NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

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

Metals and Controls Corporation Work Group

Thursday, May 3, 2018

The Work Group convened in the Montreal Room of 

the Cincinnati Airport Marriott, 2395 Progress Drive, 

Hebron, Kentucky, at 8:30 a.m., Josie Beach, Chair, 

presiding.
2 

Present:

Josie Beach, Chair

Henry Anderson, Member*

David Kotelchuck, Member

Loretta R. Valerio, Member

Also Present:

Ted Katz, Designated Federal Official

Nancy Adams, NIOSH Contractor*

Bob Anigstein, SC&A*

Pete Darnell, DCAS

Mike Elliott

Rose Gogliotti, SC&A*

Kevin Kane

Jenny Lin, HHS*

William Lorenzen

John Mauro, SC&A

Pat Mccloskey, ORAU Team

Jim Neton, DCAS

Mutty Sharfi, ORAU Team

John Stiver, SC&A*

* via telephone
3 

Contents

Welcome and Roll Call 4

SC&A Review NIOSH SEC Petition Evaluation Report

9

Action Items/Path Forward: NIOSH Evaluation 114

Petitioner's Comments, Concerns, and Questions119

Adjourn 139
4 

Proceedings

(8:30 a.m.) 

Welcome and Roll Call

Mr. Katz: This is the Advisory Board on Radiation and 

Worker Health. It is the Metals and Controls Work 

Group. It will be the first meeting of this Work Group.

There are some materials for the Work Group today 

that are posted on the NIOSH internet page under 

schedule and meetings, today's date. So you can go 

there.

Most importantly, John Mauro of SC&A has a 

presentation there. So anyone of you who want 

access to that presentation can see those slides there 

on the internet.

There is also an SC&A review. It's posted on the 

NIOSH site. But I'm not sure they've moved it yet to 

the meetings page. So you could check on that. If it's 

not there yet, it will get there. I don't know exactly 

when.

And there is a NIOSH White Paper which hadn't 

cleared DOE review in time to be posted there. But 

when it does clear, it will be posted there as well. So 

you'll be able to see -- which is the NIOSH responses 

to the SC&A review, in effect.

So all those will be posted on that, on today's date 

meeting date, that portion of the website so you can 

find it easily in connection with this meeting.

Let me get to roll call. One other thing just for people 

who are not familiar with these Work Group meetings 

that may be on the phone, please everyone keep 

your phones muted. And if you don't have a mute 

button on your phone, press *6 to mute your phone. 

And you press *6 again to take your phone off of 

mute. But please keep your phones muted except 

when you're addressing the group.
5 

For members of the public, there is on the agenda an 

opportunity for you to comment on what you've 

heard or questions later in the day. But otherwise you 

should keep your phones muted during the 

proceedings.

And also, please no one put the call on hold at any 

point. That sabotages the audio for everyone else. 

So, please, if you need to leave the meeting for a 

piece, just hang up and dial back in, but don't put the 

call on hold at any point.

Henry Anderson, are you on the line?

Member Anderson: Yes, I'm here.

Mr. Katz: Okay. So roll call.

(Roll call.)

Mr. Katz: Okay. That takes care of roll call. The 

agenda for the meeting is also posted, by the way, 

on the NIOSH website, same place, schedule and 

meetings, today's date, so you know what's 

happening when, although not what time, just order.

And with that, I think that takes care of things. Josie, 

it's your meeting.

Chair Beach: Okay. Thank you. And welcome 

everybody to our first Metals and Controls meeting.

We are going to start with SC&A. We had a 

presentation several months ago on this, on metals 

and controls. SC&A's report is posted on the NIOSH 

website. Hopefully, Andy, you found that by now and 

the slides.

Member Anderson: Nope, I'm not there yet.

Chair Beach: Okay. It's fairly simple to find it. If you 

have trouble, let us know. You just Google it. It'll 

come up.

And we're going to go through your report. SC&A's 

report is posted along with the slides. And we're 
6 

going to start with SC&A with going through your 

slides, the presentation.

And I understand we're going to stop as we get to 

each finding and have a discussion. This is the first 

SEC discussion. So there are some SEC questions I'm 

sure that are going to come out and want to be 

discussed through this process.

So, and I also noticed, Pete, the memo is posted that 

you put out, the three-pager. Did you have any plans 

to discuss that, or is that just on there for 

background?

Mr. Darnell: It was one of the documents -- 

Mr. Katz: That was -- 

Mr. Darnell: -- for background.

Mr. Katz: So that was posted as background because 

-- 

Chair Beach: Just background, okay.

Mr. Katz: -- at the time we didn't have the White 

Paper.

Mr. Darnell: Right.

Chair Beach: Okay.

Mr. Katz: But now we have the White Paper, which is 

-- 

Chair Beach: And I'm not sure how much we're going 

to get into that subsurface White Paper. I don't know 

that SC&A has had time or the Work Group has had 

time to really look at it. But we'll see how we're doing.

Mr. Darnell: SC&A's pretty much aware of what -- 

Chair Beach: I understand, yes, yes. They just 

haven't gotten anything out to the Work Group, their 

reply to it or -- so, anyway, we'll just go step by step 

and see where it takes us. I don't expect this to last 
7 

too late into the afternoon. But, again, we'll see 

where it takes us.

So, John, if you want to get started -- let me ask 

Andy. Have you got there yet?

Member Anderson: No, I'm still playing around.

Chair Beach: Okay. So did you go into Google, NIOSH 

Radiation Advisory Board? That's the simplest way to 

find it on your own computer.

Ms. Gogliotti: If you can't find it, it should be in your 

email.

Chair Beach: Oh, there you go. Someone you know 

got it to you.

Mr. Darnell: Josie, before we move on, Pat reminded 

me if we can't get the White Paper mostly addressed 

or fully addressed in this meeting, we may not meet 

the August date for the Board meeting.

Chair Beach: Okay.

Mr. Darnell: So just wanted to let you know.

Chair Beach: Okay. Thank you.

Dr. Mauro: Also what might be helpful, since we've 

seen the White Paper just a few days ago, my crew 

and myself had a chance to read it. And I think, 

though, what could get very useful is we are 

addressing the same issues, subsurface is, you know, 

the primary thrust, although we address a few other 

pathways.

What would be good is -- where I'm really headed 

here is there are these unusual pathways that were 

not addressed before but are being addressed now.

SC&A came at the problem as best we could. And you 

did too. And to get an understanding of where we are 

different on how we see it and how we come at the 

problem and the data we use, so from that 

perspective when we hit each issue we're going to be 
8 

talking about the issues you talk about.

And so, if we can engage at that point, when I'm 

talking about some of the subsurface things we did 

and the data we used, it would be good to hear a little 

bit more, because when I read your report it looked 

like you may have had additional data that we may 

not have had because you -- you know, things like 

that, but as a preface, so we could interact. Okay -- 

(Simultaneous speaking.)

Chair Beach: Okay. And then before we get started, 

sorry, John, I'm going to take it back again, we do 

have a issues matrix that was handed out this 

morning. Who's going to be keeping notes, anybody? 

I know I always do. But it would be helpful if each 

group -- and, John, I don't know if you've got 

somebody online that will keep notes for SC&A's -- 

Mr. Katz: Well, it's, we don't, I mean, we don't have 

-- in this case, we don't, I mean it's a Work Group 

meeting so -- 

Chair Beach: Right.

Mr. Katz: -- we have a transcript and -- 

Chair Beach: No, I get that -- 

(Simultaneous speaking.)

Mr. Katz: The only question is who will update the 

matrix after the meeting -- 

Chair Beach: Yes, that's what my point was.

Mr. Katz: It's just SC&A or NIOSH.

Chair Beach: Yes.

Dr. Mauro: Just action items, that's one of the 

important things. As we move through it, anyone say 

you've got an action item -- 

Chair Beach: Right.
9 

Dr. Mauro: -- and I'll write that down.

Mr. Katz: So did you put together the matrix, Pat?

Mr. McCloskey: Yes.

Mr. Katz: So, Pat, since he put together the matrix, 

he can update it after the meeting.

Mr. McCloskey: Sure.

(Simultaneous speaking.)

Mr. Katz: Yes, always, right.

Chair Beach: All right.

Mr. Katz: Thanks. John, take it away.

SC&A Review NIOSH SEC Petition Evaluation Report

Dr. Mauro: Okay. We're going to talk about Metals 

and Control Corporation and its SEC. This is a metal, 

uranium fuel handling facility, a classic AWE facility 

just outside of Boston, south of Boston. 

And they were in business, started it as an AWE, 

starting in 1952. And they continued as an AWE right 

up to about the end of 1967.

And it turns out -- in fact, I'm going to be talking 

more than going to my slides. I'll try to stay with my 

slides. But I find it easier just to talk, you know --

(Laughter.)

Dr. Mauro: So we're going to flip through the slides. 

And so we're going to be talking about there is an 

SEC petition that was filed, number 236. And it 

specifically addresses the residual period.

A previous SEC petition was filed and granted that 

covered 1952 to the end of 1967. And the reason it 

was granted was the inability to reconstruct internal 

exposures from thorium. So that's behind us.

Now we're moving on to the AWE period. And in fact, 
10

if you want to flip to page 3, and we're going to be 

talking about it's important to understand that there 

are two levels we're going to operate on.

One is the SEC question, which is can you --- and it's 

a judgement the Board makes, can doses be 

reconstructed with sufficient accuracy.

SC&A doesn't come to that conclusion. We don't 

make those conclusions. I'm saying this as my 

understanding of the policy. And certainly, Ted, 

correct me if I'm wrong.

What we say is whether we think doses could be 

reconstructed with scientifically sound and claimantfavorable and why and the data we use and the 

assumption we use and why we believe we can do it.

The judgment whether it meets the criteria of 

sufficient accuracy, certainly that's a Board decision.

And it differs from a standard Site Profile, because 

what we're really asking is, listen, do we have the 

data and the information regarding activities that we 

think is a trackable problem. It's one of the words 

I've been using for quite some time.

That differs than saying what we will call a Site Profile 

issue. That means, well, we think we can track it, but 

we don't, we may not necessarily agree on all the 

assumptions regarding resuspension factors and 

occupancy times.

These are things we have to discuss. And so they're 

different. And I think it's more important today, in 

my opinion, that we get a grasp on do we have the 

data and do we understand what took place at this 

facility to the extent that we could reconstruct the 

doses from this facility.

What those particular doses are, we have some 

estimates that we made. But they're more as 

examples that, yes, I think we could do it.

And in fact, right on page 3, and that's a good place 
11

to start the discussion, I give you the end of the 

story. And then we'll take it from there. The end of 

the story is that we believe that the doses could be 

reconstructed. So -- 

Chair Beach: John, could I back -- 

Dr. Mauro: Yes.

Chair Beach: So, on your slide, you're on page 2.

Dr. Mauro: Well, the bottom of the page says 3.

Chair Beach: Okay. But if you look online, it -- oh, it 

does say 3. Mine says 2. That's -- 

Member Anderson: I got it. I'm here.

Chair Beach: Okay.

(Simultaneous speaking.)

Dr. Mauro: Okay. Yes, I'm on page 3. Well, my hard 

copy trying -- 

(Simultaneous speaking.)

Chair Beach: That's weird. My pages are just off. I'll 

just go by this. Thank you.

Dr. Mauro: So -- 

Chair Beach: I just wanted to make sure we were 

tracking.

Dr. Mauro: We're going to get into the bowels of this. 

But in the end, our takeaway, and it wasn't easy to 

get to this position by the way when we're talking 

about it, that we think you can reconstruct the doses 

for the workers during the residual period in a 

scientifically sound and claimant-favorable manner.

However, now the second part is, but we reviewed 

your original Evaluation Report. I understand you're 

supplementing it. But we reviewed it. And we did 

have lots of concerns. And they were all delineated. 
12

And in fact, they're all itemized as observations and 

findings, which we could discuss.

But the most important issue really is our takeaway 

is that we think you can do it. Now, I want to sensitize 

everyone to this is, this was a tough judgment for us 

to make. And I'm going to tell you why in a second, 

because we're going to go to slide number 4. Okay.

I more or less already introduced this slide, but just 

to get a picture, nice to look at a picture. When you 

think about metals and control, you should think 

about that really there are these two time periods 

from 1952 to 1967, which was the AWE operations 

period where there was a very good health physics 

program in our opinion. We reviewed it. We reviewed 

what they did and all their metal workings activities 

and fuel handling activities.

And, but they did have a problem with thorium, as I 

mentioned earlier, that they couldn't reconstruct 

that. So, therefore, if you look on the left-hand side 

of my little picture, an SEC was granted, it's SEC00149, because of the inability to reconstruct internal 

doses of thorium.

And now we're going to leave that. And starting in 

1968 all the way till 1997 is the residual period. Now, 

NIOSH wrote an Evaluation Report regarding that 

time period. And the outcome of that was, yes, we 

can do it. And you describe all of your assumptions 

and how you do it.

And this is the really important point. Well, how come 

you came to that conclusion? How can you do that? 

Because there was very little data.

In other words, when you look at it, you say when 

1968 began and the residual period, there were all 

these workers -- and they're all doing now nonradiological work. It's commercial work except for 

one very special type of activity called HFIR. Not even 

going to talk about that.
13

That was a fuel activity, took place in Building 10. But 

those workers had nothing to do with the AWE. They 

just happened to be there working in their own little 

box.

And so, though there was fuel onsite being handled, 

it was in that separated area. We're not concerned 

about reconstructing those, their doses. They're not 

covered.

We are concerned about the workers that worked 

primarily in Building 10, but other buildings also, 

where they were doing their classic commercial 

metals and control work. And they were working at a 

time beginning in 1968 when they were under the 

impression there was no radioactivity there. It was 

all the fuel, that AWE-related activity was long since 

gone. They took that, got rid of it. Okay.

And you could see that, while there was AWE activity 

going on, there was a pretty good health physics 

program where took care of business and they kept 

the place as clean as they could, that sort of thing.

Mr. McCloskey: Hey, John -- 

Dr. Mauro: Yes.

Mr. McCloskey: -- you're right. All the AWE fuel left 

at that point. But there's still a lot of fuel onsite for 

HFIR.

Dr. Mauro: Yes.

Mr. McCloskey: And the workers really didn't have a 

clear distinction between it. So -- 

Dr. Mauro: Yes, but they're -- see, in my mind, I see 

what you're saying. Any doses an M&C worker might 

have experienced from HFIR work don't count -- 

Mr. McCloskey: That's correct.

Dr. Mauro: -- during the residual period.

Mr. McCloskey: That's true.
14

Dr. Mauro: It's a residual period.

Mr. McCloskey: Yes --

Dr. Mauro: That's a good point by the way, you know 

--

Member Kotelchuck: And why doesn't it count?

Dr. Mauro: Well, you know, since the HFIR work was 

fuel-related work not AWE-related and when you're -

- during the actual AWE period, there's very often lots 

of different types of radiological work going on.

Member Kotelchuck: Sure.

Dr. Mauro: Some of which is AWE work and some of 

which is not. When that's going on, there's an 

obligation. And this is the policy that NIOSH has 

adopted is, well, you have to include all the doses. 

For example, they may be working with radium 

beads. They may be working with fuel not for the 

weapons complex.

And if that's onsite and you're in the AWE period 

where people are doing AWE work, you do have to 

include those doses.

But once you leave that time period, the AWE period, 

now you're in the residual period. Any exposures 

associated with non-AWE work don't carry through. 

In other words, you don't have to add them in. Once 

you leave the AWE period, then you're in the residual 

period. So that's how we came at the problem.

We are only concerned with what are the exposures 

experienced by M&C workers due to residual 

radioactivity associated with AWE activities that 

ended in the end of 1967. So that's why it's good to 

strategically sort of understand how the game is 

played.

So what was NIOSH's job, well, our job? It was 

NIOSH's job to say, okay, starting in 1968, we've got 

all these workers doing commercial work under the 
15

impression there's no radioactivity anywhere. And 

they're doing their job and -- which was commercial 

work.

Now, it turns out along the way later on they wanted 

to terminate their NRC license. They had a license, 

originally had a license.

So a team of ORAU people, I believe, came in with 

contractors to say, well, we're going to terminate 

your license. So we're going to -- and we're going to 

D&D any residual activity. This was called the classic 

FUSRAP characterization of clean-up activity.

Well, lo and behold, what happened was they says, 

holy mackerel, there's some radioactivity still, the 

residual at this site and -- which was a classic AWE 

residual period situation. We've run into this time and 

time again. And so you have to be able to reconstruct 

those doses.

Now, it turns out interestingly enough -- and this is 

also the opening of our report, our February 3rd 

report. I asked one of our crew to look into it and say, 

listen, how often do we run into a circumstance --

Mr. Katz: Excuse me. Let me interrupt. Someone has 

an open line on this.

Dr. Mauro: Okay. Yes, well, I'm trying to set the 

table. So what we have is these workers that were 

working. And the --

Member Anderson: What slide are we on now?

Dr. Mauro: We're still on 4. And I will flip through the 

slides as we go. But I'm trying more to set the table 

--

Member Anderson: Okay.

Dr. Mauro: -- so conceptually you can understand.

And when you look at this page 4, the important point 

I want to make here is that you have this long time 
16

period from '68, from the end of '67 to '68 to 1997, 

which is the residual period, lots of workers involved 

in work doing all sorts of non-AWE activities, 

commercial work, very busy.

And a petition was filed. Listen, we found out -- this 

is the workers talking now. Geez, we found out that 

there was residual radioactivity at the site. So all 

these workers that were working actually received 

some exposure.

And they decided, their judgment was they needed 

an, they think they should get an SEC. So they filed 

their SEC petition. Okay.

NIOSH said, okay, we'll review it. And they prepared 

their SEC, more SEC Petition Evaluation Report, 

which is the report that currently is active, even 

though we all recognize that, in light of things that 

we've learned, you'll be doing some amendments. Is 

that correct?

Dr. Neton: That is correct.

Dr. Mauro: Good. Okay.

Dr. Neton: Or revisions.

Dr. Mauro: Or revisions? Whatever you see fit. All 

right.

Now, the thing that's interesting about this problem 

is that when you're in a residual period you have a 

problem. We know that usually the amount of 

radioactivity is kind of low compared to the AWE 

period because they removed all the radioactivity 

except what was residual. And so you expect that to 

happen.

But so one of the first things we did is say, listen, 

how prevalent is it where AWE facilities are granted 

SECs for the residual period. We have a lot of history.

Turns out there are 50 of them where there was a 

petition for an SEC covering the AWE period. And it 
17

turns out we found 3, so 3 out of 50. So it is kind of 

rare.

And we did that just to say, listen, under what 

circumstances do we find that SECs are granted, 

were granted. And it usually occurs when something 

unusual takes place during the SEC period. Okay. So, 

and where for some reason there's an unusual 

amount of radioactivity left over, a residual, or 

workers are doing things during the SEC period that 

are unusual that put them in contact with that 

material. And it's very difficult to reconstruct their 

doses. So we know that from historical precedent.

So the question we posed to ourselves is, okay, do 

we have that here. Is there anything unusual? All 

right. Let's flip the page.

Member Kotelchuck: Although -- 

Dr. Mauro: Yes.

Member Kotelchuck: Although -- Dave Kotelchuck. 

But we look at each case individually. And therefore, 

we're not talking about precedent, are we? We're 

talking about, okay, we're looking at this case 

individually.

Dr. Mauro: Yes.

Member Kotelchuck: But this is what has happened 

in the past. And it may inform our perspective.

Dr. Mauro: Exactly.

Member Kotelchuck: Okay.

Dr. Mauro: Exactly. That's the only reason why we 

did that.

Member Kotelchuck: Yes.

Dr. Mauro: And to get a -- it sort of sensitizes us to 

when you do run into the circumstance. That doesn't 

mean something different could happen here.
18

Member Kotelchuck: Right.

Dr. Mauro: But it sort of helped us lay the 

groundwork.

Member Kotelchuck: Okay. 

Dr. Mauro: We're going to go to slide number 5.

Participant: Excuse me. When are questions allowed, 

at the end or during the slide?

Mr. Katz: Yes, we have a session. It's on the agenda. 

But it's after all this discussion there's a -- I will ask 

for the petitioner, if the petitioner wants to comment 

or make questions. I'll ask for that later. Thanks. 

Dr. Mauro: In fact, let's stick with slide 4 just for one 

more minute. Okay?

When you look at slide 4, you'll see the top line. And 

I mentioned earlier one of your problems in trying to 

reconstruct doses during the residual period is the 

lack or deficiency of data, because usually they stop 

their health physics measurements. They stop taking 

film badge readings. They stop taking bioassay 

samples. They stop taking air samples because they 

just moved out all the radioactivity.

The contract's over. And so you're really not routinely 

making measurements. So, if you want to 

reconstruct doses during the AWE period, you got to 

become creative and say how are we going to do this 

thing.

Well, it turns out -- and that's why this top line is 

important. It says the sources of the data that are 

fundamental to being able to do a dose 

reconstruction during the residual period turns out 

taking advantage in some way the data that you do 

have, and we're going to get into this, during the 

AWE period.

There's certain information during the AWE period 

that was collected that you will see when we get into 
19

it can be useful to you in predicting what took place 

during the residual period.

In addition, once they got into the process of license 

termination, in other words before you could actually 

terminate your AEC license, you have to go in and 

ORAU goes in and contractors come in to make sure 

the place is clean and meets the current standards 

for termination of license. Everything is fine.

And there were certain measurements made. One set 

of measurements were made around the 1984 

period. I actually think it was 1982. But it's in the 

'80s.

So someone came in. It was '82. So a team came in 

and made some measurements. And they said, ah, 

we got some residual radioactivity we're finding here. 

Oh, okay.

And then later on they brought in a contractor to do 

the formal FUSRAP clean-up, license termination type 

work where a team comes in. They characterize the 

nature and extent of the radioactivity in the 

environment. Is there any? And if there is, we got to 

clean it up.

So where does the data come from so that you could 

reconstruct the doses? The data comes from 

whatever you could use that might be useful that was 

gathered during the AWE period, whatever was 

collected in that 1982 -- that '84 is the wrong 

number. I think it's 1982 on the slide.

And then in the 1990s is when a really aggressive 

clean-up program, characterization and clean-up 

program took place, which is a really good program, 

it was performed by, I think under the direction of 

some of the Texas Instruments people at the time. 

And the contractors came in. [identifying 

information redacted] came in.

[identifying information redacted]was there. 

Everybody knows -- I don't know if everybody knows 
20

[identifying information redacted]. He's the 

head of, one of the leaders of the CDC Radiation 

Studies Branch. He was part of the team. 

Interestingly, Mark Griffon, who we all know and 

love, was part of that team, and a company called 

CPS.

And we looked very carefully at that program. It was 

a good one. They had good health physics controls. 

They took lots of really good measurements.

So, at that real back end way in 1992, there's data 

that they collected. Okay. So that sort of sets the 

stage of, all right, this is a body of information we 

have available to us to somehow use to reconstruct 

doses during the residual period.

Now we can move on to, a little bit more quickly. But 

I think it so important to set the table and understand

where, you know, how this whole thing plays out. 

Slide 5. Okay.

There's only really one reason I brought up, I put 

slide 5 together. The SEC Petition Evaluation Report 

was issued in April 2017. This is the report that 

NIOSH prepared.

And that's the report that SC&A was asked to review. 

And we got to work. And we're reviewing it, looking 

at the internal, the data that they had, internal 

exposures and external exposures.

Along the way, the petitioners, I think there was 

some feedback, because they looked at the SEC 

Petition Evaluation Report also.

Chair Beach: There was two letters that were sent. 

Dr. Mauro: There you go. And they brought up a very 

important point. They said, folks, I think you guys 

missed the boat. There was an awful lot of things that 

took place during the residual period that you did not 

take into consideration. Okay.

And because of that, we held a special three-day 
21

meeting. What was the town just outside of Boston? 

Started with an M.

Dr. Neton: Attleboro?

Dr. Mauro: No, Attleboro was I think -- 

Mr. McCloskey: Madison --

Dr. Mauro: Manfield. Manfield?

Mr. McCloskey: Yes, Mansfield.

Dr. Mauro: Manfield, we met in Manfield. And, you 

know, Pat and Pete, myself and Rose Gogliotti were 

there. And we met with 12 of the workers that 

worked there during the residual period. And they 

were great. They just poured out information. And 

the transcripts I think are now available for 

everybody to read.

And these are the people that actually were there. 

They worked there during the residual period. And 

they all told their personal experience and what they 

did.

So we have -- in October, actually on the 24th 

through the 26th of October 2017, they come in and 

they tell their story. And son of a gun, they were 

right. There were some really unusual things going

on that created circumstances that were not captured 

explicitly in the SEC Petition Evaluation Report.

So the takeaway, and I think we would all agree, the 

takeaway is, you know what, we got to go back to 

the drawing board and do the best we can to see if

we could reconstruct those unusual exposure 

scenarios that they described to us using the 

information they gave us.

And so that became the key. So now, and here we 

are today talking about it.

You know, so we went ahead and wrote our report, 

this February report that includes all of this. And our, 
22

I guess, outcome is that I think we have enough data 

that we could reconstruct these unusual scenarios 

that we're going to talk about in a minute.

But it's a stretch. Okay. I'll be the first to admit we 

struggled with it. You know, do we really have 

enough information here that we could model these 

doses? And we caucused a lot on that. And we talked 

about it.

And our takeaway is, yes, I think you could do it. All 

right. And we explained why. We explained the data 

we have and why we think we could do it.

And in my opinion, it's, you know, we -- that's our 

takeaway. But really it's the Board that has to judge, 

well, do you really have enough data to do that. Do 

you really understand the scenarios, these kinds of 

unusual things that took place in the residual period 

that you could marry those activities to the data and 

somehow come out with a way to calculate worker 

doses, right?

And that's a judgment. Our takeaway was, yes, you 

could do it. And we actually give examples in our 

report of how we would do it. Okay.

Now, we're not saying -- in fact, not only that, we 

give examples. But we also talk about a number of 

strategies you could come, you could use. There's a 

lot of ways you could, you know, come at this kind of 

problem.

We picked one particular, a couple of approaches to 

do it. And we give our results and the doses.

And the outcome was, well, there are a lot of different 

scenarios, a lot of different activities. And we're going 

to talk about those activities.

But one in particular turned out to be the one that 

had the greatest potential, in our opinion, to cause 

additional exposures that were not originally 

addressed in the Evaluation Report. And that's 

referred to as subsurface activities. And we're going 
23

to get a little bit into that.

These are things that the workers did a lot of when 

they dug holes and worked underground. And, lo and 

behold, under the ground there was residual 

radioactivity.

There were pipelines that they cut. There was a lot of 

hands-on work in the hole, in the ground, under 

Building 10, and outdoors where there was residual 

radioactivity where the workers up close and 

personal close to this residual activity. All right.

So, but -- and we're going to get into other scenarios, 

other ways also that we looked at. But it turns out 

they did not really, they were not the big drivers.

Although, as we discuss this, I know Josie has her 

thoughts. There may be some others that you guys 

didn't look at. We talked about this last night. And I 

think it's important we talk about that. And we'll get 

to that. Okay. Let's move on.

Chair Beach: I just don't want to get too far into Site 

Profile stuff --

Dr. Mauro: Right.

Chair Beach: -- because I know some of your slides 

appear to be more like Site Profile in --

Dr. Mauro: Yes.

Chair Beach: So I want you to be careful with that.

Dr. Mauro: And we're going to -- I'm going to 

emphasize the data, what it is and why we think you 

could use it, and not whether we use the 50th 

percentile --

Chair Beach: Okay.

Dr. Mauro: -- the 95th percentile, no. We're going to 

talk about, listen, here's the data we have. Can you 

use that data to model that pathway? Or that just 

doesn't work. And therein lies the SEC question. Do 
24

you have the data? And are you stretching it too far? 

That's it. You know, and that's a judgment call.

So we're going to move on. And we're going to first 

talk about reconstructing the internal exposures. 

Okay. All right.

Now, we could think about this and there's --

Chair Beach: What page are you on --

Dr. Mauro: I'm on page 7 now.

Chair Beach: Okay.

Dr. Mauro: Okay. All right. Now, the way I'm going 

to tell my story is NIOSH wrote their SEC Petition 

Evaluation Report. And they have described in detail 

the method they used to reconstruct internal 

exposures during the AWE period. Okay.

And so we reviewed this report from the point of view 

of the classic approach. Okay. This is how you plan 

to reconstruct internal exposures. And do we have 

anything to say about it? Okay. That's on one level.

The other level, which is the more important level, is 

we now know that there were sources of internal 

exposure that are uniquely associated with the 

residual period that are not explicitly addressed in the 

current version of the Evaluation Report. And we're 

going to get to that part.

So I actually broke it up into two parts. Okay. What 

are our comments on your SEC Petition Evaluation 

Report and how you came at doing the internal 

exposure? And we have some comments on that. 

We'll talk about that.

But more importantly, and we got to get to this, is, 

well, what about these new pathways that the 

workers described to us. How are you going to deal 

with that? And we're going to get to that.

But let's first do the, what I call the classic Evaluation 
25

Report, internal exposures. Okay. Now, it turns out 

that the pathway that NIOSH evaluated is called the 

classic resuspension pathway for internal exposure.

You could visualize -- for those of you who have done 

AWEs, you've heard this before. But for those of you 

who haven't done AWEs, this is the classic problem. 

During the AWE period, they're machining and 

working and handling uranium. The deposits happen 

on the floor, on the ground. Okay.

When the AWE period ends, they get rid of all the 

uranium and some thorium. And what do you have 

left? You have a little residue or a little whatever on 

surfaces. Okay. It's there.

And now you're in the AWE period. And there's 

workers working around not knowing that there's 

residual uranium on the ground. And they kick it up. 

It becomes airborne. They breathe it. They ingest it. 

So you have to model that pathway. Okay. So NIOSH 

said, okay, we have to model that pathway.

And here's where we were in a fortunate position. It 

turns out that in 1966 and '67, the last two years of 

AWE operations, they took 7,776 swipe samples from 

the surface to characterize the end of, toward the end 

of the AWE operations. As part of their regular health 

physics survey program, they collected that data.

NIOSH says, okay, we're going to assume that that's 

the level of contamination that's on the floor at the 

beginning of the residual period. Good, good, classic, 

what's called OTIB-70 approach to the problem.

Then they said, okay -- and this is removable 

contamination. They take a paper. They wipe the 

surface. They count it. Okay. So they have the results 

presented as dpm per 100 centimeters squared of 

surface contamination. And they have 7,765 of those 

values.

NIOSH went ahead and said, okay, that's the stuff 

that could become resuspended and people breathe 
26

it. That's the stuff that people will be standing on and 

could get external gamma and beta exposure from.

NIOSH elected to say, okay, they're gathering the 

data, and they put it into a distribution. And they say 

we're going to pick off the upper 95 percentile of 

those 7,000 numbers.

Chair Beach: Okay. Can we -- can I stop you before 

--

Dr. Mauro: Sure.

Chair Beach: -- you get to that, because I had a 

question on the swipes before you get into the 90th 

percentile?

And my question when I originally read this was 

where did you get the swipes. So I actually went in 

and looked. And I have a list of where they were all 

located.

And I want to say that probably about 75 percent of 

them are illegible. You can't read them. And I see 

where they had '66 to '69. And you're only electing 

to do '66 and '67, those years.

But I have a question, because it's hard to distinguish 

where those were even taken. A lot of them you could 

kind of make out floor. You have the front page that 

says locker room, machine shop, x-ray inspection 

area, the applied physics lab.

I guess I'm going to have a hard time with how you're 

going to take those smears and use them in this 

environment. And most of it you can see are floor. I 

don't see a lot of walls. I don't see rafters. I don't see 

anything in subsurface areas where these guys were 

actually working. So I do have questions on those.

Mr. McCloskey: Of course, we concede that the 

subsurface isn't modeled well with this model. And 

that's why we're going to talk about a whole different 

scenario. And the rafters, there might be some 

overhead contamination surveys available there. But 
27

-- 

Chair Beach: It's not clear by those, by -- 

Mr. McCloskey: And you're right. The legibility is a 

concern. It was a struggle.

But we understood which, you know, to the extent 

that those surveys were labeled, we understood 

which areas were within the HFIR or excluded areas. 

And we tried to only use the areas that were outside 

of the HFIR within the final periods of the AWE 

operations. And so, I mean, we blow up this -- 

Chair Beach: So some of the areas that have the 

really high readings were like the enriched vault. Is 

that something you were going to use? Or the 

smelting room, the nuclear -- I mean, there's some 

that are clearly higher.

Mr. McCloskey: Yes, I think the rooms you just 

mentioned are HFIR rooms. I have maps. And like -- 

Chair Beach: Yes --

Dr. Mauro: -- we've done before -- 

Chair Beach: Yes, okay. So I'm just saying I'm 

concerned about that smear data as being usable for 

what we're talking about, some of the areas where 

you guys of concern is. So -- 

Mr. McCloskey: Okay. I know Rose looked at that 

pretty closely.

Dr. Mauro: Yes, Rose, are you online?

Ms. Gogliotti: I did actually go through that data with 

a fine tooth what NIOSH had actually used in their 

modeling versus what was actually used. And they 

were very, very claimant-favorable.

And in terms of the illegible readings, if it was, could 

have been a 4 or a 9, it was always the higher 

number. I went through maps and everything that 

could clearly be this area versus the HFIR was 
28

included.

Chair Beach: Okay.

Ms. Gogliotti: And I actually only used the later data, 

because that would be more representative of the 

residual period rather than the earlier, which had 

more activity going on from operations.

Chair Beach: So what dates are you saying were 

considered the later?

Ms. Gogliotti: The '66 and '67.

Chair Beach: Right, okay. Yes, and that's -- I saw. 

And I'm not questioning that they used the most 

claimant-favorable.

My question is more in line with where the swipes 

were taken and what areas workers were actually 

working. And that can just sit on the table for now. 

And I know we're going to get into that discussion --

Mr. McCloskey: One of the things you've seen me do 

in the past, Josie, I would take these maps, floor 

plans --

Chair Beach: Yes.

Mr. McCloskey: -- in the facility and put them in front 

of four former workers and have them point to the 

areas so that I could sort of marry what --

Chair Beach: Yes.

Mr. McCloskey: -- the description is on the survey to 

an area.

Chair Beach: Yes, and I caught that when I was 

reading all the worker transcripts. I did catch that --

Mr. McCloskey: Oh, okay.

Chair Beach: -- they were looking at maps.

Mr. McCloskey: Good.
29

Chair Beach: So I know --

Mr. McCloskey: Okay.

Chair Beach: -- that that's what you did. And I'm 

sorry I was not able to attend that meeting. But, so, 

yes, I understand that.

I just -- my concern is out on the table with those 

swipes and with where the folks were actually 

working. So we'll get into some more of that.

Member Anderson: So this is Andy. My concern was 

the representativeness and the sampling strategy, if 

there was one, when they did it.

Chair Beach: Right.

Dr. Mauro: Rose, as I recall, we talked about it and 

they set up a grid system?

Member Anderson: Okay.

Dr. Mauro: Yes.

Chair Beach: I think that was outside --

(Simultaneous speaking.)

Member Anderson: -- anything in writing, here's our 

strategy or --

Ms. Gogliotti: Well, these samples were actually 

taken as part of the regular operations at the site just 

to make sure that everything was acceptable for the 

workers that were actually working areas.

Chair Beach: Right.

Member Anderson: Okay.

Ms. Gogliotti: This wasn't part of the D&D.

Member Anderson: Okay.

Chair Beach: Not at all, which is the point I'm trying 

to make, too. And it has, there's nothing for outside 
30

in the grid sampling you're talking about. And the 

workers did work outside. And there's nothing for 

that at this point in the swipes, which is some of the 

data you're planning on using.

Mr. McCloskey: Right, the workers outside, we would 

be concerned about the subsurface exposures out 

there.

Chair Beach: Right.

Mr. McCloskey: And we concede that the model that's 

in place using this surface resuspension doesn't 

accommodate those folks well enough. And we're 

going to address that with a separate method.

Dr. Mauro: So, as I understand it, our takeaway was 

they had lots of good data and the AWE, and as an 

all classic AWE, I'm sorry, residual period for AWE 

sites, that's the OTIB-70 strategy. And it's been used 

time and time again. And it's been found to be 

acceptable. And we feel that this falls within that 

domain. And that's what was done. And once you get 

-- please.

Chair Beach: I was just going to say it does fall within 

the domain if you know what they're dealing with. 

But we're talking about subsurface work, inside and 

outside. There's roof work. There's rafters. There's 

ventilation.

And for a normal site, I agree with that. But for this 

site, I think it's unusual. And I'm not in --

Dr. Mauro: And I completely agree. And we're going 

to get to that.

Chair Beach: I know we are.

Dr. Mauro: You see, what I'm trying to do is, this is 

what was in the SEC Petition Evaluation Report --

Chair Beach: Yes.

Dr. Mauro: -- which is the classic OTIB-70 approach. 
31

Did they follow --

Chair Beach: Right.

Dr. Mauro: -- the classic OTIB-70 approach that has 

been approved? And did they have the data 

necessary to follow that approach? We will get to the 

point where that approach is inadequate --

Chair Beach: Yes.

Dr. Mauro: -- and what scenarios might have existed 

that that approach doesn't capture it. And that we 

will get to. So I felt it good to separate the two.

Chair Beach: Yes, and I just felt I needed to bring up 

the swipes since that's what we were talking about 

there. So --

Dr. Mauro: So now we have an estimate of dpm per 

100 centimeters squared. It turns out the upper end 

value that they picked was 54.8 dpm gross alpha per 

100 centimeters squared. Okay. The average turns 

out to be 12.5 if you average all of the readings.

So, and once you have the activity, whether you go 

with 12.5, you go with 58, or you go with some 

bigger, a higher number, because in theory you can 

go wherever you want to go on the distribution, then 

you apply a resuspension factor, which basically tells 

you, if you know the activity on the surface and we 

know people are working there, you get dust coming 

up that people will breathe and people could 

inadvertently ingest some. All right. Enough.

But there's this other pathway, which we will get to, 

which is what about the rafters and stuff that might 

be coming down. But, of course, the stuff that comes 

down will land on the ground and be part of, you 

know, but that, you know, but during the AWE 

operations.

But you bring up -- we're going to get to that point. 

And we did not address that. NIOSH did not address 

that. And that's going to be a subject that we've got 
32

to talk about. But I think I want to get as much --

Chair Beach: Go ahead.

Dr. Mauro: -- behind us that we could say we 

understand. And whether we agree or disagree is 

another matter.

Now, my takeaway -- and now you've got this 

resuspension factor. When you take a resuspension 

factor, you have to take into consideration how loose 

is the contamination.

And there's a lot of discussion about it. And Jim and 

I talked about it. There's guidelines. There's OTIBs.

There are times when you should use a fairly low 

resuspension factor, 10 to the minus 6 per meter. 

That means only a very, very small amount was 

coming up.

And you use that when the site is relatively clean. 

They've sort of cleaned it up. And there really isn't 

that much activity going on where people could be 

scuffling around kicking dust up. So, but NIOSH 

elected to use what I call the lower one, the 10 to the 

minus 6 one.

But our takeaway -- and I am going to get to actually 

the end of the story. Our takeaway is that if we were 

doing it I would have gone with the average 

concentration of 12 point something dpm per 100 

centimeters squared and not the upper end. And let 

me tell you why.

Picture that you've got a large floor area that's 

contaminated and it's patchy. Okay. And now all of a 

sudden work is going on. People are walking around 

kicking dust up. And the dust comes up and falls 

down, comes up and falls down. And it sort of 

redistributes itself.

So, in the end, if you're working there for a few years, 

you're not going to continuously experience the 

upper 95th percentile. How could that happen? 
33

You're going to experience more a general central 

tendency number that represents sort of the average 

conditions.

So I would have gone with a lower number. So I think 

you were very conservative.

Mr. McCloskey: And we agree at the moment that 

that's more appropriate -- 

Dr. Mauro: Yes. Although in light of what we just 

heard Josie mention, you know, that the, maybe it 

was fortuitous that you used the 54.8, because it sort 

of it takes care of some of the concerns you raised, 

heavily contaminated and where workers primarily 

worked. And maybe that could be, that could happen.

But the way I look at it, over a long period of time, 

workers would be exposed more to what I would call 

a central tendency measure of the activity on 

surfaces.

But I would have gone with 10 to the minus 5 per 

meter resuspension factor because, remember, this 

was a swipe sample.

Chair Beach: From '82, correct?

Dr. Mauro: No, no, not '82. We're still in the data that 

comes out of the AWE time period, which is 1966/'67 

data.

So we have these swipe samples. But they're swipe 

samples. Now, a swipe sample means that stuff is 

readily removable, right? So, if it's readily removable, 

that means it's readily removable. You want a higher 

resuspension factor. You don't go with the 10 to the 

minus 5.

And in fact, if you go into the history of where those 

numbers come from, the NRC, and I have a footnote 

in my report, recommends a lower number when the 

site has been cleaned up. It's gone through D&D, 

maybe not the greatest D&D, but they've cleaned it 

up. And there's not too much activity going on.
34

Well, in my mind, they may have cleaned it up, but 

obviously there was still a substantial amount of 

removable contamination swipe sample. And we also 

know there's an awful lot of commercial activity, 

people moving around doing all sorts of stuff.

So I would have gone, I would have done the problem 

a little differently. I would have gone with a lower 

concentration, 12.5 instead of 54.8 dpm per 100 

centimeters squared. But I would have gone with a 

ten times higher resuspension factor.

What's the difference? A factor of two. So we would 

have come out with a factor of two. You know, that's 

how we would -- and that's the end of my story.

Dr. Neton: And I might have read this in the report 

somewhere. I'm not sure if this is true. But there 

were multiple AWE and non-AWE operations going on 

before 1968. Is that correct?

Mr. McCloskey: Yes.

Dr. Mauro: Yes.

Dr. Neton: And so it's true that both of those 

operations were covered in the AWE period. When 

you get to the residual period, the only residual 

contamination that's covered is the AWE-derived 

contamination.

Dr. Mauro: Right.

Dr. Neton: And what we have represented in these 

smears are commingled contaminations.

Dr. Mauro: Yes.

Dr. Neton: So, in that sense, it's conservative as well, 

because I don't know if a portion was AWE versus 

non-AWE. But again, you're only supposed to cover 

the AWE-derived. And I think the way it works is if 

you can't distinguish between the two, you just 

assume it's all --
35

Dr. Mauro: It's --

Dr. Neton: But there is a conservatism built into that 

calculation as well that we're assuming everything 

that was smeared in that building was AWE-derived.

Dr. Mauro: Good point.

Dr. Neton: Just wanted to point that out.

Dr. Mauro: Agree with you.

Dr. Neton: And what I think would be interesting is 

to look and try to quantify what those ratios are, 

because if it's -- I don't know what it is.

Dr. Mauro: Yes, so --

Dr. Neton: It could be ten, you know, and --

Dr. Mauro: Yes, and that's why I say this factor of 

two difference that we came up with, it's sort of noise 

when you think about the things you're doing and the 

kinds of consideration you just don't know.

So I'm not that troubled by the fact that we came in 

with a different, maybe it was higher. The way I --

my takeaway on this is that we were both in the same 

ballpark. And this would be what we would call a Site 

Profile issue.

Dr. Neton: Right.

Dr. Mauro: Okay.

Dr. Neton: And by the way, that ratio also applies to 

all these subsurface contamination value we'll be 

talking about --

Dr. Mauro: Yes, we'll get to that.

Dr. Neton: -- distribution --

Mr. McCloskey: Yes, the two biggest projects are on 

the AWE period. And the biggest one was the Naval

Nuclear Propulsion project core assembly, so that 
36

was the lion's share of the work. It's not covered 

obviously. And then --

Dr. Neton: So you're saying the contamination in 

Building 10 specifically was a combination of work 

activity, I believe.

Mr. McCloskey: Yes.

Dr. Neton: And the extent that it was driven by nonAWE operations would be interesting to quantify.

Dr. Mauro: And that's mentioned in our report, our 

big report.

Dr. Neton: Okay.

Member Kotelchuck: This is Dave. I was not here 

back on the Board when those kinds of decisions were 

made. What drove it? Was it a legal opinion, or was 

this a technical matter that we determined?

Dr. Neton: I think it was more legally driven in the 

sense that I think the Act says something about it 

should cover activity at that facility. It didn't 

delineate AWE activity versus any other activity. So 

the position was taken that activity at that facility is 

all radioactivity at that facility during the AWE period.

That same logic does not apply in the residual 

contamination period because there's no AWE 

activity at that point.

Mr. Sharfi: So it's written into the Act.

Dr. Neton: It is.

(Simultaneous speaking.)

Mr. Katz: -- get to the bottom of the --

Member Kotelchuck: Okay.

Mr. Katz: -- it's a legal matter.

Member Kotelchuck: To me, technically --
37

Mr. Katz: Yes.

Member Kotelchuck: -- that doesn't make sense in 

terms of the exposure of people.

Dr. Neton: I agree.

Member Kotelchuck: But the law is the law. And we -

-

Dr. Neton: It's really an interpretation, though.

Member Kotelchuck: Okay.

Dr. Neton: I mean, it's not specific that you cover all 

activity. It doesn't say so. So the conservative 

interpretation was made that --

Mr. Sharfi: In the Act, the residual it specifically says 

that only --

Dr. Neton: Yes, right, yes.

Mr. Sharfi: -- residual. So it specifically excludes all 

the other stuff in the residual period --

Dr. Neton: Except where you can't differentiate, and 

then you should include both.

Chair Beach: And then in this case, it's pretty 

muddled in --

Dr. Neton: Yes.

Chair Beach: -- my mind -- this time period --

(Simultaneous speaking.)

Dr. Neton: Yes, and we've had this situation before 

where, you know, a plant or a site does a little bit of 

AWE business, I mean, more than a little, but you get 

a little bit of contamination in the AWE period. In this 

residual period, related to AWE operations. Then you 

have this massive amount of commercial activity. 

And how do you really --

Member Kotelchuck: I've seen it elsewhere.
38

Dr. Neton: And to the extent we can tweeze those 

out, we do. But in some cases and in this case --

Member Kotelchuck: Right.

Dr. Neton: -- we can't. So --

Member Kotelchuck: But it's a legal opinion, and it's 

in the law. It's the legal interpretation of the law.

Dr. Neton: Yes.

Member Kotelchuck: Then we don't have any choice 

or say.

Dr. Neton: Yes, there's no way to, or we have to 

follow it.

Member Kotelchuck: Okay.

Mr. McCloskey: John, since this is your Observation 

1, and we said we would delineate action items from 

this onto issues matrix, I think it might be worth 

noting here that we agree that we've averaged for 

the better idea, and the minus 5 resuspension we can 

agree with that. And we can just let it be no action.

Dr. Neton: I think that's included in our report, is it 

not?

Mr. Sharfi: In our matrix, we've already agreed that 

when you revise the AR that that was the other 

revision that would be in. Okay.

Member Kotelchuck: What observation was that?

Mr. Sharfi: Observation 1, page 4 of 9 on the matrix.

Dr. Mauro: Now, we're at a point now where we --

okay, we've got the airborne activity. There are 

people that are going to be breathing that airborne 

activity.

But what are we going to assume it is? We know it 

could be uranium or it could be thorium, because we 

know there's a little bit of thorium work going on, too.
39

NIOSH's position is, well, since you've, you know, it's 

most likely going to be uranium, but it could be 

thorium, too. So their position is that they will 

assume the radionuclide that's the most limiting.

So let's say you're reconstructing a dose, a particular 

type of cancer, where the thorium assumption is 

limiting from a PLC perspective, they're going to use 

that or uranium.

So we like that. I think that's claimant-favorable to 

default to the isotope that would be the limiting one 

-- 

Chair Beach: Have you moved to page 8?

Dr. Mauro: I'm on page 8.

Chair Beach: Okay. I just want to make sure where -

- 

Dr. Mauro: Yes, please remind me. I'm trying to stick 

with the pages -- 

Chair Beach: That's okay.

Dr. Mauro: -- while I, you know -- 

Chair Beach: You started talking thorium. And that is 

definitely on -- 

Dr. Mauro: And that's on that page, exactly.

So now we've got that. Now, there's one more last 

item. When we talk about the concentration that's in 

the air from resuspension and from the swipe 

samples, remember those swipe samples were taken 

at the end of the AWE period. And we're assuming 

that the, that that's the activity at the beginning of 

the residual period.

The reality is we all know that, as time goes on, 

whatever's residual is going to go down just due to 

natural attenuation factor rates. It just goes down.

Now, it turns out that NIOSH did a very thorough 
40

review of this subject in support of OTIB-70. And the 

takeaway was, well, a good rate of decline is .00067 

per day. That's the fraction of the activity that's 

present is exponentially going down at that rate per 

day.

And in theory, they could have used that as a default 

value. But they were fortunate that they had --

remember I said earlier measurements were made in 

1982? And those measurements were -- they were 

not swipe samples. They went there with an alpha 

survey meter. And they did classic, I guess, zinc 

sulfide survey getting a gross alpha count. That's how 

they did that survey in '82.

All right. They said, okay, now we know the dpm per 

100 centimeters squared, not on swipes now in this 

'82, but based on a gross. They said but -- so what 

do we do with that?

Well, we know that not all of that activity is 

resuspendable, because now we have the total 

activity. It's not just the swipe, which is 

resuspendable. We have the total activity, all right, 

only a portion of which would be resuspendable.

Well, it turns out this subject has been studied by the 

Nuclear Regulatory Commission. And there's actually 

some regulatory guides, and I cite them in my report, 

that says, you know, the reality is it's only about ten 

percent of what you might measure that is 

resuspendable.

So what they did, NIOSH did, they said we'll take the 

survey readings and dpm per centimeters squared 

and divide by ten and say that's the stuff that's 

removable. Okay.

Now we have an estimate of the airborne activity 

using the resuspension factor, whichever you choose, 

in 1968. And we have a concentration in the air based 

on this survey with the adjustment for what's 

removable in 1982.
41

You draw a line and you get a slope. And the slope 

turns out to be .00025. This is bullet number 6 on 

page 8. The slope is .00025 per day, the fraction of 

the activity that becomes airborne per day when you 

calculate the slope.

What is so nice about this, all that stuff, it's a little 

bit higher, the rate of -- no, sorry. The rate of decline 

is slower as measured when using real data. And they 

use that data. Bingo. You can't do better. Okay.

Not only that, it reinforces the default value that's in 

OTIB-70. It's another case where you say, you know, 

that's a pretty good number, because look at that, 

we've got real data, more real data. They had some 

real data when they originally did it. And now we've 

got more data.

So our takeaway is that's great. That's the way to do 

it. So our only difference from this particular 

scenario, we're spending a lot of time, but it's good 

to understand this stuff, is that we would have used 

a little different approach that may have come in a 

factor of two higher. And it sounds like you guys 

would agree with that.

Okay. All right. Now, the end of the story now is what 

about ingestion.

Chair Beach: Now we've moved to page 9.

Dr. Mauro: We're now on page 9. We're on the 

pathway, ingestion. And this is where I could use a 

little help from NIOSH.

The approach that they take is there is some 

guidance out there and some data out there that 

says, if you know what's on the surface, 

contaminated on the surface and you know people 

are working and you know that inadvertently they're 

going to use hand-to-mouth activity and then ingest 

some stuff, well, what NIOSH used was 10 to the 

minus 4 per meter squared per hour.

So whatever the activity is meters squared and dpm 
42

per meter squared, 10 to the minus 4 of that is going 

to be ingested every hour. Okay. That's the ingestion 

rate. And that was the approach that was used.

Now, I'm just going to bring this up as a question. 

That's a widely used number. It's, I believe, very 

similar to the number used in NUREG/CR-5512, 

which is sort of like a bedrock report that the NRC 

uses. And but it -- and in the past in reviews like this 

we accepted that as being -- we're okay with that.

But more recently, and Bob Anigstein could speak to 

this, more recently on the Carborundum project and 

on the --

Chair Beach: GSI.

Dr. Mauro: -- GSI, a different strategy was used. And 

all we -- and one of our findings or observations is 

that did you consider that as being another approach.

Bob, would you, if you're on the line, would you mind 

giving us a quick description of the difference 

between these two approaches?

Dr. Anigstein: Sure. Whenever there are 

measurements or the model of surface activity at the 

end of the AWE period in several cases, like 

Carborundum was the most recent one I was 

involved with, we use that. We don't take the 

airborne --

Mr. Katz: Excuse me, Bob. Bob, as often with your 

phones, this phone that you're using right now is not 

very audible. So --

Dr. Anigstein: Okay. Just a moment.

Mr. Katz: Yes, thank you.

Dr. Anigstein: All right. Is this good?

Mr. Katz: Much better. Thank you, thank you.

Dr. Anigstein: Okay. So what we've done then is, if 

you know what was going on during the AWE period, 
43

you simply say the surface activity will still be there. 

The air activity won't be there except as through the 

resuspension. So you can model resuspension during 

that period.

And also, since the ingestion pathway depends on not 

only the airborne activity but on the surface activity, 

you simply use, I believe it's TIB-9, which Jim Neton 

offered, and you use that to give you your ingestion 

pathway.

So the ingestion pathway actually does not decrease. 

It stays -- whatever the ingestion pathway was at the 

very end of the AWE period, it just continues into the 

residual period with this OTIB-70 decline of the table 

in OTIB-70 in terms of how much -- first year you 

assume there's no decline. After that for the next 30 

years, there is a exponential decline every year.

So that seems like a very straightforward way. 

Actually, it's a little on the conservative side, because 

as was pointed out by one of our colleagues, Bill 

Thurber, when he reviewed the Hooker 

Electrochemical site, he said actually there are two 

almost equal components to the ingestion pathway.

One of them is the worker gets, his hand is 

contaminated, and he inadvertently licks his fingers, 

puts his hand on his face, and some of that gets 

ingested.

And then there's a second equal pathway where he 

has a cup of coffee, and fallout from the activity, the 

airborne activity, goes into his cup. Now, that fallout 

would not exist during the residual period because 

that airborne activity is gone except for 

resuspension, which is all right.

However, we haven't really made an issue of that, is 

the factor of two difference. So either of these, either 

taking the TIB-9 or what's after TIB-9 would be 

acceptable.

I have personally been involved in this one. So, in the 
44

first history year, when I was working under a 

contract with NRC or even EPA before that years 

back, we reviewed 5512.

And as pointed out, it's a NUREG/CR. So it's a 

contractor NUREG. It's something that NRC paid for. 

But it's not necessarily accepted as NRC policy. You 

have your, when you have a NUREG without the CR 

after it, that's an official NRC document. This is just 

something that was an NRC-sponsored work.

And the 10 to the minus 4 is just an arbitrary number 

from that. Not to be deprecating, but, I mean, it does 

say, well, let's just assume that it's one squared, 10 

minus 4 is simply one squared method. You know, it 

could be a square meter, though, 10,000 square 

centimeters is a square meter. It just says, you 

know, if we're working in inches, you could write it 

just as easy and call it a square inch.

So that does not have a scientific backing. The TIB-9 

has a plausible argument attached to it. And more 

important, it has been accepted, as SC&A reviewed 

it, has been accepted work in progress.

So basically, here's what we're saying. Use the 

known activities at the end, the known conditions at 

the end of the AWE period, and then use the TIB-9 

approach.

I will say parenthetically that the ingestion pathway, 

at least for uranium, assuming there's all different 

airborne activity, makes a tiny contribution to the 

dose, because first of all, there's less intake than 

inhalation, and second of all, the dose conversion 

factor is for all of the order -- don't quote me on this 

because I'm not looking at the numbers. But my 

recollection is they're about an order of magnitude 

less than the inhalation pathway.

So it's added because you have to consider all 

pathways by law, by regulation. So we always do the 

ingestion pathway. And it always comes out that we 

-- and I'm just quoting it for recent dose construction.
45

It's typically one percent of the, give or take, of the 

inhalation pathway. So it's not something probably 

you should spend a great deal of time on.

Dr. Neton: Thanks, Bob. Okay. I'm probably in the 

best position to address this issue.

First, Bob, thanks for giving me credit for writing TIB9, but Dave Allen actually wrote TIB-9. I did review 

and approve it. So I'll take that much credit, but to 

set that record straight.

Secondly, TIB-9 -- and we've had this discussion 

before. TIB-9 requires you to have an airborne 

concentration value, an actual work process airborne 

concentration value. I don't think we have that 

anywhere at this site.

And this came up, I forget which site, but we had this 

long discussion about this. And you cannot resuspend 

material on the ground and say that's the air 

concentration that you're using to generate the 

ingestion value of TIB-9, which is 20 percent of the 

ambient air concentration, it just doesn't work 

physically or logically, because TIB-9 assumes that 

you have deposition coming from an active process, 

airborne process generation.

And we modified, I believe, TIB-70 to include this 

square meter ingestion rate to accommodate that 

lack of data onsite. So this has been discussed before 

and --

Dr. Mauro: I can help out a little bit more here, too. 

I agree with you, this whole issue of deploying two 

times the air concentration. But that's not what Bob's 

saying.

Dr. Neton: Okay.

Dr. Mauro: Bob's saying when you go through that 

process during the AWE period, which is the 

appropriate way to go, you take the air concentration 

times .2 --
46

Dr. Neton: Right.

Dr. Mauro: -- and you get the ingestion. But you get 

an ingestion. You got an ingestion now.

Dr. Neton: Right.

Dr. Mauro: Okay. That's what the ingestion is during 

the AWE period. And all Bob is saying, well, if that 

was the ingestion during the AWE period, the -- so 

forget about the air now. We're not in the air 

anymore, right. Now, we're saying this is what is 

being ingested.

And that's going to go be the same, because it's the 

same process you're going through, you know, 

inadvertent -- you see, you made a good case of 

when you're in the AWE period, you use the .2 

approach and you get an ingestion. And that works.

Dr. Neton: Right.

Dr. Mauro: But now you have an ingestion number. 

All right. And all Bob was saying is, well, if you got 

an ingestion number, that ingestion number is going 

to continue into the residual period.

Dr. Neton: But it won't, because the airborne 

concentration drops to zero from the mechanical 

process.

Dr. Mauro: But at the end of the -- think of it like this. 

You're saying that at the end of the AWE period this 

is the ingestion, how many picocuries per day. That's 

what it is at the end of the AWE period.

Well, whatever you eat, that's what's ingested and 

it's because of this hand/mouth relationship 

primarily. Well, it's going to stop, it's going to 

continue right into the -- so it's another way to think 

about it. Do you see --

Dr. Neton: Yes, I'd have to go back and look at what 

we did for the ingestion --
47

Dr. Mauro: Yes.

Dr. Neton: -- in the AWE period. I don't remember 

what we did.

Dr. Mauro: Your approach has always been after we 

fixed the .2 problem --

Dr. Neton: Yes.

Dr. Mauro: -- which we all agreed, we went to the 10 

to the minus 4 approach. And we accepted that.

Dr. Neton: Yes.

Dr. Mauro: As Bob pointed out, what was recently 

accepted was this other idea that I just mentioned 

that we applied to Carborundum and General Steel, 

where you say, well, you've got an ingestion number. 

Forget about the .2 now. You've got an ingestion 

number, how you came to it you came to it.

Dr. Neton: I don't remember how we came to it. But 

if it -- we'd have to go back and look at that. I don't 

--

Mr. Sharfi: At Carborundum we had an --

Dr. Neton: Airborne --

Mr. Sharfi: -- airborne during the operation --

Dr. Neton: At the very end of it probably.

Mr. Sharfi: Well, yes, because we did an entire -- I 

mean, we don't have an SEC during the operational 

period. So we had ingestion intakes during the 

operational period.

Dr. Neton: Right.

Mr. Sharfi: And so we now then calculated it 

separately per dose year because it has multiple 

residual periods --

(Simultaneous speaking.)
48

Mr. Sharfi: So this -- I think what we did was we just, 

like John said, we just copied over. And we really 

didn't recalculate during the residual period.

Dr. Neton: But I assume we did that because we 

didn't have any idea of surface contamination on the 

ground. See, if you have no surface contamination 

values, you have to use your airborne concentration.

Mr. Sharfi: Yes --

Dr. Neton: Because you've got a detailed map that 

tells you what the surface contamination levels are, 

then you would default to what's on the ground, not 

some extremely highly conservative value, which is 

assume that the ingestions people took at the end of, 

compared to the value that would be experienced at 

the very last day of operations.

If you have a surface contamination value and you 

have no air concentration value in the residual 

period, then to me it makes sense. And that's what 

we did.

I do agree that it's a small component in the overall 

dose. I mean, it might not -- I think if you look at the 

ingestion rates that we're using, it's probably higher 

than what we did for the ingestion, well, probably not 

the ending operational period.

It's a pretty -- this value that Bob sort of said was 

not very scientifically valid, I think is a little more 

credible than Bob portrayed it. I mean, it is a contract 

report. We do agree it's not an NRC policy decision.

But it was pretty, it's a pretty well reviewed 

document I think. And there is some science behind 

it. It's not a made up number. And I don't think it's 1 

times 10 to the minus 4, but something else in that -

-

Dr. Mauro: It's close.

Dr. Neton: Close, yes. And there is a write-up in 

there. It's pretty credible to us. And I think we all 
49

agreed several years ago that this value was 

appropriate to use when there was a paucity of 

information at the end of the operational period.

Mr. Katz: Well, I think you can iron this out.

Dr. Neton: Yes, this is --

Mr. Katz: You can iron this out in reports --

Dr. Neton: This is --

(Simultaneous speaking.)

Dr. Mauro: One point that I'd like to mention, though, 

once you move into the residual period, all of a 

sudden what happens is, as Bob pointed out, the 

inhalation contribution during AWE grossly dominates 

the intake and the inadvertent ingestion is always a 

very small fraction.

But once you move into the residual period, your 

airborne pathway drops like a rock.

Chair Beach: In most circumstances.

Dr. Mauro: In most circumstances --

Chair Beach: No, this one is a little --

Dr. Neton: -- there is no airborne concentration or 

residual contamination --

Dr. Mauro: Except for resuspension.

Chair Beach: Right.

Dr. Neton: There's zero process generated air --

Dr. Mauro: Exactly. So all of a sudden the ingestion 

pathway becomes relatively a little bit more 

important. So --

(Simultaneous speaking.)

Dr. Mauro: We should move along. Yes, because 

we're not really -- I'm spending all this time on --
50

Dr. Neton: Yes.

Dr. Mauro: -- not the important things. Let's close 

this thing down. Okay.

Dr. Neton: Could we take a little break for a second?

Chair Beach: Yes, I was going to say 10:30. But let's 

break now. Ten, fifteen minutes, what do you think?

Mr. Katz: Ten minutes is good, comfort break.

(Simultaneous speaking.)

Chair Beach: Yes.

Mr. Katz: So it's 9:50. We'll get started again at 

10:00.

(Whereupon, the above-entitled matter went off the 

record at 9:50 a.m. and resumed at 10:03 a.m.)

Mr. Katz: Okay, we're back, pretty much on time, and 

John, let's carry on -- oh, let me just check and see. 

Andy, are you back on the line? Henry?

Member Kotelchuck: Well, we've got a quorum. He'll 

be back in a moment, I'm sure.

Mr. Katz: Andy, are you there?

Member Anderson: Yes, I'm here.

Mr. Katz: Okay, great. Thanks. Okay, John, go on.

Dr. Mauro: Okay, we're on page 10 of my slides, and 

really in the home stretch of this piece. And on page 

10 it says, Okay, what are the issues that SC&A has 

raised regarding the Evaluation Report with respect 

to internal dose?

And next, page 11, is a summary of those, and we 

already talked about it. So we're done with pages 10 

and 11. We don't have to talk about that; we already 

did, okay? It simply summarizes what all our issues 

are -- simple.
51

Okay. Now, we're going to get to the meat of this 

meeting; why are we here? All right? I mean, the 

more important reason, in my mind; the Petitioners 

met with us, and they were great. And they told a 

story about -- listen, as I mentioned earlier, you 

really missed a lot of important pathways.

A lot going on there, and during that meeting, we met 

with 12 people. Notes were taken; I believe they're 

all in the record now. The transcript is out there. 

When I wrote this, I did not have a transcript, but I 

took 50 pages of notes. I think I got it right, but you 

may have more to add, and that's great.

But the important point is this: Remember when I 

opened up, I said, When an SEC is granted for the 

residual period at AWE facilities, it's because 

something unusual was going on, either in regard to 

what was left over, in terms of contamination, or 

people were doing things that were unusual, which 

put them up close and personal to contamination, 

and there are cases when that happened. In fact, as 

it turns out, there were three, where historically, we 

found SECs were granted for AWE residual period.

Well, we have one of those here. We a place where 

there was residual radioactivity, and you're going to 

see it wasn't that high, but there were some pockets 

of it that were what they are. And there are certainly 

unusual things going on that are not explicitly taken 

into consideration in the current version of the 

Evaluation Report.

Now, here's where the creative process comes in a 

little bit. In listening to the workers, I have a 

takeaway. I said, Well, what are the pathways that I 

just heard this guy describe to me that we need to 

explicitly address and try our best to quantify? And if 

we can't quantify those, we got an SEC. It doesn't 

need talking about.

If we could quantify that reasonably and say, Well, I 

think we could place a plausible upper bound, then 

we don't, in my opinion -- you guys make that 
52

judgment, but I think the doses can be 

reconstructed. It's just a matter of what assumptions 

you want me to use.

So my takeaway was that there were four pathways 

that were described to us. There was a lot of material 

that was described to us. I mean, these folks -- we 

were there for three days, six hours a day, listening 

and taking notes. These were the workers; they 

actually did this stuff. And the first one -- you see 

these four bullets on page 12 -- first one was what 

they called Subsurface Maintenance and Repurposing

Activities, especially in Building 10. Building 10 was 

where most of the activity was, where most of the 

AWE activity was, and where a lot of the residual 

radioactivity was.

And the Petitioners point out, Listen, we were digging 

into that, cracking through the concrete, and digging 

down -- not all the time, but often -- because we were 

repurposing and maintaining.

What they were doing is, they get a new contract; 

they'd have to put new equipment in to do whatever 

they've got to do. And usually doing that required 

them to dig down, build a new foundation, put in a 

new piece of equipment, dig out the old dirt, and put 

the new piece of equipment in.

But even more importantly, it turns out that a lot of 

their conduits and lines and drainage lines were all 

subsurface, and those clogged up all the time. And 

the way they explained it to us was that apparently, 

there was a lot of dust generated during the activities 

that were performed, AWE and non-AWE. And water 

would go down drainage lines and clog up the lines 

with all sorts of debris, some of which was cuttings 

and dust, chunks of uranium that were jamming up 

the lines.

Now we're in the commercial section, right? And 

they've got work to do, and they have to have their 

drainage work. So they said, Well, we've got to go 

down there; we've got to go down there for a lot of 
53

reasons. We've got to go down and clear those 

drainage lines. Sometimes they snaked it and just 

pulled out the junk. And sometimes, nope, you've got 

to dig a hole, climb down there. They said they go 

down as far as eight feet.

They go down there, they go, and they'll cut out the 

segment of pipe or conduit, whatever -- cut it out, 

replace it, and that was caulked. They're only doing 

this so that they can do their commercial work, and 

when they were doing the stuff, they had no idea 

there was residual radioactivity down there.

So here we go; those guys were in an unusual 

circumstance. They're in a hole in the ground where 

they didn't know there was residual contamination in 

the soil, and that there was residual contamination 

plugging up the drainage lines, and they were doing 

their job. That was in theory, they had the possibility 

of external exposure to uranium, but not that strong, 

but as beta and some gamma, and of course, 

inhalation. They said, How do we get out of the 

problem? We don't have an ongoing monitoring 

program of the subsurface environment. But what we 

do have is lots of data that was collected in the 1990s 

that characterized the subsurface environment, 

because they had to understand what was there to 

go through D&D, so there's data. There's data 

describing activity in the soils; there's data describing 

activities in the pipelines. And there's distribution of 

measurements there, big spreads, especially the 

pipelines. They go from very, very low concentrations 

for some of the sludge, to relatively high 

concentrations, very high, orders of magnitude 

difference between the low end and the high end. 

Member Kotelchuck: Question: for those workers, for 

external radiation, were they wearing badges?

Dr. Mauro: No.

Member Kotelchuck: Okay. Because they didn't think 

it was --
54

Dr. Mauro: During the residual period, no badges, no 

bottle acid, no anything.

Member Kotelchuck: I just wanted to confirm --

Dr. Mauro: Because as far as they were concerned, 

they were just -- this was a factor in their work.

Member Kotelchuck: Okay. But they were doing 

commercial radio --

Dr. Mauro: Yes. That continued until -- that was a 

HFIR work, and that was continued, but that's --

those workers, they were covered, they were

badged, they were under a very formal health physics 

program. But they're not in the SEC; they're out of 

the picture.

Member Kotelchuck: Okay.

Dr. Mauro: So whatever data you have for them, 

whatever you're doing --

Member Kotelchuck: It's physically in another spot.

Dr. Mauro: It's -- well, it's in Building 10, but I think 

it was blocked off. It had controls.

Mr. Darnell: We actually worked with the dosimetry 

of the person on the HFIR to see if there was any 

relationship we could come up with, and it just never 

worked. So it's completely excluded.

Member Kotelchuck: Good.

Dr. Mauro: Okay. All right, so there's one pathway. 

Let's talk a little bit about how do you get out of that? 

Well, we looked at the data, and I think you may have 

more data than we have, because we looked at the 

data that we had available up through the date that 

we finished this report, and we had a certain amount 

of data.

And the important data that we found was, the 

activity that was in the pipelines. And we said, Well, 

listen, there's activity in the pipelines, but we also 
55

know those pipelines leaked. We also know that the 

floor in Building 10 -- very often, because of a high 

water table, sometimes there were puddles that had 

been drained, so the subsurface environment got 

itself contaminated, the soil, through seepage and 

through leakage of the underground pipes.

Now we say, All right. We have a guy who goes 

underneath. He goes in there -- what's his job? He's 

going to go in there and go either excavate out the 

dirt, so they can put in a new foundation for a new 

piece of equipment, or he's going down there to 

maintain pipelines.

Chair Beach: So can I add something? The drain lines 

themselves at the surface level, those were also 

contaminated; the tops of the drain lines when they 

went back in, I believe in the early '90s, they were 

finding counts right at the floor level, weren't they? 

Of those drain lines? That was a high point.

Mr. McCloskey: I think a few inaccessible surfaces 

around those, yes.

Chair Beach: There were some pretty significant 

doses from what I remember from reading some of 

the notes.

Mr. Sharfi: I mean, I don't know about significant 

doses.

Chair Beach: Okay.

Mr. McCloskey: They're weren't doses; they were --

Chair Beach: Or, not doses, contamination. Sorry. 

Okay. So the drain lines themselves were 

contaminated. I just wanted to make sure.

Dr. Mauro: And I'm going to call on Rose in a minute, 

I want to conceptually explain what we've decided to 

do.

Mr. Darnell: One other thing that's important to note 

is, most of the work that was done on the subsoil 
56

stuff was done with dampened soil; we're not talking 

about completely dry soil.

Chair Beach: So now -- and I get where you're 

getting that from. There were certain evolutions from 

the workers' notes that I read, that they wanted to 

keep it dry in the later period.

In the early period, they said that sometimes it was 

wet, sometimes it wasn't wet. It was dusty; they 

would hose themselves off with air. So yes, it's a 

drain line, it's flooded. It's going to be moist; but not 

always.

Mr. Darnell: Then it's true then; I wasn't trying to 

take away from that part, but just so that everybody 

knew, the conditions down there were not always the 

worst case condition when they did the digging.

Dr. Mauro: Okay. So what we ended up doing was 

saying, Okay. We have all this information from the 

1990 characterization work. We talked to the 

workers; they said they believed that contamination 

setting, as represented by the work done that they 

did to characterize the subsurface and surface 

environment in the 1990s in support of the cleanup 

operation, probably was the activity that was present 

throughout the residual period. They said that they 

would believe that that was probably a fairly --

Chair Beach: Okay. Can I stop you again?

Dr. Mauro: Please.

Chair Beach: Forgive me; this wasn't in -- you guys 

did the interviews. Now, one of the points that I was 

thinking of is, they were snaking and cleaning out 

those drain lines during the whole residual period, 

correct?

Mr. McCloskey: Right.

Chair Beach: So did the workers ever tell you when 

they reamed out a line, or when they dug it up and 

they took the pipe out, what did they do with the 
57

material that was inside? Did they leave it down there 

and cover it back up?

Mr. McCloskey: So when you snake a drain, you 

literally pull the material out -- 

Chair Beach: Yes.

Mr. McCloskey: -- and dispose of it. So it's disposed 

of in whatever industrial waste -- 

Chair Beach: So in that case, I get when they snake 

it out. But when they went down, they cut through 

the concrete. They cut out a chunk of pipe, and then 

they cleaned it out, replaced the pipe. That particular 

material -- did it get left down below?

Because they're under the assumption that there's no 

contamination there; they're just working with a 

clogged-up drain. Did that come up in the interviews 

at all, what happened to that material? Because it's 

contaminated material in some cases, or potentially.

Mr. McCloskey: So you'd pull out the broken pieces 

of pipe and dispose of it, and whatever is inside of it. 

You wouldn't necessarily try to clean it up during -- 

Chair Beach: You'd just snake it out and -- 

Mr. McCloskey: But I think what you're saying is a 

good point. They wouldn't have tried to remediate all 

of the soils around there. They would do the normal 

practice of cleaning up after themselves, not leave 

material other than soils on the ground, and put it in 

a condition where you can operate.

Member Kotelchuck: Presumably, they put that in 

with their regular industrial waste, and the general 

waste pickup people would get that radiation. I 

mean, that limited amount of radiation.

Chair Beach: But it's not really radiation if it's put to 

the contamination. Because there were materials 

that they found -- metal -- they found a very long 

piece, a five-inch piece of metal -- 
58

Mr. McCloskey: Sure.

Chair Beach: But they also found shavings and stuff 

as well, in different interview notes I read. So 

anyway, okay, I was just curious if somebody ever 

said --

Mr. Sharfi: That would have to be covered under their 

commercial license to deal with radioactive waste 

anyway, so --

Chair Beach: But they weren't dealing with 

radioactive waste when they were in that subsoil.

Mr. Sharfi: They're still doing commercial radioactive 

work, so anything coming in would still be covered 

under their license to --

Dr. Mauro: The M&C workers that are seeking a 

petition are workers who are not associated with 

HFIR, and are only doing commercial work that was 

not radioactive.

Mr. Sharfi: No, I'm saying to dispose of the piping, 

they would still be under the commercial license to 

be required, on how they dispose --

Chair Beach: Had they known --

Mr. McCloskey: They had access to that building, 

because of their license, but they would not have 

identified this as a piece of radioactive material, 

right? And they would have just done whatever they 

needed to --

Member Kotelchuck: But presumably, they're not 

going to leave a pipe down there, that --

Chair Beach: Probably not.

Member Kotelchuck: They're going to remove a pipe 

to keep the site clean.

Chair Beach: I just wanted to know if it came out 

during -- if it was me, and I was a pipefitter, and I 

was cleaning out a pipe or whatever, I'd just leave it 
59

down in the dirt and then just cover it back up. But I 

was curious if that was a question that was asked, or 

if it was talked about.

Member Kotelchuck: We didn't.

Chair Beach: Okay. Thank you.

Dr. Mauro: But I think it may be the way we came at 

the problem might solve that uncertainty. What we 

did -- I'm going to call on Rose in a minute --

Chair Beach: Oh, yes.

Dr. Mauro: -- is, All right. We've got lots of really nice 

data, characterizing the uranium concentration in the 

pipes. It comes in very wide distribution. The 

numbers are in the report. Rose and I --

Ms. Gogliotti: Ten to 53,000 picocuries.

Dr. Mauro: Say again, please?

Ms. Gogliotti: Ten to 53,000 picocuries.

Dr. Mauro: Ten to 53,000; big spread.

Chair Beach: I saw that.

Dr. Mauro: Now, one of the things Rose and I talked 

about is, Okay, you've got this guy now; he's working 

down there. He doesn't know if there's any 

radioactivity, and if you'd asked me, well, we know 

the range of activity in the pipe, and we know it 

leaked. So we know that the soil in the vicinity of the 

pipe is probably contaminated too, perhaps not to the 

same level as the pipe, because it's leaked. So what's 

in the pipe is something like the source, and what 

gets into the dirt is dispersed in the dirt.

But we don't know to what extent that occurred, and 

we don't have any detail or data on what was actually 

in the dirt in the vicinity of the pipe. You folks may 

have some information on that. When I read your 

report, it looks like you may have some subsurface 

soil measurements, am I correct? When I read your 
60

report, I got the sense that you got hold of some data 

that we didn't have at the time we did our work.

Mr. Darnell: We shared it with Rose.

Dr. Mauro: Say again?

Mr. Darnell: We shared it with Rose.

Dr. Mauro: Oh, good. Okay, then the recent edit. But 

now, what we ended up doing is saying, Let's go to 

the upper 95th percentile of the uranium gross alpha, 

the uranium concentration in the pipe and say, That's 

the concentration in the soil where the workers are 

working.

Chair Beach: So the 53 picocuries; where did that 

number come from?

Mr. McCloskey: It's 53,000 is the max value that they 

found during the characterization --

Chair Beach: In 1994?

Dr. Mauro: Yes.

Chair Beach: Okay. So in '94, you have calculations, 

and you have some contamination, 53 curies comes 

from that. So between '67 and '94, some of that stuff 

got cleaned up, potentially, and you may have had 

different numbers that you don't know anymore, 

because that was already -- I mean, they were 

cleaning out these pipes for 10 years, right? Prior to 

any -- this dose that you're using?

Mr. McCloskey: Yes. It was episodic in nature. It 

wasn't large scale remediation of the subsurface 

environment. There was some snaking of material 

that came out, some isolated sections were removed. 

We have a map that shows which ones were now PVC 

if you replaced over that time period.

So yes, did they remove some activity? Would it have 

been greater prior to this survey? I would agree, but 

I don't know how significant the increase --
61

Chair Beach: But you don't know. Really, we don't 

know, right?

Dr. Mauro: You're raising an important SEC question.

Chair Beach: I know. That's why I'm raising it, 

because we don't know.

Dr. Mauro: And I think there's a point where we make 

the issue crystal clear: We are operating on the 

premise that the characterization in the pipeline, as 

acquired in the 1990s, in support of D&D, 

represented a bounding set of circumstances that 

also were the circumstances that existed in the 

subsurface environment during the residual period, 

the '70s and the '80s.

You're saying that, Well, maybe it was higher in that 

time period, and that number is not representative. 

Fair question; the only argument I would make is that 

it wasn't until they went in later, when they found 

this chunk of uranium that was sitting there. So 

whatever they may have done during the operations, 

they missed that one.

Chair Beach: That was in the '94 time frame. They 

found that when they remediated it.

Dr. Mauro: It was still there.

Chair Beach: But the workers' interview notes said 

they found metal shavings, they found other things 

earlier during their active remediation period.

Mr. Darnell: We should not discuss what they said 

they found.

Chair Beach: Okay. Sorry.

Mr. Darnell: It's okay.

Chair Beach: Okay. I just wanted to make that clear, 

that --

Dr. Mauro: I think you've raised the first SEC 

question that needs to be dealt with. That's how I see 
62

it. We operated on the premise that the concentration 

distribution that was found in the pipelines is the 

concentration distribution that was there all along, 

during the residual period.

And on that basis, we said, What are we going to do 

with that? Well, we were going to do some very 

conservative, bounding assumptions. We're going to 

assume that the concentration that the workers were 

exposed to, who were in the dirt and working down 

there, is the same concentration distribution that was 

in the pipeline.

But -- and here's where Rose talked me into this one 

-- I said, Rose, I would have went with the average, 

because the workers down there, they're working 

down there, and sometimes they're in a hot spot, the 

high end, and sometimes they're not.

But Rose said, No, no, no. If they went down there to 

fix the pipe, it's the part of the pipe that's clogged; 

that's why they're cutting it out. It's clogged, and 

they have to replace it. So they're probably tending 

to be in the areas where the higher activity is.

So Rose convinced me to go with the upper 95th 

percentile as being the concentration of the uranium 

in the soil to which the subsurface workers were 

exposed to, for the purpose of reconstructing internal 

exposures to the workers from that scenario.

So here's the issue: We took information collected 

later, in the '90s, and applied it to scenarios that took 

place in the '70s and '80s. We have two embedded, 

conservative assumptions: one, that the exposures 

that the workers might have experienced were the 

high-end exposures contained in the pipes.

The reality is, they were probably exposed to the dirt, 

more so than the -- it was the dirt that they were 

exposed to, which was diluted in other words. It 

might have leaked from the pipe only a little bit lower 

than was in the pipe, and they weren't necessarily 

always right there in close proximity to the high end.
63

Nevertheless, we can't rule that out, so we ended up 

going with the 95th percentile. But the important 

point is, this is our tract. This is a scenario where we 

think we have a tractable situation where we're 

saying, Well, it's just a matter of degree. What do 

you want to use as the concentration? So we ended 

up going with the upper-end uranium concentration 

that was observed in the pipes. So that's assumption 

number 1.

Chair Beach: So when you say, we, you're talking 

NIOSH's --

Dr. Mauro: No, SC&A.

Chair Beach: SC&A, okay.

Dr. Mauro: SC&A. Not speaking for them. We're going 

to get to --- I guess we're going --

Mr. McCloskey: I'd like to draw a distinction --

Dr. Mauro: Absolutely, because you may have come 

at the problem differently. I'm not quite sure exactly 

what you folks did, and it might be a good time to 

talk about that, because this is the big deal. I mean, 

when all is said and done --

Chair Beach: This is part of the big deal. There's more 

of the big deal.

Member Kotelchuck: Can I ask a prior question? 

Weren't they replacing pipes? I assume pipes clogged 

up during the active period, and people went down 

and replaced pipes. They would have external 

batches of that core. Were there any measurements 

of the subsurface before the residual period, and that 

will give us a clue as to what's going on? Your 

assumption that it's constant is good, but there must 

be some -- these external measurements.

Mr. Darnell: The problem is the way the plant was 

actually set up to do the work. It's not a union shop, 

so anybody in plant maintenance, operations, 

facilities -- if they weren't doing work, they could get 
64

sent to go do the drain job. They could get sent to go 

do the dust collector job. So there's really no 

demarcation of the group of workers that did that 

type of work; it was everybody.

So now you take the exposures of everybody and see 

where it goes to the specific soil type work, and you 

can't do it.

Member Kotelchuck: I see. But there's no possibility 

-- but one could have -- or, can talk to the workers 

from the active period and find out -- identify some 

who did a lot of the replacement work --

Mr. Darnell: We actually talked to some of the 

workers that did; this is how we found out there was 

no real way, even during operational period, to 

correlate back to specific workers in their dosimetry 

records.

Member Kotelchuck: Okay. It's hard to think that --

forget about union or not union. Some people 

typically did some work, and some people typically 

didn't. Admittedly, people moved around. It's hard 

for me to think that one could not identify a core 

group of workers who did that, and then look at their 

badges.

Chair Beach: This was also a 24-hour operation, so 

you might get called at two o'clock in the morning to 

come and unclog a drain. It wasn't just an eight-hour 

day or a 10-hour day; it was -- this went on around 

the clock.

Member Kotelchuck: Okay.

Chair Beach: So if you have a group of workers in 

there at midnight, and their floor is filling up with 

water, you might get a call at home, and they're 

going to catch who they can in that big, large group.

Member Kotelchuck: I see.

Dr. Mauro: You're making a good point that I like. 

What you're saying is, We looked at the data that 
65

came out of the D&D program; they're saying, Wait 

a minute. This is going on all the time, even during 

the AWE time, because pipes get clogged.

Now, I have to say that I don't recall talking about 

that with them, to what extent were you doing coring 

and snaking and things that make this work during 

the AWE operations?

Dr. Neton: Well, we never really investigated, 

because this was an SEC for the entire operations 

period.

Dr. Mauro: Right, and we didn't have the presence of 

mind to ask him, because I know we didn't ask him. 

But it's a good question, because what that does is 

say, Well, that's more data.

I said, Listen, this is what we had then, and this is 

what we have here. Well, right now I can say that we 

did our work; we just operated from the data that 

came in later.

Now, was there any data earlier? All I can say is, well, 

let me just say one thing. It seemed to me that the 

repurposing, especially the repurposing, was 

something that really became aggressive once they 

finished the AWE work. In other words, the AWE work 

was done, except for the HFIR work. And then I know 

their discussion was -- I don't know if those folks are 

on the line, listening, but -- 

Mr. Katz: There are people on the line, but -- 

Dr. Mauro: But you see where I'm going. We got the 

sense that an awful lot of repurposing took place, 

beginning in the residual period, when they started 

new operations, got new contracts, had to dig, had 

to do this. And they sought to maintain the 

subsurface pipelines.

The degree to which that type of activity took place 

during the AWE operations, we didn't explore that. 

We didn't even talk about that. And I think the reason 

you bring up, Why wouldn't we, because we weren't 
66

concerned with that.

But now that you bring up the question, that would 

have been data, if it's out there, it would be useful, 

right?

Mr. McCloskey: Well, they didn't believe they were 

digging up radioactive material during the residual 

period. I don't know that they would have believed 

now that it's the AWE operations period, that they're 

going down to these drains and digging up 

radioactive material. And I don't know that we'd be 

able to paint a person with a TLD or a film badge and 

say, Okay, since you're the person digging --

Dr. Neton: But there are bioassay data for those 

workers for uranium.

Dr. Mauro: I would be the first to agree, any film 

badge data collected during the AWE period, any 

bioassay data collected, we can't use. But what you 

can use is if someone pulled out samples of dirt, 

corings, out of a pipeline. That is important, because 

that's the material that was in the pipeline --

Chair Beach: But it only shows what's in certain 

areas. And it was pointed out, it's different in 

different areas.

Dr. Mauro: Yes. But the reason our takeaway was --

and this is a fundamental assumption -- the 

distribution of activity that was observed in the 

pipeline later on is where you get your hook. Okay, 

we've got that, and we go with the upper 95th 

percentile. We assume all the dirt that people down

there were doing -- M&C guys, not doing any bad 

work, just doing their jobs -- that's what they were 

exposed to.

Member Kotelchuck: Right, and I accept that, given 

the data that you had, that seems like a fair, 

conservative worker-friendly approach.

Chair Beach: But we're not at that approach yet. I 

mean, that's more Site Profile, correct? Isn't that how 
67

you approach --

Dr. Mauro: No, I think it's an SEC issue, because what 

we're really saying is, We could use that data to apply 

to M&C workers. See, this is data that was collected; 

it had relevance to the cleanup in the 1990s and the 

jobs they had to do.

We said, Well, that's useful information that we can 

apply to the residual period, to M&C workers, 

because they were down there doing similar things. 

The cleanup people in the 1990s, they were doing the 

same thing. They were going underground, 

excavating; but they were doing it under health 

physics program, and they were dealing with this 

stuff.

Now, we're saying that characterization also could be 

used as a hook to what might have been the 

circumstances during the residual period. There is the 

core of the SEC question.

Chair Beach: Okay. Can I add -- Henry, are you still 

on the line?

Member Anderson: Yes, I am.

Chair Beach: I don't want to ignore you. Do you have 

any questions or comments --

Member Anderson: Well no, since you're covering all 

the things I would have raised my hand for.

Chair Beach: Okay. I just wanted to make sure we 

weren't ignoring you there.

Member Anderson: No, no, I'm good. I'm on mute, 

though, but --

Chair Beach: Okay, thank you.

Dr. Mauro: So we're right where we should be right 

now. This is where the action is. Can you reconstruct 

the doses to the guys who were involved in 

maintenance and repurposing activities during the 
68

residual period? That's the question: Can we do it, 

and can we place a plausible upper bound?

And we're saying, Well, we're going to go with this 

upper end concentration in the pipeline as being the 

contamination level that these workers were exposed 

to as being a plausible upper bound.

Now, bear in mind, now, the next question is, Well, 

the people that did that, we're saying, whoever did 

it, when they did it, were up close and personal to 

the worst sections of the pipes, where the 

concentrations were at their worst. And we're also 

assuming that it's always the same person. We know 

that's not true. So we're really -- we're going to start 

to push it to the high end.

Reality is, we know from talking to the workers that 

this was a job not too many people had to do, going 

down there, doing all this stuff. And that, all of the 

maintenance, they actually had groups and names; I 

forget their names -- the groups of people that 

belonged to certain maintenance activities -- they 

would be the ones who were sent down to do this 

dirty work. And very often it was the new hires; the 

supervisors didn't go down there. But there was a 

pool of people that they drew upon.

So assuming that the same guy is always doing it is 

again another conservative assumption over years. 

But one of our dilemmas was, Well, when they were 

doing that, how long were they down there?

Chair Beach: Can we hold back that part of the 

discussion? Do you mind?

Dr. Mauro: No.

Chair Beach: Because there's more to this. There's 

the outside work we haven't even touched on. They 

were outside in the burial grounds; that was a known 

burial ground, but it was relatively unknown to these 

workers, because they were running pipes and water 

lines. And I believe there was a fire in Building 10, 
69

and so they were taking -- and I might get the 

building back and forth.

They were building a new building and taking lines 

through it. So these workers were in, digging in dirt 

outside, that they ran into pockets later of high 

contamination levels of thorium uranium. So those 

folks are part of this as well.

Mr. McCloskey: The same group of workers that could 

be called upon to remediate, unclog drains or do 

subsurface work inside the building would be called 

upon to go outside. The same group that would do 

the repurposing could go outside and dig up a 

pneumatic line or --

Chair Beach: And I think it was in '83, installing an 

air line underground, they ran into buried debris, and 

I know they ran into thorium later, when they did 

their samples. It doesn't take a fairly large dose of 

thorium to have a large internal dose; we know that.

Dr. Mauro: As I mentioned, every time you run into 

a circumstance where you're trying to model the 

internal dose, you always assume the isotope is the 

limiting isotope.

Chair Beach: Do we know how many lines were run 

in those burial grounds, or how often they were --

Mr. McCloskey: We queried the former workers and 

asked them for an upper bound on the amount of 

subsurface work they would do. We landed on a 

number that said if it took more than one month a 

year, if you combined all of this work, that would be 

a lot.

Chair Beach: That's including the subsurface work 

inside and outside?

Mr. McCloskey: Yes; the same pool of people would 

be called upon to run new utilities both inside and 

outside the building. The same pool of people would 

be drawn upon to clean clogged drains.
70

Chair Beach: Okay. Can we say that during the 

course of that work -- I know that we've already 

talked about it inside, potentially not knowing what 

they ran into in different drains -- outside when they 

were running and digging those trenches and digging 

those lines, do we know how often they ran into 

pockets that they didn't even realize they were into -

- I know they had called an HP at one point who didn't 

-- nobody has the dose for the records from calling 

him.

So do we know how often they may have run into 

different things in the course of their digging?

Mr. McCloskey: That's what you do, is bound it. We 

had them point to places where they might have done 

some utility runs and digs outside, and we had the 

subsurface data from where the contamination was, 

so we can bound it.

Dr. Mauro: The issue you're basically raising is that 

we, SC&A, paid a lot of attention to the subsurface 

work in Building 10. Rose can talk a little bit, because 

she also looked at the outdoor work, and tried to 

model those doses.

I believe I'm correct in saying the limiting dose was 

the assumption I just made about the guys 

underground in the worst place in the subsurface 

environment in Building 10.

Ms. Gogliotti: Yes.

Dr. Mauro: Yes, thank you. And that was your limiting 

pathway, compared to the outdoor work that you just 

described, which was also subsurface work. A big 

question was, how much time?

Chair Beach: Well, and how much contamination they 

may have run into? I know they found quite a bit, and 

it doesn't take very large doses to create a huge 

problem.

Mr. McCloskey: Let me just speak to one thing there, 

Rose. Your scenario for inside the building, because 
71

it does dwarf the outside one, but we have some 

differences with the way we did it. The one thing that 

the subsurface samples from inside Building 10 don't 

do for you is provide a thorium exposure.

What they did was isotopic ID inside the building, and 

it was all uranium; it didn't have any form -- any 

gross alpha there. So unless you've come up with 

some ratio from a document that would give you a 

thorium component for that dose, you're going to 

struggle to -- to be able to assign a thorium dose 

from inside.

Outside, however, we had gross alpha, a tremendous 

amount of gross alpha data, and we have ISO ID, 

which occurs in thorium. So it does that for us. We 

also incorporated a lot more of the areas outside, 

besides the formal waste burial area. We went into a 

metals recovery area; we went into the stockade; we 

went into some of the other areas. You'll see that.

Dr. Mauro: What I'm hearing is, we zeroed in on this 

subsurface work in Building 10, the way I just 

described it --

Mr. McCloskey: Right.

Dr. Mauro: -- as being a plausible upper bound 

exposure scenario for internal exposure.

Mr. McCloskey: But you had no thorium in the 

building.

Dr. Mauro: From an intake perspective, and we are 

assuming that wherever that intake is, you don't 

know whether that intake was thorium or uranium. 

Now, here's where we may differ: We're under the

assumption that you would use that -- once you get 

a becquerels-per-hour intake rate -- inhalation rate, 

let's say -- you would use thorium or uranium, 

depending on the cancer.

Mr. McCloskey: Only at gross alpha can you do that.

Dr. Mauro: Oh, when the starting point is gross 
72

alpha?

Mr. McCloskey: You can make the assumption that 

it's either one. It can be either one.

Dr. Mauro: You got the isotopic breakdown on 

Building 10?

Mr. Sharfi: Building 10 was all uranium, isotopically 

identified.

Dr. Mauro: So when there was ambiguity, when you 

weren't quite sure where the radionuclide was, then 

you go to the limiting --

Mr. Sharfi: Limiting --

Dr. Mauro: But when you know what it is, you know 

what it is.

Mr. McCloskey: You're handcuffed; you can't make, 

you know?

Dr. Mauro: So there's a --

Mr. McCloskey: And that's one of the differences with 

the inside of the building, that I was going to speak 

to earlier. John, you raised the issue of, do we have 

characterization from the AWE period of what the 

subsurface environment looked like underneath 

there?

The best thing we have is this document that SC&A 

used, and we used. It's the characterization of the 

drain lines inside of Building 10. It's not done during 

the AWE period; it's done in '96. But we interviewed 

the D&D manager at the facility; he's on the phone 

right now. And also in his affidavit, he described this 

document. It represents conditions prior to D&D 

activities; therefore, it offers good insight into 

conditions in which the employees were exposed.

So he believed that that was a good characterization 

of what was there, even though some of it -- portions 

of it were removed throughout the residual period. 
73

This remains a good characterization of the 

subsurface environment in the worst-case area.

Chair Beach: Do you have that SRDB number for that 

document?

Mr. McCloskey: Yes; 165965.

Chair Beach: I tried to go through as many of those 

as I could, but as you know, there are a lot of SRDB 

numbers with this -- yes. I have no time. Thank you.

Dr. Mauro: Once you get to the point where you say, 

I think we have a pretty good handle on the 

concentration of the radionuclides that these guys 

might have been up close and personal to -- guys 

who were working underground -- the other question 

is, how long?

We used one month per year, based on the 

information during the interviews. Of course, that 

was a guesstimate, a sense, thinking back, because 

these were the workers who did it, and their 

recollection was, Well, that's a pretty good number.

So whether one month, two months, three months is 

the right number, we picked one month, based on the 

information we had, for better or for worse.

Then the other big question -- and remember, we're 

talking internal dose -- wait a minute; these guys are 

under ground. What are they breathing? What's the 

dust loading? I have a whole appendix that says, 

Well, what are we going to use? Because I know from 

doing a lot of this kind of stuff that it's not unusual 

for concentration of airborne to go as high as a 

milligram per cubic meter, while you're involved in 

earthmoving.

But right now in this room, I'll tell you that it's 

probably about 2 to 10 micrograms per cubic meter. 

I've done a lot of measurements involved with this 

stuff, on what normal dust loading is in a room.

So we're basically saying it's about a hundred times 
74

higher; we went with 200 micrograms per cubic 

meter. So if you know the concentration of picocuries 

per gram, you know what your micrograms per cubic 

meter are, an inhalation rate, you've got an 

inhalation dose.

Now, why did we pick 200 micrograms per cubic 

meter, and not one milligram, because we talked 

about that. Well, there's a lot of evidence -- and you 

can read it; we've got a big appendix talking about 

the subject, on what the dust loads are. There's a lot 

of information on dust loadings, and it's all over the 

place.

But one of the things we found out was that very 

often, the subsurface environment was moist. And I 

said, Gee, when you have a moist environment, 

you're really not going to get up there in terms of 

dust loadings, so we went with 200 micrograms per 

cubic meter. And if you look at our appendix, you can 

judge for yourself, given the range of numbers that 

are out there from the literature, whether we picked 

the right number, the sweet spot. And we went with 

200 micrograms per cubic meter.

I'm not sure what you folks used -- oh, you used 

some other data. It came close, though --

Dr. Neton: Yes, we used 220, based on data collected 

at another facility.

Dr. Mauro: We came at it from a literature review, 

and you came at it from a specific site, which, by the 

way, was assured.

Dr. Neton: Well, we totally didn't collaborate on it.

Dr. Mauro: I didn't know about the data.

Mr. McCloskey: We didn't know it existed either, until 

Dr. Taulbee was involved in some stuff and said, I 

might have something that helps.

Dr. Mauro: That's good news. All right. Well, now you 

can see how we did the subsurface environment. That 
75

is the single biggest SEC issue that we're dealing with 

here; whether or not you've got adequate data, and 

whether you have a good enough understanding of 

the activities that took place that you could place a 

plausible upper bound on the internal dosage from 

inhalation and inadvertent ingestion.

So your starting point is the concentration 

distribution. You raised a question that was at the 

heart of the SEC: Is there anything about the fact 

that there is ongoing maintenance all the time? Do 

we feel confident that the distribution that we used 

for the uranium concentration in the pipeline -- the 

upper-end number that we picked -- as being a fair 

upper-bound value that any of the workers might 

have experienced during the residual period, which 

was decades before?

Out takeaway was, for the reasons you gave, 

probably is, for a number of reasons. But this, again, 

is a judgment call. One, we pick the upper end as 

being the concentration, and that's in the pipeline, 

not in the dirt. So right off the bat, we were pretty 

conservative there. There's no reason to believe the 

dirt's going to be higher than the pipeline.

Two, the guy that's doing it is doing it one month a 

year. Now, it could be two months a year; I don't 

know. I mean, we have workers -- we can talk about 

that. We trolled them heavily; it's all in the transcript.

We felt that one month a year was good, and we did 

one more thing, which I consider to be very 

conservative: we assumed the same guy did it all the 

time.

Chair Beach: I think in your paperwork here it said 

six to eight weeks. You guys picked a month. I would 

have gone higher, but that's just -- that's another

point that we don't need to worry about right now.

Dr. Mauro: Fair enough.

Chair Beach: And we just got through the first. We 
76

haven't talked about the other three points you made 

here.

Dr. Mauro: We're going to get to -- we'll get there. 

But this is the big one. We're in the middle of the big 

one right now.

Chair Beach: Part of it, yes.

Dr. Mauro: Yes. Okay. So we just talked about the 

first bullet on page 12.

Dr. Neton: Just before you go on, John, I might point 

out that even under those conditions, the intakes that 

SC&A suggests occurred per annually in that time 

period is really small.

Dr. Mauro: Oh, yes.

Dr. Neton: So, 1.3 picocuries per year; I mean, we're 

talking pretty small -- so even if there's some 

uncertainty there, you could, on top of that, increase 

these values quite a bit. You're still discussing very 

small potential intakes if it's a one-month --

Dr. Mauro: I think that has play here, because I know 

we've had conversations in the past that the level of 

accuracy and granularity and precision that you 

demand of your analysis does vary, depending on the 

magnitude of the doses, and how close you are to it.

Dr. Neton: Right, that's what I was trying to point 

out.

Dr. Mauro: Yes, and revealing the doses are 

reversible, notwithstanding all these things that 

we're talking -- so it's been very good.

Okay. The other pathway that we found interesting, 

that I expected to be a problem is, they had an HVAC 

system that was continually -- any dirt, any activity 

that became airborne, from resuspension or 

whatever, during the residual period, is going to be 

drawn up, passed through the HVAC system, and 

typically what an HVAC does is, it goes through a 
77

filter and some portion of it is recycled back into the 

building, a large portion, because you want to keep 

the air conditioning and the depositing.

So what's happening? The uranium's is being resuspended, it's going up and being deposited on the 

building. Now, it turns out, every so often the 

maintenance guys will go in and replace those filters. 

It was clear, in talking to those guys, that that was a 

dirty job. The dust -- what would happen is, often the 

filters crumble and generate a lot of dust, and any 

uranium that was on there would be part of the 

crumbled junk that became airborne. These guys 

would breathe it. We've got to look at that pathway.

How do we come at that problem? In a writeup, we 

looked at several ways that you could come at the 

problem. For example, you could estimate that, okay, 

we know what the airborne -- if you accept the 

understanding of the concentration that's on the 

surface -- that 7,000 slide samples -- you know that. 

You accept the resuspension factor. Now you have 

airborne concentration. Well, we're going to assume 

all of that as being swept up and brought into the 

HVAC system.

So if we know the HVAC system flow rate, which I 

believe was 14,000 cubic feet per minute --

Mr. McCloskey: That sounds about right. We have it 

somewhere.

Dr. Mauro: You know the rate at which the number 

of atoms of uranium or thorium are being deposited 

on the filter continuously. And then we also found out 

in talking to the workers that they would replace the 

filters periodically. And they mentioned that, Well, 

ideally, we should replace them every quarter and 

pull out these racks and put in new ones. The guys 

who did it said it was very dusty work. So we said, 

This could be in important pathway.

So what we said was, We've got to estimate how 

many microcuries, millicuries, whatever, are on the 
78

filters when they pull the filter. Was it once a year? 

Once a month? Well, that doesn't matter, because if 

it's once a month, there's less activity on it, because 

you only have a month's worth of accumulation on it. 

If it's once a quarter, you've got three times more 

activity on it, but it's inversely proportional to the 

amount of time. So it doesn't matter how often they 

replace it. So that sort of went away.

So we ended up going with, I believe, quarterly. We 

figured out how many atoms of uranium are on the 

filter at the end of a quarter, and the guy is going to 

pull it.

Now he pulls it out, and there's this dust. Now, what 

is that dust? That's dust that very often was 

crumbled, dried-out cardboard-type filter, and this is 

very common. It got dried out and crumbled because 

they probably should have pulled it and replaced it 

sooner.

In that case you would say, Well, what does one of 

these things weigh? We know how many microcuries, 

we know they weigh, now we know the concentration 

in becquerels per gram of junk, and that becomes 

your dust, the stuff that becomes kicked up while he's 

working.

But you know, that might not be the best way to do 

it. Maybe a better way to do it is, let's figure out what 

the specific activity is of the uranium that's airborne. 

In other words, we know the number of picocuries 

per cubic meter from resuspension, right? And we're 

assuming it's 200 micrograms per cubic meter; it's 

sort of like the chronic airborne dust loading, which 

is a fairly high chronic airborne dust loading.

But I said, Wait a minute; the higher the chronic 

airborne dust loading, the lower the specific activity. 

So no, we want to use a low airborne dust loading. 

So what we did was, we said, We have a certain 

number of picocuries per cubic meter from 

resuspension, but we have a relatively low 

micrograms per cubic meter. So we get picocuries per 
79

microgram of the dust that is being drawn into the 

filter; picocuries per microgram.

We know we're going to pick a high-end number for 

that by assuming that the dust loading is not high; in 

terms of milligrams, it's low, and that's where the 

uranium is. It's associated with that dust.

So that gives you a high specific activity for the dust, 

and that's the dust that's sitting on the filter. And it 

accumulates.

So now we're saying, All right. We now say that we 

know the picocuries per milligram of dust or per gram 

of the whatever on the filter, and we're saying, Good, 

now we've got the concentration of the dust -- not 

including the mass of the filter, just the dust that's 

on the filter. And we're saying, All right, guy pulls it 

out, and the stuff -- puff, it comes off. And what's our 

problem? Now we've got to figure out what's in the 

air? How many milligrams per cubic meter?

It turns out we have some really nice work done by 

several different sources that says, You really can't 

work for any extended period of time in an area 

where the dust loading is higher than 100 milligrams 

per cubic meter. You get to that point, you just can't 

breathe in the air. So that's a pretty nasty situation.

So we said, Okay, we're going to estimate what 

would be the dose -- what would be inhaled -- if you 

had 100 milligrams per cubic meter of air, and we 

know what the picocuries per milligram was in the 

specific activity calculation, and this guy is inhaling it 

for one hour.

So every quarter for one hour, this guy is changing

out the filter and being hit with that dust loading. 

Now, is it one hour? Is it two hours? I talked to a 

buddy of mine that actually works on building 

renovation in Newark; he renovates old homes, and 

he replaces HVAC systems. That's one of the things 

he does.
80

I called him up and said, What kind of job is that? He 

works in old buildings in Newark, big buildings. He 

said they just pull out a rack and then put it back in 

again, so it's not that the guys did it all day. So I said, 

Would you say that every time you did that, it would 

take about an hour? He said, Oh, yes.

Listen, I'll be the first to say this is -- but that's what 

we picked. Is it one hour, two hours, four hours? I 

can't really say for sure; maybe some of the workers 

talked to that a little bit at some appropriate time. 

But we used one hour.

And we said, Okay, let's assume then, this guy is 

breathing for one hour, dust that's 100 milligrams per 

cubic meter for one hour, and we know what the 

picocuries are per milligram. So therefore, he's 

breathing the air in at 1.2 cubic meters per hour, for 

an hour, he inhales becquerels or picocuries, he 

inhales every time he changes out the filter, we get 

a dose. It turns out to be nothing. I mean, a 

milligram, I forget what we got.

Chair Beach: Not much. So let me stop you and ask 

some questions. The things they did was change out 

filters, they vacuumed up there, they wiped down the 

duct work, is that correct? Are those the -- did they 

do anything else? The pulled coils or something? 

What else did they do in there?

Mr. Darnell: I don't remember them talking about 

wiping down duct work. I mean, it may have 

happened, but I don't remember it.

Mr. McCloskey: Yes, I think she's right. I think they 

were supposed to clean, and the one guy said, Did 

we clean as often as we should have? No, but there 

was some cleaning going on.

Chair Beach: So do we know the particle size that 

was up there on the filters? Do we have any 

indication of that? How much was on the filters? How 

much was left in the duct work? I just -- there's a lot 

of question I have about this --
81

Mr. McCloskey: I think his scenario has adequately 

bounded all of those things, all of those concerns. Do 

you remember during interviews if they said they 

shut down the system when they changed filters, or 

were they doing it while it was running? I can't 

remember if we asked that.

Dr. Mauro: I can find that out.

Mr. McCloskey: I seem to remember it was running.

(Simultaneous speaking.)

Mr. McCloskey: You're not going to have a breathing 

zone -- to be clear -- 

(Simultaneous speaking.)

Mr. Sharfi: If it's still running and sucking into the 

system -- 

Mr. Darnell: -- stop the whole air conditioning for an 

entire building to change filters.

(Simultaneous speaking.)

Chair Beach: Some of -- we're talking about a lot of 

different ones, though. They could actually walk into 

some of them. They were pretty large. So you don't 

know for sure whether they shut them down or didn't 

shut them down?

Mr. McCloskey: I seem to -- I was asking about that 

during an interview, and I seem to remember a guy 

saying that they'd keep it running; you couldn't shut 

things down. So if the plumes coming off the filter 

you're pulling out it's not going to stay in your 

breathing area for very long at all if the machine is 

running, right?

Mr. Darnell: You've got to remember, this is 

manufacturing, non-radioactive manufacturing at the 

time. So they don't have the same concerns with 

taking out filters, and HFIR's ventilation system was 

totally separate at that time.
82

Chair Beach: So we have no smear samples, no data 

for any of the duct work in, around filters? They didn't 

sample the filters at any time?

Mr. Darnell: No, none of that --

Chair Beach: Anything?

Member Anderson: There's really no data expected.

Mr. McCloskey: There's swipe samples from the

surfaces of the floors down below that was being 

ventilated by this system, right? That's our source 

term.

Chair Beach: But in addition to that, there were 

samples of the floors, but they ended up finding 

contamination on the walls and up above. But we 

don't have any data for that.

Mr. Sharfi: But John's estimate is assuming that the 

dust is so heavy in the room that it's almost 

unbreathable. The contamination on the walls ---

He's making an air concentration that's almost 

unworkable. I mean, we still come up with --

Chair Beach: I get that. This is also from non-union -

- I mean, you're assuming that that's the time they 

spent in there, and I'm just pointing out we still have 

no samples, no data.

Dr. Mauro: Right. But you saw what I did, though.

Chair Beach: I did.

Dr. Mauro: I put the picocuries per cubic meter on 

the very low dust line, which would place an upper 

bound on the specific activity picocuries per gram. 

That's real important.

Member Kotelchuck: Were the workers that you 

interviewed -- did you ask them how long it took to 

change the filter?

Mr. McCloskey: Yes, we did. We did.
83

Member Kotelchuck: You did, and you may have said 

it, actually.

Dr. Mauro: I got it from my buddy. But did we 

actually get it from --

Member Kotelchuck: I mean, what you say sounds 

plausible, but specifically, if you're talking about 

beta, did the workers report or give you an estimate 

of --

Mr. McCloskey: Yes. I'm trying to remember it. The 

one gentleman that was the supervisor of this team 

said they would go to a lot of buildings. Some of the 

non-nuclear buildings would do this, right? So he was 

constantly doing it, and he did put an upper limit on 

it. I'm pretty sure it was bounded by our one month 

that we've used for other things. But I'll go and find 

that data.

Dr. Mauro: Okay. I did not assume that they guy 

changing out the filter was exposed for one month to 

100 milligrams per curie meter.

Mr. McCloskey: No, no, that's not what I meant to 

say there. I meant to say that we liked some of your 

approaches here, and we were going to say that the 

subsurface -- the same pool of workers would be 

drawn upon to do this kind of work. The facilities -- it 

wouldn't be the same guys that were digging in the 

ground, but they would be within that facilities group 

or production group, and they would draw from it. So 

the subsurface one-month bounding would 

accommodate this.

Chair Beach: So I guess I wasn't clear; you're saying 

that any upper bound, any dose would just be for any 

work, every bit of work that a worker was there for a 

year, you're going to look at a one-month time period 

of any of this type of work?

Mr. McCloskey: Yes, since the same group of workers 

could be called upon to do any of these sorts of work, 

we came up with -- we gave them an additional 
84

month of what's in this model here, and we're going 

to add it to the other exposures, the other model that 

we already have. We're going to give them 11 

months of the subsurface resuspension model; it's 

already in DR.

Mr. Sharfi: Yes, 30 months of residuals, one month 

of subsurface.

Dr. Mauro: You see, where we are right now is, we're 

trying our best to reconstruct the unique exposures 

in areas that were communicated to us by the 

interviewees, and make sure we explicitly address 

those; any data.

Chair Beach: And this is such an unusual 

circumstance.

Dr. Mauro: It is; these are highly unusual 

circumstances, you got it. This is where we -- and 

we're right where we should be, whether or not this 

is a tractable question or not; that's what we're trying 

to come to grips with, and here's how we came at it.

We just covered the single most important subject, 

by the way, in my opinion, the subsurface. The dust, 

I thought was going to be the limited pathway, using 

the assumptions I used. I was surprised that we came 

in so low; that's not a big contributor. We could list 

inhalation, because it's only one hour every quarter.

Chair Beach: But I'm not sure I agree with that, 

personally. But that's --

Dr. Mauro: Fair enough.

Member Kotelchuck: But the ORAU folks put in a lot 

more.

Mr. Sharfi: For the subsurface work, not for the --

Dr. Mauro: You limited your work to the subsurface; 

you didn't look at this dust thing, the HVAC system.

Mr. Sharfi: I agree with you that the HVAC is short 
85

termed --

Mr. McCloskey: It's going to be in our revision; we're 

going to address it there, and we do agree with what 

you've done there. I don't know which one of the 

models we'll use.

Dr. Mauro: Because there are other ways you could 

do this.

Dr. Neton: And we do agree that the filter changeout 

process is a much lower dose than the subsurface 

model, which we default to. That's the plan.

Mr. Sharfi: I agree with you, John, that even if you 

say they did it more often, then the buildup is 

smaller, therefore it offsets. And even if they said 

they did it weekly, then the buildup is very small. But 

they're going to do it 52 times, so it turns out 

washing out. Even if they did it once a year it would 

be 52 times bigger, and then one hour -- time goes 

down.

Dr. Mauro: That's why we put it in terms of per-hour 

exposure. See you have to understand; we didn't 

say, This is the answer. We said, I think it's tractable. 

Here's an answer that seems reasonable to us. But 

certainly others may consider different assumptions, 

and they can be discussed or worked out, so we get 

that right.

The third bullet on page 12, outdoor activities. There, 

you're doing subsurface work outdoors, as you 

pointed out. Rose did the work, and the outcome 

was, that was not the limiting pathway, that output 

there. Rose, do you want to give a little rundown on 

how you came at the problem, what data you used 

and what assumptions?

Ms. Gogliotti: Well, that was more of a combination. 

I did the indoor work more, but there were a number 

of outdoor samples that were taken from the burial 

area. We took that data, and we looked at only the 

subsurface data and aggregated it.
86

I believe we took the average on that and used more 

realistic breathing assumptions than we used 

indoors. This model was more for people that were 

walking around in the area of the burial grounds. 

People who were interviewed reported that there was 

constantly dust on their cars that was blowing 

directly from over the burial grounds onto their 

vehicles. So that was more the path that we looked 

at.

Chair Beach: Rose, I've got a question. Didn't one of 

the interviewees say that they parked right there on 

where the burial grounds ended up being? Maybe I'm 

mistaken about that.

Ms. Gogliotti: It was pretty close to it, I believe.

Chair Beach: Okay.

Ms. Gogliotti: We didn't really look so much at the 

subsurface, digging; it was more of if you were in the 

vicinity of the area.

Dr. Mauro: One more thing that I forgot to mention 

is, remember the subsurface work on the Building 10; 

we had to assume a breathing rate. We always use 

1.2 cubic meters per hour on all of this site Class. We 

use 2.5, is that right, Rose?

Ms. Gogliotti: Yes, we used 2.5. That's a study from 

EPA exposure factors handbook for heavy indoor 

cleanup work.

Dr. Mauro: So we figured the guy down there digging 

is going to be breathing heavy while he's down there, 

so that doubles the -- 

Mr. McCloskey: I remember from the interviews that 

a lot of the initial digging was done by outside 

contractors, right?

Ms. Gogliotti: I thought that was just for the breakup 

of the concrete, and then they came in to do the 

actual digging work.
87

Mr. McCloskey: You're definitely right about the 

concrete; I agree with you there. But I thought also 

we show that some of the heavy digging was done by 

contractor.

Dr. Neton: I think the breathing rate is definitely a 

Site Profile issue.

Dr. Mauro: Oh, yes.

Dr. Neton: Maybe we can pick that up in a different -

-

Mr. McCloskey: We've been down this path before 

with other sites, and I've been going back and 

reviewing the history of this. There's a lot of 

discussion we've had in the past about what's an 

appropriate breathing rate. I don't necessarily read 

2.5 cubic meters per hour as the right rate.

Dr. Mauro: And Bob would agree with you.

Dr. Neton: I mean, ISO 366 heavy breathing is 1.7, 

and even at that, underground miners in Africa came 

out at about 1.3.

Dr. Mauro: Oh, is that right?

Dr. Neton: Yes, with no mechanization, just digging.

Mr. McCloskey: We need to revisit that a little closer, 

but I'd say that's a Site Profile issue, not really SEC.

Dr. Mauro: I've got one last bullet on page 12. One 

of the things that was talked about during the 

meeting was, there was a wastewater treatment 

program. Water was continually being used for 

various purposes, for washing the fuel elements, 

various components. Water was collected in a drain 

and then pumped to a water treatment facility, where 

the water was collected, and they separated out the 

solids. They perticipated out the solids and drained 

off the water. That had kick, and they would dry that 

out, and they'd have a press and they would squeeze 

out the solids that, turns out, had some gold in it, 
88

because one of the things they did was, they made 

certain devices that involved gold.

Chair Beach: That was in the mid-'90s, right?

Dr. Mauro: I don't know when they were involved in 

working with gold plating, but --

Chair Beach: No, I'm sorry. I meant when they were 

dealing with the water. When they were draining the 

water in --

Dr. Mauro: That was going on the whole time. The 

wastewater treatment was going on the whole time, 

so therefore one could assume that the wastewater 

that was being collected from time to time contained 

some uranium, particulate material that would find 

its way into the water and be pumped to the water 

treatment facility.

And the workers there would drain off the water, 

compress the solids, ship the solids offsite someplace 

else, where the people would process it and separate 

out the valuable minerals. Okay?

I didn't want to look at that thing. I said, You know 

what? Everything in my bones tells me that that's 

nowhere near as important as the subsurface guy. So 

I have to say that I didn't go to that one. It just didn't 

appear to be a pathway that would seem to be 

anywhere near as important as the subsurface 

pathway. But that was another pathway that I 

mentioned, but I don't analyze.

And now the reality is, we just finished internal.

Chair Beach: We forgot -- can I bring up -- we didn't 

talk about the rafters, the roof, and that's really a 

question for NIOSH. I didn't see anything mentioned, 

and I know in the '90s they vacuumed, they sorted 

rocks, they took up large sections of the roof that 

were contaminated, so did you all talk about any of 

that?

Mr. McCloskey: We talked about it during interviews, 
89

and we are going to add it to the revision of the ER, 

a section for that. What we're seeing at the moment 

is, it is dwarfed by the subsurface questions as well.

We have sample data from the roof, where, during 

AWE, they sampled that material, so we know what 

that was later in life. Then another good reason why 

the subsurface environment inside of them 

encompasses the roof is, a lot of that activity would 

be washed by rain water into the subsurface of 10 

and brought down.

Chair Beach: Right.

Mr. McCloskey: So if you look at the sample data from 

the roof, as opposed to the sample data in the 

ground, it's -- 

Chair Beach: I just wanted to make sure you guys 

were handling it, and where did that contamination 

come from? Do we have a pathway of how it got 

there? Was it some of the -- 

Mr. McCloskey: Unfiltered ventilation that exhaust 

and machines inside of Building 10 collected and blew 

onto the roof.

Chair Beach: That was during the actual AWE period? 

Nothing to do with the residual?

Mr. McCloskey: It would have been commercial work 

on post-thorium AWE to offset and later -- 

Chair Beach: Okay. And then the rafters -- we didn't 

talk -- I mentioned a little bit, the rafters; there's no 

smear samples of anything that could have collected 

on top. I know there was one interviewee that said 

there was stuff falling down every day.

Mr. McCloskey: It was dirty up there; it certainly was. 

And there was a certain amount of need to go up 

there and cut through the roof, make penetrations 

through the roof from inside the building, and there 

were statements that stuff would rain down on you 

during that period.
90

Chair Beach: Okay. So that was the raining down?

Mr. McCloskey: There are some surveys taken in the 

'90s in the upper areas of the building, so we can use 

some of that. But we're going to talk about that in 

the ER as well; we're revisiting that.

Dr. Mauro: Kathy mentioned that to me the other 

night. We did not look at that, but I was thinking 

about was there a way to get a handle on that. I 

would say, the stuff in the rafters is somehow related 

to the stuff that's on the surfaces on the floor, but 

more in the rafters.

The rafters are dustier; that's the sense we got, up 

on the roof and in the rafters. Of course, there was 

dust on the surfaces. There's 54.4 dpm a square 

meter, which is on the floor, and that was the highend value for the floor.

Now the question is, what about the rafters? Would 

you expect that the dpm of 100 centimeters squared 

would be substantially higher than that, and if so, 

how much higher?

So I say that's a reasonable question, because we 

didn't model that. But you're right, they did say they 

did maintenance up there; there's work going on.

Mr. McCloskey: Changing lightbulbs.

Dr. Mauro: So you're right back in the same place. 

Okay, you've got to come up with a concentration, 

picocuries per gram on the rafters, or dpm per 100 

centimeters squared on the rafters. You've got to be 

able to do that. That's a plausible bound, and would 

have to say, What would be the dust loading in terms 

of micrograms per cubic meter? Can you do it?

Well, I guess the micrograms per cubic meter, you 

could it. You've just got to pick one of the higher-end 

dust loadings, because they're working in a dusty 

setting. So theoretically, some judgment is needed 

as to what to pick.
91

As far as the activity goes, my first thoughts are that 

I would go on the high-end value from the stuff that 

was on the surface, unless they measured some of 

the stuff that was up there. If they measured it, then 

you've got numbers. But if you don't have any data, 

here's where you start to ask, How far do you go 

where it's stretching it too far?

But I think that I would be comfortable saying that a 

high-end value from the surface swipe samples would 

probably be pretty indicative of what the 

concentrations might have been up there on the 

rafters. Whether you accept that or not is a judgment 

call.

Chair Beach: Yes.

Mr. McCloskey: The timing would be dramatically 

less.

Dr. Mauro: Of course, and the exposure duration 

would not be full time.

Mr. Sharfi: The fact that your average to high end is 

only a factor of four, you're probably time near the 

floor is much more than the time up top. So in the 

end, the floor time might be bounding over the rafter 

time -- the exposure from the rafter.

Member Kotelchuck: Where is the ventilation coming 

in, in that facility, that building? Where are the air 

vents?

Dr. Mauro: They mentioned there were two types: 

there was a general HVAC system that overall 

maintained the air turnover, air quality. But there 

was also localized ventilation at particular 

components. But what was up there in the rafters --

Member Kotelchuck: The question is whether the 

ventilation is -- whether there is a lot of air 

movement up there, depending on where the 

ventilation units are blowing.

Chair Beach: NIOSH should know that.
92

Mr. McCloskey: Yes, we have maps of what the 

ventilation looked like for the building. There's large 

-- two or three --- I was going to pull up the map so 

I could show them -- that are general area exhausts. 

They ventilate the entire Building 10, but then there's 

also those long hoses that come down like in an auto 

mechanic's garage to ventilate separate machines. 

These were required, because of the local areas.

Dr. Mauro: Elephant trunks.

Member Kotelchuck: So if it's exhaust up there, that's 

not going to be quote "windy". I mean, there's --

Mr. McCloskey: There's an optimal amount of 

ventilation you want to provide; you don't want to 

suck all the heat out of your building in 

Massachusetts, or air conditioning.

Member Kotelchuck: But as opposed to a blower, 

something, a vacuum -- it would not disturb what 

was on the rafters as much as if things were blowing 

in. If air was blowing in, then you might not have 

very much on the rafters.

Chair Beach: Well, and I know our primary concern -

- and I mostly researched on Building 10, but there 

were other buildings too. Are there not other 

buildings that were storage areas that were 

contaminated? Was there any work done during this 

period in any of the other outlying buildings that we 

-- they're mentioned: Building 5, 10, 11, 12, 17. The 

interior of 4, 5, and 10, and the rest are exterior. Is 

there anything else?

Mr. McCloskey: Those are your key areas there that 

we're concerned about. No, the lion's share of 

radioactive material work is done in Building 10, and 

then there was some work done in some of the 

others; some waste handling in Building 5, there 

were some AWE operations that occurred in Buildings 

3 and 4. We also include people who would have 

worked in those areas in our dose reconstructions.
93

Dr. Mauro: The way I was looking at it was, though 

we know AWE activities took place in multiple 

buildings, the majority of it took place in Building 10. 

That would be where the majority of the residual 

uranium activity exposure might have occurred. So 

all of our attention was on Building 10.

Chair Beach: Right, and mine too, and that's why I 

was questioning.

Dr. Mauro: And I think we agree that Building 10 has 

been plausibly bounded. That probably will be 

applicable to all the other buildings also because 

they're nasty buildings.

Member Valerio: Do we have any data from the 

actual equipment that was used in Building 10?

Mr. McCloskey: Like survey data when they released 

it? In the '60s?

Member Valerio: During the residual period, or was it 

all removed at the end of the operational period?

Mr. McCloskey: They sent a lot of the equipment used 

for AWE operations to DWXT in Virginia -- I think 

that's in our ER -- as those operations came to a 

close. They were given to them.

So then there's commercial work that goes on, and 

there are surveys of those. They were under a pretty 

rigorous health and safety plan for doing routine 

surveys, and that work is not covered. We didn't look 

at the surveys -- well, we do have reference to them, 

and we compare to them. And there is survey data 

available, but --

Mr. Darnell: We don't need it.

Mr. McCloskey: I think I can show you some of that.

Chair Beach: They were talking about, in some of the 

interviews, where the machines were kind of cleaned 

up, but there were pockets where they found 

contamination later on. And some of those machines 
94

would have been used during the AWE possibly, but 

there was such an influx going in and out. I just 

remember reading one of the interviews last night, 

where it was talking about pockets of contamination 

still.

The lube, the oil -- I can't remember correctly, but 

there may have been some contamination last year. 

Remember that from the interviews? It might have 

been interview number 1.

Mr. McCloskey: I remember during, machines being 

talked about, but those machines being left over from 

the AWE period, I don't remember anyone saying 

that. 

Chair Beach: I can't remember why it was talked 

about that they were contaminated machines in 

pockets.

Dr. Mauro: The question would be -- okay. About that 

equipment that could have had some accumulations 

where some rain might have been, and workers that

were there could have inhaled some during the AWE 

period. Is that covered by the scenarios we've 

described?

If that did occur, it wasn't any worse than what we 

did with that. And the question would be 

concentration and duration of exposure. I mean, it's 

a legitimate question. It's possible that there could 

have been those scenarios which we did not explicitly 

address, that could have somehow been worse than 

subsurface scenarios.

Mr. McCloskey: I'd like to go back to Loretta's 

question about saving of equipment. For those I 

found SRBD 114235; 114235, pages 43 through 46. 

So this is data for commercial work. When I say 

commercial, understand that to be HFIR. And this is 

from a five-year period, during residual period. And 

then there's Table 13.2.3.1, Typical Contamination 

Survey Results. Then it talks about areas surveyed.
95

From the fuel-manufacturing area, the walls, floors, 

and equipment were surveyed. Personal passthrough areas, including the room walls, floors, and 

equipment; outer clothing for exiting the fuelmanufacturing area; protective clothing within the 

fuel-manufacturing area, and then in the general 

manufacturing areas.

So during this period of time, the FMA would have 

been an island inside of the GMA. The GMA is the 

general manufacturing area, the FMA is a smaller 

portion of that, all within Building 10, the primary 

area.

So within the GMA they surveyed the walls, floors, 

and equipment. They also have data here; this is a 

five-year summary for exposed skin of personnel 

entering the GMA from the FMA, and items and 

equipment entering the GMA from the FMA.

All the information is available and removable activity 

per 100 centimeters squared and fixed.

Chair Beach: Pat, I'm sorry. What dates was that on?

Mr. McCloskey: The date of this is February 15th, 

1979, but if you read through here, it will say that it's 

a summary from a five-year period, I believe.

Chair Beach: So mid-'70s?

Mr. McCloskey: I believe so.

Dr. Neton: And what types of levels were they 

reporting?

Mr. McCloskey: The walls, floors, and equipment 

were all less than 800 dpm per 100 centimeters 

squared. Removal of the personal pass-through areas 

were all less than 10 dpm.

Mr. Sharfi: They were less than 800 in the FMA.

Dr. Neton: In the FMA; what about the in general 

area?
96

Dr. Neton: In the general areas, they found no 

contamination.

Mr. Sharfi: Okay. That's important.

Dr. Neton: So it seems that the general area, it 

doesn't show that anything coming out of HFIR was 

actually contaminating the outside manufacturing 

area.

Member Valerio: But that was coming out of the 

HFIR.

Mr. Sharfi: So the HFIR, they did find some 

contamination on the walls, floors, and equipment. 

But when they surveyed the general manufacturing 

area, they didn't find any.

Member Valerio: Okay.

Mr. Sharfi: It was under detection limits, so there was 

no indication --

Member Valerio: Let me see that.

Dr. Mauro: Should I go on?

Chair Beach: Does anybody need a comfort break? 

Where are we at?

Mr. Darnell: I need a caffeine break.

Chair Beach: It's 11:30.

Mr. McCloskey: I don't think we're near done yet.

Chair Beach: No.

Mr. Katz: Why don't we take another 10-minute 

comfort break, then? Okay. So, another 10-minute 

break, yes.

Chair Beach: At 11:40?

Mr. Katz: Yes. We'll reconvene about then.

(Whereupon, the above-entitled matter went off the 
97

record at 11:29 a.m. and resumed at 11:47 a.m.)

Mr. Katz: Andy, are you back on the line?

(No audible response.)

Mr. Katz: On mute maybe. Henry?

(No audible response.)

Mr. Katz: Henry Anderson, are you still there?

(No audible response.)

Mr. Katz: Okay. Well, I think we can get started 

anyway. We have everyone else in the Work Group 

here in the room.

So, John --

Dr. Mauro: Sure.

Mr. Katz: -- where are we?

Dr. Mauro: I'm ready to go. We're about to change 

subject. Go to page 14 on the slides. We're going to 

be talking about external exposures. Everything we 

did so far was internal. Now we're going to talk about 

external. And again, it's important to think in terms 

of the Evaluation Report as it currently stands and 

also your addendum that we sent out. It has a certain 

protocol and uses a certain approach for 

reconstructing external exposures. Okay?

So we're -- we looked at it from the point of view, 

okay, let's see what they did and how they did it and 

the way you do it. And then of course there's the 

other side of the coin that says, okay, that's what's 

in the ER, the Evaluation Report. What about this new 

stuff that we're talking about, the sub-surface and 

everything else? Is that something that we really 

need to look at carefully just like we did for internal? 

So we could break it up into those two parts. Okay?

So the first thing, just to put it out, is the strategy 

that NIOSH has adopted in their Evaluation Report is 
98

they said, okay, we're going to have to find a way to 

assign external doses to the workers during the -- the 

M&C workers during the residual period. And the 

approach that we understand that you took is that 

there is abundant external dosimetry data that was 

collected in 1966 and 1967 that is a body of data from 

which you could say we could estimate -- get a 

distribution. And it's that data, external dosimetry 

data during the end of the AWE period; correct me if 

I'm wrong, that's used as being representative of the 

exposures experienced for the same workers during 

the residual period.

Now there are two things we want to talk about. One 

is we reviewed that data and the approach and the 

assumptions and how you came about assigning the 

values that you decided to assign. And I'm going to 

ask -- if Bob Anigstein is still on the line I'd like you 

to summarize, because he did a critical review of that 

approach to data and what you did and he has some 

comments about how he would have done it.

So, Bob, if you're still there, could you give a little 

rundown on -- and that -- by the way, that 

information, that summary is on page 15 of the slides 

if you want to follow. And but Bob could go ahead 

and explain -- 

Dr. Anigstein: Yes.

Dr. Mauro: -- what his thinking is.

Dr. Anigstein: Now, what exactly?

Dr. Mauro: Well, Bob, we're -- 

Dr. Anigstein: We're -- 

Dr. Mauro: Yes.

Dr. Anigstein: -- talking about the film badge data?

Dr. Mauro: Yes, with -- what I'd like is a summary of 

your review of how they used the film badge data to 

come up with what I would call a surrogate way of 
99

assigning external doses to the workers and how they 

used the film badge data. I know you have some 

comments.

Dr. Anigstein: Okay. First I want to say at this point 

I just read the White Paper yesterday and I'm a little 

confused because what -- they planned to use the 

film badge data for the subsurface scenario in a 

different way than for the rest of the exposures, so I 

am not quite sure unless Peter wants to chime in and 

claim this. Because in the one case prior to the White 

Paper my impression was that they tend to use the 

95th -- the upper 95th percentile of film badge data 

to assign doses for the entire residual period yearround. I mean, for each year. 

And then in the White Paper they said they're going 

to reprocess -- that's the impression I have, but they 

didn't use that word; that's my word, the film badge 

data quarter by quarter, because what they have for 

1967 is quarterly -- the Film Badge Program ended 

on September 30th, 1967. That was apparently --

there were no more film badges, so I assume there 

were not records. There was probably -- the real end 

of the AWE period was probably September 30th 

even though nominally NIOSH continued it through 

the end of the year.

And what the original intention was to use -- well, 

there was -- it was not quite clear, but they were 

going to -- in the White Paper the intention was to 

take the reading for the three quarters, put them 

altogether -- in other words, because each film badge 

record the readings -- most of them are quarterly. 

There are a few monthly records, but most of them 

were quarterly. So it has the accumulated dose for 

the quarter, accumulated dose for -- from the 

beginning of the calendar year and accumulated dose 

from the beginning of the Film Badge Program which 

started in October 1965. 

And then sometimes the workers were assigned 

doses based on their work history prior to that, 

because at that time the rule was -- there was this 
100

18 -- let's see, 5N minus 18 rule that starting with 

the age of 18 they were allowed to accumulate five 

rem per year, and therefore if they had -- say they 

were at 21 and they had no prior exposures, then 

already they were allowed 15 rem for the year if they 

hadn't been exposed or accumulated. Anyway, that's 

not relevant here. So anyway, that's the data we 

have. 

So originally there was a little bit of confusion I think 

in the way NIOSH used the data. At least that's my 

impression. But the latest statement about -- you're 

talking about data; they didn't actually produce 

numbers, was they would take all the readings 

quarter by quarter because the problem had earlier -

- I'm sorry if I'm talking a little bit in a zigzag --

problem we had earlier was -- we, meaning SC&A had 

with the film badge data, is they gave equal weight 

to the film badge reading of a worker. Let's say he 

had a reading that ended for the quarter ending 

September 30th, 1967, but he may have not had any 

previous film badges for that year because maybe he 

wasn't assigned to the program or maybe he lost his 

badge, failed to turn it in. And so there will be a 

notation in the record, this is the accumulated dose 

for the year and this is how many film badges have 

been processed for this particular worker and how 

many missing film badges there were. 

And so what I did was I reprocessed the -- this is 

prior to the White Paper. I reprocessed the film badge 

readings and I discarded any that weren't -- did not 

have all three quarters, because you couldn't put the 

same thing on the same footing. And then we took 

only the readings for the -- the year-to-date readings 

only for those workers, and I believe there were 82 

of them left, for which you had readings first quarter, 

second quarter, third quarter, the accumulation. And 

then we could go back and look at the first and 

second quarters. 

In some cases the readings were scanned. And the 

scanning was not always the same quality, so 
101

sometimes the numbers were very clear, otherwise 

they were very, very faint. But it was possible -- the 

funny thing was that in the column where it said 

year-to-date it was faint, but in the column which 

said for that quarter it was legible. So you had to --

it was very easy to take the reading for that quarter 

and go back and see. Well, what was the 

accumulated dose in the second quarter? 

So each of the very, very legible readings, some of 

which NIOSH submitted, were able to reconstruct 

based on the previous history. And the bottom line 

was -- ended up with 82 workers that had continuous 

readings for that year. And then there was a question 

of -- there was also an issue that some workers were 

issued two badges and one was labeled with a badge 

type 1 and there was a footnote on the bottom of the 

record which says badge type 1 is whole body. And 

then they would have a badge type 2, which was 

beta. And often they were the same. The badges 

were not specifically different. 

And we happened to have the great advantage of 

having on our staff as an associate [identifying 

information redacted]who was a [identifying 

information redacted] of Landauer. He wasn't 

there during that period. He joined that company 

somewhat later, but he was very familiar with their 

practices. So he said basically it was the same type 

of badge but they were processed and read 

differently. So there were only something like 20-odd 

beta badges and many more No. 1 badges.

Now what the -- whoever processed the data for 

NIOSH mistakenly lumped the beta badges together 

with the gamma badges. So even though it was one 

-- it said type 1, type 2 with the same worker's name 

and Social Security number on the -- or the serial 

number; I'm not it was the Social Security number,

also on the record. So obviously those beta doses 

should not have been included with the photon doses. 

I mean, that's a separate thing. So that was one 

mistake that we corrected. And the other one was 
102

making it -- and a couple of places where they was 

simply mis-recorded.

So we ended up with, as I said, 82 records. And by 

taking the 95th percentile -- and this is just -- there's 

more than one way of calculating the 95th percentile. 

There is a very sophisticated method called 

regression order statistics where you actually plot the 

numbers and draw a curve and pick off the 95th 

percentile off of that. Or a simplistic but actually 

perfectly good way of just ranking them in order; the 

Excel spreadsheet does that automatically, and then 

seeing where the 19th -- 95th percentile would mean 

the -- if there were 20 readings, it would be the 19th 

reading. So of course there were more than that, so 

simply interpolating between the two readings that 

spanned the 95th percentile. So it's really based on 

two numbers.

But anyway, we did that. Those were -- we did that. 

That was a simple way of doing it. 

And I came up with a higher dose. I came up with 

280 millirem per year because multiplied by -- we 

added one-third because there were three quarters 

and a year has four quarters, so to get an annual 

dose we took the 95th percentile and multiplied by 

four-thirds. So that was the bottom line. It was -- and 

it's a little higher. It's just a matter of numbers, not 

tremendously higher.

Now the uncertainty, the place where I have -- need 

some explanation is with the White Paper now NIOSH 

proposes to -- a different approach. First of all, 

they're going to take the individual quarterly 

readings, not looking at the accumulated year. And 

in that case you don't have worry whether that 

worker had one reading, one quarter badge for that 

year or three quarter badges for that. But you're just 

looking at quarter by quarter. 

I want to say we were looking at quarter by quarter, 

then take the entire distribution. In other words, I 

would take the -- take the geometric mean, the 
103

geometric standard deviation and enter -- if you're 

doing a dose reconstruction, that would be entered 

into IREP, but divided by three because it's three 

months worth and we're only assuming that the 

person was doing this remediation work for one 

month. 

So I'm not quite sure how that would then be related 

to the annual dose that they got from taking all the 

film badge readings.

Mr. McCloskey: Robert?

Dr. Anigstein: It seems to me like there's redundancy 

there.

Mr. McCloskey: Hey, Robert. This is Pat McCloskey. I 

can help you out there. You did pick up on a change 

that we're putting out in the White Paper for the 

subsurface work, but we're also going to do that in 

the ER revision for all of the workers.

So you really helped us out here. Initially we wanted 

to use as much of the 1967 data, the data from the 

end of the AWE ops as we could. And in the ER we 

said that there were 100 and, oh, how many -- 162 

data points that we had. And then you pointed out 

that you shouldn't assemble all of those records 

together because they're there. It doesn't make a 

good rank order.

So, but we looked at that and although you have --

your 82 people each have a complete 1967 record, 

we were concerned that we were also omitting some 

of the workers from 1967 that could have had a 

complete record. And it would be hard to know for 

sure because if you just delete all of the people with 

a number in the column that says they're missing a 

badge, there's no way to know that they might be 

missing a badge from 1965, for example, or 1966. 

So we wanted a new way to do this that we could 

incorporate all of the 1967 data. And as you rightfully 

noted we moved to developing a model that was 
104

based on quarters. 

Dr. Anigstein: I hear you, but what we -- but we're 

able to overcome that problem by essentially 

identifying -- by looking at the same person's records 

for the previous three quarters to identify which ones 

were missing that year and which ones are missing 

from the previous calendar year. So that's how we're 

--

(Simultaneous speaking.)

Mr. McCloskey: Oh, okay. So you reduced it down to 

82; I thought it was 87, but our new method -- and 

we handed out an updated issues matrix to everyone 

here. You don't have it, but we did calculate the 

numbers. And as soon as it gets through ADC we'll 

make it available to everyone. But what we do is we 

come up -- we use every quarterly dose from 1967 

and calculate a geometric mean and a standard 

deviation. And we used that -- we're going to use that 

approach in the ER revision for everybody. And for -

- and then for the subsurface workers we're going to 

take a third of that and assign it to them. 

Dr. Anigstein: So you would use -- you will throw 

away -- I mean, retire the original approach and just 

go with the quarterly badges?

Mr. McCloskey: Exactly. You brought up some 

reasonable --

Dr. Anigstein: Okay. No problem. That's --

Mr. McCloskey: Appreciate your review of that.

Dr. Anigstein: Actually you did that for the beta dose 

and we agreed to that.

Dr. Mauro: I'd like to jump in now, which almost 

makes the last conversation moot. I don't think you 

could use data associated at a time when there was 

uranium on site where the workers, the M&C workers 

were involved in AWE activities which was up through 

the end, I understand, of -- now if you could convince 
105

me that the film badge data that you did work with 

reflects exposures associated with the kind of 

exposure pathways that existed during the residual 

period, fine. But it doesn't look that way. 

It looks like the data you used was data from people 

who were badged during a time when they were 

working with fuel. And since we know there was no 

AWE fuel on site during the residual period, you've 

got yourself a situation where I would call it a 

surrogate data problem. You're in effect using data 

from the AWE period as a surrogate for exposures 

during the residual period.

Bob and I had lots of conversations on this and I 

came down in a place where you can't do that. In 

other words, you can't use that data to assign to the 

residual period. You got to go and model and predict 

as best you can. Similar to the way we did internal, 

got to do external. 

And in theory it's a tractable problem, and in fact we 

actually do it in our workup where we say, okay, just 

like we constructed isotopic distributions and 

concentrations in various settings we -- from there 

you could predict using classic dosimetry -- external 

dosimetry to predict what the doses were that the 

workers might have experienced. And of course that 

involves picking a concentration distribution that you 

think is plausibly bounding and derive based on those 

concentrations what the external exposure is, just 

like we did for internal. 

I don't think you could use measured data during the 

time period when there was fuel on site as being 

representative of exposures experienced during the 

residual period. So in my mind that whole strategy 

doesn't work.

Mr. Sharfi: I think we're saying it's bounding for the 

residual period. And given the small nature of the 

exposures it was accurate enough -- if the bounding 

exposures were 15 rem per year and we know the 

residual is 50 millirem, then obviously it's an over-
106

estimate, and I understand that. But then these are 

-- the external dosimetry in '67 doesn't indicate high 

exposures, and therefore it's a plausible bounding 

situation where you're -- where you can -- it's an 

acceptable bounding scenario.

Dr. Mauro: We agree that that approach is likely to 

be bounding. And interestingly enough when we did 

it our way, where we didn't look at your data; we just 

went ahead and modeled it the way it should be 

modeled, we're not that far away from you, 

interestingly enough. And that -- I consider that to 

be a coincidence, not a fundamental. 

So in my mind I still feel that you're going to run into 

what I call surrogate data problems. Because 

notwithstanding that the doses are relatively small 

and notwithstanding the fact that when you do do it 

independently the way we did it we come up with 

similar numbers, you just can't do it that way. I 

mean, there is no fuel on site.

Dr. Neton: No, there's a lot of fuel on site. 

Dr. Mauro: No, not AWE fuel.

Dr. Neton: Right.

Dr. Mauro: Yes, there's HFIR fuel, but that's not part 

of the game. 

Chair Beach: So that's what that list was. I was 

wondering why you pulled that.

Mr. McCloskey: Yes, the NMMSS inventory?

Chair Beach: Yes.

Mr. McCloskey: So you're saying since there's no 

AWE fuel there, the exposures that we've said were 

there at the end of AWE ops are too high?

Dr. Mauro: No, just not -- I'm not saying too high. 

Just can't use them.

Chair Beach: You can't use it.
107

Dr. Neton: Well, I think you're saying they're too 

high.

Mr. Sharfi: You're saying they're too high.

Dr. Mauro: Well, they're likely to --

(Simultaneous speaking.)

Dr. Mauro: No, I'm just saying --

Dr. Neton: By definition they have to be.

Dr. Mauro: Of course they are expected to be higher 

because the guys are working with fuel. In the 

residual period they weren't working with fuel. They 

were working with just this residue. So the 

expectation would be that you're going to get higher 

doses the way you did it, but it turns out it wasn't 

that much higher. It was bounding, but that's not the 

point. The point is that you can't use that data to 

assign doses during the residual period. I mean, well 

--

Chair Beach: Well, and we just talked about that in 

the internal.

Mr. McCloskey: Yes, we have to use AWE source term 

to get our exposures from, right?

Dr. Mauro: Right.

Mr. McCloskey: So don't we often use whatever is left 

at the very end of AWE ops to show --

Dr. Mauro: Only --

Mr. McCloskey: -- the beginning of the residual 

period?

Dr. Mauro: Only when you're talking residual. In 

other words --

Chair Beach: AWE.

(Simultaneous speaking.)
108

Dr. Mauro: -- no problem when you're talking about 

residual radioactivity at the end of the AWE period 

because that's going to be still there at the beginning 

of the residual period.

Mr. McCloskey: Okay. I see.

Dr. Mauro: But the external radiation field --

Mr. McCloskey: Is gone.

Dr. Mauro: -- is gone. 

Dr. Neton: Well, I don't know. I mean, the contract 

was over, but I don't know how much residual fuel 

was there. I mean, did they get rid of it? I mean, it's 

not like they -- immediately as soon as the contract 

was over all fuel was gone --

Dr. Mauro: Yes.

Dr. Neton: -- from the site.

Dr. Mauro: That's my understanding. Gone. 

Dr. Neton: Okay.

Dr. Mauro: The only fuel on site was HFIR fuel.

Chair Beach: Or what was in the drains.

Dr. Mauro: And the residue of course. But as far as 

fuel itself, we have people handling fuel, assembling 

different fuel for different purposes. That's under 

AWE activities, HFIR activities. That was all gone. 

Taken away. Mr. Sharfi: Are you saying then it's not 

plausible that it could not be bounding?

Dr. Mauro: No, no. That has nothing to do with it. I 

mean, theoretically let's say, well, you know what 

we'll do? We're going to use the reactor exposures 

from Hanford as a bounding number.

(Simultaneous speaking.)

Mr. Sharfi: Well, it was relatively bounding and 
109

grossly overestimated. That's why I said given the 

low nature of these numbers, we found it acceptably 

bounding.

Dr. Neton: I don't know. You've almost proven that if 

you came up with -- I don't know how close you came 

to what we've used, --

Dr. Mauro: Well, yes, it's in there.

Dr. Neton: -- but the exposure, the flat exposure to 

fuel is not necessarily the main exposure route in 

these people. I mean, you sort of demonstrate that 

empirically, right? You said --

Dr. Mauro: Well --

Dr. Neton: -- well, I think close is very -- dose is very 

similar to NIOSH. NIOSH used values at end of 

operation, so there must have been an exposure 

pathway that was really not directly related to fuel 

exposure.

Dr. Mauro: I will agree that during the AWE period 

workers were exposed to fuel and they were exposed 

to residue. The residue remained into the residual 

period, but not the fuel.

Now my sense is that of course the limiting -- the 

thing that's going to contribute most to your dose is 

going to be the fact that people are handling fuel. 

Now the fact that we ended up coincidentally -- that 

our models of the scenarios during the residual 

period were not that much different or lower than the 

actual data, that's just a coincidence. And the 

coincidence emerges from the fact that we fairly 

conservative assumptions for how we modeled the 

external doses during the residual period. That's 

what we did. And the fact that in the end your 

approach and our approach are not that much 

different. 

I don't -- I can't see that being an acceptable way to 

argue your point because it just breaks every rule of 

the surrogate data. Breaks every rule. Can't do it.
110

Dr. Neton: I'm not sure. We'll go back. And this is a 

-- I think this is a Site Profile that you -- 

Dr. Mauro: Yes.

Dr. Neton: You say you can do it -- 

Dr. Mauro: This is a site -- 

Dr. Neton: -- whether it's modeled or not.

Dr. Mauro: Oh, no, no. I'll tell you where -- it's -- the 

issue is can you reconstruct external doses during the 

residual period using the approach of the 

fundamental strategy that we used? You cannot 

reconstruct doses during the residual -- external 

doses using the approach you used. If we only had 

that approach, the approach you used, that would be 

an SEC, because you can't do that.

Dr. Neton: Well, I'm not so sure about it. I mean, let 

us take a crack at that bat. I mean, you're saying no, 

but I'm saying we need to go back, revisit and we 

might be able to convince you that that's true.

Dr. Mauro: If you can show that -- 

Dr. Neton: If not, then we will -- 

Dr. Mauro: -- there was no fuel on site at the time -- 

Dr. Neton: No, you're -- 

Dr. Mauro: -- those measurements were made, I'd 

buy it.

Dr. Neton: But you're assuming that the -- we're 

using the 95th percentile? That's what we're using?

Mr. Sharfi: No, the mean, geometric mean.

Dr. Neton: The geometric mean value was 100 

percent related to people working with fuel. The 95th 

percentile, I would agree with you is fuel-related. But 

the average value, the 50th percentile value is not 

fuel-related necessarily. It could be just general plant 
111

environmental conditions.

Dr. Mauro: I know, but --

Dr. Neton: That's where your assumption --

(Simultaneous speaking.)

Dr. Mauro: Well, I'll reverse it on you. You can't make 

that assumption that the doses are predominantly 

from residual radioactivity. In fact, if someone were 

to ask me, common sense would say of course it has 

to be driven by the fuel because this residue is 

relatively nothing. We know these doses are low. 

Now the fact that you actually ended up with fairly 

low doses apparently, because our doses were low in 

our models, our external, and your doses were low -

- now does that mean that, well, that means your 

doses were due to the residual activity? No --

(Simultaneous speaking.)

Mr. Sharfi: I don't think we're making the argument 

whether it's due to residual. We said it's considered 

bounding and acceptable.

It's -- the question -- my understanding of what is 

considered acceptable bounding is is it realistic or is 

it grossly overestimating? We're saying -- I mean, 

you're talking about exposures that are really not 

much more than detection limits.

Dr. Neton: I was also going to ask how much of that 

data is driven by the LOD?

Mr. Sharfi: Most of it's -- most of the data is right 

around the detection limit --

Dr. Neton: That's --

(Simultaneous speaking.)

Mr. Sharfi: -- which is indicating -- Dr. Neton: Yes.

Mr. Sharfi: -- really missed dose is -- residual 

exposure is right around the missed dose level. That 
112

--

(Simultaneous speaking.)

Dr. Neton: Well, if they were badged, we'd come with 

the same --

(Simultaneous speaking.)

Mr. Sharfi: Yes, if everybody was badged in '68, the 

dose would be almost identical. 

Dr. Neton: That would be --

(Simultaneous speaking.)

Mr. Sharfi: -- point is --

(Simultaneous speaking.)

Dr. Neton: -- data, I say good. We're done. At that 

point I would say this is good enough. Mr. Sharfi: But 

that's the point. I mean, if it's driven by missed dose, 

that's the upper limit to what the people could have 

been exposed. You can't do any better than that. If 

you've got badged data and it's driven by missed 

dose -- the doses are small. That's what we're saying. 

And it was -- if it's non-detectable and we use missed 

dose, that's part and parcel of our program.

Dr. Mauro: There's a mechanistic problem here. 

Mechanistically to use data that was acquired at a 

time when there was fuel on site and people were 

handling fuel, notwithstanding whatever dose you 

got, you can't use that --

Dr. Neton: It does --

(Simultaneous speaking.)

Dr. Mauro: -- time period when there was no fuel on 

site.

Dr. Neton: It does if you demonstrate that it was nondetectable exposure for the most part.
113

Dr. Mauro: I don't buy it.

Dr. Neton: LOD over two.

Dr. Mauro: Yes, I hear what you're saying.

Dr. Neton: So you were saying if we had the -- if we 

had the same data set one year later --

Dr. Mauro: Yes.

Dr. Neton: -- in the same place we'd be okay?

Dr. Mauro: Yes.

Dr. Neton: Then I disagree with you. So let's take a 

crack at trying to convince you logistically. But I hear 

what you're saying. I come out differently.

Dr. Mauro: Okay.

Chair Beach: So that's for Fact Finding 2. And does it 

carry over to Finding 3 as well?

Mr. McCloskey: Yes.

Chair Beach: That's what I thought. Mr. McCloskey: 

That's the beta doses.

Chair Beach: Yes.

Dr. Mauro: Yes. See, to me, I -- in effect we broke 

the Work Group into two parts. I said, Bob, review 

what they did given the assumption that you can do 

that, use the measured data in '67 or whatever. And 

what would you come up with? And he came up with 

it. And he has his comments. And it's a little bit 

different.

Chair Beach: Okay. 

Dr. Mauro: I said -- and this -- we'll move it parallel. 

Okay. When we were done we actually got into a 

discussion. Bob argued with you. If he was -- we were 

having a free and open conversation. Bob would say, 

you know, I'm okay with that. I said, Bob, I can't do 
114

it. I can't sit in this room and say that's okay. And 

then that's SC&A's position.

Action Items/Path Forward: NIOSH Evaluation 

Report Addendum, other items

Chair Beach: Okay. The first action item. That's going 

to be a NIOSH action item.

Mr. Darnell: I had a question first. Maybe I'm just not 

understanding something. If we use the numbers 

that you say we can at the start for the external, 

aren't those numbers actually more conservative, 

more claimant-friendly than what we would use if we 

found 

out -- 

Dr. Mauro: Yes.

Mr. Darnell: -- what some other number is?

Dr. Mauro: Yes.

Mr. Darnell: Then what's the point?

Dr. Mauro: They have nothing to do with each other. 

The numbers that you measure have nothing to do 

with what happened in the residual period. There's 

no mechanistic reason why those numbers have any 

relationship whatsoever to -- 

(Simultaneous speaking.)

Dr. Neton: Except to show the exposures were small.

Dr. Mauro: Except to show that the exposures -- but 

that's just -- 

Dr. Neton: It could not be necessarily detected by 

conventional film badges at that point. So, it makes 

no difference, then, John. I mean, if you've got a 

source term there and you can't detect it, and you 

take the source term and you still can't detect it -- 
115

Dr. Mauro: I'm going to show you why that's wrong. 

Let's say it turns out the models we use that try to 

explicitly address what deposits on surfaces, the 

residual activity, and the subsurface activity, and we 

did all our calculations just the way we did, okay, and 

we come up with a number that's higher than what 

you guys come up with. All right? One would say, 

well, I don't know why that happened; one would 

never expect that to happen because they don't 

actually work with real fuel. The answer would be, 

well, of course, you have to use the models for the 

residual period.

The fact that, by coincidence, you come in at below, 

it just happened to come out that way. There's no 

mechanistic reason why the numbers in 1967 should 

have any relevance to the exposure -- think of what 

people were doing. In one case, people were working 

with uranium, and the other case is people digging 

holes in the ground, where there was residual 

reactivity. And there was no uranium, other than the 

residue. There is no relationship between those 

scenarios. It's a classic surrogate data issue.

Dr. Neton: I disagree, John. I think you've got two 

populations. You've got people maybe working 

directly with the fuel, 95th percentile, and you've got 

the general workers that are working around the 

plant at the 50th percentile, which are not detectable, 

basically.

You're assuming that everybody was working with 

the fuel that was badged. That's not true. So, you've 

got two distinct exposure populations there.

Dr. Mauro: Well, do you agree that the data that you 

used for 1967 reflects exposures workers 

experienced while working with fuel? At least some 

of it.

Dr. Neton: Yes, sure. At the high end.

Dr. Mauro: How much of it is -- you don't know. See, 

I can't do it.
116

Mr. Sharfi: No, I would say the high-end data, it's 

likely -- but, since you use a geometric mean, that 

geometric mean is likely going to be dominated by 

the people who don't work with fuel. If you're using 

the 95th percentile, the upper end people are likely 

to be in that upper end because of what we do in the 

fuel.

Dr. Mauro: I hear you making your case, but you 

understand why I'm concerned. I mean, all I'm 

saying is, I'm explaining to you why I have trouble 

with that; that's all.

Mr. Sharfi: For the SEC, though, the good news is we 

all agree with the sample data we have for 

contamination for subsurface soil --

Dr. Mauro: Oh, yes, I think --

Mr. Sharfi: Do you believe that's good data? And 

FDR-12 is available.

Dr. Mauro: Yes.

Mr. Sharfi: Your method.

Dr. Mauro: Yes. No, I think you could reconstruct 

those doses, but not using the methods you used.

Dr. Neton: We're going to look at it. I mean, we may 

come on the same side, but I think we need to think 

about it before we just say, yes, I think you're right.

Dr. Mauro: Sure, sure.

Dr. Neton: I mean, I think there is a thought process 

that's going to go behind this. And I understand your 

argument perfectly, but I don't know that necessarily 

we agree.

Member Kotelchuck: It's a little bit ducking around 

the issue, but do we actually know how quickly the 

fuel was removed? You say, oh --

Dr. Neton: John says it was immediately gone.
117

Member Kotelchuck: And another perspective would 

be everything happens slowly in the world and that 

lots of things are hanging around. That's answerable.

Mr. Sharfi: The better argument, if the fuel was 

moved in '66, because, then, '67 would be data that 

was no fuel.

Dr. Mauro: You show me that there's no fuel onsite 

in 1966, I'm with you 100 percent.

Member Kotelchuck: That's discoverable, isn't it?

Dr. Neton: We'll take a look at it. I think there's some 

work that -- yes, we'll look at it.

Mr. McCloskey: We have an SRDB document that 

shows the inventory. The cover page for that from 

the person that provided it said that there's four 

different codes; now they have their three different 

codes. And we didn't find out which one of those 

codes is assigned to HFIR or --

Dr. Mauro: Right. You see, this table we're looking at, 

when all is said and done, it says, yes, there was fuel 

onsite in 1967; there's fuel onsite in '68 and '69. And 

you know what that is? That's HFIR fuel. It has 

nothing to do --

Mr. Sharfi: Yes, but if you look at the number at '66, 

it drops a factor of almost three or four, and then, it's 

consistent.

Dr. Mauro: And then, it jumps again.

Mr. Sharfi: No, I'm saying, if you look at the end of 

'66 --

Dr. Mauro: Yes.

Mr. Sharfi: -- it says 600,000. Then, it drops to about 

200,000 and stays constant.

Dr. Mauro: Yes.

Mr. Sharfi: So, it almost looks like, at the end of '66, 
118

the fuel was removed.

Dr. Mauro: Yes.

Mr. Sharfi: In '67, it is likely just HFIR material, 

because it is consistent. It's about 200,000 --

Dr. Mauro: Right.

Mr. Sharfi: -- after '66.

Dr. Mauro: Okay. So, you're making the case -- if you 

could make a case that there was no AWE fuel during 

the badge period, therefore, the badges and the data 

you have reflects the residual activity.

However, I suspect that whatever you are reading 

here is probably a combination -- right through 1967, 

what you're looking at is badge data from workers 

that were working with AWE fuel and working with 

HFIR fuel. Okay? And then, once you move into 1968 

-- here's where it could be wrong -- there was no 

AWE fuel onsite, and therefore, that data has no 

relevance. That would be my position. You show me 

wrong; I buy your argument.

Dr. Neton: We'll look at it. I think we understand the 

position.

Member Anderson: So, where are we headed here? 

We're going in circles.

Dr. Neton: Well, NIOSH has an action item 

to investigate this issue and we'll get back to you.

Member Anderson: Okay. All right. Yes.

Dr. Neton: I mean, that's one of their findings, and I 

don't think the White Paper we issued, which was just 

a subsurface model, addresses it, either. A separate 

discussion on that.

Dr. Mauro: Now, just to close things out, and I think 

we're done, at the very end of this writeup, I have a 

couple of -- it starts on page 17 -- examples of how 

we modeled the pathways, these new pathways. We 
119

talked about it. We understand it. It's there. If you 

want to read it, it's good, but I think we're done. In

other words, we really have come to the point where 

we understand why we believe you can reconstruct 

external or internal doses during the residual period, 

because you have adequate data that can be 

interpreted and used in a manner to place a plausible 

upper bound.

And we give examples at the very end. But we talked 

about it in great detail as we went through this 

process. So, if you want to, we could walk through 

those examples, but I think that we have already 

done that.

Petitioner's Comments, Concerns, and Questions

Mr. Katz: Why don't we get the petitioner's opinion?

Chair Beach: I was going to ask you if we could do 

that.

Member Kotelchuck: Let me ask you this: the 

plausible upper bound, if there were no SEC, or the 

group decides that the SEC is not acceptable, then 

you would have exactly the same number for every 

single person who worked in that residual period. 

There would be no individual -- 

Mr. Katz: Well, it's individual, depending on -- 

because their duration, their tenure there, and all 

that is different. So, they get a different dose 

reconstruction, but the same machinery for their -- 

Dr. Mauro: The only distinction would be we do know 

that there was a pool of workers that were called the 

maintenance, repurpose -- there was a lot of people 

involved in repurposing and maintenance. But there 

were other workers -- I just did a case, in fact. I just 

finished a case where, the way I concluded, I said, 

listen, my critique was, you know, by the way, we 

don't know if this worker, given this job description, 

was involved in maintenance and repurposing. But, if 

he was, you missed those doses. And that's a finding.
120

Now we have to find out, because you can't tell from 

the CATI. He was a laborer. He was a laborer. Now a 

person that's called a laborer, in my mind, well, that 

means there's a real good chance he might have 

been in that hole, but I can't say that for certain. So, 

in a practical sense, you have to make that judgment. 

Someone has to make that judgment.

And if you say that you are going to give him that 

dose, fine. But you may conclude that, no, we're not 

going to give him the in-the-hole dose. Then, you 

know what he gets? He just gets that other dose from 

the residual activity on the surfaces, because he was 

not in the hole.

Mr. Katz: All right. Go ahead, Josie.

Chair Beach: Yes. No, I was going to say, let's get 

the petitioner --

Mr. Katz: So, if we have the petitioner on the line, 

and if you want to comment or if you want to ask 

questions, this would be a good time to do it.

Mr. Elliott: Okay. Sure. This is Mike Elliott, one of the 

petitioners. Can everybody hear me?

Mr. Katz: Yes, we can hear you really clear. Thank 

you, Mike.

Mr. Elliott: Great. Thank you.

First, I just want to say, I also participated in the 

worker interviews back in October. So, I got to meet 

Peter Darnell, John Mauro -- I believe Dr. Mauro?

Dr. Mauro: Yes.

Mr. Elliott: Rose Gogliotti, and, of course, Pat 

McCloskey in person. And I just have to say how 

impressed I was with their professionalism, the 

thoroughness of their interviews, their patience, their 

willingness to really describe things to us that to a 

layperson can be very confusing. So, I just cannot 

say enough good things. I went away from that 
121

interview feeling really good, knowing that we had 

such talented people who were really approaching 

this very objectively. So, again, thank you so much.

As to what I was listening to today, it's hard to really 

summarize everything that I heard. There were 

several places where I thought, if I had the 

opportunity, I might offer a clarifying statement. And 

certainly, I will attempt to do that, and I assume 

there will be some kind of opportunity to submit 

written comments. So, I'll be sure to do that.

But I come away -- and I have to go back to what I 

seem to be consistently hearing from Dr. Mauro from 

the very start of this wonderful, if not somewhat 

complex, presentation that he delivered today. 

Obviously, a tremendous amount of work. I am really 

impressed with the effort that went into this.

But, you know, the things that I keep hearing 

consistently over and over again as he is talking is 

that, you know, there's really very little data 

available during the residual period. Yes, he does 

point out some of the data that he feels they are able 

to work with, and through some very complex 

modeling and mental gymnastics, they come up with 

ways of applying that data.

He used the statement that it was a really tough 

judgment whether or not the data was sufficient and 

whether they had sufficient understanding of the 

scenarios. He said it was kind of a stretch. And all 

throughout this entire presentation, I was hearing 

about the assumptions and the uncertainties and how 

they're starting to get around those.

And just this one example concerns the subsurface 

drain lines. I feel entirely responsible for the basis of 

his entire argument there. I was the one who stated 

the conditions that we found in the subsurface drains 

in 1994 probably reflected the conditions during the 

entire residual period. But I have to say, in 

retrospect, listening to the questions that Ms. Beach 

was asking, I think I would pause now if you would 
122

ask me again, you know, what do I really know. I had 

no definitive information on which to base that 

opinion. All I know is that those were the levels we 

measured in 1994. So, in retrospect, I wish that Ms. 

Beach had been participating in interviews because I 

think the kind of questions she asked would have 

caused me pause, and I might have been maybe a 

little less certain about making, stating the opinions 

that I did. And that's all they are; they're my 

opinions. Certainly, I don't have any data to back 

them up.

So, I have to say that, although I greatly respect the 

work that SC&A has done, at the moment I really 

don't have a lot of confidence in their final conclusion. 

And I think that, in light of the EEOICPA guiding 

principles to be claimant-favorable when there is 

uncertainty in the science or the measurements, I 

still believe this petition meets all the qualifications 

to be recognized as a Special Exposure Cohort.

I just hope the Work Group will keep that in mind 

because it's easy to get lost in the weeds. Really, 

listening to you guys today, it seems really easy to 

get lost in the weeds. And I just hope we keep the 

big picture in light here.

And I feel confident, listening to the Chairperson, Ms. 

Beach, I feel very confident that she is in with that. 

So, I feel very good about the whole process.

Mr. Katz: Michael, this is Ted.

Just let me tell you, with respect to what you started 

out with, there will be, as you know, I think, a 

transcript of this Work Group meeting. Just 

recognizing what you were saying about a lot of 

material was covered and you wished you had been 

able to jump in, or whatever, and that you would like 

possibly to submit written comments, you certainly 

can do that. The transcript will be out in maybe 45 

days or so. It will be available to the public. It will be 

posted on our website. And you can go through that 

transcript and, by all means, submit written 
123

comments on any part of the discussion that you 

would like to comment on. And that's a much easier 

way to do it than to rely on your own personal notes, 

or whatever, and worry about what you might have 

missed.

So, to submit written comments, it's no problem. You 

just submit them to Pete or Josh Kinman, to the 

NIOSH website thing. "These are additional 

comments based on the Work Group meeting." You 

know, give it some title like that. And then, that will 

go and all the Work Group members will have your 

comments, too. Okay?

Mr. Elliott: Great. Thank you.

Mr. Katz: You're welcome.

Chair Beach: Are there any other --

Mr. Katz: And thank you for those comments, Mike.

Do any of the other folks that are associated with this 

site have comments or questions they want to add to 

the meeting?

Mr. Lorenzen: This is William Lorenzen. I actually was 

part of the interview process. I also was a contractor 

to CPS, who did a lot of the remediation work. And I 

think I've forwarded some of the documented 

testimony that was done back in Mansfield last fall, 

which I appreciated the opportunity to comment on.

I listened into as much as I could today. I didn't 

realize this was going to be as long a process as it 

was. So, I did have to step in and out.

But, to reiterate what Mike said, there's a lot of 

speculation in the discussion today and I heard lots 

of statements like "common sense" and "everything 

my bones tell me." I would just get you guys to focus 

back on the fact that it should be claimant-friendly, 

and if you don't know, you don't know. But 

speculation should not be talked about when workers' 

livelihood is at stake here. So, I think that we should 
124

be very careful how you deal with this residual 

period.

It still draws me back to my original question I think 

we talked about during the interview process, which 

is, if the earlier claim was given because of thorium, 

I still don't know why we don't have a claim now 

because there's still thorium onsite. And we don't 

know anything about the thorium information, and I 

still find that a little concerning.

I do have a number of pages worth of notes here I've 

taken over the time I did listen. I'm probably better 

off submitting it in writing rather than go through it 

all with you. But just a couple of quick points.

The wipe data you guys are using, you've got to be 

very careful, in my opinion. I am a health physicist. 

I've working in the uranium industry for a long time. 

Wipe data is not activity data in the sense that you 

can't directly relate that to anything. It's just an 

indicator of the presence of contamination. And to 

take actual data and, then, convert it to activity, and 

trying to use it as a justification for resuspension, I 

think you have to be very careful about how that is 

done. So, that's one issue.

The other is, the residual period, there is no data. 

There's no airborne data. There's no badge data. 

There's no survey data. There's no subsurface 

sampling data that represents this Class of workers.

We keep talking about the levels that were found on 

the pipe being some magical 50,000 picocuries. That 

was not the highest level. I have quoted that in some 

of my testimony. We didn't measure the highest 

levels in the pipe because we knew they were hot. 

There was no need to measure. The levels, I'm sure, 

were much higher than that. So, again, to try to focus 

on one value to be an upper bound, and then, draw 

the 95th percentile, I think is really not following 

good science, in my opinion.

Again, in closing, I just want to say I'll submit some 
125

of these in writing. I appreciate what this group is 

doing, but, to quote Mike here, I think you ought to 

be really careful about some of the assumptions and 

the approaches you take when it comes to workers 

and their lives and their livelihoods.

I appreciate the opportunity to comment.

Mr. Katz: Thank you. Thank you, William.

Is there another member of the public? Comments?

(No response.)

Okay. Not hearing any --

And just on a matter of policy, because this gets 

confused a lot by people in the public about claimantfavorable or friendly, whatever, that whole 

philosophy is tied to making sure that your doses are 

conservative. So, we need to be certain, when we 

have uncertainty, that we err on the side of the most 

conservative dose. That's what that applies to. It 

really doesn't apply to granting SECs or not granting 

SECs, based on claimant favorability. So, really, it's 

completely tied to that, making conservative dose 

estimates.

Now, certainly, for SEC matters, we either to have a 

rock to stand on or we don't. And that's sort of the 

bottom line with SEC matters. But it's supposed to be 

an objective business. And the uncertainty, if we 

can't deal with the uncertainty, we don't have a rock 

to stand on. So, it's a little different just nuance, but 

it gets confused often by folks in the public.

Chair Beach: Okay.

Mr. Katz: Josie?

Chair Beach: So, any more? Did we catch everything 

that you wanted to on your metals and controls? Or 

is there any questions that need to be exchanged 

while we're in the meeting?
126

Dr. Neton: I think SC&A hasn't had a chance to look 

at that yet.

Chair Beach: Yes, that's why I'm asking if they --

Dr. Neton: So, I think it's really not worth getting 

into.

Chair Beach: I know they looked at it, but was there 

any questions you needed clarified, so we don't have

to do a technical call? Or that's kind of where I'm 

going with that. I was asking SC&A. I know you --

Dr. Mauro: I guess our expectation was that you've 

issued a White Paper. We had a chance to read it. We 

did not review the sources. In fact, we suspect that 

you may have data that we don't have when you put 

that out, but I'm not sure.

Ms. Gogliotti: John?

Dr. Mauro: Yes? Yes, Rose, yes?

Ms. Gogliotti: It kind of references what they gave 

me, because I had requested the raw data. It did 

include the FRD number references.

Dr. Mauro: Yes.

Ms. Gogliotti: And I have gone through just briefly; I 

didn't have enough time to dig really into the level 

that I believe would be sufficient.

But, in going through their data, I did find one small 

coding error. Pat looked at it and agreed with me. He 

already corrected it. It modestly reduced the dose 

outside, but nothing substantial to the modeling.

Mr. McCloskey: Do you have access to all the 

documents, all the references, Rose?

Ms. Gogliotti: I believe so, if they're all FRDs.

Mr. Katz: They are.

Dr. Mauro: So, there were none you added? In other 
127

words, we put our report out in February. Did you 

folks collect -- I know there was a lot of data, like 

Appendix A to that report that had some additional 

information.

Mr. McCloskey: I'll talk to that. Yes, you guys were 

looking for that Appendix A --

Dr. Mauro: Yes, yes, yes.

Mr. McCloskey: -- to CPS's remediations in '94 --

Dr. Mauro: Yes.

Mr. McCloskey: -- and '93.

Dr. Anigstein: This is Bob Anigstein.

I reviewed the CPS data that we have worked with in 

the White Paper. There were two new reports, and I 

was able to download them. So, I believe, John, that 

we do have everything that --

Dr. Mauro: We do. We do. We do. Okay, good.

Mr. Katz: We do. We do. He's saying he's reviewed 

them.

Dr. Mauro: Okay.

Mr. Katz: We did.

Dr. Mauro: Well, where I was headed was, that's 

important because that means that there's nothing 

that's new here in terms of data. Because, 

remember, it's the data that is the rock we stand on, 

and how we use it, and how representative it is for 

our objectives. Since we have all the data, we're 

good.

Now a question for you folks is, would you like us to 

write something that responds to what's in the BRS, 

our thoughts regarding your work? Because we read 

it, but we didn't check the numbers like we normally 

do, but --
128

Chair Beach: Well, that would be the normal 

exchange.

Dr. Mauro: Yes, but do you want to wait until you 

issue a revision? Is that it?

Dr. Neton: No.

Chair Beach: No.

Dr. Neton: We were hoping that, given that we 

recognize this subsurface model seemed to be used 

for the biggest issue, we were hoping to get some 

resolution of that, and we could drop that right into 

the revision, but rather than issue repetitive revisions 

to the ER subsurface model.

Mr. Katz: Yes, I think the path forward is we have a 

matrix now.

Dr. Neton: Updated -- 

Mr. Katz: And now that we've had this meeting, it will 

get updated based on the discussions of this meeting. 

And then, once you have that -- I think you should 

wait on that matrix from Pat before you, then, go and 

more deeply respond to the White Paper -- 

Chair Beach: Okay.

Mr. Katz: -- and the issues that have been raised 

today.

Chair Beach: Right. And then, the Work Group needs 

to weigh-in on the SEC issue as well, because we are 

not necessarily all in agreement that there's not an 

unusual circumstance or that you've proven that you 

have all the data and it's adequate. So, the Work 

Group needs to, I guess -- 

Mr. Katz: But you need to wait until the -- 

Dr. Neton: Well, no, there are additional comments 

here that at least Josie had -- 

Mr. Katz: Right.
129

Dr. Neton: -- outside of these general issues. And it 

would be good if they got put on paper somewhere.

Mr. Katz: Well, those should be ending up in the 

matrix. That's part of what should be finding its way 

into the matrix at this point. We have the matrix to 

cover not just SC&A's findings, and so on, but any 

issues that get raised here in the meeting, are part 

of the issue. Right?

Dr. Neton: That's true, but they weren't issued as 

matrix items.

Mr. Katz: No, no, I know. Of course.

Dr. Neton: Somehow they just crystalized.

Mr. Katz: I'm just saying, normally, when we update 

a matrix, we add in whatever happened during the 

Work Group meeting.

Dr. Neton: Who's going to add in the Board's new

comments?

Mr. Katz: Well, Pat, I mean Pat can take the 

beginning and start, and he can --

Mr. McCloskey: Yes, I'll need help.

Mr. Katz: Sure.

Mr. McCloskey: I mean, I don't know that I have all 

the action items that we've identified today.

Chair Beach: We haven't really identified any in here. 

I was just throwing stuff in.

Mr. McCloskey: Well, no, but they're there --

Chair Beach: Yes.

Mr. McCloskey: I mean, the contamination of the 

rafters, representatives of site data, you know, all 

those kinds of things that were brought in the panel 

discussion.
130

Mr. Katz: So, Pat --

Participant: Can I make a suggestion? Writing that 

stuff down -- Rose Gogliotti is already doing the BRS 

data input.

Chair Beach: Oh, good.

Participant: Which is where this would go.

Chair Beach: Okay.

Participant: So, why doesn't Rose take care of that?

Dr. Neton: Well, before it gets put in the BRS, we 

ought to circulate it to make sure we all agree.

Participant: Yes. Yes, of course.

Mr. Katz: So, again, we have Pat drafting a matrix. 

You can cover what you can cover. Send it to SC&A 

and the Work Group. We'll all have it. And they can 

add in what's missing.

Dr. Mauro: What I think is important is that Josie 

really hit some buttons that we didn't address. One, 

the rafters, that's important. We've got to have 

something smart to say on whether it can be 

reconstructed. There are workers up there, and you 

create, you identify --

Mr. Katz: That's part of the matrix.

Dr. Mauro: Okay. It's in there. Okay. Then, we can 

dig it up.

Chair Beach: It will be. It needs to be.

Dr. Mauro: It will be.

Mr. Katz: Please, I said, Pat will draft of matrix.

Dr. Mauro: Okay.

Mr. Katz: You will receive it.

Dr. Mauro: Good.
131

Mr. Katz: Josie and the group will receive it.

Dr. Mauro: Well, good.

Mr. Katz: If you heard things, you can put them in, 

whether you said them or whether Josie said them.

And, Josie and the Work Group Members, at the end, 

can look at it and say, did this cover everything? And 

if it didn't, the Work Group members can add to it.

So, at the end of the day, the matrix will have all the 

issues that there are to resolve, yes. And we've done 

that with other Work Groups.

Dr. Mauro: Okay.

Mr. Katz: It's not new.

Mr. McCloskey: I fully expect that you guys will be 

adding to this.

Mr. Katz: Yes, that's fine. Don't feel like you have to 

get a perfect -- you're just getting the ball rolling.

Mr. McCloskey: No problem. I don't mind.

Mr. Katz: But, I mean, stuff that you know and using 

your head, put it in, regardless of where it came 

from.

(Laughter.)

Member Kotelchuck: When is the SC&A report on 

the --

Mr. Katz: Relevant to this review.

Member Kotelchuck: I mean, we're talking about the 

matrix.

Mr. Katz: Yes.

Member Kotelchuck: Just to understand the process, 

what about SC&A's comments about the White Paper 

that's been --
132

Mr. Katz: So, they were going to wait until we have 

the complete matrix.

Member Kotelchuck: How to eliminate things out?

Mr. Katz: Wait until we have a complete matrix; 

everyone is satisfied this covers everything that's 

been discussed. And then, SC&A will go ahead with 

its response, knowing what's in the matrix, too, 

because that will be relevant.

Mr. McCloskey: That White Paper is in the matrix 

already.

Mr. Katz: Because when you do a paper, John, I 

mean, you don't need to just respond to that; you'll 

respond to everything with what you have to 

combine.

Dr. Mauro: Yes. Yes, it's a good plan.

Mr. Katz: Yes. That way, it will be comprehensive. It 

will be one report from SC&A, and then, you guys can 

go from there at another Work Group meeting.

Chair Beach: Well, and this is a bit unusual because, 

normally, SC&A puts out the matrix. And so, this 

whole process has been a little different.

Mr. Katz: It's been done. Different Work Groups have 

done it different ways.

Chair Beach: It's a little different than what I'm --

yes. I'm not saying it's wrong. It's just different.

Mr. Katz: I'm just saying, different Work Groups have 

had either SC&A -- it depends on who gets the ball 

rolling with a matrix --

Chair Beach: Right.

Mr. Katz: -- who puts it out first. But it doesn't 

matter.

Member Kotelchuck: And after the process is 

completed, we still have to meet --
133

Mr. Katz: Of course. While they've got a Work Group 

meeting --

Member Kotelchuck: -- at a Work Group meeting to 

decide --

Mr. Katz: Yes.

Chair Beach: Right.

Member Kotelchuck: -- on the SEC from our 

perspective, based on what the two groups --

Mr. Katz: Yes.

Chair Beach: It sounds like we'll have some notes 

from the petitioners. And is it appropriate -- and I'm 

talking to the petitioners, too, but I'm asking Ted --

if they want to get a hold of me as the Chairperson, 

is that --

Mr. Katz: They will send their written comments into 

the portal. And everyone will get it. It will get 

circulated to everybody.

Chair Beach: Okay.

Mr. Katz: The whole Work Group will get the 

petitioners' comments. And for that matter, the 

workers that were listening, if they want to send in 

more notes, too, about their thoughts, they're also 

welcome.

Chair Beach: Okay.

Mr. Katz: Yes.

Dr. Anigstein: This is Bob Anigstein.

In the interim, it would be useful to have the 

spreadsheets that are referred to in the White Paper.

Ms. Gogliotti: I have those.

Mr. McCloskey: He wants the film badge spreadsheet, 

Rose, probably.
134

Ms. Gogliotti: Oh, I'm sorry. 

Mr. McCloskey: Right, Robert? You want the film 

badge spreadsheet?

Dr. Anigstein: No, not the film badge spreadsheet; 

the other -- there are three spreadsheets that are 

referred to, for soil samples and other 

measurements. There are three phases that you refer 

to. There's spreadsheet calculations, the results, but 

not the spreadsheets.

Mr. McCloskey: There's only two spreadsheets we 

have for the White Paper, and Rose has the soil 

contamination one. And there's a film badge one.

Dr. Anigstein: The film badge spreadsheet I have, but 

not the -- maybe you sent them and I didn't get it.

Ms. Gogliotti: I can send it to you, Bob. I have the 

other one.

Chair Beach: Okay.

Ms. Gogliotti: And it's actually been updated since the 

initial spreadsheet was sent.

Chair Beach: Okay. And then, I'd like to make a 

comment. From here forward, if something goes out, 

can the Work Group be copied on all things?

Mr. Katz: Always.

Chair Beach: But we don't always get copies. Some 

of these things I don't think we got. I'm just saying 

for the future things.

Mr. Katz: The Work Group should always be getting 

whatever is going over to SC&A certainly. I mean, I 

don't know if that's happened, but I haven't seen 

anything drop. But that should always happen.

The other thing I just thought about, too, is, since 

NIOSH has a couple items they want to speak to, it's 

good to get those in before SC&A finishes its review 

of everything that's been discussed today, because, 
135

then, SC&A can consider your arguments on other 

matters.

Member Kotelchuck: Your comment, though, about 

everything should be sent, I have to admit, from the 

Dose Reconstruction Subcommittee, we have been 

talking to the different groups and saying, you should 

have made technical calls and speak to each other 

before you come to the Committee. So, it is a 

different --

Mr. Katz: That's different. Those Work Groups 

haven't been meeting on those issues, those other 

Work Groups. They haven't met on those issues, 

which is why nothing -- they haven't gotten any 

communications.

Chair Beach: Well, those technical calls should come 

to the entire Work Group because Work Group 

members do like to sit in and listen to those technical 

calls.

Member Kotelchuck: As opposed to the DR 

Subcommittee.

Chair Beach: In addition to the DR Subcommittee.

Mr. Katz: I'm lost on what you guys are talking about.

Member Kotelchuck: Well, the Dose Reconstruction 

Subcommittee has several times told SC&A and 

NIOSH, "Please don't bring that issue to us. Talk 

together. We're" -- I wouldn't say "wasting time," but 

"We're not efficiently using our time."

So, I just wanted to reflect that. It's a different kind 

of request here, that, no, we should get everything.

Mr. Katz: Oh, yes, that's different. Okay.

Member Kotelchuck: Is it because we're a Work 

Group?

Mr. Katz: Well, okay, with technical calls -- this is 

different. We're talking about stuff that's all coming 
136

to the Work Group. Now you're talking about 

technical calls. When we have technical calls, we 

have a memo to document what happened in the 

technical call, and that always goes to the Work 

Group or whatever group --

Dr. Neton: and that other group is invited to 

participate.

Mr. Katz: They're invited to listen in, and then, they 

receive that memo that summarizes what happened 

in the technical call.

Member Kotelchuck: Okay.

Mr. Katz: We always do that, yes.

Dr. Mauro: A thought just came from that question. 

I can't help myself.

So, when we're in DR Subcommittee meeting and 

we're going over a case, okay, and there are a 

number of findings, some of those findings are very 

specific to that person and how they did the dose 

reconstruction, and we have a concern with that.

Mr. Katz: Uh-hum.

Dr. Mauro: But, more often than not, the concern has 

to do more with the Site Profile or some other generic 

approach. We should not be discussing those matters 

-- see, in other words, my understanding is, during a 

DR meeting, we will talk about the specific dose 

reconstruction for that worker and not any of the 

generic assumptions that come from an OTIB or 

come from --

Mr. Katz: That's not true.

Dr. Mauro: Okay.

Mr. Katz: We do. We talk about them all the time.

Dr. Mauro: Because I know that sometimes we have 

found ourselves engaged in a conversation where 

we're cut off.
137

Mr. Katz: No. No.

Dr. Neton: Sometimes those get transferred to the 

Procedures group.

Mr. Katz: We have issues where there are concerns, 

findings in the DR review that, then, get referred to 

a Work Group because it's the Work Group is dealing 

on the Site Profile. That's different. But those go in 

the DR report -- 

Dr. Mauro: Okay.

Mr. Katz: -- those issues, whether they are a Site 

Profile or whether they're just specific to a quality 

assurance problem, or whatever. They go in the DR 

report.

Yes, we do, we absolutely do refer matters to Work 

Groups to resolve because they're either under an 

SEC or under a Site Profile review, and that's the 

place where the expertise is the site. So, we do do 

that. We do that quite often. In fact, there's probably 

five or six dose reconstruction cases that are sitting 

with different Work Groups because those Work 

Groups have to resolve those final matters. We just 

sort of put them on the shelf there, yes, and that's 

what I was referring to when I was saying those Work 

Groups haven't met yet on those issues, because 

they're not going to meet just for one dose 

reconstruction case. But, anyway -- 

Chair Beach: Okay.

Mr. Katz: Anything else, Josie?

Chair Beach: Henry, do you have anything to add or 

comments, questions?

(No response.)

Mr. Katz: Henry, are you still with us?

Member Kotelchuck: It takes a moment to get on.

Mr. Katz: Yes, yes, sometimes you're on. You don't 
138

know or you think you're on mute and you're not, and 

you mute yourself when you try to talk.

Henry, are you still there?

(No response.)

Okay. He may not be there anymore.

Chair Beach: And then -- 

Member Anderson: I'm here.

Member Kotelchuck: Oh, there he is. There he is.

Mr. Katz: Okay. So, Josie was just asking, do you 

have anything to add before we wrap up?

Member Anderson: Oh, I do not.

Mr. Katz: Okay. Thanks.

Chair Beach: Okay. And then, timeline on the work 

and scheduling another meeting. Is there any -- 

Mr. Katz: I think it's too soon to even talk about 

scheduling.

Chair Beach: That's why I'm asking.

Mr. Katz: Good. Well, we can come up with a timeline 

once we've wrapped our heads around what's been 

raised today, right, instead of right now, yes.

Dr. Neton: I will say, it doesn't like we're going to be 

ready to discuss this at the August meeting.

Mr. Katz: That may not be, right.

Dr. Neton: It's unlikely at this point, I think.

Chair Beach: It still would be nice to be close, so we 

-- 

Dr. Neton: Yes. No, I think we might be close, but to 

get a fully revised, polished ER out in time for August 

is, given that there's back-and-forth going to happen 
139

and at least one more Work Group meeting probably 

happens --

Chair Beach: Yes, yes.

Mr. Katz: Yes, and we also want to give the petitioner 

time to submit their written comments, and so on.

Dr. Neton: We'll work as hard as we can towards it, 

but I don't think we'll make the August meeting.

Chair Beach: Yes.

Member Kotelchuck: Good.

Mr. Katz: Josie?

Chair Beach: I had one nitpicky thing on here, but I'll 

-- 

Mr. Katz: Okay, you could share that.

Chair Beach: -- I'll bring it up to John. Anyway, it's 

on John's paper. But it's nothing.

Mr. Katz: Folks on the phone, staff, and members of 

public, petitioner, thank you all for participating.

And we are now adjourned.

Adjourn

(Whereupon, the above-entitled matter went off the 

record at 12:54 p.m.)