1

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH 

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ADVISORY BOARD ON RADIATION AND

WORKER HEALTH 

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PACIFIC PROVING GROUNDS WORK GROUP

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FRIDAY

JANUARY 16, 2015

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The Work Group convened via 

teleconference at 1:30 p.m., Eastern Standard 

Time, James E. Lockey, Chairman, presiding.

PRESENT:

JAMES E. LOCKEY, Chairman

HENRY A. ANDERSON, Member

LORETTA R. VALERIO, Member

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ALSO PRESENT:

TED KATZ, Designated Federal Official

BOB BARTON, SC&A

HANS BEHLING, SC&A

JOYCE FRANCIS, DCAS

DeKEELY HARTSFIELD, HHS

JOHN MAURO, SC&A

JIM NETON, DCAS

MARK ROLFES, DCAS

GENE ROLLINS, ORAU Team

MATTHEW SMITH, ORAU Team

JOHN STIVER, SC&A

TABLE OF CONTENTS

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Welcome and Introductions ..................... 4

Discussion:

Overview of SC&A Site Profile............ 6

Finding Number 1........................ 22

Observation Number 1.................... 25

Finding Number 2........................ 27

Finding Number 3........................ 44

Finding Number 4........................ 60

Finding Number 5........................ 63

Finding Number 6........................ 72

Finding Number 7........................ 79

Finding Number 8........................ 84

Finding Number 9........................ 96

Actions/Path Forward ........................ 107

Adjourn

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

2 1:34 p.m.

3 MR. KATZ: This is the Advisory Board 

4 on Radiation Worker Health, the Pacific Proving 

5 Ground Work Group.

6 We are meeting over a Site Profile 

7 Review that's been done by SC&A and the Work Group's 

8 taking that up.

9 The materials that we're discussing 

10 today are on the NIOSH website. If you go to the 

11 NIOSH website and you go to the Board section for 

12 meetings, today's date, you'll see all the papers 

13 that will be discussed here.

14 There's a matrix, there's the actual 

15 review from SC&A and both of those are useful to 

16 follow along with the discussion as well as the 

17 Agenda which is very simple.

18 MEMBER ANDERSON: Hi, it's Andy. I'm 

19 on now.

20 MR. KATZ: Oh, great. And so now I've 

21 heard from all my Board Members, they're all on but 

22 we need to speak to conflict of interest, so let's 

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1 just go down the roster with the Board and address 

2 whether you have a conflict with site.

3 (Roll call.)

4

5 Okay then, that takes care of matters. 

6 Everybody, while you're listening, please keep 

7 your phones on mute just to help the audio quality 

8 and, Jim, it's your meeting.

9 CHAIRMAN LOCKEY: Why don't we get 

10 started then?

11 Hans, are you going to present the SC&A 

12 overview?

13 DR. BEHLING: Yes, I am.

14 CHAIRMAN LOCKEY: Are we ready to get 

15 started on that?

16 DR. BEHLING: Yes, unless there's any 

17 other issue that needs to be resolved before we 

18 start.

19 I can only say that we do have a total 

20 of hours for completing this conference call and 

21 are there any scheduled breaks that we're looking 

22 to introduce somewhere in between the four hours?

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1 MR. KATZ: Well, Hans, I think we're 

2 hoping not to go for four hours, but I mean we'll 

3 take breaks as people need comfort breaks.

4 DR. BEHLING: Okay.

5 MR. KATZ: Yes.

6 DR. BEHLING: Okay, let me start out by 

7 saying that this is -- since this is the first 

8 meeting over teleconference for the PPG Work Group, 

9 I want to take a few minutes to discuss a few 

10 historical pieces of information.

11 And first of all, NIOSH issued the 

12 Summary Site Profile for the Pacific Proving 

13 Grounds back in August of 2006. So, that's a 

14 number of years ago.

15 SC&A was asked to review this document 

16 in 2013 and issued its draft report in November 

17 2013. Our review of the Site Profile identified 

18 a total of nine findings and one observation which 

19 is, at this point, the focus of my presentation here 

20 that's coming.

21 And in order to really fully understand 

22 the findings that we're about to discuss, it's 

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1 important to address some of the conditions under 

2 which personnel at the PPG were exposed to 

3 radiation and that not only is different but very 

4 unique from all the other DOE and AWE facilities 

5 that are part of the Energy Employee Compensation 

6 program.

7 And in Section 3 of the SC&A report 

8 which is on page 14, and I'm going to ask John Stiver 

9 to perhaps then go to the page that I identify so 

10 that we can all look at some of the information that 

11 I'm about to present.

12 And so, page 12 is the beginning of 

13 Section 3.

14 DR. MAURO: Ted, I assume that we're 

15 not on Live Meeting, so we just should do this 

16 independently on our own.

17 MR. KATZ: We have Live Meeting, but 

18 you're welcome to do this. I mean you have the 

19 documents.

20 DR. MAURO: I do.

21 MR. KATZ: So, you can do it either way.

22 DR. MAURO: Okay.

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1 MR. KATZ: I'll forward you, if you 

2 don't have that, I'll forward you the address for 

3 the Live Meeting.

4 DR. MAURO: Oh, I have --

5 MR. STIVER: John, I did send you the 

6 link earlier today, so it should be on both your 

7 SC&A and NIOSH email accounts.

8 DR. MAURO: Yes, the only problem I ran 

9 into, it requires some kind of Java update which 

10 I don't have. But I'm fine, I'm following it on 

11 the --

12 MR. KATZ: Okay.

13 DR. MAURO: Yes, I'm fine.

14 MR. KATZ: Thanks, John. Go ahead, 

15 Hans.

16 DR. BEHLING: Okay. John, can you 

17 scroll -- I'm on page 12, but you're at the bottom 

18 of page 12. Okay?

19 MR. STIVER: Okay, hang on just a 

20 second. You want page 13 or --

21 DR. BEHLING: No, no, you're on page 12 

22 and on the upper right hand side, you'll see the 

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1 page 12, the individual --

2 MR. STIVER: All right.

3 DR. BEHLING: Anyway, I want to briefly 

4 discuss some of the comparisons because there's 

5 really -- there's only one comparison to any of the 

6 other facilities that we have been dealing with in 

7 the past and that's the Nevada Test Site which also 

8 tested nuclear weapons.

9 But, there are some great differences 

10 between those two sites and then I'm about to show 

11 you just what some of those differences are that 

12 I've identified.

13 Between 1946 and 1962, the US AEC 

14 conducted a total of 105 atmospheric and underwater 

15 nuclear weapons tests at several locations which 

16 I identified in the top of Table 3-1. They involve 

17 Bikini Atoll and Enewetak Atoll, both of those 

18 Atolls are part of the Marshall Islands.

19 Also, the third area was Christmas 

20 Island and Johnson Atoll and there's a couple of 

21 other tests that were done in the middle of the 

22 ocean.

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1 And important to note when you look at 

2 those numbers that follow, not only just the number 

3 of tests at each of those sites, but the explosive 

4 yield. And below that, you have minimum, maximum, 

5 mean and median and total.

6 And then a point to note is that the 

7 total yields for, for instance, at Bikini Atoll, 

8 the total yield of nuclear weapons that were tested 

9 there. There were 24 tests with 763,838 kilotons 

10 of explosive yield

11 And you can look down the bottom of the 

12 other ones and Enewetak, that was the second most, 

13 31,653 and so forth.

14 And what it really -- if you look at them 

15 in Table 3, you see that for the 105 nuclear tests 

16 in the PPG, they had the equivalent of 151.5 

17 megatons of TNT. And again, if you segregate them 

18 out between Bikini Atoll and Enewetak Atoll and the 

19 Marshall Islands, there were 108.5 megatons of 

20 explosive yield tested there.

21 And when you then compare that to what 

22 was done at the Nevada Test Site which is defined 

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1 in Table 3-2 below, you will see obviously that even 

2 though the U.S. tested quite a number of weapons, 

3 107 at the test site, their combined explosive 

4 yield only represented 1.3 megatons. And compare 

5 that to the 155.6 megatons yield, understand why 

6 these tests were done not in the continental United 

7 States, but somewhere where it was safe to do so 

8 and that turned out to be the Pacific Proving 

9 Grounds.

10 When you go back up to Table 3-1 above, 

11 you'll see that the maximum weapons that were 

12 tested, the yields were two nuclear devices that 

13 had the yield of 15 megatons and that was the Bravo 

14 test that was done in March of 1954 and the Mike 

15 test that was done earlier in '52.

16 Those two tests, like I said, when you 

17 look at the yields of those tests for the Bravo 

18 test, it's 15 megatons. That's a thousand times 

19 greater than the explosive yield of the two bombs 

20 that were dropped and devastated Hiroshima and 

21 Nagasaki at 15 kilotons.

22 So, it gives you an understanding of 

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1 just how much of the differences exist between the 

2 nuclear tests that were conducted at the Nevada 

3 Test Site versus those that were conducted at the 

4 Pacific Proving Grounds.

5 One of the other things that I wanted 

6 to point out is the fact that when you look at the 

7 nuclear tests that were done, they were not equally 

8 spaced. Early on with the very first few tests, 

9 they were done at significant intervals.

10 And also, in addition to that, they were 

11 -- explosive yields were very, very low compared 

12 to the what was to come, especially with the 

13 beginning of the Castle series where we had thermal 

14 nuclear devices in the megaton range.

15 John, can you go to the next page? Page 

16 14 -- 13 I mean, 13.

17 And there, I'll just briefly make 

18 mention of some of the things that happened and why 

19 some of these things became a very significant 

20 problem for the rad-safe personnel that were 

21 expected to protect the workers and safeguard them 

22 from radiation exposures.

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1 And one of the things you realize is 

2 that the first series of tests, there was enough 

3 spacing in between to provide at least some 

4 adequacy in presenting some kind of program for 

5 safeguarding personnel and monitoring them.

6 And that became increasingly more 

7 difficult and so, when you go into the next few 

8 years, we had instances where there were two 

9 nuclear tests done on the same day. There were six 

10 days where two tests were done simultaneously.

11 And what it really comes down to is that 

12 both the frequency and the severity of the nuclear 

13 tests posed serious constraints on the rad-safe 

14 personnel who were there to protect the workers 

15 from radiation exposure.

16 And when you look at their program, they 

17 worked under the worst of conditions that one can 

18 imagine for a number of reasons, whether it was the 

19 remote facilities that they were working at out in 

20 the middle of the Pacific Ocean -- when we're 

21 talking about the Marshall Islands, they are 2,300 

22 miles southeast of Honolulu and 1,600 miles removed 

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1 from Guam.

2 And this was, I would say, a very 

3 difficult thing to get personnel in there and for 

4 many of these tests, for instance, in the case of 

5 Operation Crossroads which was the first series 

6 that involved Able and Baker, there were a total 

7 of 42,000 people that had to be obviously guarded 

8 against exposures.

9 And, therefore, you had large numbers 

10 of people, you had a remote location for this to 

11 take place, you had no infrastructure within the 

12 Marshall Islands or the other areas where they were 

13 tested.

14 And so, one has to really appreciate 

15 what the difficulties that existed for rad-safe to 

16 protect people.

17 So, in the last statement when I -- and 

18 on the page where I said undoubtedly impact by 

19 unexpected events, limited resources and adverse 

20 operating conditions for rad-safe personnel who 

21 were obviously in charge of protecting the workers 

22 that included obviously private citizens as well 

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1 as military personnel.

2 So, with regard to that last statement, 

3 I just want to say that our findings that we are 

4 identifying today should by no means be viewed as 

5 a criticism of the effort by the rad-safe to protect 

6 personnel in the PPG but simply I want everyone to 

7 realize -- I want to acknowledge the difficulties 

8 that NIOSH faces in the reconstruction of credible 

9 doses on behalf of claimants.

10 So, this is really -- the objective here 

11 is to identify some of the difficulties that are 

12 being looked at in our findings that we want to 

13 discuss today.

14 Among the limitations that prevent us 

15 from a complete dose reconstruction at the PPG for 

16 workers was the issue that we do not have any kind 

17 of internal monitoring at the time of the PPG. And 

18 therefore, this inability to assign internal dose 

19 from inhalation, ingestion of fallout that 

20 personnel were exposed to, and that includes 

21 obviously, fission products as well as unfission

22 weapon-grade fuel, uranium, plutonium.

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1 And as a result of that inability to 

2 assess or by any means any potential internal 

3 exposure, it was acknowledged early on that the 

4 people at -- the workers exposed to it could not 

5 be adjusted for internal exposure and, therefore, 

6 an SEC was declared.

7 And that brings me up to Finding Number 

8 1. So, John, if you want to go to page 14, this 

9 is the Review of the Introduction PPG Site Profile 

10 and it shows that in Section 1 of the ORAU Site 

11 Profile for PPG, it describes that there was an SEC 

12 petition and that SEC petition obviously pertains 

13 to the fact that internal exposures could not be 

14 reconstructed.

15 And it identifies in the first 

16 paragraph that these inclusion of non-SEC cancers 

17 were based on 250 days of employment and that turned 

18 out to be an issue that was the source of our first 

19 finding.

20 And it's important to note, as I said, 

21 that the PPG Site Profile that NIOSH developed in 

22 2006 pre-dates any discussions that we had about 

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1 the issue of 250 workdays.

2 And as a result of that, we identified 

3 in the finding, even though we knew that there had 

4 already been an adjustment made in the 250 day 

5 criteria on behalf of the NTS. And that was 

6 clarified when we looked at our Bulletin No. 06-15 

7 that's summarized on the next page, 15.

8 What that bulletin by and large then 

9 allowed us to do is to say, okay, we don't need to 

10 have 250 days for non-presumptive cancers to be 

11 included if we can at least demonstrate that they 

12 were at least 83 days given the fact that when 

13 you're on site for 24 hours that really represents 

14 three 8-hour workdays so the 250 day criteria was 

15 in fact reduced down to 83 days.

16 But, the other thing that the Bulletin 

17 No. 06-15 states, and that's in the second -- the 

18 last paragraph on page 15, that by and large says 

19 that in determining the actual employment period, 

20 the CE must have clear and convincing evidence of 

21 a beginning date (hire) and end date (termination) 

22 of employment at the PPG.

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1 And it goes on further, where the 

2 evidence is not clear and convincing or consists 

3 only of film badge data, without the beginning date 

4 or the end date he must wait for the policy guidance 

5 before proceeding with the verification of covered 

6 SEC employment at the site.

7 Now, that poses obviously a problem for 

8 most of the people who were obviously at the PPG 

9 and who were military, that posed not a major 

10 problem. But it does pose problems for people who 

11 were non-military, who were civilians and who 

12 oftentimes worked for a private company and there, 

13 the employment dates are not necessarily 

14 available.

15 And so, it goes on in this particular 

16 bulletin, it says the National Office of DEEOIC 

17 continues to explore methods by which confirmation 

18 of employment can occur for workers alleging 

19 employment at the PPG.

20 And that gave rise to the next bulletin 

21 which is on -- cited on a summary of status site 

22 on page 16. And that's Bulletin No. 07-05.

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1 And it once again talks about what this 

2 problem concerns and then offers a solution and 

3 that solution was considered to be one that was 

4 viable for establishing employment dates in the 

5 sense that this involves dosimetry assignment.

6 And the bulletin states that the 

7 individual film badges were generally issued on one 

8 day, one week or one month, depending on potential 

9 exposure to the individual. And it goes on 

10 typically film badges records would include the 

11 issue date and the end date which can be used to 

12 account employment periods at the PPG.

13 Now, we will talk about later on what 

14 that really infers.

15 MR. KATZ: Excuse me, Hans, this is 

16 Ted.

17 I mean, I'm sorry to interrupt on this, 

18 but I had a lot of exchanges with SC&A about this 

19 topic. This is really a DOL issue. We've already 

20 agreed we're going to send a memo to DOL about 

21 issues related to how they administer this matter 

22 and our information related to that.

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1 But, it really is not a good use of the 

2 Work Group's time to be spending a lot of discussion 

3 about this matter. It's not related really to the 

4 Site Profile Review.

5 DR. BEHLING: Well, I realize that, 

6 Ted. I'm sorry. I wasn't going to spend any time. 

7 I just wanted to make mention of the fact that this 

8 issue that will be resolved separately involves 

9 mission badges and that's all I wanted to say.

10 MR. KATZ: Right.

11 DR. BEHLING: And the only thing I want 

12 to say is that mission badges do not represent the 

13 conventional form of dosimeters which are usually 

14 assigned to a person either on a monthly basis or 

15 quarterly basis or any other time.

16 And whenever a person is in an area 

17 where there's the potential for exposures, that 

18 badge as we know it today will in fact fully under 

19 -- provide a measure of not only the employment 

20 period but also the full duration of exposure.

21 And that's all I wanted to do here. 

22 MR. KATZ: Okay. Thanks.

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1 DR. BEHLING: And in contrast with that, 

2 I'll just add one more statement. This issue that 

3 where we just now addressed with the badges that 

4 are oftentimes referred to as mission badges, cease 

5 to be used in, let's say, this was May 25, 1956 that 

6 we introduced a new badging system which involved 

7 assigning any person who came on to the PPG site 

8 a dosimeter and that was continued to either be 

9 replaced or maintained by that person 24 hours a 

10 day and until he left.

11 So, starting with the Operation Redwing 

12 that commenced in 1956, that issue goes by the way. 

13 And I just wanted to bring that to everyone's 

14 attention.

15 So, Finding Number 1 is, again, 

16 restricted to the issue of changing the Site 

17 Profile for the PPG to address the revised time of 

18 83 days for inclusion in the SEC, as I mentioned, 

19 and the other issue, hopefully, will be addressed 

20 by the DOL at some later date.

21 MR. ROLFES: This is Mark Rolfes, from 

22 NIOSH. We agree that an update is needed to 

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1 reflect the 83, you know, days where an individual 

2 was on site for 24 hours a day.

3 CHAIRMAN LOCKEY: You're breaking up. 

4 I'm having a hard time hearing you.

5 MR. ROLFES: Okay. Is that any 

6 better?

7 CHAIRMAN LOCKEY: That's much better.

8 MR. ROLFES: Okay. We agree that the 

9 83 days needs to be incorporated into the Technical 

10 Basis Document for PPG and so if an individual 

11 worked for the day then spent the rest of his time 

12 on site for 24 hours a day, if he accumulated 83 

13 total days, that would count as 250 workdays and 

14 would meet the 250 workday requirement.

15 And we will update the TBD with that 

16 information.

17 DR. NETON: Yes, this is Jim. I agree 

18 we're going to do that but it really is just for 

19 background information only.

20 I mean as Ted suggested, we don't 

21 qualify workers for the SEC. We receive cases for 

22 dose reconstruction that are qualified already by 

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1 DOL. So, it really would just be for background 

2 clarification more than anything. I mean we would 

3 never use that number ourselves to qualify someone.

4 CHAIRMAN LOCKEY: And Ted, do we know 

5 when the DOL is going to respond to us?

6 MR. KATZ: Well, I have -- SC&A is going 

7 to send me a memo with just sort of full-fledged 

8 information and then I will copy the Work Group, 

9 send that memo to DOL and in recent experience, 

10 they've been pretty quick to address issues coming 

11 from us. So, I expect they'll respond pretty 

12 quickly.

13 CHAIRMAN LOCKEY: Okay. For issue 

14 number four then, we're going to wait -- it's

15 resolved in a separate area from DOL, is that 

16 correct?

17 MR. KATZ: I'm sorry, I'm not sure --

18 we're talking about issue one I thought just now.

19 CHAIRMAN LOCKEY: The Finding Number 

20 1, Section Number 4, Finding Number 1.

21 DR. KATZ: Right. So, the DOL issue 

22 anyway is not really the Work Group's issue. But 

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1 that I'll take care of independently and keep the 

2 Work Group in the look as to how DOL responds.

3 DR. NETON: Well, Number 1 has been 

4 resolved.

5 CHAIRMAN LOCKEY: Well, Number 1's 

6 been resolved then.

7 DR. NETON: Right.

8 CHAIRMAN LOCKEY: Okay, thank you.

9 DR. BEHLING: Okay, next we have a 

10 single Observation Number 1 and that's very easily 

11 resolved.

12 The observation really addresses the 

13 people that were hired on location and whether or 

14 not that they would be qualified for a potential 

15 exposure associated with medical x-rays.

16 And my comments were that there was a 

17 need for more definitive guidance based on the 

18 interim since 2006 when the Site Profile was 

19 written.

20 There have been changes to the issue of 

21 assigning x-ray doses to personnel where even if 

22 the x-ray existed but it wasn't done at an EEOICPA 

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1 facility that it was not granted.

2 So I raised that as an issue and I think 

3 NIOSH responded that they would cancel the 

4 ORAU-PROC-0061 criteria and introduce the 

5 OTIB-0079 which I believe is going to satisfy that 

6 particular observation.

7 MR. SMITH: That's correct.

8 CHAIRMAN LOCKEY: Any questions about 

9 Observation 1?

10 DR. NETON: This is Jim. In general, 

11 I guess are we going to follow the protocol that's 

12 been followed by like say the Subcommittee on 

13 Procedures where we would just put these in 

14 abeyance? Is that what we're saying now or?

15 MR. KATZ: Yes, I think so, Jim. I 

16 think in these cases where we don't have it spelled 

17 out yet in a new document, that's what we would do.

18 DR. NETON: Right.

19 MR. KATZ: Yes.

20 DR. NETON: So, Finding 1 and Finding 

21 2 then I have listed as in abeyance meaning we'll 

22 revise the Site Profile and I mean some point the 

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1 --

2 MR. KATZ: The finding -- just to 

3 clarify, Jim, Finding 1 is simple enough that you 

4 can close it because there's no question as to how 

5 that gets spelled out.

6 But when you have a finding where you 

7 need to see the new text, that's when you put it 

8 in abeyance.

9 DR. NETON: Okay, that's good enough.

10 CHAIRMAN LOCKEY: So, Observation 1 is 

11 in abeyance then, right?

12 MR. KATZ: Yes, I think so, Andy -- I 

13 mean Jim.

14 MEMBER ANDERSON: Moving right along.

15 DR. BEHLING: Okay, the next issue 

16 addresses Finding Number 2 and that involves the 

17 issue of environmental dose.

18 And the term environmental dose may not 

19 even be applicable but we'll address it as 

20 environmental dose here. It is more likely to be 

21 regarded as an occupational external dose, but 

22 let's discuss it anyway under Finding 2 what is 

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1 really meant here and what's involved here when we 

2 talk about environmental dose at the PPG.

3 In the original PPG Site Profile, there 

4 was reference to environmental dose but it applied 

5 to other DOE facilities. And the reason being is 

6 that many of the people or personnel, civilian 

7 personnel, who were part of the PPG workers that 

8 we're now concerned with also had affiliations with 

9 other DOE facilities at which point they were 

10 always also granted exposures that were 

11 potentially obtained during that time period when 

12 they were at their particular DOE facility.

13 And that included among other things 

14 the occupational medical dose as well as ambient 

15 environmental dose. But when it comes to the 

16 actual environmental dose at the PPG, the Site 

17 Profile had very little to say.

18 And that's really the very important 

19 one and I think I'm going to spend just a few minutes 

20 here discussing why it's very important with regard 

21 to keeping that also as part of the occupational 

22 dose for people who were exposed at the PPG but who 

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1 may not have been monitored.

2 And so, from that point of view, I want 

3 to go to page 22 if we can.

4 And let's see here, on page 22 -- are 

5 we on 22 here? Yes.

6 We have by and large the approach that's 

7 taken by the Site Profile for estimating exposures 

8 to people who were at the PPG. And in essence, we 

9 had, as you see down on the bottom, we had an 

10 assessment here for people who were non-DOE 

11 participants and I have as an example Operation 

12 Greenhouse.

13 And these are taken from Appendix A of 

14 the PPG Site Profile and they offer you a 

15 distribution of radiation exposures on behalf of 

16 non-DoD participants.

17 As you see in the bottom there, there 

18 are a total of, let me see, I don't have -- of 551 

19 participants, 110 were exposed to zero dose 

20 according to the Site Profile and you see the other 

21 distributions, 325 were exposed to doses between 

22 1 millirem and range of 1 milliroentgen to one 

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1 roentgen and so on and so on.

2 And I just wanted to make that as a 

3 reference point with regard to what is the 

4 calculated dose at the 50th percentile which is at 

5 the very base, 0.95 rem.

6 Are we on that screen? Let's see, 

7 okay.

8 MR. STIVERS: I think you were looking 

9 at Crossroads, do you want to go down to the 

10 Greenhouse?

11 DR. BEHLING: Yes. I was looking at 

12 Greenhouse, I wasn't sure which one you were 

13 showing. Oh, that's the -- okay, at the bottom. 

14 Okay, yes.

15 Those are the numbers I just cited to 

16 you because Greenhouse, I want to reference because 

17 it identifies some of the problems that are 

18 associated with the failure to accommodate the 

19 exposures that come from fallout.

20 Anyway, let's go back. In terms of 

21 Greenhouse, this is an example of what the original 

22 PPG Site Profile would assign persons from 

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1 occupational exposure and, as I said, for non-DoD 

2 participants of which there were 551 participants, 

3 you had the average exposure for that group of 

4 individual would have been half of a roentgen of 

5 0.5 as you state down there and the maximum on that 

6 people was 8.6.

7 But for the 50th percentile value, the 

8 occupational exposure would have been assigned of 

9 0.95 rem. Okay?

10 And I want you to keep that number in 

11 mind because when we now talk about what was the 

12 dose perhaps to people who were affiliated with the 

13 Greenhouse operation? And were not necessarily 

14 even monitored. What might have been their 

15 potential radiation exposure from ordinary 

16 fallout? Which was obviously not considered in 

17 the PPG.

18 And for that, I want to just briefly 

19 spend a few minutes just to show everyone what the 

20 concerns are. And I want to go to page 30, John. 

21 That shows you something that is relevant to that 

22 particular issue. If you can raise that up, John, 

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1 to show the entire thing?

2 This is Enewetak Atoll which is the 

3 Ground Zero for the 42 detonations that took place 

4 during the time periods between '46 and '58.

5 And what you see down there are 

6 highlighted, the three areas below that are around 

7 5:00. And those identify locations, in other 

8 words, islands -- the island of Japtan, Parry and 

9 Enewetak.

10 And the reason I pointed those out to 

11 you is this is where many of the people who were 

12 a part of the Operation Greenhouse actually lived, 

13 they worked there, they lived here, they 

14 essentially spent all times there other than when 

15 they were on specific missions.

16 At the same time, when you look at the 

17 location of Japtan, Parry and Enewetak, there are 

18 a total of four tests that were a part of Operation 

19 Greenhouse.

20 And at the very bottom, the first one 

21 down there that's highlighted is the Test Dog that 

22 occurred on April 7th, '51.

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1 The second one is Easy which is at the 

2 very top. At the very top there you will see Test 

3 Easy.

4 And then the third one is in the middle 

5 and then that was Test George and the last one's 

6 Test Item.

7 And just to give you an understanding 

8 of what these facilities looked like that housed 

9 these people during this time frame, I would ask 

10 John to give you page 31.

11 And the first picture is a picture of 

12 what the island looked like for Enewetak Island 

13 that is subsequent to -- it used to be called Fred. 

14 And you see all the facilities, the buildings, 

15 these sort of makeshift buildings that were built 

16 specifically for the conduct of these tests in the 

17 Pacific.

18 When before 1946, these were islands 

19 that were covered by coconut groves and there were 

20 no structures there.

21 The one below that is Parry Island. 

22 Again, you will see all of the structures that had 

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1 to be placed there. This is where people spent 

2 their time. They either lived there, worked there 

3 or both.

4 And on the next page, there's Enjebi 

5 Camp Greenhouse and there you even see at the lower 

6 picture, John, is that is actually just nothing 

7 more than a tent city where people actually lived 

8 there who worked and spent their time there, 24 

9 hours a day.

10 On page 33, this is where we start to 

11 see what would have been a potential exposure from 

12 background alone, not necessarily covered or 

13 registered on film badges.

14 Can you scroll -- move it down a little 

15 bit so we get the full -- no, the other way, up, 

16 I'm sorry.

17 And what you see here for the time frame 

18 between April and May, the cumulative exposure that 

19 would have been received had you stayed there for 

20 the entire time period.

21 And you realize how much radioactivity 

22 had fallen in the form of fallout on Parry Island.

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1 In more quantitative terms, I want to 

2 go to, at this point, to page 35.

3 And this was actually introduced by the 

4 Defense Nuclear Agency in the rewrites that took 

5 place in 1982 where they reconstructed the doses. 

6 And this is going to be a little difficult, but if 

7 you follow the diagonal line that says arrival date 

8 on Parry Island, you will see that the starting date 

9 comes as early as at the far bottom left on the 8th 

10 of April. Okay? 8th of April.

11 And if a person came to that island and

12 stayed there for the full duration from April 8th 

13 to the 1st of June which is on the far right hand 

14 side at the very bottom, John, okay, you see the 

15 dose for that individual would have been a total 

16 dose of 4.28 rem.

17 And so, what I wanted to point out here, 

18 if a person had spent that time frame from April 

19 8 to June 1, his exposure for occupational 

20 radiation, but was due to strictly fallout for 

21 which he was not monitored, would have been more 

22 than 4 rem.

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1 And you compare that to what I just 

2 previously told you with the occupational exposure 

3 that would have been assigned to that person based 

4 on Appendix A or Attachment A in the PPG Site 

5 Profile, it would have been less than 1 rem.

6 And so, what I wanted to do is dramatize 

7 the significance of fallout as part of the exposure 

8 that in many instances could far exceed the actual 

9 monitored exposure based on mission badges that 

10 were defined in the PPG Site Profile by NIOSH 

11 earlier that I mentioned was less than 1 rem.

12 So, that, in essence, is what concerns 

13 the Issue Number 2, that is the occupational 

14 environmental dose that was really not addressed 

15 in the original Site Profile and, at this point, 

16 I think it needs to be looked at very carefully.

17 And that was not necessarily consistent 

18 throughout that whole 60 year period, but it did, 

19 in fact, involve certain locations, certain time 

20 frames that are documented within DNA documents 

21 that should be looked at.

22 And I guess from NIOSH's response, they 

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1 agree with Section 4 and you see, they will 

2 obviously address it in Section 6 of the PPG Site 

3 Profile.

4 Are there any other comments from 

5 NIOSH?

6 MR. ROLFES: This is Mark and I just to 

7 point out also that under the current SEC in the 

8 absence of bioassay data, internal dose won't be 

9 reconstructed for individuals just because of the 

10 SEC.

11 DR. BEHLING: Okay.

12 MR. ROLFES: And I'm mentioning that 

13 since you had mentioned both external and internal 

14 doses in your findings.

15 CHAIRMAN LOCKEY: Hans?

16 DR. BEHLING: Yes?

17 CHAIRMAN LOCKEY: Chairman Lockey. 

18 This 4 rem, would you consider that the maximum dose 

19 from fallout over the whole period for each time 

20 frame or is this B

21 DR. BEHLING: No, this is strictly as 

22 the slide shows on page 35. The 4.28 rem was the 

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1 calculation that was done by the Defense Nuclear 

2 Agency in 1982 when they revisited their earlier 

3 version of the issue that involved Operation 

4 Greenhouse.

5 There were two documents that defined 

6 Operation Greenhouse. The first issue was 

7 released in '51 and then there was a revision to 

8 Operation Greenhouse by the DNA in 1982.

9 And they went back and they actually 

10 looked at some of the data that they did have 

11 available and they reconstructed what the doses 

12 were at these three locations, namely the island 

13 of Enewetak, Parry and Japtan where I showed you 

14 pictures with regards to what these locations 

15 within the Atoll of Enewetak, sort of staging 

16 areas, as work areas, as housing areas, et cetera, 

17 et cetera.

18 And so, they came up with that diagram 

19 that I showed you on page 35 that allows you to take 

20 any combination of when the person may have come 

21 on site during that time frame from April to the 

22 beginning of June and when he exited.

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1 Since it's the one that is shown in 

2 darker color was one that I actually looked at on 

3 behalf of a dose reconstruction that I had to do.

4 In review of the dose reconstruction, 

5 I looked at that individual's entry which, as I 

6 said, was on -- which indicated as [identifying 

7 information redacted], hard to read, and he ended 

8 up -- that person ended up leaving on [identifying 

9 information redacted].

10 And on that basis, I concluded that that 

11 person's unmonitored exposure from fallout would 

12 have been 0.94 rem which is exactly what he would 

13 have received in addition to the occupational 

14 exposure based on what the original PPG Site 

15 Profile had that identified the value of 0.95 rem 

16 that NIOSH would have assigned him.

17 But that exposure for that duration on 

18 Parry Island, he would have also received the same 

19 amount dose from unmonitored occupational 

20 environmental dose.

21 DR. MAURO: And this is all external, 

22 Hans, right?

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1 DR. BEHLING: All external.

2 DR. MAURO: Right.

3 DR. BEHLING: And the important thing 

4 here is to understand one more thing, and that is 

5 when we look at the failure to address potential 

6 environmental dose that is not monitored is that 

7 it was very definitely significant.

8 And here I can say for those three 

9 locations that I mentioned, Japtan, Enewetak and 

10 Parry, if a person had stayed the full duration for 

11 Operation Greenhouse, he would have received a 

12 total external whole body dose of about 4 rem or 

13 slightly more than 4 rem at each of those locations 

14 from fallout.

15 And what is really significant here 

16 applies to people who do not have the presumptive 

17 cancers because their the internal exposure would 

18 have been obviously affected by these large 

19 occupational external whole body doses.

20 But, more importantly, for people who 

21 might have had a claim with skin cancer, which is 

22 not a presumptive cancer, what you also then have 

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1 to add to that dose is the beta dose, that we'll 

2 talk about under Finding Number 6, and that can be 

3 ten times higher.

4 So, I wanted to emphasize the fact that 

5 Finding Number 2 has a very real significance in 

6 behalf of presumptive cancers, skin cancers as well 

7 as non-presumptive especially the skin cancer 

8 where we have to add to the additional dose that 

9 we just identified, talked about the much higher 

10 beta dose that we will discuss under Finding Number 

11 6.

12 MR. ROLFES: Hans, this is Mark. I've 

13 got a question.

14 DR. BEHLING: Yes?

15 MR. ROLFES: I presume this is the same 

16 case that you had referenced further on in the 

17 report for which you did the fallout assessment 

18 for? Is this for the same individual that's 

19 referenced further on in the report? You said yes?

20 DR. BEHLING: Yes.

21 MR. ROLFES: Okay. We have different 

22 employment dates than what you had mentioned. We 

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1 have an employment end date of [identifying 

2 information redacted], 1951. And we also do, if 

3 you take a look in the DOE dosimetry records for 

4 this individual, I do see that there was a fallout 

5 assessment done for this particular individual 

6 from Operation Greenhouse.

7 DR. BEHLING: Oh, I remember that. 

8 But, this was done with 1951 data, not the 1982 DNA 

9 data.

10 MR. ROLFES: Okay.

11 DR. BEHLING: I realize there was a 

12 very marginal, I think like 60 millirem assigned 

13 to him from fallout.

14 MR. ROLFES: Correct.

15 DR. BEHLING: And he clearly stated he 

16 lived or stayed on Parry and Enewetak and he also 

17 spent time at Enjebi Island before they were 

18 removed because the fact that there was a test 

19 conducted on Enjebi.

20 So, I don't believe that that 

21 assignment of 60 millirem will clearly prove to be 

22 the correct value assigned from fallout.

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1 MR. ROLFES: Okay. Yet, we can 

2 certainly take a look at what you've pointed us to 

3 here.

4 MR. STIVER: This is John Stiver. I 

5 might also add that the NA unit dose assessments 

6 are available at the DTRA website for all shifts 

7 and locations for all of the PPG operations. And 

8 these are the ones that came out in and basically 

9 were published in '83.

10 And in addition to that, I know DTRA is 

11 graded in SOP Manual with operation specific 

12 appendices which I was involved with before I came 

13 to SC&A.

14 Those are not available at this time to 

15 the public because they haven't been through an 

16 external review. But they are essentially very 

17 close to the 1983 reports that are available.

18 And I've been involved in NTPR for a 

19 number of years. I can tell you that there's a lot 

20 of research and work that went into developing 

21 those unit dose reconstructions. And those are 

22 probably your best bet for assessing fallout dose 

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1 for people at different locations.

2 DR. BEHLING: Are we done with that

3 discussion?

4 DR. NETON: This is Jim. I was going 

5 to summarize.

6 I think Finding 2 is in abeyance and 

7 basically all we are going to do there is to defer 

8 any dose reconstruction to Section 6 for 

9 occupational dose considering that it's all 

10 basically occupational dose.

11 DR. BEHLING: Yes. I had mentioned to 

12 you, I only brought it up because it was an issue 

13 under environmental but, in essence, you can put 

14 it in either camp, either environmental or 

15 occupational.

16 DR. NETON: I agree. I think we kind 

17 of jumped in to the next finding really. It's 

18 getting into the reconstruction of the doses in 

19 general.

20 DR. BEHLING: Yes. Finding Number 3 

21 is a broad sweeping finding that deals with what 

22 was the priority of the monitoring that was done?

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1 And there was many, many problems which 

2 I discussed in Section 7.1, 7.2 and 7.3 and I don't 

3 want to go through -- go over all of those things, 

4 but what I want to do is perhaps just summarize 

5 those things, some of the issues that I brought up.

6 And that summary is presented in 

7 Section 7.4.1 on page 41 and 42.

8 Okay, the bottom of page 41 starts and 

9 I just want to briefly go over and among -- we've 

10 already mentioned the use of mission badges.

11 For those who are not necessarily 

12 familiar with it, mission badges were those that 

13 were assigned early on because of the shortages of 

14 film dosimeters.

15 Understand, again, I want to go back. 

16 In the case of Operation Crossroads, we had 42,000 

17 personnel on location and many of these were 

18 obviously required to have monitoring done.

19 But monitoring done was oftentimes 

20 limited to select tasks when a person had to go to 

21 retrieve instruments on the very island where a 

22 surface detonation took place.

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1 They were oftentimes then brought with 

2 amphibious ships on to the shore of that island and 

3 then on a time basis, go in there, grab that thing 

4 and bring it back for us for analysis.

5 And so, the badge for that particular 

6 task would be issued on the morning of that day and 

7 would be retrieved from that person at the end of 

8 the day and that was it. And it would oftentimes, 

9 they would subtract and background radiation that 

10 was not affiliated with that particular task.

11 And those were the mission badges that 

12 we are obviously concerned about and have discussed 

13 under Finding 1 that will obviously be an issue that 

14 the DOL will have to wrestle with.

15 But, mission badges were one of the few 

16 things that oftentimes were monitored. And so, 

17 what was not monitored was the very issue that we 

18 brought out under Finding Number 2, namely the 

19 continuous exposure 24/7 when there was 

20 significant fallout for personnel who were living 

21 and staying on these other Atolls.

22 So, mission badges obviously were only 

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1 assigned for select tasks and for a very 

2 restrictive time periods. And moreover, mission 

3 badges were not assigned for everybody. As I said, 

4 they were only there for those people that we 

5 considered or they considered were very likely to 

6 experience high radiation dose fields for select 

7 tasks in hand. On page 42, that summary continues.

8 The other issue was that if you read 

9 through some the DNA report was the practice of 

10 cohort badging. And cohort badging refers to the 

11 practice where, again, for reasons that these film 

12 dosimeters were not always there in large supplies.

13 As I said, when you had tens of 

14 thousands of people to monitor and oftentimes these 

15 badges have to be not only retrieved, issued, 

16 retrieved, but then they had to also read these 

17 badges and assess their readout and then 

18 redistribute it again.

19 And when you do that for that many 

20 people, you realize you can't do this at a low 

21 multiplication. All these facilities were 

22 obviously makeshift land facilities or onboard a 

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1 ship.

2 So, what they did in order to be able 

3 to at least provide some measure of protection for 

4 workers was to engage in cohort badging where one 

5 person would wear the badge such as the rad-safe 

6 person who was actually overseeing the activity of, 

7 let's say, 50 to 100 men and whatever that person 

8 would register on his badge would also apply to the 

9 entire cohort which would not necessarily be an 

10 accurate assessment but, perhaps, a representative 

11 assessment.

12 But another problem with cohort badging 

13 is that not always would the people who were part 

14 of the cohort identified. So, in essence, what you 

15 had was a person who had the benefit of a cohort 

16 exposure but not necessarily was documented in the 

17 records that he was part of that cohort. So, 

18 that's another major issue.

19 And in the next bullet, the cohort 

20 badging oftentimes was not necessarily even 

21 recorded. At the time, there was limited concern 

22 about getting a definitive assessment of exposure 

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1 but, perhaps, avoiding any exposure that was 

2 considered less than safe.

3 And what is the maximum permissible 

4 exposure, MPE, which is on the second bullet on page 

5 42, that value turned out to be about 100 millirem 

6 per day. So, in essence, oftentimes people were 

7 monitored strictly to avoid any exposure in excess. 

8 And if the daily exposure was below that, then it 

9 was fine.

10 And that exposure was oftentimes 

11 recorded by a dose-rate instrument. So, there 

12 wasn't even a film badge involved that would serve 

13 as a permanent record. But, it was strictly a 

14 dose-rate instrument that was monitoring the area 

15 where personnel worked and, if on a basis of the 

16 time frame that these people were in there, would 

17 suggest a dose for that day of less than a 100 

18 millirem, they were in compliance with the MPE 

19 values.

20 So, those were sometimes the mechanism 

21 by which the rad-safe people applied their practice 

22 of controlling radiation exposure among workers.

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1 Film badge, there were issues that I 

2 discussed in these other Section 7.1, 7.2, 7.3 that 

3 dealt with how these film badges were calibrated 

4 and processed and how they were interpreted.

5 And there were instances I cite where 

6 some of the film badges, we always consider film 

7 badges to have a limit of detection of around 40 

8 millirem. In some instances, as documented and I 

9 took verbatim statements out of the DNA reports, 

10 some of those badges had an LOD of 400 millirem. 

11 Below that, they were not considered reliable.

12 There were other issues regarding 

13 decontamination efforts where exposures was not 

14 necessarily one that was captured on a film badge 

15 but involved skin contamination.

16 Clearly one of the most obvious 

17 instances was the estimate of Operation Crossroads 

18 where during the Test Able, a total of 67 ships that 

19 had been amassed in the lagoon of Bikini were 

20 exposed to radiation that came from a bomb that was 

21 dropped 550 feet above them with the intent of 

22 seeing how these naval vessels would respond to a 

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1 nuclear sub.

2 And of course, as a result of that, 

3 these vessels were heavily, heavily contaminated 

4 and people would go out there and pretty much then 

5 decontaminate them, oftentimes wearing nothing 

6 more than short pants and maybe a pair of shoes.

7 And they would also get obviously 

8 contaminated on their skin as well as on their 

9 clothing and, again, that is contamination --

10 external contamination that was not captured.

11 So, all of these things were discussed 

12 here and they by and large constitute Finding 

13 Number 3. And there is a fairly extensive response 

14 on the part of NIOSH.

15 Let's see here, does anybody want to 

16 comment from NIOSH regarding the response for 

17 Finding Number 3? Mark?

18 MR. ROLFES: Let's see, I'm just going 

19 to go ahead and read through the response here.

20 It says, NIOSH understands that there 

21 are deficiencies related to the film badge 

22 dosimetry data and procedural practices identified 

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1 by the NRC in 1989 and SAIC in 1989 through 2006 

2 as well as Perkins and Hammond in 1980.

3 In light of these deficiencies, NIOSH 

4 finds it intractable to achieve more accurate dose 

5 assessments than those provided by the Defense 

6 Nuclear Agency and reduced in Attachment A of ORAU 

7 Technical Basis 52 with realistic uncertainty 

8 ranges.

9 Many of the data have been lost or never 

10 captured to make such an effort feasible. 

11 However, the next revision of the Technical Basis 

12 Document will include a revision to Attachment A 

13 to provide the 95th percentile doses as 

14 appropriate.

15 And then we've got a reference to see 

16 Findings 8 and 9 below.

17 For cases where occupation on the 

18 various islands documented in the dosimetry 

19 records and their stay times are known, either by 

20 personnel badges --

21 Sorry, I just realized I had it on 

22 speaker phone. I'm talking into the receiver so 

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1 hopefully you can hear me a little bit better now.

2 Let's see, where did I leave off? 

3 Let's see, okay.

4 -- either by personnel or cohort film 

5 badges or reentry logs, additional dose can be 

6 calculated in accordance with the information 

7 provided in Figures 7-6 through 7-10 and added to 

8 doses assigned using Attachment A to account for 

9 unmonitored exposure to fallout.

10 It should be noted that during 

11 Operation Castle in the first half of 1954, the 85 

12 to 90 percent of all personnel were issued 

13 operational film badges. In addition, all 

14 personnel involved in the reentry activities were 

15 also issued mission badges that were read at the 

16 end of each mission.

17 For Operation Wigwam on May 15, 1955, 

18 and all subsequent tests at PPG, 100 percent of all 

19 personnel were issued operational film badges. In 

20 addition, all personnel involved in reentry 

21 activities were also issued mission badges that 

22 were read at the end of each mission.

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1 DR. BEHLING: Yes, and I think that 

2 pretty much satisfies the concern. As I mentioned 

3 beforehand, some of the issues that we are 

4 identifying on behalf of the findings were not 

5 issues that proved they were throughout the entire

6 16 year period.

7 But oftentimes were issues that 

8 confined to a certain number of years in the early 

9 years and ceased to be a problem later on, 

10 especially the issue when in 1956 all personnel who 

11 came on site were issued film badges for the full 

12 duration of their stay at the PPG.

13 So, one had to realize that not all 

14 these findings have relevance to the entire 16 year 

15 period.

16 And in context, the recommendation to 

17 use the 95th percentile dose that are part of the 

18 Attachment A, it's the original PPG Site Profile, 

19 that certainly raises the bar considerably for a 

20 coworker dose in the event that there are no 

21 additional exposure data available for that 

22 individual.

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1 CHAIRMAN LOCKEY: Any other comments 

2 about that?

3 DR. BEHLING: Okay.

4 MR. KATZ: I guess, can I just check 

5 with you, Andy, and the other Board Members, 

6 though? So, how does this finding stand for you 

7 all in terms of the context that addresses his 

8 concern, but he's speaking for SC&A?

9 CHAIRMAN LOCKEY: Jim Lockey. I think 

10 I'm fine with this. If we're going to use the 95 

11 percent where additional data is not available, it 

12 sounds like that data is available after '54. Is 

13 that correct, Jim?

14 DR. NETON: No, we're going to use the 

15 95th percentile of the mission badges that were 

16 summarized in Attachment A and they were recorded. 

17 Then we'll add any additional dose that we may find 

18 or the fallout doses as Hans indicated particularly 

19 in Figure 7-6 through 7-10 if we have that 

20 information.

21 Oftentimes we don't have that kind of 

22 specific information for these folks. It's a lot 

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1 more sketchy. But if it is there, that's what we 

2 will do. We'll modify the Site Profile 

3 accordingly.

4 CHAIRMAN LOCKEY: And what about after 

5 1954?

6 DR. NETON: After '55 they were 

7 operational badges.

8 CHAIRMAN LOCKEY: And that's the data 

9 you used then, correct?

10 DR. NETON: That's a good question. 

11 Gene Rollins is on the phone, I'm not as familiar 

12 with the data as he is, I think.

13 MR. ROLLINS: It should be after -- at 

14 starting with Wigwam, everybody was issued a badge.

15 DR. NETON: Right.

16 MR. STIVER: This is John. I might be 

17 able to help out a little bit here.

18 That is correct, after Wigwam and it's 

19 particularly in their PPG operations starting with 

20 Redwing. 

21 All the participants had permanent 

22 badges and any additional mission badges they got 

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1 for a particular activities like retrieving 

2 instrumentation and so forth were worn with the 

3 permanent badge.

4 So basically, it's going to be like 

5 raisins in the pudding. I mean whereas in their 

6 earlier years, they didn't have those permanent 

7 badges so we had the mission badges which reflected 

8 activities that did not include the fallout but 

9 particular occupational activities would then have 

10 to be added to the fallout dose to get the full 

11 picture.

12 DR. BEHLING: And like I said, you 

13 know, the issues that I addressed with regard to 

14 some of the problems involving the calibration, 

15 involving issues that were oftentimes fraught in 

16 the design of the film badge.

17 One of the major concerns that they 

18 encountered were the very, very adverse conditions 

19 that the Pacific Ocean and the latitude presents, 

20 and that is the high humidity and the constant high 

21 temperatures that these badges and oftentimes 

22 badge failures that were commonplace in those days 

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1 cannot be rectified.

2 So, you have to simply live with the 

3 fact that, you know, they were certain deficiencies 

4 in the program, the design of the badges, the 

5 calibration of the badges and so forth.

6 And we can't make a change to that. We 

7 have to simply accept that that as part of the 

8 compensation as NIOSH has been doing through --

9 offer here, is to use the 95th percentile value. 

10 Because we can't go back and change what happened. 

11 We can't undo certain problems involving faulty 

12 calibration procedures or anything else.

13 But I think the benefit of doubt can be 

14 given by using the 95th percentile as the coworker 

15 value that may be appropriate.

16 CHAIRMAN LOCKEY: One more question 

17 about Wigwam. So, we have -- so, in 1955 with 

18 Wigwam when people were issued operational film 

19 badges, was that carried through when they went 

20 back to their personal headquarters? Sleeping 

21 headquarters, et cetera? Were those badges -- did 

22 they maintain those badges during that time?

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1 DR. BEHLING: Yes, they did. From 

2 what I gathered, when they were assigned, the 

3 people were actually asked to keep them on their 

4 person for the full duration, 24 hours a day.

5 CHAIRMAN LOCKEY: While they were in 

6 the area no matter what they were doing?

7 DR. BEHLING: Yes.

8 CHAIRMAN LOCKEY: Okay, thank you.

9 MR. KATZ: So then, Work Group, is this 

10 finding in abeyance?

11 CHAIRMAN LOCKEY: Let's go around. 

12 Andy?

13 MEMBER ANDERSON: I think so.

14 CHAIRMAN LOCKEY: Loretta?

15 MEMBER VALERIO: Can you hear me?

16 CHAIRMAN LOCKEY: Yes, I hear you now.

17 MEMBER VALERIO: Okay. I believe that 

18 it is in abeyance.

19 CHAIRMAN LOCKEY: Jim Lockey. I 

20 agree.

21 MR. KATZ: Okay, thanks.

22 CHAIRMAN LOCKEY: Go ahead, Hans.

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1 DR. BEHLING: Okay. Finding Number 4, 

2 the issue there is one of, let's see here, in the 

3 PPG in Section 6 of the original NIOSH PPG Site 

4 Profile, the statements that the assignment of 

5 unmonitored dose to participants who did not 

6 receive a dosimeter should be evaluated.

7 Now, I don't know what that really 

8 means. Again, it should be evaluated but can it 

9 be reasonably evaluated by someone who is a dose 

10 reconstructor without some additional guidance and 

11 additional information? And that is really the 

12 concern I had with regard to Finding Number 4.

13 So, that beyond the recommendation that 

14 an unmonitored dose should be evaluated, NIOSH 

15 really should provide some additional guidance as 

16 well as information that may be used by the dose 

17 reconstructor to do this.

18 MR. ROLFES: This is Mark, Hans. In 

19 the next revision of the Site Profile, we'll revise 

20 the statement to read as follows.

21 It says, covered employees that 

22 participated in the various Pacific Proving Ground 

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1 operations and were not badged can be assigned 

2 coworker doses as outlined in Attachment A.

3 DR. BEHLING: Okay. Now, is this the 

4 coworker dose that is referenced above under 

5 Finding 3, the 95th percentile value?

6 MR. ROLFES: That's correct, as 

7 appropriate.

8 DR. BEHLING: Okay. So, I'm going to 

9 just add that to my list here, 95th percentile value 

10 for coworker. Okay.

11 Okay, item --

12 CHAIRMAN LOCKEY: Hans, are you happy 

13 with that?

14 MR. KATZ: Hans, do you agree with 

15 that?

16 DR. BEHLING: Oh, yes, yes. I wasn't 

17 sure that I was being asked here. Yes, as I said, 

18 if the 95th percentile coworker dose and, again, 

19 I think there should be an additional statement 

20 that if there's any exposure that's associated with 

21 significant fallout as was the case with Operation 

22 Greenhouse, I think that also should be included 

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1 in unmonitored exposure.

2 CHAIRMAN LOCKEY: As an add-on?

3 DR. BEHLING: Yes.

4 CHAIRMAN LOCKEY: Right? Okay.

5 MR. KATZ: Does the Work Group?

6 CHAIRMAN LOCKEY: I'm fine with that. 

7 I vote for abeyance.

8 MEMBER VALERIO: I agree that it's in 

9 abeyance, too.

10 MEMBER ANDERSON: Yes, I agree. We're 

11 not closing out much.

12 MR. KATZ: Well, abeyance is 

13 effectively closing it. I mean the reason I'm 

14 trying to capture this, too, is because this 

15 relates to work being done by the Dose 

16 Reconstruction Subcommittee. And if we get these 

17 in abeyance then closure, then they can move 

18 forward with --

19 MEMBER ANDERSON: Okay, that's --

20 MR. KATZ: -- sited work.

21 MEMBER ANDERSON: I don't think 

22 there's anything more for us to do other than to 

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1 --

2 MR. KATZ: Right.

3 MEMBER ANDERSON: -- verify that it's 

4 occurred.

5 MR. KATZ: Right.

6 CHAIRMAN LOCKEY: That's correct.

7 MR. KATZ: Okay, thanks. Hans?

8 DR. BEHLING: Okay. Finding Number 5, 

9 the issue here is one where I think the PPG Site 

10 Profile recommended the assignment of 30-250 keV 

11 for external photon dose.

12 And when I look at the average energy 

13 from fission products that are obviously the 

14 principle source of the external photon dose, the 

15 average photon dose is more along the lines of 700 

16 keV.

17 And when I look at the radiation 

18 exposure geometry, when you have fallout, it occurs 

19 over the infinite plane, meaning that if you're 

20 standing on infinite plane and fallout is all 

21 around you, front, back, side, you are in essence 

22 exposed to a rotational isotropic exposure 

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1 geometry.

2 And when I look at the DCF values in 

3 Implementation Guide 1 for all organs, you were 

4 inclusive of skin dose, you will find that the DCF 

5 value is consistently higher for the exposure 

6 geometry of isorotation for a 250 keV photon dose 

7 as opposed to 30-250.

8 MR. ROLFES: This is Mark. And I'll go 

9 ahead and start with the response here that we have.

10 And that is that, although the 

11 isotropic or rotational geometries might be more 

12 realistic, the general approach taken in our dose 

13 reconstructions is to apply the dose conversion 

14 factor which yields the highest Probability of 

15 Causation.

16 And with the exception of the lungs, 

17 esophagus, red bone marrow and bone surfaces which 

18 are referenced in Guide 1, Section 4.4, the highest 

19 dose conversion factor is typically associated 

20 with the 30-250 keV photon energy range and the AP 

21 geometry when we're converting exposure to organ 

22 dose as you would with the film badge.

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1 In addition, that's described in Table 

2 5A of the NIOSH IREP Technical Documentation, the 

3 radiation effectiveness factor is significantly 

4 higher for photons in the 30-250 keV energy range 

5 compared to the greater than 250 keV energy range.

6 These two factors lead to the 

7 recommendation given in Section 6.

8 DR. BEHLING: Well, I don't agree with 

9 it. If you look at the DCF for rotation and ISO 

10 for any organ and, I'm looking at the exposure R 

11 to organ. In other words, a roentgen to rad dose 

12 value, the DCF's the higher for the two 250 keV.

13 MR. SMITH: Well, this is Matt Smith 

14 with ORAU team.

15 I'm looking at the same things. I 

16 picked the colon just to grab an organ that doesn't 

17 have any correction factors that need to be applied 

18 per the IG.

19 And, you know, if we take a look at what 

20 the AP DCF would be with the colon, it's a value 

21 of about 1. It's 1.06 at 30-250 keV.

22 Now, if we were to assume a geometry of 

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1 exposure that is either rotational or isotropic, 

2 it certainly could be the case in the conditions 

3 that are discussed here, the highest value would 

4 be, as you said, for greater than 250 keV, it would 

5 be a value of 0.720 and that would be for a 

6 rotational assumption.

7 Certainly, if you look at rotational on 

8 its own as a geometry assumption, the 30-250 value 

9 would be .68 and the greater than 250 would be .72.

10 So, certainly, choosing that higher 

11 energy range would be appropriate if he were just 

12 going to go with limiting your assumption to 

13 rotational.

14 But, as Mark said, on this program from 

15 a very early date, we've gone ahead and gone with 

16 an assumption of the DCF that gives us in most all 

17 cases a higher dose. And in this case, that would 

18 be using a DCF of 1 under the AP 30-250 criteria.

19 And also, per the IREP Technical Guide, 

20 when you're in that mid-range photon category, 

21 you're getting a greater REF factor which affects, 

22 you know, which drives the PoC higher.

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1 DR. BEHLING: Yes. Well, as I said, 

2 when I look at the historical data in some of the 

3 DNA documents, they oftentimes mix roentgens, rad 

4 and rem interchangeably and so it's very difficult 

5 to see what you're really measuring.

6 I realize some badges were used but were 

7 they calibrated in units of roentgens or rem or rads 

8 or rems? I don't know.

9 MR. SMITH: Well, we're certainly 

10 assuming exposure or --

11 DR. BEHLING: Okay.

12 MR. SMITH: -- the quantity being 

13 measured in the field.

14 DR. BEHLING: I guess I would consider 

15 this a minor issue given the uncertainty of the 

16 dosimetry program as a whole and then I think we 

17 can possibly put this just away and not spend a lot 

18 of time addressing that particular issue.

19 DR. MAURO: This is John. Just a quick 

20 question. Is this explanation you just gave in the 

21 Site Profile or is this something -- a position you 

22 have taken, of course, more recently and will be 

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1 applied in this circumstance?

2 MR. ROLFES: This is Mark. And this is 

3 something that has been done essentially from day 

4 one when converting exposure to organ dose.

5 The only change to it essentially is the 

6 accepted four organs which we had mentioned here, 

7 the lungs, the esophagus, red bone marrow and bone 

8 surfaces.

9 DR. MAURO: Okay, so, then this 

10 description is in the current Site Profile?

11 MR. ROLFES: It wouldn't be in the Site 

12 Profile.

13 DR. MAURO: Oh, okay.

14 MR. ROLFES: It would be in our 

15 Implementation Guideline B

16 DR. MAURO: Okay.

17 MR. ROLFES: -- or in dose 

18 reconstructors instructions on how to interpret 

19 the --

20 DR. NETON: But it does say -- this is 

21 Jim -- to use the 30-250 keV energy range which is 

22 claimant-favorable. I mean I think we've 

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1 established that, that this is a 

2 claimant-favorable approach. I don't think 

3 there's any modification required here.

4 DR. MAURO: So, 30-250 and AP is your 

5 approach to the dose conversion factor strategy 

6 for, let's say, this large surface area 

7 contamination?

8 MR. STIVER: I think this would be an 

9 isotropic or I think you can also probably use the 

10 --

11 DR. NETON: No, you could -- if you went 

12 for isotropic or rotational, you would end up with 

13 a lower --

14 DR. MAURO: Lower dose, yes.

15 DR. NETON: -- lower dose. I mean --

16 (Simultaneous speaking.)

17 MR. STIVER: We're going to go with 

18 whatever geometry gives you the highest dose in the 

19 most claimant-favorable outcome.

20 DR. NETON: But -- in almost all cases, 

21 it will be 30-250 AP geometry with the exception 

22 of the lung, esophagus, red bone marrow and bone 

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1 surface.

2 DR. MAURO: Oh, okay. Well, unless 

3 anyone else -- the way I see it is that you're taking 

4 the most bounding set of assumptions.

5 DR. NETON: That's the idea.

6 DR. MAURO: Yes. Okay, got it. Thank 

7 you.

8 MEMBER ANDERSON: Even if it perhaps 

9 doesn't most accurately reflect what it actually 

10 was?

11 DR. NETON: Well, we just don't know. 

12 I mean, yes, it could be it's more likely 

13 rotational, but we don't know. I mean --

14 MR. ROLFES: Yes, we certainly agree 

15 that the exposure geometry could be different than 

16 the AP geometry, but the AP geometry is essentially 

17 giving us a dose conversion factor two times higher 

18 than the isotropic and a little bit higher than the 

19 rotational for the colon for the organ that Matt 

20 Smith had mentioned when converting exposure to 

21 organ dose.

22 CHAIRMAN LOCKEY: So, how do we resolve 

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1 this? Is the SC&A willing to say they accept the 

2 NIOSH approach here?

3 MEMBER ANDERSON: Or the NIOSH 

4 explanation?

5 DR. BEHLING: Yes, I think it's one 

6 that we will go along with, the approach that NIOSH 

7 is taking.

8 CHAIRMAN LOCKEY: Okay.

9 MR. KATZ: So, the Work Group Members?

10 MEMBER ANDERSON: That's fine with me, 

11 yes. I understand the rationale.

12 CHAIRMAN LOCKEY: Jim Lockey. I do 

13 too. I'm fine with that.

14 MEMBER VALERIO: This is Loretta. I'm 

15 fine with that as well.

16 MR. KATZ: Okay, good. Thanks. Back 

17 to you, Hans.

18 DR. BEHLING: Okay. Finding Number 6, 

19 and this is a very important one here for at least 

20 a couple of special cases and that involves the 

21 beta-gamma dose ratios.

22 If we go to on page 44, John, we will 

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1 see what was at least in a summary fashion 

2 recommended in behalf of supplying a beta-gamma 

3 dose ratio for those instances where we had a deep 

4 dose available.

5 And in that particular table there, you 

6 see is Table 7-3, gives you an understanding of what 

7 the ratio was between beta and photon for various 

8 time frames following a detonation.

9 So that between zero and 50 days after 

10 detonation, if you had a dose rate that -- or a dose 

11 measurement that involved a photon deep dose, the 

12 beta dose or the beta dose rate would be a factor 

13 of ten higher.

14 And again, you see on that table, there 

15 were different time frames, 50-365 days, one to 

16 five years greater and five years.

17 The latter years are not really 

18 relevant with regard to the PPG. These were --

19 these tables were developed for the Nevada Test 

20 Site.

21 When you a facility such as the PPG 

22 where you had, especially in later times, 

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1 detonation after detonation, what you have to 

2 understand is the dose rate for both gamma and beta 

3 diminishes exponentially.

4 And so, if you have a detonation that 

5 took place, let's say, two months ago, and then you 

6 were subject to a fallout from a recent one a day 

7 or two old detonation, the fallout from that, the 

8 ratio may increase for the beta-gamma for the 

9 earlier one because of the time frame.

10 But the actual absolute quantity in 

11 terms of dose or dose rate would be so severely 

12 diminished so as not to really contribute very much 

13 to the new dose that was generated from a detonation 

14 yesterday where the beta to gamma ratio was only 

15 a fact of ten as opposed to, let's say, 25.

16 And so, what we really have to focus 

17 here with regard to PPG is the beta-gamma ratio of 

18 ten because of the large number and frequency of 

19 detonations.

20 But anyway, what I wanted to -- there 

21 are much more detailed information in the Nevada 

22 Test Site Profile in Appendix C, I believe.

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1 But what I really wanted to point out 

2 here with regard to my finding was that the 

3 refinement that you could introduce here for skin 

4 doses that involve certain parts of the body and 

5 that is defined by a document that was published 

6 in Health Physics by Barss and Weitz in 2006 and 

7 that is on page 45. And that is really the issue 

8 that I wanted to bring up here.

9 And what they have here is also a ratio 

10 that is defined by time from everything from a 

11 fraction of an hour all the way to two years.

12 But in addition to that, there is also 

13 the distance from the plane source to a particular 

14 part of the external body.

15 And so, you see distances from one 

16 centimeter to 200 centimeters. In other words, a 

17 six foot person or more would be essentially, you 

18 know, or more than that, a basketball player would 

19 reach that height.

20 But when you have, for instance, a skin 

21 cancer that occurs at the level of the knee or the 

22 calf, you will might also then have a secondary way 

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1 of increasing or defining that dose based on the 

2 lower level that would obviously represent a higher 

3 dose than that's represented by the dose ratio in 

4 Figure 7.3 or 7-3 that we just looked at.

5 And so, I wanted to just introduce that 

6 table and this, in fact, introduced, I believe, in 

7 the NTS Site Profile.

8 Now, one of the things that I really 

9 wanted to bring out here, however, and that is much 

10 more important than this refinement that 

11 identifies the height above the plane ground as 

12 given here in Table 7-4 by Barss and Weitz is the 

13 fact that I looked at the NTS Site Profile and on 

14 page 49 of that Profile, it gives you yet another 

15 option and this is an option that was, in fact, 

16 exercised by the dose reconstruction that I 

17 audited.

18 And when I looked at that, I sort of was 

19 concerned that this might be used more frequently. 

20 I don't know how much it was used in existing cases 

21 where there was a need to assess the beta components 

22 of a photon exposure.

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1 But on page 49, and I'll just read it 

2 to you, there -- I don't have it available, so I'm 

3 going to have to read it for portions that are 

4 relevant here.

5 It says on the second paragraph of page 

6 49 it states in the NTS Site Profile the following, 

7 no routine beta monitoring data exists for NTS 

8 prior to 1966. For the time period from 1966 to 

9 1987, 368 of data pairs were identified from 84 

10 claim files with positive beta and gamma results.

11 In other words, between 1966 and 1987, 

12 there were claims filed where there was both a 

13 photon dose and a beta dose. And they paired those 

14 and they said on the basis of that pairing, the 50th 

15 percentile beta to gamma dose ratio was 1.04 

16 essentially unity, 1-to-1, and the 95th percentile 

17 was 4.59.

18 And in the case that I looked at, they 

19 actually assessed the person with a skin melanoma 

20 and there they assigned a beta to gamma dose of 1 

21 unity, one.

22 And I looked at that and the use of NTS 

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1 data that involves empirical data, they apply to 

2 NTS but understand one thing, when I looked at these 

3 paired beta and gamma dosimeter readings that 

4 occurred between 1966 and 1987, you have to realize 

5 that the Nuclear Test Ban Treaty that says no more 

6 atmospheric testing was signed on September 24, 

7 1963 and was enacted in October 10, 1963.

8 So that even the earliest of those 

9 paired -- of beta-gamma doses were essentially 

10 established three years after the test ban treaty 

11 and up to, obviously, 20-some years later when we 

12 talk about 1987.

13 Not to mention the fact that people at 

14 NTS were not camped out out there where they 

15 detonated in years past prior to, you know, 1963 

16 and were exposed to purely fallout.

17 So, I would recommend very strongly 

18 that the issue or the option to assign a beta to 

19 gamma dose ratio of one, that might be applicable 

20 for the other years at NTS should not be used for 

21 PPG.

22 I mean, after all, the pictures that I 

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1 showed earlier, these people were there in the 

2 aftermath of Operation Greenhouse that had four 

3 detonations in rapid succession over a period of 

4 two months= time frame and they were exposed to 

5 fresh fallout. That is it. I mean there was no 

6 alternative.

7 At NTS a person might have had their 

8 badge exposed to radiation that had nothing to do 

9 with fallout, but may have been exposed to 

10 radiation sources inside buildings as opposed to 

11 sitting out there in the field.

12 So, the most important point I want to 

13 make here is that goes outside the finding that I 

14 had for Finding Number 7, but in essence, I wanted 

15 to make sure that the use of a beta-gamma ratio that 

16 was in fact used in a dose reconstruction, a PPG 

17 dose reconstruction, actually did use the issue of 

18 the 360-some badges, paired badges, that showed a 

19 50th percentile value of essentially 1.0 in terms 

20 of beta to gamma, and I hope that that will not be 

21 used.

22 MR. ROLLINS: This is Gene Rollins. I 

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1 own both of those documents, the NTS and the PPG. 

2 And I agree with you entirely and I think it's 

3 wholly inappropriate to use the 1.04 at PPG and 

4 we'll be making changes to the TBD to make sure that 

5 doesn't happen again.

6 DR. BEHLING: Okay. Okay, Finding 

7 Number --

8 CHAIRMAN LOCKEY: So, before we go on, 

9 then from the Board's perspective, any other 

10 questions about Finding Number 6?

11 MEMBER ANDERSON: No, I don't.

12 MEMBER VALERIO: No, I don't. I was 

13 just taking some notes, no.

14 CHAIRMAN LOCKEY: Okay, so we're -- and 

15 Ted, we're in abeyance with this also?

16 MR. KATZ: Yes, that sounds right.

17 CHAIRMAN LOCKEY: Okay.

18 MR. KATZ: Thanks. Hans?

19 DR. BEHLING: Okay, where are we here 

20 now? This is Finding Number 7, okay.

21 My Finding Number 7 comes in context 

22 with the statement that I paraphrased on page 45. 

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1 John? Okay, are you on page 45, John? Okay.

2 Okay, Statement Number 5 that I can read 

3 for you here. Statement Number 5 appeared in 

4 Section 6 of the PPG Site Profile and states the 

5 following.

6 Assign missed dose based on the number 

7 of exchanges found in the dosimetry records. 

8 During these tests there were operation badges that 

9 were worn for the entire test sequence, and so 

10 forth.

11 By the way, you realize afterward, 

12 we've talked about the use of a photon badge 

13 assignment did not occur until about 1956 or so time 

14 frame. So, when we talk about assignment of missed 

15 doses, one cannot really rely on that statement 

16 because these badges were oftentimes not 

17 available, if they were available at all.

18 And when they were available prior to 

19 '55 may have been associated with a mission badge.

20 And so, the missed dose as it's stated 

21 here, the assignment of a missed dose which would 

22 not necessarily apply here.

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1 And this obviously is more important 

2 when we talk about exposures that were not 

3 monitored at all.

4 So, my reference to the issue of the 

5 missed dose here based on that guidance is the 

6 Finding of Number 7.

7 And also, I wanted to -- there was a 

8 correction. If I go back, that was the second 

9 issue, and that, I have to go back to page -- oh, 

10 John, if you can go back to page 22? That was 

11 another part of that issue.

12 Okay, one of the things that I looked 

13 at was the actual calculation of the 50th 

14 percentile.

15 If you look at the equation up top here 

16 that says 50th percentile is the sum of A times B 

17 over C and you look at that and then you realize 

18 what A times B can represent and when you look at 

19 the bottom of the -- and this is for each cell that 

20 is for each of the cells A and B and over C.

21 For each of the cells, if you go to the 

22 bottom of that page, John, you will see, for 

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1 instance, that one of the things that you look at 

2 for each cell, the first cell has 0R. And I pointed 

3 out that there's no such thing as a 0R, it's below 

4 LOD. 

5 And so, what in effect that really 

6 should mean, and that's given on page -- go back 

7 now to page 47 where I made use of that example --

8 if you go back to page 47.

9 There you have the, let me see, so, and 

10 you have the first cell as zero dose and the second 

11 cell as 1 milli-R to 1-R and so forth.

12 The first two really should be adjusted 

13 in the sense where you have zero to 0.04-R and it 

14 may mean that that's the LOD and the second cell 

15 should be 0.04 to 1-R and those should be the one 

16 -- those should be the values that should be applied 

17 to the equation that I showed you on page 22.

18 And I'm not sure the response to that. 

19 What was the response? I'm not sure that there is 

20 a response. 

21 For, let's see here, as I said, they 

22 actually bridge both Finding 7 and 8. As far as 

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1 Finding 7, I said that the guidance for assigning 

2 missed dose is based on assumption and not 

3 supported by facts, and that really references the 

4 issue of mission badges and an issue that may 

5 involve coworker data that if it is available. 

6 That's really Number 7 and the issue of the 50th 

7 percentile value is really Finding Number 8.

8 CHAIRMAN LOCKEY: Number 8. So, we've 

9 addressed in 8 the 95 percentile?

10 DR. BEHLING: Yes, yes. I think for

11 Number 8 that minor error involving that 

12 calculation is obviously no longer the issue if you 

13 assign the 95th percentile value.

14 With regard to Finding Number 7, I'm not 

15 sure I know what you can do to identify missed doses 

16 when you have a time period when mission badges were 

17 assigned when exposure was defined by a cohort 

18 badge or, worse yet, a dose-rate instrument that 

19 may have assigned a dose because there are no film 

20 badges assigned.

21 We think they don't represent film 

22 badges or missed doses. You don't know what they 

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1 are.

2 So, when we talk about missed dose, we 

3 always talk about the film badge that comes back 

4 as below LOD. In those cases -- in all instances, 

5 I believe, throughout the time period, film badges 

6 were routinely processed with the subtraction of 

7 background doses. So, you don't really have 

8 anything to work with in terms of film badges coming 

9 back zero.

10 CHAIRMAN LOCKEY: Okay.

11 DR. BEHLING: I'm not sure what you can 

12 do about that. Obviously this is an inherent 

13 problem when you have obviously for many years 

14 monitoring that was done by cohort badging by 

15 dose-rate instruments or, in many instances, there 

16 was no monitoring.

17 DR. NETON: Well, Hans, this is John. 

18 I think we're going to have to talk about the 

19 difference between missed dose and unmonitored 

20 dose. I mean in the finding here you're 

21 specifically talking about missed dose which is a 

22 badge that was read that has no recorded dose on 

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1 it.

2 DR. BEHLING: Yes, as I said, the fact 

3 is they subtracted background anyway. In which 

4 case you would almost have -- if a badge had nothing 

5 above the background -- I would see what they had 

6 were lots of film badges that were distributed to 

7 people as mission badges, et cetera and then there 

8 were badges that were also kept on location which 

9 were subject to fallout.

10 I read DNA reports on behalf of 

11 Operation Greenhouse where they processed some of 

12 the badges on locations that were subject to fairly 

13 high fallout and background radiation that was 

14 substantial.

15 And what they would then do, is take 

16 those badges that had not been assigned, use them 

17 as control badges and subtract the radiation that 

18 was -- the dose that was registered on the so-called 

19 control badges from those that were issued.

20 So, you would almost invariably end up 

21 with a dose that was zero if there wasn't any 

22 significant dose other than what was already 

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1 registered on the control badges subject to 

2 fallout.

3 CHAIRMAN LOCKEY: So, Jim, how do we 

4 handle -- this doesn't seem like you can answer this 

5 question, is that correct?

6 DR. NETON: I'm not sure where we go. 

7 I guess I'm still a little confused as to what the 

8 finding is here. I mean --

9 DR. BEHLING: Well, you know, the 

10 finding of it, Jim, is essentially was based on the 

11 following statement, I read Statement 5 on page 45 

12 that says assign missed doses based on the number 

13 of exchanges found in the dosimetry records.

14 Well, you know, that's the 

15 recommendation that applies to conventional DOE 

16 facilities where you have an exchange rate and 

17 there may be instances where in a person's 

18 dosimetry record you will find that there are doses 

19 that involve film badges or TLD badges that came 

20 back with zero.

21 In that which case you say, well, what 

22 was the LOD for that particular time frame for a 

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1 film badge? And you would say, well, it was 40 

2 milli-R and if it came back zero, you'd take the 

3 midpoint and assign him 20.

4 Well, that kind of policy doesn't work 

5 for PPG where the routine film badges were not even 

6 assigned on a routine basis. And therefore, you 

7 know, what you do is reduce the assigned doses when 

8 this guidance, as I read it to you, really just 

9 simply doesn't apply.

10 DR. NETON: Well, but the next sentence 

11 I think recognizes what you just said which it says, 

12 also compare the total of the recorded doses plus 

13 the missed dose to the 50 percent dose in Attachment 

14 A and assign the larger dose.

15 So that accommodates, I think, what you 

16 were just discussing is that we don't really know 

17 the missed dose very well so we'll look at the 

18 values in Attachment A and use the larger of the 

19 two numbers.

20 DR. BEHLING: Well, I can say it seems 

21 the two badges were worn, you know, I don't see that 

22 either as a probability since both badges were to 

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1 be worn at the same time, only one's there. I mean 

2 these people weren't assigned two badges.

3 You talk about a time frame when a 

4 full-time badge was assigned in addition to perhaps 

5 a specific task where they wanted to just in a very 

6 discrete way identify what was the dose associated 

7 with that particular task which would be recorded 

8 on both the full-time badge and the mission badge 

9 that was assigned simultaneously for that 

10 duration. That didn't occur until many, many 

11 years later.

12 MR. KATZ: So, it sounds like what Hans 

13 is saying is, is you might as well drop this 

14 guidance because there's nothing to implement 

15 here.

16 DR. BEHLING: Exactly, exactly.

17 MR. KATZ: Right.

18 DR. BEHLING: Yes, I think we should 

19 just simply ignore that guidance because I'm not 

20 sure you can do anything about that.

21 DR. NETON: Okay.

22 DR. BEHLING: So, I think we covered --

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1 MR. KATZ: So, I'm sorry, before we 

2 move on, does this cover Finding 7?

3 CHAIRMAN LOCKEY: So, the results are, 

4 we're going to ask NIOSH to drop this guidance. Is 

5 that correct?

6 DR. BEHLING: I think so. There's no 

7 way you can implement this guidance, at least not 

8 in the first ten or so years, from '46 to '56.

9 CHAIRMAN LOCKEY: Yes.

10 MR. KATZ: So, I think Jim just said 

11 okay to that.

12 MEMBER ANDERSON: Just dropping it and 

13 doing nothing, is that better than --

14 MR. KATZ: Well, there's nothing to do 

15 for that period, '46 to '56.

16 MEMBER ANDERSON: Oh.

17 MR. KATZ: Yes.

18 CHAIRMAN LOCKEY: All right, so we'll 

19 drop the NIOSH guidance from '46 to '56, but it's 

20 applicable after that, correct? Correct?

21 MR. KATZ: That, I'm not going to 

22 answer. I can't answer that but that sounds like 

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1 what Hans was --

2 MEMBER VALERIO: So, Ted, I have a 

3 question. Can you hear me?

4 MR. KATZ: Yes.

5 MEMBER VALERIO: Why the '56 date? I 

6 got lost on that when under Finding Number 3 it does 

7 say that on May 15th of 1955 and also for ten tests 

8 at the Pacific Proving Ground they were issued film 

9 badges? So, why the difference in the years? I 

10 got lost there between '55 and '56.

11 MR. ROLLINS: We should be able to 

12 start using that guidance with Wigwam which is in 

13 '55.

14 MEMBER VALERIO: Okay.

15 MR. ROLLINS: Everybody was 100 

16 percent badged at Wigwam and from there forward.

17 MR. STIVER: One thing to keep in mind 

18 for Wigwam is that really it wasn't in the PPG, it 

19 was about 400 miles south of San Diego and it was 

20 a deep water detonation, an underwater detonation 

21 for a one day event.

22 And so, you don't have this issue of 

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1 fallout. There wasn't mission badges versus 

2 permanent badges.

3 MEMBER VALERIO: Okay.

4 (Simultaneous speaking.)

5 MR. STIVER: Yes, in the NTPR program 

6 beyond '56, you know, we've run in to quite a few 

7 situations where there were zero readings and we've 

8 used the same approach, the half of the NDL. So, 

9 I think at that time, it's actually a situation 

10 where you deal with the detection limit of the 

11 badge. It's not a matter of what we see earlier 

12 where they're subtracting out really large fallout 

13 doses from the contaminated controls.

14 MEMBER VALERIO: Okay, thank you.

15 CHAIRMAN LOCKEY: So, Loretta, so were 

16 the dates between '46 to '54 or '46 to '55?

17 MEMBER VALERIO: See, I would say, well 

18 --

19 MR. STIVER: From an administrative 

20 standpoint, I would say up to '55 because at that 

21 point everybody's badged.

22 MEMBER VALERIO: Right.

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1 MR. ROLLINS: Yes, the middle of '55 is 

2 when they made a decision to badge everybody.

3 MEMBER VALERIO: Right, and that's the 

4 date that I'm looking at.

5 CHAIRMAN LOCKEY: All right, so drop 

6 the NIOSH guidance from '46 to June of '55 and 

7 except -- just drop it from '46 to June of '55. Is 

8 that an appropriate date?

9 MR. ROLLINS: Now, you're sticking up 

10 this guidance that we put in a response here?

11 CHAIRMAN LOCKEY: Yes, from looking at 

12 Finding Number 7.

13 MR. ROLLINS: Okay, now, what would we 

14 do up to June of '55? What would be your 

15 recommendation there?

16 CHAIRMAN LOCKEY: Well, what I heard 

17 from -- what I heard was that the NIOSH -- we really 

18 couldn't apply the NIOSH guidance to those earlier 

19 years. It would be impossible to do that, so why 

20 mention it?

21 MR. ROLLINS: I understand that, but 

22 how did we account for the dose?

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1 DR. BEHLING: Well, I agree, again, 

2 with the fact that it can't be applied when you 

3 don't offer a film badge dosimeter routinely on a 

4 monthly basis or whatever time and during the early 

5 years up until '55, '56, mission badges were 

6 issued.

7 And from mission badges, all background 

8 exposures were subtracted. So, you don't really 

9 have the option of saying what's a missed dose? I 

10 mean they were -- they only selectively assigned 

11 mission badges and from those, the background from 

12 fallout was subtracted anyway.

13 So, I think there is no way to even deal 

14 with missed dose because they don't exist. I mean 

15 missed dose is the only dose as we normally applied 

16 to those film badges or TLDs were the processing 

17 of that badge turns out to be a value that is below 

18 LOD, and that didn't exist there.

19 MR. ROLLINS: Okay, so, what I'm 

20 hearing is that we need to put a statement in the 

21 TBD that says prior to June of '55, missed doses 

22 cannot be reconstructed.

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1 DR. BEHLING: There are no missed 

2 doses. Yes, it can't be reconstructed since there 

3 are no missed doses. They didn't issue badges and 

4 then send them back and said, oh, your badge was 

5 below LOD and we record it zero. That doesn't 

6 exist. So, there's no point in injecting that.

7 MR. KATZ: Right, there's a 

8 distinction between it's not -- cannot be 

9 reconstructed is that they don't exist.

10 DR. BEHLING: They don't exist, 

11 exactly.

12 MR. ROLLINS: Okay. We can put that 

13 statement in there.

14 CHAIRMAN LOCKEY: But July 1st '55 on, 

15 we can do that?

16 DR. BEHLING: Yes.

17 CHAIRMAN LOCKEY: Okay.

18 MR. KATZ: So, is that good with all the 

19 Board Members?

20 MEMBER ANDERSON: Yes.

21 MR. KATZ: Okay. Okay, thanks. 

22 Hans?

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1 DR. BEHLING: Yes, and you know, I kind 

2 of garbled Finding Number 8.

3 I had mistakenly identified Finding 

4 Number -- I've got so many documents here on my desk 

5 it became very confusing.

6 But Finding Number 9 has already been 

7 addressed and that is the issue that we discussed 

8 under the issue of assigning zero to 40 millirem 

9 in cell one and 40 millirem of milli-R and 40 

10 milli-R to 1-R in cell two.

11 That was actually Finding Number 9, the 

12 last one and I'm looking at NIOSH's response and 

13 they said Attachment A will be revised to ensure 

14 the coworker dose approach follows the guidance of 

15 ORAU-OTIB-20 with respect to the treatment and 

16 inclusion of potential missed doses.

17 I guess that does address potential 

18 missed doses when you have that first cell in that 

19 calculational methodology on page 22 that says cell 

20 one was really zero.

21 Well, it's zero to some value up to 40 

22 millirem. And if I look at the guidance that was 

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1 issued in the -- let me just take a look here, go 

2 through my shelf here -- I mean I look at the film 

3 badge, there's symmetry in atmospheric nuclear 

4 tests that were done by the National Research 

5 Council, they at least consistently talk about a 

6 40 millirem LOD value.

7 I think that should be either amended 

8 so that the zero should be replaced with a solid 

9 zero to 40 millirem because that is the designated 

10 LOD value that is cited commonly for all operations 

11 during the atmospheric testing period in the PPG.

12 And so, the second cell should also 

13 then read instead of 0.01-to-1 R, it should read 

14 0.04-to-1 R, and therefore, any calculations as 

15 defined on page 22 that I'd previously shown to you 

16 in the -- that comes from Appendix A from the PPG 

17 Site Profile, that calculation methodology should

18 amend those cells that have zero in the first cell 

19 and then some value that is less than 40 millirem 

20 as the starting point for cell number two.

21 I'm not sure, does anybody -- everybody 

22 follow me or am I --

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1 DR. NETON: This is Jim, Hans. I don't 

2 think it'll make a huge difference in the --

3 DR BEHLING: No, it won't make a huge 

4 difference and I'm not sure, Jim, tell me what is 

5 OTIB-20 again?

6 DR. NETON: Matt Smith probably knows 

7 that better than I do.

8 MR. SMITH: Yes, this Matt Smith of 

9 ORAU team.

10 OTIB-20 is the, I'll call it kind of 

11 like guidance document, that sets forth the 

12 methodology to do external coworker analyses. It 

13 kind of gives the layout --

14 DR. NETON: It certainly includes the 

15 guideline on using missed dose in the calculation.

16 DR. BEHLING: Okay, okay. If a missed 

17 dose.

18 But, in this case, I think we can use 

19 real numbers because, as I said, according to the 

20 National Research Council and their study of all 

21 of the nuclear tests that were done in the PPG, they 

22 consistently cite 40 millirem as the LOD for the 

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1 film badges used, so you can use that.

2 So, cell one would then become 0.0 to 

3 0.04 R and the second cell from 0.04 to 1 R and then 

4 use that equation as defined on page 22 of my report 

5 would then apply than using the numbers that are 

6 currently identified for calculation.

7 It's a marginal difference admittedly.

8 CHAIRMAN LOCKEY: Okay, any other 

9 questions? So, then I see 8 and 9 similar, both 

10 in abeyance, is that correct?

11 DR. BEHLING: Yes, I think so.

12 CHAIRMAN LOCKEY: You like those 

13 numbers? Andy?

14 MEMBER ANDERSON: Yes, okay.

15 CHAIRMAN LOCKEY: Loretta?

16 MEMBER VALERIO: Yes.

17 CHAIRMAN LOCKEY: Before I give this 

18 up, anything else we need to cover today?

19 MR. KATZ: Hans?

20 DR. BEHLING: No, as I said, I think the 

21 major outstanding issue that I'm hoping we can 

22 resolve is the issue that's now going to be in the 

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1 hands of the DOL.

2 MR. KATZ: Right, right.

3 (Simultaneous speaking.)

4 MR. KATZ: And I understand that and I 

5 will copy the Work Group and SC&A, everybody as I 

6 do that as soon as I get the memo from SC&A to work 

7 with.

8 DR. BEHLING: Yes, and just -- if I can 

9 take a couple of minutes, I can at least offer 

10 something here with regard to that issue. Stop me 

11 if you think I'm, you know, talking out of hand here 

12 or out of turn.

13 But, you know, when you have even 

14 mission badges as was defined in the second 

15 bulletin, you can at least do one thing. One thing 

16 is for sure we do know, when a person is assigned, 

17 let's say, over a six month period, let's assume 

18 he was truly there for six months and he was 

19 assigned a mission badge.

20 Let's say he was there for March to 

21 September and he was assigned one mission badge in 

22 March and he was assigned a mission badge in 

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1 September or August sometime towards the end of 

2 that six month period.

3 One thing we do know, that that's a 

4 given, we don't have to be or make any assumptions 

5 that when people were assigned there, as I had 

6 mentioned to you before, the Marshall Islands is 

7 in a remote part of the world and in the 1940s, there 

8 was no commercial air flight there. There was no 

9 landing strips for commercial airlines. People 

10 were transported there by ship mostly, military 

11 ships and so forth.

12 And when they were there, if a person 

13 was there for six months and his first badge was 

14 assigned, let's say, in March, you can be very sure 

15 that person is there until the second -- at a 

16 minimum, the second badge was issued because they 

17 don't shuffle people around for a day trip or for 

18 a single assignment of a day task that involves a 

19 mission badge.

20 So, one of the things that should be as 

21 a minimum applied when, if in the end, we can only 

22 establish employment periods on site by virtue of 

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1 badges in the early days which would have involved 

2 mission badges, then at least accept the fact that 

3 any time interval between two successive missions 

4 badges that were assigned was also time spent on 

5 site. That, as a minimum, is just a no-brainer for 

6 me.

7 And so, if we have to assist the DOL on 

8 that issue in understanding that people weren't 

9 shuffled back and forth for a single day's worth 

10 of work where a mission badge was assigned, in all 

11 likelihood, that person was there the full duration 

12 between mission badges as a minimum and there may 

13 be times before and after the first and the last 

14 mission badge that he was there. But as a minimum, 

15 you can conclude that he was there between the time 

16 frame of two successive mission badges.

17 So, it's just, you know, a 

18 recommendation that I would at least pose to them 

19 if it turns out that they are really no other ways 

20 to establish employment periods at PPG if the only 

21 option is to use mission badges as they were issued 

22 during the earlier years of the PPG time frame.

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1 MR. KATZ: Right. Hans, if you just 

2 lay out everything as clearly as possible in the 

3 memo and I will get that to DOL.

4 DR. BEHLING: Will do.

5 MEMBER VALERIO: Okay, Ted, this is 

6 Loretta, I have a quick question.

7 MR. KATZ: Yes?

8 MEMBER VALERIO: What -- I don't know 

9 what the likelihood and it's kind of hard for me 

10 to wrap my mind around it, is say a cafeteria worker 

11 would be issued a mission badge, how are they 

12 verifying those employments for those claimants?

13 DR. BEHLING: Well, that's a good 

14 question. And then for people who were never 

15 monitored, you're kind of, you know, Holmes & 

16 Narver, I'm very familiar with Holmes & Narver, 

17 I've worked with some of those people, they have 

18 pretty good records in terms of employment.

19 But there were some people inclusive of 

20 Marshallese who were used oftentimes for doing 

21 menial kinds of things and I can guarantee you 

22 there's no employment records for those 

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1 individuals.

2 And I'm sure there were people who were 

3 hired at various locations for whom we don't have 

4 a documented employment record and they may not 

5 have been ever issued a single dosimeter.

6 Now, the question is, would they also 

7 be among the claimants who are at this point of 

8 concern? I don't know.

9 I mean I'm sure that any person among 

10 the Marshall Islands is who oftentimes did work for 

11 the AEC in those days. But, you know, I don't think 

12 you have any claims coming from that direction.

13 But there may be, as you just mentioned. 

14 A person who was there who provided food services 

15 and preparation of things like where he was never 

16 in a position where a mission badge was assigned 

17 to them. That's possible.

18 MEMBER VALERIO: Right, but they still 

19 -- there was a potential of exposure to fallout.

20 DR. BEHLING: Absolutely. As I had 

21 mentioned, just for Operation Greenhouse, if a 

22 person had stayed at any of those four locations 

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1 for the period of April and May, two months, he 

2 would have potentially been exposed to around 4 rem 

3 and that dose -- that exposure is not recorded 

4 anywhere other than in a reproduced document that 

5 DNA put out in 1982.

6 And if he can prove he was there, he 

7 would obviously be in a position to take credit for 

8 that exposure. But the fact is, is there any 

9 record for that individual at this point in time? 

10 I don't know.

11 MEMBER VALERIO: Okay.

12 CHAIRMAN LOCKEY: Good question. I 

13 don't know, how do we handle that, Ted?

14 MR. KATZ: Well, there's nothing to 

15 handle here, I mean, really. This is -- the DOL 

16 will have as much information as they have 

17 available to make these, you know, 83 day 

18 determinations and that'll be that. That's really 

19 their territory.

20 So, all we can do is give them some 

21 guidance on for the information they have 

22 available, how to use it and that's what we'll be 

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1 doing. But there's -- it's a DOL issue, it's 

2 really, it's not our issue and it's -- you can't 

3 -- there's nothing to be done in the absence of 

4 information, I mean for some situations.

5 I don't how DOL handles that and, you 

6 know, guys, you're welcome to inquire with DOL how 

7 they handle that but it's really, it's not 

8 something for the Board to struggle over.

9 CHAIRMAN LOCKEY: Okay. Any other 

10 questions or issues that somebody wants to raise?

11 Okay, the action forwarded then is, 

12 what, wait until hear back from DOL?

13 MR. KATZ: Yes, I will copy you on my 

14 correspondence with them including their response 

15 and then you'll get to see what goes on there.

16 And it's been a lot of time since, you 

17 know, since Hans did the review in the first place 

18 and, who knows, you know, what DOL is doing right

19 now anyway.

20 So, you know, they may already be doing 

21 things that have sort of remediated the situation. 

22 I have no idea.

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1 CHAIRMAN LOCKEY: Very good. 

2 Anything else we need to cover today?

3 MR. KATZ: No, but I want to thank --

4 I thought this was very efficient and great job on 

5 everybody's part. So, I just want to thank you all 

6 for that.

7 CHAIRMAN LOCKEY: I concur, thank you, 

8 everybody for their time and effort.

9 DR. BEHLING: Thank you.

10 MR. KATZ: And have a good weekend. 

11 Have a good holiday weekend.

12 CHAIRMAN LOCKEY: You too. Take care, 

13 bye-bye.

14 MEMBER VALERIO: Bye.

15 MR. KATZ: Take care. Bye-bye.

16 (Whereupon, the above-entitled matter 

17 went off the record at 3:34 p.m.)

18

19

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