

3 any, let us know. Is that reasonable?

4 MS. ROBERTSON-DEMERS: Well, and 

5 the other one that came up in the interviews, 

6 curium and we're not sure if that comes 

7 through or he wasn't sure it came through.

8 DR. ULSH: If it is agreeable, 

9 Josie, what I will do is go back and look at 

10 the references again and see if I can come up 

11 with numbers for recovery for these other 

12 radionuclides for the gross alpha technique, 

13 or I've also got to check to see whether 

14 thorium was actually, whether this was the 

15 technique used for it. I'm not sure. I can't 

16 say at the moment.

17 DR. NETON: But let me ask a 

18 question. I thought earlier I had heard that 

19 this gross alpha technique was used in 

20 general, but there was specific concern about 

21 some operation that would rely on some other 

22 process. Is that not correct?
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1 DR. ULSH: Well, the way it was, 

2 Jim, it was a 20-or-so-step procedure, and at 

3 different stages in those 20 steps -- maybe it 

4 was after; Don, correct me if I'm wrong -- but 

5 they did the same procedures up to a point, 

6 and then they would have a branch. Okay, if 

7 we're concerned about thorium, we're going to 

8 do this one elution. If we're concerned about 

9 something else, we will do this different 

10 elution. I think that's --

11 DR. NETON: But we're talking 

12 about the gross alpha, though. We didn't go 

13 further.

14 MS. ROBERTSON-DEMERS: The first 

15 20 steps.

16 DR. NETON: But the gross alpha 

17 would bring down all the gross alpha emitters. 

18 I mean, presumably, that's what they're 

19 saying. This is the sort of cerium 

20 precipitation is the way I understand it.

21 DR. ULSH: Right.

22 DR. NETON: And they would not go 
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1 any further with that unless they believe 

2 there to be some type of a potential exposure, 

3 unique exposure scenario, where they could go 

4 and isolate the individual radionuclides.

5 DR. ULSH: Right.

6 MS. ROBERTSON-DEMERS: Well, 

7 there's some question as to when they started 

8 routinely implementing anion exchange, which 

9 is now part of the procedure.

10 DR. ULSH: Well, the best 

11 documentation -- I didn't know that there was 

12 a question on that. That's '66 and '67. That 

13 is when they did the anion exchange.

14 MS. ROBERTSON-DEMERS: Actually, 

15 they did it starting in '82, according to 

16 [identifying information redacted]. What we 

17 brought up was that the date provided by 

18 [identifying information redacted] may or may 

19 not be the right dates, and that's what Warren 

20 was saying on the phone.

21 DR. ULSH: He was? Maybe he did. 

22 Maybe I missed it. I don't know.
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1 DR. NETON: Okay. Well, I guess I 

2 didn't want to complicate the issue here. It 

3 sounds to me like we've got an assignment here 

4 to go back and look at the quantitative 

5 processing of these samples for different 

6 radionuclides.

7 I would suspect, you know, I've 

8 done chemistry like this before. I would be 

9 surprised if there was a differential. I mean 

10 the rare earths go down -- cerium 

11 precipitation will bring down most of the 

12 stuff out of the solution.

13 MS. ROBERTSON-DEMERS: Well, let 

14 me clarify here. It is the first 20 steps of 

15 the program. It's the rapid gross alpha 

16 determination, is what we are talking about, 

17 not the anion exchange.

18 DR. NETON: I understand, but I 

19 don't think there's 20 steps in a gross alpha 

20 determination, are there? That sounds to me 

21 like --

22 MS. ROBERTSON-DEMERS: Well, I was 
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1 trying to communicate to Brant, you know, he 

2 can go back and look at the procedure.

3 DR. NETON: Yes, but you're 

4 talking about the gross alpha, where there is 

5 no attempt made to isolate individually the 

6 radionuclides. I understand.

7 CHAIR BEACH: And, Kathy, you will 

8 get other radionuclides if they don't have 

9 them on the list.

10 DR. ULSH: Okay.

11 DR. BISTLINE: Ready to move on? 

12 I think the next issue is, and it sort of goes 

13 into the same vein as what we were discussing 

14 with gross alpha, but this is a different 

15 issue. It's the beta gamma issue, beta gamma 

16 emitters.

17 First of all, the fact that the 

18 availability of bioassay technique does not 

19 equate to appropriate implementation of the 

20 fact that there is an absence of beta gamma in 

21 the internal monitoring period for a majority 

22 of the years when beta gamma emitters were 
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1 present at Mound, particularly the production 

2 era.

3 Urine bioassay data have been 

4 located for cesium-137 in '93 through '95; 

5 cobalt-60, '93 through '95; manganese-54, '94 

6 through '95, and the strontium-90, '93 through 

7 '97.

8 And NIOSH has indicated that beta 

9 gamma emitters played a minor role at Mound, 

10 in Mound activities, and for the most part 

11 only existed in trace quantities, research and 

12 production-scale operations. They have not 

13 produced objective data regarding the 

14 quantities of material handled or processed or 

15 the concentration for these radionuclides.

16 Going along with this, well, let 

17 me say that the Road Map -- and again, this 

18 talked about Road Map, but it identifies 

19 situations where beta gamma emitters were 

20 handled in the absence of alpha emitters. 

21 However, a method of reconstructing doses from 

22 beta gamma emitters has not been presented, 
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1 closely linked with the issue are previous SEC 

2 determinations made for other sites.

3 It gets into the issue that Mound 

4 extracted polonium-210 from bismuth targets, 

5 irradiated at Hanford for the development of 

6 initiators, beginning in 1943 at the Dayton 

7 Laboratory, and work was transferred to the 

8 Mound lab in Miamisburg, Ohio, in 1949. This 

9 process was started in February 1949 at Mound.

10 NIOSH stated that the Monsanto 

11 Chemical Company Evaluation Report, that 

12 polonium impurities produced a number of 

13 activation products that were beta emitters. 

14 Silver-112 was a particular problem with beta 

15 particles, and there are others, other beta16 emitting radionuclides of concern, antimony 

17 and iron, cobalt, cesium, bismuth, tin, zinc, 

18 mercury. I could give the isotopes of those, 

19 but will not to save time.

20 I think it is more important to 

21 deal with this issue, and that is that NIOSH 

22 has determined at this time that there's a 
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1 lack of sufficient monitoring and source term 

2 data for nuclides other than polonium between 

3 1943 and '49 at MCC, Monsanto Chemical 

4 Company. Although polonium bioassay data 

5 used in conjunction with coworker data from 

6 Mound lab, an ambient environmental polonium 

7 intake, internal intakes could be used to 

8 support internal dose reconstruction, due to a 

9 lack of information, internal exposure data 

10 for the use and production of radionuclides 

11 other than polonium.

12 NIOSH has concluded that there are 

13 insufficient data available to support 

14 internal dose reconstruction with sufficient 

15 accuracy at the Monsanto Chemical Company for 

16 the time period 1943 through 1949. This 

17 inability to complete internal dose 

18 reconstruction at MCC for the 1943 through '49 

19 time period is because of a lack of 

20 information and internal exposure data for 

21 radioisotopes other than polonium, such as 

22 antimony, and so on.
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1 NIOSH has provided justification 

2 for excluding Mound workers from 1949 through 

3 September of 1949, although they have granted 

4 an SEC for MCC for the period immediately 

5 prior to this, and for Mound, starting in 

6 October of 1949.

7 But polonium work continued at 

8 Mound through 1971, with decontamination of 

9 the major polonium production area completed 

10 in '73. There has been no explanation of why 

11 the situation at MCC, which was a basis 

12 granted the SEC at MCC, is different from that 

13 in the Miamisburg location.

14 In addition to the polonium work, 

15 beta gamma emitters were associated with 

16 operations at LLNL and LANL, where SECs were 

17 granted for fission and activation products 

18 prior to '74, actinium, curium, neptunium, 

19 thorium, strontium.

20 Limited beta gamma measurements at 

21 Lawrence Livermore National Labs and Los 

22 Alamos National Lab were not suitable for dose 
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1 reconstruction. Yet, the absence of data 

2 prior to the 1990s for beta gamma emitters at 

3 Mound does not warrant an SEC.

4 Again, at LLNL and LANL, the 

5 availability of workplace air monitoring is 

6 limited and covers only some buildings and 

7 time periods. For many situations, NIOSH has 

8 indicated materials were handled in small or 

9 trace quantities. However, they have not 

10 provided quantitative information, ratios of 

11 secondary radionuclides, of primary 

12 radionuclides, or the relative dose secondary 

13 radionuclides will deliver, and whether it 

14 will influence the claims.

15 So I'll stop at that because that 

16 kind of summarizes the issue of beta gamma 

17 emitters issues that we have.

18 MR. STEWART: Firstly, I would 

19 just like to make a couple of comments about 

20 Monsanto Chemical Company's approach at the 

21 Mound site, because there's really no data out 

22 there right now.
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1 Before, when we had some 

2 information on the Monsanto Chemical Company 

3 or the Dayton Laboratory operation in the 

4 Mound site Technical Basis Document, but that 

5 has been taken out, since it was separated out 

6 as an SEC.

7 I just wanted to bring up a couple 

8 of points. We have a fundamentally different 

9 exposure at the Dayton Laboratory operations 

10 than we do at the Mound site. The Dayton 

11 Laboratory operations did some other 

12 operations when they were researching the 

13 parts that they were fabricating, eventually 

14 using polonium. But, in the early days, there 

15 was a significant amount of work with radium 

16 as well. There were several other 

17 radionuclides that they look at.

18 And you can see in the internal -

19 - in the external dose records that are 

20 available -- they're not complete -- there are 

21 some very large beta doses to some of the 

22 researchers, and those are episodic, or 
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1 intermittent, rather, based on what they were 

2 doing at the time. Okay?

3 Another important fact to keep in 

4 mind was that, when they eventually settled on 

5 the polonium process, they had not yet settled 

6 on the source of that material. By the time 

7 they got to Mound, they had determined that 

8 the best way to fabricate polonium was not 

9 from recycling it from lead tailings and 

10 things like that. But, by processing 

11 irradiated bismuth bricks, which went through 

12 the reactor at Hanford or another, I think Oak 

13 Ridge, which are fundamentally different than 

14 fuel. I'll just point that out.

15 So, by the time they got to the T 

16 Building at Mound, they were just using 

17 irradiated bismuth. So you have kind of a 

18 different source term than you would have in, 

19 say, in a fuel operation. Okay?

20 And finally, the levels of control 

21 at the Dayton Laboratory facilities were a lot 

22 less. They were working in fume hoods and in 
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1 some cases bench tops. So there were a lot of 

2 internal doses at that point, and they had 

3 very high levels, levels that would scare us 

4 under our current controls.

5 Part of the reason, they kept 

6 getting better controls, but they couldn't 

7 really get there until they had designed a 

8 purpose-built facility to do that. Okay?

9 Now they also had other 

10 radionuclides there. I mentioned radium 

11 earlier, but they only had bioassay for 

12 polonium. So all we can predict was the 

13 polonium intakes from their records. Okay?

14 Having said that, I'll turn it 

15 over to Brant to respond.

16 DR. ULSH: Well, yes, I was going 

17 to make some of the similar points. If you 

18 think about how we have handled other 

19 situations in an SEC context, we have 

20 repeatedly been questioned on our ability to 

21 back-extrapolate in time. I would say that 

22 that cuts both ways.
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1 You cannot back-extrapolate 

2 blindly in time from Mound to Monsanto and 

3 assume necessarily that the similar problems 

4 exist. And in fact, there's reason to think 

5 that they didn't.

6 A couple of the reasons Don 

7 mentioned. The source term is different. 

8 But, also, one of the main reasons of building 

9 the T Building at Mound Laboratory was to 

10 build on the experience of the Dayton Lab, 

11 take in mind the problems that they 

12 experienced at Dayton Lab, and to improve the 

13 controls that were instituted in the T 

14 Building to minimize exactly the exposure 

15 problems that they experienced at Dayton Lab.

16 It is true that there were some 

17 beta gamma emitters produced and activation 

18 products, in particular, produced in the cans 

19 that were used to encase the bismuth before 

20 they went through the reactor. That was the 

21 source of a lot of the beta and gamma problems 

22 associated with the polonium program.
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1 I would also remind you that we 

2 have thousands of, I believe it's thousands, 

3 of polonium bioassay. It's hard to imagine 

4 that, if you're talking about contaminants in 

5 polonium, you would, number one, be concerned 

6 about the minor constituents and not the 

7 polonium. The polonium would be the primary 

8 radionuclide. If you got an intake of these 

9 other alpha or beta -- sorry -- of these other 

10 beta gamma emitters, you would see it in a 

11 polonium intake.

12 So some of the other programs, and 

13 there weren't many, that involved beta gamma 

14 emitters would have been the reactor waste 

15 program. Again, that is entirely within the 

16 SEC period. I don't think it's claimant17 favorable to say that the people were exposed 

18 to beta gamma emitters during the SEC period

19 and we cannot reconstruct it. If you want us 

20 to say that, we will talk about it, but I 

21 don't think you really do.

22 In terms of other things that were 
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1 handled in isolation, we are not aware of any 

2 big project, you know, major-scale programs 

3 that occurred with beta gamma emitters in 

4 isolation that would have led to a significant 

5 exposure potential.

6 Sure, on occasion, I think there 

7 was a small strontium operation, and to call 

8 it an "operation" is even an exaggeration. I 

9 think it involved two people, Don? Two 

10 research chemists, we know who they were. It 

11 is not like they had a strontium program or a 

12 cesium program that we're aware of.

13 I don't think I'm misspeaking, am 

14 I?

15 MR. STEWART: There was one 

16 operation of cesium; they were pulling it out 

17 of a waste stream.

18 DR. ULSH: Right, right. So I 

19 just don't see how there was a large exposure 

20 potential to beta and gamma emitters at Mound.

21 Again, the primary purpose, the 

22 primary work at Mound was, first, polonium and 
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1 then later plutonium-238. That's the haystack 

2 that we're talking about here, not the 

3 needles.

4 MS. ROBERTSON-DEMERS: Do you know 

5 the timing of the exact date when they started 

6 the differential processes for polonium, 

7 meaning extracting it from the lead, 

8 extracting it from the bismuth slug, and so 

9 forth?

10 MR. STEWART: That is in the 

11 Dayton Laboratory period. So it is not 

12 specifically covered.

13 DR. ULSH: Well, at Mound, Kathy, 

14 I think that was one --

15 MS. ROBERTSON-DEMERS: What I 

16 would like to do is compare the processes that 

17 were used for polonium extraction from the 

18 beginning through '73.

19 MR. STEWART: Dayton Laboratory is 

20 already an SEC.

21 MS. ROBERTSON-DEMERS: I want to 

22 compare the different processes at Dayton Lab 
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1 with what happened at Mound.

2 DR. ULSH: If that is something 

3 the Work Group would like us to follow up on, 

4 we can look for process descriptions for the 

5 polonium program at Mound and Dayton Lab.

6 MS. ROBERTSON-DEMERS: Right now, 

7 I am just asking for the dates for when the 

8 changes in the processing of polonium 

9 happened.

10 DR. ULSH: Well, whenever it 

11 started at T Building, I don't know; I'm 

12 guessing here, Kathy, but I know that Mound 

13 Lab started operation in 1949. I believe that 

14 it was either '49 or '50 that the T Building 

15 went operational. It might be a year or 

16 two --

17 MS. ROBERTSON-DEMERS: Okay, I'm 

18 going to ask the question differently. What 

19 was the process at the Dayton Labs when it 

20 closed, the polonium process? And what was 

21 the process in T Building in 1949?

22 MR. STEWART: The T Building 
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1 process was irradiated bismuth bricks. Later 

2 irradiated bismuth cans. That's what they 

3 were set up to do.

4 MS. ROBERTSON-DEMERS: What was 

5 the process in 1948 at Monsanto?

6 MR. STEWART: I honestly don't 

7 know when they stopped using lead tailings and 

8 when they started to do the bismuth bricks 

9 prior to the Mound operation. I can get you 

10 that information, if you feel it is useful. 

11 However, I will point out that that is covered 

12 under an SEC at this point.

13 MS. ROBERTSON-DEMERS: What we are 

14 trying to understand is exactly -- I'm trying 

15 to get a better understanding of exactly why, 

16 and I know that you guys have talked, given 

17 your points why the situation at Monsanto, 

18 where you're calling out the same 

19 radionuclides that were in the activation 

20 products, is different than the situation in 

21 1949 at Mound.

22 DR. ULSH: Well, I think the 
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1 primary reason that we consider the situation 

2 to be different is that it is a totally 

3 different facility, and the T Building at 

4 Mound was built specifically to minimize the 

5 exposure potential that occurred at the Dayton 

6 Lab. The exposure potential was not only from 

7 polonium, but, as Bob I guess mentioned, all 

8 of their activation products.

9 That's why they built T Building 

10 the way they did, a closed system, remote 

11 handling, to minimize the beta and gamma 

12 exposure potential.

13 MS. ROBERTSON-DEMERS: Okay. So 

14 what you're saying is the difference is 

15 radiological controls?

16 DR. ULSH: As opposed to what? I 

17 mean, yes, radiological controls certainly 

18 plays into it, yes.

19 MS. ROBERTSON-DEMERS: I'm trying 

20 to understand the differences between them.

21 DR. ULSH: Radiological controls 

22 is certainly a significant factor in this. I 
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1 agree with that. And again, the source term 

2 differences that Don described.

3 MS. ROBERTSON-DEMERS: And I guess 

4 I'm not quite understanding why Monsanto calls 

5 out, you know, all of these specific 

6 radionuclides.

7 DR. ULSH: Again, because there 

8 was an exposure potential at Monsanto Chemical 

9 Company to be exposed to these different 

10 radionuclides because of their lack of 

11 radiological controls as compared to, say, for 

12 instance, the T Building.

13 MS. ROBERTSON-DEMERS: Okay. So 

14 it's coming down to radiological controls?

15 DR. ULSH: By and large, yes.

16 MS. ROBERTSON-DEMERS: Because the 

17 isotopes --

18 MEMBER ZIEMER: Well, wasn't it 

19 also process?

20 DR. ULSH: And process for at 

21 least a portion of the time.

22 MS. ROBERTSON-DEMERS: Well, 
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1 that's what I'm trying to understand.

2 DR. ULSH: So I think, then, what 

3 you're asking -- Don, if I understand what you 

4 said, was they started with, let's just call 

5 it, a led tailings recovery effort at Monsanto 

6 Chemical Company. At some point in time, and 

7 it's probably not a bright line -- I'm just 

8 guessing here -- they decided, no, this isn't 

9 going to work out; we're going to do 

10 irradiated bismuth bricks.

11 MR. STEWART: Right.

12 DR. ULSH: And that happened 

13 sometime during the Monsanto Chemical 

14 Company -- and then that process carried on at 

15 Mound. Am I correct so far?

16 MR. STEWART: Yes. I don't have 

17 those dates for you because I wasn't prepared 

18 for this question.

19 DR. ULSH: Yes. If the Working 

20 Group is interested in this question, we can 

21 try to track down the date at Monsanto 

22 Chemical Company, when they switched from lead 
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1 tailings to bismuth bricks. I don't know why 

2 we need to, but if that's something you are 

3 interested in, we will do it.

4 MEMBER ZIEMER: It sounds like the 

5 decision to do that was based on radiological 

6 issues, that you had all these beta gammas 

7 that were a problem in the process, and there 

8 may be some efficiency issues, too, but --

9 DR. ULSH: I think that might be a 

10 major factor, too.

11 MEMBER ZIEMER: Yes, but from an 

12 exposure dose point of view, as I understand, 

13 at Monsanto they had a lot of beta gamma stuff 

14 that was problems.

15 MR. STEWART: Well, we don't know 

16 a lot about that. Certainly I saw some beta 

17 dose rates on film badge results. So I 

18 inferred from that that there was a beta gamma 

19 problem.

20 DR. ULSH: Well, and in fact, we 

21 have been told that.

22 MEMBER ZIEMER: But your focus 
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1 here is on internal --

2 DR. ULSH: Right.

3 MEMBER ZIEMER: -- dose from beta 

4 gamma, which per unit activity is typically 

5 much lower than alpha, but I guess it's a good 

6 question: is the beta gamma, as I understand, 

7 Bob, your question, is the beta gamma, do we 

8 know that it is insignificant compared to the 

9 alpha? Is that sort of the underlying 

10 question?

11 DR. BISTLINE: That's it.

12 MEMBER ZIEMER: And then --

13 MS. ROBERTSON-DEMERS: Was it 

14 insignificant to all organ cases.

15 CHAIR BEACH: Is there a specific 

16 period you're looking for? Is it the pre-SEC 

17 for Mound time period of February --

18 MS. ROBERTSON-DEMERS: Well, can I 

19 break it up into two periods?

20 CHAIR BEACH: Sure.

21 MS. ROBERTSON-DEMERS: There is 

22 February 1st, 1949 through September 30th, 
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1 1949. Okay?

2 MEMBER ZIEMER: Which is what?

3 MS. ROBERTSON-DEMERS: Which is an 

4 uncovered period that the petitioner 

5 requested.

6 DR. ULSH: February 1st through 

7 September what?

8 MS. ROBERTSON-DEMERS: Through 

9 September 30th.

10 CHAIR BEACH: And you said you 

11 were going to break it into two?

12 MS. ROBERTSON-DEMERS: Yes. Okay. 

13 Now there was another piece of information on 

14 that time period, too. In addition to the 

15 issue with polonium, there was also for a 

16 period of time a lack of neutron monitoring, 

17 which was also specified in the Monsanto

18 report as rationale for granting an SEC.

19 DR. ULSH: So are you implying, 

20 then, that there are no or, rather, 

21 insufficient neutron monitoring during the 

22 polonium program at Mound? Is that where 
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1 you're headed?

2 MS. ROBERTSON-DEMERS: Neutron 

3 monitoring started up in August. So there was 

4 a period of time when there was no neutron 

5 monitoring.

6 MEMBER ZIEMER: But that's a 

7 different question.

8 MS. ROBERTSON-DEMERS: Yes, but it 

9 plays into that time period.

10 MEMBER ZIEMER: Yes, yes.

11 DR. ULSH: August of '49?

12 CHAIR BEACH: The same time period 

13 you mentioned before, February 1st --

14 MS. ROBERTSON-DEMERS: Yes.

15 CHAIR BEACH: -- 1949 to September 

16 30th, 1949.

17 MR. HINNEFELD: Pardon me. Is the 

18 origin of this question that the Mound SEC 

19 starts in October something, or when did it 

20 start?

21 MS. ROBERTSON-DEMERS: It starts 

22 in October.
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1 MR. HINNEFELD: Of 1949. But you 

2 would have to say there was radiological work 

3 there starting in February? Is that what 

4 you're saying?

5 MS. ROBERTSON-DEMERS: Right.

6 MR. HINNEFELD: Okay. Well, I 

7 certainly wasn't aware of that.

8 DR. ULSH: I don't know. All I 

9 can tell you is that the basis for the current 

10 SEC at Mound was when the material for the 

11 radium, actinium, thorium separations came on 

12 site. It was not related to the polonium 

13 program.

14 Off the top of my head, I don't 

15 have memorized when the T Building went hot. 

16 I mean that's a time of transition from 

17 Monsanto to Mound. There might be a gap. I 

18 don't know.

19 MR. HINNEFELD: We will have to go 

20 check. We are not prepared to do that today.

21 MR. STEWART: Yes, I will observe 

22 that your quotation from [identifying 
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1 information redacted] that you're referring to 

2 actually says we have neutron monitor prior to 

3 September.

4 DR. ULSH: Are you looking at me 

5 or -- okay. I didn't think I said that.

6 (Laughter.)

7 MR. HINNEFELD: We'll have to 

8 investigate that period of time. That seems 

9 to be what the question is about, is that 

10 period of time from February to October.

11 MS. ROBERTSON-DEMERS: The 

12 question is there's indication that the 

13 polonium process started up in February.

14 MR. HINNEFELD: Okay.

15 CHAIR BEACH: Okay, so that's for 

16 polonium. Now you brought up neutrons.

17 MS. ROBERTSON-DEMERS: Well, no, I 

18 meant --

19 CHAIR BEACH: Okay.

20 MS. ROBERTSON-DEMERS: I'm just 

21 saying that, for that same period of time, 

22 there's also a question that Monsanto was --
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1 also another reason for granting the SEC was 

2 for the lack of neutron monitoring. And you 

3 have the same situation from February through 

4 August of that time period.

5 MR. HINNEFELD: Have you cited any 

6 references for us about the origin of the 

7 radiological work? Or what's the basis of 

8 stating that the radiological work started in 

9 February of '49? Are those in something you 

10 provided to us?

11 MS. ROBERTSON-DEMERS: I don't 

12 know. I'll have to go back and get the 

13 reference for you.

14 MR. HINNEFELD: Okay. I mean it 

15 seems to me what you are saying is there is 

16 this gap period from February to October of 

17 1949 when radiological work was going on at 

18 Mound, when there hasn't been a lot of 

19 consideration of how we are going to do that.

20 I think I'm not sure about the 

21 guys in the room, but I kind of thought that, 

22 well, Mound started as an SEC. That's kind of 
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1 what I thought was going on. Maybe I'm wrong 

2 on that.

3 DR. ULSH: Well, again, it's a 

4 little misleading to think of MCC, Monsanto 

5 Chemical Company, as one facility. I mean 

6 there was Unit 1, 2, 3, 4.

7 MR. HINNEFELD: Yes, okay.

8 DR. ULSH: And they involved -- I 

9 mean polonium was the primary operation, but, 

10 yes, there is this time of transition between 

11 MCC and Mound. In terms of when the polonium 

12 work actually started at Mound, I don't know. 

13 It's not a question that we have focused on. 

14 I don't have that off the top of my --

15 MR. HINNEFELD: Okay. We're not 

16 prepared to deal with this question today, but 

17 you'll find out.

18 DR. ULSH: Right.

19 MR. CHEW: In the [identifying 

20 information redacted] document.

21 DR. ULSH: Go ahead and tell us 

22 what [identifying information redacted] says.
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1 MR. CHEW: The [identifying 

2 information redacted] document said in R 

3 Building, 127, and just gave a time frame. In 

4 1948, the polonium pilot program started in 

5 room 127 and room 120, 1948, but did not give 

6 any more details.

7 MR. HINNEFELD: In R Building.

8 MR. CHEW: In R Building, in rooms 

9 127 and 128.

10 DR. ULSH: I think you're right. 

11 I think there's gap between the end of the 

12 Monsanto SEC and the beginning of the Mound 

13 SEC. I wouldn't argue with that.

14 In terms of these other issues 

15 that you talked about a lot, you said --

16 MS. ROBERTSON-DEMERS: There's 

17 that time period, and then the other concern 

18 is the beta gamma emitters from March 1st, '59 

19 forward -- this is the other section of it --

20 with the lack of bioassay data.

21 DR. ULSH: Which beta gamma 

22 emitters are we talking about? From '59 
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1 forward?

2 MS. ROBERTSON-DEMERS: Involves 

3 cesium --

4 DR. ULSH: Well, again, I'm not 

5 aware of any --

6 MS. ROBERTSON-DEMERS: Anything 

7 that was a part of the aluminum --

8 DR. ULSH: So you're associating 

9 these with the polonium program?

10 MS. ROBERTSON-DEMERS: Not 

11 exclusively.

12 DR. ULSH: All right. As I 

13 understand your concern, you've named cobalt, 

14 cesium -- I don't know, maybe a few others, I 

15 don't know -- associated with the polonium 

16 program, but you're also, I think, saying that 

17 these presented an exposure hazard at Mound 

18 outside of the polonium program. Am I --

19 MS. ROBERTSON-DEMERS: The gamma 

20 emitters were not only associated with the 

21 polonium program, but they were associated 

22 with other programs --
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1 DR. ULSH: Yes, they were.

2 MS. ROBERTSON-DEMERS: -- outside 

3 of the SEC.

4 DR. ULSH: Okay. Can you give me 

5 a hint as to what you're talking about, which 

6 ones?

7 MS. ROBERTSON-DEMERS: What about 

8 the process in the WD Building? I mean this 

9 comes back to the Road Map, which you're 

10 asking us to provide additional data for.

11 DR. ULSH: No, actually, I'm just 

12 asking what your concerns are. I just want to 

13 make sure that we answer your concerns.

14 MS. ROBERTSON-DEMERS: So that 

15 kind of goes into WD 101, 104.

16 MR. CHEW: What page are you on 

17 there, Kathy?

18 MS. ROBERTSON-DEMERS: Ninety, 94, 

19 95.

20 MEMBER ZIEMER: Is this in the 

21 Road Map, now --

22 MS. ROBERTSON-DEMERS: Yes.
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1 DR. ULSH: Okay. This --

2 MS. ROBERTSON-DEMERS: It's page 

3 98, 112. And there's several examples of 

4 where this stuff is coming up. The same page, 

5 98, WDA118A.

6 DR. ULSH: Okay. Hold on, just 

7 give me a sec. Do you have a time frame, 

8 Kathy? I'm not looking at the Road Map right 

9 now.

10 MS. ROBERTSON-DEMERS: For which 

11 one?

12 DR. ULSH: Your concern about WD 

13 Building.

14 MS. ROBERTSON-DEMERS: Okay. Let 

15 me go backwards here.

16 For WDA112, for example, 1980 to 

17 '84.

18 DR. ULSH: Okay. Here's what I 

19 can tell you about cesium at least. It was a 

20 one-time shot. Oh, by the way, the reference 

21 here is -- do I have a SRDB number on there? 

22 Well, the MLM number is MLM-2929, and it's got 
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1 an SRDB cover sheet here and unfortunately, 

2 I'm not adept at picking out the SRDB number.

3 First author is W. H. Bond. What 

4 we're talking about here is removal of cesium 

5 from a salty aqueous waste with sodium 

6 tetraphenylboron.

7 What I have highlighted here is 

8 that in this waste it's supernatant. The 

9 cesium-137 counts ranged from 570 down to 4 

10 counts per minute.

11 Okay. "The waste disposal group" 

12 -- this is from the intro -- "The waste 

13 disposal group at MRC Mound has the 

14 responsibility of processing low-level 

15 contaminated aqueous waste generated during 

16 normal operations. Usually, these wastes are 

17 contaminated only with plutonium-238. 

18 Occasionally, other isotopes, such as 

19 actinides, occur in the waste.

20 "With minor process alterations, 

21 these isotopes are easily removed. However, 

22 cesium-137 leaked from a tank used for 
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1 development waste and was the major 

2 contaminant in one 4600-gallon batch."

3 "This waste" -- I'm moving around 

4 now. This is not a continuous quote. "This 

5 waste was not likely to be encountered again. 

6 The physical processes, such as reverse 

7 osmosis and evaporation, were eliminated 

8 because of the one-time-only aspect."

9 So the point I'm making there is 

10 that this is not an ongoing program. This 

11 document clearly indicates that it is a one12 time-only situation.

13 "The cesium concentrations are 

14 provided."

15 I think that might be all -- and I 

16 think this is dated, this is 1982. So it 

17 corresponds with the time frame you're talking

18 about. I believe someone might have said -- I 

19 don't know if it was you -- that there were 

20 some cesium bioassays around that time period.

21 MS. ROBERTSON-DEMERS: Ninety, it 

22 was in 1990.
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1 DR. ULSH: Okay. Nothing around 

2 this time period?

3 MS. ROBERTSON-DEMERS: No.

4 DR. ULSH: Okay.

5 MEMBER ZIEMER: What was the date 

6 there?

7 DR. ULSH: Well, it's a little 

8 unclear, Paul. I think I guessed from the 

9 references -- there's a card attached; I can 

10 show it to you -- 1982.

11 MR. STEWART: The data captured 

12 says 8/13/81.

13 DR. ULSH: Okay, '81 or '82.

14 So that's what I know about cesium 

15 in WD Building, this one-time operation. I'm 

16 not saying there's nothing else. I'm just 

17 saying this is all I'm aware of. If there's 

18 anything else --

19 MR. STEWART: Are you talking 

20 about bioassay results in the mid-nineties?

21 DR. ULSH: Well, she said that 

22 there are cesium results in the nineties.
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1 MR. STEWART: Are you talking 

2 about in vivo results?

3 MS. ROBERTSON-DEMERS: No.

4 MR. STEWART: They're not in vivo 

5 results?

6 MS. ROBERTSON-DEMERS: No. 

7 They're urinalyses.

8 DR. ULSH: I'm not sure. I 

9 haven't seen the cesium results in the 1990s, 

10 and I don't know what the rationale for taking 

11 them was.

12 MEMBER CLAWSON: When you say a 

13 one-time use, was it one time for a great 

14 period or was it just one day we did this?

15 DR. ULSH: No, I didn't say one16 time use. The authors did.

17 MEMBER CLAWSON: No. Well, this 

18 is what I'm saying. I'm trying to understand 

19 if one-time use, is this a run of so much?

20 DR. ULSH: Yes. Yes. It's one 

21 batch of waste that was contaminated with 

22 cesium. It says, "This waste was not likely 
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1 to be encountered again. The physical 

2 processes, such as reverse osmosis and 

3 evaporation, were eliminated because of the --

4 quote -- one-time-only aspect. That's the 

5 words of the author, not me.

6 CHAIR BEACH: But no dates? Or 

7 did you say '80 --

8 DR. ULSH: Well, this document I 

9 think is dated around 1982, but it might be 

10 '81 because that's what the data, the document 

11 date says. So it's either '81 or '82, Josie. 

12 That's about as close as I can narrow it down 

13 right now.

14 MR. CHEW: The [identifying 

15 information redacted] document is between '80 

16 and '84. So you're right.

17 DR. ULSH: So this is a bit more 

18 specific of a range.

19 MR. STEWART: I will just make a 

20 statement here about dose reconstruction. If 

21 we were to encounter cesium-137 results in a 

22 claim, even outside a period of concern that 
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1 was mentioned in the TBD, we would assign this 

2 dose for negative results, and we would 

3 assign, you know, an assumed dose, based on 

4 bioassay results.

5 But the results are in the record. 

6 It's going to end up in the dose 

7 reconstruction, regardless of whether the TBD 

8 says to do it or not.

9 MS. ROBERTSON-DEMERS: The point 

10 is there are no results.

11 MR. STEWART: I thought you just 

12 said there were results.

13 DR. ULSH: No, no, she said in 

14 '90.

15 MS. ROBERTSON-DEMERS: No results 

16 in '90, '93 to '95.

17 MR. STEWART: Okay.

18 MS. ROBERTSON-DEMERS: Not in '80.

19 MR. STEWART: We're not presuming 

20 the source term during that time. But, even 

21 though we're not presuming the source term 

22 during that time, it's going to end up in the 
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1 dose reconstructed because the result is in 

2 the record.

3 DR. ULSH: No. Hold on. Hold on, 

4 Don. I think you're confused here a little 

5 bit.

6 What we have here is a description 

7 of an event or a run here of a waste 

8 processing event that happened around the 1981 

9 or '82 time frame, and at least what they are 

10 saying here is that there are no corresponding 

11 bioassay results for cesium.

12 MR. STEWART: For that event. I 

13 see.

14 DR. ULSH: And we see cesium 

15 results in '93 to '95, is what they're saying. 

16 And what you're saying, I understand what 

17 you're saying. For those results in '93 to 

18 '95, we would include them in the dose 

19 reconstruction. That doesn't address this 

20 situation here, though.

21 MR. STEWART: That's correct. It 

22 does not address that.
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1 DR. ULSH: Right? Have I 

2 accurately summed up everybody's words?

3 I'm not sure. I mean, obviously, 

4 well, first of all, at least according to this 

5 document, it says that it is a one-time-only 

6 thing. It's not an ongoing thing. That is 

7 what this document appears to indicate to me.

8 I would have to look at the 

9 details of the process to determine whether or 

10 not there was an exposure potential. I mean, 

11 if this is an entirely closed system, you 

12 wouldn't expect there to be an exposure 

13 potential, but I can't say that at this point 

14 in time.

15 If you would like, we can examine 

16 this a little further.

17 MS. ROBERTSON-DEMERS: I thought 

18 that was part of the table we were doing.

19 MR. FITZGERALD: Yes. In the 

20 larger context of providing, I think, specific 

21 examples with the question of exposure 

22 potential, this seems to be part and parcel of 
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1 that, that we would identify, for example, 

2 this one as one that we would want you to 

3 pursue and give you some -- actually, in this 

4 case, we actually have the evidence that would 

5 be the starting point perhaps for you to look 

6 at it.

7 So we would include this as part 

8 of the list that we would provide. Rather 

9 than trying to parse this out, make it part of 

10 the package.

11 MEMBER ZIEMER: Do you have the 

12 concentrations of the solutions?

13 DR. ULSH: The abstract, Paul, 

14 says the concentration in the supernatant of 

15 the waste was from 570 down to 4 counts per 

16 minute per mil.

17 MEMBER ZIEMER: Well, you would 

18 have to know efficiencies, but --

19 DR. ULSH: I think there might be 

20 more information, hold on.

21 MR. CHEW: That is down to the 

22 nanocurie level then. It says in nanocuries.
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1 DR. ULSH: There is a -- hold on. 

2 Let me read it to you, so I don't misstate it.

3 "However, cesium-137 leaked from a 

4 tank used for development waste and was the 

5 major contaminant in one 4,600-gallon batch."

6 MEMBER ZIEMER: Is that the 

7 concentration of that batch?

8 DR. ULSH: I believe -- that's the 

9 way I'm interpreting it.

10 DR. NETON: What year was this 

11 batch?

12 DR. ULSH: Well, Jim, we've got 

13 two possibilities. The data capture sheet 

14 says 8/13/81.

15 DR. NETON: Okay, '81. That's 

16 close enough.

17 DR. ULSH: Yes, so it's '81 or 

18 '82.

19 I don't know. There's some 

20 interpretation here. I don't want to give you 

21 these other -- I'll show you these numbers, if 

22 you would like, but I don't know quite how to 
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1 interpret.

2 DR. BISTLINE: What source term is 

3 this waste? Does it say? Or where it came 

4 from?

5 DR. ULSH: Not specifically here.

6 MR. STEWART: It said it was from 

7 development wastes.

8 DR. BISTLINE: Yes, so that's what 

9 I'm wondering. Something was going on that 

10 generated this.

11 MR. STEWART: Well, it leads me to 

12 wonder if that wasn't that bismuth phosphate 

13 plant process way back when.

14 DR. BISTLINE: Now we're in the 

15 eighties. It makes you wonder.

16 MR. STEWART: Yes, but if they 

17 didn't process it, it's been around in the 

18 waste stream for a long time. You know, 

19 cesium is going to come into solutions. It's 

20 quite easy.

21 DR. BISTLINE: Yes, it's half-life 

22 and everything.
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1 DR. ULSH: I would have to look at 

2 this closer, but on my cursory inspection 

3 here -- it's been a while since I've looked at 

4 this -- I don't see any clues that would 

5 answer your question or yours one way or the 

6 other.

7 DR. BISTLINE: It just raises a 

8 question in your mind as to where it came from 

9 and what was going on.

10 MEMBER CLAWSON: This also comes 

11 back to what I said earlier about, when a 

12 process stopped --

13 DR. BISTLINE: Yes, certainly.

14 MEMBER CLAWSON: -- where did it 

15 all go? You know, if this had been sitting 

16 around since the forties in there, or 

17 whatever, that's --

18 DR. BISTLINE: Well, we ran into 

19 it at Rocky. We knew of a project that was 

20 going on in the 83 Building back in the 1960s, 

21 and in the 1990s they came to me and I said 

22 there had been some plutonium-239 in there, 
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1 and everybody said, no, it couldn't have been; 

2 they never did have plutonium there. I knew 

3 of one project that went on and, sure enough, 

4 they found it under the lathes and up in the 

5 ventilation system.

6 DR. NETON: Well, this is kind of 

7 normal operations. It was generated during 

8 normal operations at Mound, is what this says. 

9 So it wasn't something that had been brought 

10 in --

11 DR. ULSH: Wait where?

12 DR. NETON: "The waste disposal 

13 group has the responsibility for processing 

14 low-level contaminated aqueous waste generated 

15 during normal operations."

16 DR. ULSH: Keep reading.

17 DR. NETON: "Usually, these wastes 

18 were -- occasionally, other isotopes occur in 

19 the waste."

20 Yes, but this sort of indicates 

21 that something was generated during the 

22 normal -- during an operation at Mound. It 
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1 wasn't that they brought in this waste from 

2 somewhere else.

3 DR. ULSH: Right. It is not waste 

4 that was brought in from somewhere else and 

5 processed at Mound. I didn't get that 

6 impression from this.

7 DR. BISTLINE: No, but the 

8 question is, where? You know, what room or 

9 what building generated this? So who could 

10 have gotten exposure? Or was there a 

11 potential --

12 DR. ULSH: If you would like, we 

13 can take it as an action item to review this 

14 particular situation further.

15 CHAIR BEACH: And I think it will 

16 be part of SC&A's --

17 (Simultaneous speaking.)

18 MEMBER ZIEMER: Brant, do we know 

19 if Mound had access to whole body counting 

20 services at all?

21 DR. ULSH: Yes, I believe they 

22 did, yes.
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1 MEMBER ZIEMER: Because if you had 

2 a concern about cesium, I am not sure you 

3 would be doing urine analysis. It would be 

4 much easier to have -- I mean they didn't have 

5 their own whole body counter, right?

6 DR. ULSH: I believe they did.

7 MEMBER ZIEMER: Oh, they did?

8 DR. ULSH: Yes.

9 (Simultaneous speaking.)

10 DR. BISTLINE: It was in the 

11 seventies because it was after that accident 

12 in Rocky Flats, and they came, got plans from 

13 us as to how to go about building that lung 

14 counter.

15 MR. HINNEFELD: They had their own 

16 at some point.

17 DR. BISTLINE: Yes.

18 MEMBER ZIEMER: Cesium distributes 

19 in the total body, mostly tissue, but it is 

20 pretty easy to detect, either a crystal or 

21 a --

22 MS. ROBERTSON-DEMERS: I think 
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1 there was some question as to the type of the 

2 whole body counter in the energy range that 

3 was affected over.

4 MEMBER CLAWSON: Well, that comes 

5 out --

6 MEMBER ZIEMER: Well, if you 

7 calibrate, it doesn't matter. You can 

8 calibrate for cesium. You may have issues of 

9 efficiency, but then you just count longer. I 

10 mean you can use a crystal that's not designed 

11 for -- if I were doing cesium, I would use a 

12 big sodium iodide. But if it's a little one 

13 that someone was using for --

14 DR. BISTLINE: 238.

15 MEMBER ZIEMER: -- 238 X-rays or 

16 something, you can still do it, but the 

17 efficiencies are just poor.

18 DR. NETON: Well, I guess the 

19 question is, do we have any cesium-137 unusual 

20 counts in bioassay records?

21 MR. CHEW: Yes.

22 DR. NETON: We do?
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1 MR. CHEW: No, that's the 

2 question.

3 DR. NETON: We need to look at 

4 that. I mean, yes.

5 MEMBER ZIEMER: Well, I wasn't 

6 asking that specifically, but it might be a 

7 good question. But it just occurs to me, if 

8 someone was concerned about internal 

9 exposures, I'm not sure I would expect them to 

10 be doing a urine bioassay. It's so easy to do 

11 these things.

12 Cobalt would be the same way, a 

13 very specific peak. But strontium would be a 

14 different problem.

15 DR. ULSH: Strontium is different.

16 MR. CHEW: Bob, to answer your 

17 question, at least I'm going to reference the 

18 [identifying information redacted] document 

19 again, recognizing what it is supposed to be 

20 for. It says, "In 1948 to 1951" --

21 MEMBER ZIEMER: Can you talk a 

22 little louder, Mel?
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1 MR. CHEW: -- "five shipments of 

2 bismuth phosphate was received from Hanford, 

3 which included crib materials and samples from 

4 two other stages of the process, and the 

5 plutonium separation program from irradiated 

6 uranium-235, PUREX, and tributyl phosphate 

7 materials from Oak Ridge."

8 DR. ULSH: But that's the reactor 

9 waste program.

10 MR. CHEW: Yes.

11 DR. ULSH: And what was the end 

12 date on that, Mel?

13 MR. CHEW: And that was '48 to '51.

14 DR. ULSH: It could have. I don't 

15 know.

16 MR. CHEW: Cesium came along with 

17 that. So, when they scooped it off, they 

18 probably stored it. We don't know that.

19 CHAIR BEACH: So let me check in 

20 -- excuse me. Sorry. We're getting close to 

21 the lunch hour.

22 How much data adequacy do you 
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1 think we still have to go? I was hoping to 

2 wrap it up before lunch, but if not --

3 DR. BISTLINE: Well, there is the 

4 completeness issue. That might be a bit of a 

5 discussion. I think we ought to just do lunch.

6 CHAIR BEACH: Okay. So I will 

7 suggest that we go ahead and break for lunch 

8 then, 12:30 to 1:30.

9 MEMBER CLAWSON: So am I clear on 

10 this last item, that you guys are going to 

11 research into it? Part of it was looking at 

12 the whole body.

13 DR. NETON: Well, that's going to 

14 be part of, I think, the SC&A list of areas 

15 where there were activities that we may not 

16 have adequate bioassay data for.

17 MEMBER CLAWSON: Okay.

18 DR. NETON: Didn't show up on their 

19 list. We certainly would be aware of -- we 

20 will pursue that.

21 MEMBER CLAWSON: Okay.

22 MR. KATZ: So we are adjourning 
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1 for lunch. We will be reconvening, for folks 

2 on the phone, at 1:30.

3 Thank you, everybody.

4 (Whereupon, the above-entitled 

5 matter went off the record at 12:32 p.m. and 

6 resumed at 1:31 p.m.)

7

8
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

2 1:31 p.m.

3 MR. KATZ: Good afternoon. This 

4 is the Mound Working Group, the Advisory Board 

5 on Radiation and Worker Health. We are 

6 reconvening after lunch break, and we're ready 

7 to go.

8 Josie?

9 CHAIR BEACH: We are going to 

10 continue our discussion on data adequacy and 

11 completeness.

12 One agenda item, I am going to 

13 note for the record, right after data adequacy 

14 and completeness, we are going to go into 

15 shallow dose. That should be a very quick 

16 topic. One of the members is going to leave 

17 early.

18 So, with that, we will go ahead 

19 and I can turn it back over to you, Bob. 

20 Would you like to continue?

21 DR. BISTLINE: Okay. The next 

22 issue is the data completeness issue. One of 
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1 the issues, one of the big things about this 

2 is our concern that dose reconstructors use a 

3 comprehensive set of internal and external 

4 dosimetry information on individual records.

5 When one looks at the list of 

6 sources of information, internal dosimetry and 

7 external dosimetry, it's about a page long of 

8 different data files and sources of 

9 information. The primary data available for 

10 use by the dose reconstructors are internal 

11 and external dosimetry information found in 

12 the individual's radiation exposure file and 

13 electronically through MESH, if printouts are 

14 not already available in the file.

15 NIOSH, in their response to data 

16 completeness, failed to address many items 

17 raised in Mound's internal dosimetry data 

18 completeness, such as, number one, multiple 

19 bioassay results for a single day, which are 

20 not two independent samples, but one sample 

21 that was split.

22 Two, inconsistencies between the 
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1 PORECON and POLON data, and incomplete fecal 

2 data in the individual exposure file and 

3 electronic data.

4 And fourthly, incomplete in vivo 

5 data in the individual's exposure file and 

6 electronic data.

7 Fifthly, the absence of MJW 

8 database results, absent from the individual 

9 file and MESH, which contain unique bioassay 

10 information for other radionuclides.

11 To obtain a full monitoring 

12 history for any individual, the dose 

13 reconstructor must have to consult, may have 

14 to consult sources other than the individual 

15 file or MESH. Based on conversations with our 

16 own individual reviewing DRs, this is not a 

17 routine practice.

18 Another item is tritium data in 

19 MESH prior to October of 1981 is only 

20 available in milligram and is based on an HTO 

21 intake. Log books are in many cases the only 

22 source of tritium bioassay data for this time 
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1 period. There are two years for which 

2 bioassay data has not been located. And based 

3 on the approach defined by NIOSH for STCs, 

4 this data is critical for assessment of dose.

5 And lastly, the petition raised 

6 the issue of Mound plant employee health 

7 records being removed from Mound and buried in 

8 Los Alamos, New Mexico. Implicit with the 

9 bound records burial in Los Alamos is whether 

10 the buried records contain dose reconstruction 

11 data that, one, are not available elsewhere 

12 and, two, are critical to conducting the dose 

13 reconstruction with sufficient accuracy.

14 The point is that a review of the 

15 classified set of records retrieved from MJW 

16 Corporation, by MJW Corporation from Los 

17 Alamos, which is available at OSTI, does not 

18 provide direct evidence that unique dose 

19 reconstruction information was available in 

20 the buried records. However, the only direct 

21 evidence that can be obtained is by digging up 

22 the records and reviewing them.
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1 I think that pretty well covers 

2 the points dealing with the data completeness 

3 issue.

4 Response?

5 DR. ULSH: I would first note that 

6 a number of these issues have been discussed 

7 at length at previous Working Group meetings, 

8 and I'm thinking specifically of the buried 

9 records issue. It is almost like that 

10 conversation never happened because here we go 

11 again talking about the same thing.

12 Also, I tried to catch all the 

13 issues that you mentioned, Bob. The first 

14 few, anyway, it seems to be it boils down to 

15 the dose reconstructor has to look in multiple 

16 places to get a complete file.

17 Without commenting on the merit or 

18 not of that, that may be true. It may very 

19 well be true. I don't see why that, in and of 

20 itself, would be an SEC issue.

21 If there's an instance where they 

22 didn't do that, that would certainly be a 
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1 valid criticism of the dose reconstruction. 

2 You might even be able to say we should alter 

3 our procedures to ensure that that was done 

4 for Mound dose reconstructions. I mean that 

5 would certainly be a valid criticism there, 

6 but that is not, in and of itself, an SEC 

7 issue.

8 Fecal data, yes, it's true, it's 

9 the same as everywhere else. You would like 

10 to have more fecal data, but, it was for 

11 various reasons, it wasn't done a lot, the 

12 same as everywhere else. When we have it, we 

13 use it. But, primarily, Mound used urinalysis 

14 data. So that is true.

15 MS. ROBERTSON-DEMERS: Can I 

16 identify something here? We are not 

17 necessarily saying that these issues are SEC 

18 issues because somewhere out there the data 

19 exists. We just want you guys to be using all 

20 the data available.

21 DR. ULSH: Noted. We will use all 

22 the data available. And where we don't, we 
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1 should expect to be criticized for that. And 

2 if it's not an SEC issue, why are we talking 

3 about it in an SEC meeting? That would be my 

4 question.

5 MS. ROBERTSON-DEMERS: Because we 

6 haven't closed out Items 12 and 13 yet.

7 DR. ULSH: If it's an SEC issue, 

8 we should be talking about it. If it's not an 

9 SEC issue, we should be talking about it 

10 either not at all or at TBD review or a dose 

11 reconstruction review, depending on where the 

12 issue would most appropriately fit.

13 Now, in terms of the tritium data, 

14 I don't know. It seems like you guys didn't 

15 get our response on this.

16 MS. ROBERTSON-DEMERS: Yes, you 

17 said that there were a lot of the books also, 

18 and the question is, what are you doing? Are 

19 you going and pulling those tritium bioassay 

20 data out of the log books, which are not 

21 necessarily in the individual exposure file or 

22 MESH?
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1 DR. ULSH: To answer your 

2 question, I don't know if we're doing that 

3 yet. Because what we said in our response was 

4 that, yes, we originally stated, and you 

5 accurately captured what we stated, and that 

6 was that pre-1982 data are available only in 

7 terms of the annual dose in MESH, but that is 

8 no longer accurate.

9 What is true now is we initially 

10 said that, but we discovered, I discovered a 

11 few sample pages that were captured by SC&A in 

12 September or October of 2008. Then, in 2009, 

13 I discovered those sample pages. That led me 

14 to re-request those boxes that SC&A had 

15 reviewed from DOE.

16 I went and we had a data capture. 

17 We opened up those boxes, and they're full of 

18 the tritium log books, the tritium bioassay 

19 data. So we captured them.

20 Now that happened fairly recently, 

21 the latter half of last year. So those have 

22 certainly been scanned and captured. Whether 
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1 or not they have been coded and are being 

2 routinely used in dose reconstruction yet, I 

3 can't say, but they certainly will be.

4 MS. ROBERTSON-DEMERS: Well, that 

5 is the bottom-line question, is whether they 

6 are being used in dose reconstruction.

7 DR. ULSH: Well, what I said was 

8 these data have been captured and will be 

9 available for tritium dose reconstruction. 

10 So, yes, we are committing to using that data 

11 as soon as we can get it in a form where it is 

12 routinely available.

13 And I would anticipate that this 

14 would probably result in a PER, where we would 

15 go back and look and make sure that either we 

16 redo the dose reconstructions as appropriate 

17 or determine that it's not necessary, just 

18 likes any other situation.

19 MS. ROBERTSON-DEMERS: The reason 

20 that we brought 12 and 13 up is because they 

21 have not been closed down.

22 DR. ULSH: I understand, but we 
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1 responded to those issues. It appears that 

2 those responses are not being registered.

3 I mean, if you want to say that 

4 our response is inadequate in some way, fine, 

5 we'll entertain that. But it's a little 

6 frustrating that it has not even been taken 

7 into account.

8 MS. ROBERTSON-DEMERS: I will 

9 repeat what I just said, okay, about all the 

10 different sources of internal dosimetry data. 

11 The problem is not that it doesn't exist, 

12 okay, because it does. The problem is making 

13 sure it is used in dose reconstruction. That, 

14 I'm telling you, is not an SEC issue, I agree 

15 with you.

16 DR. ULSH: Okay.

17 MS. ROBERTSON-DEMERS: Okay?

18 DR. ULSH: Do we need to keep 

19 discussing then?

20 MEMBER ZIEMER: Well, the data 

21 have been captured now, and the intent is to 

22 use it? That's what we're hearing.
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1 DR. ULSH: Well, specifically, 

2 Paul, the tritium log books that contain the 

3 early tritium bioassay data --

4 MEMBER ZIEMER: Yes, right.

5 DR. ULSH: -- have now been 

6 captured.

7 MEMBER ZIEMER: Right.

8 DR. ULSH: And we are at some 

9 point in the process in terms of making that 

10 available for dose reconstruction, yes.

11 MEMBER ZIEMER: Right.

12 CHAIR BEACH: Is there anything 

13 else, then, on --

14 DR. ULSH: Buried records.

15 CHAIR BEACH: Buried records, yes.

16 DR. ULSH: If it is the judgment 

17 of the Working Group that the only way to 

18 resolve this is to go dig up the records, I

19 would say it is pretty clear what the path 

20 forward is.

21 I didn't hear any new information 

22 in regard to this issue beyond what has 
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1 already been discussed extensively at, I 

2 believe it was, the last Working Group 

3 meeting.

4 I think I heard Bob say that MJW's 

5 review did not definitively show that there 

6 was unique bioassay data -- I might be getting 

7 some of this wrong, Bob -- in the buried 

8 records. But the only way to know for sure is 

9 to go dig up the records.

10 I can speak for NIOSH, I think, 

11 that we're not going to go dig up the records 

12 without compelling evidence that it contains 

13 unique bioassay data. Even if we did have it, 

14 I don't know that it would be feasible to do 

15 it. And even if it was done, I don't know 

16 what condition the records would be in to be 

17 used anyway.

18 I don't think the status on that 

19 issue has changed since it was discussed last 

20 time. I don't know what more we could 

21 provide.

22 MS. ROBERTSON-DEMERS: What we're 
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1 saying is we can't give you any direct 

2 evidence. We can't prove that what's down 

3 underground has that data. Okay? And the 

4 only way we could do it is to dig it up, so 

5 they will be scanned. They're not going to 

6 dig it up.

7 DR. ULSH: Well, then I would 

8 present to the Working Group, you have heard 

9 all the relevant information that NIOSH can 

10 provide. Correct me if I'm wrong, but I would 

11 say that you guys have probably done the same, 

12 and now it is in your hands. I don't know 

13 what else we could offer on that.

14 MEMBER CLAWSON: So it is proving 

15 a negative or --

16 DR. MAURO: This goes to the heart 

17 of every coworker model. We always have an 

18 incomplete database to reconstruct the dose 

19 for an individual, always. And usually there 

20 is a protocol. Every site has a protocol for 

21 dealing with how do you fill in information 

22 for missed dose and for workers who weren't 
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1 monitored but should have been.

2 Now this is very similar to the 

3 second case. There may very well be worker 

4 records that are not in a worker's file that 

5 are perhaps buried somewhere, whether it's 

6 bioassay or not. The question is, is the 

7 coworker model and the data on which it is 

8 based -- I presume we have a coworker model to 

9 fill in the blanks.

10 In other words, if you're 

11 reconstructing someone's dose in tritium, or 

12 external dose, you have a film badge or a 

13 bioassay record for that person. It is 

14 probably missing some information, and you are 

15 going to have to fill in the information. I 

16 assume you have a coworker model.

17 The question always becomes, 

18 whenever we deal with any SEC issue, do you 

19 have sufficient information to build a 

20 scientifically-sound claimant-favorable 

21 coworker model?

22 Now, when we were looking at the 
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1 records on which their coworker models are 

2 built that we find, usually the test we use 

3 for any site -- this goes to every site we 

4 look at -- we develop a little matrix. We 

5 say, okay, here's time and here's different 

6 job functions, and here are the different 

7 radionuclides as a function of time and job 

8 function that might be important to 

9 reconstruct a person's dose.

10 Can we, for each one of these 

11 little boxes, and we think about it like a 

12 Rubik's cube, every box, do we -- and I say, 

13 "we" -- have the wherewithal to reconstruct 

14 the person's dose who may have operated in 

15 that box at this time period doing this job? 

16 We know that he probably was exposed to 

17 certain radionuclides, but we don't have a 

18 complete bioassay record for him. Do we have 

19 a coworker model that can assign to him a dose 

20 with sufficient accuracy?

21 And this goes to the question of 

22 whether those records are lost or whether they 
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1 were never collected in the first place. So I 

2 think that really goes to the heart of the 

3 matter: Is the coworker model adequate? 

4 Notwithstanding the fact that there may be 

5 some records that either were lost -- it's 

6 almost like when we were talking NTS; there 

7 was a lot of badges that were left behind. 

8 There's no doubt about it. We interviewed 

9 enough people to say that.

10 But our research showed that, 

11 notwithstanding the fact that there were 

12 badges left behind, a coworker model could be 

13 built where you could assign, where we felt 

14 that the upper end of the distribution wasn't 

15 compromised by that process. As a result, a 

16 coworker model could be built.

17 What we have here is a similar 

18 situation. It sounds like it's clear that 

19 some records were buried.

20 DR. NETON: Well, we don't know 

21 that.

22 DR. MAURO: Oh, we don't know 
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1 that? Oh, okay. I didn't know that.

2 DR. ULSH: We do know, John is 

3 correct, we do know that some records were 

4 buried.

5 DR. MAURO: Okay. Now I'll take 

6 it --

7 MS. ROBERTSON-DEMERS: We have 

8 indirect evidence that there were RadCon 

9 records buried, but not direct.

10 DR. MAURO: Okay. I am just 

11 trying to look at it as, if I was doing the 

12 dose reconstruction, can I still do this 

13 person's dose reconstruction, notwithstanding 

14 the fact that there might be some records that 

15 are not there that were lost, buried, or never 

16 collected in the first place? If I can't do 

17 that, we've got an SEC issue because I can't 

18 reconstruct this person's dose with sufficient 

19 accuracy. I mean I guess that is the question 

20 on the table.

21 The fact that there may very well 

22 be buried records, I don't think that 
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1 necessarily means we have an SEC issue. Also, 

2 the fact that there might be some records that 

3 are buried that are bioassay records and, 

4 therefore, it is not a complete dataset, does 

5 not automatically mean you can't build a 

6 coworker model.

7 So I guess the question is, you 

8 know, do we have some question whether you can 

9 build a coworker model?

10 DR. NETON: Well, that is a 

11 different question. I mean, first, we start 

12 off talking about these records missing, and 

13 now you're saying that the coworker model 

14 should be robust --

15 DR. MAURO: Well, I mean, in the 

16 end, that's the only reason why it is 

17 important.

18 DR. NETON: Well, maybe we should 

19 talk about that. I haven't heard any 

20 criticism of the coworker model.

21 MS. ROBERTSON-DEMERS: Actually, 

22 there is a coworker model for polonium. There 
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1 is a coworker model for plutonium, period.

2 CHAIR BEACH: Paul?

3 MEMBER ZIEMER: The way I kind of 

4 look at this is, well, a couple of points. 

5 One is, if there were really a dearth of 

6 information, then gathering this additional, 

7 if there were additional, might be really 

8 critical. You have a really decent database 

9 here at this facility to start with.

10 One could even argue that there is 

11 some likelihood, if there were rad records 

12 there, they might be duplicates even. I mean 

13 that would be an argument. I don't have any 

14 real basis for that, but you could think about 

15 why would you bury some records and not 

16 others.

17 The other thing that I think is 

18 sort of practical, and we sort of have done 

19 this in other cases, is to ask a kind of cost20 effectiveness issue. What do we gain by the 

21 extra cost of -- what is the program gain?

22 It's my, I don't know if it is a 
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1 feeling or just more of kind of the picture I 

2 get from what I hear from DOE as well as 

3 others who have looked at this, is that 

4 retrieving those records is not a trivial 

5 exercise. If it were, it would have been 

6 done.

7 I'm not even sure DOE would be 

8 willing, without really compelling evidence, 

9 be willing to go in and dig those up. It was 

10 my understanding that that could be an issue 

11 with DOE even.

12 So you would have to say, well, 

13 what's the cost/benefit of that? If it is 

14 going to cost -- I don't know, pick a 

15 number --

16 MEMBER CLAWSON: Well, the last 

17 one was at $5 million.

18 MEMBER ZIEMER: Yes. If you're 

19 going to cost that, is it worth that, 

20 particularly with the dataset we have? So 

21 there's kind of a practical issue, too.

22 I think, at the end of the day, 
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1 you would have to say, yes, there is this 

2 possibility. Is it such that it's a show3 stopper in terms of, as you say, John, either 

4 a coworker model or just individual dose 

5 reconstructions?

6 So all you can say is, yes, that 

7 is a possibility. There may be more data out 

8 there that we don't have available.

9 MS. BRACKETT: This is Liz 

10 Brackett. Can I say something?

11 MR. KATZ: I'm sorry, do you want 

12 to repeat, Liz?

13 MS. BRACKETT: I just said my 

14 name, that's all. I wanted to throw something 

15 in.

16 MR. KATZ: Yes.

17 MS. BRACKETT: We discussed this, 

18 I believe, at the last meeting, and I don't 

19 have the documentation in front of me because 

20 I thought this was a closed issue. But I 

21 think it was in the MJW documentation. I 

22 mean, granted, we did not look at every single 
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1 box. We went looking specifically for 

2 bioassay data.

3 But, in our final report, it says 

4 that we did not find anything at Los Alamos 

5 that was not already at Mound in their 

6 microfiche. We verified that everything that 

7 had been sent out there that we looked at was 

8 already still present at Mound on site, and 

9 there was a discussion about the microfiche 

10 and what might have happened to that. I don't 

11 know, microfilm and microfiche.

12 DR. ULSH: Yes, you're right, Liz, 

13 that's exactly what I was referring to, the 

14 discussion at the last Working Group meeting. 

15 I don't believe that anything has changed 

16 since then, at least certainly not on our end. 

17 I haven't heard about anything that has 

18 changed on SC&A's end. I can't speak --

19 MEMBER CLAWSON: Liz, this is 

20 Brad. Let me ask you a question.

21 I remember this comment that was 

22 made out there. How much of it did you review 
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1 out there at Los Alamos?

2 MS. BRACKETT: Well, what I 

3 reviewed out there was a very small fraction 

4 of what got sent back. Unfortunately, I mean 

5 this was -- what -- 15 years ago? I don't 

6 remember the details.

7 MEMBER CLAWSON: I understand.

8 MS. BRACKETT: But on site, I 

9 didn't look at a lot. But, after going on 

10 site and finding polonium log books, we asked 

11 for something like 45 or 50 boxes to be sent 

12 back, I think. Those were looked at. There 

13 was a lot reviewed on site because it was all 

14 shipped back to the site.

15 MEMBER CLAWSON: And how many 

16 total boxes were buried?

17 MS. BRACKETT: I don't know that 

18 because I wasn't aware that they were buried 

19 until this whole thing started.

20 DR. ULSH: I think it's also 

21 important to put this into context. We are 

22 treating this like it is an unusual event. In 
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1 fact, it's not. DOE, and the government in 

2 general, have a records retention schedule. 

3 Records are destroyed in one way or another 

4 all the time. The requirements for keeping 

5 records depend on what kind of records they 

6 are.

7 Theoretically, at least, and 

8 everyone knows that no system is perfect, 

9 dosimetry records are supposed to be retained 

10 for -- I don't even know if there is a limit. 

11 It might be 75 years.

12 MR. HINNEFELD: I believe it is 70 

13 years, but that can be different --

14 DR. ULSH: Seventy years.

15 So you have to look at the weight 

16 of the evidence here. I think we have 

17 assembled the weight of the evidence, and now 

18 you just have to decide what you think about 

19 it.

20 We don't have anything that 

21 suggests that unique bioassay data was 

22 included in this lot of records that was 
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1 buried. We do know some of the other types of 

2 records that were buried. I mean it is listed 

3 in there, financial records, some engineering 

4 records, those kinds of things. But that 

5 doesn't violate any records retention 

6 schedule.

7 I just don't know what else could 

8 be provided. You can always speculate. 

9 Actually, I agree with SC&A; the only way to 

10 know for sure is to go out and dig them up, 

11 and I don't think that's even going to do it 

12 because who knows what condition the records 

13 would be in?

14 But you have to ask yourself, 

15 given the weight of the evidence that we have 

16 available, do you see a dramatic deficiency 

17 that would compromise our ability to do dose 

18 reconstruction with sufficient accuracy? I 

19 don't see it, but it's up to the Working 

20 Group.

21 CHAIR BEACH: What does the 

22 Working Group think about the data 
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1 completeness issue? It's kind of a separate 

2 issue.

3 What I have heard is the first 

4 couple of issues you brought up are TBD 

5 issues.

6 MS. ROBERTSON-DEMERS: That is 12.

7 CHAIR BEACH: That's 12? Okay, I 

8 guess I have these under 13 then.

9 MS. ROBERTSON-DEMERS: You mean 

10 because it's multiple records?

11 CHAIR BEACH: Yes. Well, under 

12 data completeness issue, I have that all 

13 listed under 13.

14 MS. ROBERTSON-DEMERS: Okay, data 

15 completeness is broken into, actually, data 

16 completeness, and then the Los Alamos records 

17 is the 13.

18 CHAIR BEACH: Okay. I just don't 

19 know that we should continue this conversation 

20 on the buried records. Unless someone feels 

21 differently, I think we should close out this 

22 issue. Because unless we get something from 
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1 NIOSH that they are going to dig up those 

2 records, then we just keep going back and 

3 forth on this same issue.

4 MEMBER CLAWSON: Jim brought up 

5 something, and I guess I'm just going to voice 

6 my opinion of why it kind of concerns me 

7 somewhat.

8 I know that we can fill in the 

9 gaps, and so forth, but to what accuracy? 

10 That gets into one of the real big questions 

11 and stuff.

12 They have just found what they 

13 have called log books, and they were tritium 

14 log books. Also, in all these buried records, 

15 it indicates that there were log books. Now 

16 they're saying that they're engineering ones, 

17 and so forth like that.

18 We have heard from so many 

19 petitioners, and so forth like that, that 

20 there was bioassay information that got 

21 buried, and so forth. Be it what it is or 

22 whatever else like that, it's kind of --
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1 CHAIR BEACH: So are you 

2 suggesting we ask them to --

3 MEMBER CLAWSON: No, I don't think 

4 that we can. I just want to voice my concern. 

5 When you get into data accuracy, or whatever, 

6 well, that's fine, I can take bits and pieces 

7 of it and make this model, but to what 

8 accuracy really is it? I have a problem with 

9 that. But I don't think we are going to be 

10 able to dig them up, either.

11 MS. ROBERTSON-DEMERS: Just for 

12 clarification, I'm not suggesting that we 

13 should go out and dig them up. I'm just 

14 suggesting that the only way we can give you 

15 direct evidence is to actually look at the 

16 records.

17 CHAIR BEACH: Right.

18 MEMBER CLAWSON: That's not going 

19 to happen. So I guess we can close it and go 

20 with what we've got and go from there.

21 MEMBER ZIEMER: Well, the other 

22 comment I think -- I don't know who made it; 
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1 maybe you did, John -- but just to emphasize 

2 that having 100 percent of the records at a 

3 site is not that common. It always comes down 

4 to, do you have enough ultimately to make the 

5 right decisions, whether it is an individual 

6 dose reconstruction or an SEC? Whatever that 

7 decision is, do you have the information you 

8 need to make that decision?

9 DR. MAURO: It's always the 

10 coworker, I mean when it is all said and done, 

11 it's always the coworker model that is in 

12 play.

13 MEMBER ZIEMER: Yes.

14 DR. MAURO: Always.

15 MEMBER ZIEMER: Yes.

16 DR. MAURO: And if you can't build 

17 a coworker model that is scientifically-robust 

18 and claimant-favorable, you've got an SEC.

19 MEMBER ZIEMER: Right.

20 DR. MAURO: If you have the 

21 data --

22 MEMBER ZIEMER: You either have an 
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1 SEC or the coworker model uncertainty gets 

2 bigger.

3 DR. MAURO: Yes. Oh, yes, but 

4 that's not a model, yes. To the point where, 

5 of course, then you go to the test of 

6 plausibility.

7 MEMBER ZIEMER: Yes, right.

8 DR. MAURO: I mean, in the end, 

9 this is the dilemma.

10 MEMBER ZIEMER: Right.

11 DR. MAURO: The horns of the 

12 dilemma we are always on, you know. And if 

13 you have very limited data, that puts you in a 

14 position to make an extremely claimant15 favorable coworker model, which places you in 

16 a place of, wait a minute, are we walking into 

17 the territory called plausibility? It's the 

18 same story.

19 MEMBER ZIEMER: Yes.

20 DR. MAURO: And the only reason I 

21 brought it up this way was that I think that 

22 the fact that records are buried, it would be 
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1 great if they weren't. But my question is, 

2 you know, do you have a robust coworker model 

3 for the various exposures and everything else 

4 we're dealing with?

5 We talked about a lot of subjects 

6 here. It sounds like you have lots of data. 

7 But, I mean, I haven't looked at it. I don't 

8 know if it is even an issue.

9 Is the coworker model one of the 

10 issues that we're looking at on this SEC 

11 review?

12 CHAIR BEACH: Under 13?

13 DR. MAURO: Yes, on one of these 

14 items.

15 CHAIR BEACH: Not that I'm aware 

16 of.

17 Kathy, John just asked if coworker 

18 was part of 13. I don't believe so.

19 MS. ROBERTSON-DEMERS: No, there's 

20 a coworker model for polonium. There's a 

21 coworker model for plutonium. That's what's 

22 available, and then I will let Ron speak for 
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1 the external.

2 And the concern for these buried 

3 records was not merely internal dose, but all 

4 dose.

5 MEMBER ZIEMER: Yes, could it 

6 affect other things besides dosage here?

7 DR. BUCHANAN: As far as I recall, 

8 we closed the external coworker model at 

9 Mound, SEC issues.

10 DR. ULSH: To clarify, I think it 

11 was external data completeness. Right?

12 MR. FITZGERALD: Yes. I don't 

13 know the number. Whatever the number was, 

14 yes.

15 DR. ULSH: Yes, I don't know the 

16 number, either. Okay.

17 CHAIR BEACH: So I guess I need to 

18 ask the Work Group what your thought is, 

19 either to leave it open or to close it at this 

20 point? And I am suggesting that we close it.

21 MEMBER CLAWSON: Buried records?

22 CHAIR BEACH: Thirteen.
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1 MEMBER CLAWSON: That is all we 

2 can do.

3 MEMBER SCHOFIELD: Say they are 

4 digging up the records in that area, and 

5 they're either digging everything up or we 

6 have done a lot of that, but the reality is 

7 you will have to assume all those records are 

8 now contaminated.

9 MS. ROBERTSON-DEMERS: They were 

10 from the beginning, yes.

11 MEMBER SCHOFIELD: Yes, but they 

12 are in worse shape now.

13 MS. ROBERTSON-DEMERS: Yes.

14 MEMBER SCHOFIELD: This is based 

15 on some of the workers who were out there 

16 working in that hot area, repacking and 

17 things. We will have to assume that they are 

18 just beyond reach forever.

19 CHAIR BEACH: Okay. So 18 and 19 

20 was closed. It was adequacy, completeness of 

21 external dose records, and we closed it on May 

22 27th.
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1 MEMBER ZIEMER: Well, I agree we 

2 should close this issue. I think it is fine 

3 if the record shows that there's potential 

4 records there that couldn't be used. I mean 

5 you'll use what you have. In my mind, there 

6 are enough records to make an adequate, if you 

7 can get the coworker, to make it, and it could 

8 be somewhat modified, if you had some other 

9 data.

10 But, as you said, John, this is 

11 like others where you're going to work with 

12 what you have. If it's inadequate to bound 

13 doses, then you go in one direction. If you 

14 believe it is adequate to bound, you go in 

15 another direction.

16 So I think the possibility that 

17 Kathy raises is probably you have to say it is 

18 a real possibility, but we are probably not 

19 going to get those records, if they exist.

20 MS. ROBERTSON-DEMERS: I guess the 

21 question becomes, you've got a coworker for 

22 polonium; you've got one more for plutonium. 
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1 Do you need one for anything else?

2 MEMBER ZIEMER: Oh, well, that may 

3 be a separate question, I guess.

4 MS. ROBERTSON-DEMERS: And that's 

5 actually a new question.

6 MEMBER ZIEMER: Yes.

7 MEMBER CLAWSON: Well, that comes 

8 down to, do we have the right coworker models 

9 for Mound? I know at some sites we use a 

10 bounding one, but --

11 MEMBER ZIEMER: Well, I can't 

12 answer that. I mean you're addressing it to 

13 staff. Are there other --

14 DR. ULSH: No, Kathy is correct. 

15 The coworker models that are in place for 

16 Mound are polonium and plutonium because those 

17 were the primary radionuclides of interest at 

18 Mound.

19 The other one that you could maybe 

20 make a case for would be tritium. What I can 

21 tell you is that tritium was confined; the 

22 operations occurred in certain areas, access-
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1 controlled areas. If you went into the 

2 tritium building, you were on tritium 

3 bioassay, with the exception that Kathy 

4 specified yesterday, you know, in the DOE era, 

5 the 54, whatever it is. You know, if it's 

6 less than 100 millirem, you don't have to be 

7 monitored.

8 But, prior to that, if you went to 

9 work in those buildings, you were on tritium 

10 bioassay. So it is our position that we don't 

11 need a coworker model.

12 The same with external, and I 

13 think we discussed this at one of the early 

14 Board meetings as well, our basis for 

15 concluding that. I think that went into the 

16 decision to close out the data 

17 adequacy/completeness issue for external.

18 CHAIR BEACH: Well, if you go back 

19 and you look at our matrix, we actually 

20 combined 12 and 13. Under 13, without reading 

21 it, I know you can go back and look at it 

22 yourself, that closes out the 453 boxes. 
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1 Basically, we would be leaving the top 

2 paragraph open, No. 12, and closing out 13.

3 MEMBER CLAWSON: What was No. 12?

4 CHAIR BEACH: It was the internal 

5 dosimetry data completeness. I don't know if 

6 you have --

7 MEMBER CLAWSON: I've probably got 

8 it, but it's in my file.

9 CHAIR BEACH: But, from the way we 

10 wrote it up, it doesn't affect anything but 

11 what we have just discussed on the buried 

12 records, basically.

13 MR. FITZGERALD: The two are 

14 combined because they are two different facets 

15 of the same issue.

16 CHAIR BEACH: Phil, what's your 

17 thoughts?

18 MEMBER SCHOFIELD: I think we can 

19 close this issue and, like I said, personally 

20 knowing Area G, those records are a dead 

21 issue. I mean there's just absolutely no way, 

22 regardless of what is in them, that we will 
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1 ever have access to them.

2 CHAIR BEACH: Okay. So I would 

3 say that we officially close 13, the external 

4 data completeness portion of the matrix. Do 

5 you need more words?

6 DR. ULSH: You said "external".

7 CHAIR BEACH: Yes.

8 DR. ULSH: Is that what you meant 

9 to say?

10 CHAIR BEACH: Oh, I'm sorry. 

11 Internal.

12 DR. ULSH: Okay.

13 CHAIR BEACH: Data completeness. 

14 Excuse me. Internal. Yes, that's correct.

15 DR. ULSH: Well, I don't know 

16 where you are headed, but are we going to 

17 discuss other aspects of this issue? I mean I 

18 think what you did was just close the buried 

19 records issue.

20 CHAIR BEACH: Yes.

21 DR. ULSH: But there's still other 

22 things --
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1 CHAIR BEACH: Well, 12 and 13 were 

2 combined.

3 DR. ULSH: Yes.

4 CHAIR BEACH: So I don't want to 

5 mistake that we have closed 12. We have only 

6 closed 13.

7 DR. ULSH: I understand.

8 MR. FITZGERALD: I think he's 

9 asking for some clarification on it.

10 DR. ULSH: Well, I guess what I'm 

11 asking, Josie, is, are there further actions, 

12 not the buried records part, but the other 

13 part that's not closed yet, are you requesting 

14 any further actions from NIOSH?

15 CHAIR BEACH: I think what we need 

16 to do is go back and look at that separately 

17 and see if there's anything more, after 

18 looking at your White Paper, if some of the 

19 answers you gave are not complete or not 

20 satisfactory to SC&A.

21 MEMBER CLAWSON: That would be 

22 covering the coworker models or --
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1 DR. ULSH: We haven't spent a lot 

2 of time on coworker models.

3 CHAIR BEACH: No, we haven't. No, 

4 that's separate from what --

5 DR. MAURO: In a way, for example, 

6 the conversation we had earlier on this gross 

7 alpha protocol, where in the early years they 

8 were collecting urine samples and then 

9 precipitating all the alpha emitters out, and 

10 I would say that you have, apparently, a lot 

11 of data in the gross alpha activity in urine 

12 without going to isotopic specific.

13 We talk about, in my little 

14 Rubik's cube picture, okay, so there's this 

15 time period where people were working with 

16 some suite of radionuclides that were 

17 transuranics or actinides. That is well18 documented in the literature. Okay?

19 Then the question becomes, well, 

20 how are you going to reconstruct the doses to 

21 the workers who might have been working with 

22 that material at that time period? And the 
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1 answer, I guess, is, well, what we have is 

2 data on all these workers, and we have all the 

3 gross alpha activity.

4 Now it turns out, however, one of 

5 the issues that came out regarding adequacy of 

6 data, which is really the subject, is, well, 

7 it seems that there's some question whether 

8 all of those different forms of the actinides 

9 were, in fact, precipitated out at a 90 

10 percent level or an 80, whatever the percent 

11 number is that you are going to pick.

12 In effect, you are going to ask 

13 yourself the question, am I in a position 

14 where I could assign a dose to these workers, 

15 making some assumptions on what the recovery 

16 was?

17 MEMBER ZIEMER: Don't we have a 

18 follow-up action?

19 DR. MAURO: Yes, we do, and we 

20 haven't found out -- no, I'm trying --

21 MEMBER ZIEMER: That's what we're 

22 waiting on for that? Is that it?
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1 DR. ULSH: We do have a follow-up 

2 action on recoveries, yes.

3 DR. MAURO: I do have a place 

4 where I'm going with this. So what I am 

5 saying is we have gone down a very linear 

6 process to deal with that question.

7 But now, superimposed on that is, 

8 okay, good, you've got a way to adjust or to 

9 make use of this gross output data. However, 

10 do you have it for all the workers you need to 

11 have it for, and all the different buildings, 

12 and all the different time periods that are 

13 necessary?

14 Because, you know, for example, 

15 there may be some workers that worked in a 

16 given building in a given different time 

17 period where you don't have that sample. 

18 There may be a lot of workers. There may be 

19 categories of workers that did a certain job. 

20 This goes back to over and over again we're 

21 in the same position, which means that you 

22 have to build a coworker model.
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1 And it's, oh, okay, we do have a 

2 bunch of workers that worked in this building 

3 -- I'm talking in principle -- in this 

4 building at this time period, where we don't 

5 have that data. Okay? We don't have that 

6 data.

7 If we don't have the data, that 

8 means you are going to have to assign, but you 

9 do believe there's a real possibility they may 

10 have inhaled some of this stuff. Well, that 

11 means you have to build a coworker model.

12 Now the test that we put that to 

13 is, okay, do you have enough data for that 

14 time period for that category of worker or at 

15 that building that you could build a 

16 distribution, you know, enough data to build a 

17 distribution that says, yes, the exposures 

18 look like this for the workers? It may be 700 

19 or 1,000 measurements made for that time 

20 period in that building.

21 Well, in my mind, if each of those 

22 measurements have been appropriately developed 
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1 by taking into consideration recovery, you're 

2 in a position now where you could pick off and 

3 assign, you're in a position now to build the 

4 coworker model; that is, either to assign the 

5 full distribution or the upper 95th percentile 

6 to any given worker that, for some reason, was 

7 not monitored.

8 So, in a way, everything we are 

9 really talking about goes toward really the 

10 coworker model. I mean there are technical 

11 issues embedded, like recovery fractions, that 

12 certainly you have to deal with. But if you 

13 can't deal -- see, the problem that comes, if 

14 you can't deal with the recovery fraction 

15 properly, you can't build that coworker model.

16 MS. ROBERTSON-DEMERS: First of 

17 all, the reason we didn't do a Nevada-type 

18 data comparison is because MJW did a rather 

19 extensive QA on the polonium and plutonium 

20 data during the pre-1989 dose reconstruction 

21 process, and we accepted that.

22 DR. MAURO: Okay.
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1 MS. ROBERTSON-DEMERS: Okay? For 

2 those two radionuclides.

3 It kind of goes back to what we 

4 were discussing earlier. We have identified 

5 gaps in the data based upon what's in the 

6 [identifying information redacted] document, 

7 but now we're being told that the [identifying 

8 information redacted] document is not the 

9 tell-all of things, and that we need to go 

10 back and provide further examples on where 

11 material was handled.

12 The comparison has already been 

13 done to the [identifying information redacted] 

14 document, but now the [identifying information 

15 redacted] document has gone away. So now that 

16 comparison has to be made to something else.

17 CHAIR BEACH: Okay. So, on 13, 

18 Kathy brought up originally in the internal 

19 completeness records several different issues. 

20 So what I would like to do is get back to you 

21 on exactly where we are at with the remaining 

22 issues, if that works.
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1 DR. ULSH: Yes.

2 CHAIR BEACH: Okay.

3 DR. ULSH: And I would just add 

4 one small comment to what John said.

5 Think about other sites, and I'm only 

6 going to use this one because I can't think of 

7 another one, and I hate doing it.

8 MEMBER CLAWSON: Oh, no.

9 DR. ULSH: Thorium at Rocky Flats, 

10 I thought I would never speak those words 

11 again.

12 (Laughter.)

13 But the situation is that, for 

14 instance, at Rocky Flats, the primary 

15 radionuclides are plutonium and uranium. You 

16 don't build a coworker model for all of these 

17 little exotics because, No. 1, there wasn't a 

18 large exposure potential to a large group of 

19 people, and consequently, you don't have a 

20 large enough population of urinalysis results 

21 or other results to make a valid coworker 

22 model, nor do you really need one.
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1 I would present to you, John, that 

2 at Mound the ones where you really need a 

3 coworker model are polonium and plutonium, and 

4 that's why we chose those two. You could go 

5 through the laundry list, like in the 

6 [identifying information redacted] document.

7 So I'll just pull out one off the 

8 top of my head, iron-59, I think. That is an 

9 exotic that is listed in [identifying 

10 information redacted]. I'm not saying that 

11 there was an exposure potential to that.

12 You wouldn't build a coworker 

13 model for that because we would say that, 

14 well, first of all, I think for that 

15 particular one, there is no exposure 

16 potential. But, okay, that's maybe not a good 

17 example.

18 Curium, a small, discrete 

19 situation. You wouldn't necessarily need a 

20 coworker model, the assumption being, of 

21 course, that if there was an exposure 

22 potential, they were monitored for it.
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1 So I would say to you that a lot 

2 of these other radionuclides are in that 

3 category where they are not of a sufficient 

4 scale to warrant a coworker model.

5 DR. MAURO: I hear what you are 

6 saying. I understand that. There's the whole 

7 suite of radionuclides, and you say to 

8 yourself, well, in the end, we know certain 

9 radionuclides were present. Okay?

10 And what you're telling us is 

11 that, well, there's certain radionuclides that 

12 might have been present, but you feel, and 

13 maybe rightly so, that they were not handled 

14 in sufficient quantity and in a manner that 

15 could have contributed importantly to anyone's 

16 dose.

17 DR. ULSH: Absolutely correct.

18 DR. MAURO: Now I think the fact 

19 that the material was there, present at the 

20 site, and you have some knowledge of how much 

21 of it was used and under what conditions it 

22 was used, needs to be disclosed because that 
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1 becomes the basis for your not including them 

2 in your dose reconstruction.

3 I mean I would think, if I were 

4 doing the dose reconstruction, and I was held 

5 accountable for that, and I knew that this 

6 worker worked in this building at this time, 

7 and I knew that there were certain 

8 radionuclides there, I would take it upon 

9 myself to say, okay, I have to convince myself 

10 that by not including the actinium or this 

11 isotope or that isotope, I did not 

12 underestimate this dose because of the way in 

13 which that material, the quantity and the way 

14 in which the material was handled.

15 And I could look in the mirror and 

16 say, you know, I feel good, and I could tell 

17 this person whose dose reconstruction I just 

18 did I think that we did the right thing by 

19 them.

20 And that's the judgment you are 

21 making right now. I don't know the extent to 

22 which all of that has been documented, of 
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1 their rationale, but not including a coworker 

2 model or a database for many of these, we'll 

3 call, exotic radionuclides, the ones that you, 

4 for example, you pointed out there's a time 

5 period when actinium was there, but there is 

6 no bioassay data for it.

7 And the argument that is being 

8 made is, well, you know, based on everything 

9 you could tell, there is no reason why anyone 

10 would have been exposed to any significant 

11 extent during that time period.

12 Now, interesting, who has the 

13 burden of proof?

14 DR. NETON: Well, I guess look at 

15 the question, John. I think the question is, 

16 there was no activities and there was no 

17 monitoring is a different question than there 

18 were activities, and we're saying monitoring 

19 wasn't required.

20 DR. MAURO: Well, I would say --

21 DR. NETON: That's different. 

22 That's a different question.
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1 DR. MAURO: No, I'm just thinking, 

2 as a health physicist thinking about the 

3 problem, I think in the case of the actinium, 

4 because there was comprehensive attention, 

5 detailed attention, to it during this time 

6 period here, and then nothing over here, and 

7 then, again, in this time period, I guess I 

8 would say -- I'm always afraid to go down 

9 these roads because I'm not a Board member. 

10 I'm just one of the guys sitting around the 

11 table.

12 But it sounds to me that they had 

13 the wherewithal to make prudent judgments, and 

14 they made some prudent judgments in the back 

15 end of the process to monitor for actinium 

16 when they were digging that stuff up, because 

17 they knew there was the potential.

18 So I have to say, just me asking 

19 myself the question, I think they probably did 

20 the right thing by actinium because there's 

21 every reason to believe they understood what 

22 they were dealing with and they knew what to 
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1 do, when to do it.

2 Now is that convincing enough for 

3 you or for you? I don't know.

4 The same thing goes for the other 

5 radionuclides. Now, apparently, there's a 

6 long laundry list of radionuclides. Each one, 

7 somehow, a person has to come to grips with 

8 themselves as a health physicist and say, 

9 listen, am I doing the right thing by the 

10 workers by not including some contribution 

11 from this source?

12 And if you say no, in the end, 

13 unfortunately, in the end, implementing all 

14 these guidelines becomes ultimately a degree 

15 of subjectivity that we collectively have to 

16 think was designed here.

17 Now I don't know. There's these 

18 other radionuclides we're talking about. So I 

19 don't know. I think you mentioned a number of 

20 them.

21 You know, what are some of the 

22 radionuclides that you do? It might have been 
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1 important. The cobalt is good. Those are 

2 good. The cobalt, cesium, and strontium, now, 

3 apparently, they were there. Okay?

4 Right now, there are time periods 

5 when we know that they were there, but you're 

6 not reconstructing the doses to some workers 

7 from those in those years. Now there's got to 

8 be a reason why you feel it's okay not to 

9 include that, and I think that has to be 

10 articulated, your rationale for not explicitly 

11 addressing those.

12 DR. NETON: I think this goes to 

13 the action item that SC&A picked up in the 

14 morning session, I think, which is to identify 

15 those activities where we don't feel there are 

16 any there. You're going to put together a 

17 list that says, hey, but this stuff was here, 

18 and they were doing something with it. Prove 

19 to us why bioassay was not necessarily 

20 required for these activities.

21 DR. MAURO: Is that something you 

22 would like us to do or them to do?
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1 CHAIR BEACH: No, we're okay. I 

2 think we already solved that.

3 Okay. So we're finished with 

4 that, with issue 13. It's closed.

5 I would like to go ahead and move 

6 on to the shallow dose issue briefly before 

7 break.

8 I know Ron does have a --

9 MR. FITZGERALD: Ron has a flight 

10 to catch.

11 CHAIR BEACH: -- flight to catch.

12 MR. FITZGERALD: We're moving that 

13 one up.

14 CHAIR BEACH: Which I mentioned 

15 right after lunch.

16 So, Ron, if there's no objection, 

17 you're on.

18 DR. BUCHANAN: Okay. The shallow 

19 dose issue, of course, stems from the fact 

20 that there was some low-energy photons and 

21 beta exposure at Mound. In the beginning, 

22 there was some, but not a lot. Off and on, 
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1 there was beta and low-energy photon exposure 

2 potential at Mound.

3 They did some badging. They 

4 didn't always read the badges, and they didn't 

5 become DOELAP-accredited until 1991. So SC&A 

6 raised concerns a year or two ago that the 

7 data wasn't there to assign dose during dose 

8 reconstruction.

9 So NIOSH came out with a review of 

10 Mound site shallow dose prior to 1991, issued 

11 a White Paper in March of 2009.

12 SC&A reviewed this White Paper and 

13 presented their results, I believe, at the May 

14 28th Working Group meeting here.

15 What NIOSH proposed in Table 4 of 

16 the March 2009 White Paper was to do some 

17 adjustments based on some correction factors, 

18 mainly a ratio of the gamma ray to calculate 

19 the shallow dose at certain times in certain 

20 operations, because it was a facility 

21 widespread problem. It was certain operations 

22 at certain times in certain locations.
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1 So SC&A reviewed that, then, their 

2 White Paper, and pretty much agreed with the 

3 concept they presented in Table 4 of their 

4 March 2009 White Paper, except we felt that 

5 the period 1979 through accreditation in 1991 

6 was left out and should be addressed, because 

7 in the original White Paper, they said that 

8 this would be used as stated in the dose of 

9 record.

10 So NIOSH responded in September of 

11 2009 with another White Paper which had some 

12 modification. In Table 1 of that White Paper, 

13 they do make adjustments up through June of 

14 1991, when Mound became accredited for beta 

15 and low-energy photon dosimetry.

16 So SC&A reviewed that. We did not 

17 go into all the correction factors and how 

18 they were derived, and NIOSH did not state 

19 numerical values for all of them.

20 However, from a concept point of 

21 view, SC&A finds that this is not an SEC 

22 issue, that if there are items or issues, it 
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1 would be with a Site Profile, you know, the 

2 No. 1.2 or 1.3, or something like that, as 

3 opposed to not being able to reconstruct 

4 adequate shallow dose.

5 So, at this time, SC&A recommends 

6 that, if these conditions in the revised White 

7 Paper of September of '09 are implemented, 

8 that we do not have an SEC issue with this.

9 CHAIR BEACH: Any comments back?

10 DR. BUCHANAN: That's issue 16 --

11 CHAIR BEACH: Pretty easy on that 

12 one.

13 So the last thing that the Work 

14 Group asked was that NIOSH comment to SC&A's 

15 April White Paper, which they have done, and 

16 we are hearing the report now from Ron that 

17 SC&A is satisfied with the answers from NIOSH.

18 So I guess I would ask the Working 

19 Group if you're ready to close this item, 

20 based on SC&A's response and NIOSH's?

21 MEMBER CLAWSON: Yes.

22 MEMBER ZIEMER: Yes.
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1 CHAIR BEACH: Everybody's in 

2 agreement? Okay. So, then, I would suggest 

3 that this item be considered closed. So one 

4 more.

5 Are you ready for the break?

6 MEMBER ZIEMER: I'm glad you 

7 stayed for that, Ron.

8 CHAIR BEACH: Yes, thank you. 

9 That was easy.

10 DR. ULSH: Josie, after our break, 

11 what's next? Is it plutonium-238?

12 CHAIR BEACH: Yes.

13 DR. ULSH: Liz, what's your 

14 schedule?

15 CHAIR BEACH: We can do it now, 

16 also.

17 MS. BRACKETT: I have another 

18 conference call at 3:00, but I can skip that, 

19 if needed. I don't think Tom is on because I 

20 think he's probably traveling by now.

21 DR. ULSH: If you can skip it, 

22 that would be great.
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1 MS. BRACKETT: Okay.

2 DR. ULSH: Thanks.

3 CHAIR BEACH: So would you prefer 

4 to not take a break and just go right into it?

5 DR. ULSH: No. No, no.

6 CHAIR BEACH: No, no. You want a 

7 break. Okay.

8 DR. ULSH: Yes.

9 CHAIR BEACH: Let's do that then. 

10 So 10 minutes?

11 MR. KATZ: Okay, until 35 after.

12 CHAIR BEACH: So 2:35, yes.

13 (Whereupon, the above-entitled 

14 matter went off the record at 2:24 p.m. and 

15 resumed at 2:39 p.m.)

16 MR. KATZ: Okay, this is the Mound 

17 Work Group, and we are just getting started 

18 again after a brief comfort break.

19 We are on to perhaps our last --

20 CHAIR BEACH: Oh, no.

21 MR. KATZ: No?

22 Nice try, though. Nearly our last
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1 agenda item.

2 CHAIR BEACH: Yes. Okay, so we 

3 are going to get started with high-fired 

4 Pu-238.

5 Brant, are you ready?

6 DR. ULSH: Oh, no. I'm trying to 

7 pick up the thread about where we left this 

8 issue.

9 This is another issue, just like 

10 all the rest, where we have had a number of 

11 iterations here.

12 CHAIR BEACH: Yes.

13 DR. ULSH: I think the last 

14 significant event was our issue of our 

15 response, and that came out in September of 

16 2009. That document was two parts. Now it's 

17 coming back to me.

18 Our document was meant to respond 

19 to two of SC&A's documents on this issue. One 

20 I think was the White Paper, and we went 

21 through in the normal point-by-point format 

22 for that.
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1 I think the second one was the 

2 additional material that was sent over related 

3 to, I think prepared by Rich Leggett --

4 MR. FITZGERALD: And Joyce.

5 DR. ULSH: -- and Joyce.

6 So our responses I think are on 

7 the table there. I guess, rather than walk 

8 through the 20, or whatever, issues, 22 

9 issues, I guess I would just like to say, you 

10 know, what is it you guys, what's still 

11 hanging out there that you want to discuss on 

12 this?

13 MR. FITZGERALD: I am going to 

14 summarize this.

15 Joyce, are you still on? Joyce 

16 Lipsztein?

17 (No response.)

18 DR. ULSH: Well, I guess I should 

19 ask, is Liz Brackett there still?

20 MS. BRACKETT: Yes, I'm here.

21 DR. ULSH: Okay.

22 MR. FITZGERALD: Okay. Well, let 
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1 me try to summarize it.

2 I thought the last exchange was 

3 pretty productive. I think we did start out 

4 with a number of issues. I sense and I 

5 observed we converged to the point where it's 

6 really the assignment of what we're calling a 

7 type J dissolution model versus what I think 

8 NIOSH has coined as type L. I'm losing track 

9 of these letters, but I think that is where we 

10 left it.

11 You know, certainly one comment 

12 has been -- well, if we're talking about which 

13 version of the dissolution model should be 

14 applied, is that an SEC issue? I think what 

15 we are looking at at this point is which one 

16 would be bounding of the phenomena that may 

17 have existed or that would have existed at 

18 Mound during the handling of Pu-238 at the 

19 site.

20 I want to just tick off the -- I 

21 wouldn't call them arguments, but the comments 

22 that we have that would support the type J 
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1 model that was based on an event at Los Alamos 

2 that we think has pertinence for Mound.

3 First off, even though it was 

4 based on a Los Alamos event, we think there is 

5 a high likelihood that the pellets involved 

6 did come from Mound. Mound produced most of 

7 those cermet pellets back then.

8 So let me just go through that and 

9 just try to cut to the quick, because I think 

10 we have made a lot of progress. We have 

11 converged this thing down to what would be the 

12 most appropriate bounding model.

13 Unless Joyce joins us -- Joyce, 

14 are you there?

15 DR. LIPSZTEIN: Yes, I'm here.

16 MR. FITZGERALD: Okay. We can 

17 talk about the model after I just kind of 

18 outline why we think the type J is a better 

19 fit.

20 DR. LIPSZTEIN: Okay. We don't 

21 know what is the best model, and we don't know 

22 exactly what kinds of, now let's call it, non-
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1 monotonic behavior of plutonium to circulate, 

2 which one is the best fit for Mound.

3 The only thing we know is that the 

4 type J that was at Los Alamos, observed at Los 

5 Alamos, is the most claimant-favorable model. 

6 We know that some of the plutonium-238 heat 

7 sources, the molybdenum cermet disc, most of 

8 them that were handled at Los Alamos came from 

9 Mound. So this makes us think that probably 

10 Mound workers could be exposed to type J also.

11 The other problem is that at Mound 

12 people, workers, could be exposed to various 

13 -- there were various techniques that were 

14 used at Mound for the production of heat 

15 sources, not just one technique.

16 So we think that the most 

17 restrictive model should be used for Mound. 

18 For example, there was the development of a 

19 model by NIOSH which was type L, and then we 

20 found some data that were more restrictive 

21 than type L, and things like that.

22 So I think that the best thing 
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1 would be to go to the most restrictive one 

2 that we can find and that is possible to be 

3 found at the Mound, which we think is the 

4 model that was found in the accident at Los 

5 Alamos National Laboratory.

6 DR. NETON: If I can jump in real 

7 quickly, I'm recalling this conversation now 

8 that Tom Lebone was involved at that time. I 

9 believe that Tom's -- the type L model was 

10 based on Mound-specific data.

11 DR. LIPSZTEIN: Yes.

12 DR. NETON: Some folks that Tom 

13 saw that clearly showed evidence of an 

14 incident, and he could model.

15 The J values from Los Alamos, if I 

16 remember correctly, Tom made some comments to 

17 the effect, and I think it's actually an 

18 appendix to one of the White Papers, that the 

19 generation of that type J material was the 

20 result of some very unique set of 

21 circumstances that caused that to happen.

22 We were at that time unconvinced 
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1 that that scenario actually happened at Mound.

2 DR. ULSH: I can give more detail, 

3 if you would like.

4 DR. NETON: Okay, yes, go ahead, 

5 Brant.

6 DR. ULSH: Joyce, I think that we 

7 would probably agree that there's at least a 

8 reasonable likelihood -- in fact, it is 

9 probably probable -- that that material 

10 involved in the incident at Los Alamos 

11 originated, was prepared, originally 

12 manufactured at Mound. I don't think that we 

13 would say otherwise, barring evidence to the 

14 contrary.

15 But Tom's point was that it's not 

16 just the identity of the material, but the 

17 particular details of what happened at Los 

18 Alamos that contributed to the generation of 

19 this material.

20 First of all, let me see if I can 

21 recall the details here. And, Liz, you jump 

22 in and correct me where I go off the rails.
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1 I think it has got to be 

2 relatively fresh material because the problem 

3 with, well, the issue with plutonium-238 is 

4 that it has got a high specific activity. So 

5 it breaks up the matrix in relatively short 

6 order. That is why it is different from, say, 

7 for instance, Super S 239, plutonium-239.

8 What happened at Los Alamos was 

9 they were cutting apart a heat source, I 

10 believe, immediately after or very shortly 

11 after they did extensive vibration testing. 

12 So it generated a respirable aerosol.

13 I think what happened was they 

14 overpressured a glove. They overpressured the 

15 chamber in which they were cutting on this 

16 heat source and it blew this material. Once 

17 they cut into it, the freshly-generated 

18 aerosol, it blew out into the room and exposed 

19 some people.

20 Now, at Mound, what you had was, I 

21 think this was what was called the microsphere 

22 program, maybe not officially. But they would 
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1 drop plutonium-238 through a plasma torch and 

2 make microspheres.

3 Now the microspheres themselves 

4 are not respirable. I mean, from a 

5 respiratory standpoint, they look like 

6 boulders.

7 So that's not an issue at Mound. 

8 It is only the unique exposure conditions, I 

9 think, that Tom documented, and he actually 

10 interviewed some of the people that were 

11 investigated at the Los Alamos incident. I'm 

12 fuzzy on the details.

13 So it was our contention that, 

14 yes, the material probably did come from 

15 Mound, but it was the unique conditions that 

16 occurred during this incident that led to the 

17 formation of this type J material.

18 Liz, have I captured it 

19 accurately?

20 MS. BRACKETT: Yes, that sounds 

21 right, that they had done some vibration 

22 testing for something like 40 days. It was 
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1 some very long test.

2 Unfortunately, I had hoped that 

3 Tom could be here because he's the one who has 

4 worked on all this. He was available all day 

5 yesterday until about noon today, but we just 

6 missed him.

7 DR. LIPSZTEIN: Let me put it in 

8 another way, then. What we all think 

9 together, I think NIOSH and SC&A, they all 

10 believe that there might be some kind of model 

11 that would be a bounded model for this non12 monotonic material, right? Okay.

13 So there was the development of a 

14 model by NIOSH that would describe very well 

15 the accident that happened at Mound, one 

16 accident that happened at Mound. Then we 

17 found another accident at Mound that was not 

18 bounded by that specific model. On the 

19 contrary, the other model was more, let's say, 

20 more restrictive than the one that was 

21 developed by NIOSH.

22 We had several discussions about 
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1 all the urine data and all the graphs that you 

2 have provided us. I remember specifically Jim 

3 saying you don't expect us to go through all 

4 those thousands of graphs and try to develop a 

5 model for anyone that looks like -- that had a 

6 pattern that would come up and down. And it's 

7 true, you cannot do that.

8 So I think we have to have a model 

9 that is bounding. So, if you have a model 

10 that is bounding, and we don't want to analyze 

11 all the data that exists for Mound and make 

12 all the scenarios that could have happened. 

13 So that those graphs were developed, we have 

14 to have the most bounding model, the one that 

15 is more restrictive that delivers the higher 

16 dose to lung and to systemic tissues, right?

17 So, because type J really happened 

18 in an installation, and because people could 

19 have been exposed to type J at Mound, because 

20 there was this material there, and because 

21 there were other processes in which workers of 

22 plutonium-238 were involved and handled, then 
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1 we think that the most bounding as possible 

2 model has to be applied to be claimant3 favorable and not to err. If we err, we err 

4 on the side of the claimant.

5 So that's why we think type J 

6 would be a better model for Mound and for all 

7 plutonium-238 non-monotonic exposures.

8 DR. ULSH: Okay. Jim and I are 

9 having a little sidebar conversation here, and 

10 it is triggered by what you are saying, Joyce.

11 I'll just put an idea on the table 

12 for discussion. We have reasons for 

13 preferring type L because that was developed 

14 on Mound-specific data. But what if we 

15 committed to, as we do dose reconstructions at 

16 Mound, if we come across one or two, or 

17 however many, that don't appear to fit type L, 

18 then we would certainly entertain the 

19 possibility of using type J or whatever model 

20 is appropriate for that particular dose 

21 reconstruction.

22 DR. LIPSZTEIN: Yes, we gave you 
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1 an example of two people that we knew that 

2 were exposed in an accident at Mound and whose 

3 type L didn't fit because you had another fix. 

4 So that's why we don't know.

5 So, if we don't know, we have to 

6 apply the one that gives the highest dose, 

7 which would be type J. And it's not 

8 implausible because, as you say, the

9 molybdenum cermet discs came from Mound.

10 DR. NETON: Let's back up a little 

11 bit, though.

12 I think where we have a sufficient 

13 number of bioassay points, we would probably 

14 fit the model ourselves. I mean there would 

15 be no reason to -- you know, we wouldn't 

16 blindly default to a type L model if the 

17 bioassay data itself, themselves, would not 

18 appropriately fit that model.

19 So I think really what we are 

20 talking about here is what our default would 

21 be in the absence of sufficient bioassay data. 

22 Isn't that more correct, Liz? I think that 
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1 is what we are talking about here.

2 DR. LIPSZTEIN: Yes, it's not 

3 treated well to develop a model for each 

4 exposure for each worker. You don't do this 

5 for the others, for example, type S. Type S 

6 plutonium, it's not everybody behaves like 

7 type S plutonium. Actually, you have 

8 particular parameters for the lung that are 

9 not exactly type S, but, yes, you apply type 

10 S. Type M also, it's not particular for that 

11 worker. For each worker, the lung parameter 

12 will behave differently.

13 For me, it doesn't make sense to 

14 develop a model for each worker that could be 

15 exposed to plutonium-238 with special non16 monotonic behavior.

17 DR. NETON: I'm not saying for 

18 every worker, because the reality of it is 

19 that we probably wouldn't have many workers. 

20 You know, barring these incidents where you 

21 found type L materials, we wouldn't have that. 

22 So we would have to come up with some sort of 
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1 default value.

2 What I'm hearing you say, though, 

3 is that there is a possibility of a model out 

4 there, whether it's J, which you believe is 

5 the most bounding, or whether it is L, that 

6 could be used to reconstruct dose for this 

7 type of plutonium-238.

8 DR. LIPSZTEIN: Yes, all the time, 

9 we have agreed on that.

10 DR. NETON: Well, I'm not sure I 

11 understood that as well.

12 So I'm not sure where to go with 

13 it, other than, as a practical matter, I don't 

14 know that it makes that much difference 

15 whether it's L or -- J is the other model? 

16 Yes.

17 CHAIR BEACH: It might have for 

18 those two.

19 DR. LIPSZTEIN: Yes. Yes.

20 DR. NETON: Well, I mean --

21 DR. LIPSZTEIN: It makes sense for 

22 the lung.
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1 DR. NETON: The lung doses are 

2 going to be sufficiently large --

3 DR. LIPSZTEIN: Yes.

4 DR. NETON: -- under I think 

5 either scenario --

6 DR. LIPSZTEIN: Yes.

7 DR. NETON: -- that they are going 

8 to be well over.

9 DR. LIPSZTEIN: Yes.

10 DR. NETON: That really shouldn't 

11 be a consideration, though. The reality of 

12 what's there should be the consideration.

13 I'm reluctant at this point to 

14 make a decision for our program that type J is 

15 the appropriate model. But I think, now that 

16 I understand that you do believe that type J 

17 would be appropriate, and it wouldn't be 

18 implausibly high, I think we need to take that 

19 back and consider our options as to where to 

20 go.

21 I think, under previous 

22 discussions, it was my belief that SC&A felt 
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1 that, even if we had a model, it was sort of 

2 in the same camp as these tritides, insoluble 

3 tritides, that applying it would be 

4 implausibly high because we couldn't identify 

5 who to apply the exposures to.

6 But if SC&A is of the opinion that 

7 we could use it, and it wouldn't be 

8 implausibly high, we can take that back and 

9 think about it.

10 MR. FITZGERALD: You know, I think 

11 the consideration of to what extent the 

12 physical handling of the circumstances of the 

13 event at Los Alamos, I think is somewhat 

14 speculative as to know, yes, it might have or 

15 it might not. I think that is kind of where 

16 we are coming from, that the claimant17 favorable assumed that this could have been 

18 reflective of --

19 DR. NETON: I'm encouraged. I 

20 think we're closer than ever on this. I just 

21 don't want to make sort of an ad hoc decision 

22 on my own here, and we need to take it back to 
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1 our group to talk about how we might want to 

2 land on this.

3 MR. FITZGERALD: Yes, I think the 

4 last exchange was, again, I said at the 

5 beginning, was pretty fruitful. I think this 

6 is where we are at.

7 DR. ULSH: Can we agree -- I don't 

8 remember when they started the advent of the 

9 microsphere program. I don't know, whatever 

10 the date is.

11 MR. FITZGERALD: Whatever the date 

12 is.

13 DR. ULSH: I mean this is a high14 fired process. So the types of operations 

15 that you might have encountered in the very 

16 early days of the SM Building, for instance, 

17 when they were doing plutonium nitrate or 

18 plutonium oxide, before they started doing the 

19 microsphere project, it doesn't seem to me 

20 that there would be a basis for concluding 

21 that there would be a potential for highly22 insoluble plutonium-238 because it is a high-
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1 fired process. If you aren't doing high2 firing processes -- can we agree on that?

3 MR. FITZGERALD: Yes. I mean, 

4 certainly, you're going to have to have 

5 temperatures that would be high enough.

6 Bob, you would know what this is 

7 approximately. I mean you would have to have 

8 the temperatures.

9 MEMBER SCHOFIELD: Are we really 

10 sure of that? Because the reason why I say 

11 that, I've seen how it's all done. I've been 

12 involved.

13 It goes through two stages, 

14 typically. And, of course, I'm having to base 

15 this on what I know about the Los Alamos 

16 process, where it would definitely be high17 fired.

18 MR. FITZGERALD: Now we 

19 acknowledge the RTG. I think we're talking 

20 about operations that were non-RTG operations 

21 that may have been low-temperature operations.

22 MEMBER SCHOFIELD: They were low 
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1 temperature? Because, actually, I know --

2 DR. BISTLINE: What do you 

3 consider low temperature?

4 MR. FITZGERALD: Well, that is 

5 kind of what Brant's asking.

6 DR. BISTLINE: Because anything 

7 above about 800 degrees, it gets to the high8 fired, and you end up with some high-fired, 

9 not all high-fired. But, once you get up 

10 around a little over 1,000 degrees, then 

11 almost all the plutonium is going to be high12 fired plutonium.

13 DR. ULSH: So somewhere in the 

14 hundreds of degrees centigrade is what we're 

15 talking about, right?

16 DR. BISTLINE: Okay. Because 

17 around 750 to 800 degrees, you're going to 

18 have quite a bit of high-fired out of that 

19 temperature.

20 DR. ULSH: Well, I would have to 

21 go back and look at what actually happened 

22 prior to the microsphere program because, of 
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1 course, the inherent assumption in what I'm 

2 saying is that there weren't processes prior 

3 to that that would have led to those kinds of 

4 temperatures, and I need to verify that. I 

5 can't say that's the --

6 MR. FITZGERALD: Yes, there's been 

7 some fabrication processes that --

8 DR. BISTLINE: Because even at 

9 Rocky, we had, you know, just the regular 

10 production process; we found out that some of 

11 those did have temperatures that got up there 

12 approaching the 800 degrees centigrade 

13 temperature, just in the plutonium process, in 

14 the normal production.

15 DR. ULSH: And you had a couple of 

16 little fires there, too.

17 DR. BISTLINE: Pardon?

18 DR. ULSH: You had a couple of 

19 little fires there, too.

20 DR. BISTLINE: Yes, 1600 degrees.

21 MR. FITZGERALD: There was a lot 

22 of high-fired --
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1 DR. BISTLINE: But we found, just 

2 in natural production, that you did have 

3 temperatures, say, in the normal production, 

4 routine production, we had temperatures that 

5 were --

6 DR. ULSH: And if that were the 

7 case at Mound, then my suggestion would not 

8 have -- I would just have to look at it.

9 DR. NETON: We will look at it. 

10 We are going to take this back and look at the 

11 issue.

12 CHAIR BEACH: Any other questions 

13 from the Work Group before we move to the next 

14 topic?

15 MR. FITZGERALD: Joyce, do you 

16 have anything else?

17 DR. LIPSZTEIN: No, no.

18 MR. FITZGERALD: Okay.

19 DR. LIPSZTEIN: Then, once we 

20 accept the model, then we have to know what to 

21 do with the coworker model. Because you have 

22 a non-monotonic. So I don't know how to 
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1 build, but that's some other problem, not just 

2 an SEC issue. That is something that can be 

3 solved once we are beyond the model.

4 CHAIR BEACH: Thank you.

5 Okay, so the next topic we are 

6 going to get into, and this is going to be 

7 headed off by SC&A, is the Road Map, and it 

8 may be a little quicker than what we thought, 

9 based on some of the new information on the 

10 Road Map.

11 So, Kathy, are you heading that? 

12 Or, Bob?

13 MS. ROBERTSON-DEMERS: Well, I can 

14 just give you some of the items that were 

15 raised when we looked at the completeness of 

16 the Road Map.

17 We contended that you could add 

18 these if you did a subsequent revision. So 

19 some of these issues in themselves are not SEC 

20 issues.

21 MR. FITZGERALD: I don't know. We 

22 could provide these as comments, specific 
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1 comments, rather than trying to correct, you 

2 know, correcting the 140-page Road Map. I 

3 mean we could certainly provide those 

4 comments.

5 I think what we were getting to, 

6 and I think it was referred to as a tool 

7 anyway, or as a way to demonstrate what the 

8 [identifying information redacted] report has 

9 in it to the Work Group, we didn't see really 

10 an SC&A question, other than the questions of 

11 adequacy, which we have been talking about.

12 MS. ROBERTSON-DEMERS: Well, it 

13 depends upon what the purpose of the Road Map 

14 is. I mean, there are some gaps.

15 MR. FITZGERALD: Do you want to 

16 talk about the corrections or gaps in the Road 

17 Map, even though it may not have SEC 

18 implications?

19 CHAIR BEACH: No. I think we need 

20 to step back on that, based on the new 

21 information --

22 MR. FITZGERALD: Yes.
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1 CHAIR BEACH: -- and come back 

2 with that.

3 MR. FITZGERALD: I mean that might 

4 be part of what we're coming in --

5 CHAIR BEACH: Yes.

6 MR. FITZGERALD: But that gets to 

7 the heart of the issue, which is bioassay, 

8 rather than -- you know, to me, it is not 

9 quite a Site Profile issue, but how complete 

10 is the Road Map? Well, we could work at that, 

11 but I'm not sure that gets us where we want to 

12 go.

13 CHAIR BEACH: No. I think we need 

14 to wait.

15 I think, Brad, you had something?

16 MEMBER CLAWSON: Well, personally, 

17 I was under the misinterpretation of what the 

18 Road Map was for. Now we have come back, and 

19 that it was more of a D&D guidance in the 

20 later years.

21 I have been trying to find it on 

22 there because I remember reading in there, in 
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1 the [identifying information redacted] 

2 document, that these isotopes were there or 

3 considered there in the ceilings and floors, 

4 and so forth like that. And now I am being 

5 told it was just part of production.

6 So I think we need to step back 

7 and look at how we are really going to use 

8 that and what the adequacy was there.

9 CHAIR BEACH: Well, and the 

10 implications it has for previous issues on 

11 internal data adequacy.

12 MEMBER CLAWSON: Well, then the 

13 other thing that came up, and you know we did 

14 this on a side conversation I believe, but 

15 when we talk about a process ran from -- and 

16 I'm just throwing out numbers -- 1949 to 1959, 

17 then to come to find out that it was only 

18 actually for two years in that period, I think 

19 that we need to refer to that differently 

20 because the actual process was only two years, 

21 but then we had it stored elsewhere, and so 

22 forth like this.
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1 And we have found other areas 

2 where the process, while we're sitting there 

3 with strontium or cesium, something like that, 

4 had been in these tanks for so long, and all

5 of a sudden, we had a leak. That process 

6 ended. It had been there for five to ten 

7 years.

8 DR. ULSH: Well, it wasn't clear 

9 that that was the genesis of the material. 

10 It's possible, but we haven't --

11 MEMBER ZIEMER: Well, uncertainty 

12 about what the end-point means in the 

13 document --

14 MEMBER CLAWSON: Right.

15 MEMBER ZIEMER: -- is it the end 

16 of the official project or is it the end of 

17 when the material is actually sort of 

18 available in that facility? I think you 

19 showed somewhere that, basically, the end was 

20 when everything was concreted up. So I think 

21 there's some question. It may be clear, but I 

22 guess there were questions at least in 
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1 people's minds as to what that end-point means 

2 in the document. Or is it the same in every 

3 case?

4 DR. ULSH: I don't know. I don't 

5 know if the end-point means the end of active 

6 operations or if it means final D&D.

7 Do you recall, Mel?

8 MR. CHEW: No, I don't.

9 MEMBER ZIEMER: If it is 

10 consistent throughout, and we know what it 

11 means, that would be important.

12 MR. CHEW: But most of the time, 

13 when the specific operation was mentioned, it 

14 did give, like in that particular room the 

15 material was present, so between 1951 and 

16 1954.

17 So I think, in essence, it really 

18 is both. Okay?

19 MEMBER ZIEMER: Yes. Well, I 

20 think we have all experienced that, where a 

21 project ends and you can identify that either 

22 by funding or by some other document, but, in 
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1 practicality, somebody later has to do 

2 something with some stuff, either get it out 

3 of there or drum it up or decon something. So 

4 it would help to clarify that in some way.

5 MR. CHEW: But the thing when they 

6 were compiling the document, they were trying 

7 to gather the best information as they 

8 possibly can. If, for instance, there was 

9 some specificity to tell you that this 

10 particular process occurred in that particular 

11 room, they put it in.

12 MEMBER ZIEMER: Kept it in.

13 MR. CHEW: If it wasn't sure, they 

14 put it to whatever the time was.

15 MEMBER ZIEMER: Right.

16 MR. CHEW: So recognizing what the 

17 genesis of the document itself is and what its 

18 intended purpose is.

19 To answer your question, it does 

20 kind of help you, that if you came back and 

21 D&Ded, this material potentially may be up in 

22 the ceiling and the wall, and that's --
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1 MEMBER ZIEMER: Regardless of the 

2 time frame.

3 MR. CHEW: Right.

4 MEMBER CLAWSON: Right. And 

5 that's a very good point, but what I was 

6 considering that is that this document showed 

7 that we had this here, from here to here, and 

8 that we should have been monitored for that 

9 portion of it.

10 MR. CHEW: But you've got to 

11 remember why we put the thing together in the 

12 first place, because Mound, being a 

13 significant long period of time, had many, 

14 many different campaigns of different 

15 materials. It was good to try to put a Road 

16 Map together, so we can at least say, yes, we 

17 know these particular operations happened at 

18 this period of time with these kinds of 

19 materials, to the best of how the document was 

20 put together.

21 MEMBER CLAWSON: Well, and I think 

22 we also need to look at why this document was 
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1 put together. Because, according to some of 

2 the interviews that we have had, they started 

3 going into the D&D process of this, and it's 

4 like the building, and there was no residue, 

5 and then they would go rip out a piece of 

6 equipment, and they would reveal product and 

7 different sources that have been there for 40 

8 years and, all of a sudden, people had 

9 uptakes.

10 And they were trying to figure out 

11 what was going on, and come to find out it's 

12 because they didn't have a record of what had 

13 been where. That was my understanding kind of 

14 a little bit of why the [identifying 

15 information redacted] document was there.

16 But I was under the impression 

17 that, from here to here, you had a potential 

18 for exposure to it. I think we need to kind 

19 of look at that.

20 DR. BISTLINE: But, again, I think 

21 there is a question as to how it is going to 

22 be an important question, how useful that Road 
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1 Map is going to be.

2 MEMBER CLAWSON: Right.

3 DR. BISTLINE: Because if a dose 

4 reconstruction person goes to that, thinking, 

5 you know, I'm going to use this as a trail for 

6 this, there are things missing. There's a lot 

7 of information that is --

8 MEMBER CLAWSON: Right.

9 DR. BISTLINE: For instance, the 

10 big explosion is not listed as one of the 

11 incidents that occurred. And you've got 

12 references in there back to the [identifying 

13 information redacted] document. Well, how 

14 many of the dose reconstruction people have 

15 Q-clearances to be able to go back and look at 

16 this document?

17 MR. CHEW: But they wouldn't do 

18 that.

19 MEMBER ZIEMER: They don't use the 

20 Road Map, do they?

21 DR. BISTLINE: Well, is it going 

22 to be used for that?
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1 DR. ULSH: Then, also, it is not 

2 the entire [identifying information redacted] 

3 document that is classified. It is only one 

4 particular appendix.

5 DR. BISTLINE: Right. Right.

6 MS. ROBERTSON-DEMERS: Can I read 

7 something that might clarify something from 

8 the [identifying information redacted]

9 document?

10 CHAIR BEACH: Yes.

11 MS. ROBERTSON-DEMERS: Okay. I 

12 found a quote in there, all dates represent 

13 the duration of actual usage of radioisotopes 

14 in their respective projects. It is clearly 

15 understood that residual amounts of all 

16 radioisotopes referred to in each room may 

17 still be found in floors, walls, and ceilings, 

18 and should be considered up to the present in 

19 every case for decontamination work.

20 DR. ULSH: So what that tells you, 

21 and I think that's consistent with what we're 

22 saying the purpose of the [Identifying 
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1 information redacted] document was, if I'm a 

2 D&D manager and I'm going in to decontaminate 

3 a particular, you know, D&D a particular room, 

4 what should I be looking for? What is the 

5 universe of potential things? Not that it is 

6 verified that it is there, but that at some 

7 point it might have been. So we had better be 

8 monitoring for it. I think that's consistent.

9 MEMBER CLAWSON: Yes, I just --

10 MR. CHEW: And monitoring may not 

11 be necessarily qualified as, not necessarily 

12 looking for that specific isotope, but doing 

13 what we consider the Rad Control, smears, 

14 swipes, sampling, to see if there is any 

15 indication of any activity of any type. When 

16 you produce the positive samples, that is when 

17 further analysis would be warranted. I think 

18 that's where it is.

19 So it is not in trying to address 

20 every isotope that was mentioned in that 

21 particular room. That was not the intent.

22 But I think you know that, Kathy. 
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1 You've been an operating person. The 

2 screening methods --

3 MS. ROBERTSON-DEMERS: I think 

4 that is insight into [identifying information 

5 redacted]'s mind.

6 MEMBER CLAWSON: And that was what 

7 I was reading, and you get to the very last 

8 statement of it, you know, where it says that 

9 it should be considered. I was taking it that 

10 that progeny can be there, no matter what. 

11 Even though it's in the ceilings, or whatever, 

12 it could still be there.

13 And a lot of times, in RadCon's 

14 eyes, they monitor for certain things and go 

15 through that process. That was the way I was 

16 looking at the document, and that's not how it 

17 really can be used, I take it.

18 DR. ULSH: No, but, Brad, I think 

19 that the attitude that you just described 

20 would be exactly the appropriate attitude for 

21 a D&D manager in that situation.

22 MEMBER CLAWSON: Yes, and there is 
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1 no question, D&D, but what I was looking at is 

2 D&Ds here in the 1990s, or whatever else like 

3 that. But what I was reading into this, and 

4 this could have been my personal thing, is 

5 that they should be considered to be there 

6 until this time. You know, that there was 

7 stuff there, because there are so many times 

8 before this document was ever even done, 

9 especially at Mound, we hear of it all the 

10 time, them going through the rafters and 

11 everything else like this. Well, that's not 

12 part of the D&D era, but those radionuclides 

13 could still be there.

14 This is inherent to Mound because 

15 they built one facility on top of the other. 

16 They were a cobbled-up mess, and I've heard 

17 this many times in the workers discussing 

18 this.

19 One of the biggest ones is 

20 electricians dragging stuff through all this, 

21 because they would wire it for something like 

22 this, and then they would have to change this 
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1 and drag different pipes through, drilling 

2 through concrete and everything else like 

3 that. This was well before the [identifying 

4 information redacted] document was brought up.

5 That is kind of what I'm looking 

6 at, why I feel the way I do.

7 CHAIR BEACH: Paul, did you have 

8 anything?

9 MEMBER ZIEMER: No. I think what 

10 Kathy read helped define in my mind a little 

11 better that those dates, beyond those dates, 

12 the residual which implies that the bulk of 

13 the stuff has been removed, but that doesn't 

14 mean there isn't some activity behind.

15 MEMBER CLAWSON: Right.

16 MEMBER ZIEMER: If that's true in 

17 every case, I think you've answered my 

18 question. At least the intent of that is that 

19 the end dates when we have taken the known 

20 stuff out of the room, there still might be 

21 some unknown residual behind.

22 MR. CHEW: If you look at the 
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1 document, there are specific places and 

2 specific processes are mentioned. Then those 

3 places you will find specific dates when you 

4 would think that that's the campaign time. I 

5 think that answers your question.

6 MEMBER ZIEMER: Right. Yes.

7 MEMBER CLAWSON: All right, and 

8 then there is also ones out to the side of it, 

9 that basically 10 years later they re-drummed 

10 this, and so forth. And those pop up several 

11 places in there.

12 CHAIR BEACH: Okay.

13 MEMBER ZIEMER: So what's going to 

14 happen on this? You guys are going to 

15 indicate the gaps?

16 MR. FITZGERALD: Yes, we can 

17 provide those as information to NIOSH, but I 

18 don't think -- again, it's in the SEC context, 

19 as much as this exercise that we were talking 

20 about this morning.

21 CHAIR BEACH: I was just realizing 

22 that we have had the Road Map on our agenda at 
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1 every Work Group meeting, but we have never 

2 gotten to it. So it was always at the end. 

3 Well, at least the very last meeting, it was 

4 actually the first time we were going to 

5 discuss it, and it was at the end. So I 

6 wonder if that's why we didn't put more 

7 emphasis on it and never actually got to 

8 discuss it.

9 So, with that, we've got two 

10 remaining topics. They should be fairly 

11 quick.

12 The PAAA violations, Issue 21, 

13 where we were, we were close to closure at the 

14 last meeting. We asked NIOSH to answer three 

15 questions from SC&A's April 2nd document of 

16 2009. I believe that's been done.

17 I know that part of the issue, and 

18 I'm going to let Kathy speak to this, we have 

19 deferred some of PAAA to 11, the data 

20 adequacy.

21 So, with that, I believe --

22 MS. ROBERTSON-DEMERS: Well, I'm 
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1 not sure that those questions have been 

2 answered.

3 CHAIR BEACH: Well, no, I'm not 

4 saying they have been answered. They have 

5 just been referred to that.

6 MS. ROBERTSON-DEMERS: As far as 

7 the bulk of the PAAA issues, we have already 

8 come to resolution on that, but there were a 

9 couple of PAAA issues that were relevant to 

10 data adequacy. And it really kind of 

11 overlapped with some of the other data 

12 adequacy issues. So we moved them over under 

13 data adequacy.

14 Our concerns were that there were 

15 examples of recurrence where inadequate 

16 frequencies or failure to effectively 

17 implement the collection of bioassay samples 

18 occurred.

19 Just to get a little bit more 

20 specific, there were situations where 

21 individuals entered under an RWP, required 

22 that they submit a bioassay sample. In these 
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1 cases, the individual did not submit a 

2 bioassay sample after their entry, and that 

3 was the end of it. There was no bioassay 

4 sample after that entry. And the question 

5 was, how are you going to deal with that 

6 particular situation?

7 And the other question was, we had 

8 some situations where we had short-lived 

9 radionuclides. For example, tritium, which 

10 has an effective half-life of 10 days, and the 

11 bioassay didn't occur until 30 days or more 

12 after the entry.

13 How would you address situations 

14 where you weren't sampling as frequently as 

15 you should have? So I really have more 

16 questions.

17 DR. ULSH: Would you like me to

18 respond?

19 CHAIR BEACH: Yes.

20 DR. ULSH: Okay.

21 CHAIR BEACH: Please.

22 DR. ULSH: I believe that the 
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1 questions that Kathy is referring to were the 

2 subject of our response dated September 2009. 

3 These were the follow-up questions that SC&A 

4 had.

5 I'll read the questions because 

6 the response is quite lengthy. I will just 

7 refer you to the response.

8 Question 1 that we addressed was, 

9 how will dose reconstruction be completed for 

10 individuals who entered under RWPs without 

11 appropriate tritium bioassay and did not 

12 submit a post-job tritium bioassay sample in a 

13 timely manner?

14 We give a fairly lengthy response 

15 here, almost a full page. So I would refer 

16 you to that.

17 SC&A Question --

18 MEMBER ZIEMER: I have it out 

19 here, but can you give us a couple-of-sentence 

20 summary?

21 DR. ULSH: Oh, I've got to read it 

22 to find out what we said.
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1 MEMBER ZIEMER: You've got to 

2 remember what the response was?

3 DR. ULSH: Paul, I think in a 

4 nutshell what it was was Gene Potter performed 

5 a detailed analysis of the RWPs in question 

6 that were the subject of the Price-Anderson 

7 Act violation, and went through each one of 

8 them and looked at when the work, under each 

9 one, how many workers, RWPs required a count 

10 less than 30 days, and how many workers 

11 actually submitted that.

12 Then, oh, boy, let's see.

13 MR. CHEW: Gene is on the line, by 

14 the way.

15 DR. ULSH: Hello, Gene.

16 (No response.)

17 Are you sure?

18 (Laughter.)

19 MR. CHEW: I thought he was.

20 MEMBER ZIEMER: Well, can I just 

21 ask, while you're looking at that, we know who 

22 those workers were under the Price-Anderson 
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1 thing, right, or do we?

2 MS. ROBERTSON-DEMERS: There is 

3 one other element to this that I have 

4 forgotten to mention. For this particular 

5 case, yes, you know, because these RWPs that 

6 were evaluated were, I believe, from '96 to 

7 '97. There is a question, however, well, 

8 these are the RWPs that got looked at.

9 MEMBER ZIEMER: That's what I'm 

10 asking.

11 MS. ROBERTSON-DEMERS: Is there 

12 a --

13 MEMBER ZIEMER: Right, was there a 

14 pattern?

15 MS. ROBERTSON-DEMERS: -- a 

16 frequency problem outside of these two?

17 MEMBER ZIEMER: Well, there's two 

18 parts to it. One is it seems to me, if you 

19 know the identity of the persons, you can go 

20 back and do something with that, based on 

21 either the other bioassays or you assume 

22 something. So you can reconstruct dose in 
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1 some way or another.

2 But the larger question is, this 

3 was a headquarters review under Price4 Anderson, was it? So we don't have an 

5 indication, or do we, whether it's a sampling? 

6 Because, typically, what happens --

7 MS. ROBERTSON-DEMERS: It is a 

8 sampling.

9 MEMBER ZIEMER: -- if they start 

10 to find one or two of these, they keep pulling 

11 the string. So sometimes these get to be 

12 pretty complete.

13 So I am just asking if we know the 

14 completeness of this. If this is it for that 

15 group, I think it's seven.

16 DR. ULSH: Well, I think the 

17 scenario that you describe, Paul, is exactly 

18 what happened at Mound. They found a problem 

19 on a particular sample. So they went back and 

20 looked, and there were actually multiple 

21 Price-Anderson Act violations, all related 

22 around the same subject.
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1 In fact, we are looking at several 

2 RWPs here. One, two, three, four, five, six, 

3 seven RWPs here.

4 MEMBER ZIEMER: Right, right.

5 DR. ULSH: Of course, we are in 

6 the same situation. You can always speculate 

7 about, you know, we can't prove a negative. 

8 All we can say is that these were the problems 

9 that were identified, and we've done an 

10 analysis of these identified problems.

11 Were there others? We don't have 

12 evidence to suggest that, but we can't prove a 

13 negative. I mean there might have been other 

14 problems. Who knows?

15 MEMBER ZIEMER: On these, you 

16 would do something specific for these 

17 individuals if there were a claim? Does this 

18 show up in their file for the dose 

19 reconstructor?

20 MR. POTTER: Brant, this is Gene. 

21 I'm on. I think I missed your calling on me 

22 while I was trying to unmute myself.
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1 DR. ULSH: Okay.

2 (Laughter.)

3 DR. ULSH: Did you hear Paul's 

4 question? And thank you.

5 MR. POTTER: Yes. One thing that 

6 I need to add that hasn't been brought up in 

7 the discussion, I mean you've been perfectly 

8 right. But the way the program worked at 

9 Mound during the D&D era was that if you 

10 signed in on an RWP, the clock started running 

11 for a bioassay. So as you can see from our 

12 list, if you have Table 1 in front of you 

13 there, that SW Building, there are four 

14 different RWPs being worked in '97 --

15 DR. ULSH: Yes.

16 MR. POTTER: -- that required 

17 tritium bioassay. Some of these workers were 

18 working on various RWPs.

19 So as a matter of efficiency, the 

20 question is really being asked in the wrong 

21 way, that people received a periodic tritium 

22 bioassay rather than one necessarily after 
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1 their very last entry. Therefore, it becomes 

2 a missed dose issue sort of thing that is 

3 dealt with in dose reconstructions all the 

4 time.

5 But, yes, these are all the cases 

6 that were brought up involving tritium, every 

7 RWP that was questioned.

8 DR. ULSH: So our response on that 

9 issue is on the table. If there are 

10 additional concerns, we would --

11 MS. ROBERTSON-DEMERS: Were the 

12 RWPs -- I don't remember off the top of my 

13 head -- from '96 through '97?

14 DR. ULSH: The ones listed in 

15 Table 1 at least are in '97.

16 Gene, do you have any further 

17 insight?

18 Is that what you're asking about, 

19 Kathy, the particular tritium one?

20 The ones that we were asked to 

21 investigate, I think are the subject of the 

22 Price-Anderson Act violations; the RWPs look 
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1 like they're dated in '97.

2 MS. ROBERTSON-DEMERS: I guess one 

3 of the concerns is if you are sampling for 

4 tritium on a monthly basis, are you really 

5 adequately capturing an uptake which may have 

6 occurred right after the last sample? And how 

7 often does this exist?

8 These are smaller groups of 

9 people.

10 DR. ULSH: Well, again, I guess 

11 what I would ask you to do is consider our 

12 response here that's on the table. I could 

13 read through it, if you would like me to, 

14 but --

15 MEMBER ZIEMER: These are still on 

16 routine bioassays as well as the specials?

17 DR. ULSH: Correct.

18 MEMBER ZIEMER: So you're talking 

19 about a miss, which means that you would 

20 overestimate dose because you would take the 

21 next one based on an earlier sample rather 

22 than the missed one.
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1 DR. ULSH: I believe that's 

2 correct. Right, Gene?

3 MR. POTTER: Right. In this case, 

4 we do have the details. As Dr. Ziemer 

5 suggested, one could look at the other workers 

6 who signed in, but dose reconstructions are 

7 not done at that level of detail. You know, 

8 it is an underestimation or overestimation 

9 approach.

10 MEMBER ZIEMER: But if this 

11 individual had a whole regular series of 

12 bioassays, but one of these were missed in 

13 this particular work permit, wouldn't you 

14 still catch it in the next -- how frequently 

15 were they?

16 MS. ROBERTSON-DEMERS: In this 

17 case, the gaps were from --

18 MR. POTTER: About two-thirds of 

19 the people had bioassays within 30 days of 

20 their last entry.

21 MEMBER ZIEMER: Okay, 30 days. 

22 What do we have for tritium? Is it eight 
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1 days?

2 MS. ROBERTSON-DEMERS: There is a 

3 broader question here.

4 CHAIR BEACH: And that's the 

5 question I want to ask, just for 

6 clarification. So there's broader issues that 

7 are going to be handled in data adequacy. The 

8 questions that were asked in the April Work 

9 Group meeting or we asked NIOSH to answer the 

10 three questions, those are the ones that have 

11 been answered. I believe SC&A was satisfied 

12 with those answers. Is that correct?

13 But I know there is a broader 

14 issue related to data adequacy that will be 

15 brought up during the data adequacy issue that 

16 maybe we should have discussed earlier today. 

17 Is that --

18 MS. ROBERTSON-DEMERS: Which is,

19 were bioassay samples taken frequently enough 

20 outside of these identified situations? What 

21 are you going to do for people who just kind 

22 of drop off the map after they were exposed?
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1 CHAIR BEACH: Okay, because these 

2 are kind of new questions. We haven't given 

3 these.

4 DR. NETON: That was the last 

5 question that was asked. If you are talking 

6 about the actinium people, "How will dose 

7 reconstructions be completed for the 11 

8 individuals who submitted actinium samples and 

9 did not have a follow-up sample to those 

10 discovered in 1995?"

11 MS. ROBERTSON-DEMERS: Right. 

12 We're not talking about those people that are 

13 identified. We are talking about others that 

14 may exist. These were existing, these people 

15 were identified because of a Price-Anderson 

16 violation.

17 CHAIR BEACH: Okay. So I think 

18 there's two things going on here. I think 

19 Kathy's talking about data adequacy. We 

20 should have maybe captured some of that during 

21 the data adequacy discussion.

22 The Price-Anderson, the original 
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1 three questions that were on the table, I 

2 believe those have been answered. Is that 

3 correct?

4 MS. ROBERTSON-DEMERS: Let me put 

5 it to you this way. Twenty-one, matrix item 

6 21, will be closed.

7 CHAIR BEACH: And that's what I 

8 want to get to, but the issues that Kathy is 

9 bringing up will need to be put in context and 

10 submitted as questions, new questions I would 

11 say, probably during -- I think we've already 

12 captured that for Issue 11, data adequacy. Is 

13 that fair enough?

14 Because it was confusing to me 

15 until I got kind of a handle on where we were. 

16 So for the Work Group, the questions that we 

17 originally asked at the last Work Group 

18 meeting were for NIOSH to submit answers to 

19 those first three questions. They have done 

20 that, and Kathy has indicated she is satisfied 

21 with the answers.

22 I agree with that, and I would 
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1 like to close issue 21 and then take that 

2 up --

3 MEMBER ZIEMER: On your data 

4 adequacy?

5 CHAIR BEACH: Yes. Due to the 

6 lateness of the day, how does the rest of the 

7 Work Group feel about that?

8 MEMBER CLAWSON: That is fine, 

9 just so we don't lose it.

10 CHAIR BEACH: We won't lose it. 

11 Okay. So that is where we are at with that.

12 Kathy, do you want to continue 

13 discussing that as data adequacy, or do you 

14 want to just frame up those questions when Joe 

15 submits the questions to NIOSH?

16 MS. ROBERTSON-DEMERS: I think at 

17 this point we haven't asked the question 

18 clearly enough to know the answer. So we will 

19 put it in --

20 CHAIR BEACH: Okay. Does 

21 everybody agree with that?

22 Okay. So we are going to consider 
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1 PAAA closed, but with some questions that will 

2 be in the data adequacy. Okay?

3 So the last item, D&D issue 10, 

4 and I'm not quite sure -- SC&A, do you want 

5 to --

6 MR. FITZGERALD: Yes, let me 

7 handle that.

8 We did a number of interviews, 

9 dose and Site Profile and after the ER came 

10 out and workers had expressed some concerns 

11 over lapel sampling in the D&D era. And we 

12 had similar issues, but not the same issues, 

13 arise during the Rocky Flats SEC review.

14 We deferred, I should say the Work 

15 Group deferred action on D&D for some time 

16 because of some activities going on with the 

17 Price-Anderson, Issue 21, whatever. So we 

18 didn't really pick it up until, I think, this 

19 past summer. So it wasn't that long ago.

20 And the Work Group requested after 

21 the last Work Group meeting to go ahead and 

22 put a very brief memo that just highlighted 
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1 some of the concerns that were coming out of 

2 the interviews and to amplify on what was in 

3 the issue matrix, which we did.

4 I think NIOSH's response was 

5 pretty comprehensive, to say the least. I 

6 guess I am pleased to announce that there's 

7 one issue which will sound familiar to Brant 

8 since we, I think, went through this at Rocky 

9 Flats, which is the termination bioassays. Of 

10 all the issues that were addressed and 

11 clarified in the response, I think we are 

12 still unsettled about the status of 

13 termination bioassays in the D&D era at Mound.

14 We raised that issue at Rocky 

15 because, again, there it wasn't clear, given 

16 the transient nature of the workforce, whether 

17 there was sufficient termination bioassays 

18 upon which to do a coworker model. I think at 

19 Rocky the response was to go and take a look 

20 at that, compare distributions between the D&D 

21 work force data that you had versus the 

22 operating work force. It turned out in that 
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1 case the distributions were very similar, 

2 which certainly facilitated going ahead and 

3 using the operating coworker model for the D&D 

4 workers.

5 Here I think the same question is, 

6 where do we stand on the D&D work force 

7 termination bioassays? Is there enough 

8 adequate data there that it is an important 

9 coworker model or not?

10 I think that is the only real 

11 lingering question out of all that. I think 

12 the rest of it, the lapel sampling and 

13 everything else that had been kicking around, 

14 I think that has been satisfied.

15 So that would be the one issue 

16 that I would propose the Work Group, I 

17 suppose, ask you to maybe come back with, is 

18 some information regarding the status of 

19 termination bioassays.

20 I know it was a very small, 

21 relatively small percentage at Rocky, but, 

22 again, because the dose distributions were 
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1 similar between the two workforces, that 

2 didn't become an issue in that SEC. But, 

3 certainly, you would want to have that at 

4 least looked at before we let this one go.

5 DR. ULSH: I am waiting on the 

6 high sign from you.

7 CHAIR BEACH: Oh, I'm sorry.

8 (Laughter.)

9 Please, go ahead.

10 DR. ULSH: In fact, this issue was 

11 included in SC&A's D&D memo, and it was also 

12 included in our response to that memo. In our 

13 response, we designate it as SC&A Comment No. 

14 7 and our Response No. 7.

15 I believe that in the original 

16 comment that SC&A made they raised this, 

17 saying we had a similar concern at Rocky 

18 Flats. So our response also focuses on the 

19 fact that this issue was already considered 

20 and determined not to be an SEC issue at Rocky 

21 Flats, and I don't see a whole lot of 

22 differences. As you, yourself, stated, the 
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1 contractor was the same. So the policies were 

2 fairly, were pretty much the same, too.

3 Just to quote from our response, 

4 "It may be true that some D&D workers failed 

5 to submit a terminal bioassay. However, Mound 

6 also used workplace indicators, such as air 

7 monitoring" -- and in parentheses --

8 "(including lapel air samplers as well as 

9 general area samplers), pre-job and process 

10 characterization, and routine bioassay. The 

11 chances that a worker could receive a 

12 significant intake would require the 

13 simultaneous failure of multiple levels of 

14 monitoring and radiation control, all having 

15 occurred after the worker's last bioassay, but 

16 prior to termination."

17 So, certainly, you can speculate a 

18 scenario like that, but what we said is this 

19 scenario is speculative, and the chances of it 

20 occurring are remote, and no evidence to 

21 support it has been provided or discovered by 

22 NIOSH.
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1 Even in the highly unlikely event 

2 that it did happen on occasion, which has not 

3 been demonstrated, there would have to be some 

4 evidence of selective non-compliance with more 

5 highly exposed workers being most likely to 

6 skip terminal bioassays. Again, we don't have 

7 evidence for that, either.

8 MR. FITZGERALD: Yes, I think the 

9 reaction would be that, again, it's not that 

10 dissimilar from Rocky, and I think they also 

11 had, as you pointed out, some similar 

12 monitoring systems.

13 But if the percentage of 

14 termination bioassays was relatively low, I 

15 think -- and again, there is no way of knowing 

16 it now; I think that was checked at Rocky, and 

17 I think you established it was relatively low. 

18 Then that's where we went into this.

19 They, again, still had the same 

20 fallback. I mean they, you know, certainly 

21 had lapel sampling. They certainly had 

22 bioassays for certain classes of workers. If 
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1 you remember, there was a couple different 

2 classes of workers. Some, in fact, were on 

3 bioassays; some were not.

4 But, again, I think establishing 

5 whether or not you had a low compliance on 

6 that issue, and what the implications are in 

7 terms of the use of that, of the coworker 

8 model for that class of workers, would be 

9 something that we would see as the one 

10 remaining issue.

11 CHAIR BEACH: I have a quick 

12 question. This may have already been 

13 discussed. Did they put a lapel sample on 

14 every single worker or was it a group?

15 DR. ULSH: No, not on every single 

16 worker.

17 CHAIR BEACH: Okay.

18 MR. FITZGERALD: And I would think 

19 you would have a body of workers. You know, 

20 you're talking about all kinds of different

21 workers here, people that were doing the 

22 actual D&D, construction workers, 
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1 electricians. The ones that were clearly in 

2 the rad zones doing the teardowns had the 

3 lapel sampling and probably more routine 

4 bioassays, but you had a whole variety of 

5 workers that would have different levels of 

6 monitoring. In some cases, if they didn't go 

7 right into the D&D rad zone, probably didn't 

8 have bioassay, and the baseline and 

9 termination bioassay may have been it.

10 So I guess the question is if they 

11 were to be a claimant and were to have 

12 indicated at a certain time frame at the site 

13 at Mound, how would one do dose 

14 reconstruction? It would be you would have to 

15 use a coworker model, since you, apparently, 

16 wouldn't have data. The question is how would 

17 you do it if there wasn't a distribution you 

18 could rely on?

19 I think that is a similar issue to 

20 the ones at Rocky.

21 CHAIR BEACH: Well, you may have a 

22 problem identifying all the workers under the 
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1 one lapel. Because I know right now at 

2 Hanford that dose doesn't always follow the 

3 group of workers.

4 DR. ULSH: Okay, that's a separate 

5 issue because --

6 CHAIR BEACH: But it is an issue 

7 that I have.

8 DR. ULSH: Sure. It would 

9 certainly be an issue if we were relying on 

10 lapel air samplers to do dose reconstruction. 

11 And that is a separate issue that was also 

12 covered extensively in our response.

13 We are not proposing to use lapel 

14 air samplers for dose reconstruction. I'm not 

15 going to commit to saying that they are never 

16 any good. All I'm saying is at Mound we use 

17 urinalysis.

18 CHAIR BEACH: But you used lapel 

19 to decide who got the urinalysis? Is that not 

20 correct?

21 DR. ULSH: No, the use of -- not 

22 entirely correct. It's incomplete. Let's put 
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1 it that way. The lapel air sampling was 

2 layered on top of routine bioassay and on top 

3 of whatever was required by an RWP.

4 CHAIR BEACH: Okay.

5 DR. ULSH: Now, if you had a lapel 

6 air sampler that gave you a positive reading, 

7 that gave you an indication that there might 

8 have been an exposure, then that would be a 

9 triggering event for getting a special 

10 urinalysis sample.

11 CHAIR BEACH: But it had to hit a 

12 certain --

13 DR. ULSH: Well, sure, it had to 

14 give you a positive indication --

15 DR. NETON: Above and beyond the 

16 routine --

17 CHAIR BEACH: Okay.

18 DR. ULSH: But that's layered on

19 top of routine and probably RWP-specific 

20 urinalysis as well.

21 MR. FITZGERALD: But, you know, 

22 again, the population of, quote, "D&D workers" 
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1 is a pretty heterogeneous group, and they were 

2 monitored that way, which made sense. But, on 

3 the other hand, if you're going to apply a 

4 coworker model for that group, can the 

5 distribution be relied upon if, in fact, most 

6 of them, if they weren't monitored regularly 

7 or had lapel sample, didn't have this 

8 termination bioassay?

9 I'm just raising that question. I 

10 think, from our perspective, it would be 

11 difficult, and it wouldn't be necessarily 

12 representative, if you missed 50 percent, say 

13 50 percent was non-compliance. I don't know 

14 what that number is actually.

15 DR. NETON: It is not clear to me 

16 that, you know, people don't -- you're not 

17 going to have 50 percent of the people leaving 

18 en masse, I don't think.

19 MR. FITZGERALD: Without doing a 

20 termination? I think Rocky came out to be 

21 almost a third --

22 MEMBER CLAWSON: A third?
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1 MR. FITZGERALD: -- as I recall. 

2 That's why that concern was the genesis of 

3 looking at the distribution because that 

4 would, in fact, influence the coworker, if you 

5 were missing that much of the --

6 DR. ULSH: Well, again, I get back 

7 to the point in our response where we said 

8 that in order for that to be a problem --

9 let's say it's a third, like it may have been 

10 at Rocky. I don't remember.

11 MR. FITZGERALD: Right, right.

12 DR. ULSH: You would have to have 

13 some evidence that there was selective non14 compliance where you would have the highest 

15 exposed people more likely to skip their 

16 termination bioassay. That doesn't sound 

17 plausible to me. I can't envision a scenario 

18 where you would have the highest exposed 

19 people being more likely than anyone else to 

20 skip out on the termination --

21 MR. FITZGERALD: I don't know. 

22 I'm just raising the question how 
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1 representative is the distribution. I don't 

2 know.

3 DR. ULSH: I would say, from the 

4 Rocky experience, and Gene's on the phone and 

5 can attest to this, you're correct that we did 

6 do some analyses there that turned out to show 

7 not a problem. That wasn't a trivial 

8 undertaking.

9 MR. FITZGERALD: Right.

10 DR. ULSH: I'm not saying that 

11 we're refusing to do it. That's not within my 

12 power to do that. But I just want to caution 

13 you, consider the level of effort and the time 

14 that is going to be involved in pursuing this, 

15 if we take a similar approach at Rocky.

16 MEMBER ZIEMER: At Mound.

17 DR. ULSH: Yes, sorry. It is 

18 late.

19 (Laughter.)

20 MR. FITZGERALD: Not to meld the 

21 two sites any further, but I just think that 

22 is the question that we have on the table. It 
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1 is the Work Group's judgment, but whether the 

2 coworker model would be representative, if you 

3 were missing a large degree of the data, the 

4 bioassay, termination bioassay data --

5 MEMBER CLAWSON: So everybody at 

6 Mound during the D&D era were on a routine 

7 bioassay?

8 DR. ULSH: No.

9 MEMBER ZIEMER: No.

10 DR. ULSH: The DOE order in place 

11 at -- I can never remember that darn thing --

12 DR. NETON: 54.11.

13 DR. ULSH: -- 54.11 indicated that 

14 if you had less than 100 millirem exposure 

15 potential per year, you weren't required to be 

16 on a bioassay.

17 DR. NETON: 10 CFR 835.

18 DR. ULSH: But if you had an 

19 exposure potential higher than that, you were 

20 required to do routine bioassay.

21 MEMBER ZIEMER: So, in principle, 

22 it is the most likely exposed people were on 
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1 the program.

2 MEMBER CLAWSON: And I understand 

3 what the theory behind that is, but I'm 

4 watching it right now, that it's interesting 

5 because people are popping from one area to 

6 another. Unfortunately, in talking to the 

7 workers of Mound, there were numerous ones 

8 that said, "I have no bioassays." And they 

9 were there for only the last five or six 

10 years.

11 DR. ULSH: It wouldn't surprise 

12 me.

13 DR. NETON: I mean I'm sure they 

14 had the rad worker, 1 rad worker 2 

15 categorization going. So the people in the 

16 rad worker 2 were the ones that were 

17 identified having the potential for exposure, 

18 exposures typically exceeding 100 millirems. 

19 Your rad worker 1 probably weren't going to be 

20 sampled. That was some conscious effort went 

21 into deciding, making those decisions.

22 You also have to remember they had 
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1 this lapel air sampling program. By and 

2 large, lapel air samples are much more 

3 sensitive than any bioassay program for 

4 plutonium, for example, much more sensitive. 

5 You can get down to DAC-hour tracking on lapel 

6 samples, where a urinalysis sample is not 

7 going to show something at a much, much higher 

8 level of missed dose.

9 So you've got those things that 

10 would trigger the special samples, and there's 

11 sort of multiple layers built into this 

12 program by this era. I agree with Brant that 

13 it would be hard to imagine that a worker 

14 would have gotten out the door without having 

15 -- with having had a very significant 

16 exposure.

17 MR. FITZGERALD: Yes, one last 

18 word. Again, the termination bioassay is your 

19 safety net in a system where you are taking 

20 people off of routine bioassay, relying on 

21 these different hierarchies of specifics, 

22 monitoring in certain locations.
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1 I think, whereas in a routine 

2 program the termination bioassay is probably 

3 less important, in this case I think it is 

4 actually relatively more important. But, 

5 again, I think --

6 DR. NETON: Let me be clear what 

7 we are talking about here then. I mean these 

8 were short-term D&D workers that maybe worked 

9 three months and had an entrance baseline and 

10 a termination? Is that what we are talking 

11 about?

12 MR. FITZGERALD: I think there is 

13 a different -- it is a very heterogeneous 

14 group. I think you had people that were 

15 probably there for a fair amount. There were 

16 people that were in and out fairly quickly. 

17 Some were probably rad worker 1 that did real 

18 hot work. Some people were probably ones that 

19 did support work. Some people were probably 

20 construction crews that dug things in the 

21 ground who may or may not have been 

22 bioassayed, depending on the RWP.
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1 In that kind of a process, you 

2 would have to be, I think, careful that, 

3 because the group is heterogeneous and you do 

4 have some reliance on RWPs and how samples 

5 that -- if you didn't have some way to verify 

6 before they actually ended employment that 

7 they didn't pick something up, I'm not sure 

8 how you would actually assign something.

9 If somebody came back as a 

10 claimant saying, "I worked these 18 months at 

11 this site, did construction work. I can't 

12 remember if I did it under RWP", and 

13 voluntarily did not do a bioassay at the 

14 end --

15 DR. ULSH: But let me ask you 

16 this, Joe.

17 MR. FITZGERALD: Yes.

18 DR. ULSH: I mean everything that 

19 you just said here in the past minute or so, 

20 you could take out Mound and you could put in 

21 Rocky Flats. The situation is exactly the 

22 same. You had a heterogeneous population. 
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1 You had people --

2 MR. FITZGERALD: Well, and the 

3 same D&D era, too, yes.

4 DR. ULSH: You had the same 

5 regulations in place.

6 MR. FITZGERALD: Yes.

7 DR. ULSH: You had the same 

8 contractor in place.

9 MR. FITZGERALD: Right.

10 DR. ULSH: Is there any reason to 

11 believe that the experience at Mound would 

12 have been significantly different from the 

13 experience at Rocky Flats, given all those 

14 similarities?

15 MR. FITZGERALD: I don't know. I 

16 don't know, and you don't, either. I just 

17 think we are saying that, based on the system 

18 in place, we would believe, but don't know 

19 whether or not the lack of termination 

20 bioassay would matter.

21 In other words, we are saying it 

22 wouldn't matter because the system was 
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1 implemented effectively enough that it is 

2 unlikely that somebody who would have had an 

3 intake would not -- get off the site without 

4 having that intake estimated. And I'm saying, 

5 well, that may be, but my experience at DOE, I 

6 would be a little nervous to make that 

7 assumption that the system was so tight, that 

8 you are unlikely to have anybody with an 

9 intake not being accounted for, particularly 

10 if there is a low compliance rate on the 

11 termination bioassay.

12 These were voluntary, and people 

13 just, when they left --

14 DR. NETON: Were they voluntary? 

15 I'm not sure if they --

16 MR. CHEW: At Rocky Flats, they 

17 were. I do not know about Mound.

18 MR. FITZGERALD: Well, I mean the 

19 employment contract had them coming back, but 

20 a lot of them just didn't, and when they left 

21 the site, they were gone.

22 DR. NETON: I've had that similar 
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1 experience at Fernald.

2 MR. FITZGERALD: Yes.

3 DR. NETON: I mean you can't make 

4 contractors, who you don't even know are 

5 leaving that day, submit a sample. Even if 

6 you mail them specimen bottles, you're not 

7 going to get them back.

8 MR. FITZGERALD: I guess it's a 

9 two-part question. I mean, if the answer is 

10 you had 80 percent compliance, and that number 

11 I think is accessible, just by virtue of --

12 DR. NETON: That was going to be 

13 my question. I mean, how difficult would it 

14 be to just obtain that raw statistic, which 

15 is, what percentage of people who 

16 terminated --

17 DR. ULSH: I don't know.

18 Gene, are you still on the line?

19 MR. POTTER: Yes, I am.

20 DR. ULSH: We actually have the 

21 benefit of having Gene on the line. Gene did 

22 this effort for us at Rocky Flats, and Gene is 
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1 also at least moderately familiar with MESH.

2 So I'll put that question to you, 

3 Gene. How significant of an effort are we 

4 talking about here?

5 MEMBER ZIEMER: Just define the 

6 numbers now --

7 MR. POTTER: I haven't worked with 

8 the MESH data recently enough to really answer 

9 that question. You know, we struggled with 

10 this at Rocky Flats, like all DOE contractors 

11 did, and I even did a study among the 

12 Westinghouse contractors at one point. This 

13 is a common issue, as I think we all realize.

14 But I would just say that, using 

15 the example of Rocky, the people doing the 

16 heavy D&D work were the union workers who were 

17 generally long-term employees. Most of the 

18 ones that were, you know, coming and going, 

19 they may have been removing asbestos in non20 rad areas, for example. A short-term 

21 contract, you may not know they are onsite. 

22 You certainly didn't know when they left, that 
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1 sort of thing. Not heavy D&D people.

2 I can't think of a single example 

3 where we have a guy, you know, as we have 

4 discussed, workplace indicators, such as lapel 

5 sampling for contaminations, nasal swabs, and 

6 so forth, the real way to detect intakes of 

7 alpha emitters of regulatory significance, and 

8 I can't think of any of our people who had 

9 significant intakes that would not be aware of 

10 and participate in the termination bioassay 

11 program.

12 MR. FITZGERALD: Is this Rocky, 

13 Westinghouse, and which workers? This 

14 is Rocky?

15 DR. ULSH: Rocky, right, Gene? 

16 Who are we talking about?

17 MR. POTTER: Yes, I'm giving 

18 examples of my familiarity with termination 

19 bioassay at Rocky.

20 MR. FITZGERALD: Oh, Rocky. Okay.

21 MR. POTTER: And also, I tried to 

22 answer the question on Mound, but I really 
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1 didn't. I'm not sure how hard it would be to 

2 look at the termination statistics.

3 DR. NETON: Yes. You would almost 

4 have to know that they were required to leave 

5 a sample. So you have to get to an RWP level, 

6 I would think.

7 DR. ULSH: I think that is kind of 

8 what we --

9 DR. NETON: And look at a 

10 termination date, and it would be, in 

11 retrospect, thinking about it, it might be a 

12 fairly --

13 DR. ULSH: Non-trivial. And 

14 again, I bring you back to our response, where 

15 we lay out the extensive unlikely chain of 

16 events for this to happen. I can't say that 

17 it's 100 percent impossible, it's not. But 

18 all of these levels of monitoring would have 

19 to fail and --

20 MEMBER ZIEMER: And it would have 

21 to be widespread.

22 DR. ULSH: Well, right, and he 
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1 would have to get a significant uptake after 

2 his last sample, and then leave before he got 

3 another one, and we would have to have a 

4 reason to believe that the most highly-exposed 

5 people were more likely to have this happen. 

6 I just don't see it.

7 MR. FITZGERALD: Now I know, as I 

8 recall, the bioassay program at Rocky did keep 

9 that statistic because I think that was one of 

10 the drivers for us raising the issue, was I 

11 think it was a third or something where they 

12 were indicating that was the experience in 

13 terms of voluntary compliance with doing a 

14 termination bioassay.

15 I think to look at this issue, 

16 rather than you bite the whole apple, the 

17 first question is, how widespread? I mean, if 

18 it turns out that it is 75 percent compliance, 

19 that makes it a much different question than 

20 if it's, say, 30 percent compliance. If that 

21 answer, if that statistic is available in the 

22 bioassay program records or from the D&D era, 
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1 which is not that far back, that would be 

2 something that would help.

3 DR. NETON: Unless Mound had 

4 calculated it and provided it in some sort of 

5 a memo format, I don't know exactly if they 

6 are available.

7 MR. FITZGERALD: I don't know. 

8 Like I said, I haven't seen it, but I haven't 

9 looked for that specific piece of information. 

10 I am wondering if somebody, since that wasn't 

11 that far back, I don't know if Liz Brackett or 

12 somebody could actually maybe put their 

13 fingers on that kind of information.

14 Because I would propose that you 

15 don't launch into something without at least 

16 having that piece of information maybe 

17 available.

18 DR. ULSH: You know, our response 

19 is on the table. I'm reluctant to commit to 

20 something when I don't know what level of 

21 resources are going to be required. At least 

22 in my estimation, it is very implausible that 
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1 there would be a problem. Nonetheless, my 

2 opinion is not what drives it. If the Working 

3 Group has a sufficient concern, and you would 

4 like us to check into it --

5 CHAIR BEACH: I would like to go 

6 on record saying, yes, I would like you to 

7 check into it because --

8 DR. NETON: And keep in mind, this 

9 could be a huge man-hour effort.

10 MEMBER ZIEMER: I wonder if we can 

11 do it, I wonder if we could consider a two12 step process, where you determine -- because 

13 Gene didn't seem to know -- whether or not 

14 that information is sort of readily available 

15 versus -- and then maybe come back and say, 

16 Here's what it's going to take in time and 

17 effort to do this.

18 I would be reluctant to task them 

19 to a $50,000 effort or something.

20 CHAIR BEACH: Right. Well, and I 

21 can agree with that, but I also --

22 MEMBER ZIEMER: I mean, if the 
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1 information is readily available, that's one 

2 thing. If it is a major -- both in time and 

3 effort, then we need to know that, it seems to 

4 me, in advance.

5 MR. CHEW: Just let me make a 

6 statement here. We've got to be a little 

7 cautious. Just because your name is on an RWP 

8 and you signed off on it, it doesn't 

9 necessarily mean that you went into the work 

10 area to do the work. You were there at the 

11 time the RWP was discussed. So not everyone 

12 whose name is on the RWP, then, necessarily 

13 had to submit a sample because they may not 

14 have gone into the hot area to do the job. So 

15 I just want to use caution.

16 MEMBER CLAWSON: And, Mel, I 

17 understand that, but vice versa, too. Just 

18 because you're not on an RWP does not mean 

19 that you didn't go into the area. We see this 

20 continuously.

21 MR. CHEW: That is probably more 

22 unlikely, though.
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1 MEMBER ZIEMER: That depends on 

2 how enforcement --

3 MEMBER CLAWSON: Yes.

4 MEMBER ZIEMER: Just a 

5 clarification, what document are you in? I 

6 guess I'm looking at the wrong one. What 

7 response document are you in at the moment? 

8 Or what is the date of it?

9 DR. ULSH: Well, it is September 

10 2009, and the title is: NIOSH Evaluation of 

11 Decontamination and Decommissioning Issues at 

12 the Mound Laboratory.

13 MR. FITZGERALD: And that was No. 

14 -- what number was it?

15 DR. ULSH: I don't know. Matrix 

16 issue, you mean?

17 CHAIR BEACH: Oh, 10.

18 DR. ULSH: Ten?

19 CHAIR BEACH: Ten?

20 DR. ULSH: Matrix Issue 10.

21 CHAIR BEACH: Yes.

22 DR. ULSH: Paul, I sure hope this 
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1 is not one where I forgot to put you on 

2 distribution.

3 MEMBER ZIEMER: Well, I'm not 

4 finding it here, but sometimes it's --

5 MR. FITZGERALD: It is SC&A 

6 Comment No. 7 in that document.

7 CHAIR BEACH: Well, I've got a 

8 hard copy here, too, that I would hand to you, 

9 if you want to look at it, Paul.

10 MEMBER ZIEMER: Yes.

11 CHAIR BEACH: I am just not 

12 willing to let that issue go. I understand 

13 Paul's suggestion of maybe doing it in a two14 step. I would agree with that.

15 DR. ULSH: So is the action item, 

16 then, that I hear is: get back to the Working 

17 Group with an estimate of what level of effort 

18 is required to come up with the frequency of 

19 termination bioassay? Right?

20 CHAIR BEACH: Yes.

21 MEMBER CLAWSON: At least the 

22 feasibility of it.
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1 DR. NETON: Or, if it is readily 

2 available, we would report the number, but if 

3 it looks like it is going to be more than just 

4 a trivial exercise, we would report back.

5 MR. FITZGERALD: I guess it is the 

6 difference between, if there was some 

7 documentation, a memo, or something that would 

8 put that information forward or not --

9 DR. ULSH: If it has already been 

10 calculated?

11 MR. FITZGERALD: Right, yes. In a 

12 sense, if somebody was tracking this, if it 

13 wasn't done, then, yes, I think doing it fresh 

14 would be pretty onerous.

15 DR. ULSH: Okay, I've got that 

16 noted as an action item.

17 MEMBER ZIEMER: Is this NIOSH 

18 response to Mound matrix Issue 10, dated 9/4?

19 DR. ULSH: Oh, no.

20 (Laughter.)

21 CHAIR BEACH: Did I give you the 

22 wrong one?
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1 DR. ULSH: 9/4? September 4th?

2 MEMBER ZIEMER: Yes. Go ahead.

3 CHAIR BEACH: 2009?

4 DR. ULSH: Oh, you're talking 

5 about an email title? That may very well be 

6 it.

7 MEMBER ZIEMER: No, I'm talking 

8 about a document. Yes, it is this one that 

9 you -- I have this.

10 DR. ULSH: What you just read, 

11 NIOSH response, was the subject --

12 MEMBER ZIEMER: That was the email 

13 title.

14 DR. ULSH: -- line of the email, 

15 yes.

16 MEMBER ZIEMER: Yes, yes. I've 

17 got it.

18 CHAIR BEACH: Okay, anything else 

19 on D&D?

20 (No response.)

21 Any unfinished issues? I think we 

22 would like to get back to you in email form on 
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1 action items.

2 DR. ULSH: That would be great.

3 CHAIR BEACH: Instead of trying to 

4 rehash them here with the scribbles that I 

5 have and Joe has, and probably everybody else.

6 MEMBER CLAWSON: Josie, I do have 

7 some questions --

8 CHAIR BEACH: Okay.

9 MEMBER CLAWSON: -- with Brant on 

10 tritium.

11 You said earlier that the reason 

12 that you don't have a coworker model for 

13 tritium was because you had specific people 

14 that were, 10 people, if I remember right, it 

15 was?

16 DR. ULSH: No. You're mashing 

17 together --

18 MEMBER CLAWSON: Tritides. 

19 Tritides. Okay.

20 DR. ULSH: For hafnium tritide, 

21 what I am saying is the workers that we 

22 interviewed named the 10 people who could have 
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1 an exposure potential for hafnium tritide.

2 For other tritides, we are 

3 proposing that anyone on tritium bioassay at 

4 Mound could have potentially been exposed to 

5 those others.

6 MEMBER CLAWSON: Okay. Well, with 

7 those 10 people, here's my question. It's 

8 twofold. How were they controlled? How did 

9 they control that they were on a tritium 

10 bioassay? I mean, was it the facilities?

11 My understanding was these 

12 facilities, you have to be on a bioassay.

13 DR. ULSH: Yes. Yes. In the 

14 tritium buildings at Mound, to go in there in 

15 that time frame, you were required to be on 

16 tritium bioassay. So, for those 10 people, 

17 yes, they would most certainly be on tritium 

18 bioassay.

19 MEMBER CLAWSON: Well, what 

20 happened to the product after you got done? 

21 This hafnium tritide, once they built this, 

22 were there any other people that could have --
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1 or what happened to the product after they 

2 made this? Who could have been involved with 

3 it?

4 DR. ULSH: It went to its intended 

5 purpose.

6 MEMBER CLAWSON: Okay. So nobody 

7 else ever touched it except these 10 people? 

8 This is part of my thing. I'm seeing and I'm 

9 watching that maybe on this scale in the 

10 laboratory they built this project. They 

11 built this item, and those 10 people were the 

12 only ones that were involved with it. But 

13 then it proceeded on down the pathway, and 

14 other people were involved with it then, 

15 because they weren't involved in the 

16 production of it, but they were involved in 

17 the handling and processing of it.

18 DR. ULSH: Let me be careful.

19 MEMBER CLAWSON: Right.

20 DR. ULSH: It would not have been 

21 in the form, Brad, that would have presented 

22 an exposure potential.
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1 Now I think that that is my 

2 answer. There might be some situations that 

3 we're still discussing with SC&A.

4 MEMBER CLAWSON: Okay.

5 DR. ULSH: So I don't want to 

6 present --

7 MEMBER CLAWSON: And I think those 

8 we're going to have to do in a different 

9 atmosphere because I just want to make sure, 

10 because I have seen this happen before. As 

11 this product is produced, that part of it was 

12 reclassified, and as it went down the line, 

13 it --

14 DR. ULSH: Became less and less --

15 MEMBER CLAWSON: You didn't have a 

16 need to know of it. You know, you were just 

17 handling it.

18 But the only controls that bother 

19 me is I know right now in facilities that, if 

20 you work in this facility, then you are on 

21 this bioassay program. Now, for somebody to 

22 come into these facilities and do work, say 
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1 electricians versus whatever, that are not 

2 assigned to that facility, were the only 

3 controls rad worker permits?

4 Because I see it quite often that 

5 people come in and work in areas that require 

6 bioassays, but they are not a continuous 

7 worker there, so they don't put it. This is 

8 where I'm getting with the tritium. There's 

9 not a magic door there that you have to slide 

10 to be able to get through.

11 I know in our areas now we have 

12 people that, if you don't have keycard access, 

13 you can't get into our facilities because of 

14 the requirements. But there was nothing like 

15 that in Mound.

16 Some of the employees, and one of 

17 them was an electrician who made a comment 

18 that he was not on the tritium bioassay 

19 because he was actually out of kind of the 

20 central shop. I mean he didn't have to submit 

21 them because --

22 DR. ULSH: What time period? Do 
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1 you recall?

2 MEMBER CLAWSON: This was in the, 

3 well, he was there for 20 years, and the last 

4 era was in the late nineties. So, you know, 

5 that's back into the --

6 DR. ULSH: Without knowing the 

7 particulars, it's hard to say, Brad.

8 MEMBER CLAWSON: Right.

9 DR. ULSH: But my understanding is 

10 that, before DOE -- after that, there was the 

11 100 millirem per year criteria. So it is 

12 entirely plausible to me that the situation 

13 you are describing, where someone came out of 

14 the central shop, or whatever, if there was a 

15 judgment that his exposure potential was less 

16 than 100 millirem per year, he would not be 

17 required to be on bioassay after that time.

18 Before that time, it is my 

19 understanding that, if you went into the 

20 tritium buildings at Mound, even if you were a 

21 visitor, you were required to leave a tritium 

22 urine sample.
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1 MEMBER CLAWSON: Well, this is 

2 where we got into this visitor-type step. I'm 

3 just trying to get that clarified in my mind 

4 because it is amazing to me, and I see it 

5 continuously, that things fall through the 

6 cracks.

7 DR. ULSH: Well, and I can't --

8 MEMBER CLAWSON: You know, you 

9 can't -- I realize that. You can't --

10 DR. ULSH: And, Brad, I can also 

11 tell you, though, that if you look at layers 

12 of access, I can't tell you that there were 

13 keycard controls or that kind of thing.

14 MEMBER CLAWSON: There was, and 

15 I've already looked.

16 DR. ULSH: But you've got the 

17 tritium building --

18 MEMBER CLAWSON: Now in certain 

19 rooms there were.

20 DR. ULSH: That's where I am 

21 headed.

22 MEMBER CLAWSON: Right.
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1 DR. ULSH: The tritium building 

2 does not equate to tritide necessarily, and 

3 that certainly doesn't equate to hafnium 

4 tritide.

5 MEMBER CLAWSON: Right.

6 DR. ULSH: The places where the 

7 hafnium tritide were being worked on were 

8 security-controlled, security padlock9 controlled, and you didn't just wander in. If 

10 you were an electrician from somewhere else, 

11 if you didn't -- I mean you didn't just wander 

12 in there.

13 MR. CHEW: I think, and I remember 

14 that interview, too, when somebody had to come 

15 in to do any kind of work that you are talking 

16 about, I think the persons we interviewed said 

17 they secured the material.

18 DR. ULSH: Right.

19 MR. CHEW: That was very clear.

20 DR. ULSH: Yes.

21 MR. CHEW: Not only from a 

22 security standpoint, but from exposure to 
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1 that --

2 DR. ULSH: Well, it was in the 

3 follow-up.

4 MR. CHEW: Right.

5 DR. ULSH: Remember, we had the 

6 meeting in Germantown, and that was one of the 

7 things we were asked to follow up on with that 

8 person.

9 MR. CHEW: Right.

10 DR. ULSH: And we did that. That 

11 was the outcome of that.

12 MEMBER CLAWSON: Okay. Earlier 

13 today, we got into a discussion of when there 

14 was a question, and please forgive me for my 

15 ignorance, but I'm trying to understand the 

16 rules and the laws, too. You made the comment 

17 that you didn't understand why -- if this was 

18 an SEC issue. I want to ask you, what is 

19 considered an SEC issue?

20 (Laughter.)

21 Because I will be right honest 

22 with you. My interpretation of this is, if 
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1 there's a lack of data there, then it is an 

2 SEC issue. But I'm seeing that, if we can put 

3 some numbers up on it, then it is not an SEC 

4 issue. I'm just trying to get a feeling for 

5 what truly is the SEC issue.

6 DR. ULSH: Do you recall the 

7 context? Was it in the tritide discussion 

8 that this came up?

9 MEMBER CLAWSON: Yes.

10 DR. ULSH: Okay. What I meant 

11 when I said this is not an SEC issue is that, 

12 if we agree that the dose from hafnium tritide 

13 can be modeled, then, in my mind, it's my 

14 position that the SEC issue was closed. There 

15 might very well be a legitimate TBD issue.

16 In other words, the question would 

17 be, okay, well, you've got this model for 

18 hafnium tritide, but who are you going to 

19 apply it to? Is it just these 10 people? Is 

20 it a larger group of people?

21 A very valid question, but not an 

22 SEC issue. It is a TBD issue.
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1 MEMBER CLAWSON: Okay.

2 DR. ULSH: Because, at worst -- at 

3 worst -- we could say we're just going to 

4 apply it to everyone on tritium bioassay. So, 

5 to me, that's an application question. That 

6 is a TBD issue. That is totally separate from 

7 SEC.

8 MEMBER CLAWSON: And this is what 

9 I'm trying to understand because, in that 

10 context, it basically could be said that there 

11 are no SEC issues because we can always put a 

12 number on it.

13 MEMBER ZIEMER: No, no.

14 DR. ULSH: Not necessarily. Not 

15 necessarily, Brad.

16 For instance, let's say we 

17 couldn't agree. Let's say it was -- I don't 

18 know; I'm just saying -- let's say it was 

19 SC&A's position that there's no way you can 

20 estimate doses from hafnium tritide. That 

21 would be an SEC issue because then we can't 

22 estimate the dose. We can't bound the dose.
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1 But, once we agree that you can do 

2 that, then we enter into the arena.

3 MEMBER CLAWSON: And like I say, 

4 please forgive me for my ignorance here, but 

5 then we go clear to the other side of if it's 

6 plausible or not. And I'm trying to get it 

7 figured out because I've seen some lung counts 

8 now that, you know, you even say to yourself, 

9 Paul, why couldn't we figure this one? 

10 Because of the radon, then it went clear to 

11 implausible, but it's an SEC issue.

12 I am really trying to get a handle 

13 around an SEC issue because, to me, take the 

14 420 boxes that were buried. You know, there's 

15 insufficient data there. Or it's come up so 

16 many times, and I really have a hard time 

17 understanding about the SEC issues, of what 

18 constitutes a lack of information.

19 MEMBER ZIEMER: Well, the ones 

20 where we have had clear SECs are ones where 

21 they don't have an idea, for example, on how 

22 much activity was there. That would be a 
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1 simple case. You don't know how much activity 

2 was there. You know that there was, let's 

3 say, thorium, but not how much or how it was 

4 used. You don't have any basis to come up 

5 with any number, high or low.

6 DR. NETON: If you look at the 

7 SECs that have been granted to date, most of 

8 them have been internal exposure issues where 

9 there is no monitoring data, thorium 

10 particularly and some other nuclides. So you 

11 have no bioassay monitoring data and no means 

12 to determine what the upper limit could have 

13 possibly been, based on other values, like air 

14 sampling. There's no good air sampling 

15 measurements. There's no source term mix.

16 MEMBER ZIEMER: Which is different 

17 than saying it is a big dose, but I know it is 

18 no greater than this. You can't bound it.

19 DR. NETON: Right. Otherwise, we 

20 would be guessing, if we had to put an upper 

21 limit. I could say it's certainly less than 

22 some million rem, but that's not a plausible 
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1 value. There's no logical connection there 

2 why you believe it --

3 MEMBER CLAWSON: Well, I'm trying 

4 to figure out where that area is in there 

5 because I'll give you a situation, and we just 

6 have it, and that's NTS. Look at everything 

7 that we had there, and then, all of a sudden, 

8 it's not.

9 I'm really having a hard time 

10 getting around what really is an SEC issue 

11 because it seems like to me that we could put 

12 a number on anything, but then we get into the 

13 plausible and not plausible.

14 DR. NETON: Yes, it is a very 

15 difficult issue. I think you are not alone in 

16 that sense. I mean it is a struggle to 

17 determine when it is truly implausible. That 

18 is why we have these debates. I mean it takes 

19 a long time to -- or discussions, I'll say --

20 to come to that conclusion.

21 And NTS is a good example. It 

22 took us a while to pull the thread far enough 
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1 to say, you know, at the end of the day, it's 

2 true, we don't really know with any confidence 

3 what the upper limit on these exposures were. 

4 We've got a lot of data, but we had to pull 

5 the thread all the way to the end, and then 

6 finally say there's no more thread to pull, 

7 and there's no connection we could make to 

8 their exposures, based on the bioassay 

9 monitoring program that was in place at the 

10 time.

11 MEMBER CLAWSON: Well, so I hope 

12 you, I hope NIOSH understands, as the Work 

13 Group, why we pull on some of these threads so 

14 far. It is because this has been an ongoing 

15 thing. I hope that the frustration with us, 

16 me and sort of whatever else like that, but 

17 this is a difficult thing for us to get 

18 around. It sounds like that it is difficult 

19 for all of us. And I know for the claimants 

20 because I have heard numerous times, how come 

21 this; how come that?

22 And if there's no data, you have 
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1 only got these two points, how come don't we 

2 get it? I just wanted to know where we were 

3 at on that because I'm really having a hard 

4 time getting around that. I'll be honest.

5 It's yours.

6 CHAIR BEACH: The only other thing 

7 is the security thing we talked about. Do we 

8 want to try to come up with some type of a 

9 date or should we wait? Because I know the 

10 biggest holdup will be getting the documents 

11 to one place, which we haven't agreed on where 

12 that may be.

13 DR. ULSH: Josie, can you talk 

14 about that after we close?

15 CHAIR BEACH: Yes, sure.

16 DR. ULSH: I've got some thoughts, 

17 and maybe I can get some clarification from 

18 you.

19 CHAIR BEACH: Okay.

20 MEMBER CLAWSON: I know DOE-Idaho 

21 has got some nice areas.

22 CHAIR BEACH: So does Hanford.
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1 (Laughter.)

2 Okay. So, then, I would like to 

3 officially close this portion of the meeting.

4 MR. KATZ: Do you even want to try 

5 to schedule the next or is that too many 

6 uncertainties to do that?

7 CHAIR BEACH: Can we do that 

8 offline?

9 MR. KATZ: Yes, we can. We don't 

10 have to schedule online.

11 CHAIR BEACH: Okay. Let's close 

12 then.

13 MEMBER CLAWSON: I think, most of 

14 all, we have got to get our kind of note to --

15 CHAIR BEACH: Well, we need to get 

16 the action items out, so that everybody kind 

17 of knows. Because I know some things SC&A is 

18 going to wait for NIOSH. So it might be 

19 difficult to try to plan it.

20 And we also need to have the 

21 secure meeting before --

22 MR. KATZ: Sure, and that can take 
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1 some doing.

2 CHAIR BEACH: Yes. It's tough.

3 MR. KATZ: So we are adjourned?

4 CHAIR BEACH: Yes.

5 MR. KATZ: We are adjourned. 

6 Thank you, everyone who has hung in with us on 

7 the telephone.

8 (Whereupon, the above-entitled 

9 matter went off the record at 4:11 p.m.)

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