NEAL R. GROSS

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U.S. Department of Health and Human Services

Centers for Disease Control

National Institute for Occupational

Safety and Health Advisory Board on Radiation and 

Worker Health

Argonne National Laboratory-West/Idaho National 

Laboratory Work Group

Thursday, July 16, 2020

The Work Group convened telephonically at 11:00 

a.m. Eastern Time, Philip Schofield, Chair, presiding.
2

Present:

Phillip Schofield, Chair

Henry A. Anderson, Member

Josie Beach, Member

Genevieve S. Roessler, Member

Also Present:

Rashaun Roberts, Designated Federal Official

Nancy Adams, NIOSH Contractor

Bob Barton, SC&A

Ron Buchanan, SC&A

Bob Burns, ORAU Team

Grady Calhoun, DCAS

John Cardarelli, ORAU Team

Mitch Findley, ORAU Team

Rose Gogliotti, SC&A

John Hamawi, ORAU Team

Joe Fitzgerald, SC&A

Jenny Naylor, HHS OGC

Mark Lewis, ATL

Lavon Rutherford, DCAS

Steve Ostrow, SC&A

Tim Taulbee, DCAS
3 

Contents

U.S. Department of Health and Human Services 

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Argonne National 

Laboratory-West/Idaho National Laboratory Work 

Group Thursday, July 16, 2020 1

Welcome and Introductions/Introductions 5

SEC-00219: Burial Ground (1952-1970) 6

NIOSH Responses to SC&A Comments 6

SC&A Review of NIOSH Response to 

SC&A-TR-2017-007, Draft Review of 

NIOSH's Evaluation Report for Petition 

SEC-090219, Idaho National 

Laboratory; Burial Ground, 1952-1970 

by Joe Fitzgerald 7

Work Group Discussion 18

SEC-00219/224: Evaluation of EBR-II and 

BORAX-IV for ORAUT-OTIB-0054 Applicability

70

SC&A Presentation 70

NIOSH Presentation 73

Work Group Discussion 85

83.14 Verification and Validation (V&V) of 

Temporary Badges at the Chemical Processing 

Plant (1975-1980); SEC-00238; SC&A June 

25, 2020 memo 87

SEC Petitioner Commments 100

Work Group Discussion 100

August Board Meeting Session Plans 100

Board Review System Entries 107
4 

Follow-up Actions 111

Adjourn 114
5

Proceedings

(11:00 a.m.)

Welcome and Introductions/Introductions

Dr. Roberts: Good morning, everybody. Sorry to 

interrupt the conversation about smart cars and 

such, but this teleconference is for the Idaho National 

Laboratory, Argonne National Laboratory-West Work 

Group. 

I'm Rashaun Roberts, and for those who may not yet 

know, I became the Designated Federal Officer, or 

DFO, for this Advisory Board on Radiation and Worker 

Health a little more than a month ago. This is my first 

Work Group meeting as DFO. It's excellent to be here 

with you and I want to officially welcome all of you to 

the teleconference.

I am hearing a little bit of interference in the 

background, so if people could mute, that would be 

great. If you don't have a mute button, press *6 and 

that should mute you.

Before we dive into the presentations today for this 

meeting, let's go ahead with roll call and address 

conflict of interest. And I will go ahead and speak to 

conflict of interest with regard to the Members of the 

Board who sit on the Work Group. And my 

understanding is that in order for them to serve on 

this Working Group they cannot have conflicts of 

interest.

So with that let me move into the roll call for 

Members of the Board who are on the Working Group 

starting with our Chair and then in alphabetical order.

(Roll call.)

Dr. Roberts: Thank you very much, and again 

welcome to you all. And before we officially move into 

the meeting I just wanted to cover a couple of brief 

items in order to keep things running as smoothly as 

possible and so that everyone speaking can be clearly 
6

understood.

So as I mentioned before I would ask that each of 

you to please mute your phone unless of course you 

need to speak. If you don't have a mute button, press 

*6 to mute. If you need to take yourself off mute, 

press *6 again.

The agenda and the complete set of presentations 

and papers that are relevant to today's meeting can 

be found on the NIOSH DCAS website. All of these 

materials were sent to the Board Members and to 

staff prior to this meeting.

SEC-00219: Burial Ground (1952-1970)

Dr. Roberts: So with that let's go ahead and get 

started with the presentations. And I'm going to turn 

the meeting over to the Chair of this Working Group, 

Phil Schofield.

So, Phil, did you want to clarify the order of 

presentation under Number 1 on the agenda or would 

you like me to do that?

Chair Schofield: Sorry. I was on mute. Yes, if you 

want to go ahead and clarify that.

NIOSH Responses to SC&A Comments

Dr. Roberts: Okay. So we really want the Work Group 

and others to be able to follow things more easily. So 

what we're going to do is tweak the order of the first 

of the presentations listed under Number 1 on the 

agenda slightly so that things are done in 

chronological order and have a better flow than 

what's suggested on the agenda.

So in my short time as DFO I've learned that things 

can be really challenging to follow because different 

reports and reviews and responses to reviews are 

generated at different times. So while NIOSH's 

presentation under Number 1 on the agenda covers 

one time period of review and report, SC&A's 

presentation covers multiple time periods of reports 
7

and reviews. So SC&A is actually going to present in 

two parts. 

So instead of having NIOSH go first, we're going to 

have SC&A provide part one of its presentation first. 

NIOSH's presentation will follow, and then SC&A will 

do part two of its presentation. And I'd like to ask 

that NIOSH and SC&A provide an explanation or 

overview of exactly what they're covering as they 

open their respective presentations so that 

everybody's clear and can follow along.

So with that I'm going to go ahead and turn the floor 

over to Joe Fitzgerald and/or Bob Barton to give part 

one of the SC&A presentation.

SC&A Review of NIOSH Response to SC&A-TR2017-007, Draft Review of NIOSH's Evaluation 

Report for Petition SEC-090219, Idaho National 

Laboratory; Burial Ground, 1952-1970 by Joe 

Fitzgerald

Mr. Fitzgerald: Yes, this is Joe Fitzgerald. Thank you, 

Rashaun. 

Just as an overview the management or 

programmatic issues that were raised in our 2017 

report were largely carried over to the May 2020 

report in response to NIOSH's January response, so 

just to keep it straight. We have maintained our 

position relative to those issues from 2017 to the 

present report.

So I'm just going to essentially reiterate our -- since 

we haven't had this discussion since 2017, our points 

raised in both that report as well as our more recent 

response.

There's going to be a slight overlap because there 

were additional programmatic considerations raised 

by NIOSH in its January report that added to that ER 

review, so just to avoid confusion we'll treat the 

programmatic issues first. And Bob Barton is going to 

address a proposed bounding approach for actinides 

which was -- that figured in the most recent NIOSH 
8

report but we did not address back 2017. So as far 

as sequence he'll address that after NIOSH presents. 

That way you'll have a sense of what that proposal 

is.

Anyway, again let me just say that -- let me see. If 

you can go to slide, the first slide, Position 1(a). I'm 

not going to give the -- so much the background. I 

think NIOSH has a very detailed summary of the ER 

background, so I'm just going to defer to them to 

save time. So we'll just go right to pretty much our 

positions. And I'm on Position 1(a), Contamination 

Control. And this one is somewhat more detailed as 

you'll see in NIOSH's report as well as our response, 

much more detailed and with more subsets than the 

other positions. So just bear with me. This is going 

to be -- this is going to seem a little lengthy and 

detailed, but the others are very, very brief.

Okay. The first thing I want to emphasize is that the 

finding that NIOSH makes that the INL operating 

contractor was treating the burial ground as a, quote, 

low priority prior to 1969, December of '69, was 

actually a conclusion reached by the Atomic Energy 

Commission's Idaho Office. 

And I want to clarify that because in NIOSH's 

response that seems to be attributed to SC&A, and 

actually all we're doing is citing what AEC found back 

in that time frame. And we defer of course to AEC as 

the more authoritative voice on that question of 

priority since they were the governing entity at Idaho 

and had done the independent reviews of the 

program.

I think it's fair to say that NIOSH makes -- and we've 

gone through their most recent report in some detail 

-- has made quite a bit of the available procedures, 

memos and other documentation that again they 

contend is evidence of a mature radiological control 

program and, as they put it, one that does not 

tolerate contamination at the burial ground. 

However, in our report we offer some of the following 

responses, and I think we've outlined these in the 
9

report. We didn't detail them all in our slides, but we 

think they're pretty specific to the items that NIOSH 

has raised.

The first one, as far as NIOSH's reference to a 1961 

management memo -- and this is highlighted I think 

as you'll later see in the NIOSH slides. This 1961 

management memo, which basically indicates that 

contractor management would manage the burial 

ground, much as it would manage the rest of the site 

as far as RADCON -- we just want to emphasize that 

if you look at the details of that statement, it's part -

- it's in response to what essentially is a new contract 

between Phillips Petroleum, which was the original 

contractor at Idaho, with the Atomic Energy 

Commission. 

And what they're doing there is stressing the 

importance of treating the burial ground like the rest 

of the site, but from our standpoint we see this as 

actually a management expectation or a goal and not 

necessarily reality in terms of what was actually 

practiced in the field. And I guess my perspective is 

that managers and contractors came and went at 

Idaho, and as well as at the other DOE sites over 

time. And it's just a normal course of business. 

And the question of what was being done on the 

ground is probably the real issue and we think that 

the interviews and the comments of the workers and 

the statements of the Atomic Energy Commission at 

the time are probably much more persuasive and 

important than what line management may have 

intended or wished to see happen back in 1961. So 

we just want to point that out, that this is where I 

think the contemporary observations and the 

experiences of the workers at the site in terms of 

what actually happened is critical.

And again in the -- in its response to our 2017 review 

NIOSH observes that site work permits were in fact 

applied and used at the burial ground. And we don't 

disagree, but our review of those SWPs, those 

permits, show that they tend to emphasize industrial 
10

safety precautions. And that's not too surprising. 

The steel-toed shoes, the eye protection, whatever it 

might be in terms of the kinds of operations at the 

burial grounds that were happening certainly make 

sense. There are some cases where monitoring, rad 

monitoring surveillance would have been required 

and -- but there's no provision for follow-up 

bioassays that we could find. 

So I think, yes, there were permits written for the 

burial grounds, but if one actually scrutinizes those 

permits, I think you'll find a wide variety of 

precautions and those precautions in a lot of cases 

were for industrial hygiene and safety rather than 

rad.

NIOSH also notes that smears were used extensively, 

but we present documentation and HP interviews that 

indicate there was no smear counting at the burial 

ground itself and that smear counting equipment, 

much of which dated back to the 1950s, had by the 

1960s become outdated and deficient as found by the 

operating contractor itself. So this is from a review 

that the contractor had done.

Moving onto occupational air sampling, I think both 

NIOSH and SC&A agree that low and high-volume air 

samples were taken, but not routinely, and there was 

no -- not necessarily any procedural protocol that 

required it other than for the Rocky Flats drum 

dumping. And I think there's a photo that you'll see 

that shows some air sampling done by a dumping 

truck. 

And just note that that sampler is positioned on the 

rim of the trench, so that's not going to necessarily 

give you a representative air sample for the worker 

that might have to go in the trench to do any clean 

up or adjustments for the drums, or for the --

necessarily the bulldozer operator who later is going 

to compress and crush those drums. So I think that's 

one thing to keep in mind was the kind of air sampling 

that was done.
11

In terms of alpha monitoring it's pretty clear it wasn't 

considered reliable by a number of the health 

physicists at the site, at the burial ground at the time. 

And I think you'll see those quotes -- and I'm not 

going to go through all the quotes, but those quotes 

are on page 14 of the un-redacted version of our 

report.

Okay. Finally, for contamination control writ large, I 

think again documented interviews -- and we did a 

number of interviews, and actually between NIOSH 

and SC&A over a number of years there were quite a 

few interviews with workers and health physicists. 

We certainly found that many of the statements, 

many of the comments spoke to prevalent 

contamination, low-level contamination, but 

contamination nonetheless associated with spilled 

drums and material in the trenches and whatnot. And 

again this is in our report, the un-redacted report on 

page 13. Again there's numerous excerpts of those 

interviews with health physicists, the HP techs and 

the workers themselves that were handling the 

waste. And I think that pretty clearly establishes that, 

yes, you did have contamination related to that 

operation and that this is something that certainly the 

workers at the time recognized. And all we would say 

is that the Work Group should weigh these 

statements by the individuals who were at the burial 

ground during the '50s and '60s against the claims 

that contamination was not tolerated and that 

because there were, quote, no contamination or little 

contamination that may preclude ever having to do a 

special bioassay. 

So I really do think that you have to go back to the 

contemporary experience of the workers themselves 

and the health physicists who were lead 

responsibilities for RADCON to look at that question 

of whether or not there was in fact contamination at 

the burial ground.

To move on, as far as NIOSH's opinion regarding a 

health physicist being in charge of both health 
12

physics and the operation of the burial ground being 

a good thing, all we can say is that AEC categorically 

disagreed with that. They saw an organizational 

conflict of interest, and I think we view it the same 

way.

The AEC Idaho Office conducted an investigation of 

leaking Rocky Flats drums and other irregularities at 

the burial ground and they established that one root 

cause was the -- what they saw as a conflict of 

interest. 

In their view this was not a positive attribute or a 

positive thing. They thought the HP organization 

could not independently judge RADCON safety issues 

while pursuing the mission of waste management as 

well. In the end AEC demanded that the two 

management functions be separated. And this was -

- this happened in 1971, but it was pretty clear in the 

AEC finding that this was a long-standing functional 

arrangement for the burial ground. So this wasn't 

something that just happened.

And in terms of the implications of a conflict of 

interest we, I think, included a comment we received 

from one of the HPs that we interviewed. It's 

redacted, but you'll see it on page 14 of our unredacted report. I think that comment is pretty telling 

because it certainly points out that when a health 

physicist wears two hats, one for mission and one for 

RADCON, it can put that HP in a position where the 

judgment made may not be in fact particularly in the 

independent interest of radiological protection. And I 

think that's the concern that the AEC found as well. 

But I just wanted to make sure that was clear that 

that was the basis for the reorganization. It wasn't 

an overall finding of poor radiological performance at 

all, but certainly the concern over how judgments 

would be made and what the implications of those 

judgments would be.

Okay. My final comment on the first position is that -

- and this is a new finding, so I'll just comment on 

this. It's in our report in May, but there's a new 
13

finding that because polyethylene liners were used in 

the Rocky Flats drums, even if they were flung open, 

the contents would not likely spill out. 

And as noted in our report there are a number of 

reasons that we think this assumption doesn't 

necessarily hold up, but I think the most conclusive 

finding that we highlight is that the contractor 

themselves did a survey of retrieved drums; this was 

in the early '70s, 1972 to be exact, where they were 

-- they wanted to see the status or the exact 

conditions of the contents of those drums. These are 

Rocky Flats drums that were buried. And of the 16 

drums that they surveyed they found that three had 

no liner at all. Five had liners that were folded but not 

taped shut. Three were found to be taped shut, but 

were torn or rotted. And so of the 16 only five were 

actually found taped and intact. That's about twothirds of the liners that were surveyed in those drums 

were in fact -- that were found to lack integrity. So 

two-thirds of the drums, of the 16 that were 

surveyed, did not have polyethylene liner integrity.

So we just wanted to point that out that -- and that's 

in addition to the empirical evidence that when drums 

were -- the lids came off the drums; and this is from 

interview accounts by workers, the contents spilled 

out in the trenches. So we have that as well. So in a 

sense we just don't think there's any question that 

there was some contamination from the spillage from 

those drums.

Any questions on Position 1(a)? I know that was kind 

of lengthy, but I wanted to give you at least a 

thumbnail on what we found in our report. Okay. I'll 

move on to the next slide, Position 1(b), which is 

dealing with rad waste source terms. 

In terms of monitoring I think it's pretty clear that we 

accept NIOSH's position regarding mixed fission 

products being controlling for on-site waste, but our 

problem is more the off-site waste, the Rocky Flats 

waste, which we think -- where we think the source 

term is more uncertain. And I think within that 
14

conclusion presented by NIOSH we would disagree 

that -- with the contention that the lack of special 

bioassays can be explained by the little 

contamination that existed at the burial ground. And 

again, as we pointed out earlier, I think all the 

commentary by HPs and workers at the site would 

suggest otherwise in that regard.

Okay. If we can move to -- I was saying we would 

move faster. If we could move to Position 1(c)? This 

is on special bioassay program implementation. 

And we agree with NIOSH that -- and this is from 

their report -- that there's no way to find evidence of 

a worker in '52 to 1970 being placed on special 

bioassay as a result of a special contamination event 

at the burial ground. We disagree however that --

again that the lack of special bioassays can be traced 

to lack of personnel contamination. So again, that's 

our point on that.

Any questions on I guess 1(a), 1(b) and 1(c)? We 

kind of split it up that way. All relate to contamination 

control.

Member Beach: Joe, I just have a quick -- I don't 

know how off-topic this is, but the flooding that 

occurred in the burial grounds, what kind of effect 

would that have had for the spread of some of this 

contamination with the 16 drums you identified as 

two-thirds of them coming open? Any ideas on that?

Mr. Fitzgerald: I'm sorry. I missed the very beginning 

of your question.

Member Beach: The burial ground flooding. I know 

there was a couple of times that the different pits 

flooded. Would there be any contamination issues 

from those flooding incidents?

Mr. Fitzgerald: Well, yes, I mean there was some 

modicum of contamination from the flooding itself 

that happened in '62, and they did quite a bit of 

sampling from that. As far as any impact to workers 

I think it was relatively minimal because they actually 
15

did some fair amount of monitoring while the flooding 

was going on and after the flooding was done, but I 

don't recall that being a big issue in the aftermath.

Member Beach: Okay. Thanks.

Chair Schofield: Joe, this is Phil. Could I ask you a 

quick question?

Mr. Fitzgerald: Yes.

Chair Schofield: Okay. The drums particularly from 

Rocky Flats, they did not -- at that time they were 

not doing a characterization of the waste they were 

putting in the drums, did they?

Mr. Fitzgerald: Well, they had manifests for some of 

them, not all of them necessarily, but where Rocky 

would do -- they would do scanning of the contents 

and inventorying the contents before they would seal 

them and send them, and Idaho would do some 

exterior monitoring and smearing when they received 

them. But the -- as far as the specific contents, 

radiological contents, that was less detailed, less 

obvious. So for Rocky Flats drums there wasn't a 

detailed accounting of the activity levels inside the 

drums themselves, although there was -- it was 

pretty clear what the material was and what the 

nuclides would be. But the distinction of how much of 

what, isotopes and whatever, that wasn't the, 

necessarily the information that you got.

Chair Schofield: Oh, okay. Thanks.

Mr. Fitzgerald: And I think before -- and maybe 

NIOSH will present this -- I think as I recall, before 

'64 there wasn't a lot of detailed information on drum 

contents as well, so it got better later from that 

standpoint.

Moving on to what we call Position 2. This is the dose 

reconstruction approach with actinides and mixed 

waste. And I think I just want to reemphasize we 

agree with NIOSH that the mixed fission products, 

the MFPs, are the dominant source terms for on-site 
16

waste, but where we're more concerned is regarding 

the off-site waste and the conclusion that I guess the 

burial workers were necessarily exposed to similar 

levels of mixed fission products as other unmonitored INL workers. 

So certainly for on-site waste we clearly see a means 

by which you can take mixed fission products as the 

dominant nuclide, and certainly that's what the site 

did in terms of their surveillance and whatnot. But as 

far as making that assumption or jumping to the 

assumption that you can assume that the exposure 

experience at the burial ground was similar to the 

reactors and CPP, we just don't know what the basis 

of that would be and we didn't see anything that 

really put a sort of punctuation point on that. So 

that's something that we're looking for still.

I want to go ahead -- this is the piece that I referred 

to earlier that Bob Barton was going to present that 

related to the new proposal that was contained in the 

January report using the additional workers from the 

'78-'79 exhumation project to more or less backapply that information to bound actinides. We're 

going to -- I think Bob's going to address that after 

NIOSH presents because that's probably the most 

substantive new piece of information or approach 

that's been added since 2017. So along with what 

Rashaun mentioned, we'll do that after NIOSH 

presents.

But if you can jump past that, which is Position 2 to 

our slide on Position 3, I'll continue with the program 

issues and more or less wrap that up, and we'll come 

back to Position 2 with Bob after NIOSH.

And Position 3 is the rad monitoring program, and 

this is the question of the rigor and defense-in-depth 

of that program. And as we noted earlier, SC&A 

doesn't question that INL had the management 

directives, the RADCON procedures and the records 

to demonstrate that it implemented a monitoring and 

contamination control program. It's just that the 

statements made by its workers, made by INL 
17

workers at the burial ground, again the HPs, the 

waste handlers, as well as the AEC and contractor 

managers at the time -- these seem to contradict the 

stated NIOSH thesis that a low-level rad waste landfill 

of the '50s and '60s had a mature RADCON program 

that exemplified a defense-in-depth protective 

strategy, and in the end one that did not tolerate 

contamination. So again, we just again see a 

contradiction from the statements made by the 

workers and that particular thesis that's being 

advanced.

And in our final slide, I'm going to jump past the 

conclusions to the final slide, SC&A views the burial 

ground as having a contamination program 

commensurate with the rad waste landfill of the era. 

This is the '50s and '60s when less management 

priority was assigned to such operations and sporadic 

low-level contamination from the unloading and 

dumping of drums was a common part of work and 

frankly did not warrant a special response from the 

rad control program. 

I think that would be how we would view it. And that's 

a decidedly different view I think than what NIOSH 

presented in the ER and what is presented in the 

January 2020 response to our 2017 report. So what 

I think the Work Group -- I just want to underscore 

that, is you essentially have two very different 

narratives, very different takes on how the burial 

ground was managed as compared with the rest of 

INL.

And again our conclusions are summarized in the 

next-to-last slide, and I pretty much have covered 

them so I'm not going to repeat that, but I want to 

make one final note because this is sort of a hand-off 

to what Bob will present last, is that in the January 

2020 response I think it's fair to say that NIOSH has 

added a fair amount of post-1970 data and operating 

perspectives that came out of the new RWMC, Rad 

Waste Management Center, the RWMC Waste 

Retrieval Program, and has back-applied it, has backapplied this experience to the burial ground of the 
18

'50s and '60s. And I think Bob is going to get into at 

least one particular concern that we have, how that 

back-application may pose a real problem as far as 

representativeness. 

But I think one thing I just wanted to point out in 

closing is that with the advent of waste retrieval and 

above-ground storage this new RWMC became the 

pilot showpiece for DOE in this regard complex-wide, 

and under that spotlight upgraded its RADCON 

program, upgraded PPE, added routine bioassays and

exercised what certainly could be considered 

stringent contamination control procedures. 

So as far as the tact of looking to the late '70s for 

operational perspective and data to back-apply to the 

burial grounds of the '50s and '60s I think one has to 

be very careful, and that's kind of what our 

admonition would be and one would need to very 

critically look at whether you're dealing with apples 

and apples and that there's representativeness to 

what you're doing when you do that. I think there's 

some real concern on our part that that may be a 

problem.

Okay. So that's the programmatic piece of our 

presentation and Bob will come back later with an 

analytic piece on the back-application of the '78-'79 

data, as I said.

Any questions from the Work Group?

Work Group Discussion

Member Roessler: Joe, this is a question from Gen, 

and it's probably directed to more than just you, but 

as you've gone through this it's quite obvious that 

you're putting a lot of emphasis on the interviews 

with the various people, contractors and workers, 

and you even said it was critical. And that's as it 

should be because that will present the perspective 

that seems to be missing. 

And I know there were many. I was involved in I think 

most of the interviews, not all of them. And of course 
19

what we did is -- some of us at the interviews took 

notes in order to put this on record and these notes 

were then given to a transcriber who put them in the 

-- and I assume they're in this Site Research 

Database.

I would like to have access to those. Maybe I should 

have been able to get them before, but it just 

occurred to me when I read your report. And I think 

it's really important since we have new Work Group 

Members for them to be familiar with the whole 

perspective for them to actually go back to the 

originals of the interviews. 

And I guess my main point on that is as I think back 

on the interviews, the wide spectrum of comments -

- and I won't go into that much now, but I want to 

myself make sure that the comments that you 

selected for your report are representative and not 

just selective.

So now getting to my question: Is that database 

accessible to Work Group Members?

Dr. Taulbee: Gen, this is Tim Taulbee. We can provide 

you with a listing of all the SRDB numbers or the 

actual interviews themselves for those that were 

concerning the burial grounds. That's not a problem. 

We can provide that to all the Work Group Members.

Member Roessler: Okay. Was that available? I can't 

get on my CDC computer, so I didn't know if I just 

missed and it was available and I should have --

Dr. Taulbee: They're all in the Site Research 

Database at this time, but finding them, locating 

them can be a little difficult. So we can pull them out 

from the Site Research Database and provide them 

to you all.

Member Roessler: Okay. So all Work Group Members 

can get them. Now I know SC&A obviously has gone 

over them and NIOSH has, and perhaps you're going 

to have some comments on that, but at that point --

this point that was my main question.
20

Mr. Fitzgerald: Yes, and I think that's true. I think it 

would be very helpful for all the Work Group Members 

to review all the effort that went into talking to the -

- not just again the waste handlers, but also the HPs, 

HP techs. There's also a memorandum written at the 

time by the Atomic Energy Commission and the 

contractor. All of those I think is the -- are the body 

of contemporary perspectives, not conclusions 

reached much later, but actual contemporary 

perspectives.

And as contemporary perspectives I think another 

thing that is important to keep in mind is that if you 

interview -- and I think we did, all of us did, enough 

workers, and maybe it was 20, 30, 40 or 50 in the 

end, you're not going to get in certain topical areas 

100 percent unanimity as far as what was recalled 

and what was considered to be the case. I think in 

most cases we're talking about 30, 40 years later.

So in the context of asking about do you remember 

certain monitoring, do you remember certain 

contamination, depending on, one, the worker's 

recollection; two, the type of job they had; and three, 

perhaps what stood out as important or not, I think 

you're going to get a variety of answers. 

But I think what our concern is is that when you come 

to a categorical conclusion without much qualification 

that a low-level waste landfill of the '50s and '60s did 

not have much in the way of low-level contamination 

in the face of dumping thousands of drums, that part 

I think ought to be queried very firmly by looking at 

what the workers recollected from that time frame. 

Because I think when one goes to that kind of 

conclusion you really want to be careful about making 

sure that the contemporary perspectives align with 

that. And that would be certainly our viewpoint as far 

as how one looks at the interviews. It's almost one of 

challenging that premise. And if you find your senior 

HPs and HP techs -- let's say 75 percent of them are 

accounting for contamination, then I think you'd have 

to question whether that premise holds or not.
21

So that's kind of our perspective. When you're 

looking at an operation such as a rad waste landfill 

where you don't have a lot of records and you're 

talking about a time period that goes back quite a 

ways, you really are going to have to rely on, 

probably more so than other cases, first-person 

accounts. So that's the reason why I think there's a 

particular importance attached to looking at these 

accounts. So I agree with you that certainly all the 

Work Group Members should look at all these 

accounts and weigh them again in the context of the 

premise that's being advanced in the Evaluation 

Report about the lack of contamination or low-level 

contamination at the burial ground and the 

implications of that for how one would do dose 

reconstruction. So that's kind of how I would view 

that.

Member Roessler: Well, Joe, I certainly agree with 

you that it's important that -- and there was a 

tremendous amount of time and effort put into this. 

So I'm pleased to know that Work Group Members 

can get this data, and perhaps later we can talk more 

about how that -- how we can get that. So I think we 

can move on then to the -- your next part.

Member Beach: This is Josie. One thing I want to 

bring up since we're talking about interview notes, 

and I don't know if we can take it up here, Rashaun, 

I'm going to leave that to your discretion, but the 

inconsistency in -- regarding the redacting of the 

interview comments between SC&A and NIOSH's 

reports. I think we need to take that up as a 

discussion maybe as a full Board, or -- I'm not really 

sure. It seems different in these reports for INL than 

in the past reports.

Ms. Naylor: Josie, this is Jenny Naylor with HHS 

Attorney. I'm happy to take that now because I'm not 

quite sure talking more specifically about some of our 

legal concerns would be appropriate in the public 

forum, like the Advisory Board. So I'm just sort of 

going to touch on some of the concerns that we have 

with the redaction.
22

And you're right, there is some inconsistency 

between the redaction in the 2017 and the 2020 

burial report. And with each iteration we're basically 

looking at how much information has already been 

released out in the public. And so I just want to frame 

this discussion by saying that when I do the legal 

review and recommendations to the Advisory Board, 

I'm actually doing it on behalf of the Department and 

it's to support the Department's proactive release 

under FOIA to the public.

So this redaction is not to the Board's document, but 

you should still receive the un-redacted and you 

should still have access to all the documents relevant 

to your petition evaluation in the SRDB, which is 

where you can find the raw source material.

So there are different people who are providing these 

redactions, so like I say, I do it for the Advisory 

Boards and technical documents, and NIOSH actually 

has a different set of staff that supports that 

redaction process. But the redaction is actually made 

-- or release of these public -- release of these 

documents is actually made under FOIA's proactive 

release to the public. So this is not the same as 

requesting a FACA document under the Advisory 

Board's Record Request Policy. So I'd just make clear 

that that's what we're coming now.

So I also want to remind the Board that under 42 CFR 

83.15, Subsection B the individual Board Member has 

to take steps necessary to prevent the disclosure of 

information of a personal nature or concerning the 

petition, petitioners or any others, and that the 

disclosure would constitute a clear unwarranted 

invasion of personal privacy. 

And when a member brings a case against -- based 

on unreasonable infringement of privacy interest 

against the federal government, in that suit the 

defendant is the HHS Secretary, not the SC&A 

authors or individual Board Members. And the 

resources used to defend that lawsuit or any payout 

or settlements for the lawsuit is also funded by the 
23

taxpayer. They do not come out on the pockets of 

SC&A authors or individual Board Members.

So now let's talk about like the document review 

process. When I review SC&A documents, I put my 

recommended redactions in a comment balloon. I 

don't actually apply the redaction. The black strips 

that you see in the public versions of the document, 

that's actually done by the -- I think the document 

managers for SC&A.

So when I was reviewing the 2020 burial ground 

report I did ask why there is such a heavy use of 

block quotes from interviewees and from CATIs, 

because I know that SC&A tends to summarize notes 

from interviews or CATIs instead of just copying and 

pasting. So I sent an email to SC&A back in May 

specifically asking why there was such a heavy use 

of verbatim quotes, and my concern at the time is 

that using such verbatim quotes repeatedly, 

particularly for a couple individuals, might undermine 

the Agency's efforts to preserve the interviewee's 

privacy. 

And I also questioned whether this is a good practice 

to the extent that verbatim publications of 

statements may create a chilling effect on potential 

future interviewees.

So I understand that these interviewees are not 

whistleblowers and they're not really afforded that 

level of confidentiality, but it's important to make 

sure that workers will be willing and comfortable to 

talk to us.

So when I stated this to the SC&A document 

manager, I specifically asked her to let me know if 

the authors have any questions or concerns with the 

redactions. And then the next day I received a 

response from SC&A explaining to me that the 

verbatim quotes are important because it's the 

precise wordings and the interpretation of that quote 

that there are issues here, which is fine. But I didn't 

hear anything else about the redactions.
24

So I'm still -- so I think a couple of days ago I'd 

actually gone back to do a cross-reference between 

2017 and 2020 reports. I am still very alarmed at the 

frequency and the intensity of verbatim block quotes, 

sentences and phrases from certain individuals just 

littered through the pages in the 2017 and 2020 

reports. 

So at the start of every interview I know that you --

SC&A, Board Members or NIOSH informs the 

interviewees that your participation in the 

discussions are voluntary and that they will be 

treated in a confidential manner. So I'm really not 

sure that our confidentiality assurance to 

interviewees actually means anything if we're 

publishing these verbatim interview statements. So 

for --

Member Beach: Hey, Jenny, can I stop and ask you 

a question on that?

Ms. Naylor: Sure.

Member Beach: So the interview notes are given 

back to the interviewees, they read them and then 

they accept and basically give the permission for us 

to use those also, is that not true? And we would not 

use them if we did not have the written consent from 

the interviewees.

Ms. Naylor: We don't have written consent. And also 

the Advisory Board Members and SC&A are in no 

position to provide confidentiality assurance. Only 

the Department gets to do that, and there's a proper 

policy for doing so. So Advisory Board Members and 

the SC&A are in no position to provide this security -

- confidentiality certification. That is -- there are 

separate procedures for doing that. And also for them 

to actually waive their privacy interest, we would 

actually have to ask them to sign a privacy waiver 

authorizing them to actually use their statements. 

But I mean the bottom line is that is this a good 

practice going forward? Board Members who are 

participating in this deliberative process have access 
25

to the source material un-redacted. So what we're 

talking about here is whether the public members 

need to know -- what we're trying to do here really 

is to sort of balance the statutory responsibility 

between protecting the workers' privacy while 

facilitating meaningful participation from them, not 

just at public meetings, but also providing their 

recollection and unhindered thoughts with the 

Agency.

So I think that's what -- that's the crux of the issue 

here. If we make the habit of block quoting 

interviewees, how do they feel about that the next 

time that we want clarification from them or we want 

to interview them again? So I think those are just the 

implications that you probably want to think about 

and balancing how that redaction in a public version 

interferes with your deliberation and your 

responsibility to provide advice to the Secretary.

Member Beach: Okay. Thanks, Jenny.

Rashaun, I'm wondering if we can request a review 

of this with select Board Members.

Dr. Roberts: Can you say more about what you would 

have in mind?

Member Beach: Well it just feels like this needs to be 

an OCG -- or an OGC review process. This -- anyway, 

I understand what Jenny is saying, but this is really 

a policy question for the Board.

Dr. Roberts: Yes.

Ms. Naylor: Josie --

Member Beach: And it's changed from --

Ms. Naylor: No, Josie --

Member Beach: -- what we've been doing the past 

20 years here.

Ms. Naylor: No --
26

(Simultaneous speaking.)

Ms. Naylor: -- and this is not a Board policy issue.

Member Beach: Okay. Well, it feels like -- it just feels 

like a Board policy question and an OGC policy 

question here. I don't know what anybody else --

Ms. Naylor: I disagree that this is a policy issue. This 

is basically OGC needing to weigh the risk to the 

Agency for unwarranted intrusion into a public 

member's privacy and balancing that with the 

Department's proactive release policy under FOIA.

Member Beach: Okay. It just seems new, Jenny, now 

more so than --

Ms. Naylor: No, it's not.

Member Beach: -- in the past report.

Ms. Naylor: The 2020 -- no, Josie. What has changed 

is that in the 2020 report there are two individuals 

whose interview summaries were used in multiple 

instances. I think one of the interviewees actually 

had five block quotes or phrases or sentences 

attributed to that person. So the question here is how 

do we still balance this statutory responsibility to 

prevent this unwarranted invasion to personal 

privacy with the Board's responsibility to deliberate 

over these materials and make a presentation --

make advice to the Secretary. Like I said, Board 

Members always have access to un-redacted 

material.

Member Beach: Okay. I guess for me I'm just -- why 

the difference between 2017 and 2020? It just -- it's 

like the policy changed or something changed that 

we're not aware of. So --

Ms. Naylor: No, it's not policy change. When we are 

doing the balance of -- when we're doing these risk 

assessments and also we try to balance that need 

with the Board's deliberative process, we're basically 

looking at how much information is already made 
27

available. Okay? And so in 2020 there were a lot 

more quotes that were put in this report that was not 

in 2017. 

Member Beach: So what's the difference between the 

block quotes that NIOSH used in their report and --

it seemed like they -- the block reports were okay 

and just the name was taken out, and it seems to me 

that would do the same with SC&A's reports. The 

quote could stay but the name associated with it 

should be blocked.

Ms. Naylor: So, Josie, the issue here is not the use of 

block quotes. It's the frequency and the intensity of 

using block quotes from certain individuals. This is a 

case-by-case evaluation. So you could use block 

quotes. But what happened here in the 2020 report 

is that there were five quotes attributed to one 

individual and it gives me pause in terms of what that 

actually means going forward. Is this a best practice? 

But I think what SC&A explained to me is that this is 

special because the actual quote -- the actual 

wording and the interpretation of the wording aren't 

at issue here. I haven't seen this level and this 

intensity of using block quotes from one individual in 

however long I've been with the program. 

Member Beach: Okay. Thank you.

Dr. Roberts: Okay. Question, Joe. Were you done 

with your presentation?

Mr. Fitzgerald: The programmatic side of it. And as 

you were pointing out earlier, Bob Barton will follow 

NIOSH's presentation, which is next, with the more -

- sequentially the latest rendition, so it makes more 

sense for him to go last.

Dr. Roberts: Okay. Great. So at this point we can 

move on to the NIOSH presentation, Phil, if that's 

okay with you.

Chair Schofield: That's fine with me. 
28

Dr. Roberts: Okay. And I believe it's Mitch Findley 

who will be doing that presentation.

Mr. Findley: That is correct, Dr. Roberts.

Can everyone hear me okay?

Chair Schofield: Yes, we can hear you fine, Mitch.

Mr. Findley: Okay. 

Chair Schofield: Can you hear us?

Mr. Fitzgerald: Yes, the presentation, is it available 

to be brought up?

Chair Schofield: Yes. John, do you have it ready?

Mr. Cardarelli: Yes, I was questioning whether or not 

we use -- hold on, the Skype. So shall I bring it up 

and share my screen?

Mr. Findley: Yes.

Mr. Cardarelli: Okay. 

Mr. Findley: So it's good to hear some familiar voices 

this morning, or I guess this is afternoon now. Hope 

you're all doing well during these unusual and trying 

times.

Since we've not met for a while I thought I would 

provide some review prior to getting into the NIOSH 

responses to SC&A's review of the burial ground from 

the SEC-002019 Evaluation Report.

John, could you go to the next slide, please? And so 

what I've done is I've broken this presentation up 

into three parts. You'll be glad to hear the first two 

parts are relatively short with about three slides 

each. The first is just to review the burial ground from 

1952 to 1970. 

And the second part is just to review the SEC 

Evaluation Report conclusions for the burial ground. 

Okay? And I have listed the dates of the beginning of 

radiological operations on July 3rd, 1952 through the 
29

end of the evaluated period of December 31st, 1970. 

And then we'll get to the heart of the presentation 

with the responses to SC&A's review. Much of that 

will kind of look and sound familiar since Joe has 

spoken about the -- in his presentation.

Next slide, please? Okay. So you should be looking 

at a slide that's got a number of images on it. Just to 

kind of re-familiarize everybody with the site, on the 

left-hand side is the INL Reservation, which is 

trimmed out in a darker black line. I have got a line 

drawn in the bottom left hand which points to the 

burial ground location on site. And if you look about 

the 2:00 position from the burial ground, you'll see a 

blue box that says CFA. That is the Central Facilities 

Area and that will become important as we discuss 

the burial ground since the burial ground was the 

location that was actually managed out of the Central 

Facilities Area.

The photo insert at the top right is basically a figure 

of what the burial ground looked like in 1955. Very 

simplistic. There was a road that went in. It was just 

basically an empty field, if you will, that had a trench 

in it. And so trenches were the first thing that were 

used at the site to bury on-site-generated waste. So 

this would be the primarily mixed fission product 

waste that Joe discussed.

There's a little bit -- there's a little insert there of a 

gate going into the burial ground. That's the entry 

road. And this is just a control gate to get into the 

burial ground. And on that sign, you can't read it 

because it's kind of small, but it says entry only under 

the Atomic Energy Commission Health Physics 

authorization -- you have to have authorization from 

the AEC HP. And so that gets again back to the point 

that Joe was making about that the AEC had not only 

radiological control responsibilities, but had 

management responsibilities as well.

So the bottom right-hand photograph, that's an 

aerial view of the burial ground in 1970, which is the 

end of the evaluation period. And you'll note that 
30

there are no buildings, anything like that. The first 

building was the 601 Building, which was not built out 

there until 1976. You will notice in the foreground 

that there is a long rectangular darker area. That is 

actually an asphalt pad that had been poured and 

was called the Transuranic Storage Area Pad; and 

that's Pad 1 there, that was used around that --

implemented about that time for above-ground 

storage of transuranic waste.

I should point out that while the burial ground was 

kind of a location on site, it really wasn't an area. It 

didn't get its own dosimetry code until 1975, and 

even then it had maybe 20, 30 people on the monthly 

exposure reports.

Next slide, John? Just a recap of some important 

events that occurred at the burial ground. As I 

mentioned earlier, in July '52 the first waste trench 

was opened for disposal of INL waste. Some of the 

initial Rocky Flats waste was actually placed in some 

of these early trenches as well, but as the waste 

shipments increased and there were larger items for 

burial, waste pits were implemented. And so these 

were fairly deep large holes in the ground, if you will, 

that -- and you'll see pictures a little later where 

waste was placed.

The first TRU shipment from Rocky Flats occurred in 

1954. And there was mention earlier of dumping of 

waste drums. That was for a period of time between 

November of 1963 through late '69. Prior to 1963 

they were hand-stacked. There were some concerns 

about cost and external dose exposure, so they 

started doing some dumping which -- kind of mass 

dumping. And they stopped that in 1969 for a 

number of reasons which I'll cover later. One of the 

reasons was they were running out of room at the 

burial ground. And it's much more orderly to place 

the drums and stack them than to dump them en 

masse, if you will.

One other item during this time period was that it 

was -- the INL burial ground was a designated burial 
31

site for other AE sites, AEC sites and some non-AEC 

waste generators. So these were things like 

universities, research centers and even a little bit of 

military waste was sent there as well.

Ms. Beach asked earlier about the flooding events. 

There were two significant flooding events during this 

'52 to 1970 time period. The big one was the Chinook 

flood event in 1962. They made some measures to 

make sure it wouldn't happen again because the -- it 

was -- it impacted the burial ground pretty 

extensively. 

The second flood event in 1969, there was some 

snow drifts which blocked some of the ways for some 

of the water to leave the burial ground area, and so 

they ended up having a second flood event there.

Next slide, John? The picture to the right should be a 

familiar one to those of -- following the work on the 

burial ground. This was the first waste retrieval that 

had ever been done at the burial ground. It was 

performed in November of 1969. They were looking 

for a specific Rocky Flats waste drum and was one of 

the reasons why we had to do a revision to the SEC00219 Evaluation Report.

In the '69-1970 period -- again I will get into this a 

little more later, but there were some policy changes 

requiring how solid TRU waste could be stored. And 

that's all I'll say about that right now other than the 

fact that in November of 1970, that's when the first 

waste was stored on that asphalt pad that I pointed 

out in the aerial photo of the burial ground in 1970.

Next slide, John? Thank you. 

Next slide. So regarding the SEC-002019 petition for 

INL, the petition was received on July 8th, 2014 and 

the basis from the Form B of the petition was that --

no personal knowledge of internal monitoring for 

plutonium, neptunium or fission products. So the 

worker didn't think they were -- the former worker 

didn't think there was any monitoring for these 

things. And the date range was from 1949 to 1970. 
32

Qualification went through and the petition was 

qualified in September of that year, and it looked at 

all areas, all workers at INL from 1949 at the 

beginning of the year through December 31st of 

1970.

Next slide, John? So at INL we -- during our 

investigations into documentation out there and also 

lots of interviews, which have been mentioned

already, it was pretty apparent that all workers in 

INL's radiological areas including the burial ground 

were monitored for external radiation exposure. 

Dosimeters were required for entry into any fenced 

area at INL and this included the burial ground. And 

there are provisions in the Tech Basis Manual for INL 

and Argonne National Lab-West. I should mention 

that those were two separate sites basically until 

2005. ANL-West is known as the Materials and Fuels 

Complex now at INL. The ANL-West Evaluation 

Report was SEC-00224.

So for the SEC Class that we added for the Chemical 

Processing Plant we did some extensive reviews of 

the external dosimetry, and even including 

temporary dosimetry to ensure that Class members 

could be identified by the external dosimetry records 

that we have. As a matter of fact I think Bob Barton's 

going to talk a little bit more about some of the 

temporary badges for the AE-314 that was done for 

the Chem Plant from '75 to '80 a little later in this 

meeting.

Next slide, John? 

Participant: On internal monitoring?

Mr. Findley: So for internal -- I'm sorry? Yes, that's 

correct.

So for internal monitoring for the SEC Evaluation 

Report we said that we would assess missed 

strontium-90 or cesium-137 intakes in accordance 

with OTIB-0054 and OTIB-0060. The potential 

intakes for other radionuclides when mixed fission 

products were present could be estimated on a case-
33

by-case basis in the current internal dosimetry -- or 

internal dose tech basis.

Next slide? This was the summary or conclusion table 

that we came up with for INL, and you'll notice that 

for most everything we think that the dose 

reconstructions were feasible. You will notice from 

'67 to '70 out there are a few lines that have --

they're lighter green in color. And these are where 

we've indicated that we think co-exposure models 

are necessary during that time period. And the 

reason for that was a shift away from in vitro 

bioassay to a reliance on in vivo bioassay. 

However, at the same time they changed the 

frequency of the in vivo counting from once a year to 

every four years, which caused us some pause and 

this ended up being the impetus basically for 

developing a beta-gamma co-exposure model for 

INL.

Next slide? Okay. So again this will be the heart of 

the presentation. These are responses to the SC&A 

review that was performed in response to the 

Evaluation Report.

Thank you, John. So as Joe mentioned, there were 

three positions that SC&A evaluated. The one that 

you're looking at on the screen -- I will not read it to 

you because you've seen it, but this is Evaluation 

Report Position 1. And this had to do with 

contamination control, as Joe indicated. 

So the format for this kind of going through this is 

we've got things from the Evaluation Report that I 

have listed here. Then we'll talk about the identified 

positions that SC&A had. And then when you start 

seeing some blue text that says NIOSH response, 

that will be kind of the response to the review that 

SC&A did, or the positions that they reviewed.

So there are three sentences in that -- can you go 

back just one slide real quick? 

There are three sentences in that position. And John, 
34

if you'll go ahead and go to the next slide now. As Joe 

indicated they took that position and broke it out into 

three different positions. These were addressed

separately. And again I will not read these to you 

since we've seen them before. But we're talking 

about an internal dose monitoring program for 

Position 1(a). For Position 1(b) we're talking about 

controlling radionuclides. Position 1(c), the use of 

special bioassay.

Next slide? Thank you. So the preliminary finding for 

our assertion, the burial ground's internal dose 

monitoring program was based on a strict 

contamination control program with entry and exit 

monitoring. SC&A has questioned whether the term

strict is really an accurate term here for 

contamination control and believed that there was a 

more, in their words, haphazard inconsistent 

approach to limiting contamination during this time 

period and that there was inadequate health physics 

monitoring and little evidence of contaminationdriven bioassay.

Next slide, John? Joe mentioned the excerpt here. So 

this is when Phillips Petroleum, which was a primary 

contractor at the site, or prime contractor, took over 

operations of the burial ground. They kind of laid out 

what their expectations were for running the burial 

ground, or for running the -- operating the burial 

ground. And I included this because I think it's 

important that you know what the management 

expectations are being set out.

Basically we're asking that the burial ground be run 

just like --

(Audio interference.)

Mr. Findley: If I could get -- can't hardly hear. Hello?

Chair Schofield: Somebody mute their phones.

Dr. Roberts: Hello? Please mute --

Mr. Findley Hello?
35

Dr. Roberts: -- phone.

Chair Schofield: Yes, somebody needs to mute their 

phone. 

Dr. Roberts: Hello? Someone's phone is off mute. 

Please mute, please.

Hello? Someone's phone is off mute. Please mute, 

please. 

Nancy, is there any way to mute the phones on 

Skype?

Ms. Adams: -- line needs to be cut.

Dr. Roberts: Hello? Someone's phone is off mute. 

Please mute, please. There's a lot of interference.

Chair Schofield: You may need to have Zaida cut that 

line. That's worked in the past when this has 

happened.

Dr. Roberts: Nancy, do you know if there's a way to 

mute the phone?

Ms. Adams: There is, and I'm trying to get a hold of 

the operator to do that.

Dr. Roberts: Okay. Thank you. Hi. If you can hear 

me, if you could please mute your phone.

Ms. Adams: I don't understand why we're not getting 

service from the operator.

Dr. Roberts: Now it's on the laptop, too, so someone 

joined audio on the laptop.

Chair Schofield: Dr. Roberts, you might be able to 

mute all folks, but I don't know if you can then unmute only one person, by hitting the participant 

actions button in the lower left-hand corner.

Dr. Roberts: Okay. I can try. I don't see where I can 

do that. Again, if everyone could mute the phone.

Ms. Adams: Well (audio interference) not muted now, 
36

so --

Dr. Roberts: Yes. Would it make sense for people to 

hang up and get back in?

Hello? Please mute your phone.

Mr. Calhoun: Rashaun, I think maybe this -- this is 

Grady. This may be what John said, but if you look at 

the participants and you click on that, a box comes 

up and you can say participant action. And then you 

can hit mute audience. I tried, but I can't do it. 

Dr. Roberts: Yes, I don't see where I can do it, but 

let me try.

Mr. Calhoun: If I looked -- yes.

Dr. Roberts: Okay. No, that's not it. 

Mr. Findley: I'm not sure the person's actually on the 

Skype because it looks like everybody's either muted 

or is not -- actually has their audio turned on for the 

Skype session. I think that noise might be coming 

from somebody just on the conference line.

Chair Schofield: Yes.

Dr. Roberts: I'm wondering if we could have -- hang 

up and call back in. Would that make a difference?

Participant: Or you could say the person with the 

crying kid in the background needs to mute their 

phone.

(Laughter.)

Dr. Roberts: I don't think they're listening though.

Mr. Lewis: This is Mark. I've called in a couple of 

times, went back. If you all hung up and done it again 

--

Ms. Adams: How about if we take a couple-minute 

break and then call back in at --

Dr. Roberts: 12:30?
37

Ms. Adams: -- 12:30? Yes.

Dr. Roberts: Yes. Let's try that. Thank you. 

Ms. Adams: Hey, it's quiet.

Dr. Roberts: Now it's -- okay. Shall we continue?

Chair Schofield: Yes, it quit now.

Dr. Roberts: Yes, it's gone. Okay. All right. Do you 

feel comfortable continuing, Mitch?

Mr. Findley: Sure. I was just getting an earful of 

background noise, and I was pretty sure you guys 

were too, is why I kind of stopped. Can everybody 

hear me okay now? 

Dr. Roberts: Yes.

Mr. Findley: Okay, great. We can push through if 

you'd like, and then maybe take Ms. Beach's request 

for a mercy break after this.

Dr. Roberts: Sure.

Mr. Findley: Okay, so we were on slide 1 of 3 of the 

preliminary finding for 1(a), and this was the excerpt 

from Phillips Petroleum Company on the 

management expectations for operation of the burial 

ground. This is due again to a contractor change.

I should mention at this time, the burial ground was 

only open on Tuesdays and Fridays, from 8:30 to 

4:00. So, it had a weekly number of hours that it was 

open, about 15 hours a week. This was not open fulltime. And that Rocky Flats waste were scheduled on 

certain days during the month, so they were not 

coming in and out, the Rocky Flats waste, every day 

as well. Next slide, John.

I did fail to mention that on these response slides, 

where you see NIOSH Response to blue tags, that's 

what I was referring to earlier, that these are 

basically the responses to the SC&A positions.
38

For the monitoring practices at other INL facilities and 

the evaluation we did at the burial ground, we felt 

that the radiological monitoring was based on 

exposure to potential for workers.

In the response paper there are examples of this, 

where you'll have like a whole body count scheduled 

and a lot of it depends on where you work and also 

what you do.

So, for example, a manager may not be counted for 

a whole body count, whereas a health physics 

technician or an operator, somebody like that, will 

likely be counted at a higher frequency. There are 

also examples of this for in vitro bioassay, as well. 

Safe work permits were utilized. Idaho used this 

term, safe work permits, instead of radiological work 

permits, that's used at a lot of sites, because they did 

include some industrial safety precautions as well, as 

Joe mentioned.

However, there are places on the safe work permits 

for things like respiratory use and other protective 

measures as regarding to rad exposure.

Shipping records, again, these are examples of these 

were provided in the response paper, contamination 

surveys. Joe mentioned that the place of origin or the 

originator of the waste, did contamination surveys 

early on with Rocky Flats. They actually sent an HP 

tech with the shipment before they got to INL.

The shipments were received in the Central Facilities 

Area and went through another round of 

contamination surveys and radiation surveys, before 

being sent to the burial ground for disposal, or for 

burial. 

The documentation that we reviewed indicated there 

just weren't very many instances of contamination, 

from the records. There was one record that's 

included in the response paper where there were 

hundreds, thinking of 2-300 dpm of beta-gamma 

contamination, and even it was sent to CPP to be 
39

decontaminated. So our statement about small 

quantities of contamination not being tolerated, we 

think is borne out in the documentation. 

As evidenced in the response paper, we provided 

examples of procedures on waste burial and we found 

them back as early as 1955. 

As has been discussed several times, a health 

physicist was actually in charge of the radiological 

control and operation of the burial ground. 

Everything went through the HP that was assigned at 

a Central Facilities Area. 

In our estimation, it just kind of makes sense that if 

you're going to entrust an organization specializing in 

rad control, that strict contamination control would 

be something that would be a priority, because you 

don't want the operation becoming highly 

contaminated, because it adversely affects 

operations. We could find no data to suggest that this 

was the case at the burial ground between 1952 and 

1980.

Except for the floods, we could not find any evidence 

of suspension of operations because of poor 

radiological conditions at the burial ground. Next 

slide, John.

The photo, or the image, on the right, is actually one 

of these mass dumpings, if you will, of Rocky Flats 

waste drums. You will see these are 55-gallon drums, 

lots of them in the Sealand container. There are three 

workers to the left of the pit that these drums are 

being put into, and I put a red box around the air 

sampling head that was used. 

The motor for the air sampler is basically at the foot 

of the worker to the far left, the one to the farthest 

of the left, you'll see a little device there. That is the 

mechanical pump, basically, for the air sampler.

We were not able to find many special bioassays. 

There were some for workers that kept showing up 

on safe work permits, and we would find their names 
40

in documentation. Again, there were not a lot of 

workers that went out there and worked in this 

location that was only open a couple days a week. 

The SC&A, or as Joe mentioned, it's really difficult to 

distinguish which ones, which workers were at the 

Burial Ground versus at CFA. CFA had responsibilities 

at the burial ground, the ARA-I Hot Cell and a number 

of other areas. Just because it was not a true facility, 

it was difficult to identify them, although we think we 

have a decent handle on the primary people that 

were working out at the burial ground during this 

time. 

The issue of poly liners was brought up earlier. We 

had suspected that poly liners were used, but we 

really got these confirmed when we interviewed 

some of the former workers associated with the Early 

Waste Retrieval Project that occurred in 1976 and 

1978. This was very highly contaminated work that 

was performed, and there are interviewees which 

indicated that the tops would pop off during these 

dumpings.

There were also others that indicated that they never 

observed it. Doesn't mean it didn't happen, but the 

frequency, or the occurrence, of these is, it would be 

hard to speculate based on the interviewee 

information that they provided. Next slide, John.

The next finding was 1(b). It says, with the exception 

of Rocky Flats waste, mixed fission products were 

considered petroleum radionuclides. SC&A had 

indicated that it's not clear whether a suitable source 

term can be derived for what radionuclides workers 

may have been exposed to during specific waste 

shipments, and whether such exposures can be 

bounded by existing NIOSH methods. Next slide.

As I mentioned earlier, waste shipments were 

surveyed leaving the site of origin, and also at the 

burial ground. Also, in 1965, the Interstate 

Commerce Commission was responsible for 

regulating transport of radioactive materials, and 

they had a limit of 500 dpm per hundred square 
41

centimeters of alpha. 

In the response paper there are some small 

calculations that are made based off of resuspension 

factors, and also some ingestion dose conversion 

factors, which indicate even the 500 dpm alpha, 

we're looking at doses less than one milirem CEDE. 

This is the committed effective dose, internal dose, 

for 50 years.

There are some examples of radiological data that 

are came with the required forms for each disposal. 

Again, examples of that are in the response paper 

that we wrote. I keep referring back to it. There are, 

I think there's 68 or 70 screen shots from documents, 

excerpts from documents, and photos, that try to 

provide first-hand responses to some of these 

concerns that are direct from INL documentation.

As was common practice out at INL, when there were 

non-routine radiological conditions, INL would 

perform special monitoring. So this was not just at 

the Burial Grounds. This was implemented in a 

number of different places.

When they did that, radionuclides involved would be 

identified, again, CFA, very close to burial ground, 

those analyses can be performed there. Then they 

would request special bioassay if deemed necessary. 

As previously mentioned, there are some coexposure models that are being developed for INL. 

There are a total of seven of them, including one for 

beta-gamma contamination, and one for plutonium239. Next slide.

As Joe mentioned, one of the things that was kind of 

new with the response paper was taking a look at the 

bioassay data from the 18 workers who participated 

in the exhumation work in the 1970s, to provide a 

bounding estimate. After the SEC-00219 evaluation 

was completed, we were a little bit concerned about 

the increased exposure potential at the Burial 

Ground, because again, in November of 1969 they 

had their first waste retrieval, and there were a lot of 
42

other things getting ready to happen at the Burial 

Ground with regards to new regulations and how 

waste was handled at the Burial Grounds.

We took a look at some of these waste retrieval tests 

in the 1970s. This would be the solid waste retrieval 

test which occurred in '71, the initial drum retrieval, 

which I believe was '74 to '78, and then the early 

waste retrieval from '76 to '78.

The early waste retrieval was the one that was done 

in Pit 2, had waste drums that were in very poor 

condition, and represented the highest exposure 

potential based on the contamination levels that were 

encountered. I do recall that from the report on the 

early waste retrieval project, it stated that about two 

million counts per minute alpha was frequently 

encountered during that work.

Again, they did have a plastic suit and other 

protective measures in place, but that's a lot of 

contamination. They concluded that the available 

equipment and established safety and operating 

procedures were effective in preventing personnel 

exposures.

So, again, we think that using these 18 workers 

would be bounding for the 1952 to 1970 period, 

where it's literally just disposal of waste where you're 

digging trenches and pits, putting waste in it and 

covering it with soil. Next slide, John.

The last of the Position 1 findings had to do with the 

workplace indicators. Again, this was kind of the 

paucity, if you will, of special bioassay at the Burial 

Ground, and the limited use and unreliability of 

available alpha monitoring instruments. Next slide.

Getting back to this special bioassay issue, there are 

examples in the response paper of special bioassay 

for workers that were assigned out of CFA that were 

routinely working at the Burial Ground. It just does 

not say, look for facility Burial Ground. It says CFA. 

So we do have, again, a list of names that we've 

complied while reviewing lots of documents.
43

One of the things that we did in reviewing of the 

documents on hand was, we took a look at the 

Central Facility Area health physics monthly reports. 

These were put together every month, and these are 

the ones for Central Facilities Area.

We have a section in there on the Burial Ground, 

which included off-site and onsite waste disposals, 

and we've got about 58 percent of the monthly 

reports for the time period between 1952 and 1970. 

So we've got roughly 130 of these things. Table 1 of 

the response paper has got a complete accountability 

for which ones we have and do not have.

We looked at those and really found almost nothing 

regarding contamination events being reported in the 

CFA monthly health physics reports. It is our 

assertion that if contamination events had been 

commonplace, especially during the drum dumping, 

it's highly unlikely that this would have persisted over 

almost a seven-year period. We think special 

bioassay would be much more easy to identify. 

There's just not much, and there's really very few 

indications in the monthly reports about this, as well. 

Next slide.

This is an example of a whole body count on the right, 

about how it's difficult to identify a Burial Ground 

worker. You'll see, in a red box there is a craft or 

profession and it says, yardmen. As we've described 

in previous meetings, these were basically laborers 

that were farmed out to different locations on site to 

perform labor. 

They were extensively used out at the Burial Ground, 

and at the bottom of that red box you'll see that the 

work area is listed as CFA. That's about as close as 

you're going to get to identifying somebody as a 

Burial Ground worker. There were certain 

occupational titles which were very commonplace out 

at the Burial Ground, with the yardman being one of 

them. Okay, John, next slide.

That's the end of Position 1. The finding for Position

2, in the evaluation report we had determined that 
44

we thought internal exposures at the Burial Ground 

were directly related to the materials being disposed 

of in the ground. Up until that initial drum retrieval in 

November of 1969, that the potential was virtually all 

from mixed fission products that was being buried at 

INL, and any of the off-site stuff, it was primarily 

plutonium from the Rocky Flats plant.

You'll see the SC&A response down at the bottom 

there. We discussed this before. I will not read that 

to you. Next slide, John.

So, our response here again is we propose that we 

take the bioassay data from these 18 workers that 

we identified during this highly-contaminated 

exhumation work in the 1970s, primarily the early 

waste retrieval work. We identified these when we 

were looking at whether we needed to do an 83.14 

Evaluation Report for the Burial Ground in the 1970s.

We believe that the bioassay data provided the 

bounding estimate, as we, again, think that there 

was a much higher exposure potential doing that type 

of work versus waste emplacement. 

OTIB-60 allows for the application of co-exposure 

data. Again, I mentioned a number of co-exposure 

models are being developed. We hope to have the 

OTIB for the models finished up by the end of this 

calendar year, so good progress is being made on a 

very difficult and technical development of these coexposure models.

We have not taken a look yet at the SC&A concern 

over the use of cesium-137 and strontium-90 as 

indicator radionuclides. I did want to mention that. 

The last preliminary finding, our last position, we 

indicated that we thought the radiological monitoring 

program at the Burial Ground was quite good. It 

included, basically, management by the health 

physicists, safe work permits for all waste disposals, 

personnel surveys were completed at the end of 

work, air monitoring was performed, and 

decontamination was performed, at CPP if needed.
45

I failed to mention at the beginning of this, but one 

of the things that INL did before start-up of 

radiological operations is, they went to other sites 

that had some experience with operation times, to 

basically pick their brains and to bring back good 

ideas, talk to them about what worked and what 

didn't work. 

And so, they had that, the experience of others to 

lean on when they were setting up their rad 

protection programs at the site.

SC&A, again, the word there is checkered with the 

rad program at the Burial Ground, and doesn't 

believe that we should be able to claim that it 

precluded any unmonitored plutonium uptakes up to 

1970. 

The defense-in-depth that we have pushed forth is 

not evident, based on their review. I think Joe 

mentioned that we seem to have opposing views of 

the same information, so I think that's a very fair 

assessment.

Other concerns that were stated by SC&A, they were, 

again, late in this time period of evaluation. I think 

that assessment was actually in '71. They were 

concerned about the conflicted role of the HP at the 

Burial Ground. I can understand that at that 

particular time.

Regarding lack of management support for the Burial 

Ground, again, it just is not evident in the 

documentation. They do mention funding for 

contamination detection equipment.

What I want to do now is just kind of go over some 

of these changes that were occurring in the 1969-

1979 time period, because they really weigh heavily 

on what was going on at the Burial Ground. This was 

a real time of transition for the area, or location, I 

should say, wasn't even an area by then. 

So, just going through the little dashed items up 

under the first sentence up there, the reorganization 
46

of the Burial Ground was not really due to poor 

radiological controls. The facility was transitioning 

away from these simple, low-risk burials to aboveground TRU storage, waste retrievals, and other 

operations as well.

In fact, to this day, those waste retrievals and other 

operations are ongoing. If you take an area, if you 

look up an aerial view of the radioactive waste 

management complex, the RWMC, which the Burial 

Ground is known as now, it is stunning, the 

transformation between the photos that I showed 

you at the beginning of this presentation in 1970, and 

what it looks like now. It's completely different.

In May of 1969 there was a fire at Rocky Flats, which 

dramatically increased the waste shipments to the 

Burial Ground. Idaho Senator Frank Church got 

involved in that. That became a real hot potato for 

what to do with this waste. They did not want it just 

to keep coming into the state.

The other flood occurred in 1969, as I mentioned 

previously. The first federal environmental legislation 

was passed in '69 as well, the National Environmental 

Policy Act. In addition to that, the AEC wanted to 

develop some long-range policy standards and 

criteria management for AEC waste, so you can see 

there are a number of factors that are playing into 

going from a fairly simple disposal operation into 

something much more complex. Next slide.

We don't believe that Burial Ground was a lowpriority by INL management. We did interview the 

Burial Ground [identifying information 

redacted] during one of our interviews, and that did 

not come across when speaking to him.

Speaking of interviews, I think the suggestion that 

we go back and take a look at all of the interviews 

that were performed, and there were a number of 

these, that they go back and be looked at in toto is 

an excellent idea. Take a look at all of the interviews. 

Some of them will conflict, and just take a look at 
47

what the preponderance of the opinions were on 

operation of the Burial Ground.

Again, it is our belief that the burial operations were 

low-risk activities, and the later waste retrieval 

activities were a little bit more involved and 

represented in increased exposure potential. Next 

slide.

This was the preliminary conclusion that was 

provided for the Burial Ground from the SEC-219 

evaluation report. Basically, that the defense-indepth approach and available internal dose data to 

the known radioactive source term, the term there 

says, fall short, given a review of the available 

documentation and interviews. Next slide.

Again, we did an extensive review of a number of 

documents. I've mentioned the CFA monthly reports. 

We also looked at the CFA HP logbooks, which would 

contain information about the Burial Ground 

operations and also log sheets, and did not see 

contamination as being a common occurrence at the 

Burial Ground.

We believe that the Burial Ground was properly 

managed, and that most of the interviewees were 

favorable about the (telephonic interference). Again, 

there were some dissenting opinions, but if you take 

a look at it you can come to your own conclusion. 

One of the things that surprised us when we were 

doing the 83.14 determination of the 1970s was that 

a couple of workers indicated that the Burial Ground 

was actually a preferred area to work at. That caught 

us by surprise. We did not think that that would be 

the case, but yet it was stated. Next slide.

Listed at the bottom of this slide here are some of 

these occupations that I mentioned earlier that were 

typically associated with Burial Ground work. In 

particular, if you look at labor or yardman, equipment 

operator, and heavy equipment operator, we found 

that these three, we were told that they were 

basically the same occupation ladders. That 
48

somebody came in as a laborer or yardman, got 

promoted up to an equipment operator, then became 

a heavy equipment operator. 

That's why those three are often seen with the Burial 

Ground work. Obviously because those, the labor and 

the equipment, are needed for the types of work that 

are being done out there. Then we also have truck 

drivers, and HPs as would be expected as well. Next 

slide.

There was no routine bioassay program at the RWMC 

until 1978. Special bioassay was described as 

necessary per professional judgement by the health 

physics, and the Burial Ground workers from '52 to 

1970 would have dose contributions from mixed 

fission products, using these co-exposure models 

that are being developed as well. Last slide.

Again, I reiterate that for the actinide dose 

reconstruction, we propose using the bioassay data 

for those 18 workers that participated in this highly 

contaminated waste retrieval work in the 1970s. We 

believe that this will provide a bounding estimate.

Lastly, the Tech Basis Manual for internal dose for INL 

and ANL-West, it'll be revised when we incorporate 

these changes and get these co-exposure models 

finished.

John, that's all I have.

Mr. Cardarelli: And that's the end of this 

presentation, Dr. Roberts.

Mr. Findley: There was mention about Bob Barton 

following this?

Mr. Cardarelli: Oh, yeah. 

Dr. Roberts: Yes. I wanted to see if the Work Group 

Members had any questions or comments about this 

presentation.

Member Beach: Yeah. Do we want to take a break 

first, though? We've been at this for a couple of 
49

hours. Just a question.

Dr. Roberts: Sure, yes. But I did just want to 

entertain any questions, and then after the break we 

can start with a new presentation, if that's okay?

Member Beach: Well, I have a couple of questions. 

This is Josie. 

Dr. Roberts: Go right ahead.

Member Beach: Okay. If you go back to the Slide 16, 

the original contract, your answer was, or to the 

haphazard suggestion?

Mr. Findley: Right. This was the excerpt out of the 

Burial Ground operations memo?

Member Beach: Yeah. I was just wondering what the 

actual practice was. This was original management 

responding to the new contracts, right?

Mr. Findley: Correct.

Member Beach: And I don't know, from my 

experience they don't usually or necessarily carry 

over to later contracts.

Mr. Findley: Right. We could not find anything in the 

SRDB related to management expectations prior to 

1961, other than the procedures that were in place. 

Those went back to, I believe, 1955.

Member Beach: Then if you look at slide 17, talking 

about the procedures, as an operator for 32 years out 

at Hanford, I know that the procedures didn't always 

equal the practices. I guess, for that first bullet, 

monitoring practices, you say that other INL facilities 

were being used.

Those were so different. I mean, we're talking 

reactors, CPT, they were all different. How do you 

know that this, how do you know those training 

practices went over into the Burial Ground?

Mr. Findley: Well, they had these standard operating 
50

practices, I think is what they called them, and in 

them they would list, the one that I mentioned by 

example was the whole body count schedule. They 

would have a whole body count scheduled, for 

example, for CPT or for TRA or for Test Area North, 

and there was one for CFA as well. The Burial Ground 

was not listed on there. The extension of that logic is 

that they did not think the exposure potential was 

warranted by routine bioassay.

Member Beach: And the next bullet kind of goes into 

that, the safe work permits, shipping records, how do 

we know that they were adequate and implemented? 

I guess that's the key, is where's the proof of the 

implementation of those documents?

Mr. Findley: I think the proof is in, basically, the lack 

of contamination events that we were able to find, 

looking at monthly reports and logs and bioassay 

records. Just of, they just aren't there.

Dr. Taulbee: Josie, this is Tim. I just want to chime 

in a little bit here. If you look at how the rate rad 

monitoring was done at the other facilities, 

specifically talking about the air sampling, 

occasionally, on an as-needed basis. Do those seem 

different between that type of operation and what 

they were doing at the Burial Ground? 

You've got a new facility, whatever was brought in 

the Rocky Flats drums to be dumped, they set up air 

monitoring for that. They monitored those people, 

they did contamination surveys of the drums coming 

in, they dumped the drums and took air samples 

during it, and then after everything was done they 

monitored the people going out. 

They were all wearing PPE at those times, when they 

were dumping those Rocky Flats type of drums. So, 

that's what we don't see any difference with. 

Member Beach: Yes, Tim, and I see that on slide 19, 

but there's only one air monitoring in that photo. In 

this particular picture, it depicts how they're 

haphazardly dumping those drums, with only one air 
51

monitor, not really in the area where the workers are.

And then we've also seen pictures where they're 

dumping or moving around in the drums with no 

protection, no whites, they're just in their street 

clothes or blue coveralls. 

Dr. Taulbee: Okay. I'd like to see some of those 

pictures, because we do have a tremendous number 

of pictures of people being monitored as they're at 

the Burial Ground, and the people doing the work 

were actually wearing PPE, wearing the anticontamination clothing. There are people in street 

clothes, but they're not doing any of the work. 

They're more observing, from the pictures that I have 

seen, from that standpoint.

I think the key to this is back to James' request was, 

and what Joe mentioned and what Mitch mentioned 

here and that's to go back to those interviews and 

look at what those workers were describing at the 

area and how things were being conducted at the 

facilities. I think that if you go through all of that then 

I think it will paint a more complete picture.

Member Beach: I almost wonder if it raises to the 

level of actually pulling all those interview notes out, 

since they have been so heavily discussed, and 

actually having some kind of a memo or paper written 

on them, to bring them all into one spot. I mean, I 

know I can go into SRDB quite easily, and look at all 

those documents, but I'm not sure if all the Work 

Group Members are so inclined. It might be 

something to think about, Phil.

Chair Schofield: Yeah, I agree. I think that would be 

a good idea, and I had a question, too. A lot of these 

drums are coming in. Did they wear TLDs? What was 

their exposure? Some of these drums are going to be 

obviously very hot internally, throwing off a lot. 

Others are going to be very mild and basically there's 

almost no exposure to the skin of the drum.

Were these documented? Did they wear dosimeter 

pins on their wrists? Were they using dosimeter pins 
52

or using TLDs? What was their monitoring?

Dr. Taulbee: Phil, this is Tim to answer that. I can 

take it. Everybody going into the Burial Ground had 

to wear a film badge dosimeter or a TLD. In this 

particular time period it was primarily film badges. 

So, everybody coming in, if they were a temporary 

worker then they were badged and given a film badge 

dosimeter to come into the facility. So all of the 

external monitoring was conducted there.

(Simultaneous speaking.)

Chair Schofield: Okay. Just one other question while 

I'm still thinking about it. On their TLDs, I know it's 

been practiced at some facilities, basically when they 

read the TLDs they're really looking maybe for 

neutron exposure or gamma exposure, and they're 

not really paying a lot of attention to the other 

exposure. Generally, when their badges were read, 

did they read them straight across the board? You 

know, we're looking both at your gamma exposure 

and your neutron exposure?

Chair Schofield: I know they were looking at the 

gamma exposure and the beta exposure. I'm not 

sure of the neutron exposure, but I can't imagine that 

it would be significant. And the reason that I say that 

if you look at that picture of the drums being 

dumped, people are standing quite a distance away 

from there and there just isn't going to be much 

neutron or gamma exposure from that. 

It's more when you're directly handling the drums, if 

they were placing them in individual locations, that 

was when they were receiving more of the external 

dose in the earlier years, and at that time there's very 

little internal exposure potential. But I'm not sure of 

the neutron monitoring in those very early years. But 

we can get back to you on that.

Chair Schofield: Okay, thanks.

Member Beach: This is Josie again, Tim. So isn't the 
53

issue internal, and there are no bioassays? There's 

sporadic air sampling. You also have uncertain source 

terms. And I know you're saying, according to this 

picture, yes. They are standing a bit away, but 

they're not always that far away. This picture doesn't 

depict everything that happened at the Burial 

Ground. We've seen pictures where they're much 

closer to the waste.

Dr. Taulbee: There are several questions there.

Member Beach: Yes, sorry.

Dr. Taulbee: Could you go back and repeat the first 

one, because I had the answer ready for that one.

Member Beach: The issue is internal, and there's no 

bioassays with the Burial Ground. 

Dr. Taulbee: There are bioassays. There's a special 

bioassay that we can't explicitly put to a person in 

the Burial Ground. We find special bioassay for 

people who worked at the Central Facilities Area, and 

Mitch showed an example of that in his presentation. 

If you look carefully at the one slide that shows a 

whole body count request, it's a special bioassay for 

an individual.

We can only tie it to Central Facilities. It could have 

happened over at the Hot Cells, we don't know, but 

we have a pool of special bioassays for people at the 

Central Facilities. Some of those are very, very likely 

to be from the Burial Ground. We just can't find 

anything that explicitly says Burial Ground, because 

that really wasn't a facility. The Central Facility 

controlled it. 

So there is bioassay on a special basis for Burial 

Ground. There are air samples associated primarily 

with burial of the Rocky Flats waste, which is the 

alpha contamination hazard that they were well 

aware of. So there is the air samples, there is the 

bioassay.

What we're proposing for dose reconstruction is to 
54

use the bioassay for people who extracted the waste, 

who were going in and digging up the waste from the 

initial drum retrieval, from the early waste retrieval 

projects, and using their bioassay and applying it to 

people who worked at the Burial Ground. We feel that 

when they went back in to dig it up, that was a much 

higher potential for exposure, and that that would be 

the bounding scenario.

So that what Mitch has been pointing out throughout 

his presentation. Those early years were a very 

simple dumping type of operation. You put the drums 

in, dump them into the pit, and you run over it with 

a bulldozer, cover it all up with soil using a bulldozer, 

and there were times when they run over it, and they 

would compact it further and put more dirt on. That 

was the operations.

Now, when you go back in and you start digging up 

those same drums after these floods, there's going 

to be a higher potential for exposure. And that's the 

bioassay that we are proposing to use through this 

entire time period.

Going back to those interviews in total, and looking 

at what the workers had to say, I think is a great 

idea. We can compile that information as you are 

requesting. It's not, I'm not going to summarize any 

of it, we're going to put it together for you all into 

one location, so that you have it, you don't have to 

go searching through the SRDB.

I think when people try to summarize it, you have a 

tendency to try to put your own opinion into that, and 

I think you guys reading the original interview 

summaries that were reviewed by the interviewees 

that said, I agree with this, is very important for this 

work.

Member Beach: Okay. A couple of your points. So, 

there's really no way to officially tie the bioassays to 

the exposure at the Burial Ground in the earlier 

years. You have no actual way of tying that, is that 

correct?
55

Dr. Taulbee: That is correct.

Member Beach: And then, the 1970s, I guess I 

question how representative that is, because the way 

that work was conducted was so different from the 

way it was conducted in the '50s and '60s, up into 

the early, or I should say the late '60s when the AEC 

did their report and found numerous issues with the 

way work was being conducted at the Burial Ground. 

I guess I have questions about the 1970s as being 

representative to those earlier years.

Dr. Taulbee: I think that's what Bob is going to 

present next, about that. The one thing that I would 

say from that standpoint is, there are differences 

between the different waste retrievals. I believe the 

initial drum retrieval was very similar from a 

monitoring standpoint to what you see with the 

dumping of the drums in the 1968 time frame.

So there's very good similarities between those two. 

That's something to consider. Anyway, Bob's got his 

whole presentation to do.

Member Beach: I understand. And so, Tim, NIOSH is 

going to take on putting all the interview notes in one 

place. Can you reference all the SRDB numbers in 

that report also, in case we want to go back and 

verify some things ourselves?

Dr. Taulbee: Oh, absolutely. Absolutely. In fact, I 

envision these all being combined into one PDF file. 

We will pull the SRDB documents out and put them 

directly into one file for you. It might be two or three 

volumes, but we'll see.

Member Beach: And I feel like I'm hogging the floor 

here, but I've got one more comment on slide 32. 

The last bullet, Mitch said that several interviewees 

during the 83.14 determination indicated the Burial 

Ground was an actual preferred area to work. From 

my experience, I would say that would be true, 

because there was such little management oversight 

that it would be a good place to be --
56

Member Anderson: Left alone. 

Member Beach: -- perspective. Was that you, Henry?

Member Anderson: Yes. 

Member Beach: I didn't catch what you said. 

Member Anderson: Oh, I said, because they were left 

alone.

Member Beach: Yes, yes.

Member Anderson: There was nobody there, pointing 

out the things.

Dr. Taulbee: I would only encourage you to read the 

actual interview and come to your own conclusions 

with regards to that.

Member Beach: Right, okay.

Dr. Roberts: Okay. Are there any other questions? 

It's been a while, so I'm thinking we need to go to 

break for maybe 15 minutes. Would that be sufficient 

for people?

Member Anderson: I have one short question.

Dr. Roberts: Sure.

Member Anderson: And that is, throughout this we 

hear that this was considered a low-risk burial, and 

what I'm wondering is, what's the documentation 

that it in fact was low risk, continuously? And the 

assumption is, all the burial pits at that time, for 

general waste like this, typically were considered low 

risk, and then when we get to the '70s all of a sudden 

there's a recognition of the risk being recognized 

there.

So, it would be nice, I couldn't tell if there were 

surveys that were done to document that in fact that 

assumption was correct.

Mr. Findley: Well, the air sampling data that we have 

from some of these are not showing any significant 
57

contamination. However, as Mitch was pointing out, 

when they went in and started digging up some of 

these drums where the drums had breached, and 

digging out some of that, the contamination levels 

are incredible, or not incredible, but in the millions of 

dpm type of range.

So, that's where some of the basis of this comes, but 

a lot of it comes from just general observing and 

thinking about what is happening. You've got drums 

that are surveyed below a certain contamination level 

that are being dumped into a pit, they go down and 

they're covered up from that standpoint.

Did some of them rupture at the time? Possibly. In 

fact, it was likely maybe one or two of them did. The 

pictures that you look at, though, of the massive 

amounts of drums being dumped, don't show a huge 

number of drums being breached from that 

standpoint. You look at some of the pictures, most of 

them are intact before they're covered up from that 

standpoint.

That's why we envisioned that they were considered 

to be low risk. You go back in and start digging them 

out, after the floods, after they've been sitting for ten 

years, after they've been deteriorating, that's when 

the risk was much higher. That's the bioassaying 

data, of those workers, is what we're proposing to 

use.

Member Beach: Tim, weren't most of those workers 

all in bubble suits?

Dr. Taulbee: For the early waste retrieval they were, 

but for the initial drum retrieval, no, they were not. 

And Bob's got some pictures showing that in his 

presentation. But I think we should take a break now 

and then get back to Bob's presentation.

Dr. Roberts: Why don't we do that? And since it's 

about 1:20, why don't we come back at about 1:40 

and resume? 

(Whereupon, the above-entitled matter went off the 
58

record at 1:19 p.m. and resumed at 1:41 p.m.) 

Dr. Roberts: Okay, great. I think that may be just 

about everybody. And I see that Bob has his 

presentation up. So let's just continue along.

Mr. Barton: Great. Thank you, Dr. Roberts. And good 

afternoon, everybody. Or, I guess, Josie, it may be 

still good morning. But that conversation that was 

going on just before the break is actually a pretty 

good lead in to what I'm going to be briefly 

presenting here.

As you can see, for those of you on Skype, I do have 

a slide up here, which is a strange sort of an outline 

of what I'm going to be talking about. This is actually 

a new 508 requirement for us, and it looks a little 

strange.

But as you can see, I only have five slides and two of 

them are photographs. So hopefully this will go 

quickly so we can get right back into that 

conversation.

So anyway, as was discussed during the previous 

NIOSH presentation, the proposed method for 

reconstructing transuranic, doses of the transuranic 

material, and we're really talking about that Rocky 

Flats material in the pre-1970 era, is to use bioassay 

for 18 workers who were involved in the drum 

retrieval operations that were occurring in the 70s.

So there were 18 workers, and we have both 

urinalysis and fecal results for those 18. There were 

samples in the late 70s, the '77, '78 time frame. And, 

again, we're mostly associated with those drum 

retrieval operations, which we'll see in a second.

So this next slide, and this is Table 1 in SC&A's 

report. And I'm on Slide 10 because I was following 

on the online presentations.

This is basically just a table that shows the makeup 

of these 18 workers. And you can see we have 

basically four job categories. We have health physics, 
59

equipment operator, labor, supervisor.

And, actually, as Mitch mentioned in his presentation, 

it's not surprising that there were so many equipment 

operators because that was really the sort of typical 

career track. You would start out as a yard man, be 

promoted to a laborer, then promoted to equipment 

operator and then eventually heavy equipment 

operator, which I would assume is included in both. 

Both of those are included in the equipment operator 

category here.

So these job titles make sense. And if you look at the 

column headings, we have the initial drum recovery 

and early waste retrieval operations. Those are the 

drum retrieval operations that we're talking about.

And then you have a few workers who were just 

classified, again, by the site as just general 

operations at the RWMC.

If you look along the bottom line there you can see 

it's split right into thirds between the initial drum 

recovery, or IDR, the early waste retrieval, or EWR, 

and then the general operations.

So our next slide, and this is where we want to kind 

of talk about what was going on in those drum 

retrieval operations. And the real issue from SC&A's 

standpoint is how relatable are the exposures that 

those workers experienced during these retrieval 

operations, how relatable and really the buzz word in 

this program is how representative are those 

exposures to what might have been experienced 

prior to these retrieval operations for that period 

we're trying to reconstruct.

What we have here is a photograph of the inside of 

what's known as the operating area containment 

structure. This is part of the early waste retrieval 

operations. And, you know, one thing I think, and 

even Tim mentioned, one thing that's great about 

Idaho is they photographed a lot of stuff. So there is 

a lot of great photographs like this one to really get 

an idea of what was going on.
60

So you see this operating area containment, you see 

everybody is in bubble suits. You can see the supply 

air hoses. I believe that might be a continuous air 

monitor possibly in the right corner. As you can see, 

they're digging into the ground, again, retrieving 

some of these drums that were really in pretty tough 

shape.

Now this operating area, I guess, its confinement 

structure, it was actually this modular metal building 

that was within what was known as an air support 

weather shield. It's basically a big inflatable building 

that covered over the top of this metal building.

There are actually three different, I guess you would 

call them changing rooms just to get in and out of 

this metal structure where the digging is actually 

taking place, three different rooms to come in and 

three different rooms to basically dress out to leave 

the structure. So there was a high level of control 

over contamination going in and out of this.

We know there were at least 10 continuous air 

monitors that were associated specifically with this 

early waste retrieval. Six of them were actually inside 

this metal building. You had two more on the outside 

of the building in case any contamination escaped. 

And also two that were on the HEPA filters that were 

filtering the air coming out of that building.

So as you can see there's a very high level of 

sophistication and contamination control and 

radiation protection that was going on with this 

operation. And, again, that's the EWR.

The other major drum retrieval operation that these 

18 workers, again, these 18 workers had been 

proposed to use for dose reconstruction, here's two 

photographs from the IDR, the initial drum retrieval.

The top photograph you can see what I assume would 

be a health physics tech. He's monitoring the outside 

of one of the drums that has been retrieved. He's in 

full anti-Cs. It looks like it was taped around the 

hands and feet. And he has a half mask respirator 
61

strapped around his neck.

And what we learned from the interviews is they 

didn't actually have to wear those full-time, but 

basically because they had so many monitoring 

devices and instrumentation around, if there was any 

indication of a breach of those drums or any airborne 

contamination, those alarms went off, the half mask 

went on and a lot of times they would even evacuate. 

And that would even be for alarms that might go off 

just because of elevated radon or thoron in the area.

So, again, a very high level of sophistication with the 

health protection program during these retrieval 

operations.

The bottom half of that photo shows again another 

tech. It looks like he's working on one of those 

continuous air monitors, which is placed in the air of 

one of the retrieval pits.

So, again, the question is did the workers, who were 

involved in this type of activity, is the exposure 

potential that they experienced relatable or 

representative of what could have been experienced 

prior to this 70s operation when the burial ground 

really became the radioactive waste management 

complex.

So that's really the gist of our main concern here. 

And for those of you on the phone and maybe not 

able to see the presentation, what I have here is just 

a quote that pretty much summarizes NIOSH's 

position on the subject, which is that they would 

consider it bounding because these burial activities 

would have had a much lower potential for 

contamination and therefore a lower potential for 

internal exposure than the unearthing activities that 

took place.

And we certainly agree that the contamination levels 

and the potential for airborne activity are certainly 

bounding. When you are pulling these drums up, 

some of them are ruptured, especially in that EWR 

building, where they're all in bubble suits. But the 
62

point is, they were in bubble suits.

So our question is while the nature of the 

environment, radiologically speaking, is definitely 

more hazardous, is the potential for actual uptake of 

these contaminants also bounding?

And that's really the question that's sort of a 

balancing act. Yes, we totally agree there are 

elevated more hazardous conditions during these 70s 

operations but also the oversight, the radiological 

control, the interest by management, things such as 

that, was also quite different.

One other thing I would point out about this, this 

topic came up -- Gen, you pointed it out earlier --

while the interviews that occurred were for the time 

period prior to this that we're talking about 

reconstructing were often contradictory.

You had differing accounts of what contamination 

control measures there were and health physics 

oversight. As many of you know, because I 

remember you were at the table for these interviews, 

during this period of drum retrieval, the interviews 

were remarkably consistent.

There was a small dedicated workforce that was 

highly trained to do this work. The work was 

performed. They all said it was a high level focus on 

safety.

As I said, there was a lot of interest at the time with 

these projects. I believe a few interviewees 

mentioned there was an observation window in 

which, you know, management would come through 

or even some politicians might come through just to 

witness what was going on with the safety measures 

that were in place.

They also mentioned that during this time of the 

drum retrieval, there was a high reliance on the 

health physics staff, and there was a high level of 

confidence that they were being protected there.
63

And also that health physics coverage was almost 

universally said to be continuous. They were always 

there. They were always monitoring.

And so, again, the issue for SC&A, and this is my 

second bullet here, although the contamination 

certainly would be considered bounding for these 

retrieval operations, we're concerned is it really 

relatable considering differing levels of actual health 

physics oversight, contamination control and 

protection measures?

Now I have one more slide here. And this is -- I put 

it in here because it was in our report. So I sort of 

felt obligated to talk about it. Right now I kind of wish 

I didn't.

But if we decide that the exposures during these 

retrieval operations are relatable, that they can be 

considered representative or bounding of that earlier 

period, we're just pointing out a couple things about 

how that data for the 18 was actually used to 

eventually model an intake rate and how the dates 

you choose to start and end the model intake period 

can have a significant effect on what that intake rate 

is.

Now it may be that the calculation shown by NIOSH 

when they originally proposed the method of using 

the 18 workers as a co-exposure model was simply 

an example. But in any case, this is in our report so 

I wanted to mention it. But I would consider this 

largely what we say is a Site Profile type issue rather 

than an SEC discussion.

So, again, to sum it up, our main concern is can we 

really use data from these workers who were 

monitored in the late 70s under much different 

conditions?

Both radiologically, they were more dangerous 

conditions. But from a safety aspect, they were much 

more stringent. And so how representative is the 

data for these 18 workers in the guise of using it for 

burial ground workers prior to this when it was a 
64

much different area?

So that's really all the slides I have. I'd love to 

entertain any questions.

Member Beach: This is Josie. I do have a question on 

your earlier, well, your first or your second slide, if 

that's okay. 

Mr. Barton: Sure, Josie. Do you know what number 

slide that was?

Member Beach: No. Because on mine it doesn't show 

the numbers. It was the very first one you presented. 

And I don't really the slide up.

But my question is, and I don't know if you can 

answer this or Tim or a combination. I'm curious, and 

it struck me when I read this report, is how 

representative are the 18 workers?

If you look at the list, you have health physics, 

equipment operators, heavy on the equipment 

operators, very light on laborers. And to my 

knowledge and experience with these types of 

operations, you're going to have a lot of labor force 

working inside the entry tents, exit tents, cleaning up 

waste. And so I guess it's light on the laborers.

How representative would these monitored workers 

really be?

Mr. Barton: Well, I can only -- go ahead, Tim.

Dr. Taulbee: No, go ahead, Bob.

Mr. Barton: I was going to say I guess I can only 

speculate that they were chosen because it was such 

a, I guess, for the burial ground a very high level 

operation. And as I mentioned, the equipment 

operators were sort of more senior people.

You would start -- again, the typical career track that 

we heard from several interviewees was that you 

start out as a yard man and then you became laborer 

and then you became an equipment operator.
65

So one possibility, and this is sheer speculation, is 

that they had equipment operators doing more laborlike tasks simply because they had more experience, 

and they were really the more senior employees. 

That is pure speculation. I don't have any information 

to that effect.

Dr. Taulbee: This is Tim. That is actually along the 

same lines as I recall during the interviews. It goes 

along that career path, if you will.

And they also indicated that the equipment operators 

did a lot of the hands-on work directly related to the 

running of what I consider heavy equipment. But 

they had a different definition of heavy equipment 

versus equipment operator type of scenario.

So there's a blending going on there and then the 

actual job titles themselves. They're going to be 

changing as people were promoted up.

So, you know, in essence you can really lump those 

two in together in my opinion. But, again, that's just 

my opinion from what I recall with the interviews. 

But, again, if you read back through the interviews, I 

think you will get a better feel for that. 

Member Anderson: Do we have an idea of how many 

total workers were involved in these kind of -- the 

burial or retrieval process? I mean, is the 18 

representative of how many workers?

Dr. Taulbee: Yes. The 18 is representative of the 

workers. As I recall, Mitch, and correct me if I'm 

wrong here, but the total number of people 

monitored at the burial grounds in this time period 

was around 30 to 40? Is that correct?

Mr. Barton: That is correct, Tim.

Dr. Taulbee: And a large number of them were over 

at the Transuranic Storage Area. Inside these two 

operations that were going on simultaneously, the 

IDR and the EWR, the initial drum retrieval and the 

early waste retrieval, they were small dedicated 
66

crews that were doing this. So these are very 

representative, at least in my opinion, of the workers 

in that time period at that area.

Mr. Barton: I guess I would just add to that, you 

know, in the documentation that identified these 18, 

it was a targeted sampling for the purposes of 

determining not only had any intake occurred, but to 

also establish baseline levels of lung burdens or body 

burdens that could be used to affirm later intake 

should they occur but also to look retrospectively but 

also to establish a baseline.

So they did make an attempt to really target the folks 

that they felt at the time would be most at risk for 

these retrieval operations.

Member Anderson: Okay.

Dr. Taulbee: Could I ask you, Bob, to go to Slide 12? 

And this is something I'd like to point out where we're 

in a bit of disagreement here with SC&A. And, again, 

I would encourage everybody to go back and to read 

the interviews when we send them out to everyone.

But the lower picture here, where the individual is 

working on the continuous air monitor, I want to 

point out a few things when he did his presentation.

But the air sampler is positioned there near the edge 

of where the pit has been dug. When you look, you 

can see the top of the excavator down in the pit. 

There would be a worker down in there. This is 

retrieving the drums from this area.

And you will notice the worker who is working on the 

cam there. He's wearing an anti-Cs. He's wearing a 

hard hat, he's wearing shoe covers, as pointed out.

And if you recall back to Mitch's presentation on Slide 

19, which is the dumping of those drums going into 

the pit where they're standing there at the edge of 

the pit and the air sampler is there again at the edge 

of the pit. They're all wearing PPE coveralls with shoe 

covers. They're all wearing hard hats.
67

You don't see a big difference here in the monitoring. 

Yes, the air sampler is much more sophisticated here. 

It's a cam instead of a filter paper, but the same 

general purpose is there, of monitoring the air that 

would be coming up out of the pit.

In this particular case, there's somebody down in the 

pit. In the other examples that we were looking at, 

there aren't, I guess, in a sense, other people milling 

around.

Here we've dug into contaminated soil where drums 

have been sitting for 10 to 15 years. And we've 

retrieved some of those drums and they're continuing 

to do that. So this is why we feel this is the more 

hazardous work here. And the monitoring isn't that 

different from that standpoint.

Yes, the instrumentation is more sophisticated. But 

the basic premise of monitoring the air and protecting 

the workers through PPE to keep contamination off of 

them is the same.

In this particular picture, we're using the bioassay 

from these workers here working down there in the 

pit, recovering these drums that have been 

(telephonic interference) as the basis for the dose 

reconstruction for that earlier time period where they 

were just dumping it.

Chair Schofield: A quick question. Did they ever 

check the levels of radon when they were down in the 

trenches?

Dr. Taulbee: I don't believe so. We do have evidence 

of them checking the radon levels on their air 

samples and letting them decay off when they were 

doing some of the smears. But, you know, if you're 

wearing a plastic hard hat, you're going to get radon 

on one. And so, you know, you've got to let them put 

tape on.

So there was some of that reference within SC&A's 

report of the individual talking about the conflicts of 

operations and health physics team, that conflict of 
68

interest. There's a paragraph there that discusses 

that. And the example given is actually monitoring 

for radon in that sense, of letting it decay off. But the 

actual (telephonic interference), especially when 

you're talking about just to be fluid in the --

Dr. Roberts: I can hear some interference. Excuse 

me. Is everyone on mute, please? Thank you.

Dr. Taulbee: And, Mitch, please jump in if you know 

of any additional data on that.

Mr. Findley: No. I believe your response was correct, 

Tim. Mr. Schofield, I don't recall ever seeing any air 

results where they were specifically monitoring for 

thoron. It was always typically this natural decay 

products showing up on the air filters and then letting 

them decay off so they could, you know, measure for 

the occupational radionuclides of interest.

Chair Schofield: Okay. That does bother me a little 

bit. Okay. Thanks.

Dr. Taulbee: One thing to keep in mind, Phil, is that 

when you think of the operations in those earlier 

years up to 1970, it's dumping waste into open pits. 

There aren't any buildings or anything along those 

lines. So this is right off on the plains of Idaho type 

of scenario.

And there is early measurements before the waste 

was put there of the natural uranium and thorium in 

the soils.

Member Beach: This is Josie --

(Simultaneous speaking.)

Chair Schofield: Tim, did I understand you to say that 

the 18 workers, that data you're using, were all down 

in the retrieval pit here?

Dr. Taulbee: They would have been moving in and 

out around there. They would have been down in the 

pits. We've got pictures of that, up here on the top. 

There's one guy who's driving a forklift, the 
69

equipment operator. So they would have been 

moving all around.

And we're using their bioassay, not the air samples. 

We're using their bioassay.

Chair Schofield: Do you have photos of the guys who 

actually had the monitoring done?

Dr. Taulbee: Yes.

Member Beach: So can I point something out? This is 

Josie. I went back and looked at SC&A's earlier 

report, April 2017. If you look back at their Appendix 

2, they've got several burial ground photos in that 

report that are pretty interesting as far as being able 

to see the actual operations of the earlier years, not 

what Tim is talking about now. But it might be helpful 

for folks to look at those again.

That's the one, Tim, where I was saying there was a 

gentleman working around a drum with just street 

clothes on. And it appears that he's leaning over a 

drum with the lid popped off. And I think it might be 

a camera in his hand. He may or may not have a 

mask on.

It's hard to really tell. But you can see damaged 

drums in this picture. And he's right on top of them 

actually. So, anyway, I just wanted to point that out.

Dr. Taulbee: Okay. We'll take a look at that, Josie.

Dr. Roberts: Okay. Great. Any more questions or 

discussion? Okay. Well, hearing none, I'm assuming 

we can go ahead and move on to Number 2 on the 

agenda.

But just to kind of, you know, recap what we need to 

kind of move forward on some of the differences in 

perspectives articulated by NIOSH and SC&A, it 

sounds like DCAS is going to pull the interviews out 

of the database and kind of compile them with some 

reference numbers, SRDB reference numbers in the 

report in a PDF file to allow for the Working Group 
70

Members to take a look at the interviews. It sounds 

like that is one deliverable to kind of pave the way 

forward.

SEC-00219/224: Evaluation of EBR-II and BORAXIV for ORAUT-OTIB-0054 Applicability

Dr. Roberts: So let's go ahead and move to the 

second point on the agenda, SEC 219/224 evaluation 

of EBR-II and BORAX-IV for ORAUT-OTIB 54 

applicability starting out with an SC&A presentation 

by Steve Ostrow.

SC&A Presentation

Dr. Ostrow: Hi, everyone. It's Steve Ostrow. Let me 

see if I can get the slides up here. Okay. That seemed 

to work. Can everyone see the first slide?

Chair Schofield: Yes.

Dr. Ostrow: Okay. Great.

Dr. Roberts: Yes.

Dr. Ostrow: Here we go. Amazing work. All right. So 

this is really -- my presentation is fairly short. And 

it's really a prelude to the NIOSH companion 

presentation.

We've been looking at reactor characterization for 

several years now. And I'm going to go into a little 

bit about the history. And then NIOSH will discuss 

afterwards their current paper, ORAUT-RPRT-0099, 

which they just released recently.

So just a little background that OTIB-54, Fission and 

Activation Product Assignment for Internal DoseRelated Gross Beta and Gamma Analysis, is one of 

the primary tools that NIOSH uses for dose 

reconstruction and in particular for INL.

But we had reviewed the OTIB separately from this 

when we were looking at procedures and found this 

methodology sound in general. So we have no 

quarrel with OTIB-54.
71

The investigation that we're doing specifically for INL 

was whether this methodology, whether the OTIB 

envelope, the important conditions of the INL and 

ANL-West reactors, and we started off with a series 

of reports from 2015 and 2016, looking into this. 

And as you know, INL had a lot of reactors, 52 of 

them. And since it's a test site, a reactor test site, a 

lot of the reactors are very unusual, very different 

from any commercial reactors. So it was a question.

And obviously NIOSH couldn't look into all 52 

reactors in great detail to see if the OTIB envelopes 

them. So after some meetings and papers and so 

forth, we prioritized the reactors into three classes, 

high, medium and low categories. And these 

categories were based on technical issues about what 

sort of reactors they were, how they were operated 

and what sort of cores they had and things like that.

And we also factored in the potential of the reactors 

actually exposing the people. Because if you had 

some reactor that had a very unusual core 

configuration but there was hardly any people 

around, that would be a low priority. So you had 

other reactors where there were a lot of people 

around. So that's how it's painted. And there was a 

lot of discussion between NIOSH, SC&A, and the 

Work Group.

A little more background, the TIB-54, as I started 

saying before, the TIB-54 determines internal go to 

when only gross data or gross gamma measurements 

are available. And it defines vision and activation 

product intake so different radioisotopes that are 

directly tied to an indicator radionuclide with the 

strontium-90 and cesium-137.

This is a very technical OTIB. I've looked at lots of 

them. And this one is really off the chart for 

complexity. And the OTIB generated using outputs 

from the ORIGEN code primarily, which is part of the 

SCALE system of reactor codes, nine different 

representative cases based on four different reactors, 

which are intended to envelope the range of reactor 
72

nuclide fuel types in operating scenarios.

The ORIGEN code basically does build-up and decay 

of radioactive material if you give it an initial fuel 

input and operating history to generate inventory, 

radioactive inventory.

These are the archetype reactors that are modeled in 

the OTIB. And to apply the OTIB, which over the 

years has gotten a little bit better because there's a 

workbook that goes with the OTIB right now, there's 

four different types.

So if you have a given reactor in a given situation, 

and you want to use the OTIB, you have to pick one 

of the reactor types and see which one envelopes 

your particular situation the best. That's the simple 

way it's done.

After several back and forths between us and NIOSH 

doing the White Paper and discussion, and finally at 

the May 16 Work Group meeting, the NIOSH, SC&A, 

and the Work Group agreed on the course of action, 

so all the possible scenarios and so forth, that these 

are a list of different reactor that NIOSH is going to 

analyze. These are the action items out of this.

So this is a 2017 meeting. And about three years 

later now, NIOSH produced this document that 

NIOSH is going to be discussing after this the BORAXIV reactor core and the EBR-II reactor. And we 

agreed with NIOSH on certain limiting conditions --

I'm not going into it here -- that sort of maximize 

potential for exposure for personnel.

So that's where we are. The SC&A hasn't had a 

chance to look at NIOSH's ORAUT report that they 

just came out, the 0099 report, in any detail. I went 

through it real quickly. A lot of stuff in there to look 

at.

And we look forward to the opportunity during the 

presentation and actually reviewing the report and 

giving our assessment to the Work Group. So I'm 

finished.
73

First of all, any questions from any of the 

participants? Okay. If no questions, I'll turn it over to 

--

NIOSH Presentation

Dr. Roberts: Yes. But, okay, you were heading where 

I was heading, which is to turn it over to the next 

speaker from NIOSH. And the person that will be

speaking is Bob Burns.

Mr. Burns: That is me. Good afternoon.

Dr. Roberts: Good afternoon.

Mr. Burns: Can everyone hear me okay?

Chair Schofield: Yes.

Mr. Burns: Okay. Good. And I guess, there is it. Okay. 

I see the presentation. And John Cardarelli, I'll just -

- I'll probably just cue you as best I can as far as 

when to advance the slides. I'll just use -- I don't 

know if you can see the slide numbers or not, but 

we'll figure it out.

Mr. Cardarelli: Yes. Will do, Bob. Thanks.

Mr. Burns: Okay. I'll jump right in here. This 

presentation is a summary of ORAUT-RPRT-0099, 

which was an evaluation of the EBR-II and the 

BORAX-IV reactors versus TIB-54 applicability as 

Steve just discussed.

So, I guess, Slide Number 2. This is an overview of 

the presentation. We're going to discuss the objective 

of RPRT-0099, the reactors that were considered and 

how those were selected, how those were modeled 

and the source term generation, the calculation of the 

fission and activation product content of the fuel lift 

at end of life or at the end of the ordination period 

for those reactors.

Use of that source term information for computing 

organ doses and comparisons of those organ doses 

with doses predicted or computed by the TIB-54 
74

method using the same bioassay or same unit 

bioassay or unit intake. Basically the same intake 

scenario.

John, I think I got ahead of you. I skipped the 

transition slide there, right. Cool. All right.

So our presentation today is going to summarize 

RPRT-0099, which, as I said, documents organ dose 

computed using fission and activation product source 

terms determined for the EBR-II, the BORAX-IV 

reactors.

And we calculate those organ doses and compare 

those with the same doses or from the bioassay 

model as computed from the TIB-54. And, you know, 

why do we do that? Why do we want to see what that 

looks like with respect to this question of applicability 

of TIB-54 to all these reactors that ran INLs over the 

years?

So ultimately it was a question of, you know, was 

TIB-54 sufficiently bounding? So, again, continuing 

with our purpose here, basically these were -- the 

slide synopsizes the method where, you know, the 

manual calculations for the BORAX-IV, the EBR-II 

source terms and compare those with the results 

from the TIB-54 tool. Those reconstructors use a 

software developed specifically to implement TIB-54 

given the complexities of those dose calculations.

But since that software tool doesn't encompass or 

include the BORAX-IV or the EBR-II source term 

information, those organ doses were calculated 

manually, if you will, using the spreadsheets and 

other processing tools that we used to developed 

TIB-54.

Slide 6, John. Forgive me if I'm jumping ahead of 

you. Thank you. I'm looking through my hard copy. 

But the key here, the analytical approach, you know, 

as far as the comparisons and the organ doses 

between the two, everything is identical. The only 

difference is the source term, or the two source 

terms, the source terms from the EBR-II and the 
75

BORAX-IV, everything else is the same.

John, you can skip the transition slides there, John. 

Thank you. Just some background refresher 

information. Steve already covered this so I won't 

repeat anything.

But TIB-54 was prompted by a need. In the earlier 

days of the project, we had a number of claims that 

were backlogged, was the term we used, due to the 

fact we didn't have a means to assign fission product 

mixtures from bioassay urinalyses specifically that 

were done on a gross analyses, that were either 

gross beta or gross gamma bioassays. So that's what 

prompted TIB-54 in the first place.

And what it does is for a given gross beta or gross 

gamma urinalysis it computes what we call an 

indicator nuclide activity. It tells you for giving gross 

beta or gross gamma results, the fraction of that 

that's comprised by the so-called indicator 

radionuclides, those are simply our reference points 

of strontium-90 and cesium-137, which is our 

prominent fission products of isotopes you would 

expect to see in any bioassay result.

And then it also assigned the rest of the mixture, the 

so-called associated nuclides, relative to those 

components, fractions of the indicator radionuclides.

I'm trying to synopsize some of this. Yes, thank you, 

John. Continuing on, as Steve already presented, the 

SC&A did some evaluations. Looking at, you know, 

just the wide gamut of reactors that were built and 

constructed and researched at INL and ANL-West 

over the years and just created this report prioritizing 

those.

And I don't know what's all here. But I'm always 

asked the question, would TIB-54 envelope with 

sufficient accuracy these reactors? The rationale for 

reactor selections, as has been discussed, we 

modeled the EBR-II and the BORAX-IV of the 50-odd 

reactors that were constructed at INL.
76

This is the slide I thought I was on. Forgive me, folks. 

I'm sorry. Let's go ahead and jump to Slide 12. Okay.

So the EBR-II was selected because it was an 

unmoderated, sodium-cooled fast reactor, but it used 

a uranium fuel as opposed to a MOX fuel.

In TIB-54, we considered the FFTF fast reactor that 

operated at PNNL at Hanford, actually. But that 

reactor was fueled by a mix oxide of plutonium and 

uranium fuel. The EBR-II was a uranium metal alloy, 

if you will, uranium fissium specifically, fissium just 

being a uranium alloyed with stable elements to 

represent the expected fission products.

So the EBR-II operated pretty much in a steady state 

like the reactors that were considered in TIB-54. But, 

you know, being an experimental reactor, there were 

numerous subassemblies that were placed in the core 

at various times for, you know, research purposes.

So, again, this is a good test bed, if you will, with 

respect to looking at how it compares with TIB-54.

Next, John. Okay, likewise, the BORAX-IV, is a 

thorium-fuel reactor, which we didn't really -- I don't 

think we have anything in the representative reactors 

we considered in TIB-54 that was thorium fueled. So 

that was the rationale for cleaning the BORAX-IV, 

which, again, was an experimental reactor. You 

know, we didn't run it for long periods of time. And 

ultimately it didn't run to a really high burn up. So 

this is some of the bases for selecting these two to 

start with.

Okay. So we discussed the reactors we selected. So 

now we're going to talk about how we modeled those. 

Again, as already has been discussed, we used the 

SCALE code system, which was likewise how we 

created TIB-54 in the first place, but this is later on.

So TIB-54 was created using Version 6.0 in the 

SCALE code system. For this Report 99, we used the 

current version, which is SCALE 6.23. So there was 

some improved capability there we were able to take 
77

advantage of.

But basically there's two modules within scale that 

are primarily used, TRITON, which is a code used for 

nuclear fuel depletion and that's used in conjunction 

with the ORIGEN isotope generation completion 

code.

So the two of those together tell you the depletion of 

the nuclear fuel, which in other words gives you the 

composition of the fuel as a function of burn-up for a 

given lattice, given -- you know, a combination of fuel 

and fuel pins, moderators and so forth.

One difference between the model that we did for 

RPRT-0099 and TIB-54 was, whereas in TIB-54 were 

given reactor or given fuel assembly, whatever 

nominal power we used, reactor power we used for 

that case, that and whatever the target burn-up we 

wanted and just divided those two out. And I did that 

irradiation or did that model and said the reactor ran 

at that power constantly for, you know, whatever the 

required time was to get to the total burn-up.

But in other words I collapsed the -- I didn't account 

for real power history. I didn't account for the reactor 

power going up and down and up and down. I just 

collapsed everything into one long run.

And that was intentional. That was done to maximize 

the predictive or calculated short-lived fission 

products relative to the longer-lived fission products, 

relative to the indicator nuclides.

So that's just one of the numerous layers of 

conservatism we built into TIB-54. But for these 

reactors we considered in RPRT-0099. For the 

BORAX-IV, the EBR-II, we used a more realistic 

power history because that seemed more appropriate 

for this kind of comparison.

The TRITON and ORIGEN models were used, again, 

this is the fission product content at the end of the 

irradiation cycle for various combinations or the 

various fuel assemblies that we considered.
78

And then the ORIGEN code was then used in a 

standalone mode to decay those out for the same 

decay times that are considered in TIB-54, which are 

10, 40, 180, and 365 days.

So the next couple of slides are some images showing 

the reactor modeling lattices. Sorry, John. I jumped 

one again.

Slide 16 is the lattice model for the EBR-II. And you 

can see the characteristics of hexagonal geometry for 

a fast reactor and the next slide, the next page, for

the BORAX-IV, you see kind of a loose lattice, more 

of a power reactor type of a lattice that you would 

expect.

But in both cases you see the -- this one was done 

by Dr. John Hamawi. You see the levels, the 

completeness and the detail he included in his 

models. He did a really nice job with those.

Okay. So the -- actually, John, let's go ahead and 

jump up one slide to 19 for the table. This text here 

just talks about that table.

So this information here, these are reactor modeling 

parameters that were used for the EBR-II and just 

there were three -- as we said, EBR-II used a number 

of different fuels and fuel assemblies. Three of those 

were selected for consideration in RPRT-0099.

There's a Mark IA fuel assembly that was a radiator 

or a model using average, you know, typical 

parameters. There's a Mark II assembly that I believe 

was a model using maximum parameters. And there 

was also one of the experimental assemblies.

So from the table there, you can see the different 

burn-ups that were modeled for those different 

assemblies. We also see the uptime and the lifetime 

in days that were used.

I would point out those uptime and lifetime were 

totals. Those are telling you that the sum of the 

uptime -- and the sum of the uptime plus the 
79

downtime. That's not telling you the sequence of up, 

down, up, down, up, down that were actually used in 

those reactor models.

And RPRT-0099 itself references -- there's some very 

detailed reports that cover these reactor models in 

great detail. Those are actually referenced in RPRT0099.

All right. And likewise, the slide here showing the 

reactor model and the parameters that were used for 

the BORAX-IV. The BORAX-IV, EBR-II modeled -- Dr. 

Hamawi modeled specific subassemblies for the 

BORAX-IV. The entire core was modeled. Basically, 

he modeled a quarter core and then that was 

expanded up for the entire thing.

Okay. So the output of the reactor modeling then is 

the source term, the fission and activation product 

content in the fuel at end of life.

So we had a number of slides here talking about how 

we use those to get to the doses that we compare 

with those from TIB-54. But in a nutshell, it is the 

identical process that we followed in TIB-54, or as I 

said, we used the exact same method. The only 

difference was the source term.

So the exposure pathway -- oops, John. You jumped 

on me. That's fine. The exposure pathway was 

inhalation of airborne mixed fission and activation 

products.

And we used two intake periods, a two-year period 

and a ten-year period. We calculated those to 28 

ORIGENs, the 28 ICRP-68 ORIGEN specifically, that 

are considered in TIB-54. Noble gases and actinides 

were excluded, which is always going to be the case. 

TIB-54 addresses only fission and activation 

products, not actinides. And the noble gases are 

taken out because there's no internal doses 

associated with those.

But the next bullet there makes the point that even 

though we take the noble gases out we leave the 
80

noble gas decay products in. So it's not like the 

downstream particulates are being omitted or lost in 

the source term.

The next slide. As in TIB-54 we considered three 

different types of cases for urinalysis. We have gross 

beta urinalysis where minimal chemical separation 

was performed, a gross beta urinalysis where, you 

know, separation chemistry was performed, 

strontium separation chemistry specifically, and a 

gross gamma analysis.

And then for each one of those three cases, we run 

the source term with and without the iodines. There 

were some cases, you know, facilities applied iodine 

filtration and such, you know. Later on it was less 

likely for orders to get iodine intakes early on. But we 

ran them both ways.

And then the following slides are going through 

discussing what I termed the -- that's how the 

manual calculations were done as opposed to those 

that just come out of the TIB-54 software tool. And, 

again, this is just summarizing the process used in 

TIB-54 to begin with.

So we take the source term from the reactor 

modeling. The next step in that process we apply 

release fractions from a given DOE standard, the DOE 

1027 standard specifically, which pertains to accident 

analyses for different types of nuclear facilities.

So the product of the source term and the release 

fractions we treat that as if that was what was in the 

air and available for the worker to inhale. So we 

multiplied those out on an activity basis and then we 

normalized them. Everything is stated relative to 

everything it. So that's how we come up with what 

we call the normalized intake fractions, the NIFs 

values.

Following that then we used published or tabulated 

organ dose per unit intake, or committed organ dose 

per unit intake factors. And we take this really long 

list of isotopes from the reactor modeling and using 
81

these, you know, published committed dose factors, 

we determined the isotopes that deliver greater than 

or equal to one percent of dose to any organ.

And we select those. And that gives us our list of what 

we call our dosimetrically significant nuclides. So that 

takes our list of 900 or so fission and activation 

products and collapses it down to about 30 or so that 

were actually the dose drivers, the internal dose 

drivers.

And in TIB-54 that occurs in or is presented in TIB54 Table D-1, just in our local vernacular here, we 

tend to refer to those 30 dosimetrically significant 

nuclides as the D-1 nuclides. We use that term for 

hearings using that term.

So then the next step in the process, we take that list 

of D-1 nuclides, and we assume a two year chronic 

intake. We use intake retention fractions calculated, 

assuming a two year chronic inflation intake, and we 

calculate what we would then see in 24 hour urine.

So at that point, we can take the -- you know, we 

have that on an isotopic basis. So at that point, that's 

what gives us our urine activity fractions. We take 

the ratio of the cesium-137 or the strontium-90 as 

appropriate to the total and that's what gives us our 

given gross beta or gross gamma analysis. That's 

what tells us of the component of our composition of 

that that we assign to the indicator radionuclide.

And then I want to jump ahead to Item E here. And 

once we calculate this list of dosimetrically significant 

nuclides, about 30 something nuclides long, there's 

an additional step that we put in TIB-54 back in the 

day when these calculations were done manually.

The original early version of TIB-54 we considered, I 

think there were four representative reactors. And we 

actually averaged everything together. So it was just 

a single set of urine activity fractions and associated 

nuclide values.

So at that point, or back then, the dose 
82

reconstructors did all those calculations manually 

when they were actually evaluating a claim. So in an 

effort to make the calculational burden a little less on 

them, we added a step where we took that list of 30 

nuclides, and we reduced it further based on 

contribution to committed effective dose.

So just as the initial list of 30 was based on 

contributions to committed organ dose, we likewise 

determined the nuclides that contributed greater 

than or equal to one percent to committed 

effectiveness and that reduced the list from 30 to 17 

or 18 or so.

And if you look at TIB-54, you'll see those presented 

in Table E-1, the so-called E-1 isotopes. And it's those 

E-1 nuclides that are actually used for those eventual 

dose calculations. Those activity fractions, ratioed to 

the cesium and strontium, are the associated nuclide 

fractions that are used for dose assignment.

So then back to Item D. Item D is kind of a 

housekeeping item. I was talking about in RPRT0099, how, in general, we have a bioassay result of 

whatever for a given claim. The dose reconstuctor 

would then, in principle, would multiply that by the 

urine activity fraction and back-calculate the intake 

of the indicator radionuclide and then apply the 

associated radionuclide fractions to get the dose.

But what's done in practice is that gross beta or gross 

gamma urinalysis result, we assume that it's all 

indicator radionuclide, calculate that intake and then 

that gets multiplied by the urine activity fraction and 

the dose calculations proceed from there.

You get the same result but it makes the calculation 

more straightforward. And that's what Item D there 

is talking about.

And then, as I said, once we have the indicator 

radionuclide intake, then we calculate the organ 

doses using the associated radionuclide fractions, the 

so-called E-1 isotopes.
83

So the bottom line is we crank through that process 

manually using the same spreadsheets and other 

analytical tools that are used to create TIB-54 in the 

first place, took the source terms for the EBR-II and 

the BORAX-IV, calculated all those organ doses and 

then we compared those with the output from the 

TIB-54 tool for the same intake, the same assumed 

intake. And, again, we assumed an intake. We gave 

a unit 24 hour urine result of one picocurie per day.

And, John, I jumped up to Slide 28 here. So, well, 28 

and 29 kind of go hand-in-hand. But so to compare 

one to the other, the TIB-54 results relative to the 

manual calculations for EBR-II and BORAX-IV, we 

simply ratioed the two for each of the three urinalysis 

types, the gross beta, the gross beta with separation, 

and gross gamma.

And for each of the four reactor fuel, reactor fuel 

assemblies that were considered, the BORAX-IV and 

the three EBR-II facilities, and, again, we just took 

straight ratios of those and then we compared.

So if you look at the next slide, so there is a table 

there. Thank you, John. For each one of the bioassay 

types and for each of the four reactor fuel assemblies 

that were considered, of course, there's 28 individual 

results for all 28 organs that are compared.

What this table is showing is the lowest ratios of TIB54 to RPRT-0099, to the EBR-II and the BORAX-IV 

dose results, and the lowest ratios meaning the cases 

where the organs for which the doses were the 

closest together. So, again, we're ratioing TIB-54 to 

the reactors under consideration. Anything greater 

than one means the dose from TIB-54 exceeded that 

or vice versa.

So, again, these are just the lowest values or the 

cases where the doses were the most similar or were 

the closest together.

So for instance just in the first line there, for the 

minimally processed gross beta urinalysis with the 

iodines included, you see from the BORAX-IV, the 
84

ratio. This smallest ratio between the two was a 

factor of 1.03 for the bone surfaces. And then you 

can just move across the line there. For the Mark IA, 

the EBR-II assembly it is about two percent higher 

for the liver and so forth.

The lowest number on that page is for the gross 

gamma with iodine for the Mark IA assay from the 

EBR-II where you see the organ doses were 

essentially in unity for both the thymus and for the 

esophagus.

Jumping back to the previous slide, and so we see 

that the ratios are all greater than one. But in some 

cases not by much. So we're not suggesting that that 

inclusion that we showed in RPRT-0099 would be 

excluded to the other reactors. That clearly is 

something that's going to require further evaluation.

The only other point I want to make here is regarding 

interpretation of these values on this table on Page 

29. So if we have values greater than one, you know, 

that would give us assurance that TIB-54 is bounded 

from these reactors. But I don't want to give anyone 

the impression that the inverse of that would be true, 

if we saw values less than one that that would mean 

that TIB-54 was not bounding. That is not the case 

because keep in mind, you know, we developed TIB54 to be sufficiently bounding.

Our goal was to create a tool that assigned a dose 

that, you know, we were confident exceeded any real 

workers real dose but not excessively so. Our goal 

was to -- you know, the ballpark we were shooting 

for there was an order of magnitude.

So, you know, it would be entirely possible to 

postulate a set of reactor parameters that would give 

a higher dose than what TIB-54 would predict or 

would produce. But by no means would that mean 

that TIB-54 was bounding --- or was not bounding. 

Excuse me.

So just to summarize, as has been discussed, TIB-54 

is the tool that we use when we have gross beta or 
85

gross gamma bioassays, to have an isotopic mix for 

those for the purposes of dose reconstruction.

As SC&A discussed during its previous report asking 

and, you know, seeking to verify TIB-54 enveloped 

all these reactors that operated INL over the years 

and prioritizing those.

So in RPRT-0099 was our, you know, initial 

evaluation of that question for the BORAX-IV and the 

EBR-II reactor systems and, you know, it did show 

that TIB-54 bounded those. But, you know, 

additional work is needed for these other reactors.

So RPRT-0099 documents the first two of those and 

just basically that's where we are. 

Dr. Roberts: Okay.

Mr. Burns: And, John, I'll kick it back to you.

Mr. Cardarelli: Thanks, Bob. And I'll pass it on to you, 

Dr. Roberts.

Work Group Discussion

Dr. Roberts: Okay, great. I would just ask if the 

Working Group Members have any questions.

Member Beach: None here. This is Josie.

Dr. Roberts: Go ahead, Josie.

Member Beach: No, sorry. I said none here.

Dr. Roberts: Okay. Anyone else?

Member Anderson: I don't have any either. This is 

Andy. I still don't understand it all.

Member Roessler: This is Gen. I don't have any 

questions.

Chair Schofield: Yes, this is Phil. I don't have any 

questions.

Dr. Roberts: Okay.
86

Dr. Ostrow: This is Steve Ostrow from SC&A again. I 

just have a general question for NIOSH. So I assume 

that you're going to be using a similar technique to 

analyze the other reactors? Is that true?

Mr. Cardarelli: Bob?

Mr. Burns: Go ahead. Oh, was that for me? Sorry, I 

thought you said to NIOSH.

Mr. Cardarelli: Oh, okay, Bob. I'm sorry. I get mixed 

up sometimes.

Mr. Burns: I'll go. No problem at all. Boy, I don't want 

to answer your question -- it's a good question. But, 

I mean, we will certainly go down that path. But I 

think there's other methods we could consider here.

You know, the first question I would have as I was 

alluding to, okay, we have these ratios to come out 

less than one what does that mean? So, the question 

I would have at what point would we concerned about 

TIB-54 being bounding?

If I saw a ratio of .9, .8, I don't think that would 

bother me. If it started getting down to .2 or 

something, that might give me pause given, like, I 

said, versus our goal of bounding real workers to, you 

know -- or real doses to real workers by an order of 

magnitude.

So that said, something else we've considered is in 

addition to this type of an evaluation or something 

along that line is actually making use of all of the 

bioassay data we've collected over the years.

And I've not described -- you know, keep in mind that

TIB-54 is a complex-wide document. But make use 

of that and, you know, apply some of these modeling 

assumptions and, you know, through TIB-54 look at 

what the predicted bioassay data would be, compare 

that to what we actually see in the field and give that 

-- you know, use that as kind of the defense-in-depth 

type of evaluation with respect to bounding, if you 

will. Excuse me.
87

Dr. Ostrow: Okay. Thank you.

Dr. Roberts: Okay. Any other questions or comments 

or points of discussion on the OTIB?

Dr. Ostrow: Well, this is Steve again. Just want to ask 

the Work Group, does SC&A have direction to go 

ahead and look at this report that NIOSH produced, 

ORAU produced?

Dr. Roberts: Okay. I'm going to defer -- Phil, what's 

your thought?

Chair Schofield: I would say let's go ahead and have 

them do it.

Dr. Roberts: Okay. Go ahead.

Dr. Ostrow: Great. Thank you.

83.14 Verification and Validation (V&V) of 

Temporary Badges at the Chemical Processing Plant 

(1975-1980); SEC-00238; SC&A June 25, 2020 

memo

Dr. Roberts: Okay. Anything else on this topic. Okay. 

Well, if none, let's move into SC&A's presentation of 

its memo on the 83.14 V&V of temporary badges at 

the Chemical Processing Plant for '75 to '80.

Mr. Barton: Okay. Thank you, Dr. Roberts. This is Bob 

Barton again. I do not have presentation slides for 

this. I'm honestly not sure how helpful they would 

have been because this report is really loaded down 

with Privacy Act considering it's really focused on the 

claimant population.

But I'll be working right off the PA cleared report 

memo, memo report that's on the website. And I'll 

throw it up here on Skype for those of you, just for 

ease of reference. But I'll try not to scroll through 

really too quickly because I'm not sure how Skype is 

going to react to that.

Anyway, we're talking about the 83.14 for the 

Chemical Processing Plant, and this is from 1975 to 
88

1980. And a bit of history, because I think it's helpful 

to be able to put this in context.

This is actually the third SEC period for CPP. And the 

first period ran from 1963 into early 1970 and then 

you have early 1970 through 1974 and then you have 

this 83.14 period.

And they're really delineated by what the external 

badging requirements for the Class Definition itself. 

As you can see, the 83.14 Definition is up on the 

screen right there. And, again, so it's very similar to 

that first period, '63 to '70 where an external badge 

is required to essentially become part of the class for 

adjudication purposes.

So you couldn't just be an INL worker. You had to 

have proof that you entered the Chemical Processing 

Plant during that period and that proof is really in the 

external badging requirements.

So that badging requirement is a little unusual in this 

program. And so it obviously gave the Work Group 

and the Board a little bit of pause.

So during the process of sort of digging into that, it 

was discovered that for INL, for temporary and visitor 

badges, in other words you didn't have necessarily a 

permanent at the site or at CPP. You might be issued 

a temporary badge.

And it was discovered that unless you accrued a 

positive dose on that temporary badge, INL had not 

what's known as indexed those badges with the 

individual who was issued the badge. So if you went 

to the site, you know, back prior to about 2016 and 

requested records for an individual, you would get 

whatever dosimetry records they had. But if there 

were temporary badges that had zero dose on them, 

you weren't getting them because the site just simply 

wasn't associating all those temporary badges with 

the individual.

So, again, back in 2016, DOE and INL, they 

performed a massive coding and indexing effort to 
89

basically take all those temporary badges, enter 

them into their dosimetry indexing system so that 

now if you made a request for a claimant's dosimetry 

records, now you're getting all those temporary 

badges, even if there was a zero accrued dose on 

those.

So that sort of took care of that problem. But there 

was still definitely some concerns as these temporary 

badges were mostly handwritten during this period. 

And really the only identifying information was 

generally the person's name and the employer. There 

was no what's known as an S number or a security 

number, which is basically a unique identifier for the 

individual at the site.

So now you have this handwritten temporary badges, 

and you might have legibility issues. You could have 

multiple people with the same name or other types 

of human error that might have occurred during this 

coding effort so that the question remained is it still 

possible that we might inadvertently exclude 

someone from the SEC when in fact they did enter 

the Chemical Processing Plant during this period?

So, again, this is a little bit of history because this 

first period is very similar to what we did for this 

83.14.

So the first period, SC&A developed a V&V strategy. 

Again, it's very similar to what we're going to be 

talking about here. Basically, we identified claimants 

who we knew had temporary badges at a Chemical 

Processing Plant. But if you went and looked into their 

individual dosimetry file they were missing.

So now DOE has done this coding effort. All of those 

temporary badges should be correctly ascribed to the 

Energy employees and so this shouldn't be a problem 

anymore.

So we developed a strategy where we said we're 

going to identify all these essentially missing records 

in some claimant files and then we're going to go rerequest the records from the site and see what they 
90

return and see if all those temporary badges that we 

know should be associated with the claim are now 

correctly included.

So that first V&V, again, for the 1963 to '70 period 

where it's required to have at least one badge to be 

included as part of the SEC, we actually found that 

DOE came back with about almost 95 percent what 

I'll call a success rate. That is 95 percent of the 

badges that SC&A had identified as missing were now 

being correctly included in those claim files.

And so that was actually presented before the Board 

back in last April, that's 2019, at the meeting in 

Pittsburgh. And that 95 or it was actually 94.5 

percent was deemed acceptable.

And now we're back to the 83.14 period here, which 

was presented to the Board. And obviously similar 

concerns were voiced over that requirement of an 

external badge. So SC&A was tapped again with 

performing a very similar V&V evaluation that I just 

described.

Again, we're going to identify badges associated with 

claimants that we know were in CPP. They have a 

badge associated with CPP, but it is currently missing 

from their dosimetry file.

So we came up with our proposal of how we're going 

to do it. Again, it was very similar to what we've done 

for the earlier period. And that went in front of the 

Board in March of 2019 during the teleconference. 

And it was approved to move forward.

So that proposal included a total of 37 claims with 

736 missing badges from their DOE monitoring file. 

So this is what we're going to check. We have a group 

of 37 claims that cover 736 missing badges. We're 

going to send those off and see what we get back 

from DOE.

Now what's a little different about this evaluation 

than the previous one I described, is this one is 

actually a little bit twofold. We were not only testing 
91

DOE/INL's ability to correctly ascribe the temporary 

badges to the individual. But we had a secondary 

source.

And this is known as -- well I know it as NIOSH hotlinking. And as I understand it, this is basically a 

process that when NIOSH captures records during 

the normal process of research and a given claimant's 

name might be on it and the document is germane to 

dose reconstruction, it's essentially automatically 

linked to the claim file so that it can be used in the 

DR process.

So this is sort of a secondary piece of information, if 

you will, a separate piece of information that is just 

done through the course of the program. But it sort 

of provides a -- I guess, it's going to be a safety net, 

if you will, that if DOE misses the record, then there's 

a chance it would be picked up anyway through this 

hot-linking process and the claim would have the 

requisite evidence to be included in the SEC for CPP.

So we evaluated both what DOE was returning to us 

and also this facet of the program known as hotlinking. We evaluated them separately but then also 

what was the combined effect of the two.

I'm going to scroll down, and hopefully this doesn't 

make anyone sick here, to Table 1. It sort of shows 

the overall results. And this is Table 1. It's in SC&A's 

report on the website. Okay. I hope everybody can 

see that.

So, anyway, this is the overview of basically the 

success rate that we had. Again, we had over 736 

badges that we wanted DOE to check. And then also 

we could just see what the NIOSH hot-linking process 

was going to produce at the same time. And, again, 

this hot-linking process is not related to the V&V. This 

is just something that is done as a matter of course 

in the program.

So as you can see from the table, DOE had an 82 

percent success rate. In other words, 82 percent of 

those badges that SC&A had identified with the 
92

claims were returned correctly. So 18 percent were 

still being missed.

When looking just at the NIOSH hot-linking process 

by itself, we had a very similar 83 percent success 

rate. And if you looked at the two in tandem, in other 

words, if DOE missed it, did the hot-linking process 

pick it up or if hot-linking missed it, did DOE pick it 

up? Overall, it was about a 93 percent success rate.

Now Table 2 is really loaded down with Privacy Act 

material. So it's pretty heavily redacted with good 

reason. But basically you can see line-by-line for each 

claim we looked at how many badges did SC&A 

identify? How many were correctly returned by DOE? 

How many were identified through NIOSH hotlinking?

And, again, I don't want to go through line-by-line. 

I'm not sure. But one word you might notice that 

there were actually three cases out of the 37 in which 

none of the identified temporary badges, these are 

badges identified by SC&A as associated with the 

claim, none of them that we identified were actually 

returned by DOE. So that's essentially on a specific 

claim, a zero percent success rate. And I'll get to 

these three claims in a minute, because really those 

are the most important, I feel.

But first, I just wanted to just quickly list some other 

takeaways from the V&V results. I'm going to scroll 

back down to the conclusions. Again, I don't know 

what this looks like on other people's Skype. Look 

away if you're starting to feel seasick.

Okay. So as I just said overall, there was an 83 

percent success rate for the NIOSH hot-linking 

process. There was an 82 percent success rate from 

DOE.

Now, again, by comparison, when we did this for the 

earlier period, we actually got nearly a 95 percent 

success rate, and that's very surprising. The reason 

being, in the earlier period, like I said, you only had 

a name and a company to really go off of, and they 
93

still got 95 percent of them that we could identify 

them. So now we're down to 82 percent, which is a 

fairly marked decrease.

And the reason that's surprising is in this latter 

period, the visitor badges were often typed and not 

handwritten and also they would include an 

identifying piece of information, the security number. 

You would think with three pieces of information, the 

security number, the name, and the employer, it 

would be easier to identify these badges, but that 

wasn't the case this time around. And we're not sure 

why that is.

But, again, when you considered both the DOE 

success rate and the NIOSH hot-linking success rate 

in tandem, you end up with about a 93 percent 

success rate in correctly ascribing these temporary 

badges with the claimant.

Also eight of these 37 contained 100 percent 

temporary badges identified for the hot-linking 

process. So eight of 37, the NIOSH process got all 

100 percent that SC&A had identified, 15 of 37 

contained 100 percent from DOE. And then when you 

looked at them combined, 19 of 37 contained all the 

temporary badges if you looked at both the hotlinking and the DOE provided dosimetry, when you 

take them in combination.

And of those three cases where DOE did not return 

any of the temporary badges that we had identified. 

So for two of the cases, as I said, DOE did not return 

any of them. However, the NIOSH hot-linking process 

actually found 90 percent and 100 percent of the 

badges for those two individuals, respectively.

So I guess that's one of those cases where even 

though DOE happened to miss them, this sort of 

secondary function that the program does, again, for 

all sites -- this is not related to INL or related to the 

V&V -- that process itself identified 90 percent and 

100 percent where DOE came back with zero.

The third case is a little bit more troubling. Again, 
94

DOE did not return any of the temporary badges that 

were identified by SC&A. And so in this case, there 

was actually no hot-linking in the claim file. And I 

believe the reason for this is hot-linking has been, 

relative to the program, a sort of recent 

development. And this case itself had been 

adjudicated. The gross reconstruction had been done 

quite a while back.

So I'm not sure if this process was really being 

utilized when this claim was being researched for the 

purposes of DR and I think, and I'll let NIOSH 

certainly comment on that, I believe if any of these 

cases where hot-linking wasn't performed, if they 

were reopened, you know, for example for a Program 

Evaluation Report or anything like that, I believe then 

that process would kick in.

But I'm just assuming that for this one case where 

we got nothing from DOE and the NIOSH function 

wasn't performed, I believe it's just because of the 

age of the case, when it was submitted and when it 

was worked.

But to get back what was really more, I guess, 

concerning, you know, was when we looked at why 

DOE might have actually missed this one and missed 

all the records that we had identified.

What appears to have happened is when we sent the 

information back to the site, back to DOE and INL to 

research the claim and return all the dosimetry 

records, that's what we asked for, just do it again. 

Research the case again and give us everything you 

got.

And we got nothing back. If you dig a little further in 

there, it appears that the site researched an Energy 

employee who had the same name but had a 

different Social Security number than what was 

requested.

So that is the reason why none of the records for that 

individual were returned. So on their end we made 

the correct request for this individual, but what they 
95

researched was the incorrect Social Security for that 

particular claim.

So that's really an overview of the results of this V&V 

investigation. Again, the main question is what are 

the chances that someone might slip through the 

cracks and be excluded from the SEC when they 

really should be included because of the requirement 

of having a badge, whether it be a regular badge or 

a temporary badge.

And so the success rate for DOE was 82 percent 

based on that NIOSH hot-linking process, the 83 

percent. And when you take the two in tandem, it's 

93 percent.

So that sort of ends my little spiel here. I won't call 

it a presentation because I didn't have slides. But I 

would be happy to entertain any questions.

Member Beach: Bob, this is Josie. I just have a typo 

question. On Page 6 under Number 17, if you just 

look across, the percentage is 23, 21, 21 and then 

it's 2.

Should that be a -- would that be a 21 or a 22? It's 

in your Table 2. Second from the bottom, no, the 

bottom one. Do you see which one I'm talking about? 

The one that says 2 96 percent? Hello?

Chair Schofield: Bob, are you still on?

Mr. Barton: I'm sorry, everybody. I think I got on 

mute somehow. Yes, I see what you're talking about. 

So what you're seeing that should not be two. Likely, 

it's probably 22.

Member Beach: Okay. That's what I was wondering.

Mr. Barton: Yes. Both NIOSH hot-linking and DOE 

returned 21. But probably not the same 21 badges. 

Probably taking in combination, that should be 22 not 

just 2. That's a good catch.

Member Beach: Okay.
96

Dr. Taulbee: One point -- this is Tim -- that I would 

like to try and point out here. Of the 37 people, 

remember, this methodology is for inclusion into the 

SEC. Of these 37 people that Bob looked at, which is 

a small sample, 36 of them made it in the SEC based 

upon these results. One that is not, it appears that 

the site responded with the incorrect Social Security 

number for a claim for somebody else.

So we are actually following up now with the site to 

request that additional one. Well, I guess, in case the 

worker requests that. If this is sufficient, then we 

won't make that request to go and do that follow-up. 

But, you know, the way this stands right now, 36 of 

37, which comes out to 97 percent of the people 

would be correctly identified into the SEC.

Member Beach: And then, Tim, what's the 

mechanism, not on the sampling here, what's your 

mechanism in place if there is one person that is not 

included in the SEC but that person says, "well, I was 

there"? What do you do to go back and correct that?

Dr. Taulbee: Well, for one thing, you know, if they 

indicated that in their CATI, for one thing, we would 

certainly be doing more investigation along those 

lines to see: is there any indication in the records? 

Did we miss something? Did DOE miss something? 

And we would do a follow-up with DOE, you know, 

asking specifically about it. And they can go through 

their records and search again.

So, when somebody indicates or affirms that they 

were there at CPP, we would go through extra effort 

to try and verify whether we have temporary badges 

for them.

Member Beach: Is that a follow-up that happens 

without the person requesting it? Is that something 

you could go, "well, this person, based on what we 

know, should have records." Would you do it 

automatically or would it require something from the 

person?

Dr. Taulbee: No, I believe we would do it 
97

automatically. The person doing the dose 

reconstruction would look at it and say, hey, I've got 

dosimetry here for CPP, or they're saying they 

worked at CPP in their CATI, and then they would do 

follow-up.

So I don't believe there's anything that the claimant 

has to indicate other than during the CATI. Or, you 

know, if we see something that points to them 

working at CPP; like, it could be a bioassay result, for 

example, that existed for them at CPP, that would 

raise a flag as well with the dose reconstructor.

Member Beach: Thank you.

Dr. Roberts: Any other questions or comments on the 

V&V? 

Okay. So where does this leave things, is my 

question?

Member Beach: I believe, as a Work Group, we would 

have to say whether we agree with this or not, right?

Dr. Roberts: So, does that track for you?

(Simultaneous speaking.)

Chair Schofield: Anybody have any comments?

Member Roessler: I was going to make a comment. 

In view of what Tim just added to the analysis and 

apparently bringing the number up to 97 percent, it 

seems to me that, compared to the one we approved 

earlier, then this looks good to me, if I understand it 

right.

Member Beach: Gen, that was what my conclusion 

was also. This is Josie. I agree with that perspective.

Member Anderson: Yeah, I would, too. I mean, they 

identified a few things. But I think it has practical 

utility and it really covers it pretty good. 

I think your question, Josie, about what happens if in 

an interview an individual says I was there, so they're 
98

kind of that 1 out of 99 or 97 percent, I think that 

follow-up is appropriate, too. I think there was a 

substantial number reviewed here, so I think that 

adds to the confidence in it.

Member Roessler: I guess I would take my comment 

and put it into a motion that the Work Group 

approves this approach.

Mr. Barton: Well, if I may, this is Bob. The SEC Class 

Definition, as it is right now, which includes the 

requirement for a badge, has already been approved. 

So it's really a question of whether the Work Group 

approves of that requirement, that it is feasible, or 

the Work Group feels there is not a realistic chance 

that a person will be left behind, so to speak, because 

that was the question at the onset.

The SEC definition was approved right away because 

we didn't want to drag it out. But the question 

remains, did it need to be changed in light of this 

analysis? Did it need to be changed from requiring a 

badge at the Chemical Processing Plant to something 

more universal like just requiring an INL badge?

As I said at the outset, this is sort of that middle SEC 

period from '70 to '74 where the requirement is just 

simply an INL badge. And the reason for that is 

because you could take a badge from TAN or TRA and 

use that to enter CPP, whereas the period we're 

talking about now, you would literally leave your 

badge at TAN, go to CPP, pick up a new badge at that 

location. And then, when you left CPP, leave your CPP 

badge at the cart rack there.

And that's something we looked at as part of our 

proposal. And we found that there were many 

workers who had as many as five different site 

badges during the same month. You know, they had 

a badge at essentially each area.

So the question really is, does the Work Group 

approve of the Class Definition as currently written 

and is being administered, you know, right now?
99

Member Roessler: Based on what you've just shown. 

Is that --

Mr. Barton: That's correct. The action for SC&A was, 

this activity was essentially to give confidence or give 

the Work Group pause about the requirement of 

having a Chemical Processing Plant-specific badge 

rather than expanding it to just simply being 

monitored at INL.

Chair Schofield: I think it gives me a lot of confidence 

in what it's showing. But that's my own personal 

opinion.

Member Anderson: So, no need to change anything, 

is what we're basically concluding. Nobody gets left 

out if you have to have a badge --

Mr. Barton: That is correct.

Member Anderson: -- at a site.

Chair Schofield: So I'd say all in favor?

(Chorus of ayes.)

Dr. Roberts: So it sounds like everyone is in 

agreement, is what I'm hearing.

Member Anderson: Yes.

Chair Schofield: Yes.

Dr. Roberts: Now, is this something -- it feels like 

something that needs to be brought up in the August 

meeting of the full Board.

Member Roessler: Yes.

Dr. Roberts: Yes. Okay.

Chair Schofield: Yeah.

Dr. Roberts: Okay. Great.

Member Anderson: It doesn't have to be a long thing. 

Just that this review was done and we reviewed the 
100

results of it and confirmed the appropriateness of the 

case definition.

SEC Petitioner Commments

Dr. Roberts: Okay. Okay. Great. So it sounds like 

we're done with this issue. So, if okay, I'm not sure 

if there are any petitioners on the line, that we do 

have an agenda item for any petitioners who may be 

on the line to comment.

(No response.)

Work Group Discussion

August Board Meeting Session Plans

Dr. Roberts: Okay. I'm not hearing anyone. 

Okay. Then I think we can move to the final point on 

the agenda, which is the discussion of the August 

Board meeting session plan, which seems like a brief 

summary of what we discussed on the V&V would be 

appropriate to cover in the Board meeting.

Are there other items from the Work Group that we 

need to cover in August?

Chair Schofield: Not in August, but I would like to see 

a little more fleshing out of SC&A and NIOSH's 

position on how the, let me say, the quality of the 

data that they're using for chronic out at the waste 

pits.

Dr. Roberts: Mm-hmm. And to move that forward, 

what more is needed?

Chair Schofield: I think a simple White Paper or 

maybe just a telephone conference call, you know, 

kind of distill it down to where the differences are 

still. And then, instead of going back through 

everything, you know, "this is our point of view and 

this is why we're here," and see where they actually 

-- they may be closer together than it sounds like. I 

mean, we covered a lot of ground today.
101

Dr. Roberts: Yeah.

Member Anderson: Are we going to get a summary 

of the interview data from NIOSH? I think that will be 

helpful. I mean, that's a deliverable we probably 

won't get before the August meeting. But I think, 

once we have that, that will help resolve the 

variability and interpretation of what the interviews 

provided.

Dr. Roberts: Mm-hmm. So we're looking at another 

Work Group meeting, possibly, down the line. It 

probably would be after the August Board meeting to 

come back together on that.

Chair Schofield: Yeah, I don't see enough time for 

people to get through and look through those 

interviews. And DCAS is going to put it together so 

we just have -- instead of having to look all over the 

database, we have it one place. I'd be interested in 

going back through those.

Dr. Roberts: Okay. Great.

Member Anderson: We'll have to come to a 

conclusion on the use of the coworker model. And 

that group of 18, does that meet the criteria for being 

appropriate coworker information since it's different 

in time period and it's different in the actual 

activities.

Dr. Roberts: Mm-hmm.

Member Anderson: I think the whole thing -- if we 

don't feel that's an appropriate coworker group, then 

doing dose reconstruction with existing data really 

doesn't support that.

Dr. Roberts: Mm-hmm. Okay.

Member Anderson: We did a little discussion about 

that, but I think that -- at least in my mind, and this 

is Andy -- that's a key factor.

Dr. Roberts: Mm-hmm. 
102

Chair Schofield: Well put.

Member Anderson: I mean, the descriptive 

chronology and what went on the site and things like 

that, that's interesting. But the crux of the matter is: 

what about dose reconstruction for those workers 

who were there? And this is coworker group adequate 

to do that?

Dr. Roberts: Right.

Member Anderson: And I think there were some 

questions about that.

Dr. Roberts: Yeah. So you're referring to the group 

of 18.

Member Anderson: Yes.

Dr. Roberts: Okay. Anything else?

Member Beach: So, how many -- we've got, what, 

three items here? SC&A to review NIOSH's OTIB-099, 

the new report that came out. And then the 

interviews. And then, SC&A, will you give us anything 

on the Burial Grounds in response to NIOSH? Or --

Mr. Findley: In terms of the backup of 18 workers' 

data?

Chair Schofield: Yes.

Mr. Findley: Well, I think, Bob, we provided our 

comments. I guess the issue is NIOSH responding to 

those comments.

Dr. Roberts: Okay. Yes.

Mr. Findley: Yeah, our May report has our view of 

that and raises some questions that perhaps NIOSH 

can provide some early answers to the Work Group.

Dr. Roberts: Mm-hmm.

Dr. Taulbee: Okay. We can do that. This is Tim.

Chair Schofield: Gen, do you have anything?
103

(No response.)

Dr. Roberts: Okay. So we've got some good followup action items, it sounds like. We do have one small 

bullet on Board Review System Entries that I didn't 

want to skip. So I just wanted to open that up.

Dr. Ostrow: Okay. Hi. This is Steve. I'll see if I can 

share the PowerPoint presentation.

Dr. Roberts: Okay.

Member Anderson: Did we resolve the redacting 

issue?

Member Beach: No.

Member Anderson: Whoops.

Ms. Naylor: Okay. So, what is it that needs to be 

resolved?

Chair Schofield: I seems to me legal is going to have 

to sit down with us and we're going to have to figure 

out this whole redaction. Because I have to agree 

what Josie's comments earlier were. This seems like 

a whole new ballgame on this now, unless I 

misinterpreted what Josie said.

Ms. Naylor: Josie, OGC is not changing any policy. 

There's not one policy. There's no policy. It's about 

doing the job of balancing the litigation risk to the 

Department and balancing that with public access to 

information under the FOIA proactive release policy.

I mean, I'm not sure what is it that the Board is 

concerned about, because you all have access to the 

redacted information. In fact, the un-PA-cleared 

documents, the unredacted documents, have been 

sent to you guys even prior to the PA redacted 

version. So you should already have the report 

without any redactions in it.

Chair Schofield. Okay. I'll have to go back over that.

Ms. Naylor: I mean, is the concern here that the 
104

Board is not getting the information that you need in 

your deliberations? Or is the concern that the public 

is not getting the information?

Member Beach: Well, I think a combination. And it 

just seems like it's changed, even from the 2017 

report up until now. And you don't need to re-explain 

all of that. I'm not 100 percent satisfied with that, 

with the -- but I'm not 100 percent sure where to go 

at this point. It's very inconsistent, in my view.

Ms. Naylor: What is inconsistent is the information 

that's provided in the -- the amount of information 

being provided in the 2020 report. When more 

information is provided, a decision needs to be made 

on whether more information needs to be redacted.

Member Anderson: So it's really a cumulative thing?

Ms. Naylor: Every time.

Member Anderson: Yeah. So, we have multiple 

documents that have put in quotes from the 

interviews. And when another report goes back to the 

same interviews, it doesn't use the exact same quote 

previously. You have to look at cumulative references 

to the same individual's interview as now that rises 

to a level of concern. And I think that's -- I'm not 

sure the Board is appreciative of that, if that's the 

case.

Ms. Naylor: So, for example, in the 2017 report, 

there was one individual with two quotes attributed 

to it. In the 2020 report, there were five quotes 

attributed to the same person.

Member Anderson: Yeah.

Ms. Naylor: So, I mean, that is the concern here.

Dr. Taulbee: And this is Tim. If I could interject here. 

Because Jenny mentioned something there that I'm 

hoping everybody is really grasping: that you have 

copies of the unredacted reports. All of the Board 
105

Members have a copy of that. So, all of your decision 

basis can be off of the unredacted. You know, you've 

got the actual information sitting there. The only 

thing that Jenny is redacting is the identification that 

goes out to the public.

Chair Schofield: Would it be possible that some of 

these comments they're making kind of in a 

generalized way, maybe we have two or three people 

who make similar comments about a subject, and we 

could break that out from one person and say, you 

know, "here's some of the comments that were put 

forth by people"? I don't know. That's why I'm 

asking.

Ms. Naylor: I guess, you know, you have to look at 

this on a case-by-case basis, right? And what is the 

objective here? Is it to provide the public with more 

information than what's currently been redacted by 

the OGC?

If that's the case, I'm always happy to take a second 

look. And also public members can send a Federal 

Advisory Committee Act record request to the DFO. 

And maybe at that time there's a second review of 

the redaction that is made under the proactive 

release policy under FACA.

So, I mean, public members do have several ways of 

getting to the information. However, it still means 

that -- you know, the Department still has a statutory 

responsibility to protect the privacy of those who 

come forward and tell us their stories, as well as 

preserving the program's integrity to make sure that 

future workers will be willing to talk to us.

(Pause.)

Chair Schofield: Well, maybe once they put 

everything in that file, then we can access it and 

that'll answer those questions for us, I hope.

Dr. Taulbee: This is Tim. What we will be sending you 

will be unredacted, just as I mentioned before. So 

you will see the full version of everything. However, 
106

what ends up going out to the web as far as a 

discussion will be heavily redacted based upon those 

interviews. So, keep that in mind. Again, the Work 

Group Members will have an unredacted version.

Chair Schofield: Okay.

Member Roessler: So, Tim, how will you be sending 

those?

Member Anderson: Through your CDC account, right?

(Simultaneous speaking.)

Member Anderson: If you don't have a computer, 

you're out of luck. Yeah, that's the problem.

(Simultaneous speaking.)

Dr. Taulbee: We'll mail it.

Member Roessler: Okay, by FedEx or something. 

Okay.

Dr. Roberts: To folks who can't access their CDC 

accounts.

Member Roessler: Okay. We should let who know, 

then?

Dr. Taulbee: Rashaun.

Dr. Roberts: Yes, me.

Member Roessler: Okay. All right. In writing 

probably, right? Or are you taking notes now?

Dr. Roberts: No, I have the note.

Member Roessler: Okay. So I don't have to let you 

know I want it by FedEx or some other means?

Dr. Roberts: No, no, I'll make note of that now.

Member Roessler: Okay. Okay, good.

Mr. Barton: This is Bob. Can I just ask: did all the 

Work Group Members today, were they able to get -
107

- were you all able to get unredacted copies of the 

reports that were discussed today? Or do we need, 

possibly, to send copies of those out? Because I think 

in this case it's very important that you see 

unredacted copies.

Member Roessler: Yes, I need an unredacted copy. I 

didn't realize until too late that mine was so redacted.

Dr. Roberts: Right. But, you know, they are --

(Simultaneous speaking.)

Dr. Roberts: Typically, what I will do when the noncleared version is sent out, I will email your non-CDC 

account and tell you to check your CDC account for 

the unredacted version of it. And then if you don't 

have access to it, then we typically FedEx it to you.

Member Roessler: That sounds good.

Member Anderson: The only troubles I've ever had is 

trying to get into the base storage, because I don't 

go there that often. So it's very helpful when you 

send it, you know, to my CDC confidential site as an 

attachment. That's a lot easier for me than trying to 

go into the data system to figure out the numbers on 

the various documents and things like that.

Board Review System Entries

Dr. Roberts: Okay. Are we ready to move into the 

Board Review System Entries?

Chair Schofield: I believe so.

Dr. Ostrow: Okay. This is Steve Ostrow. Can 

everyone see the slide I have up?

Chair Schofield: No, I don't see it.

Dr. Roberts: Not yet.

Dr. Ostrow: It should be. I've been sharing it. It 

should be there.

Member Anderson: Okay. It will be there in a minute.
108

Member Anderson: It's still loading. It's there.

Dr. Ostrow: Okay. That's it. Okay. Great. This is just 

a simple little thing. The Board Review System, BRS, 

we started into NIOSH 17 years ago, into INL 17 

years ago. NIOSH issued its first TBDs in November 

2003. SC&A did its first review in 2005. The first Work 

Group meeting, INL Work Group meeting, was 2009. 

And since then there's been many revisions of the 

TBD, lots of back and forth between all the parties. 

And we ended up identifying 38 Site Profile review 

issues. And there were tons of documents that went 

behind this; I won't even bother listing them.

And it turns out that none of the issues were ever 

posted in the BRS. And this was typical for a lot of 

the sites, not just the INL site. Last year, 2019, the 

project DFO at the time, Ted Katz, directed SC&A to 

form a comprehensive update of the BRS, not just

INL but for all the different.

SC&A went ahead. We went through all our 

documents and back and forth, and we sent a draft 

BRS Site Profile issues file to NIOSH to look at it and 

review it.

About a year later, March 2020, NIOSH marked up 

SC&A's 38 issues. And for the issues, it's not just the 

issue, it's the whole timeline. At such and such a 

date, SC&A produced a report. On such and such a 

date NIOSH produced a report and response and 

there was a Work Group meeting. So it's the whole 

timeline. And it has links in it, too, that you can click 

on different reports and you can actually pull them 

up in the BRS.

So, in March 2020, NIOSH sent us a mark-up that 

had grown now to 112 pages of comments and back 

and forth. And that was Megan Lobaugh, who is out

right now on leave.

We thought NIOSH made a real great effort on this 

and a lot of really helpful things. And, between April 

and June, we did some revisions of the Site Profile 
109

issues file. And then we worked with NIOSH to 

actually post it with the BRS, which is not a trivial 

process. It's one of these things that takes a little bit 

of technical skills to do that. But we worked closely 

with NIOSH and got all the secret ways of doing it 

and so forth. So, we did it.

And just recently, July 3rd, the Site Profile Issues BRS 

went live. Which means that, if you go to the BRS, 

which I believe is under the DCAS tool set, and click 

on that and go to the INL Site Profile Issues, you have 

a discussion of each individual issue and links to the 

actual documents that are referenced, which I think 

would be -- we'd like to revolve these 38 issues 

eventually, I'm sure. So, this would be very helpful 

for the Work Group.

This is just information on how it's listed. And the 38 

issues, this is where we are right now, 20 of the 

issues are closed, 16 are in progress, and two are in 

the abeyance. 

I believe the distinction, in progress means we've 

talked about it, discussed it, but still up in the air. It 

hasn't been resolved yet. In abeyance, I think it 

means we haven't dealt with it yet. 

I just made a comment that two of the issues were 

actually combined, 9 and 23 are close enough 

together that everyone agreed to combine it.

And the future activities for this. So far these are just 

Site Profile issues. There are also SEC issues, too, 

that came up in the last couple of years looking at 

the SECs at INL and ANL-West.

In April 2019, we sent NIOSH 35 draft SEC BRS 

entries for their review and comment. And we don't 

know exactly where NIOSH is on this, but we assume 

that they will go ahead and comment like they did on 

the Site Profile issues. And those will eventually be 

put into the BRS as a separate section.

It's a moving target because we stopped looking at 

Site Profile issues two or three years ago because 
110

we're giving priority to SEC issues. But the SECs have 

been moving along, so some of these issues SEC 

issues will have to either modified or we may answer 

them and so forth.

Just a note that at the May 16th, 2017 Work Group 

meeting, we had found three of the issues, LOFT 

Reactor, the HTRE test, and the Material Test 

Reactor, which came out of the SEC deliberations, 

should really be transferred to the Site Profile -- they 

should become Site Profile issues. This was an 

agreement between us and NIOSH and the Work 

Group.

NIOSH advised us the correct way to do this is not to 

transfer them now to the Site Profile BRS but wait 

until they're actually in the SEC BRS, which will come 

eventually, and then do a formal transfer of the 

issues from one to the other. 

So, that's where we are right now. And if anyone 

wants to look at it, it's actually up and live, the BRS 

for this.

Member Beach: Steve, this is Josie. I did review it, 

and I was mostly looking at the SEC issues. And so, 

let me clarify, NIOSH -- you have sent to NIOSH the 

different SEC issues. I think there's 30 of them. And 

you're waiting for a response back to update the 

BRS?

Dr. Ostrow: That's correct, Josie.

Member Beach: Okay. And I noticed those are 

unspecified SC&A users. So, at the time that you get 

those responses back from NIOSH, will you attribute 

a user to that specific SEC item and then add 

documents to those --

(Simultaneous speaking.)

Dr. Ostrow: Yes, we will. If you take a look at the Site 

Profile BRS that we just put in, we'll follow a similar 

format where we put in attribution on the issue. And 

we'll link to the reports also.
111

Member Beach: So that's something that needs to 

get some higher priority maybe, especially the SEC 

issues, to make sure those are tracking with where 

we're at as to the issues. 

Tim, can you tell us, or somebody from NIOSH, 

where you guys are on that?

Mr. Cardarelli: Hi. This is John Cardarelli.

Dr. Taulbee: Go ahead, John.

Mr. Cardarelli: Okay. I am working with Megan. And 

we will definitely -- we have an action item to 

basically put our entries into the BRS. And we will 

work diligently on that. Hopefully, in the next month 

or so we should reconcile what we can into that data 

system. Tim, do you want to add anything?

Dr. Taulbee: No. That's good.

Dr. Ostrow: Okay. So I assume you'll do something 

similar like you did to the Site Profile issues, that 

you'll mark up what we send however you like, send 

it back to us, and we'll work with you guys to actually 

post it.

Mr. Cardarelli: Yes.

Dr. Ostrow: Okay. Good.

Member Beach: And then can you let us know when 

that's done?

Dr. Ostrow: Yes, sure.

Mr. Cardarelli: Yes, we can.

Member Beach: Thanks. 

Dr. Roberts: Thank you. Anything else? 

(No response.)

Follow-up Actions

Dr. Roberts: Okay. Great. So, in terms of action 
112

items, I just want to make sure we know what needs 

to be done.

So, obviously, DCAS is going to gather the 

information on the interviews and put that together. 

And we'll be sending unredacted versions both to 

CDC accounts, and if that's not acceptable to people, 

mail them to them.

It seems like another thing that needs to be done is 

that NIOSH needs to respond to the SC&A report on 

the Burial Grounds -- I forget the action item. Let me 

try to get back to the exact. We need to develop a 

response, just to be accurate, yeah, to SC&A's report 

-- SC&A's review of NIOSH's response to the SC&A 

TR-2017-007 draft review of NIOSH's report for SEC219 for INL.

Member Beach: I think it's the May report.

Dr. Roberts: Yes, the May report. Okay. 

Dr. Taulbee: Right. What we're going to be 

responding to is why we believe the 18 workers are 

representative and bounding. That was brought up 

with for co-exposure model.

Dr. Roberts: Right.

Member Beach: So that's in addition to a response to 

the May report, right?

Dr. Roberts: Yes. That's my understanding. Okay. So 

we have that. 

That we need to schedule a Work Group in the future 

to talk about what the remaining areas of 

disagreement are. That will need to be scheduled for 

some time after August, once the interview data is 

disseminated to folks.

It also looks like a response from NIOSH is needed to 

the BRS entries. And there's going to be some 

interaction with the Work Group Members to put 

those entries into the BRS, if I'm understanding that 

correctly.
113

Dr. Ostrow: Well, I don't think with the Work Group. 

This is Steve. I think SC&A and NIOSH with that.

Dr. Roberts: Okay. SC&A and NIOSH. Okay. And then 

do we need an SC&A review -- SC&A was tasked with 

reviewing the work that NIOSH put together on the 

reactors. Is that correct?

Dr. Taulbee: Yes. That would be RPRT-0099.

Dr. Roberts: RPRT-0099. Okay. Perfect. Thank you 

for helping me with that. Am I missing anything?

Dr. Ostrow: This is Steve. Longer term, NIOSH, I 

heard, is continuing work on the reactor 

characterization studies, like the Report-0099 but for 

the other reactors that we identified.

Dr. Roberts: Okay.

Dr. Taulbee: Yes. This is Tim. That is ongoing work. 

And the modeling is done for several more of those 

reactors. It's the number crunching that is currently 

ongoing with that. So, there will be additional reports 

associated with that effort.

Dr. Roberts: Okay.

Chair Schofield: You're going to be doing that after 

you retire.

(Laughter.)

(Simultaneous speaking.)

Dr. Roberts: It sounds like we want to do a brief 

update -- sorry. Can you hear me? 

(Simultaneous speaking.)

Dr. Roberts: Go ahead.

Member Beach: Oh, I was going to say, I didn't know 

if there would be a report out from SC&A and/or 

NIOSH on that for the full Board or if just Phil is going 

to do it.
114

Chair Schofield: I think we can just do it. I mean, 

there's not a lot to report out on. I think today went 

pretty well.

Dr. Roberts: It sounds like that would be a pretty 

straightforward and maybe even a fairly brief update 

to the full Board. So, Phil, you said that you would 

cover that?

Chair Schofield: Yeah. And I'll send it to you for 

review.

Dr. Roberts: Great. Okay. Any other action items? 

(No response.)

Dr. Roberts: Okay. Any other comments before we 

adjourn the meeting? 

(No response.).

Adjourn

Dr. Roberts: Okay. Well, hearing none, thank you for 

your hard work. This has been quite a marathon 

meeting. I think a lot got discussed, a lot got done. 

So, thank you so much for engagement, and we will 

be in touch.

Chair Schofield: Okay. Thank you.

Dr. Roberts: Thank you.

(Whereupon, the above-entitled matter went off the 

record at 3:47 p.m.)