NEAL R. GROSS

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Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

124th Meeting

Wednesday, August 22, 2018

The meeting convened at 8:30 a.m., Eastern Time, 

at the Hilton Providence, 21 Atwells Avenue, 

Providence, Rhode Island, Ted Katz, Designated 

Federal Official, presiding.
2 

Members Present: 

Henry Anderson, Chair

Josie Beach, Member

Bradley P. Clawson, Member

R. William Field, Member*

David Kotelchuck, Member

James E. Lockey, Member

Wanda I. Munn, Member

David B. Richardson, Member

Genevieve S. Roessler, Member*

Phillip Schofield, Member

Loretta R. Valerio, Member

Paul L. Ziemer, Member*

Ted Katz, Designated Federal Official

Registered and/or Public Comment Participants: 

Adams, Nancy, NIOSH Contractor

Barrie, Terrie

Blaze, D'lanie

Calhoun, Grady, DCAS

Crawford, Chris, DOL*

Darnell, Pete, DCAS*

Domina, Kirk

Elliott, John

Elliott, Michael

Fitzgerald, Joe, SC&A

Grimes, Kurt*

Harmond, Lokie, DOE 

Hartsfield, Dekeely, HHS

Hand, Donna* 

Hanlin, Daryl 

Hinnefeld, Stu, DCAS

Hughes, Lara, DCAS

Mauro, John, SC&A*

Mcfee, Matthew, Orau Team

Nelson, Chuck, DCAS

Neton, Jim, DCAS

Rutherford, Lavon, DCAS

Stiver, John, SC&A

Taulbee, Tim, DCAS

Whitten, Dianne
3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health 124th Meeting 

Wednesday, August 22, 2018 1

Roll Call/Welcome 4

NIOSH Program Update 10

DOL Program Update 16

DOE Program Update 22

Feed Materials Production Center Site Profile 

Review 24

Sandia National Laboratory Petition #188 51

SEC Petition Status Update 60

Board Work Session 63

Procedures Reviews (Estimating Skin Doses) 

OTIP 17 (Findings 7 & 15) & Overarching Issue 

9 81

Metals and Controls Corp. SEC Petition #236 

(Attleboro, MA, 1968-1997) Update 94

Public Comment 122

Adjourn 142
4 

Proceedings

(8:29 a.m.) 

Roll Call/Welcome

Mr. Katz: Good morning, everyone on the line and in 

the room. This is the Advisory Board on Radiation 

and Worker Health. This is our meeting Number 124.

I think we're setting some sort of record in Advisory 

Board meeting numbers. But, first, some 

administrative -- well, first of all, welcome, everyone, 

to the meeting.

Some administrative matters first. For people who 

are following along remotely and not in the room, the 

meeting materials for today's meeting, the agenda 

and the materials are posted on the NIOSH website 

under this program, under schedule and meetings, 

today's date.

So you can go there, you can pull up the agenda, you 

can pull up the background reading as well as the 

presentations that are being given today and 

tomorrow, this meeting goes through mid-day 

tomorrow, and follow along that way.

Also, the agenda has on it information for a Skype 

link. And so if you want to follow along by Skype, 

then you can actually see the presentation slides as 

they're being presented in the room. You don't have 

to do that, but you can.

Also, public comment time. There's a public 

comment session today at the end of the day. It 

begins at 5:00 and continues till 6:00 or until the 

comments are finished, whichever comes first.

So if you plan to give comments and you're remote, 

please be on the line by 5:00 because we never know 

how long that will go.

And just to note for people in the room, public 

comments, there's a sign-in book outside, and you 

should sign up if you want to give public comments.
5

Let's do, for roll call, we'll do roll call. I think -- hello? 

It's okay?

Okay. For roll call, I'll speak to conflict of interests, 

it just makes it easier, then we'll run through the roll 

call.

But for today's sessions we have two sessions where 

there are conflicts among Board Members. We have 

a Feed Materials Production Center, Fernald as we 

know it, discussion of the Site Profile review. And for 

that Dr. Jim Lockey will be recused from that 

discussion.

And then following that and a break we have an SEC 

Petition discussion for Sandia National Laboratory. 

And for that session we have two Members who will 

recuse themselves. And that is Mr. Schofield and Ms. 

Valerio. So I just note that now; it's easier.

So let's run through roll call. We have several Board 

Members who couldn't be here in person, but should 

be on the line. And we'll just run down alphabetically.

(Roll call.)

Mr. Katz: Okay, then, so, last piece of business, this 

is not administrative, but we have -- we've had some 

Board Member retirements since we last met, and 

we're going to have a tribute for that.

And for that we're going to have Ms. Beach read the 

tribute and then put that forward as a motion for the 

Board to accept. Josie?

Member Beach: Yes. Hopefully you can hear me. 

I'm going to be reading off my computer here. It's 

not very long at all. Okay. Let me know if this is 

going to work.

Members of the Advisory Board on Radiation and 

Work Health, the Board, wish to pay tribute to Ms. 

Wanda Iris Munn and Dr. John W. Poston, Senior, 

who have resigned this year from the Board after 

tenures of extended and exceptional service.
6 

In both cases their CVs are far too extensive to do 

justice to their careers and accomplishments. But we 

hope to provide a brief sense of these.

Wanda began her service to the Board in 2002 at its 

inception as one of the ten original Members 

appointed by President George W. Bush. Her history 

and career, or careers, is colorful and storied and 

deserves some note.

She is the daughter of a pioneering American family, 

her mother having gone west in a horse drawn wagon 

in the late 1800s.

Her nuclear engineering career was preceded and 

accompanied by employment spanning medicine, 

education, investment, accounting, law enforcement, 

and elective office. This elemental family imprint and 

wide professional experience has been well reflected 

in her clear headed and practical perspectives on the 

-- and the diverse questions confronting the Board in 

its examination of historical operations at nuclear 

weapons facilities. It has also served the Board 

through the clear and systematic approach Wanda 

brought to resolving each question at hand.

As a front line nuclear engineer, a rare 

accomplishment among women of her generation, 

Wanda worked on the design and development, 

startup and management of the Fast Flux Test Facility 

at Hanford. The quality of her engineering work and 

-- was repeatedly awarded during her career and 

ultimately landed her in the Oregon State 

Engineering Hall of Fame.

It was also represented in her participation and 

leadership in professional societies associated with 

nuclear technology, including the Society of Women's 

Engineering, the American Nuclear Society, and the 

Columbia Chapter of Health Physics Society.

This rich professional experience at Hanford gave her 

keen insights into so many complex operations that 

the Board has evaluated over these years at so many 

diverse facilities.
7

The Board has benefitted and is grateful for the 

enumerable contributions made by Wanda, who 

missed no more than one or two of the hundreds of 

meetings of the Board and its many Work Groups and 

Subcommittees over her 16 year tenure.

It will also be missed the figure Wanda cut among the 

Board, as an independent minded colleague of feisty 

conviction, candor, and sympathy. Given the heavy 

burden of discussion that comprises our extensive 

Work Group and Subcommittee proceedings, the 

Board will perhaps especially miss the fine parsimony 

of her elegant dry wit and humor.

Dr. John Poston has been with us almost as long as 

Wanda. He was appointed to the Board by President 

George W. Bush in 2005.

He also bears some similarity to Wanda in his bent 

for efficiency. In John's case, he was not loquacious, 

he rarely spoke first or most on a matter before the 

Board and its subgroups.

Even as a Work Group chair, however, he always 

brought important clarity and his questions and quick 

resolve of technical issues and his insights and 

answers.

This is not surprising given his scientific pedigree. He 

is a highly published researcher in health physics and 

has served at the top levels of science, and more 

recent years, as a professor of nuclear engineering 

for Texas A&M and, previously, Georgia Institute of 

Technology, to heading the medical physics and 

international dosimetry at Oak Ridge National 

Laboratory.

He is a former president and fellow of the Health 

Physics Society, a fellow and former executive of the 

American Nuclear Society, a fellow of the American 

Association for Advancement of Science, 

distinguished emeritus member of the National 

Council on Radiation Protection & Measurement, a 

chair and member of multiple committees of the 

American National Standards Institute establishing 
8

national dosimetry and radiation protection 

standards and a longstanding member of just about 

every other national, international body addressing 

the measurement of exposures to ionizing radiation 

and the protection of radiation-exposed persons.

With his wealth of expertise, in addition to training 

generations of students of nuclear engineering and 

health physics, he has directly advised and led 

advisory committee serving numerous health physics 

programs of international, foreign national, federal, 

and private nuclear operations spanning decades.

These have covered a vast expanse of technologies 

and purposes, including power and nuclear weapons 

production, nuclear medicine, waste disposal, 

contamination, remediation, weapons production, 

nuclear medicine, waste disposal -- did I say that 

again, I did, sorry -- and addressing the threats of 

nuclear environmental disasters and terrorism.

The Board has been fortunate to have John's deep 

experience in dosimetry, its capabilities and 

limitations as it is practices across myriad operations, 

settings, and circumstances. It has also benefitted 

from his enduring collegial manner, his efficient 

chairing of Work Groups and his good company 

during its travels, which will be missed.

In as much as Wanda I. Munn and Dr. John W. 

Poston, Sr., have made significant contributions to 

the ongoing work of the Advisory Board on Radiation 

and Worker Health during their years of membership, 

we also remain -- we who remain as Members of the 

Board thank them for their service, their scientific 

insight, and their wise counsel through many 

complex Board deliberations. They have served the 

Board and this country well.

This tribute is hereby adopted this 22nd Day of 

August 2018, at the 124th meeting of the Advisory 

Board on Radiation and Worker Health in Providence, 

Rhode Island.

Mr. Katz: Thank you very much, Josie. And, Paul, 
9

do you want to handle the parliamentary business of 

getting this adopted? You might be on mute.

Member Ziemer: No, I'm here. I think we just 

require a second to Josie's motion, and I will give that 

second, then you can call for the vote.

Mr. Katz: Very good. So we have a second in Paul. 

And all in favor?

(Chorus of aye.)

Mr. Katz: Thank you. Motion passes. Thanks a lot, 

Josie.

Member Roessler: Ted, may I add something to that?

Mr. Katz: Yes, absolutely.

Member Roessler: This is Gen.

Mr. Katz: You or any other Members.

Member Roessler: The tribute certainly captures 

very well the talents and personalities of Wanda and 

John. When I reflect on their contributions, two 

words come to my mind, and that's intelligence and 

integrity. Their presence on the Board is going to be 

sincerely missed.

Mr. Katz: Thank you, Gen. Okay then. So let me 

just mention one last administrative matter. Stu, you 

can come up, it's okay.

Just, as you all note who see the agenda, we have 

POTUS designate still there for chair. We're still 

waiting for our Chair to be appointed. So that's still 

in the works.

In the meantime, I'm pitching in as acting chair. And 

as we've done previously with meetings, in my case 

that means I don't engage in the dialogue on issues, 

and I do not vote on issues, but I'm just 

administering the processes here.

Okay, and with that, thanks, Stu, we're on to the first 
10

agenda item. 

Mr. Hinnefeld: Thank you, Ted. I guess I'm coming 

over the, am I coming over the speaker okay?

Mr. Katz: Yes, you sound good.

NIOSH Program Update

Mr. Hinnefeld: Well, thanks and welcome, 

everybody. Nice to see everyone again. I was telling 

Ted a while ago it seems like I've been doing this for 

a long time, but not as long as Wanda though, that's 

for sure.

I'm here to give our typical update on news and 

statistics. A couple of things that are going on that I 

thought I would mention.

This first has to do with our website and the material 

that you can find on our website, or will soon be able 

to find on our website.

Now for some years now we have made it a point of 

putting discussion papers for Work Group meetings 

on our website in advance of the Work Group 

meetings so that people who were calling in to the 

Work Group would be able to follow the discussion 

and see the items that were being discussed.

And it's been a few years ago now, I was asked at a 

meeting in Denver, I know Terrie was there, I think 

D'Lanie and Kirk were there too, you know, it would 

be nice, these papers have references, it would be 

nice if we could see those references as well.

And I said, well, I think we could probably do that 

because, see, I didn't have to do the work to make 

that happen. So it took a lot more work than I 

thought, but it is very close. And probably by the 

next meeting we will have, be able to post 

references.

And there are a number of White Papers that have 

been there for a while that we have the references all 

lined up and ready to go, we just need to push the 
11

button and go live on this, on this application.

And there will be a link underneath the discussion 

paper that says, cited references. You click that link, 

and it will bring up a list of the references. And that 

list will also be clickable links, you can click on that 

link and it will pull up the reference.

Now some of these references we are not -- we won't 

be able to make public because they are just full of 

Privacy Act information. And rather than embark on 

this huge redaction campaign there is just going to 

be a note, not available to the public. And if 

something is not available, it's almost certainly 

because of Privacy Act information.

But anything that we can make public, it will be there 

for people to look at. And that is, also, serves the 

purpose of providing some public access to this 

wealth of documents that we've collected over the 

years.

So it took longer than I thought, and it was harder 

than I thought, but it's -- we built an application, our 

computer folks have built an application that walks 

us through the process and then loads it up on the 

website. So it's pretty good.

My second item has to do with, for some reason there 

seems to be a lot of national interest right now on 

low level radiation effects. We just recently had 

commissioned SENES -- I'm sorry, it's the Oak Ridge 

Center for Risk Analysis, used to be SENES, to do a 

paper on the latest information on dose and dose rate 

effectiveness factor, that's what DDREF is, which is a 

factor that modifies what would otherwise be a 

strictly linear no threshold model for dose effects.

And there is actually, in several national meetings, 

there is quite a bit of discussion being developed 

about the linear no threshold model and is it really 

the appropriate model to use. There was a discussion 

at the Health Physics Society meeting this summer. 

I think the plenary session was about low level risk 

and LNT.
12

The Conference on Radiation Health, which is a 

conference that meets every two years in association 

with the Radiation Research Society, is meeting in 

late September. And the topic is low level dose 

effects and LNT.

And there is even a debate one day about whether 

there is enough scientific information available to 

essentially reject LNT and say that the risk really isn't 

linear, down to zero.

And there's a similar meeting convened a week later 

by the Health Physics Society and the American 

Nuclear Society in Pasco, Washington, on low level 

radiation effects and the low level risk model, low 

level dose risk model.

And then I just learned that the National Academies 

will hold a meeting next May on low level radiation 

risk. And I think that is sort of a discussion of what 

research should be done going forward in terms of 

low level radiation health effect.

So there is quite of lot interest going on, on this topic 

right now. Quite a lot of discussion.

And I think in large part because of the degree of 

discussion and the various numbers, there are quite 

a number of opinions out there about what you

should be doing with low level radiation risk model.

We don't propose to change our model right now, 

based on anything we've received. We intend to wait 

for the discussion to proceed for a while before we do 

anything with any modifications to the IREP model 

along those lines.

The IREP model does in fact include right now dose 

and dose rate effectiveness factor. And we just 

figured, until something more definitive comes up, 

we'll just continue to use what we're using. So that's 

where that stands right now.

And then the rest of our updates are outreach type 

information. Since the last meeting we did 
13

participate in a DOL sponsored authorized 

representative workshop. That was in Kennewick, 

where they have invited authorized reps. And they're 

organizing these sort of aligned with their district 

offices. So it wasn't in Seattle it was in Kennewick, 

but it kind of aligned with Seattle Office.

They did one last winter in Florida, aligned with the 

Jacksonville Office.

And then at the bottom of the slide you'll see that the 

DOL is sponsoring another one in Cincinnati. That 

would be aligned, essentially, with the Cleveland 

District Office, even though it's a couple hundred 

miles away.

So we are -- and we, I think, are going to host that. 

It looks like right now we will host that DOL 

sponsored authorized workshop in our building, so 

we'll be involved in that also.

In addition to that, we also conducted a one day dose 

reconstruction and SEC workshop, a site specific one 

for Sandia, in Albuquerque back in June.

We do that with our outreach contractor, ATL 

international. And also in conjunction with them 

annually, they sponsored a two day dose 

reconstruction and SEC workshop in Cincinnati, that 

we provide most of the presentations for.

Our staff goes down and presents most of those. So 

that's coming up in September of this year as well.

So those are my news items. I'll go on to some 

statistics. I'll just go through these really quickly. 

They're in the handouts.

These numbers of total cases going inexorably 

higher. Closing in on 50,000 cases that we've 

received. And some thousand of them, you know, 

our inbox tends to have about 1,000 of them at any 

given time. Things that we've received that are not 

done yet.
14

Of those that we've returned to DOL, most of them 

were returned with a DR and a few have been pulled 

for various reasons. And then about 3,500 have been 

pulled for SEC.

We're at the point now that when we add SECs, 

oftentimes we don't pull that many claims for SEC 

because when we add an SEC, we don't have this big 

pile of claims sitting there to be done. We've done 

the dose reconstructions, and so DOL will actually 

then go reopen those cases and run them through 

the SEC process after we had already sent them 

back. So, but they get a second look when the SEC 

is added, after we've already done the dose 

reconstruction.

These are how the breakdown of the cases in our 

inbox occur. Some 160 of those, where we have 

completed a draft dose reconstruction that's with the 

claimant to review and then provide the OCAS-1 back 

to us.

So we think we might be done with those, depending 

upon what the claimant tells us when they see the 

draft. So they're not all sitting on -- in our place.

Of the cases that have sent back, these are the 

breakdown on successful versus unsuccessful or 

compensated versus non-compensated. Slightly less 

than 30 percent of the cases with dose reconstruction 

are compensated. None of this has really changed 

very much.

These are DOE records requests. You can see that 

where there's almost nothing, what we would call 

late, which is more than 60 days. And the 130 are 

because we continue to get new claims, we continue 

to make requests, and they continue to respond.

In terms of the first 20,000 claims, most of them 

have been returned to DOL, either pulled or 

submitted with the dose reconstruction.

Three hundred fifty-seven have been 

administratively closed, and so our record keeping 
15

kind of shows those with us. Those could be 

reopened if the claimant decides they want to 

continue the process. They're administratively 

closed because the claimant doesn't return the 

OCAS-1 form.

And then there are a few of them that we're working 

on. Anything that's an initial in the first 20,000 is a 

case that had been administratively closed at one 

time and then the claimant, or maybe the claimant, 

the original claimant's survivors decided to pick it 

back up and process it again.

And so those are cases that since there was never a 

dose reconstruction sent, they're considered initial 

cases even though we have not been working on 

them the whole time. They've been administratively 

closed for most of the time.

And so that completes that. So I'll try to answer any 

questions anyone might have on anything I covered.

Mr. Katz: Andy.

Member Anderson: Yes. Stu, who attends the 

workshops? The --

Mr. Hinnefeld: The dose reconstruction workshops? 

Well, when we do a site specific one, we oftentimes 

contact a labor organization that represent the 

workers at the site that we're covering.

And in large part, they're also the ones who come to 

the two-day workshop in Cincinnati. We have had 

people from DOL district offices come. Some of our 

advocates have come to those.

But it's in large part, ATL's contact list is with labor 

organizations that represent the workers at the 

covered facility.

Mr. Katz: Do we have any other questions from our 

Board Members on the line?

Member Roessler: Ted, this is Gen. I'm seeing the 

slides very well, and I could hear you had Josie okay, 
16

I hear the people on the phone very well, but Stu I 

imagine is at the podium there, and he was very 

difficult to hear. It sounded very muffled.

Mr. Hinnefeld: Sorry. Maybe I'm mumbling in my 

old age.

Member Roessler: Oh, that sounded much better. I 

think speakers at the podium need to make sure 

they're close to the microphone.

Mr. Hinnefeld: Okay. I was probably looking at my 

screen rather than the microphone, and so I guess 

that will be a warning for people up here that come 

up to talk.

Member Roessler: That would help. You're coming 

through clearly now.

Mr. Hinnefeld: Okay, it's a little --

Mr. Katz: Yes.

Mr. Hinnefeld: -- I guess it's a pretty directional mic.

DOL Program Update

Mr. Katz: Yes, I think all these mics, the closer you 

are to the face of the mic the better. Any other 

questions? Very good, thank you, Stu.

And we go on to the DOL program update, which I 

think is being done remotely from Chris Crawford. 

Are you on the line?

Mr. Crawford: Yes, Ted, I am here. Good morning.

Mr. Katz: Welcome.

Mr. Crawford: Great to be here. Stu, would you let 

me know when the first slide is up?

Mr. Katz: Right. He's working on it, I'll let you know.

Mr. Crawford: Sure.

Mr. Hinnefeld: Okay, it's there, Chris.
17

Mr. Katz: Yes. 

Mr. Crawford: Great. Thanks for your help, Stu. 

Let's go to the second slide.

Mr. Hinnefeld: Okay.

Mr. Crawford: Okay. This slide shows the 

compensation already paid through the program. 

You'll see that for Part B compensation we have $6.6 

billion paid out. For Part E compensation, we have 

$4.4 billion paid. Medical bills, a separate reckoning, 

$4.3 billion.

And the total of $15.3 billion for the program, paid 

out in compensation for approximately 202,000 

cases filed.

Next slide, Stu.

Mr. Hinnefeld: All right.

Mr. Crawford: Now, for Part B cancer cases, with a 

final decision to accept, we've accepted, with dose 

reconstruction cases, 10,628, which resulted in 

payments of $1.6 billion in compensation. For 

accepted SEC cases, which amount to about 26,500 

cases, we paid out $4 billion compensation.

For cases accepted based on both SEC acceptance 

and PoC, Probability of Causation, greater than 50 

percent, we have 1,038 such cases, and $156 million 

in compensation has been paid on that account.

For the totals, including all accepted SEC cases, dose 

reconstruction cases, and combined of 38,160, we 

have paid out $5.7 billion in compensation.

Next slide please.

Mr. Hinnefeld: Yes, sir.

Mr. Crawford: Now for the status of cases and 

location of NIOSH referrals, we show approximately 

50,100 cases refereed to NIOSH for dose 

reconstruction. Of those, about 48,400 cases have 
18

been returned to DOL from NIOSH, 42,000 of them 

with a dose reconstruction, and about 6,400 of them 

were withdrawn from NIOSH with no dose 

reconstruction. We show approximately 1,700 cases 

currently at NIOSH.

Next slide, Stu. For Part B cases with dose 

reconstructions and final decisions, we have 33,600 

cases in that category, the final approvals about 

11,700, the final denials, 21,900, for a 65 percent 

denial versus 35 percent acceptance breakdown.

Next slide please. This shows Part B cases filed by 

type. If we start with NIOSH and go clockwise from 

there, we see that 35 percent of our cases have been 

sent to NIOSH. Another 29 percent are under other, 

which includes silicosis, beryllium sensitivity, chronic 

beryllium disease.

We see that 9 percent are RECA cases, for uranium 

miners. And then we see that there is 15 percent of 

cases that are never sent to NIOSH. They're 

accepted as SEC cases without going to NIOSH.

And then finally we see that there are SEC cases that 

are referred to NIOSH, 12 percent of the cases. In 

most cases, because there are multiple cancers, 

some of which may not have been included in the 

SEC, so NIOSH has to evaluate the case with a dose 

reconstruction to see if those cases can qualify for 

medical benefits as well.

Next slide please. Here's a slightly different look. 

These are Part B cases with final decisions and will 

include SEC cases.

We see that there is very close to 100,000 cases with 

final decisions under Part B, of which 52,600 are Part 

B approvals and 47,400 are Part B denials. Here we 

see that approvals are about 53 percent and denials 

47 percent.

Next slide please. Our top four work sites, these are 

the usual suspects, Hanford, Savannah River Site, Y12 Plant, and Los Alamos National Laboratory.
19

And this is for cases generated in the, well, the 

federal third quarter, calendar second quarter.

Next slide please. And here we have the monthly 

percentage of new cases, DOE cases versus AWE 

cases, and the most recent readings show the AWE 

cases slipping a little to six percent of the total cases, 

versus 94 percent being DOE.

Next slide, Stu. Here we have an overall look at our 

SEC petition sites being discussed during this 

meeting.

Starting with Sandia National Laboratory, we see 

there are nearly 4,000 cases of which about 660 have 

been returned by NIOSH with a DR. There have been 

1,809 final decisions, 1,223 Part B approvals, 1,120 

Part E approvals, and $336 million in compensation 

and medical bills paid.

Metals and Controls Corporation in Massachusetts, 

we see that there is somewhat less than 1,000 cases. 

Four hundred and forty-eight have been returned by 

NIOSH with a DR, 937 have final decision issued 

under Part B, 457 have been approved under Part B.

We don't have any Part E approvals because this is 

an AWE site. And $73 million in compensation has 

been paid out.

Idaho National Laboratory has approximately 6,200 

cases, of which 1,900 have been returned with a DR 

from NIOSH, we have 2,700 final decisions, 965 Part 

B approvals, 1,258 Part E approvals, and $321 million 

in compensation paid.

And we have the De Soto Facility in Los Angeles 

County. Seven hundred and sixty-four cases filed, 

223 returned by NIOSH with a DR, 362 final 

decisions, 207 Part B approvals, 190 Part E 

approvals, and $53 million in compensation and 

medical bills paid.

And, next slide please. The last site to be discussed 

is the Feed Materials Production Center in Fernald, 
20

Ohio.

Here we have a large number of claims, 5,334 shown. 

NIOSH has completed a DR for 1,529 cases. We have 

2,282 final decisions, 1,019 Part B approvals. We 

also have 1,098 Part E approvals with $305 million in 

compensation and medical bills paid.

Next slide, Stu. Moving on now to DEEOIC outreach 

events. This first slide is actually boilerplate. We've 

all seen it before.

But the program conducts town hall meetings and 

traveling resource centers. And in the cases of small 

SECs, press releases are issued in lieu of meeting.

There are also quarterly medical conference calls, 

authorized representative workshops. And then 

there are informational meetings regarding medical 

benefits provided under EEOICPA, in some cases held 

with the SEC town hall meetings.

Next slide, Stu. Here we see the members of the 

Joint Outreach Task Group, which we're all familiar 

with I believe.

And that includes the DEEOIC membership, the 

Department of Energy, the DOE Former Worker 

Medical Screening Program, National Institute for 

Occupational Safety and Health, of course, the 

Ombudsman to NIOSH for EEOICPA Part B, Denise 

Brock, and DOL's Office of the Ombudsman for 

EEOICPA, Malcolm Nelson. There were monthly 

conference calls, and this group conducts the town 

hall meetings.

Next slide please. And we see a list of the most 

recent outreach events, starting with the quarterly 

conference call, but there is no information on that. 

That was June 12th and 13th, 2018.

Then there was an outreach event in Moab, Utah from 

the Denver District Office. Thirty-seven people 

attended, and four new claims were filed. That was 

June 7th.
21

Then there was another Denver District Office 

presentation, Grand Junction, Colorado, on June 6th, 

with 30 in attendance and one new claim.

There was an authorized representative workshop, 

May 15th and 16th, 2018 with 24 in attendance.

And then there was an outreach event in Ames, Iowa 

April 17, 38 in attendance and seven new claims filed.

And we see another outreach event, Bridgeton, 

Missouri, March 20th and 21st, 2018. Thirty people 

in attendance, four new claims filed.

Next slide please. Now we're looking at future 

outreach event. Town hall meeting in New 

Kensington, Pennsylvania, August 22nd, which is 

today.

Next slide please. The next outreach will be a town 

hall meeting also in Shiprock, New Mexico, August 

29th and 30th, this month.

Next slide. And we have an authorized 

representative workshop taking place in Cincinnati on 

October 16th and 17th.

Next slide, Stu. And then we have a future outreach 

event, the fall meeting, which is being held in 

Washington, D.C. at DOL on October 24th, 2018.

Now the remaining slides won't be shown, but they're 

available on the Board's website. They're 

informational slides about what the program covers 

and who are eligible survivors, that sort of thing. 

Useful but not to be read here.

Are there any questions from the Board?

Mr. Katz: Thank you, Chris. Any questions on the 

phone from Board Members?

Okay, hearing none, thanks very much, Chris, for 

your update.

Mr. Crawford: Thanks.
22

DOE Program Update

Mr. Katz: And we're on to DOE. And we have to 

welcome here Ms. Lokie Harmond from DOE. So, a 

new face, welcome.

Ms. Harmond: Hi, I'm Lokie Harmond, and I will 

provide the update for Department of Energy in 

support of EEOICPA.

DOE's core mandate is to work on behalf of the 

program claimant to ensure that all available worker 

and facility records and data are provided to DOL, 

NIOSH, and the Advisory Board.

DOL responsibilities are to -- I'm sorry, includes 

responding to individual claim requests, via the SERT 

system, to DOL and NIOSH. Also providing support 

and assistance to DOL, NIOSH, and the Advisory 

Board on large-scale research and site 

characterization projects.

DOE process about 18,000 records a year, and 

they're split between EVs, for DOL, dose records for 

NIOSH, and DAR requests for DOL. 

Individual records that are from claimants who have 

often worked at multiple DOE sites, for multiple 

contractors and subcontractors, and different jobs or 

divisions over a career. And for a typical request for 

a worker's record, DOE may have to search different 

sites, departments, and within different record 

sources and databases.

In FY17, DOE responded to 18,522 records over 25 

DOE locations.

Listed here are the average number of pages for each 

type of request, and the size of the record packages 

are dependent on the years worked, along with a 

number of other factors.

In FY18, for the first and second quarter, DOE 

responded in under 60 days to 7,976 out of 8,167 

record requests from DOL and NIOSH. So that's 
23

about a 97 percent on-time response rate.

And many of the sites had near perfect records. And 

below are a couple of examples from the sites.

DOE provides support to DOL and NIOSH on largescale research projects. Listed here are a couple of 

sites for projects that are going on, and many of our 

research projects do go on at the same time.

DOE supports classification of document review for 

final reports for DOL, NIOSH, and the Advisory Board.

We also research and maintain the Covered Facilities 

Database. And listed below is the link where you can 

find the full listing.

DOE continues to participate in all JOT meetings and 

AR workshops.

Our office also supports the Former Worker 

Screening Program, and their mission is to identify 

and notify former workers at risk for occupational 

disease and offer them medical screening that can 

lead to treatment.

The Former Worker Program has two links. The first 

link is their website, and the second link is a copy of 

their brochure.

That's it. Any questions?

Mr. Katz: Thank you, Lokie. Do we have any 

questions from Board Members?

Member Richardson: Could I? Hi, this is David 

Richardson. Could I ask a question? It's probably 

something that you might not answer right now but 

that you could get back to.

One of the items is DOE funds and coordinates 

records related to different activities, employment 

verifications for the DOL and dose records. I was 

wondering how much it's costing DOE currently?

What's the budget for these activities?
24

Ms. Harmond: I'll definitely have to get back with 

you.

Member Richardson: Yes, I know that wouldn't be 

something that you would be --

Ms. Harmond: Yes.

Member Richardson: But I'm sort of curious about 

kind of that aspect of this program.

Ms. Harmond: Okay.

Member Richardson: Thank you.

Ms. Harmond: Yes.

Mr. Katz: So, Lokie, you could respond to me, and 

I'll pass that along to --

Ms. Harmond: Okay.

Mr. Katz: -- the Board Members whenever you get 

that.

Ms. Harmond: I will do that. Okay.

Mr. Katz: Other questions? Questions from any 

Board Members on the line? Okay, great.

And our next session is on Fernald. And, John, is it 

John or Bob that's going to be presenting? John? 

Welcome, John.

Mr. Katz: Just for the record, Dr. Lockey has recused 

himself for this session.

Feed Materials Production Center Site Profile Review

Mr. Stiver: Can everybody hear me fine? Okay.

Good morning, Members of the Board and other 

attendees. I'm John Stiver from SC&A, and today I'm 

going to be presenting the, what is essentially the 

closeout of the Fernald Site Profile review.

You will recall last year, about this time at the Santa 
25

Fe meeting, we went ahead and the Board agreed to 

close out the SEC issues. However, when I go 

through this presentation, you're going to see 

remarkable similarities to that presentation last year, 

mainly because a lot of the SEC issues were, as they 

were discussed over this 12 year period, were moved 

over to the Site Profile side.

And so in the interest of maintaining continuity, I'm 

going to go ahead and go through some of that 

material as well again today. Let me see here if I can 

get this thing to work.

All right. First, a little bit of background information 

about the Fernald Site, which is also called the Feed 

Materials Production Center.

It was located, obviously, near the Village of Fernald 

in the Miami River Basin about 20 miles northwest of 

Cincinnati in southwestern Ohio. Covered an area of 

about 1,050 acres. And a production area that 

encompassed approximately 136 acres in the center 

of the site.

I forgot, Fernald began operations in 1951, was fully 

operational by 1954. And as you can see highlighted 

here, the primary function was convert uranium ore 

concentrates and recycled materials either to 

uranium oxides or highly purified ingots and billets 

for machining or extrusion into tubular forms of 

assorted uranium enrichments.

There were nine separate plants. The pilot plant, 

ancillary buildings, administrative buildings that were 

connected by a network of roadways, along with 

storage pads, gravel ground cover, railroad access, 

landfills, so forth.

Outside the fenced area there was the waste storage 

area. There were six low level radioactive waste 

storage pits and two earthen-bermed concrete silos 

that contained the K-65 residues.

I think that was the code for the high specific activity 

radium-bearing residues. One concrete silo that 
26

contained metal oxides and all the affected adjoining 

areas.

As far as the, let's take a look at the historic overview 

of the review process. This basically began back in 

about 2006, and this continued for 12 years.

Our Site Profile review was delivered in November of 

2006 where 33 findings were identified. And 

concurrent with that, SEC Petition 46 was put forth in 

April of 2006.

And this was all employees. The proposed Class was 

all employees of DOE, DOE contractors and 

subcontractors employed at FMPC from January 1st, 

1951 through December 31st, 1989.

SC&A released our SEC Evaluation Report review in 

July of 2007. And we found there were basically six 

principle issues.

The first was the coworker model for uranium internal 

exposures. The second was the HIS-20 database, 

which was used to, it was basically data used to 

create the uranium coworker model.

There was the issue of the constituent levels in 

recycled uranium. Issue 4 was the use of radon 

breath data for reconstructing doses from the 

inhalation of radium-226 and thorium-230.

Issue 5 was a review of radon emissions from the K65 silos and associated exposures. Issue 6 was the 

reconstruction of internal exposures from the 

inhalation of thorium-232.

There were basically two components. One was 

based on daily weighted exposures. Basically air 

concentration data. And the second was based on 

chest count data.

And this last one was kind of an orphan issue that 

was carried over from our initial review and probably 

should have been in the Site Profile issue. And this 

was the absence of performance standards and 
27

quality assurance for personnel dosimeters.

And the issues matrix revision 5 was the latest 

version. And it basically has a detailed narrative of 

all of these different issues, both Site Profile and SEC.

There have been a total of 24 Work Group meetings 

since the inception, from August 2007 until just a 

couple of weeks ago in August 2018. Numerous 

White Paper exchanges and discussions.

As of last year, basically this slide, I should have 

changed this, but this was, it's just a loose end that 

didn't get corrected. But there have been three 

classes added to the SEC from June 2012 up through 

September 2013. And these are all listed.

I provided links to the HHS designations. I don't 

think we really need to review these again right now 

since the SECs aspect has already been covered.

I'll go through the issues kind of briefly. SEC Issue 1 

was obviously the coworker model for uranium 

internal exposures. And the central issue here was 

the completeness and adequacy of the bioassay data 

they use for dose reconstruction to support OTIB-78, 

which is the internal dose coworker model.

OTIB-78 has been revised three times from 2009 to 

2016. And the coworker model has been 

incorporated into the internal dose TBD, TBD-5, Rev. 

3. And then the TIB was cancelled.

The issues related to the applicability of the uranium 

coworker model to Fernald construction workers. 

And that was actually the basis of the addition of a 

coworker Class to the SEC from 1951 to 1983.

Issue 2 is the validation of the HIS-20 database. 

There are really two parts, Part 2A and 2B.

2A was basically validation of the accuracy with which 

the hard copy records were translated and converted 

to electronic data. A validation study was completed 

on that in December of 2010 and basically resolved 
28

all of SC&A's concerns. And at the February 2011 

meeting, it was recommended that subpart 2A be 

closed.

2B was the concerns about the integrity of the hard 

copy of bioassay data itself. This is where Petitioner 

raised concern.

And SC&A had prepared a report that described 

different strategies that might be used to investigate 

the integrity issues, possible data falsification, or 

things along that nature.

And the Work Group agreed that any such 

investigations would require considerable 

expenditures of resources. It was kind of the same 

type of thing that we tried for NTS, and resulting in 

inconclusive outcomes. And so this issue was not 

tasked and was closed.

Issue 3 is recycled uranium. This one has been going 

on continuously and was finally resolved at the 

meeting a couple weeks ago, in the August 10th 

meeting.

And this concerned the default concentrations on 

uranium mass basis of plutonium-239, neptunium237, and technetium-99. They were associated with 

the receipts of recycled uranium at Fernald.

Obviously, plutonium is the big player here as far as 

dosimetry is concerned. The doses can be two to five 

times higher than uranium dose for certain organs.

There are three periods of interest here. Basically, 

1953 to 1960 there were 45 metric tons in storage 

total with very little exposure potential.

1961 to '72, uranium, recycled uranium was 

processed, but the data do suggest that most of it 

was within specification, which was nominally ten 

parts per billion on uranium mass basis.

From 1973 to 1985 there were more highly 

contaminated receipts, mostly from the gaseous 
29

diffusion plants. This was termed POOS for 

plutonium out of specification.

And then after '85, from 1986 on, Westinghouse 

Materials Company replaced National Lead of Ohio as 

the Fernald M&O. And they institute a 

comprehensive improvements in the HP and 

industrial health programs. And we felt that from 

there on dose reconstruction was probably possible.

Eight Work Group meetings took place from October 

2008 to August 2018. In February 2012, there was 

an agreement on the constituent concentrations. 

Now recall, this was still at a time when this was 

considered an SEC issue. It had not yet been 

resolved.

We agreed that from 1961 to '72 plutonium would be 

100 parts per billion, neptunium 3,500, technetium99, 9,000.

And then from 1973 to the present, plutonium would 

go up to 400 parts per billion, neptunium to 11,000, 

and technetium to 20,000.

As of August 2018, we had had a -- first of all, let me 

back up a little bit. We had determined this was 

going to be a Site Profile issue in 2012. And TBD-5, 

Rev. 3 came out in March 2017.

And NIOSH had proposed different concentrations on 

what had been agreed to in the -- before this had 

been transferred to the Site Profile side. They had 

proposed a tenfold reduction in plutonium-239 from 

100 to 10 parts per billion. Neptunium also went 

down from 3,500 to 400, and technetium from 9,000 

to 6,000.

This was based on the notion that, basically, NIOSH 

had felt that they had uncovered a Lot sequence ID 

that would allow them to identify the timing of 

various receipts, and so they had based this upon 

that, that Lot ID sequence.

SC&A took a look at that and used the same approach 
30

and came up with considerably different values than 

NIOSH. We found quite a bit that were over ten parts 

per billion.

And then NIOSH went back and looked at this and 

took a closer look at this Lot ID sequence, and it 

turned out there were -- some of those Lot IDs could 

be used to identify timing, but others were for very 

different purposes.

And so it was determined that we really couldn't use 

this timing data at all or the sequence ID to identify 

timing.

And so really the only thing left that was really a solid 

number was this ten parts per billion. And we were 

a little bit concerned that this was only going to be 

used, we understand, for partial dose reconstruction 

given this is during the SEC period.

But we thought, well, you know, you're taking away 

a lot of dose for these people that don't meet the 250 

day criterion, so why not give them a little bit more. 

But try to give them maybe the 95th percentile or an 

upper bound value for this material.

But I guess NIOSH's position on this and their 

procedure is really to -- doing partial dose 

reconstruction is to use a best estimate instead of an 

upper bound. And there was some discussion on this 

at the August 10th meeting. And the Work Group 

agreed that that was probably a reasonable best 

estimate and considerably claimant favorable 

approach to take. And so that issue was closed.

Issue 4 is the use of radon breath data for 

reconstructing doses from the inhalation of radium226 and thorium-230. We agree that radon breath 

data -- or analysis was a scientifically valid method 

to reconstructing radium and thorium-230 when the 

intake ratios of the two radionuclides are known and 

the impacted worker populations can be identified.

There was one remaining issue, this is the 

reconstruction, reconstruction of thorium-230 dose in 
31

uranium- and radium-poor raffinates. So basically, if 

you don't have any uranium or radium, you might 

have a thorium intake, a thorium-230 intake, that 

would go undetected.

And we had agreed early on that this could be --

these doses could be bounded. And this was moved 

to the Site Profile status.

Again, lots of White Papers were exchanged, and a 

lot of discussions took place. In the August meeting 

NIOSH provided a pretty compelling argument as to 

why they could use bioassay and a ratio method to 

bound any intakes in Plant 2 and 3.

Where there might be this issue for about a three 

year period, from '59 to '61, where they were 

handling types of materials where there could 

possibly be this sort of an intake. And they had kind 

of a novel approach.

They looked at the DWE data, and I believe there 

were -- it was based -- I think it was about .1 of the 

maximum allowable concentration, which translated 

to about seven dpm per cubic meter of air.

And so based on a breathing rate of 1.3 cubic meters 

per hour, ten hour work day, 250 days and then 

spread out, I think that came out to about 26 

picocuries per day intake. And then they compared 

that to the bioassay.

And assuming that they had Type F material and a 

missed dose calculation, I believe they came up with 

an intake of about 24 picocuries per day of uranium. 

And then when using the ratios to thorium-230 and 

the other alpha-emitting non-uranium nuclides in the 

raffinates, it came out to about 27 picocuries per day.

So that actually demonstrated that they could bound 

the DWE-based data using the bioassay and the ratio. 

And so the Work Group agreed to go ahead and close 

that out at the August 10th meeting.

Let me see if I can get ahead here. Issue 5 was radon 
32

emissions from K-65 silos. Again, lots of White 

Papers were exchanged.

As a practical matter, NIOSH believed this issue 

really had very little significance with respect to dose 

reconstruction for actual claimants.

Again, this was an issue that we felt was important 

from an SEC standpoint because the doses could be 

quite high. But after the SECs were granted, it turns 

out it was really only about a six month period where 

this would really come into play for any claimants.

And rather than force the issue and continue 

discussions about the scientific merits of their 

approach, we went ahead and agreed, the Board 

agreed, or the Work Group agreed that if they use 

the 95th percentile of their model that would be 

adequate for dose reconstruction purposes. And that 

issue was closed. This is related to TBD issues 25 

and 26.

Now moving on to the reconstruction of internal 

exposures from inhalation of thorium-232. This is 

Issue 6A. This was based on the DWE data.

And we were really concerned with the breathing 

zone and general air sample data and the air 

concentrations. We're probably going to be okay if, 

and only if, you can identify where the workers were 

in the facilities and which operations and buildings 

and time periods these activities took place.

Most of this air sampling was based on gross alpha 

activity and really wasn't focused on thorium work 

that occurred at the site but rather on uranium work. 

And thus, the samples really contained unknown 

proportions of uranium and thorium.

And plus, our research showed that workers really 

couldn't be reliably placed in thorium processing 

facilities during the period of interest.

6B was the reconstruction of internal exposures 

based on chest count data. 6B chest count data was 
33

used to reconstruct thorium-232 exposures from two 

different periods.

'68 to '78, the results were reported in milligrams of 

thorium. And from '79 to '88 they're reported in 

nanocuries of thorium based on lead-212 

measurements.

As far as the earlier period, in April 2012 an SEC was 

voted for all workers from 1968 to 1978, based on 

the inability to place sufficiently accurate upper 

bounds on intakes based on results reported in 

milligrams of thorium.

Basically, NIOSH used an empirical equation to get 

milligrams of thorium from chest count data. And it 

was applicable to that particular method that was 

used with a particular source term. And that really is 

not applicable to the forms in various equilibrium 

conditions that occurred at Fernald. And there are 

extremely large uncertainties involved.

From 1979 to 1988, the results were reported, as I 

said, in nanocuries of thorium. And the Work Group 

accepted NIOSH's methodology based on activity 

measurements of lead-212.

And again, as I said earlier, Finding 4.5.1, 

performance standards for personnel dosimeters, we 

didn't really question the merits for the use of the 

dosimetry data, but we considered -- felt that there 

was a need to consider the quality of the data and 

the context of the stated limitations.

We felt that expanding the range of uncertainty 

afforded personnel dosimeters that were used at the 

time to account for these deficiencies was really more 

an issue of uncertainties introduced by human error.

Basically, there were two aspects of this. Control 

badges were not routinely processed for badges worn 

by workers. And they didn't have a bona fide official 

training program for the technicians who assessed 

the badges.
34

Because there was really no way to rectify these 

deficiencies, the Work Group agreed to close this out 

at the September 2014 Work Group meeting.

And, basically, this is as of August of 2017. The 

Board voted to close out the SEC issues. I can go 

ahead and read this, even though this isn't the exact 

wording that went into the record, but the Fernald 

Work Group recommended that the Board find 

radiation doses could be estimated with sufficient 

accuracy for National Lead of Ohio and NLO, Inc., and 

Westinghouse Materials Company of Ohio employees 

from 1979 through 1989, and for covered employees 

other than NLO and NLO, Inc. from 1984 through 

1989. Basically, the subcontractors.

The Board voted to accept this position at the August 

2017 meeting. And that completed the Board's 

consideration of SEC Petition 46.

Now, moving on to the Site Profile issues. From my 

original review of November of 2006, of the 33 

original findings, 27 were closed, four were in 

progress and two were transferred to the Procedures 

Subcommittee.

In addition to that, there were two other aspects that 

have come up since that. One was November of 

2014. We reviewed NIOSH's White Paper about dose 

reconstruction methodology for the post-SEC period, 

from 1979 to 2006. We came out with seven findings 

and seven observations in that review.

And then in 2016 we reviewed the internal dosimetry 

coworker data. Basically OTIB-78, which, as you 

remember, was incorporated into TBD-5. And now 

we had two findings and six observations.

Now, let's take a look now at the findings that were 

in progress or transferred from the 2006 Site Profile 

review. Findings 7 and 8 had to do with raffinates 

poor in uranium and radium. And I just explained 

that to you.

At the August 10th meeting, 2018 meeting, the Work 
35

Group accepted NIOSH's proposed method for 

bounding doses to uranium- and radium-poor 

raffinates. And that issue was closed.

Findings in Item 10 regarding recycled uranium. 

Again, at the August 10th meeting those issues were 

closed. The Work Group agreed that the ten parts 

per billion was sufficiently conservative and a best 

estimate partial dose reconstruction.

Findings 17 and 19 are correction factors for 

extremity beta exposures measured by film badges 

were transferred to the Subcommittee for Procedure 

Review. And these were really kind of wrapped up 

with the review of OTIB-13, but they're closed as 

they relate to the Fernald TBD.

Let's move ahead. Now, let's take a look at the postSEC review. This mainly has to do with thorium 

methodology. The three periods, '79 to '89. 

Monitored workers here are going to be receiving 

their results from the mobile in vivo radiation 

monitoring laboratory, and unmonitored workers are 

going to be getting coworker intakes that were 

developed from that data set.

From '90 to '94, monitored workers are going to be 

using the individual in vivo examination center, the 

fixed monitoring system they had in place at the 

time. And the unmonitored worker is going to be 

assigned ten percent of the derived air concentration, 

the DAC. And that's going to apply to all radiological 

workers who were not monitored.

From 1995 to 2006, I mean, basically what we're 

looking at here would be the remediation period. 

Monitored workers are going to use the individual 

IVEC results or breathing zone data, which are 

available for them, as appropriate. And unmonitored 

workers will have no coworker dose assignment 

because basically they were -- anybody who was 

involved in the remediation D&D efforts were 

monitored. It was pretty well-documented who those 

people are.
36

More on the post-SEC thorium review. Findings 1, 3, 

and 5 basically involved who was going to be 

assigned the doses. And, basically, it was going to 

be all radiological workers who were not monitored 

from 1979 to 1994. At last year's July 28th meeting 

the Work Group recommended closing that.

Finding 2, intake assignments. We felt that maybe it 

might be appropriate to use the 95th percentile, but 

the Work Group determined the 50th percentile with 

the associated GSD was sufficient for most 

radiological workers.

The 95th percentile would be workers who submitted 

baseline fecal samples and workers employed by IT 

Corporation. That was the subcontractor that was 

handling the repackaging activities. And, again, at 

the July 2017 Work Group meeting that was 

recommended to be closed.

Finding 4 related to which Class, or should we use 

class-wide DAC values or Class W. Should it be the 

currently proposed Class W DAC for application of ten 

percent of the DAC values for unmonitored thorium 

dose reconstruction. And back in March of this year 

this was discussed and SC&A concurred with NIOSH's 

conclusion that the site utilized the Class W DAC in 

controlling airborne contamination levels. And that 

was recommended to be closed. That was really 

based on a lot of historic documentation that showed 

that Class W was indeed recommended and used.

There were also several observations. I think we 

have enough time to go through some of these.

The first three are basically in agreement with what 

NIOSH proposed. We found the in vivo monitoring 

program did focus on the most highly exposed jobs, 

such as the chemical operators. Not surprisingly, 

workers were positive in vivo results for thorium 

daughters, lead-212 and actinium-228, were resampled ten times as often as the rest of the 

monitoring population. So they did have awareness 

who these workers were and they were doing the due 

diligence and were vigilant.
37

Observation 3. We concurred with the claimantfavorable assumptions discussed in the December 

2014 Work Group meeting. This was regarding the 

triple separation of thorium. This is in regards to the 

chest count data bias adjustment we felt accounted -

- was acceptable criteria for unsupported radium 

exposure related to Post-SEC Thorium Finding 7.

Observation 4, I noted the review of the in vivo 

coworker distributions were not performed at the 

time of review due to SEC discussions of timeweighted OPOS methodology. So no action was 

required there.

Let's see. Observation 5. We did a review of 22 

unmonitored claimants from 1990 to 1994, which 

indicated chronic exposure to -- no chronic exposure 

to thorium above the ten percent of the DAC. At least 

it would be highly unlikely for that to have occurred.

Observation 6. SC&A had requested clarification on 

breathing zone codes used to identify thorium 

results. And those are now discussed in Attachment 

E of the internal dose TBD update.

Observation 7 was: the temporal collection and 

measurement criteria for breathing zone samples is 

not apparent in the Fernald database. And NIOSH 

provided additional information that specified that 

breathing zone data were collected on a daily basis, 

but generally were reported on a weekly basis.

And thoron and unsupported radium, let's take a look 

at that. NIOSH modeled thoron exposures in Building 

65, which is the thorium storage area, for comparison 

with the site-wide model, and additionally provided 

justification for parameter selection on the site-wide 

model. And this was the subject of SC&A Finding 

Number 6. At the March 15th, 2018 meeting, SC&A 

concurred with the proposed thoron dose 

reconstruction approach, aside from one minor

calculational error.

As far as unsupported uranium, NIOSH is going to 

assign intakes in the rare case where the in vivo 
38

result for actinium-228 is a factor of 1.5 or higher 

than the associated lead-212 result. And this was the 

subject of SC&A Finding 7. And at the July 2017 

Work Group meeting, the Work Group recommended 

closure on that issue.

Now, moving on to the uranium coworker model. As 

I said earlier, the methods that were developed in 

OTIB-78 Rev. 3 were integrated into Attachment C of 

the Fernald internal dose TBD. The uranium intakes 

were derived; large data set, 400,000-plus bioassay 

results.

The unmonitored worker assignment, intake 

assignment, involved all prime contract workers from 

'52 to 2006, and all construction trade subcontract 

workers from 1984 to 2006. As earlier stated, the 

SEC-46 was established for subcontractors from 

1951 to 1983.

Okay. There were two findings in our review of OTIB78. The first one related to the treatment of negative 

and zero bioassay results. When we felt that that 

was inconsistent with the guidance in RPRT-53. And 

NIOSH indicated that feature revisions of the 

coworker model will use RPRT-53 methods, and the 

effect is likely insignificant. Again, in July 28, 2017 

the Work Group recommended closing this finding. 

Or, excuse me, putting it into abeyance until such 

time as the new revision comes out.

Finding 2 had to deal with paired bioassay 

measurements for the same worker. It could be 

different by one to three orders of magnitude, and 

we were kind of concerned on that, on the same day. 

NIOSH investigated that and determined that the 

higher result was correct and the lower results were 

removed from the analysis. And that was 

recommended closed on July 28, 2018.

Again, six observations, along with our review of 

OTIB-78. The first being that SC&A could not 

recreate their calculations for some years in the late 

'80s and early '90s. It turned out that we were using 

-- both SC&A and NIOSH were using different 
39

procedures. It turns out NIOSH used the correct 

procedure, so we withdrew that observation.

Observation 2 was just kind of an agreement. As 

expected, the use of the time-weighted one-person, 

one-statistic, or TWOPOS, method does reduce the 

variability but did not significantly affect the 

geometric mean of the distribution. That was 

recommended closed, as well.

Observations 3 to 6. There was additional 

information in the bioassay database comments 

column that was not utilized in the coworker 

calculations. I think this was to show what those are: 

reported results below the control limit; notations, 

the sample might have represented a preemployment sample; indications of contamination or 

otherwise invalid samples; and identification of 

solubility type and intake route.

And NIOSH went ahead and acknowledged that in 

future revisions those comments will be considered. 

And the Work Group recommended putting those into 

abeyance until future revisions of the TBDs come out. 

With one exception, and that's the accuracy of the 

information designating solubility type and intake 

route cannot be confirmed. So that's not going to be 

used.

And, in conclusion, all of the remaining Site Profile 

issues have been closed or put into abeyance. The 

issue -- I shouldn't say the findings have been closed. 

Most of the observations have either been closed or 

put into abeyance as of the August 10th, 2018 

meeting. And so the Work Group recommends that 

the Advisory Board close the Fernald Site Profile 

review officially. 

And that's that. That's all I have for today.

Mr. Katz: Thank you, John. I think it should be 

obvious to everyone the remarkable work effort 

that's been put into this site by the Work Group and 

NIOSH and SC&A. 
40

And, Brad, do you want to, before we get into 

questions, do you want to add anything to --

Member Clawson: Yes. Yes, I do. I know everybody 

is sitting there saying, "Oh my God, you went through 

this." I realize that, and I apologize to John, but I'm 

the one that asked him to do this.

Most of you haven't been on the Board since we 

started this. I wanted to go over kind of a roadmap 

of where we have been and what we have done, 

because this is a big milestone because we're coming 

to a close of the Site Profile. And I'd like to thank 

NIOSH, I'd like to SC&A and all the Board Members 

that have worked on this and supported us. Thanks.

Mr. Katz: Okay, let's move on to questions, then, 

starting in the room with questions.

Mr. Stiver: I knew it was going to be David.

(Laughter)

Member Richardson: I just have a few notes on the 

presentation, and maybe I could start at the end, 

because I think it relates to Issue 2. Issue 2 had to 

do with validation of the database, and there were 

two types of concerns in the validation of the 

database. 

In talking about using the coworker data, the 

question of the accuracy of the information 

designating solubility type and intake route could not 

be confirmed and thus was not used.

So the suggestion there was that there was some 

types of information, although indicated in the 

database, that you were questioning the accuracy of 

it and therefore it was going to be discounted. Which 

led me to think about other concerns about the 

accuracy of the information, or just this general issue 

of Issue 2.

And it sounded like, Part B at least, was a question 

about the integrity of bioassay data. And that was 
41

raised by the petitioner. And, in the end, it sounded 

like that was going to be hard to validate and 

therefore just set aside.

Mr. Stiver: Well, it would be the kind of situation 

where you're trying to prove a negative. There was 

no way to really -- you know, we tried several -- you 

know, proposed several approaches as to how you 

might go about doing that.

And, basically, based on previous experience, lots of 

resources were expended, and at the end of the day 

there was just -- the results were inconclusive. There 

was no way to really identify, we can say that these 

data, there's some smoking gun that there was some 

data manipulation or something along those lines 

that might have taken place. And so it was a decided, 

the Work Group had decided, and the Board had 

accepted, that that really wasn't a wise use of 

resources.

I think I had to -- if I can remember back that far --

it was a long, long time ago -- I think it was before I 

even got involved in Fernald, but there was some 

concern about scrubber data from Fernald that had 

gone offsite and had possibly been bad data and been 

doctored or something like that.

We had gone through the records and reviewed that. 

I think it was kind of taken out of context. I can't 

remember offhand exactly what the details are. I can 

probably go back and do some research on that. 

Maybe Stu could fill you in on that.

Mr. Hinnefeld: This is Stu Hinnefeld. I should 

mention I'm conflicted at Fernald but have an 

authorization from the Office of Ethics to work with 

the Advisory Board on this petition and these 

resolutions.

My recollection of the origin of that content was, in 

certain portions of the Fernald database, the site 

would make a judgment about what solubility Class 

the person was exposed to, and put that. That was 

what was questioned, and do we know that's right?
42

And that doesn't relate to our dose reconstruction 

approach, because when we do a dose reconstruction 

approach, we do, you know, all the potential 

solubility classes, and the one that's most claimantfavorable is the one we use. And so we make no 

judgment. And so any judgement the site made 

about solubility wasn't relevant.

With respect to proving that the data is good in the 

database, and I don't know that there is a particularly 

good way to do that absent the hard copy records, 

which I'm pretty sure not retained; they were kept in 

like a lab notebook or something, and even then it 

would be pretty laborious; but I'm pretty sure those 

were not retained since the data was what was 

considered in the record.

I will say that the bioassay laboratory was tested 

many times during the '80s, and including even 

before the DOELAP laboratory accreditation program, 

and it performed quite well each time. So, other than 

that, I don't know what else we can offer.

Member Richardson: So, the first point that you 

raised had to do with my question about the coworker 

data and this issue the solubility and intake route.

Mr. Hinnefeld: Correct.

Member Richardson: The second question about the 

concern of the integrity of the hard copy bioassay 

data, as raised by the petitioner, you're saying in fact 

the hard copy data have not been retained at all and 

so --

Mr. Hinnefeld: Well, I'm guessing that the original 

hard copy data would be in a laboratory notebook. 

The chemist in the laboratory and whatever they kept 

in their notebook. Now, that was quickly transposed 

in what was considered the record. And I don't think 

those lab notebooks were retained. I don't think 

we've encountered those.

Member Richardson: And so the basis for the original 

concern by the petitioner about the integrity of the 
43

hard copy bioassay data, do you know what the 

foundation for that concern was?

Mr. Hinnefeld: Give me a minute. I think historically 

there was -- or, at some point, there developed a 

certain distrust towards the management. I think 

employees weren't terrible informed early on.

Even when I started rad worker training, it was really 

cursory and there wasn't a lot explained. And so I 

think there was a lot of room for doubt and, "yeah, 

you tell me it's good but what do I know about it?" 

And there wasn't a lot of serious discussion with 

people about it, it was just kind of like, "don't worry 

about it, trust us." And I think that gave rise to the 

suspicion, but I don't know that there was a particular 

observed reason for it.

Member Richardson: So there weren't -- because 

there's one suggestion of ways to assess this, which 

would be some sort of statistical approach looking for 

anomalies, which I agree would involve a lot of effort.

There's another direction that people sometimes 

take, which is was there a whistleblower case, is 

there documentary evidence that there was some 

concern about the quality of either hard copy or 

transcribed hard copy data that went into a 

database?

Mr. Hinnefeld: I don't -- when you're talking about 

whistleblower, you would be talking about insider, a 

person who's in a position to know that. I worked in 

the lab, and I don't remember anything like that. 

When I got there in the '80s, the people in the lab, 

as far as I know, did their work and wrote down the 

results. And I don't know of anyone ever raising 

concerns from the lab.

Member Richardson: Thanks.

Mr. Katz: Other questions in the room?

(Simultaneous speaking.)
44

Mr. Katz: Go ahead. Or maybe, Andy, do you want 

to pipe up first?

Member Anderson: Yeah, sure. I mean, it's kind of 

a monumental thing to close this out after all these 

years and it's kind of the question I have is, where 

does it go from here?

I mean, there seems to be a number of things in 

abeyance and other issues that could be impacted as 

the program continues in other areas, so what's the 

plan to go back, or how would we know whether 

something needs to be re-looked? I mean, we closed 

down --

Mr. Hinnefeld: Well, the item in abeyance about the 

coworker study was a variation in how sensor data 

are used, right? Sensor data or non-detect bioassay 

data. And the way it's used at Fernald is actually 

slightly more claimant-favorable than the way we say 

we're going to use it. 

And so, for that reason, we didn't go off and re-do 

the entire coworker data set, because it's a huge data 

set. We said this is favorable, okay, we can live with 

that. So, you know, we didn't -- there is no 

immediate plans for that.

In terms of the other resolutions, the Site Profile 

issues, there will be changes to how dose 

reconstruction -- the guidance for dose 

reconstruction and the subsequent Program 

Evaluation Report to reconsider cases that could have 

been affected by those changes that were not 

compensable when the dose reconstruction was 

done.

Member Anderson: Okay.

Mr. Katz: Right. And let me just translate that. So, 

with PERs, when we do a Program Evaluation Report, 

the Board then looks at that report to see that 

everything was done in accordance with how it was 

expected to be done. So that gets reviewed at that 

point.
45

Brad, do you want to say something?

Member Clawson: Yeah, I was just going to mention 

that, what Stu just said. Because after this, actually, 

SC&A will review also the process and submit to us 

that all of the agreements that we have made on 

there have been put into the Site Profile. Or the TBD.

Member Anderson: Okay.

Mr. Katz: Thank you. 

Member Anderson: Lots of moving parts

Mr. Katz: Yes. David, did you have another 

question?

Member Richardson: Yeah. And thank you for your 

patience with me, because it seems like some of 

these issues you've talked about for a decade.

The recycled uranium issue, I was wondering if you 

could help me to understand the significance of 

assumptions about the plutonium level within the 

recycled uranium. And you've settled on what you're 

calling a nominal ten ppb level for plutonium, and it 

sounds like there was a lot of discussion about how 

you settled there.

When I'm talking about kind of the implications of 

this, two things I guess I'm wondering about is, there 

were other values, like the 95th percentile, the 

distribution, which is substantially higher than ten. If 

you would translate that into dose to specific organs, 

what would the implications be there?

Mr. Stiver: Actually, basically you're looking --

originally we had agreed on a hundred parts per 

billion. There was the -- I think that was based on 

the ten parts per billion specification with basically a 

factor of ten added on for uncertainty, which is kind 

of a common practice in a lot of different aspects of 

health physics.

NIOSH had agreed to that basically because they had 

already done dose reconstructions in the past, so it 
46

was going to be an administrative thing to carry it 

through. And after the SEC passed and it became a 

situation, from 1961 to '72 is within the SEC. So the 

only place this would ever come into occurrence 

would be for skin, prostate, or for less than 250 days 

of exposure. 

And so it becomes an issue for partial dose 

reconstruction. And so we have a ten part per billion 

specification, but we don't know what data in that 

enormous set in Appendix F, I believe it is, of the DOE 

2000, which is the Ohio Field Office report that was 

put together for a period of about ten months, a 

tremendous effort. And there's a lot of data in there, 

but we don't know the timeframe for any of that.

And we thought we had a handle on it. We thought 

we could use that lot ID code to identify the timing of 

it. And so we went through an exercise, Bob Barton 

did a great job on that, and went through and in using 

that code, came out with a distribution. And so, wait 

a second, this is way higher than ten parts per billion, 

the 95th percentile is more like 100.

And so NIOSH went back and then did more analysis 

and Stu gave a really good breakdown of that at the 

August 10th meeting. And it turns out that some of 

those codes you can identify dates, but other times 

it's used for other aspects. And so you don't really 

know.

So there's really no solid way to build a distribution. 

So all we're stuck with, we're left with this ten. Ten 

parts per billion.

And so, how do you put some uncertainty limit on it? 

Should it be two, should it be a factor of three, should 

it be a factor of ten? You just don't know. You're 

getting off into the realm of conjecture.

And so, since it's no longer an SEC issue, we thought, 

we kind of came to the conclusion that this is the only 

number out there we can really hang our hat on. And 

if we put out an uncertainty factor without any basis 

for it, I think it's going to be subjective. There's no 
47

way to really quantify that.

And so that's why we wound up settling on the ten as 

being the reasonable best estimate.

Member Richardson: And you're hanging your hat on 

the ten because it's the geometric mean of --

Mr. Stiver: It was a production specification. Most

of this material came out of Hanford at the time. And 

most of it was below ten parts per billion. It was the 

Group 6, I believe, in the DOE field office report. I 

mean, we talked about this for years.

Member Richardson: Yeah.

Mr. Stiver: You're coming in at the last minute part 

of all this, so I understand the confusion.

Member Richardson: And in terms of the impacted 

organs from an intake under different assumptions, 

now you're not talking about the key target organs 

for plutonium, you're not talking about the impact on 

the lung, for example, or liver. Well, perhaps liver. 

You're thinking--

Mr. Stiver: Yeah, liver bounds --

Member Richardson: -- about other cancers which 

would not be covered, is that correct?

Mr. Stiver: Well, it would be other cancers. Basically 

skin, prostate would be the two that wouldn't be 

covered. But then also, if a guy has a claim and he's 

less than 250 days during that time period, it could 

be for any organ.

Member Richardson: Right. Right.

Mr. Stiver: So there would be a tenfold reduction in 

the dose from that plutonium presumed in that 

particular source term and exposure scenario. From 

what it was said on before, which would have been 

the 100. That was actually our last bone of 

contention for recycled uranium. It carried through 

until this month.
48

Member Richardson: And could you help me once 

more to understand why there is no -- because in fact 

you did calculate standard deviation along with the 

geometric mean from the data that you had, but you 

believe that it was a mixture of distributions?

Mr. Stiver: Well, the thing is, we thought we had the 

Rosetta Stone to identify the timing. And based on 

that approach, put together a distribution. But it 

turns out that's not a good distribution because it 

includes -- we don't know that -- well, actually, we 

have a pretty good idea that it doesn't actually -- all 

those data are not from 1961 to '73. Or to '72.

So there was really no way to identify "this particular 

set of data come from this timeframe." If we knew 

that, we could develop a distribution, we could do all 

the statistics on it, and be very comfortable with the 

result. But we don't have that.

Member Richardson: And the concern is that you 

have data that come from outside that period and 

that's where these outliers come from?

Mr. Stiver: Possibly.

Member Richardson: Because you have some 

observed values which are substantially higher than 

ten.

Mr. Stiver: Yes. If you use the lot ID sequence 

approach, which has turned out to not be valid. So, 

we thought we had a handle on it, but it turns out we 

don't.

Member Richardson: But, again, the problem with 

using all the available information and generating a 

standard deviation, regardless of lot ID, what is the 

problem there?

Mr. Stiver: The problem is you're taking data from a 

different timeframe when there was more 

contamination coming in and wrapping it back in to 

the earlier time period.
49

Member Richardson: And not wanting to say, in the 

absence of information, a claimant-favorable 

approach would be to use the 95th percentile, the 

distribution from the observed data?

Mr. Stiver: Well, the thing is, we know that the highly 

contaminated material didn't start arriving until 

1973. So, we have a higher value based on the most 

highly contaminated situation and the workers who 

were involved in that. And that came out to be the 

400 parts per billion. Basically, continuous exposure 

at 400 parts per billion. We know most of them didn't 

get that, but we don't know who was involved in 

these different sub-projects that would have possibly 

entailed those exposures.

So, to take that data and use it to generate a 

distribution for the earlier period just doesn't make 

any sense to us.

Member Richardson: Okay.

Mr. Katz: Okay, thank you. How about our Board 

Members on the line, do we have any?

Member Ziemer: This is Ziemer. I don't have any 

questions. I was on the Work Group, so I've gone 

through all these things, but I do want to thank John 

for his presentation. He covered a vast amount of 

data, and a vast amount of work in that Work Group, 

in a very concise way. It made it seem like a lot, but 

very well done, John, we appreciate it.

Mr. Stiver: Thank you. I appreciate that, Paul.

Mr. Katz: Thank you, Paul. All right, then, if there 

are no other questions, what we have here, then, is 

a recommendation from the Work Group for the 

Board to accept its Site Profile review. And since it's 

coming from a Work Group it doesn't require a 

second.

If there isn't any other discussion left, then we can 

move to vote. So, I'll just run down the line 

alphabetically. Anderson?
50

Member Anderson: Yes.

Mr. Katz: Beach?

Member Beach: Yes.

Mr. Katz: Clawson?

Member Clawson: Yes.

Mr. Katz: Field?

Member Field: Yes.

Mr. Katz: Kotelchuck?

Member Kotelchuck: Yes.

Mr. Katz: Dr. Lockey is recused, not in the room. Dr. 

Richardson?

Member Richardson: Yes.

Mr. Katz: Roessler?

Member Roessler: Yes.

Mr. Katz: Schofield?

Member Schofield: Yes.

Mr. Katz: Valerio?

Member Valerio: Yes.

Mr. Katz: And Ziemer?

Member Ziemer: Yes.

Mr. Katz: Right, in all in favor, it's unanimous, the 

motion passes and the Site Profile review is accepted.

And, again, congratulations and thank you for this 

quite remarkable amount of work.

Mr. Stiver: Thank you.

Mr. Katz: And this takes us to our break period. 

We're just a couple minutes early.
51

Please be back on time because we're dealing with 

an SEC session, and so we need to get started 

pronto. That's what the petitioners would expect. 

And that will be Sandia, I believe. Thank you.

(Whereupon, the above-entitled matter went off the 

record at 10:11 a.m. and resumed at 10:31 a.m.)

Mr. Katz: All right, so, now we are back in business 

on the Sandia SEC petition. And let me welcome 

Chuck Nelson from NIOSH, who's doing the 

presenting here.

Mr. Nelson: Thank you, Ted.

Mr. Katz: And is the lead investigator for NIOSH. 

Thank you.

Mr. Nelson: How is everybody doing? Can you hear 

me okay there on the telephone line?

Member Ziemer: Yes, very clear.

Mr. Katz: Okay.

Member Roessler: Very good, thank you.

Sandia National Laboratory Petition #188

Mr. Nelson: Thank you. Like Ted said, my name is 

Chuck Nelson. I'm the lead health physicists for the 

Sandia National Lab. And what I'd like to talk about 

today is a little history about Sandia with regard to 

the SEC petitions.

Originally, the petition qualified back in October 21st, 

2011. And the petitioner proposed a Class which 

essentially included security guards, police officers, 

central alarm system operators for any area of 

Sandia and with a timeframe of January 1, '63 

through May 21st, 2011.

And based on that, we did add a Class on February 

21st, 2012, and it read as follows. "All personnel that 

worked in any area at Sandia National Lab in 

Albuquerque, New Mexico for the period from 
52

January 1, 1949, through December 31, 1994." So 

we cut it off at 1994, expecting that the program had 

gotten better. And so at that point we continued our 

evaluation.

Now, the basis for the 1949 through 1994 SEC Class 

was that there was insufficient monitoring data and 

information to reconstruct internal doses for those 

years. And what we were lacking was internal 

program monitoring documentation, internal 

monitoring data, and process information.

We did conclude that we could reconstruct external 

doses, including medical X-rays that were performed 

onsite as a condition of employment.

Now, after that time period, we committed to 

evaluate and determine the Sandia monitoring 

program completeness. It's how sufficient it was, 

how appropriate it was for all of Sandia-Albuquerque

population from that 1995 period through May 21st, 

2011. And we would document those results in an 

addendum.

Now, for this current addendum we performed 17 

interviews with 15 people. There were five security 

guards. We had seven health physics professionaltype, whether they be internal dosimetrists, rad 

protection engineers, those type of people. We also 

interviewed industrial hygienists, a database 

manager, and a researcher.

Also performed during this time since the last SEC, 

we did seven site data captures. And during that 

time, we've captured 800 relevant documents, and 

now we have a total of 5,400 documents.

Things we looked at for this time period were internal 

memos. Those were actually pretty telling. 

Radiation work permits, radiologic surveys, incident 

reports, air monitoring data, internal dosimetry 

records, breathing zone monitoring -- so that would 

be like your personal monitoring for individuals --

your derived air concentration, DAC hour tracking. 

And also in the review we looked at the monitoring 
53

program, data collection and availability, and the 

programs compliance with the requirements.

We looked at DOE's Noncompliance Tracking System, 

how the site responded to it, any items that they 

identified through that system, and any corrective

actions taken. We did the same for the Occurrence 

Reporting and Processing System. That's ORPS. And 

we looked at the sites internal assessments and 

procedures.

Now, based on all the review that we did, we are 

proposing a Class extension in this addendum, and it 

reads as follows: "All employees that worked in any 

area of Sandia National Lab in Albuquerque, New 

Mexico, during the period from January 1, 1995 

through December 31, 1996." 

And there are really twofold reasons of why we 

proposed this Class extension. And there were 

internal monitoring program concerns, which I'll go 

into some details here in a moment on that, as well 

as air monitoring data deficiencies.

Now, a little history about their internal monitoring 

program. Really, the internal monitoring program for 

Sandia didn't begin to be very formalized until about 

1993. At that time, they hired internal dosimetrists 

and people with more expertise and internal 

dosimetry. And it's very evident when you look at 

their internal memos and documentation that things 

were done previously on an ad hoc basis; then, now, 

during this time, the program scene would be getting 

better and better. But it took a little while for that to 

happen.

They established their first interim internal dosimetry 

policy in December of 1993. And like I said, we were 

seeing the internal dosimetry progressing with 

continual development and improvement.

So, in this 1995 and '96 time period, we saw changes 

in the monitoring approach, we saw a lot of 

procedures being developed, and data was being 

collected and they were reviewing, they were actually 
54

dealing with records better. They were reviewing 

them and putting them into more of a retention 

formalization, which it wasn't totally mature but we 

were seeing the evidence of that.

Now, internal monitoring program concerns. 

Documented program assessments, internal memos, 

and interviews conducted by NIOSH with Sandia 

employees revealed that really the staffing wasn't 

quite where it should be for the program 

development.

So, we were seeing the program getting better and 

better but we were also seeing some growing pains 

and the need for better staffing. And you'll see this 

over and over again. And it's the WebDose. That's 

their internal monitoring database. It wasn't fully 

functioning. So, that was as the case in previous 

evaluations. And it really was getting tough to try to 

get any records from them in an efficient and reliable 

manner.

One point of note is the internal dosimetry manager, 

we interviewed him, and we also, looking at some 

internal memos, he said that there were errors in 

data entry due to hand entry and lack of adequate 

personnel to enter the data into the database.

He said sometimes a rad tech would be in training, 

they would pull him out of training to manually enter

this information in the database. And so we were 

seeing some issues with that when we requested 

some information from the site.

Okay, I mentioned previously about individual DAChour tracking. We did not find any official records 

during the '95 and '96 period. And we did see them 

-- it was procedurally required in 1997, and we did 

find that evidence.

This personal air monitoring, BZ monitoring, was not 

stored in the site's electronic monitoring database, 

which is this WebDose, for these years.

So, this all led us to the conclusions that during this 
55

'95 and '96 time period, with regard to feasibility, 

that these uncertainties concerns associated with this 

changing internal monitoring program, it was very 

evidence during this time period.

And although we saw the site making several 

improvements, you know, by use of personal and 

area air monitoring, it did seem to lack the 

formalization in that we didn't find adequate evidence 

that some key implementing procedures were fully in 

place until mid-'96 and certainly by 1997.

And we judged air monitoring data insufficient due to 

a lack of required record retention and review 

procedures during this time period. And, again, we 

were seeing some issues with WebDose.

And based on this lack of data availability and internal 

monitoring program concerns, we have determined 

that dose reconstruction for this time period January 

1, 1995 through December 31st, 1996 is not feasible.

Now, during this time period, there were 243 claims 

with employment. And of those 243, five claims had 

internal dosimetry data and 95 claims had external 

dosimetry data.

Now, this is kind of a standard slide here where we 

show feasibility. And we determine dose 

reconstruction, again, it's not feasible for all 

radionuclides from an internal standpoint. And, as 

previously, we concluded that external doses can 

reconstructed for beta, gamma, neutron, and 

occupational medical X-rays.

Some of these slides are a little redundant, but, 

again, the proposed class extension is "all employees 

that worked in any area of Sandia National Lab, 

Albuquerque, New Mexico during the period of 

January 1, 1995 through December 31st, 1996."

Again, as always, for partial dose reconstructions, if 

the individual doesn't fall under the SEC, if we had 

any internal monitoring data, we'll use that in order 

to complete a claim.
56

Okay, so, that covers the '95 and '96 period, which 

our addendum -- we added an SEC. So the question 

is, what about the '95 through the 2011? We are 

going to continue to evaluate and determine the 

monitoring program completeness. And what we ran 

into is, every time we get a copy of this WebDose 

from the site we find issues.

So, again, in May we got another version of their 

WebDose. We found some issues, they committed to 

getting back to us in September with some 

resolutions. They were confident that they could do 

that. And we also had received about 6,000 pages of 

air data that we want to go through so we can look 

at the field monitoring program. We expect to be 

done with the Evaluation Report addendum by the 

end of 2018. 

I think that's it. Any questions?

Mr. Katz: Before we go to questions, Andy, do you 

have any remarks you want to make before we go to 

questions?

Member Anderson: No. I mean, the only thing would 

be our -- we did meet and we voted to support the 

addition. But we can get to that later, after 

questions.

Mr. Katz: Yeah. Right. Questions, Board Members in 

the room? David.

Member Richardson: You described the internal 

monitoring program as transitioning from bioassay to 

the use of personal and area air monitoring. Does 

that mean that they're transitioned away completely 

from bioassay monitoring?

Mr. Nelson: No. No, they still do bioassay 

monitoring, but they actually had a Dr. Skrabal come 

in and evaluate the program, and they determined 

that for, where there was some technology shortfalls, 

you need to start doing more personal air sampling 

for those radionuclides that are difficult to detect.
57

And so we saw evidence of that. They started 

merging in that direction. But, no, we still see 

bioassay at the site.

Member Richardson: And for the example of the 

feasibility findings for -- you said there was five 

claims from the period that had internal dosimetry 

data. By internal dosimetry data there do you mean 

personal air sampling or do you mean that those five 

had bioassay data?

Mr. Nelson: They had bioassay.

Member Richardson: Okay.

Mr. Nelson: Yeah, the only personal air sampling files 

we found is from a data capture during that 

timeframe in '95 and '96. We brought them back and 

we requested to the site, like we would any claim, 

"hey, for these individuals, send me everything that 

you have."

Well, what we got back didn't have anything to do 

with the personal air samples. Which was 

problematic for us.

Member Richardson: I see.

Mr. Katz: Do any of the Board Members on the line 

have questions for Chuck?

Member Roessler: No questions.

Mr. Katz: Thanks, Gen.

Member Ziemer: I have no questions. This is 

Ziemer.

Mr. Katz: Thanks, Paul.

Member Field: No questions.

Mr. Katz: Thanks, Bill. Andy, do you want to -- if we 

have no other questions, then, the Work Group did 

meet just a little more than a week ago, I think.

Member Anderson: Yes.
58

Mr. Katz: So, Andy, do you want to report on that?

Member Anderson: So, we met and we basically 

went through this presentation and I think asked 

many of the similar questions and raised the issue of, 

we really have not had a committee meeting because 

all of the proposals have continued to increase the 

size of the cohort for the SEC.

And we thought this, even though it was just a short 

period of time and we have a few questions about 

what was the reason for the cut-off that they chose 

on the upper end, when it really hasn't been 

determined when it's really been settled or is all the 

data there. And there's a commitment, again, to 

hopefully close this out. Probably not in time for the 

next Board meeting, but we thought their decision 

was an appropriate one, and the committee voted to 

add this, these years, to the SEC.

Mr. Katz: To recommend it. Before we get to that 

though, let's then go to the petitioner. I believe he 

was intending to be on the phone, so, do we have the 

petitioner on the line? For Sandia. 

I'll give you a moment. Perhaps you're on mute?

Okay, I'm not hearing the petitioner. Although I was 

told he planned to attend, but perhaps just to listen. 

So, then, let's move on.

So, Andy has noted the Work Group is recommending 

the addition of this class for these two years. And 

since it's a recommendation from a Work Group, it 

doesn't require a second, just a vote. And if there 

are no other questions, we'll go on to the vote. 

All right, we'll do this alphabetically again. We have 

several Board Members that are recused, I'll get to 

that when we go through them. 

So, Andy?

Member Anderson: Yes.

Mr. Katz: And Josie?
59

Member Beach: Yes.

Mr. Katz: And Brad?

Member Clawson: Yes.

Mr. Katz: Bill?

Member Field: Yes.

Mr. Katz: David Kotelchuck?

Member Kotelchuck: Yes.

Mr. Katz: Jim Lockey?

Member Lockey: Yes. 

Mr. Katz: Dr. Richardson? David.

Member Richardson: Yes.

Mr. Katz: Gen?

Member Roessler: Yes.

Mr. Katz: And then Mr. Schofield and Ms. Valerio are 

both recused. And Dr. Ziemer?

Member Ziemer: Yes.

Mr. Katz: Okay, and that makes it unanimous and 

the motion passes. And there will be a letter writeup. We don't have that letter write-up, but we'll get 

that to Board Members to copy-edit or what have 

you, and then we'll get that out from here. Thank 

you very much.

And that completes our sessions, I believe, for the 

morning. Yes, we're on to -- oh, I'm mistaken? No. 

Yes, so, we have a lunch break from 12:00 to 1:30 

and then we'll have a Bomber for SEC petitions 

update. So, thank you everybody and we're 

adjourned for lunch. And we'll see you again at 1:30 

Eastern Time.

(Whereupon, the above-entitled matter went off the 
60

record at 10:50 a.m. and resumed at 1:30 p.m.)

Mr. Katz: So welcome back, everybody, to the 

Advisory Board on Radiation and Worker Health. Let 

me check and see about my Board Members on the 

line. 

(Roll call)

Mr. Katz: Great, thanks, so we have all our Board 

Members here. Okay, I think we can go right into --

yes, I don't have any new faces in the room so I don't 

think I need to make any announcements about 

anything. 

We can go right into SEC petition status update from 

LaVon Rutherford. 

SEC Petition Status Update

Mr. Rutherford: Thanks, Ted. I'm LaVon Rutherford, 

I'm the Special Exposure Cohort health physics team 

leader for NIOSH and I'm going to give the SEC 

update. 

We provide this update at every Advisory Board 

meeting and it lets the Advisory Board know petitions 

in qualification under evaluation and currently under 

Board review, and any potential 8314s we have. 

Alright, to date we are up to 249 petitions. We have 

two petitions in the qualification process, we have 

three evaluations in progress at this time, and it says 

we have nine petitions with the Advisory Board, it's 

actually ten.

Okay, petitions in qualification, we have two petitions 

in qualification that are both for Clinton Engineering 

Works. The operational year is 1943 and 1949. All 

employees is one and the other one is all Roane 

Anderson employees. 

The current Class Definition is for Tennessee Eastman 

employees, that's why we've received these two 

petitions. 
61

Petitions under evaluation, Sandia National Lab, this 

is '97 to 2005. Chuck Nelson spoke earlier about '95 

and '96 and the Board took action on that. 

These are the remaining years and we anticipate 

completing that has Chuck had mentioned at the end 

of this year.

Lawrence Livermore National Lab is, again, a 

continuation of an existing petition. We added a 

Class up through 1989 and we are evaluating the 

1990 to 2014 period under this petition. It's all 

employees. 

We expect to have this addendum completed in May 

of next year. Superior Steel is an 8313 new petition 

that we received. We're well underway with our 

evaluation. 

We do expect to have that completed in December. 

It may or may not be ready in time for the December 

Advisory Board Meeting and Ted is aware of that. 

As I mentioned, we have ten Petition Evaluations that 

are at some various stage under Board review. 

I didn't look at that password when you put it in 

earlier. Okay, I'm going to make sure I didn't miss 

something here, I thought I did. 

Okay, we have ten Petition Evaluations that are 

under Advisory Board Review at various stages.

Hanford, we did have a little discussion about this at 

lunch and we are working on setting up a Work Group 

meeting to discuss the matrix. 

We have been reviewing documentation to determine 

whether prime contractors' radiological control 

programs were meeting bioassay commitments. 

Those might remember that the lower-tier 

contractors drove in SEC for the 1984 to 1990 period 

I believe. 

Savannah River Site, we continue to work on 
62

resolving issues raised by SC&A and the Work Group.

Los Alamos National Lab, we have been working on a 

White Paper that responds to SC&A's review of our 

addendum. 

That report is actually just completed my review and 

it's headed to Jim's -- Dr. Neton's desk for final 

review and approval. So we expect to have that 

report out at the end of this month. 

Again, Sandia National Lab Albuquerque, I think 

we've talked about that one enough. Idaho National 

Lab, I know we have it on the agenda tomorrow to 

discuss. 

We have been working through issues in the Advisory 

Board's Work Group, identified by the Work Group 

and SC&A. Argonne National Lab West is with the 

Advisory Board and SC&A, as well.

Area IV Santa Susana, we had a couple of open 

issues that were raised by SC&A. We've been 

working to resolve those issues. I imagine Work 

Group updates when we get to those will get into a 

little more detail if needed. 

Metals and Controls, there is a Work Group update 

scheduled for tomorrow that will be both the Work 

Group and NIOSH.

Member Beach: It's today.

Mr. Rutherford: Oh, is that today? Well, there you 

go. That's today, my bad. 

The De Soto Avenue facility, that's tomorrow. See, I 

was looking at De Soto Avenue. De Soto Avenue 

facility is a new petition. We've recently completed 

that evaluation and we will be presenting that 

evaluation tomorrow. 

This is just a table of the open petitions with some 

years awaiting a recommendation by the Advisory 

Board, and it's basically a summary of what I just 

presented.
63

And at this time, we have no 8314s, potential 8314s, 

to discuss, and that's about it. Questions?

Mr. Katz: Any questions from folks in the room?

Mr. Rutherford: You guys are awful easy on me since 

Dr. Melius is not here. 

Board Work Session

Mr. Katz: How about my Board Members on the line, 

do you have any questions for LaVon? All right then, 

thank you, LaVon. Alright, we have a Board work 

session now, so let's do scheduling.

So the first item I have on there is we need a location 

for -- we have a Meeting December 12th and 13th of 

this year. 

We need a location for it and so I've done what 

homework I could do on this matter and I can run 

through what I've thought about. 

But my suggestion is LA because we have two SEC 

petitions open there, one may get -- and depending 

on how things go with SC&A, we have to talk to --

maybe put a priority on that if we're going to go with 

LA, but see how quickly we can do the SC&A review 

for the new petition if we end up tasking that.

And then we have NIOSH work underway, whether 

it's ready or not is also a question, but it may be 

ready in time. So, LA is, anyway, my first thought. 

I'll just tell you about the other locations that I gave 

thought to and why I wouldn't recommend them first. 

So, there's Albuquerque, we've been there recently 

twice and it seems very doubtful that we're going to 

have Sandia ready, with the Board ready on that in 

time for that meeting. 

It's in relatively early December so that's why I didn't 

recommend it but I gave it thought. I gave thought 

to Augusta, Georgia, for Savannah River Site but 

SRS, things are not ready. 
64

There are issues which we're going to pursue about, 

again, getting records and materials cleared, and so 

on, in a timely fashion from the site. But that's been 

a problem. 

It's possible that the Carnegie SEC that LaVon just 

told you about would be ready but it's Pittsburgh and 

I don't know, Pittsburgh is a terrible weather spot at 

that time of year. So, that's not encouraging. 

And then Idaho Falls, I thought about that because 

of the burial grounds work but, again, that time of 

year is a little bit questionable for weather.

So that's how I landed it at LA but I'm open to other 

thoughts, other locations from Board Members if you 

have those.

Member Beach: Sounds reasonable.

Member Anderson: Where in LA?

Mr. Katz: Well, I used to have more say in that than 

I do these days so it's the best we can do is what I 

would say. 

Member Beach: Oakland is our normal spot.

Mr. Katz: Oakland is Northern California and the 

past places we've used because they were the easiest 

in terms of the airport were Manhattan Beach and 

Redondo Beach. 

We've done both of those before and they're easy 

because it's easy to walk about and get your meals 

when you're not in the Board meeting and so on. 

But I'm open to suggestions and maybe we'll chat 

with the Petitioner, I'll chat with the Petitioner later, 

if there are other thoughts about where might be 

good. 

But anyway, I'll follow up on that and so let's go with 

that, LA for the next meeting. 

Okay, then I need to also schedule dates out a year, 
65

as we always do, and the next approximate 

timeframe is the week for a teleconference that we 

have for when we're scheduling would be June 24th, 

that week, the week of June 24th for teleconference.

I think June 24th is probably a Monday so Josie is 

suggesting Tuesday the 25th. Does that work with 

everyone in the room? That's going to be 11:00 a.m. 

Is that okay with the three Board Members on the 

line too?

Member Roessler: It's okay with me.

Member Field: It's okay with me. 

Mr. Katz: Paul? Okay, he may be on mute. Okay, 

so we may have lost Paul for the moment but June 

25th, let's have that, then, for the teleconference.

Okay, and then the next in-person meeting 

approximate timeframe not surprisingly is around 

now, so August 19th is the week. 

(Off mic comment)

Member Beach: I like fall vacations myself. 

Mr. Katz: So we're talking about the week of August 

19th. One of the difficulties is none of the summer 

months are great for the same reason.

July is terrible because we also have the 4th of July 

week which kills a lot of people's availability. 

And we don't want to let five months run between 

meetings or then it's sort of hard to get our three 

meetings in.

Member Ziemer: I'm okay in August.

Member Roessler: I'm okay.

Mr. Katz: I think Paul said he's okay with August. I 

think it's just tough that August is about the right --

Member Anderson: But it's back to school. 
66

Mr. Katz: Exactly, August 21st, August 22nd. Who's 

that from? Jenny. 

So we can't hear this but apparently there's some 

background noise on the phone so I just would ask 

everyone but my Board Members to please mute your 

phones and if you don't have a mute button, press 

*6, that will mute your phone. 

But some people are having a hard time hearing on 

the phone. So August 19th is a Monday so the 21st 

and 22nd would be Wednesday, Thursday. That's 

usually a good time of the week to do it. 

Anybody have any trouble with the 21st and 22nd of 

August? Going once? Okay, 21st and 22nd of 

August. Great, thank you, and I'm sorry, I know it's 

hard. 

Member Kotelchuck: It's not a problem for the rest 

of most of the Board. 

Mr. Katz: Okay. So now we're onto Work Group and 

Subcommittee reports and this should go relatively 

quickly because a lot of Work Groups haven't --

Member Beach: On the 17th of April is that a call or 

a Board meeting?

Mr. Katz: That would be a Board Meeting. 

Member Beach: Thanks.

Mr. Katz: So I'm going to run down the Work Groups 

and Subcommittees alphabetically. The first one is 

Ames, nothing new there. And Argonne East, Brad? 

Member Clawson: We have had a Work Group 

meeting, we're proceeding forward with it. Nothing

real new but we did meet. 

Mr. Katz: The next one that doesn't have any 

activity, we have a new Chair I'll just announce I

guess. 

Dr. Roessler has agreed to be Chair for Blockson with 
67

Wanda's retirement but we have no action on that. 

Brookhaven National Laboratory?

Member Beach: No change, we're still waiting for the 

updated TBD and it looks like we have a new status 

of January.

Mr. Katz: Thank you, and Carborundum, Gen?

Member Roessler: Yes, we just have Site Profile 

issues and NIOSH just finished a paper on the Monte 

Carlo calculations for the mixed uranium- plutonium 

fuel pellet work there. 

That paper has been delivered through SC&A so that 

will take place I think and then NIOSH also said that 

they'll follow up soon with a paper that details the 

NIOSH resolution to all remaining Site Profile issues. 

That paper is now in internal review. 

Mr. Katz: Thank you, Gen. Dose Reconstruction 

Review Methods?

Member Kotelchuck: Well, we were talking about this 

earlier, we don't have a date set. A couple of us have 

responded. 

There is at least one possible date available of the 

original choices and I urge the other Members of the 

Subcommittee to please respond quickly.

Mr. Katz: We are looking to a meeting in --

Member Kotelchuck: The Work Group to respond 

quickly.

Mr. Katz: -- meeting at the end of September. Thank 

you. Fernald, we've heard from today so I think that 

takes care of that. Grand Junction, Bill? 

(No response)

I don't hear Bill. You're muted. We haven't had any 

Work Group activity on Grand Junction. I don't know 

what the coordination report says as to what's 
68

coming next. 

Do you have that, LaVon?

Mr. Rutherford: Yes, we recently updated the Site 

Profile, completing everything in May of this year.

Mr. Katz: So is that awaiting a second look or are we 

finished?

Mr. Rutherford: I believe we were finished. 

Member Field: Okay, it's Bill. I just muted it and 

couldn't get back on. We wrapped that up I think. 

Mr. Katz: Okay, so then we can retire the Work 

Group for the time being, correct?

Member Field: Yes.

Mr. Katz: Thank you. Hamburg, Brad?

Member Clawson: We've got a Work Group 

scheduled coming up to be able to go over the matrix. 

Part of the issue is that we've lost Sam and Chuck 

has taken up the work there. 

And we've got the matrix that we've got to go over 

and get a path forward, and with the passing of Jim, 

I've just taken it up. 

So we've got a Work Group I believe next month or 

in October. I think he said we would try to do it early 

October. 

Mr. Katz: Thank you, Brad. 

INL, okay, we have a presentation for INL, 

presentations that will update people not just on the 

SEC petition that's ready for potential action but also 

for the other petition and that's tomorrow. 

Lawrence Berkeley? That's Paul. 

Member Ziemer: Sorry, I was on mute. Well, the 

Work Group hasn't met. We do have now a document 

on assessing internal doses of alpha, beta, gamma 
69

bioassays. 

That document is with the Work Group. I think we're 

still awaiting some responses to SC&A comments on 

that, but in any event, probably if we're able to, the 

Work Group, we haven't had any meetings at all. 

DCAS has got a lot of work going on at Lawrence 

Berkeley but we haven't actually looked at any of the 

documents at this point. 

If we're able to maybe towards the end of the year, 

we can at least look at the ones that are available. 

Mr. Katz: John Stiver, do you happen to know from 

the coordination report about what timeframe we 

have for that?

Mr. Stiver: We are waiting for NIOSH responses. 

Mr. Katz: The ball is in NIOSH's court? Oh, I see, 

alright, I got that backwards. Thank you. Okay, so 

towards the end of the year, is that what we're 

saying? 

Member Ziemer: I think that NIOSH is still 

responding to the White Paper on assessing internal 

dose from alpha, beta, and gamma bioassays.

So I think that's still in progress if I'm not mistaken. 

I don't know if Megan is on the line or who is handling 

that now for NIOSH? I don't know if Lara is still doing 

that one, is she?

Mr. Katz: Yes, so that's still underway. Let's see, 

where were we? Next we have LANL. Josie? 

Member Beach: We heard from LaVon earlier. The 

Work Group is waiting for the White Paper to go 

through NIOSH and get to the Work Group and then 

we'll review that and schedule a Work Group Meeting. 

Mr. Katz: And that's coming pretty soon I think, the 

paper? 

Member Beach: Sounds that way, yes. 
70

Mr. Katz: And then we'll have SC&A take a look at it 

too. Okay, Metals and Controls we'll have this 

afternoon. Mound, Josie?

Member Beach: We've pretty much wrapped up. Are 

we waiting for one more TBD? John, do you 

remember? The external, right? 

So we should see that and SC&A is already scheduled 

to review that, correct?

Mr. Katz: Sure.

Member Beach: And then, John, this is for Stiver, I 

noticed SC&A was asking about doing some sampling 

on how the database is applied in practice.

Is that something we need to talk about as a Work 

Group? 

Mr. Stiver: That was something we had earmarked 

earlier on.

Member Beach: So maybe in conjunction with your 

review we can discuss that?

Mr. Stiver: That would be a good time.

Mr. Katz: Yes, we should do that in the Work Group 

session. Very good, thanks, Josie. What about the 

test site, Brad?

Member Clawson: We had a Work Group in April of 

2018, I believe it's with NIOSH on the whole-body 

ratio. The last I heard we were waiting for NTS. 

Mr. Katz: Right, there's been some back and forth 

between staff on NTS for now quite some time. So it 

is moving forward. Oak Ridge National Lab, Gen?

Member Roessler: Okay, I have had no update from 

NIOSH or SC&A. The last thing that I think happened 

was we had the exotic radionuclide report from 

NIOSH, we received that in April. 

My understanding is it's now under SC&A review. 
71

That's all I know, so maybe if we have someone from 

SC&A or NIOSH who would like to comment, that 

would be good. 

Mr. Katz: Can you come to the mic, please?

Member Roessler: That's the hot seat, Joe. 

Mr. Fitzgerald: Joe Fitzgerald. Yes, we are fairly well 

through our review of Report 0090, which is exotic 

radionuclides X-10 ORNL. 

We'd anticipate a response being prepared and ready 

by sometime late September, early October. So in 

another three or four weeks we should have it out 

through editing and into your hands and the Work 

Group's hands. 

Mr. Katz: Okay, so, Gen, that sounds like you've 

given NIOSH time to read that and you read it later 

this year, November. 

Member Roessler: Good, thanks, Joe.

Mr. Katz: Thank you, Joe. Okay, PPG we're going to 

hear from Jim on that. We addressed that in a 

previous Board meeting and Jim has done the followup on that. 

So Portsmouth, Paducah, K-25?

Member Schofield: I think they're almost closed 

there. I can't think of anything that's still open on 

those. 

Mr. Katz: So Chuck has just reported there's a 

neutron White Paper that's coming out in the next 

month or so on that. So we'll have SC&A take a look 

at that when that comes out, John Stiver, and then 

we'll have a Work Group. 

So maybe this is also later this fall, October, 

November. Great, thank you. Sorry, I had to take 

some notes. Rocky Flats, David? 

Member Kotelchuck: Right, Rocky Flats, nothing to 
72

report. 

Mr. Katz: Sandia, we're set on Sandia, we know 

where we are there. Santa Susana, also we'll be 

hearing about Santa Susana. Actually, we're hearing 

about DeSoto so Santa Susana, where are we with 

that?

Phil?

Member Schofield: We still have some items still 

open there. 

Mr. Katz: And who is holding the ball?

Dr. Hughes: So we have a couple items open with 

the Work Group for the last Santa Susana petition 

and we're hoping to get this to the Work Group by 

the end of the year. 

It's just been a time scheduling issue mostly to 

complete the couple White Papers and send them to 

the Work Group. 

I hope to have them to the Work Group soon, within 

the next couple of months or so. 

Mr. Katz: So that's two? You said a couple, is that 

correct? 

Dr. Hughes: There were two issues, I'm not sure 

exactly how it's going to be presented to the Work 

Group. It might be wrapped up in one but the two 

issues will be addressed. 

Mr. Katz: Okay. Thank you, Lara. Okay, SRS, Brad?

Member Clawson: Tim's been working on this. 

NIOSH has got the action and they've gone through 

a sampling plan. Right now we're having a little bit 

of trouble getting documents out of SRS. 

But we're looking later on this year to be able to have 

a Work Group meeting, review the process. 

Mr. Katz: Great, sounds like a busy fall for us. 
73

Science issues, David? 

Member Richardson: If you'll remember in the April 

meeting we had a presentation on DDREF, I think the 

outstanding issue in the short-term for us is there 

were peer-review comments provided to NIOSH.

And I think our next action item is for the group to 

get together after having looked at those peer-review 

comments and part of the presentation to wrap up a 

report on that topic. 

But as Stu presented today, there's this other issue 

that there are a number of other organizations also 

working on this same topic. 

And I believe the sense from NIOSH that was 

conveyed by Stu is that NIOSH is not intending to 

move quickly on this until those have happened as 

well. 

But in terms of our own work, I think the next thing 

is to finalize a report on this, reviewing the peer 

review comments and incorporating what we found. 

Mr. Katz: Tim?

Dr. Neton: I did put out a White Paper at the end of 

June, June 28th, that summarized our position on 

this and to a large extent, Stu summarized our 

thinking about the ongoing efforts. 

But there are some other issues too, we thought, 

related to the assignment of DDREF less than one by 

the SENES people and that sort of thing. 

It's a short read, seven, eight pages and I think the 

Work Group has it at this point. And we can probably 

look at that in addition to the peer review comments. 

Mr. Katz: Right, okay, so you'll let me know, Dave, 

when the timeframe is right to set up a Work Group 

meeting. SEC issues, that's Andy but he's just 

inherited this Work Group so there's no report there. 

Member Anderson: No, I don't have anything to 
74

report.

Mr. Katz: There are several tidbits that need to come 

before that Work Group at some point. 

Member Anderson: I don't think we have anything 

right now. 

Mr. Katz: There's not any major --

(Simultaneous speaking.)

Member Anderson: We're waiting for some reports 

or I guess we're waiting to be told when NIOSH is 

ready to sit down with us. 

Mr. Katz: Subcommittee on dose reconstruction, 

Dave?

Member Kotelchuck: First, just to note that we lost 

two senior Members to retirement, Wanda Munn and 

John Poston, who we talked about this morning and 

passed a resolution of thanks. 

I'm happy to say that we have two new Members, 

Loretta Valerio and Jim Lockey, and we're back to 

work. 

We met on July 24th and we finished the blinds that 

we had and we, amazingly, seemed to come to very 

near the end of our previous sets for dose 

reconstruction. 

That is, there are some that are in progress, there 

are some that are with other Subcommittees. But 

basically, we are going to start working with audits 

and other things on the new set. 

There's a good chance that we will not need a 

meeting, we'll not able to have a meeting until a lot 

more work is done, maybe towards the spring of this 

next year. 

I was wondering, as Chair of the Subcommittee, in 

the past both Dr. Ziemer and Jim Melius had talked 

to me and others have said it would be nice to update 
75

our report to the Secretary. 

This appears to be a period in which there will be 

relatively little in terms of meetings. And I thought 

about it and I thought if I'm going to be asked to do 

it again, maybe this would be a good time. 

And I would like to mention this to the Board to think 

about. Would you like me to do that? Is this an 

appropriate time? I'll be glad to. 

Member Clawson: Yes. 

Member Beach: I think I brought that up at the last 

Work Group meeting. I know I was saying it in jest 

but --

Member Kotelchuck: Yes, but I took it seriously. 

Member Clawson: We figure if you're bored, by the 

time -- it should get there. 

Member Kotelchuck: I'm never bored. There has to 

come a time and this is a nice break for me, such that 

I can devote attention to this and primarily it will be 

an update of the last report. 

Mr. Katz: Yes, it has a nice new aspect to it because 

we've now reviewed a lot of blind, we didn't cover a 

lot of blinds in the last report knowing that we hadn't 

-- we were sort of midway with those. 

So this is a good opportunity to have some emphasis 

on that, which we haven't really addressed in much 

detail in that report, I agree. And we may get to 

having more meat on the table for the Subcommittee 

a little sooner because we do have a set and it's going 

through the individual Board Member reviews 

presently this fall. And the quicker that gets wrapped 

up, the quicker we have more reviews ready for the 

Subcommittee, but thank you. That's a good idea.

Member Kotelchuck: I'll take a crack at it. 

Mr. Katz: Right, and we have Rose to help us with 

the graphics and so on. 
76

Member Kotelchuck: The graphics were a major 

contribution to the last report and I hope Rose will be 

able to do it or someone from SC&A. 

Mr. Katz: Sure. Okay, Subcommittee on procedures 

review, we have a new chair. Josie?

Member Beach: Big shoes to fill there. I'm just 

getting my feet wet. I know that this afternoon, Dr. 

Neton, you're going to close out some outstanding 

issues. Well, you're on the schedule. 

And then just briefly looking through the procedures, 

I mean, we have 60-plus that are closed. 55 or 25 

that we have open issues on the procedures and 

around 28 that are in progress or in abeyance. 

I've just been kind of going through the different 

procedures, I have a couple that I've seen that we 

have, the Work Group's never looked at that I will 

bring up at the next Work Group meeting. 

Other than that, just wish me luck and hopefully lots 

of help from older Members. 

Member Schofield: Did you refer to everybody as 

old?

Member Beach: Older.

Member Schofield: Oh, okay. 

Mr. Katz: TBD-6000. Paul? 

Member Ziemer: We have nothing active going on. 

The only sort of back-burner item right now we have 

for Joslyn, there is some older activity that needs to 

be completed. Right now I think the ball is in NIOSH's 

court to comment on some things relating to the 

MCNP library as far as the Joslyn site is concerned. 

I think the latest thing I saw from Dave Allen was 

that NIOSH intends to have their comments out some 

time by the end of this year. So that's sort of a backburner item. Otherwise, TBD-6000 hasn't met lately, 

so there are no action items. 
77

Mr. Katz: Okay, thanks Paul. And then there's its 

sister Work Group, uranium-refining AWEs. Andy?

Member Anderson: We're just on hold right now. 

Mr. Katz: On hold. And then, finally, there's the 

surrogate data. Paul has been chairing that, is now 

chairing that. 

And that also hasn't met but it also has -- Paul, I don't 

know if you want to cover anything there? 

It has an item, a small item to deal with, with -- I 

forget the site right now but there is a site for which 

the surrogate data issue -- I don't recall right now. 

There's a site, we've been holding it, we've been 

waiting on that. It was a surrogate data issue that 

came up at the Board meeting actually and we 

referred it to the surrogate data Work Group but it 

hasn't actually taken it up. 

Member Ziemer: Sorry, Ted, instead of the mute 

button --

Mr. Katz: It's okay.

Member Ziemer: I ended the call, I just had to dial 

back in, but -- so obviously I am new to this 

chairmanship, but I didn't hear what you had to say.

Mr. Katz: I was just saying, Paul, there is one site 

with a surrogate data issue. It came up as part of 

the SEC -- as part of the maybe Site Profile review. 

Dr. Melius brought it up and thought that the 

surrogate matter should be looked at for that site, 

not that he had great concern about it. And we've 

had it on the burner, and I don't recall the site. 

Member Ziemer: Okay, we need to track that down 

then. 

Dr. Neton: This is Jim. I think it's the one that was 

Dow Chemical, maybe --
78

Mr. Katz: Dow Chemical. 

Dr. Neton: -- in California. No, not Madison. 

Member Ziemer: Not Madison I don't think. 

Dr. Neton: It's a facility that was based out of 

California and did some early pilot plant work with 

extractions and there was a radon issue there, and I 

think Dr. Melius raised a concern about sufficient 

accuracy of the radon values that we used. 

I think in that particular case we actually used the 

radon from one -- that old TIB that had the Florida 

phosphate industry stuff that we couldn't use 

because of the ventilation rates. 

And so I wrote a response to that quite a while ago, 

and no action has been taken since then. It's a very 

small piece, maybe three pages long. 

Mr. Katz: Right. So I'll -- Paul, I will unearth that 

report from Dr. Neton and send that to you. Maybe 

we can set up a -- it should be a brief Work Group 

call for that. 

Member Ziemer: Right, sounds good. 

Member Kotelchuck: That wasn't the blind case with 

-- I think it was, and I'm very glad to hear that a 

report was done and please CC me on that. 

Mr. Katz: I'll do that.

Member Kotelchuck: Send it to me. Thank you.

Mr. Katz: I'll do that.

Dr. Neton: I think what happened there is this came 

up in a blind review, and Dr. Kotelchuck spoke to Dr. 

Melius about the issue who then was concerned 

enough to forward it on to the surrogate data issues 

for consideration.

Member Kotelchuck: Very good, I'm so glad that's 

done. I really would like to close that. 
79

Mr. Katz: So I'll do that, I'll take care of that followup. 

Member Beach: And, Ted, I forgot to mention we do 

have a Subcommittee Meeting scheduled for October 

31st, just for the record, for Procedures 

Subcommittee. 

Mr. Katz: Right, right. 

Member Beach: I didn't mention it during the report. 

Mr. Katz: Thank you. That's what I was thinking of 

when we were trying to figure out when we had 

already scheduled the other Work Group, but yes. 

Okay, that takes us through all of our Work Groups. 

And I believe -- oh, no, so last but not least we have 

April public comments which I can run through for 

you all if you want to follow along. You received two 

documents for that. 

There's the summary document, and then there's a 

document with all of the transcript, related transcript. 

The summary document's really adequate for this 

purpose here. I don't think any of these are hard to 

follow. 

So we have a -- there was a comment on -- I'll take 

you through from Page 1 on, there was a comment 

on Portsmouth where I addressed that comment in 

person at the Meeting, so that's taken care of. 

For Fernald, there were a couple comments, and 

those have been handled by Stu, one related to 

different practices at Fernald in the past, and Stu is 

aware -- the program is aware of those practices and 

accommodates us with its DR methods. 

The second related to DOE's external exposure limit 

being high, too high to be protective, as the 

commenter put it, and, again, Stu explained that that 

limit doesn't really relate to what has to be done to 

do the dose reconstructions. 

And we had several comments related to Dr. Melius, 
80

then we had a Rocky Flats comment about Petitioners 

not being allowed to go through records, certain 

records, access to them. LaVon has handled that 

directly with the commenter.

We had a general comment about CLL, and we've 

addressed that. And then we go on to Sandia, and 

we had several comments about Sandia, this is 

Albuquerque. And these are going to be addressed 

in the final addendum you will receive on Sandia at 

the end of the year.

Let's see, okay, and then there were also comments 

you might recall about how long will it take to get 

certain information out of Sandia. But that bridge 

has been crossed since, and those records are -- and 

we've gotten those records from Sandia so that we're 

no longer hung up there. Then we had comments 

related to Pinellas. 

I addressed them in real time at the Meeting, and 

there was also a comment by the same commenter 

about job titles being used for dose reconstructions, 

and it was explained that we don't rely just on job 

title to make dose reconstruction decisions. 

And then finally, there was another comment related 

to Rocky Flats related to documents the Board should 

have looked at, and the Board had those documents 

prior to their voting on Rocky Flats. And that was 

discussed with the commenter.

And that's it for the comments from April. Any 

questions?

Okay, then that takes us -- it's early, but I don't see 

any reason why we can't just carry on to the 

procedures reviews if we're ready to do that.

And then we can extend the break because we want 

to start the Metals and Controls at the proper time. 

But, Jim, if you're ready? 

So this is a session on the procedure reviews. We 

dealt at the last prior Board Meeting or maybe it was 
81

two Board Meetings ago, I'm not sure, about skin 

doses, various issues, and Jim is following up on 

those. 

Procedures Reviews (Estimating Skin Doses) OTIP 

17 (Findings 7 & 15) & Overarching Issue 9 

(continued)

Mr. Hinnefeld: Ted, I'm not sure I'm going to be able 

to show this to Skype. I can show it to the room, but 

I'm not sure I'm going to be able to show it to Skype, 

but they are on the website if anybody's on the phone 

and is on our website. 

Mr. Katz: So why don't we just identify these 

documents so that people can follow along as well as 

the Board Members.

Mr. Hinnefeld: It's called Procedures Review 

Presentation excerpt. 

Mr. Katz: Right. 

Dr. Neton just said excerpted previous presentation 

material, and that, you can find that under the 

procedures review session on the NIOSH website for 

people in the public who want to follow along with 

these. 

They're not extensive either. 

Dr. Neton: Right, I do not have a formal 

presentation. I thought I could cover these two 

simple issues, one not so simple but I thought I could 

verbalize our findings. 

Just to refresh your memory, Ted did say that these 

are related to OTIB-17, the Procedure Review 

Committee's review of the interpretation of 

dosimetry data for assignment of shallow dose. 

Back at the April 11, 2018 Board Meeting, Wanda 

Munn presented this presentation, and there were a 

couple questions raised on this presentation and a 

companion piece, which is overarching issue 9. 
82

They're all related to skin dose, and we'll just cover 

them here at one time. I think there was like 15 

issues that were raised by SC&A in their review, and 

the Procedures Review Subcommittee closed out all 

of them, but a question was raised on two findings, 

the closeout of Findings 7 and 15. 

I believe David Richardson raised this question, and 

it had to do with Finding 7. That is our selection and 

calculation of the attenuation factor that protective 

clothing would afford over certain areas of the body. 

And I think this was specifically related to the 

protection factor for the genitals. 

There was no quibble about the 4 millimeter 

thickness, but I think after reading several times the 

question, I think it had to do with the relative 

attenuation of undergarments versus like coveralls, 

that sort of thing. 

And we went back and looked at this in some depth 

and went back and looked at three different sets of 

protective clothing, three different sets of clothing 

and did measurements and came out with the result 

that these values could range anywhere from 1 to 5 

millimeters, and the density would be somewhere 

around 1.5 grams per cubic centimeter for both the 

undergarments and the protective outer clothing 

based on the fact that these are cotton garments. 

We re-ran the calculations using the mean of the 

distribution of the values that we measured and came 

out with very similar results for two of the three 

nuclides that were listed in Table A1 of TIB-17. 

That would be for strontium-90 and yttrium-91. 

What surprised us, though, was that the value for 

rhodium -- ruthenium -- rhodium -- ruthenium-106, 

rhodium-106 was different by about a factor of two. 

In other words, the attenuation factor would be 0.5 

not 0.2 something that was reported in the TIB. 

Remember, this TIB was written back in 2005. It's a 

fairly old TIB, and those values were run originally 

with VARSKIN. VARSKIN is a program that we use 
83

to assess these correction factors. 

It's a pretty well recognized industry standard for 

that calculation. And in the VARSKIN Version 3 we 

got a value of X and VARSKIN value -- Version 5 for 

ruthenium/rhodium gave us a factor of 2 difference. 

So given that, we believe that it's appropriate to go 

back and revise Table A1, and so this finding really 

should not be closed at this time. 

So we're going to go back and, in fact, we were in the 

process of revising TIB-17 before this happened and 

namely, that was to incorporate the new ICRP 116 

dose conversion factors that had been put out some 

time ago. 

So this is a good time for us to go back and look at 

this quite old procedure. So that was Finding 7, and 

Finding 15 was actually the same thing about the 4 

millimeter thickness and the relative attenuation of 

the protective clothing that we measured. 

So given that this procedure will be revised, it will be 

reopened, then, at the time it is revised, and I 

suggest the Procedures Work Group could take it up 

again at that time if that's acceptable. 

So if there's any questions on that particular issue?

Member Richardson: You said that you went back 

and did some measurements?

Dr. Neton: We obtained representative samples, I 

don't want to say they're representative, samples of 

protective clothing of three different types. 

Undergarments, coveralls, I guess, that sort of thing. 

Member Richardson: Apparently my short term 

memory is terrible, but I recall one of the issues being 

the permeability of the undergarment, not just the 

thickness but the assumption that you had a perfectly 

impermeable undergarment.

Dr. Neton: I thought so when you were talking, but 
84

I went back and reviewed the transcripts and that did 

not come through in the transcripts. If that's the 

issue, we did not evaluate that particular concern. 

That could be taken up again I guess when we revise 

this procedure, but we reread the transcripts very 

closely, and it had to do, I thought, with the 

differential attenuation of the undergarment versus 

the --

Member Richardson: You don't remember the phrase 

perfectly impermeable underpant. Well, it sticks in 

my mind.

Dr. Neton: It was not just me, we had three, four 

people review it. 

But I apologize if we misinterpreted your question 

then, but it's a good time because we're going to go 

back and revise it anyway, so we can take that issue 

up at that time. 

Okay, that was two of the findings on TIB-17, and 

then let's skip over to the overarching issue 9, which 

are still both related to skin exposure. 

The first one of these was Concern 1. If you 

remember, we had a model, and this is interesting, 

this is not related to TIB-17 necessarily. 

It's related to a dose reconstruction review that was 

done for Blockson -- no, Bridgeport Brass, where the 

finding was that you did not incorporate a dose 

calculation for finely suspended material that would 

fall, drop down, and deposit on a person's skin and 

give them a dose from their exposure. 

So we proposed in that Dose Reconstruction 

Subcommittee review a model for that, and at that 

point, I think they recognized this was probably an 

overarching issue, and it got transferred over to 

Procedures Review Subcommittee. 

In that model for Bridgeport Brass, we came up with 

an estimate of 16 millirem per year to bare skin, a 
85

pretty small level of exposure. And we resolved one 

question which had to do with -- we assumed the skin 

was only contaminated for eight hours per day, and 

then Dr. Kotelchuck raised the question as well, how 

do you know if people take a daily shower, could it 

not be more than that? 

So we went back and looked at the Site Research 

Database and found about seven sites that did AWE 

work in the 1940s and 1950s, this is Atomic Weapons 

Employer work, which is what this was designed to 

cover. 

And in each of those cases, showering at the 

workplace was the recommended practice. Now, that 

doesn't mean all facilities do that, but it seemed to 

be -- the health and safety laboratory would go in 

and make recommendations. 

And for instance, Chapman Valve, they were very 

clear, these people need to wear protective clothing, 

shower at the end of the shift, that sort of thing. 

So it certainly seemed to be the bulk of the evidence 

points to that, but I would say that we can't 

definitively prove all cases did that.

Now, having said that, I looked at this from a much 

broader perspective, and I'm a little bit concerned 

about what we're doing here. We're assigning, in the 

case of Bridgeport Brass, 16 millirem to the skin. If 

you go back and look at the -- and this is for uranium 

facilities, if you look at the skin exposure that we're 

assigning based purely on working with the uranium 

metal itself, the dose is almost 6 rem per year to each 

worker for every year at the 95th percentile, which 

we had assigned for workers. 

So you've got this huge 6 rem dose that we're 

assigning, and we're sort of quibbling over here about 

whether it's 16 or maybe 32 millirem. I'm kind of 

questioning the value of this calculation. I'm not 

saying we're going to omit it but maybe couch it in 

somewhat better terms. 
86

Also, on top of that, Bridgeport Brass actually wore 

dosimeters, so you could also question whether the 

dosimeter itself would become contaminated, and 

that in itself would have indirectly measured that 

exposure to the skin as well because the 

contamination would not just preferentially deposit 

on the head but possibly on the dosimeter. 

So we're going to go back and take a look at that 

issue. I went back and looked at the original 

transcript, this is a lot of digging, going back; thank 

goodness for transcripts. 

I went back and looked at the original transcripts, 

and these items were not really officially closed, they 

were listed as in abeyance, the reason being that we 

committed to writing this in some procedure 

somewhere. 

Well, we didn't. There is no procedure. The only 

place this modeling exists is in the response to the 

Bridgeport Brass dose reconstruction review. 

So we need to go back, we're going to incorporate 

this into TIB-17, discuss some of the broader issues 

that I mentioned about the sanity of assigning 16 

millirem versus 6000 millirem to the workers and 

include that in the TIB-17 revision as well. 

So, Josie -- I was going to maybe close these out. 

Well sorry we couldn't do that, we're just trying to be 

intellectually honest here and make sure we do the 

right job. So that's where we are with those two 

issues. 

Okay, the last one is probably the most complicated 

to explain, at least in one part, but I'll give it a shot, 

and I don't think we're going to change this one 

unless I hear some compelling argument to the 

contrary, at least at this point. 

SC&A raised a concern. In TIB-17 there's an 

approach that we prescribe for how to deal with 

localized skin contamination. That is contamination 

that is not distributed uniformly over the whole body. 
87

And SC&A recognized that the risk models 

themselves were developed from whole-body 

exposure, the Hiroshima and Nagasaki survivors in 

particular were whole-body radiation. 

So are these risk models really appropriate to assign 

that risk value, excess relative risk per sievert, to 

something less than whole-body radiation, a square 

centimeter of skin, the 14 percent of the body that is 

covered by your exposed skin, the head and the 

hands, that sort of thing. 

So we actually prior to this had asked Oak Ridge 

Center for Risk Analysis to opine on this issue. And 

David Kocher, who you all know, he presented at the 

last Board Meeting I believe, in January of 2014 

issued a review White Paper of this exact issue. 

And he evaluated the three possible exposure 

conditions that can occur or three possible conditions 

that we need to reconstruct.

One is that a small area of the skin is contaminated, 

and we know that the contamination is exactly over 

where the skin cancer was located. 

And that relates to -- and then the question is, is the 

excess relative risk per sievert for a whole-body 

exposure okay to use for that small irradiated skin? 

And I think this was distributed to the full Board 

maybe a few weeks ago, Ted. So I'm not sure 

everyone's read it, so I'll go over it a little bit. 

The idea that Kocher proposed, and I agree with it, 

is that if the excess relative risk is equal to the excess 

absolute risk over the baseline risk, if the excess 

absolute risk and the baseline risk are proportionate 

all over the body, then it's okay because you would 

multiply the numerator or denominator by some 

fraction of skin, 0.1, 0.5, that sort of thing. 

And it cancels out, and it's okay to use the excess 

relative risk per sievert for whole-body radiation. 

That's based on one key assumption, that the 
88

baseline risk and the excess absolute risk are uniform 

over the body. 

And can we prove that? No. So that's an open-ended 

question. 

You can evaluate a couple different scenarios where 

it may be claimant-favorable to do that if you're 

reconstructing dose for skin that is exposed usually 

because the UV exposure also causes skin cancer, 

which would drive the baseline risk up for those 

cancers. 

Likewise, it may underestimate it if you have skin 

that's normally protected and you don't have -- the 

baseline risk might be lower.

So SENES looked at this or Oak Ridge Center for Risk 

Analysis looked at this in some detail and basically 

came to the conclusion that right now, there's not 

sufficient information to be able to weigh in one way 

or the other on those unique cases. 

So we're using the whole-body radiation, and that's 

the best we have right now. That's the first situation. 

The second situation is the skin cancer, the 

contamination you know was measured, and it was 

measured on the forearm, and the skin cancer was 

on the back. 

In that case, clearly, the risk is zero unless there's 

bystander effects or something to that effect. So we 

would assign a zero value. 

The third situation is the trickiest of all of them, and 

that is where you have a skin contamination, a known 

skin contamination, but you don't know where it was. 

This kind of puzzled me a little bit because I didn't 

think we had ever used this before. It turns out that 

this was developed way back when for the Hanford 

facility where we had a hot particle issue. 

And so you could have a situation where there were 

hot particles -- there's a probability of a hot particle 
89

depositing on someone, environmentally I think this 

is where it originated, and you know there's a 

probability that it could deposit on the skin, it was 

never measured, and you have a skin cancer. So 

what's the risk associated with that?

Well, in this situation where you don't know if the skin 

was irradiated over the tumor or not, it falls into the 

realm of binomial distribution. 

Let's take, for example, if you have 14 percent of 

your skin contaminated which would include your 

head and your forearms and your hands, that 

represents 14 percent of the skin.

If 14 percent were contaminated, but you didn't know 

where the tumor was, then the maximum dose would 

be -- we would assume, just like we did when we 

knew where it was, let's assume it was all over the 

14 percent, that would be the maximum dose. 

And that would happen 14 percent of the time. The 

other 86 percent of the time, the dose is 0. 

So you would have a binomial distribution where we 

would have a spike, 86 percent, 0 dose, 14 percent, 

the maximum dose.

And in this case for the Bridgeport Brass, it was 16 

millirem. Well, we don't have a binomial distribution 

in IREP. It doesn't exist.

So what was done was we developed this log-normal 

approximation of the binomial that SENES 

investigated in some detail in their White Paper, and 

concluded, correctly so, that the log-normal 

approximation of a binomial is a claimant-favorable 

thing to do. 

Since this issue was raised, we have communicated 

with SENES, and they are actually in the process now 

of producing a binomial distribution test model for us 

to use in IREP to see, indeed, if what we're doing is 

definitely claimant-favorable and whether or not we 

might want to move forward in the future and have 
90

the true binomial distribution for this situation. So 

that's all I have to say on that issue, unless there's 

any questions. 

The third issue is a little bit complicated, and I hope 

I did it some justice. Any questions? 

Mr. Katz: Any questions from Board Members on the 

phone?

Member Anderson: Just a quick, so back to the 

individual case reviews, I don't recall if I've ever been 

involved with any of the detailed reviews. 

Do they know the exact site of the cancer, or is it just 

listed skin cancer?

Dr. Neton: No, we know where the skin cancer 

occurred, we don't know if the contamination was at 

that site or not. 

(Simultaneous speaking.)

Member Anderson: -- location? 

Dr. Neton: Yes, originally we went and searched 

through the database. I didn't see any cases where 

we used it and then it sort of popped out of the 

woodwork and I said, oh, yes, we did use it at the 

Hanford site. 

And not a lot, I think a couple dozen times maybe, 

something like that, it's been used and it's exactly for 

this environmental, hot particles that were coming 

out of the stack at Hanford that we've used it for. 

And we believe -- like I say, I'm very confident it's 

claimant-favorable what we're doing because this 

lognormal approximation really overestimates the 

upper dose quite a bit. But that's what we're doing. 

Member Beach: So that didn't get used at INL? 

That's another area I would have thought maybe.

Dr. Neton: I'm not seeing it ever used at INL. Tim 

may know more than I do on this but --
91

Dr. Taulbee: This is Tim Taulbee. We haven't 

actually looked or pulled through IREP to see whether 

it has been used at Savannah River or INL. 

Dr. Neton: Yes, we pulled out -- this model uses a 

certain GSD that you wouldn't encounter in most 

dose reconstructions. In fact, if I've got one square 

centimeter of skin contamination, the lognormal 

approximation has a GSD of 14. 

So we just went through all the IREP runs and said, 

which ones have GSDs of 14? And at first we saw 

zero but then we realized they actually combined the 

environmental uncertainty with the dose and came 

out with a GSD of like 14.2 so that's why we missed 

it. 

But it is being used, and again, we're committed to 

looking at the test version that SENES puts together 

to see how well this plays out for us. 

Member Schofield: So how many sites do you expect 

this to be applied to? I mean, we also have Pacific 

Proving Grounds, we have NTS. 

I guess we have to handle it on a case-by-case basis, 

that's sort of a cop-out but I really don't know. How 

likely is it that you have a known hot particle, 

airborne hot particle problem? 

I guess that's the way I look at it and I know Hanford, 

they did have that in the early years but it could be 

applied at any place that you have a suspicion that 

that occurred. 

We allow for other areas of the skin to be 

contaminated more than 1 centimeter. 

It's based on the percentage of the skin that's 

contaminated and honestly, I don't think we would 

ever be using that because it's very unlikely if you 

had something in a worker's record that said he had 

5000 DPM per 100 square centimeters of skin 

contamination without some reference as to where it 

was. 
92

Usually, it comes with a full diagram of the body with 

measurements and that sort of thing. So the only 

unique situation I can think of is this hot particle 

problem, and that was the origin of it. 

In fact, the example in TIB-17 clearly indicates that 

they had hot particles in mind to use this one but they 

did make it more general and allow for other than hot 

particles. 

So I think the bottom line of all this, we're reopening 

TIB-17 and a couple of the issues are going to be 

fleshed out, refined for better detail. 

And unless we see something really -- it's possible 

we could use a binomial but we're going to go back 

and verify and make sure that these things are 

claimant-favorable and see where we go from there. 

Member Anderson: So any idea when SENES is going 

to complete their --

Dr. Neton: Probably not very long. I don't do 

computer programming. To me, everything is 

simple. It's just allowance for another distribution. 

We allow for lognormal, constant, normal, that sort 

of thing. 

No one ever envisioned, at least when we started the 

program, that we would be using a binomial 

distribution.

Mr. Katz: Any other questions? Thanks, Jim. 

And then we'll just -- John Stiver, we'll just have a 

focused review when they do come out with their new 

OTIB so you can look at how they've handled these 

matters. 

Okay, we have a little bit of time before we have 

Metals and Controls at 3:30 p.m. So if someone has 

something else they want to do between now and 

then, I think we can be on break. And please just 

come on time for Metals and Controls. Thank you. 

(Whereupon, the above-entitled matter went off the 
93

record at 2:41 p.m. and resumed at 3:29 p.m.)

Mr. Katz: So welcome, everyone, back after our brief 

recess. So we have the Metals and Controls SEC 

petition that we're addressing with the rest of this 

afternoon and then public comment session. 

Let me explain a little bit about how this will work. 

For Metals and Controls, the Work Group Chair will 

provide an update on the Work Group's activities. 

Pete Darnell, are you on the phone line? 

Mr. Darnell: Yes, Ted, I am. 

Mr. Katz: Great, welcome. 

And then, Pete, who is the lead at NIOSH for the SEC 

evaluation, he'll follow up and explain about followup actions related to the last Work Group Meeting 

and the work products that are out there and in the 

works. 

And then after that, we'll have the SEC petitioners 

address us and I think I can say their names, since 

at least one, Mike Elliott, is here. 

And Mike, that's your father, correct? Your brother. 

Oh, no relation. For real? Okay. So, the two Mr. 

Elliotts anyway will speak to us as petitioners and 

then after that, we'll go right into public comment 

session and I'll make some remarks about 

administrative matters related to that. . 

And then if there are other members of the public in 

the room, they'll have the first opportunity to 

comment, particularly if they're addressing Metals 

and Controls, since that's the focus of this afternoon. 

And if you are and you'd like to do that, then there's 

a signup sheet out front where members of the public 

can sign up. The petitioners don't need to sign up.

And then we'll take folks on the phone later and I'll 

address that. But let me just check on the line and 

make sure I have my other Board Members on the 
94

line. So, Paul, Bill, and Gen, are you on the line?

Member Ziemer: I'm here. 

Member Roessler: I'm here.

Member Field: I'm here too. 

Mr. Katz: Super. Okay, then I think that takes care 

of it. With no further ado, Josie?

Metals and Controls Corp. SEC Petition #236 

(Attleboro, MA, 1968-1997) Update

Member Beach: Thank you. Metals and Controls, we

have met once last May, May 3rd, to be exact. This 

first slide, of course, covers the Work Group 

Members: Henry Anderson, myself, Dave Kotelchuck, 

and Loretta Valerio. 

So, this is going to feel a little bit like I'm throwing 

the kitchen sink at you. During our first Work Group 

Meeting, we had an issues matrix which we covered. 

We had a nice presentation from SC&A. 

It was actually our first Work Group meeting where 

we had our Work Group Members be able to comment 

on different issues that maybe didn't hit the matrix, 

and so you might see some of that. 

And again, we'll follow up with where we're going 

from here. So if it feels like a lot, most of these were 

all discussed previously with some or a little bit of 

resolution, which I know Pete will cover in more 

depth. I'm just throwing it all out there. 

So, the first issue is the internal exposure associated 

with the subsurface maintenance and re-purposing 

activities in Building 10. 

This one was really important to me. Part of this, the 

petitioners talked about in that building a lot of 

floods. In my opinion, that washes down several 

potential unknown contamination issues down into 

those subsurface areas. 
95

The Landauer Film Badge Dosimetry Reports were an 

incorrectly calculated annual 95th percentile external 

penetrating doses to workers in the residual period. 

Those, if you have questions on them, again we'll 

have NIOSH online to follow up on some of these. 

NIOSH incorrectly calculated the 95th percentile beta 

skin dose to workers in the residual period. 

And then we had the swipe data used in the model. 

The last two years of operation is what swipe data 

we're using. 

So the Work Group questions the appropriateness of 

the survey locations included in the model and the 

overall representativeness of the data given that 

much of the -- this is one of mine. 

When I went through and looked at all of them, it was 

hard to read them, a lot of them were illegible. I 

know SC&A went through them with a fine tooth and 

NIOSH was claimant favorable on how they reported 

those. 

However, I still have questions about that swipe data 

based on their location and where they're going to be 

used for. So, more on that.

The Work Group also questioned how the model 

bounded exposures in the ceiling area near the 

rafters or the work pertaining to the roof penetrations 

for the HVAC maintenance. 

That really wasn't addressed early on. So I know it's 

been noted and we'll see some more on that. 

Okay, so issues continuing the distinction between 

the production and non-production workers, I 

question how that was defined in the ER and I 

understand the new ER that will be coming out at the 

end of the year should address that, according to 

NIOSH. 

Methods used to calculate ingestion rate should be 

more consistent with other sites. That, if you were 
96

listening in on the Work Group meeting, was covered. 

SC&A questions using exposures, experienced by 

high-flux isotope reactor workers as supporting 

evidence to validating the valid bounding methods 

used. Again, that was talked about and I think we 

have a resolution on that one. 

It may be inappropriate to use external dosimetry 

data collected during the last year of Atomic Weapons 

Employer, AWE, operations as the basis for bounding 

the external doses during the residual period. 

And on the line, am I doing okay on this mic? Can 

you hear me all right?

Mr. Katz: Sounds good. 

Member Field: Thank you. 

Mr. Katz: I find myself drifting so I wanted to make 

sure. Okay, so Work Group Members' concerns, 

some of these came up at the Meeting, some of them 

were just listed in the matrix after our meeting. 

So first one, how representative is volumetric 

contamination data from the drain line 

characterization to exposures experienced by 

maintenance workers? 

The second one, it goes back to the available sample 

data, how it was analyzed with either the isotopic 

identification or gross alpha techniques. The use of 

such data, we're questioning if it's acceptable, the 

absence of isotopic analysis. 

NIOSH assumes that the gross alpha activity is either 

all uranium or all thorium, whichever gives the higher 

PoC. The amount of time subsurface work was 

performed each year that one is a huge concern for 

me because I'm not sure if the workers were clearly 

heard. 

I know we went out and talked to the workers but I 

don't know if it was really well-understood how many 

actual time was spent there so that's something I'm 
97

going to keep a watch on, how that continues to 

manifest. 

And SC&A proposed a filter dust loading value of one 

hour per year. I feel like that's low. I feel like I need 

to get more information from the workers in the 

HVAC unit. 

One hour per year, to me it just depends on how 

much time, so I need some more clear idea of what 

was happening in those HVAC units. 

When I read through the reports from the workers, it 

seemed like some workers were in there wiping down 

the inside of the those units, changing out filters, 

vacuuming. It just seems like an hour a year seems 

low. But I might be wrong. 

So I need some clarity on that. NIOSH needs to 

demonstrate and back up their concerns using 

example dose reconstructions, applying assumptions 

and models being proposed with the information and 

the data that is available. That's pretty standard, we 

typically do that at each site. 

And then NIOSH needs to confirm the adequacy and 

completeness of the data so we do have some more 

work ahead of us. 

Okay, to follow along with Work Group Member 

concerns, work during the Metal and Controls 

residual period included renovations, demolitions, 

and extensive maintenance, all taking place without 

health physics support, training, or knowledge of 

radiological hazards for the entire Class period. 

Second bullet, radiological exposure potential in subsurface areas, drains, utility trenches and exterior 

areas. Some of this we've already mentioned, I'm 

just adding to it. 

All previously mentioned activities have high 

potential for residual radioactivity. Workers were not 

monitored. The swipe samples NIOSH needs to use 

from late in the operation period do not represent --
98

Mr. Katz: Can you hold on one sec? Someone on the 

line is not muted. If you would all on the line mute 

your phones and press *6, if it's someone on hold 

they can't hear me talking right now is the trouble. 

But if someone would go out, Nancy, can you ask him 

to go outside and cut the line that's on hold? Thanks. 

It's bearable in the room but it may not be bearable 

for folks on the phone so, Paul, do we need to wait 

until that line is cut before proceeding?

Member Ziemer: Ted, it is pretty hard to hear.

Mr. Katz: It's hard to hear I think I heard so let's just 

wait a second. Sorry about that, everyone. 

Let me just note again please don't put this call on

hold at any point. If you need to leave the call, hang 

up and dial back in because you'll upset the call for 

everyone else trying to listen. 

Alright, Josie, go ahead. 

Member Beach: So right about the second bullet, if 

it's not clear, it should be clear to you that 

subsurface, utility trenches, and exterior areas -- I 

have a lot of questions about that area and how the 

swipe data is going to cover those workers in that 

time period. 

So maintenance work performed on the roof with 

potential exposure to workers, it was not mentioned 

in the ER so there was penetrations through the roof, 

the roof had contamination on it. 

Again, some of the workers claimed it took two to 

three months in a given year that they may be doing 

that type of work with no monitoring again, unknown 

levels of uranium and thorium in subsurface areas 

inside and outside areas. 

So that, of course, is a key for me, combining and 

reducing all intrusive work activities, the roof work 

including rooftops, roof penetration work, roof line 

just under the roof deck, drains, utility trenches, 
99

exterior soils to one month per year seems on the 

low side and that's my opinion on that one. 

Petitioners' concerns, so the Petitioners, I know I've 

seen a couple of different letters before our Work 

Group meeting and then we got one after our Work 

Group meeting and so what I did was try to combine 

some of those. 

I may have missed some, if I did, I know you guys 

will jump in and throw what may have been missed.

So petitioners' concerns: workers were untrained, 

unmonitored, and unaware of what they were being 

exposed to on a routine basis, working in sub-surface 

soils and drains, utility trenches, on roofs, and in the 

exterior areas.

I'm hoping you'll expand on that in some of the work 

that was being done and help us understand that 

process. Metals and Control workers use aggressive 

work practices coming in direct contact with source 

materials with no controls and no limit to exposures. 

In 1982, they had surveys used to release the 

building interiors for unrestricted use. They were 

flawed and were limited in scope. There were no 

intrusive surveys done inside the drain lines, utility 

trenches, subsurface areas, overhead areas, exterior 

areas that served former AWE areas. 

So a big note of concern there. The characterization 

surveys that were done in 1994 and 1995 showed the 

survey in 1982 missed considerable amounts of

radioactive residual activity. 

The 1992 survey, we're limited to formal burial sites 

and I believe workers were actually running lines 

through these burial sites with no monitoring during 

the residual period.

Estimation of one month duration of exposure per 

year is low, Metals and Controls maintenance 

workers should have been exposed to subsurface 

residual radiation sources. 
100

Source materials require no excavation while snaking 

out plug drains, pulling wires through underground 

conduit, installing and repairing surface and 

subsurface utility trenches. 

And I misspoke, they would have been exposed in 

that first sentence. 

And lastly, in 1985, the survey failed to identify, 

detect, or quantify volume of buried debris or where 

the majority of the respirable radioactive 

contamination was found and does not represent 

likely exposures to maintenance and M&C 

maintenance workers, maintenance workers exposed 

in job descriptions not described accurately or left out 

completely. 

And lastly, the ER lacks sufficient data to meet its 

own criteria of estimating the bounding dose to 

workers in a scientifically sound and claimantfavorable manner. 

Last thing I want to say is this was an unusual sites 

with unusual scenarios that put workers in contact 

with radioactive materials in unmonitored, unknown 

levels of contamination for unknown periods of time. 

I can't say it any better than that. It's a tough one 

and I know in SC&A's presentation, they mentioned 

it was a tough call to make and I still feel that way.

So that's all I have. Any questions? 

Mr. Katz: Thanks, Josie. Before we go to questions, 

let's hear from Pete first and then we can take 

questions for both of you. 

Pete has notes but he was going to speak from, I 

think, your slides so you might want to help him with 

the slides.

Pete, are you there? Maybe Pete's line was the one 

on hold that we cut. Pete Darnell, are you there?

Mr. Darnell: It's hard to figure out if you're on mute 

or not on mute. 
101

Mr. Katz: I'm just jesting, Pete. We can hear you 

now.

Mr. Darnell: If you don't mind, I'd like to use Josie's 

slide presentation and I'll speak from each one of her 

slides. 

Mr. Katz: Thanks and so Josie will switch the slides 

for you as you speak. 

Member Beach: Which one do you want to start with?

Mr. Darnell: That would be your Slide 2. I'll tell you 

when to shift slides. To preface, it's true, we haven't 

met since May and a lot of work has been done. 

And actually, during the May meeting, the meeting 

was mainly about SC&A's presentation so we didn't 

get a lot -- NIOSH didn't get a lot of information out 

about what was going on in their path forward. 

So an overarching path forward that we have is that 

we published a White Paper on the sub-surface and 

repurposing exposure model. The Work Group is yet 

to talk about that and we're still waiting on review by 

SC&A. 

NIOSH will continue to refine that model. We're also 

developing a second White Paper which will address 

some of Josie's concerns specifically about the 

Building 10 ceiling area on the roof in the HVAC 

system. 

The planned completion date for that White Paper is 

December 2018. While that's going on, we're also 

revising the Metals and Controls Evaluation Report 

and that's planned for completion January 2019.

After that point is when, during the normal course of 

our procedures, we'll develop and present the 

example dose reconstruction. For bullet point A on 

slide 2, the Working Group met to discuss the White 

Paper. 

We have recalculated point B, the external 

penetrating doses that is issued. This has yet to be 
102

reviewed by the Working Group. Point C is the same 

thing with the beta doses, we've recalculated and are 

awaiting review.

Point B, the site data, NIOSH addressed the legibility 

of representativeness of the data legibility and that's 

coming out in the next publication of the issues 

matrix that is currently out in review by the 

Department of Energy. 

As soon as we get that back, we'll get that posted to 

the website and get it ready for review by the 

Working Group. 

Slide 3, please? 

NIOSH ER revision defines local production workers 

in the construction and maintenance service 

organization, facilities organization, or production 

machine operators/helpers, and production and 

repair R&M organizations. 

Those are workers within Buildings 4,5, and 10. 

These workers also perform sub-surface work in the 

area surrounding Building 10 from a rear area, 

metals recovery area, Building 11, railroad spur area, 

and Building 12 areas. 

Those were all the workers that are going to be 

included in subsurface and roof models that we're 

currently working on. 

The remaining workers, in other words, the admin 

people, the people that didn't do the hands-on work 

that had access to Buildings 4,5, and 10 will be 

considered non-production or administrative 

employees. 

And again, as with anything that NIOSH is doing, 

we'll keep that under review and modify as we get 

new information. 

Point B, NIOSH uses the TIB-9, Technical Information 

Bulletin 9, as the preferred approach. The basis for 

that concept is that ingestion is proportional to 
103

contamination and contamination is proportional to 

airborne radioactivity. 

We've addressed this issue previously in one of the 

Board's Procedures Subcommittee and it's part of 

overarching issue 2 that is mainly for the Board.

Bullet C, NIOSH agrees that the exposure personnel 

working in the HFIR is likely larger than exposures to 

covered personnel. We will delete or edit our 

comparisons or references cited by SC&A.

That's in the Site Research Database. Do you need 

me to quote the Site Research Database numbers or 

are my notes that you have good enough?

Mr. Katz: No, your notes are distributed, thanks, 

Pete. 

Mr. Darnell: Okay. Point D, in the current approach 

NIOSH has not calculated minimal doses during the 

site residual period, making the ER conservative.

However, we do agree that the source term over time 

should complete these exposures and we're going to 

provide new calculations for that in the condition 

report to maintain agreement with the depletion of 

external doses. 

Slide 4, please. At the May 3rd, 2018, meeting, the 

Working Group asked NIOSH to determine that 

volumetric contamination data taken from the drain 

line characterization, where it's representative of the 

exposure of experience by maintenance workers 

throughout the residual period. 

SC&A stated that the use of the 95th percentile value 

from the sample data could accommodate the 

potential in any event higher contamination levels 

encountered that were missed by the 

characterization study. 

The long way around is we've come to a preliminary 

agreement that the 95th percentile of the 

contamination in the highest priority lines, which is 
104

representative of what the workers could have been 

exposed to. 

And again, as with anything, NIOSH will continue to 

review and revise as we get more information.

Point B, in the published White Paper, and that's the 

paper that's on the website right now, we presented 

the method to model the exposures in distortion 

fields in the drains with both uranium and thorium 

exposures to maintenance workers. 

And I hope you'll forgive my use of maintenance 

workers as a generic term. I'm really talking about 

all the people I discussed earlier. 

Point C, during the interviews, both NIOSH and SC&A 

specifically asked experts about their occupancy 

rates and there's a host of site reference database 

documents and personnel interviews where this was 

discussed. 

And again, there was a preliminary agreement of 

one-month occupancy rates. What that basically 

means is that a worker in the specific groups I talked 

about earlier would get the highest dose one month 

a year assigned at the 95th percentile. 

But that's Point D, the dust-loading value discussed 

in the published White Paper compares favorably to 

that developed by SC&A and we will review and 

revise this as we get more information. E will be 

sample DRs I discussed earlier. 

F, NIOSH considers the value of data available to 

characterize the sub-surface environment and 

determine that the information used from the first 

White Paper was adequate with use where 

appropriate layers of conservatism apply. 

And we're going to continue to work on that as this 

information is reviewed, new information is found, or 

data is revised. NIOSH will continue to update that 

model. 
105

Next slide, please. Bullets 1 through 3 and 5, NIOSH 

recognizes there was the lack of training in health 

physics support to the M&C workers and we've used 

this information in the development and revised of 

the working papers in the Evaluation Report. 

We feel very strongly this is important information 

and that's why we are using it. 

Let's see, bullet 4. NIOSH, again, addressed the 

subset that's been repurposing concerns with the 

White Paper that we're going to be reviewing soon. 

Slide 6, please. 

Again, point A, NIOSH recognizes lack of training and 

adequate support. Point B, during the interviews, 

we've discussed specifically about the work practices 

and soil conditions. 

We asked very specific questions about that with the 

guys who did the work and that information is 

documented in the Site Research Database 

document. 

We used that to develop the revision to the 

evaluation of the report in both White Papers. Point 

C, not to belabor the point but we had published a 

White Paper. That paper does not rely upon the 1982 

decommissioning surveys. That was a sticking point 

and issue and we are addressing that. 

Point D, we did use decommissioning surveys to 

develop part of the ER and part of the bounding, but 

we used that information along with D&D levels, 

successful contamination levels, and a host of other 

factors to come up with the boundings. 

It's not just one thing or one factor that gave us the 

bounding dose. I feel like I'm not saying that very 

well. I'm sorry if it's not coming across. Slide 7, 

please. 

Bullets 1, 2, and 4. NIOSH considered the data 

available to test drive the environment and other 

work environments. 
106

We've determined that the information used in the 

first White Paper, which is the one that's published, 

was adequate for use with appropriate layers of 

conservatism applied. 

We used characterization data from 1982, '92, '94, 

'95 to develop sub-surface internal and external 

models. We're currently developing the White Paper 

for the ceiling access. 

Again, as we get more information, as we learn more 

of these models, they will be revised and fine-tuned. 

Point B, again, we did ask the workers during the 

interviews about occupancy rates and we were very 

specific and pointed in asking how long they will work 

there, what was the longest amount of time they 

worked there in each of these areas. And that's 

documented in the SRDB and we used this to 

determine that one-month occupancy rate. 

Slide 8, please. NIOSH considered the data that 

characterized the subsurface environment and other 

work environment. We use the information in the 

first White Paper, the one that's published. 

We feel that it's appropriate for use with a 

conservative -- where conservatism is applied. I'm 

sorry, I'm losing my breath a little bit. 

Again, we also use characterization data from 1982, 

1992, and 1994 to 1995 to develop surface internal 

and external numbers. We're currently developing 

the worker ceiling exposures. 

Finally, bullets 2 and 3, this is information that we 

plan to include in the revision to the Evaluation 

Report. And I think that concludes it for me. 

Mr. Katz: Okay, thank you, Pete. So first matter, 

then, do we have questions for Pete and Josie from 

the room? Board Members?

Member Lockey: Josie, one question. There was a 

survey in 1982, 1985, 1992, 1994, 1995. Any 
107

remediation after doing those surveys or not?

Member Beach: I'm probably not the best one to 

speak to that. I know they tried to clear the building 

with the '82. Does anybody have more information? 

NIOSH? 

I know SC&A -- there was just different periods they 

were trying to get rid of their license or because they 

weren't doing the work anymore. 

I believe that was the '82 survey and I guess if you 

have the answer or John Stiver?

Mr. Darnell: I couldn't hear the question, I apologize. 

Member Lockey: So, Jim, the question was there was 

a survey in '82, '85, '92, and '94 and '95. So after 

those surveys, was there any additional remediation 

done? 

Member Beach: Yes. 

Mr. Darnell: Yes, there was. 

Member Beach: From my limited knowledge on it, it 

kept getting larger and larger based on those 

surveys. 

So the '82 survey, and Mike, I guess if you had some 

more to add to that, you were there, if that's 

appropriate. 

Mr. Elliott: Good afternoon. Mike Elliott with the 

petitioners, former employees at M&C. I was there 

from '83 --

Mr. Katz: Can you pull the mic closer to you? Thanks. 

Mr. Elliott: I apologize. I worked at M&C Attleboro 

site from 1983 to 2011. 1982 as you correctly 

pointed out in your speech was the final 

characterization surveys of the HFRI, high-flux 

isotope reactor area, which was a portion, the 

northwest portion, of Building 10.
108

And that resulted and also extended into some 

surveys of the adjacent buildings as well, 3,4, and 

10. That resulted in the NRC releasing the building 

interiors for unrestricted use. 

The 1985 survey was specific to the former burial site 

between Building 11 and 12. That was conducted by 

ORISE at the request of NRC, I believe,

or DOE and that was just to try to get a sense of how 

much contamination remained in the former burial 

site, low-level nuclear burial site. So that was '85. 

'92 was also the burial site. There was both an initial 

characterization survey in '92 and then subsequently, 

there was a final clearance survey which also was 

checked by ORISE.

That was, again, just the burial site, what we knew 

at the time to be the burial site. As you correctly 

pointed out Ms. Beach, we knew then that we had not 

found the margins. The contamination extended well 

beyond the area that we excavated but we stopped 

at that time. 

And then '94 to '95 were comprehensive site 

characterization surveys with intrusive borings in 10-

meter grids going down approximately six feet at 

each location and collecting samples at depth and 

trying to put together some systematic -- there were 

both walk-over surveys of the entire site as well as 

systematic surveys, intrusive surveys, into the soils 

in which we analyzed the soil samples using the gross 

alpha screening technique. 

And I'll talk about that during my comments later.

Mr. Katz: Thank you, Mike. Other questions for Josie 

or Pete or Mike? Other questions for the Board 

Members who went before or Board Members on the 

line?

Member Ziemer: This is Ziemer. I have one 

question. I assume that there will be written 

responses, or there are already? 
109

Mr. Katz: Paul, his notes I did circulate already to 

the Board Members.

Member Ziemer: Were those the ones that were with 

the Board notice that you sent out? I guess I missed 

that one. 

Mr. Katz: Yes, Pete's notes are in one of those 

installments. 

Member Beach: I think it was the fourth installment.

Mr. Katz: David?

Member Richardson: This is just a question about 

clarity of the timing of materials. There's a White 

Paper which we received and there's the presentation 

of issues that are of concern to the Working Group. 

It doesn't seem like any of the issues presented are 

with regards to the White Paper. Is that correct? 

Member Beach: When I was writing the slides, I had 

a really difficult time because we have a matrix but 

it's very limited in nature in my opinion and we 

brought more issues to the Work Group meeting but 

we didn't really the time, like Pete said, to address 

those. 

And they did worker interviews, which I was not part 

of and said that there were certain things that were 

decided based on worker interviews, which I find to 

be flawed. 

So I'm not sure moving forward if we need to do more 

expansive worker interviews, the time limit on the 

subsurface work is one of them, the roof work. 

So, to me, it seems like it was a foregone conclusion 

that it was done before we actually had a Work Group 

meeting. So, we're trying to build from that, if that 

makes any sense. 

Dr. Neton: This is Jim Neton. I think what happened 

is when we issued that initial White Paper, the 

original ER that I presented about a year ago now I 
110

think had some flaws in it. 

We used the surface contamination values and came 

out with our traditional TIB-70 resuspension model 

and Mr. Elliot pointed out during that Meeting and 

others that we need to consider these volumetric 

issues, what we've determined to be the subsurface 

exposure model.

And after that presentation, we went back and NIOSH 

developed a subsurface exposure model which is the 

one that's posted on our website now. 

Unfortunately, the meeting that we had on May 3rd 

never really got to review that subsurface model. 

People started coming up with additional concerns 

and issues that were related to the rafters and the 

roof, and that sort of thing. 

And we're working on that piece now. That's an 

additional piece of that but I think what we need to 

do is go back and have SC&A issue a formal review 

of that first model and we recognize that there are 

some issues there, but that needs to be done and 

then we can move forward with this with Part 2. 

Mr. Katz: And just to fill in the gap then there, Jim, 

that's underway. I've spoken with SC&A and they're 

working on getting that done by mid-September so 

that we can keep everything moving forward at a 

reasonable pace.

So far, I haven't heard that's not feasible. I think 

they're aiming to get that done and out by midSeptember and then you guys can look at that and 

then we can have a Work Group meeting even to 

address that piece while we going forward with the 

other work underway. 

Member Beach: And I think it would be nice to 

actually update the matrix that captures these 

legitimate concerns in a cohesive way. It's hard to 

piecemeal out the actual issues in my opinion. So 

that would be nice if we had that done too. 
111

Dr. Neton: I think Pete indicated he has updated that 

matrix and it's at the Department of Energy for 

review right now. And as soon as it's releasable we'll 

forward it out. 

Mr. Katz: Right, and I gather it reflects some of the 

responses to that we don't have in the record right 

now. Jim?

Member Lockey: Jim, one question in the surveys 

were surveys after '82 about subsurface 

contamination potential. Any additional surveys 

inside the buildings after '82? 

Dr. Neton: Pete might know this better but, yes, 

originally, we just had survey data of the surfaces 

and it's correct that there was volumetric 

contamination of the drainpipes and such, and we 

used the data from those surveys to construct what's 

called the subsurface exposure model. 

We took a 95th percentile of the volumetric 

contamination values and used that to establish what 

the potential exposure to the maintenance and other 

workers that were doing repurposing activities and 

whatnot at the site to address their exposures. 

So we went beyond using the surface smear data and 

we used the data that was determined during these 

additional site characterization efforts. 

Member Lockey: And these surveys of the rafters 

and things like that?

Dr. Neton: That's what we're working on, that's the 

second White Paper and I don't know that we have 

surveys of the rafters. I know we're working on a 

position on that. 

We've got the HVAC system, you've got the rafters, 

you've got other materials. And that's still yet to be 

addressed. 

Member Lockey: So that's the second phase?

Dr. Neton: That's the second phase, right.
112

Mr. Katz: David? 

Member Kotelchuck: Jim, how could the borings in 

the soil tell you what was inside the drainpipes? 

Dr. Neton: Actually, I think they surveyed the pipes 

to some extent, they actually took samples out of the 

pipes and measured them. These were not borings 

samples, these were in the building. 

There's borings that were taken around the site, 

that's a different -- and we have a model for that as 

well for the general site characterization data. 

But the volumetric contamination of the pipes was 

actually assayed.

Mr. Katz: Other questions for Board Members or on 

the phone? Board Members?

Dr. Mauro: Ted, this is John Mauro. I just wanted to 

jump in and ask a question for clarification. 

I am right now working on reviewing the White Paper 

which deals with sub-surface exposures during 

maintenance and repurposing both within Building 10 

and outdoors, the very major issues that I know are 

before us. 

In doing that, I'm right in the middle of that right 

now, it's within the context that White Paper falls 

within the context of what I would call a compendium 

of material. 

What I mean by that is in addition to the White Paper, 

there were other exchanges of information that went 

back and forth, questions, answers, memos. That 

was part of, I would say, the record. 

Some of it was informal and there were certainly 

issues that emerged that go well beyond just the 

subsurface exposures. 

So my question to everyone here on the Board that 

would help me is, I could prepare what I would call a 

narrowly-defined review where I directly go to the 
113

White Paper and look at the specific subsurface 

models, assumptions, and data that we use to 

evaluate internal doses to workers that were doing 

the maintenance and repurposing activities in the 

1970s and 1980s using the available data that's 

primarily collected in the 1990s. 

Now, there are many other issues, for example, 

external exposures to the people in the subsurface 

environment doing these activities. Of course, 

you've just mentioned the rafters, an issue that was 

not addressed at all quantitatively by the team. 

So, I guess my question is, my deliverable to the 

Work Group, should I keep that very narrowly 

focused and explicitly address point by point the 

approach, methods, assumptions that are in the 

White Paper? 

Or should I more broadly present the compendium of 

material that was exchanged and the issues that are 

on the table and have been discussed and are part 

and partial to the story that's emerging before us? 

Mr. Katz: John, I think I can answer that for 

everyone because NIOSH is yet to be able to address 

the rest, for example, the rafters work. 

They have another White Paper in the works for that 

and so it really wouldn't be appropriate for you to be

digging into that until you see what they proposed. 

Dr. Mauro: I agree with that. 

I guess I was more interested in the external 

exposure to subsurface environment and some of the 

material where that has been exchanged, the number 

of papers. 

And I don't want to go into detail, that went back and 

forth and it established context within which the 

White Paper --

Mr. Katz: So, John, this is really not a great venue 

for working this out but I would suggest you do is 
114

send us a little brief email and discuss what it is, the 

questions you might have that you think perhaps go 

beyond the scope of the review you're doing right 

now so that NIOSH can have a chance to address 

whether that's already getting addressed. 

If it's not, then raising questions about those things 

is great, but if they're already addressing that, then 

there's no point you digging into matters that they're 

already going to be answering. 

Dr. Mauro: Very good, I'll take care of that. 

Mr. Katz: So, if you do that as soon as possible, I'll

get that both to the Work Group and to NIOSH and 

we can get answers and you can get extra direction 

if you need it. 

Dr. Mauro: Very good, I'll get that out right away. 

Mr. Katz: Thank you, John. Okay, I think now we're 

ready to hear from the Elliotts. I don't know which 

one of you wants to go first but however you would 

like it. 

We're glad you were able to join us for this meeting. 

We really appreciate it. 

Mr. John Elliott: Thank you for the opportunity to 

address this board. I will take less than three 

minutes of your time.

My name is John Elliot, I am one of the original people 

who filed a written affidavit in support of the petition, 

as well as having participated in the NIOSH interview 

process conducted October 2017 in Mansfield, Mass. 

I suffer from chronic myeloid leukemia, a cancer that 

is often associated with radiation exposure. I am on 

chemotherapy every single day, presumably for the 

rest of my life. Daily chemo comes not without its 

significant side effects. 

Additionally, should my medical coverage change, 

Medicare, Medicaid, and a meager stipend from 

Texas Instruments, this chemotherapy would cost 
115

me approximately $100,000 per year.

I am an unfortunate victim, an example of the 

hazards to which I and others were exposed. At no 

time was I ever warned of potential exposures. At 

no time was I ever monitored for potential exposures. 

A great wrong was committed against myself and 

others who held positions similar to mine. It is not 

overstating the fact to say you can correct this 

injustice for a limited group of people to correct the 

mistake that was made by not including us.

As for myself, I began my career at M&C TI in 1969. 

As I'm sure you are aware from my affidavit, I do 

have a copy if anyone would want a copy, I held a 

variety of positions during my 34-plus years which 

exposed me to significant amounts of radiation. 

Building 10, pipefitting; snaking out drain lines; 

repairing, replacing below-grade contaminated pipe; 

excavating the surrounding contaminated soil; 

installing services through, at, and on the roofline; 

many penetrations through the roof; blowing off dust 

on the beams and enabling us to attach hangers and 

run pipe, hang pipe; repairing running services 

through Building 10, the utility trenches; and as well 

as contaminated exterior areas surrounding Building 

10, 11, and 12.

It's amazing to think how incredibly often we actually 

did this type of work. These tasks were done with a 

very significant amount of -- a great regularity, very 

high frequency. It was demanding, it was physically 

aggressive work that always generated localized 

cloud dusts and showers of dust. 

And I can recall very vividly many times, more than 

once daily, taking a shop air gun and blowing off the 

dust off of ourselves just to kind of do a quick 

cleanup.

You only have to review my affidavit, once again, to 

take greater note of the many exposures to which I 

and others were subjected. With no warning, no 

monitoring, no controls, no respirators, very little 
116

PPE. I thank you for your review, your careful review 

of this matter.

Mr. Katz: Thank you, Mr. Elliott. Mike.

Mr. Michael Elliott: Thank you again, and good 

afternoon to Members of the Board, and really 

appreciate you coming out here to Providence to give 

us a chance to meet you in person. Much better than 

chatting over the phone.

One thing I wanted to address, the gentleman down 

here, it might have been you, sir, yeah, asked a 

question about why we did the or how we had the 

measurements on the contamination in the Building 

10 drains and duct. And he was absolutely correct. 

There were actual samples collected. 

I think there were approximately 15 samples 

collected from the drain. So that they ran, first of all 

they did some type of, you know, instrument was run 

through the lines where they could get through the 

lines. Some of the lines were completely blocked. 

And they took beta/gamma measurements.

And then in the area where there were some higher 

concentrations, they collected actual samples of the 

sediment. Also, there were some samples of the 

surrounding soils around some of the lines that we 

ended up digging up. 

So the reason why we did that survey, it was, I 

believe it was August 1995 when we did that 

sampling of the drain lines, was because, you know, 

we had gone back into the interior areas, we found 

there was still elevated contamination in areas that 

had been released for unrestricted use. 

And so we started doing some pilot remediation and 

finding that as we went down, as we dropped our 

meters down the drain holes, the concentrations 

were going up. Well, first we thought it might be just 

geometry or something. But lo and behold, it was a 

real mother lode of highly enriched uranium.
117

At that point, Westin was on board as our primary 

health physics group, and they really got very 

anxious and were concerned that if we started 

disturbing this stuff during our remediation, we could 

cause materials to accumulate as sufficient quantities 

in the presence of water in certain geometries, that 

we might actually cause a criticality event.

So the reason why we did that survey was to, 

primarily to eliminate the possibility that we were 

going to cause a criticality event. So we only did 

isotopic measurements for uranium, thinking, you 

know, I guess that was -- I'm not a health physicist, 

I need to make that clear. 

But my understanding was the health physicists were 

only concerned about uranium at that point because 

they were, they wanted to make sure that it was not 

fissile material that might result in a criticality event. 

We did not do isotopic, in retrospect I regret this, but 

we did not do isotopic sampling for, or analysis for 

thorium.

And that would be one of my questions to NIOSH, is 

how, you know, I can understand in places where we 

have gross alpha screening measurements, they 

might do their magic with their dose assessment 

modeling. But how do you do that in the drains, for 

example, where we only have isotopic uranium 

concentrations? We do not know how much thorium 

was present. 

And those were by far the highest uranium 

concentrations we encountered anywhere on site 

were in those drains. Same drains that John Elliott 

described in his affidavit that he was snaking out and 

in some cases excavating. 

And I think one of the reasons for the confusion 

during the worker interviews was when we were 

asked, you know, how much time did we spend doing 

that kind of work. I think most of the workers were 

thinking, well, how much time do we actually spend 

cutting open the floor and excavating out pieces of 

drain line or excavating out conduit, not thinking 
118

that, really, their exposures were occurring during 

these non-intrusive events as well. Like John would 

get called on numerous occasions to clean out a drain 

line.

So you know, I think that the work interviews, you 

know, I really, I do not want to in any way suggest 

that they weren't done thoroughly. And I have the 

greatest respect for Peter Darnell, for Pat McCloskey, 

for Dr. Mauro, and the young woman whose name 

eludes me at the moment but was there with Dr. 

Mauro. They did a great job.

But you know, sometimes hindsight is 20/20, and I 

don't think we necessarily understood all the 

questions exactly the way that they were going to be 

used later on. So if it's okay, I will dive into my 

prepared comments.

I'd like to commend Dr. Mauro and his team at SC&A 

for their honest assessment at the May third Work 

Group meeting that this Petition Evaluation is 

complicated by unusual circumstances. And it's a 

stretch to say the bounding dose of this Class of 

employees can be estimated in a scientifically sound 

and claimant favorable manner.

I'm somewhat paraphrasing what I believe I heard 

Dr. Mauro say. The Chair of the M&C Work Group, 

Ms. Josie Beach, has done a great job listing many of 

the uncertainties and questions that remain. 

One additional technical consideration worthy of note 

that I would like to bring to your attention today 

concerns the gross alpha screening technique that we 

relied on extensively for the 1994 and '95 systematic 

characterization surveys, and which SC&A has used 

in developing their estimate of the bounding dose.

This novel method, in 1994, was tailored to our 

decommissioning project by our health physicist at 

the time, CPS, in that timeframe, circa 1994, to 

quickly and cost-effectively screen soils to determine 

if they were above or below the cleanup criteria of 30 

picocuries per gram.
119

The correlation curve that was based on a dozen or 

so samples that ranged in concentration from a low 

of ten picocuries per gram to a high of a couple 

hundred picocuries per gram was what they used to 

establish to the NRC that that method was adequate 

for our purposes in determining whether or not we 

had met our cleanup criteria.

Even in that narrow range, we found that the 

screening results for samples below 30 picocuries per 

gram were biased high. So we were actually 

probably excavating and disposing of more material 

than we needed to. And the results for samples 

above 30 picocuries per gram were biased low.

But that didn't really bother us, because we knew we 

were going to be digging that stuff up anyway. This 

is probably due to the fact that the sample prep was 

not ideal within this screening method. A bulk 

sample was dried, sieved, and deposited on a petri 

dish at a certain thickness, you know, before being 

placed over an alpha detector instrument. 

There was no attempt to plate out an infinitesimally 

thin layer of homogenous sample on a slide, as I 

understand is the preferred method for alpha 

spectroscopy. This likely resulted in significantly high 

internal shielding by surrounding soil grains, causing 

the low bias at the higher concentrations.

And who is to say how much bias there might have 

been at the higher activity concentrations, such as 

what we encountered in the building interior 

subsurface soils samples or elsewhere.

The gross alpha screening technique was designed 

primarily to help us determine the limits of 

excavation, not to accurately characterize the sitespecific conditions of the source term. I would posit 

that it is inappropriate to use this data as the basis 

of modeling doses to employees who were exposed 

to this source term.

The one area where we did perform isotopic uranium 

analysis, the Building 10 floor drains, exhibited the 
120

highest concentrations observed anywhere across 

the site. Lacking any isotopic thorium analysis, which 

we now know was likely also present, who knows 

what we might have found for a source term in that 

location?

This begs the question that had we used a more 

accurate isotopic analytical method, rather than the 

gross alpha screening technique for the systematic 

characterization surveys, what impact might that 

have had on the source term characterizations?

My point is that no matter where you turn in this 

evaluation, there is no end to the uncertainty. And 

by extension, I believe we can have no confidence in 

the model. There is no reliable source term 

characterization on which to base the bounding dose 

to this group of workers.

Against the backdrop of all this uncertainty, here's 

what we know for certain. Workers in this Class came 

in intimate contact with sources of radioactive 

materials originating during the atomic weapons 

period that were released in an uncontrolled manner 

into subsurface drains, subsurface soils, utility 

trenches, exterior soils where waste was managed, 

and overhead areas of the building interiors, onto the 

roofs of the buildings that housed the nuclear 

operations, and into the pockets and recesses of 

certain pieces of manufacturing equipment.

The residual contamination went undetected, 

unmonitored, and uncontrolled for over 20 years. 

Recall that we excavated close to 600,000 cubic feet 

post-1992 of contaminated soil and debris during 

that 1992-96 decommissioning project.

As we have heard in the affidavits supporting this 

petition, like my colleague John Elliott, in worker 

interviews last October, and again today during the 

public comment period, and I believe you'll be 

hearing from my colleague Daryl Hanlin later, the 

work performed by facilities constructions services 

and equipment R&M maintenance workers involved 

physically aggressive work practices that most 
121

certainly disturbed the radioactive sources and 

resulted in localized dust clouds of contaminated 

material.

By nature, these maintenance work practices were 

non-routine, and by that I'm not talking about the 

frequency. I'm saying in terms of the physical 

activities were non-routine. It was completely unlike 

the routine work practices that would be performed 

by trained radiation workers in the controlled 

manufacturing areas where personnel exposure 

measurements had historically been performed.

There is no comparison between these two Classes of 

workers. By extension, any historical exposure 

monitoring of workers in the nuclear manufacturing 

areas is not comparable to that which was later 

experienced by the members of this Class under 

evaluation.

The workers in this Class received no awareness 

training about the hazards to which they were 

exposed. They received no monitoring of their 

exposures, and there were no administrative or 

engineering controls in place to limit their exposures. 

Since there were no measurements or controls and 

the work was by its very nature non-routine, 

remember I said that's the physical activities, not the 

frequency, we have no way to estimate the 

resuspension factor for the materials disturbed in the 

course of performing their work tasks. 

Recall that the resuspension factor is one of the 

essential elements of the model that NIOSH and 

SC&A have relied upon for estimating internal dose 

in the subsurfaces, which I presume is the topic of 

that White Paper that I just saw for the first time 

today.

In reference to the regulatory requirement of how 

NIOSH is to evaluate a petition for adding a Class of 

employees to be recognized under the SEC, as 

articulated at 42 CFR 83.13, paragraphs (c)(3), and 

I quote, If it is not feasible to estimate with sufficient 
122

accuracy radiation doses from members of the Class, 

as provided under paragraph (c)(1) of this section, 

and as I'm sure you know, paragraph (c)(1) requires 

access to sufficient information to estimate the 

maximum radiation dose that could have been 

incurred by any member of the Class, then NIOSH 

must determine, as required by statute, emphasis 

added, that there is a reasonable likelihood that such 

radiation dose may have endangered the health of 

the members of the Class.

When I read this regulatory citation and I reflect on 

all the uncertainties and gaps in the information used 

to estimate the bounding dose for this Class of 

workers, lack of adequate source term 

characterization, incomplete knowledge of the 

nature, frequency, and duration of jobs performed in 

intimate contact with the source terms, a complete 

absence of any measurement or monitoring of the 

workers who are the subject of this petition, it seems 

clear to me that this is a scenario in which NIOSH 

must determine, as required by statute, that this 

Class of employees should be added as a new Class 

recognized under the Special Exposure Cohort.

In light of these realities, I can only hope that the 

Advisory Board will exercise its duty to pass along its 

recommendation to the Secretary of Health and 

Human Services to designate this Class as an 

addition to the SEC.

Thank you again for the opportunity to testify before 

the Board today.

Public Comment

Mr. Katz: Thank you, Mike. Board Members, do you 

have questions for Mike while we have him? Or on 

the line? Okay, then. Thank you very much, Mr. 

Elliott.

I think what we'll do now is go into the public 

comment session. Before I do that, let me just make 

a few administrative notes for people so they 

understand how this operates. 
123

First of all, if you're in the room right now, we don't 

have enough people in the room that we really need 

you to go out and sign up if you haven't already 

signed up. But Nancy, could you get the signup sheet 

so that I have that.

So for your public comments, just understand this, 

and then we'll take people on the phone after we've 

addressed everyone who's in the room. So people on 

the phone, and we'll start with people on the phone 

who want to address Metals and Controls, in case 

there are any of those on the phone, and then we'll 

go on to other topics as we have time.

These Board meetings are all transcribed verbatim, 

so that everything you say is captured and published. 

And I just, you need to understand the exception to 

that is that if you discuss other individuals than 

yourself, their privacy we'll protect. So, because 

they're not here to tell us that they are okay with you 

talking about them. Even if they're family members, 

it doesn't matter.

So just understand that we'll redact enough 

information to protect their privacy. It's not that you 

can't discuss other individuals, it's just that we'll 

redact enough information so that their privacy's 

protected in the record that's published for this. And 

these, the transcripts for these meetings are all 

published on the NIOSH website for everybody to 

read.

So understanding that, then let's go to public 

comments. And then I'll start with public comments 

in the room. Let me just see. So, sir, Daryl, did you 

sign? Oh, yeah, you're already actually on here, so 

you can go first, yeah. Please identify yourself on the 

front end of your comments.

Mr. Hanlin: My name is Daryl Hanlin. I worked at 

Texas Instruments, the M&C plant, in Attleboro from 

1975 until about 2002. I worked in the Facilities 

Group with Mike and John Elliott, in fact, I worked for 

John Elliott. And I had dual purpose also. I'm an 

electrician but I also, John asked me to develop a 
124

safety program within the facilities organization so 

that we could handle things safely.

I would like to reiterate what John what John said, is 

that we were never, ever told about anything about 

radioactivity. Anything that we did, it was never any 

monitoring ever whatsoever. 

When I first started, I'll tell you a brief story. I can 

laugh at it now, but I can tell you this. In 1977, I 

was hired into Building 10, and I was sent to go look 

for a wooden pallet. And so, as I'm going along the 

loading dock, not even realizing where the 

radioactive stuff was, and I walked along the loading. 

And there's this big door open and I see a pallet, and 

I walk into there. And I'm heading over to the pallet, 

and the next thing I know I have a shotgun aimed at 

me and telling me hold my hands up.

I'm like holding my hands up, and then I had a bunch 

of individuals coming in the doorway that I came in 

with every jacket, every law enforcement thing. And 

they had guns on me. And I'm like, what did I do. 

So I don't know why that 1977, when it was all 

cleared up. But you know, I lived that, and they let 

me take the skid, so that's a little story for you.

So yes, I would like to reiterate and go through some 

of the things that, operations that we did. Now, I 

also was doing our facility safety. I was a training 

facilitator, so I wrote and established procedures and 

we tried our best to work with the OSHA regulations 

and incorporate them into our training. We did 

heavily train them, but we never had anything for 

radiation.

But for myself, I'll digress a little bit. I can remember 

having to, well, we had a flagpole out in Building 12, 

and I was tasked, my job was to bring power out to 

the flagpole and set up some lights. So I went from 

in the boiler room in Building 12, and then I handdug the trench, which I only found out this weekend 

that Mike told me that that was the main burial site.
125

So I hand-dug that trench and I laid all the pipes. 

And it took me several days to go from the boiler 

room to get outside. It was a lot of work. I was in 

the soil, I'm covered in it. I now realize I brought 

that home to my kids and it went into the laundry 

and everything else. 

And you know, I can't even say I washed my hands. 

I might have sat out, because I was so dirty, I don't 

think I went in, I just ate outside. So I don't think I 

washed my hands. Now, I'm just thinking it was dirt, 

not a problem. Hindsight now, it worries me.

I do have two heart conditions. I have a pacemaker 

and I had to A fib, which I had a procedure done on, 

but it may come back. I also now have a problem 

with my adrenal glands, and I'm working with my 

doctors on that. So I'm hoping it's not going to get 

any more serious, but the exposures were there.

So yes, hired into Building 10, worked all around the 

site. Yes, we were one of those, myself included. I 

made penetrations through the rooftop in Building 

10. We ran pipes from one location to another. Also, 

I don't think anyone mentioned that, they talked 

about the trestles and everything else. 

But you know, there were electrical bus duct that was 

run throughout this whole plant. And you know, so 

it'd be yea high and about yea wide, and it had, you 

know, electrical bus bar. You'd slide a little window 

and you'd put these big switches on, the bus switch 

on there. And then you'd just plug them in and, you 

know, you run your pipe from there.

Well, those bus ducts were loaded with dust. We 

were frequently putting stuff on top of them, or if you 

had to go take an old switch out, you kind of like just 

blow it off with your face, you know, just push it away 

with your fingers and your hands. 

You know, we didn't wear dust masks. For one, it 

was too hot. And so you'd just try to hold your breath 

and work as you may. But you'd get constantly 

covered with dirt, dust. Well, now we know it's, 
126

there's radioactive particles included in there, which 

is a concern. 

But this is stuff we did on a daily basis all the time, 

where we had lifts, we had our own lifts and then we 

rented lifts as well. So we had Genie booms and 

bucket lifts, and that's the kind of work we did. So 

we're always up in the ceiling, we're always creating 

dust, very aggressive. 

I mean, you'd have some two-inch or four-inch pipe. 

You'd either have to cut out and pull it down, you're 

creating all kinds of dust, you're pulling these things 

out on the floor. We'd have to pull wires through the 

floor as well, take all the old stuff and trench in the 

floors in different places all over the site, including 

outside.

Like I remember, again, back in, we did some 

trenching on that same main burial site on Building 

12, that flag location I was talking about, flagpole 

location. So there was numerous of us there.

Now, you may have had, and I will read, you may 

have had some testimony previous. This is first time 

of testifying. But we ran, when we had a brand new 

credit union built, we ran power and security lines, 

data lines and everything else through all the 

buildings, from Building 1, which was the furthest 

most point, into Building 12, through Building 10, 

through Building 4, all the way down to the outer 

portion of the site which had the new credit union 

that was built.

And so we had manholes that it went into, and we 

would pump out the water all the time. And we'd get 

down into the pits. We'd get covered in water all the 

time, you know. You'd be putting a vacuum on there 

to get it started and just, you know, stuff happens. 

And when you pull the wires, it creates a vacuum 

thrust anyways, and more water comes into the 

manhole while you're trying to work.

So we're constantly getting dirty and wet and trying 

to do our jobs. And there was numerous manholes. 
127

What we did was just pump out the water onto the 

topsoil or grass or whatever was, you know, we just 

had to get it away from us.

And so those are just some of the tasks. And I forget 

how long it took us to do that, but it was quite a 

challenge to go through every building, cable trays, 

some pipe work and installing pipework and digging 

up the floor. Opening some, they had some trenches 

in the floor that had removable covers and stuff as 

well.

So, and that was another thing now. We, putting 

power, we made capacity for the plant to do different. 

We were always moving around because it was 

different products that were always coming on line. 

And we made capacity for those. Hence, we had to 

cut old stuff out and put new stuff in.

But some of the other things for power, we'd find a 

height, a ceiling height and put in cable trays. While 

we're trying to clamp the cable trays to support them, 

we constantly had dust. It was a constant thing, so 

you're rubbing up against everything. You'd cut into 

a wall so you could pass through from one building, 

like Building 4 into Building 10. And those are the 

kind of things.

Now, otherwise, we tried to use existing cable trays 

that are up there. Again, loaded with dust.

One of the projects I had in Building 10, and there 

were several of us working on it, and it took months 

to do this, but we had old, old, old fluorescent lighting 

and some metal arc lighting. It's kind of something 

you used to see in parking lots, but.

Well, they had layers upon layers of dust on them. 

So what we did first is we tried to install a track 

lighting, a large track lighting system. And then 

afterwards, we went down and we cut down all of the 

fixtures. And I'm telling you, they had sometimes 

three to four inches worth of dust caked up on top of 

them. That was in Building 10.
128

Now, we had no idea that this was contaminated in 

any way, shape, or form. Now, it was a dust storm 

when we did that. It was literally everywhere. John 

mentioned about, you know, shop air, and that's 

true. 

We used to, we'd get so, we'd just use the shop air 

and blow our clothes off. But sometimes you'd do 

like spurts of it just to get it collected on the floor, 

and then you'd sweep. And it's always a plume.

And so you never could do a cleanup. We wouldn't 

release that. I realize now we actually should have 

been treated kind of like an asbestos removal. We 

would capsulate and then remove, that would have 

been a better program. But we weren't aware of 

that.

So I can emphasize, again, that, you know, it was a 

lot trench work. For instance, so I did a lot of training 

for all the facilities groups. But I can only train for 

what we were aware of. So even the grounds crew. 

So you know, they'd go out and they'd dig the soil up 

and plant trees and stuff like that. 

And you know, they're mowing the lawn. Well, that, 

all the contaminated area, the lawn mower sucks up 

dust and blows it out while they're cutting, right. So 

that's some of the things they had exposures to that 

as well. I don't know how you calculate, but these 

are some of the work processes and some of the work 

being done.

And so I think I had a couple other things I wanted 

to say, but -- oh. There's one that really bothers me, 

and it's Defense-related work. And it took place in 

Building 1. That's not, I don't think, under the scope 

of what you're talking about here. But again, we had 

never any signs saying radioactive material, don't 

dig, don't do that. There was no warning or anything 

else.

But in Building 1, we had a freight area, a freight 

elevator area from, which almost joined into Building 

2. And then it went down an aisle and it kind of went 
129

left for a production line. Well, I was involved with 

the first remodeling of that, and they had a nice tile 

floor and you would drill through it. 

Put a quarter inch bit down through the floor, run 

some wire or something down there, and you'd go 

downstairs to try to find it. To see if it's okay, you 

know, if you had an obstacles in the way you could 

run your pipe. And that's how we ran it.

And then of course then we didn't have long enough 

drill bits. So we would drill halfway down through the 

floor, and then we'd go in the bottom of the floor, get 

up on ladders and drill the other halfway up. 

I can't remember, Michael would have to refresh 

memory what that particular radioactive material is. 

Radium-226? Yeah, radium-226. Well, those were 

releases not only to use and myself while it was 

drilling, not knowing, I just thought it was wood dust, 

right. But it has some, you know, residual radium226.

But that was released in everybody's breathing 

atmosphere. And for, you know, all the workers that 

were involved in that. And it wasn't until the second 

kind of remodeling that I was ironically I started off 

saying about the elevator, that the first and only time 

I realized that there was a problem with that, and I 

had done, I had worked on that for almost a year 

doing that. 

One of my coworkers who worked in the Safety 

Department, Dean Chapman, I know you're not going 

to mention names, but Dean Chapman come over 

and said, hey, what are you doing. You got to stop 

right now. I'm like what are you talking about, I'm 

just drilling a hole through the floor. I got to, you 

know, move some equipment. And he says, you can't 

do that. He explained that was a radioactive 

problem.

So I put down the tools and everything, and he was 

kind enough to bring me to his office, and he had a 

map of the location on the floors where all the, it had 
130

all the contamination. 

So again, there was signs on the walls that said, hey, 

don't drill through this floor. And I guess their way 

of encapsulating it was to just put tiles down and not 

disturb it again. But there was no training to say 

don't disturb this and don't cut it.

So it's kind of like that with the whole site. But I'm 

just saying, this is a daily basis. We're very 

aggressive, I mean even the duct work. The large 

pieces and small pieces of duct work. Now, they 

might cut into a piece of duct work on the side and 

extend it off to go to another area, or they might take 

big sections out altogether.

Now, that might involve taking a Sawzall and it 

vibrates and it shakes like crazy. Well, you know, a 

couple of sledgehammers. You had to pound it and 

break it down. So these kinds of things always dust 

released, and it's the kind of work that we're just 

used to doing and not realizing what we had.

That's all I have to say for now unless you have any 

questions.

Mr. Katz: Thank you very much. Do we, and do we 

have your contact information? Oh, you've got it, 

okay.

Mr. Hanlin: Yes, I also left, not that I'm looking for a 

job. I left my resume at the desk.

Mr. Katz: Perfect. No, that's very -- you obviously 

know a lot, and that's why I was asking. Thank you. 

So next let's see. So I don't have anyone listed in 

the room from this site, other than who we've already 

heard from. Is there anyone else in the room? I 

don't believe so.

How about on the phone? Is there anyone from Metal 

and Controls on the phone who wants to give 

comments? Okay, not hearing any. Then let's go to 

folks in the room first who have comments for today. 

So first on my list Delaney, Ms. Delaney Blaze. 
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Welcome.

Ms. Blaze: I'm Delaney Blaze of CORE Advocacy. I'm 

also the petitioner of SECs 235 at Santa Susana and 

246 at the DeSoto facility.

Today I'm going to talk about the Boeing Company's 

fulfillment of requests for employment records for 

workers of Santa Susana, Canoga, and DeSoto. I 

think the Board needs an update on this situation, it 

seems to be playing out like a soap opera at these 

sites.

Workers are currently unable to obtain timely, 

accurate, or complete eligibility verification or 

employment records from Boeing. This results in 

incomplete dose reconstructions because the dates of 

covered employment are routinely misreported to 

NIOSH.

I represent several workers, some of whom qualify 

for the SEC. And yet 120 days have passed without 

any response from DOE or Boeing for employment 

verification or records. Just days before these claims 

were due to be denied because the workers could not 

establish any eligible employment, go figure, the 

Boeing Company provided a handful of records for 

each worker.

These records were consistently absent of work 

locations or radiation data for workers who clearly 

should have such documentation. Workers whose 

employment in a covered area spanned upwards of 

30 years.

So the Boeing Company states its employment 

databases are extensive, that they date back to the 

1940s. And prior to 2014, this statement was 

consistent with timely records responses that 

typically contained abundant records. It was not 

uncommon to receive up to a thousand pages of 

unique documents in response to a standard records 

request.

Then DOE stated in 2004 that Boeing's employment 
132

records are, quote, So accurate and complete, they 

cover an employee's entire work life. This was DOE's 

assertion when it tried to convince the Department of 

Labor that only a handful of select Santa Susana 

workers were actually eligible for EEOICPA at all. And 

that all responsibility for determining the eligibility of 

the workers really should be at the sole discretion of 

Boeing.

That letter from DOE that made that claim was 

obtained under the FOIA, and I can provide it upon 

request.

Recently, a 45-year Santa Susana hot lab and DeSoto 

powder room employee provided me with copies of 

his radiation records, which he had meticulously 

collected while he was employed. This gave us an 

opportunity to compare his actual records to a typical 

Boeing records response, which we eventually 

received about 120 days after he filed the claim.

The Boeing Company supplied the records less than 

24 hours after I provided some of the employee's 

radiation data as evidence of covered employment. 

This employee provided his quarterly external 

occupational exposure records showing he was 

consistently monitored at various locations at Santa 

Susana and the DeSoto facility.

He also supplied complete bioassay evaluation data, 

whole body and in vivo counting data, a site HP's 

letter stating that Rockwell never reported whole 

body or in vivo results for workers at Santa Susana 

or DeSoto. And a letter from the site physician 

stating that this employee had been among the most 

exposed of any workers included in the Rocketdyne 

worker health study.

In addition, the employee provided some incident 

reports. So obviously, we expected all these records 

and then some to be provided by Boeing in response 

to the Department of Energy's records request. 

But none of these items were included in Boeing's 

response, with the exception of a single, two-page 
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quarterly external radiation record that was missing 

several years of exposure, and that under-reported 

the number of whole body and bioassay evaluations 

when compared to the employee's copy of the same 

document.

No bioassay data, no whole body or in vivo counting 

data, no HP letter, no physician's letter. And at first 

glance, this response to be comprehensive. It totaled 

close to 800 pages. But on closer review, it was 

revealed the Boeing has supplied the same records 

repeatedly, conspicuously lacking references to 

locations and radiation data.

It was a duplicitous document with a falsely inflated 

page count that made it appear much more detailed 

than it actually was. This is not the only records 

response that we've received in such a condition.

In addition, the incident reports that Boeing provided 

were incomplete. Several additional incident reports 

that involved this employee were easily retrieved 

from the Boeing incident report database. Yet Boeing 

redacted this worker's name and his exposures from 

each incident report, along with the names of 

managers and supervisors that were involved in the 

incident, in violation of its contractual and legislative 

requirements under the Act.

The Boeing incident report database revealed the 

Boeing had also extracted portions of the incident 

reports that it had provided by selectively removing 

the diagrams that showed where the employee had 

been standing during the event, and first-person 

written accounts of the incident that were offered by 

the worker.

Comparison of the unredacted incident reports to the 

employee's bioassay data showed discrepancies, 

where bioassay evaluations had occurred, excuse 

me, for which no incident reports had been provided. 

Or incident reports indicated a need for bioassay, but 

the bioassay records did not reflect a corresponding 

analysis.
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We were able to provide the unredacted incident 

reports to the Department of Energy for review. They 

were retrieved from the Boeing incident report 

database obtained under the FOIA. 

To date, according to Department of Energy, the 

Boeing Company is still refusing to provide 

unredacted clean copies of those incident reports, 

and currently DOE states its attorneys are locked in 

impasse with Boeing's legal department on this issue 

for Santa Susana and DeSoto workers.

Why now, almost 20 years after this program's 

enactment? Let's pretend that this worker, like the 

majority of workers out there, had no access to his 

own records to fulfill the burden of proof, and he is 

not represented by an advocate or anyone familiar 

with site history. He just hopes that the contractor 

and the agencies are going to do what they're 

supposed to do to ensure that he gets a fair 

evaluation.

How might this situation have turned out for him? In 

2014, several irregularities and inaccuracies in 

Boeing's employment verification responses were 

verified. They're systemic. It was discovered that 

since 2005, the company has consistently supplied 

employment verification sheets that actively 

misrepresent the eligible workers as employees who 

do not qualify for the program. 

So years or decades of easily verifiable covered 

employment, if we actually evaluate worker records 

instead of taking Boeing's word for it, are 

systematically disqualified. Some are shuffled into 

dose reconstruction based on a dramatically 

diminished perception of covered employment and 

exposure.

Now, since we discovered this problem, the quality of 

records responses has declined. Essentially, while 

Boeing has been permitted to continue providing the 

misleading and inaccurate information, which even 

Boeing states should never be used to establish 

eligibility because it's so unreliable, official 
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employment records that can be used to verify the 

eligibility have begun to disappear.

This suggests that efforts to actually fix this problem 

have not been pursued. But efforts to make the 

problem harder to discover have been actively 

implemented.

There are two other issues to quickly address. 

Boeing Company has not identified site remediation 

subcontractors. Current site remediation workers 

under subcontract to Boeing are automatically 

disqualified from EEOICPA. 

Some are legacy workers who transferred to 

subcontract status with no change in job duties or 

work locations, other than their radiation programs 

were discontinued and they are no longer monitored 

for radiation exposure.

When I asked Department of Energy about this, they 

took the issue to Boeing. According to DOE, Boeing 

was shocked. They had no idea who that 

subcontractor was, or what the subcontractor might

be doing on site, until I supplied DOE with photos of 

the workers at the Area 4 Radioactive Materials 

Handling Facility, wearing Boeing-issued site 

remediation clothing and gear, wearing work badges 

identifying Boeing as the primary contractor and the 

subcontract employer.

This apparently inspired Boeing's powers of 

recollections, and DOE stated that Boeing was able to 

verify subcontractor presence at the site. 

But DOE said since Boeing is no longer under contract 

to perform site remediation, these workers, 

employed by the second largest site remediation 

subcontractor and hazardous waste transport 

company in the country must be there for some other 

purpose. The workers are not considered to be 

eligible for EEOICPA.

I've since obtained several documents authored by 

Boeing that verify site remediation services at Area 4 
136

by the subcontractor and about eight other 

subcontractors. I'm working on a report to address 

the issue to ensure that the additions to the 

databases for subcontractors are made so that we 

can cover these workers. 

But this is getting ridiculous. And why aren't these 

workers monitored for radiation at locations where 

they were once required to wear radiation protection?

Lastly, the Board should be aware that [identifying 

information redacted] and Rocketdyne took over 

from Boeing in 2005. They qualify as a corporate 

successor. Workers never changed job duties or 

work locations after this merger. It was reasonable 

to assume that their personnel records were simply 

transferred to the new employer.

Although Boeing has informed Department of Energy 

that employment records for these workers should be 

obtained from [identifying information 

redacted] and Rocketdyne, DOE has not included 

[identifying information redacted]Rocketdyne 

in its records requests. 

Boeing states these workers retired in 2005, but 

evidence consistently shows their employment 

continued for [identifying information 

redacted]Rocketdyne, a corporate successor, for 

years. Records for these guys could verify legacy 

work locations and establish eligibility during site 

remediation. According to Greg Lewis, the issue is 

being investigated.

So there's the update. Workers affiliated with Santa 

Susana and its related sites are having serious 

problems getting verification and records. Their dose 

reconstructions are incomplete, their evaluations are 

not based on complete information, and we have 

compelling evidence to suggest orchestrated 

obstruction by the contractor.

These issues provide a basis for SECs at Santa 

Susana and DeSoto. Every claimant is deserving of 
137

a fair evaluation based on accurate complete records 

under EEOICPA, and it is our job to ensure that they 

get it, or that they have access to an SEC 

appropriately. It's a privileged to address the Board. 

Thank you.

Mr. Katz: Thank you, Delaney. Next on the list I 

have Terrie Barrie.

Ms. Barrie: Good evening, Members of the Board, 

and thank you for allowing the opportunity to address 

you. My prepared public comments have been 

changed a little bit. I had a couple of conversations 

this morning that clarified some of the issues here. 

So this might sound scattered, but I'll try my best to 

it.

First of all, I want to thank all of you for serving on 

this Board. It's not until, you know, someone leaves 

that we realize how important your work is to us, and 

we thank you for your continued service.

I was pleased to see that the Work Group for the 

Metals and Control had a concern about consistency. 

This is very important. As you know, the ten-year 

review recommended that all decisions be as 

consistent as possible, whether it's dose 

reconstruction or how a SEC petition is decided.

I have heard complaints, I always hear complaints, 

about the Hanford and SRS SEC petitions. Those are 

in limbo. The reason is that NIOSH keeps finding new 

information, new documents. That's great, okay. 

But these guys have been, they're waiting -- let me 

see, claimants at Hanford for the contractor worker 

have waited over six years for a decision or a final 

recommendation. SRS is into their second decade.

There has to come a time when enough is enough. 

And when it comes to consistency, that was not given 

to the Rocky Flats workers. You may remember that 

thousands of boxes were uncovered by NIOSH at Los 

Alamos. And NIOSH did review, you know, a certain 

portion of those record. But there are so many 

thousands of other documents that could be reviewed 
138

that might hold that smoking gun. Not necessarily 

for magnesium thorium. 

There was a copy, I have a copy of the indices that 

NNSA gave me, or through a FOIA request. And 

although some of my wish list coincides or agrees 

with what NIOSH pulled, there's a couple of others 

on there that I couldn't link up with NIOSH's indices. 

For instance, there was a box, I imagine it's a box, 

it's unclear from the FOIA request, of neptunium 

analysis from 1987.

If you remember, I believe in 1985 was when the 

production for neptunium ended at Rocky Flats. So 

I'm kind of curious, you know, what's in that box? Is 

it analysis from 1985 back, or is it something from 

1987, where it shouldn't have been?

So that's something that NIOSH and the Board and 

the Work Group really should take a look at. I gave 

NIOSH my wish list and they're going to, LaVon said 

that he did remember the neptunium. And he 

believes that he requested that from NNSA, but he's 

not sure of what the resolution of that was.

The other part of consistency that I'd like to draw 

your attention to is the Board voted to expand 

Sandia's Class, and that's great. They deserve it, you 

know, NIOSH agreed that they don't have enough 

documentation for all, to reconstruct dose for 

radionuclides. 

Now, I'm not sure if this is an SEC issue for Rocky 

Flats, or if it's a Site Profile issue. But there's a 

number of exotics that I don't believe NIOSH has 

come up with a methodology to reconstruct dose. 

For instance, californium, there was, you know, 

documentation of californium present there. Cobalt60, of course. And then from these boxes down, 

there's thorium and halfnium and erbium, there's a 

box on that. And something about the Tokamak 

fusion core experiment. 

It's unclear, it's in the Rocky Flats documents, but 
139

how much involvement did Rocky Flats have? Were 

they part of that experiment? Were they just on the 

distribution list for that document? It's unclear, but 

something that needs to be, I would ask that the 

Board take a look at it.

And from my other conversation this morning, there's 

a number of Site Profile issues that are outstanding, 

but because of the SEC petition, that was kind of put 

on the back burner. So maybe we can take a look at 

that again to make sure that the dose reconstruction 

is accurate and consistent.

I think that's about it. Although I do want to make a 

sincere thanks to Stu Hinnefeld for incorporating the 

suggestion for putting the citations that you use 

online for the public. I forgot that we asked for that, 

so I'm glad you didn't. So thank you very much.

Mr. Hinnefeld: We're counting on you remembering.

Mr. Katz: Thank you, Terrie. Okay, I don't have any 

others listed, but let's go to people on the line. Again, 

let's start with if there's someone from Metals and 

Controls on the line. Okay, I don't hear any.

Mr. Grimes: Kurt Grimes.

Mr. Katz: Hello?

Mr. Grimes: Kurt Grimes with the Security Police 

Association, Sandia National Laboratories.

Mr. Katz: Okay, so that's not Metals and Controls, 

but that's fine. I didn't hear anybody from Metals 

and Controls. Can you just say your name a little 

more clearly? It was hard to make out.

Mr. Grimes: Kurt Grimes.

Mr. Katz: Kurt Grimes, thank you. Okay, Sandia. 

Go right ahead.

Mr. Grimes: Yes, I'm the President of the Security 

Police Association, and I know, thank you for the twoyear addendum that was added. And also in addition 
140

to that, I know you're still looking from 1997 forward,

I believe through 2011. And I believe you're also 

looking at, now you're looking at a lot more data in 

regards to air samples.

So the question I have, I think what you're looking 

at, correct me if I'm wrong, but the question you're 

looking at is whether or not air samples are actually 

going to be sufficient enough, that there was enough 

air sampling done that internal dosage 

measurements would not have to have been 

accomplished or performed here at the labs.

So the question I would have is if there was any, that 

you could take a look at this while you're doing your 

review, is if there are any incidences to where air 

sampling actually prompted internal dose 

measurements to be performed.

Mr. Katz: Thank you. I'm sure that's not something 

someone can answer on the fly.

Mr. Grimes: No, that, I know that the investigation 

is ongoing, and I would like to submit that to the 

Board for them to have NIOSH to look at that.

If there were incidences where the air sampling 

actually prompted internal dose measurements to be 

performed here at site.

Mr. Katz: Yes, and I'm seeing head nods from the 

people in the program. So they will look at that.

Mr. Grimes: Okay, thank you.

Mr. Katz: You're welcome, thank you. Okay, other 

members of the public on the phone.

Ms. Hand: This is Donna Hand.

Mr. Katz: Welcome.

Ms. Hand: Okay, I'd just like to again thank the 

Board Members for all they've done and have been 

doing. But my main concern now is that, as I 

mentioned before in the last hearing, everything is 
141

not consistent. The SEC petition for Pinellas with the 

metal tritides and everything says it didn't even 

qualify. 

But yet here you've got Sandia, who took over the 

neutron tube and the neutron generator, those 

workers qualify now all the way up until 1996. 

Whenever the Pinellas Plant workers, that dealt with 

the metal tritide, that neutron tube and the neutron 

generator in a warehouse-type facility, everything, 

and there was no air monitoring records.

There was occasional internal samples, urine 

samples, everything, that wasn't even done properly. 

But yet we don't qualify? It's inconsistent and it 

appears to me that it's more like a political game. 

Pinellas Plant workers deserve the same treatment 

and the conception of, you know, consistency of 

fairness and equal application of the law that you've 

given now to the Sandia workers.

Los Alamos workers and Sandia took over the tube in 

1992 all the way up until 1997, whenever Pinellas 

finally closed. So you've got the metal tritides, which 

is one of them is still classified. You know, those 

workers that were in a separate building at Sandia 

that was made nothing more for the neutron 

generator, they get to have an SEC petition to 1996.

You know, it doesn't seem like there's a consistency 

here at all. And then whenever you have the skin 

cancers now that you're talking about, and it's a log 

normal distribution, then why is all the skin cancers 

at Pinellas Plant a triangular distribution with zeros? 

Whenever Neton said that there's no zeros. But yet 

we're having the dose done at a triangular 

distribution with zeros instead of log normal. 

It appears that whoever is doing and reviewing the 

Technical Basis Document for Pinellas is just 

assuming that the facts are true whenever the 

evidence that I have been giving for years now shows 

contrary to it. 
142

And I just would like for the Board Members to be 

aware of that so that it is their duty to make sure that 

every dose reconstruction is scientifically valid and its 

consistency. And they're the ones that appoint the 

SECs and tells NIOSH no, you cannot do that dose. 

Thank you.

Mr. Katz: Thank you, Donna. Other members of the 

public on the phone? Okay, hearing none -- do you 

have another comment? Come right up and just 

please identify yourself again.

Mr. Hanlin: Thank you. I'd just like to extend my 

comments, Daryl Hanlin. After I sat down, I realized 

that we were talking about the drain systems, and I 

want to give you an idea of what the environment 

was like at Texas Instruments. It's kind of flat land, 

and we were subject to a lot of flash floods.

And so actually, Building 10 was kind of at a higher 

elevation than Building 4 as far as they had a little 

ramp you'd go down. But Building 10, it'd be like a 

little river that ran outside through the building. And 

at times, the head pressure would be so bad, the 

drains actually went in reverse.

I kid you not. They'd come up out of the floor, 

shooting up like a fountain, over my head. And that 

would happen. So it's kind of reverse, pushing 

everything that was going down up again. And so 

that would roll through all the buildings, and there'd 

be times, take you hours to get all the water out. 

Workers are spreading it around just trying to get it 

out, pumping it out and using squeegees to get it out. 

I just wanted to let you know that that happened 

quite frequently over the years.

Adjourn

Mr. Katz: Thank you, thank you. Okay, if there are 

no more public comments, then we are adjourned for 

the day. And we'll see you all bright and early 

tomorrow morning at 8:30. Thank you, everybody.
143

(Whereupon, the above-entitled matter went off the 

record at 5:18 p.m)