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1 

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH 

+ + + + +

ADVISORY BOARD ON RADIATION AND

WORKER HEALTH 

+ + + + +

WORK GROUP ON SEC ISSUES

+ + + + +

WEDNESDAY

MAY 27, 2015

+ + + + +

The Work Group convened via telephone 

at 10:00 a.m. Eastern Time, JAMES M. MELIUS, 

Chairman, presiding.

PRESENT:

JAMES M. MELIUS, Chairman

JOSIE BEACH, Member

GENEVIEVE S. ROESSLER, Member

PAUL L. ZIEMER, Member

NEAL R. GROSS

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2

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ALSO PRESENT:

TED KATZ, Designated Federal Official

BOB BARTON, SC&A

MILTON GORDEN, SC&A

JENNY LIN, HHS

JOHN MAURO, SC&A 

DAN MCKEEL

JIM NETON, DCAS

JOHN RAMSPOTT

JOHN STIVER, SC&A
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3

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A-G-E-N-D-A

Welcome and Roll Call ......................... 4

Discussion

Dow Chemical Company - Madison, Illinois 

Facility Technical Basis Document (TBD-6000 

Appendix C) Review ............................ 6

Public Comment ............................... 34

Status of Guideline Development for Co-Worker

Dose Models ................................. 40
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4

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

2 10:00 a.m.

3 MR. KATZ: Welcome, everyone. This is 

4 the Advisory Board on Radiation Worker Health SEC 

5 Issues Work Group.

6 The Work Group is dealing with two 

7 matters, or mostly one, Dow Madison Appendix C of 

8 TBD-6000 review by SC&A. 

9 And then we're just going to catch up 

10 on status of matters with respect to coworker 

11 models at the end of this meeting.

12 Since we're talking about a work site 

13 let's get conflict of interest from agency staff. 

14 Let me respond to Board Members. None of the Board 

15 Members have any conflicts with Dow so we can 

16 dispatch with that.

17 And for the record, we have our Chair 

18 and all our Work Group Members online, present.

19 So, let's go -- oh, and I should mention 

20 on the website is the agenda for the meeting today. 

21 So it's on the NIOSH website under the EEOICPA part 
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1 of the website, Board section, meetings, today's 

2 date.

3 And both the agenda and the SC&A review 

4 of the Dow Madison TBD are posted there on the 

5 website.

6 So, let's go on to attendance for staff 

7 members starting with the NIOSH ORAU team.

8 (Roll call)

9 MR. KATZ: Okay, then. We have 

10 attendance and I think we've covered everything.

11 Please mute your phones, everyone, 

12 except for whoever might be addressing the group. 

13 And press *6 if you don't have a mute button to mute 

14 your phone. Press *6 again to take your phone off 

15 of mute.

16 And Jim, it's your meeting.

17 CHAIRMAN MELIUS: Okay, thanks Ted. 

18 And Jim Neton, it looks like we have you outnumbered 

19 today. But we know you'll do well.

20 DR. NETON: I hope so.

21 CHAIRMAN MELIUS: And my understanding 
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1 from my correspondence with you is that there's no 

2 written response from NIOSH or ORAU to the SC&A 

3 review, but you are prepared to address the issues 

4 raised by SC&A. 

5 It's really up to you and SC&A how you 

6 want to -- what's the easiest way to do this.

7 Jim, if you want to go through, I think 

8 there's a total of two findings and five 

9 observations in the SC&A review. If you want to 

10 lead through them that might be the easiest way and 

11 most efficient way of doing it.

12 DR. NETON: Yes, I think that makes 

13 sense. I think there's only -- yes, there are five 

14 observations. You're right.

15 It might make some sense if SC&A would 

16 just sort of put their position for each one on the 

17 table and I can respond in kind.

18 CHAIRMAN MELIUS: That would be fine 

19 also. So I don't know who's speaking for SC&A?

20 DR. MAURO: This is John Mauro. I 

21 worked very closely with Milton on this review so 
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1 I guess I'll kick it off.

2 CHAIRMAN MELIUS: Okay.

3 DR. MAURO: And Milton, please help me 

4 out. I know that you did a lot of the heavy lifting 

5 also. 

6 And Bill Thurber was involved also in 

7 a consultative capacity. Unfortunately I guess 

8 he's not joining us today, but we'll move forward.

9 The first finding has to do with the 

10 classic resuspension factor issue. And it's an 

11 interesting issue. Let me explain.

12 During operations, 1957 through 1960 

13 where was the uranium machining going on, the way 

14 in which the internal doses were derived was the 

15 classic TBD-6000 approach which are based on the 

16 Adley data which gives you information on dust 

17 loadings for different types of machining 

18 operations.

19 And it's empirical data. In other 

20 words, it's what they measured.

21 So in one strange respect we said, geez, 
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1 I wonder why they put in resuspension factors. You 

2 do that when you're modeling it. But when you 

3 actually have real data, in this case the Adley 

4 data, the TBD-6000 data, that in effect reflects 

5 anything that's in the air, whether it's from 

6 direct airborne from machining or from 

7 resuspension.

8 So, our first reaction was you really 

9 don't need to do that, that is add in the 

10 resuspension portion because it's effectively 

11 already there from the empirical data.

12 But then on closer inspection maybe it 

13 was okay to do that, and stay with me for a minute 

14 on this.

15 During the operations period, '57 

16 through '60, you really could break it up into two 

17 time periods.

18 There was the 1957-58 where they were 

19 doing one type of operation. And then '59 and '60 

20 where they were doing another type of operation. 

21 So two different types of operations, so two 
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1 different sets of empirical data from TBD-6000 were 

2 used to reflect the two different types of 

3 machining operations.

4 When you get to the second one you ask 

5 yourself the question, okay, you're in the second 

6 half. That might have been the extrusion part, I 

7 forget. It was a different operation than in '59 

8 and '60.

9 You say, okay. I go into TBD-6000. I 

10 pull out the airborne dust loading, and I get a 

11 concentration, and I do my inhalation dose 

12 calculations.

13 Then you say well, wait a minute, hold 

14 it. In '57 and '58, preceding that time period, 

15 there was already residual radioactivity on the 

16 ground from those first two years of operations.

17 So, in a way that would add, in other 

18 words it would add to the contribution to airborne 

19 dust loading that occurs a little bit later in '59 

20 and '60.

21 So, in sort of a circuitous way we went 
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1 through a process saying I wonder why they put that 

2 in.

3 And then it dawned on us well, maybe 

4 that was a good idea, and certainly it's 

5 claimant-favorable.

6 That being the case -- I'm sorry for the 

7 long story, but I want you to understand 

8 conceptually.

9 That being the case our first finding 

10 is well, if you're going to do that, wouldn't you 

11 want to use a resuspension factor of ten to the 

12 minus five? Because it's sort of like an active 

13 environment. So that was our first finding. 

14 Wouldn't it have been better to use ten to the minus 

15 five and not ten to the minus six per meter. So 

16 that's finding number one.

17 And I guess it's good at this point to 

18 sort of hand it over to Jim and see what his thoughts 

19 are.

20 DR. NETON: Okay, thanks John. I 

21 think the situation here is actually a little 
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1 simpler than you think.

2 The nature of this operation was that 

3 it only occurred for 21 days out of 250 work days. 

4 So, the resuspension that we're using 

5 is actually resuspension for the additional work 

6 days that were there after the 21 days out of 250.

7 DR. MAURO: Ah okay, okay.

8 DR. NETON: So you don't have a 

9 continuous operation here. You've got the 21 

10 days' worth of project work and then regular work 

11 going on. And clearly there could have been some 

12 resuspension from the 21 days of operation.

13 DR. MAURO: So there are these windows 

14 at each campaign so to speak.

15 DR. NETON: Exactly.

16 DR. MAURO: I've got you. Okay, good, 

17 thank you. Got that clarified.

18 DR. NETON: And we treated those 

19 separately. 

20 And in fact, what we did was we assumed 

21 that the deposition occurred on the first day 
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1 instantaneously of each two-year period. So it's 

2 fairly claimant-favorable in that respect. We 

3 didn't bother to integrate it over time.

4 And on top of that I think the thinking 

5 behind using ten to the minus six versus ten to the 

6 minus five.

7 And actually, there's a -- this is in 

8 TIB-70. TIB-70 is talking about the residual 

9 period. This is actually during the operational 

10 period.

11 DR. MAURO: Yes.

12 DR. NETON: But the ten to the minus six 

13 has been the default. And then we would need to 

14 justify why that wouldn't be appropriate.

15 And in this situation, as I said, there 

16 was 21 days' worth of work. What they did, and if 

17 you look there's a contract out there on the Site 

18 Research Database, number 10273 which is the 

19 contract between Mallinckrodt and Dow.

20 This work was done on behalf of 

21 Mallinckrodt under contract. It was written in 
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1 1957.

2 And they defined in that contract a 

3 28-hour work cycle. And the work cycle was such 

4 that at each work cycle there would be 6 hours of 

5 setup time, 16 hours of extrusion, and then 6 hours 

6 of cleanup time. 

7 So, after every single operation there 

8 was 6 hours of cleanup. So we felt that after they 

9 cleaned up the operations sure there could have 

10 been some residual much as it probably fixed, and 

11 the resuspension factor of course only applies to 

12 loose contamination. Therefore, I think the ten 

13 to the minus six is appropriate here.

14 DR. MAURO: Jim, I have to agree with 

15 you given that you have this record of cleanup after 

16 each campaign.

17 DR. NETON: So then after that the 

18 place is essentially -- I wouldn't say it's clean 

19 clean, but it's definitely been cleaned to the 

20 point where they removed all the loose material.

21 DR. MAURO: It's not an unreasonable 
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1 assumption. 

2 DR. NETON: And in fact, I think as you 

3 pointed out, even so, the resuspension is a fairly 

4 minor, minor component of the intakes that are 

5 being assigned from the extrusion operation which 

6 in -- well, the extrusion operation in 1957 and '58 

7 I think the air concentration was 553 dpm per cubic 

8 meter, but it has a GSD of 5 on it like we do with 

9 all these TBD-6000. 

10 So the upper end of that distribution 

11 is almost 8,000 dpm per cubic meter versus some 

12 trivial amount of resuspension.

13 DR. MAURO: Yes, it varied the 

14 resuspension contribution. I understand.

15 DR. NETON: Right. Okay.

16 DR. MAURO: This is John. And from my 

17 perspective Jim has thoroughly answered the 

18 question to my satisfaction.

19 CHAIRMAN MELIUS: Any Board Members 

20 have questions on that issue?

21 MEMBER ZIEMER: This is Ziemer. I 
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1 think that's very helpful. Jim's explanation 

2 clarified that to me. That was very helpful.

3 CHAIRMAN MELIUS: Great. Josie or 

4 Gen, anything to add?

5 MEMBER ROESSLER: No, that explains it 

6 for me.

7 MEMBER BEACH: For me too. I don't 

8 have any questions.

9 CHAIRMAN MELIUS: Okay, thank you.

10 DR. MCKEEL: Dr. Melius, this is Dan 

11 McKeel.

12 CHAIRMAN MELIUS: I'm sorry, it's not 

13 public comment period. We'll give you time at the 

14 end. So I'd ask you not to interrupt, please.

15 DR. MCKEEL: Thank you.

16 CHAIRMAN MELIUS: Okay, Jim, I don't 

17 know what -- how you want to do this, in what order, 

18 but Jim Neton, do you want to go on?

19 DR. NETON: Yes. I think SC&A maybe 

20 could discuss the nature of finding 2 and then I'm 

21 prepared to discuss that as well.
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1 CHAIRMAN MELIUS: Okay.

2 DR. MAURO: I'm going to pass this one 

3 onto Milton. It has to do with some tabulated 

4 material.

5 Milton, are you in a position where you 

6 could address this particular issue? Because I 

7 don't recall my bringing this particular one up.

8 MR. GORDEN: Okay. This has to do with 

9 a calculation performed in TBD-6000 in Section 

10 7.1.5 of TBD-6000.

11 There's a calculation in regards to the 

12 surface contamination concentration. 

13 In TBD-6000 they calculate using 7,000 

14 dpm per cubic meter. They calculate a surface 

15 contamination of -- I'm sorry -- yes, surface 

16 contamination of 1.47 times ten to the eight 

17 picocuries per square meter.

18 And in order to duplicate it what I did 

19 was I converted the 7,000 dpm per cubic meter 

20 multiplying it by the deposition factor of 7.5 

21 times ten to the minus four meters per second. And 
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1 then converted from 30 days down to the second.

2 And in my report on page 13 is kind of 

3 where I summarize that. And I come up with a value 

4 of 6.1 times ten to the 6 dpm per square meter.

5 Now, I realize the units are different. 

6 I calculated dpm per square meter and in TBD-6000 

7 it's picocuries per square meter.

8 I just thought it was very interesting 

9 that the difference was almost a factor of -- or 

10 exactly a factor of 24.

11 And so I didn't know whether there were 

12 some conversion issues going on there. 

13 But, be as it may, if I keep apples to 

14 apples and compare picocurie per square meter to 

15 picocurie per square meter I still come up with a 

16 difference. 

17 I come up with a 1.36 times ten to the 

18 seven picocuries per square meter as compared to 

19 the 1.47 times ten to the eight picocuries per 

20 square meter, which is a factor of between 10 and 

21 11.
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1 And so I didn't know if there was -- I 

2 could be miscalculating, but I didn't know if 

3 there's an error in TBD-6000 that would then affect 

4 Appendix C numbers.

5 And that's -- I guess are there any 

6 questions?

7 CHAIRMAN MELIUS: Jim Neton?

8 DR. NETON: Yes, I can comment on that. 

9 SC&A is absolutely correct. There is 

10 an error in that calculation in TBD-6000. And in 

11 fact, I think 24 hours per day was entered into the 

12 calculation twice inadvertently.

13 But that calculation in Section 7.1.5 

14 of TBD-6000 was an example that assumed that one 

15 had 100 MAC or 7,000 dpm per cubic meter air. Sort 

16 of indicating if you didn't know anything else, 100 

17 MAC air, use it and that's what you would get.

18 I'm not even aware that that number has 

19 been used in any calculation. But it's certainly 

20 not used in Dow Appendix C. So even though the air 

21 is -- we acknowledge there is an error in that 
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1 number it wasn't used in the Appendix that's been 

2 reviewed. 

3 I'm not sure how to handle that. We do 

4 need to fix that, but it was not an Appendix C issue.

5 CHAIRMAN MELIUS: I guess we refer it 

6 back to Dr. Ziemer.

7 MEMBER BEACH: That's what I was going 

8 to say too.

9 MEMBER ZIEMER: Well, if you're not 

10 using it in the Appendix. So it's just an error.

11 This is basically, Jim, that you were 

12 using as 100 MAC, was it not?

13 DR. NETON: That's correct.

14 MEMBER ZIEMER: So, we have this 

15 information in the record here. I guess I would 

16 defer to Ted in terms of administratively how you 

17 handle that.

18 MR. KATZ: I think we can just, since 

19 we have this finding it's sort of independent of 

20 this review in a sense.

21 But we can get this put in the BRS and 
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1 then just follow up to make sure there's closure 

2 at the end.

3 But I guess the folks at NIOSH need to 

4 figure out if this calculation isn't used for any 

5 site then I'm not sure why it's even -- whether it 

6 matters at all, and whether we need to close it.

7 DR. NETON: Right. I mean, we may have 

8 to close it by just removing that example 

9 calculation.

10 MR. KATZ: I think the TBD-6000 Work 

11 Group anyway can just -- that is the right place 

12 to just drop this. 

13 And at whatever point NIOSH figures out 

14 whether they're going to remove it or whatever they 

15 can report back and then they can close that 

16 finding.

17 DR. NETON: Well, I think I'm going to 

18 pass this over to Lori Marion-Moss on our side. 

19 And she's the keeper of that database for us. And 

20 see how she wants to enter it in there and notify 

21 Wanda that it's been entered.
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1 MR. KATZ: Okay.

2 DR. NETON: I think that's the best 

3 way. That seems to me the easiest way to go.

4 MR. KATZ: Sure.

5 DR. NETON: Okay.

6 CHAIRMAN MELIUS: How do you want to 

7 handle the observations, Jim?

8 DR. NETON: Oh, I'm sorry, I was on 

9 mute. I can probably just go over them. Then if 

10 SC&A has any questions on my response. Because 

11 they tend to be a little easier than the others do.

12 CHAIRMAN MELIUS: Okay.

13 DR. NETON: Observation 1 is actually 

14 related to finding 1 which says separate 

15 resuspension values in the operational period are 

16 not necessarily what the air sampling data would 

17 account for.

18 I think we discussed that and the 

19 rationale behind why we thought we needed them.

20 DR. MAURO: This is John and I agree.

21 DR. NETON: Yes. So I think that one 
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1 was simply dealt with.

2 This observation 2 is a little 

3 trickier, but it has to do with the assumptions that 

4 were made to assign resuspension during the 

5 residual period which begins in 1961.

6 And the gist of the finding was that the 

7 table group seemed to follow the laborer category. 

8 It's supposed to be 50 percent of the worker 

9 category and it's not.

10 And the reason for that is because the 

11 resuspension factor was actually sort of a combined 

12 average of the two periods, 1957 and '8, period 1, 

13 and 1959 and '60 as period 2.

14 And so in 1959 they pulled the data out 

15 of Table C.2. I think it's Table C.2. Bear with 

16 me here. I have six documents open on my table 

17 here.

18 It wasn't Table C.2. It was Table 7.2 

19 out of TBD-6000. 

20 So, Table 7.2 of TBD-6000 talked about 

21 the air sampling data for facilities that extrude 
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1 uranium rod which is what occurred in 1957 and '58.

2 And the general labor category is what 

3 we would use for labor. And if you look on Table 

4 7.2 the value assigned there is 147 dpm per cubic 

5 meter. That's what we used for the first two 

6 years.

7 In the second two years we used the data 

8 from Table 7.7. And the data there indicates --

9 the general labor daily weighted average was 845 

10 dpm per cubic meter.

11 So, if you calculate the total value 

12 that's resuspended based on most air 

13 concentrations you end up with the value that we 

14 have for the general laborer in the column.

15 But it's a hybrid of those two data 

16 points, not one table or the other that SC&A seems 

17 to be assuming.

18 I don't know if there's any questions 

19 on that. I've done the math, it works out. I 

20 think the number is correct.

21 DR. MAURO: This is John. I think that 
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1 explains it to our satisfaction.

2 DR. NETON: It's a hybrid of the two 

3 tables. And you have to pull the laborer data out 

4 of each table separately and calculate the total 

5 amount that would be on the ground and then inhaled 

6 in 1961.

7 DR. MAURO: Yes, we didn't do that, and 

8 that explains it. Thank you. 

9 DR. NETON: All right. And then 

10 observation 3 is the header for Table C.5 which does 

11 have an error. We acknowledge that and we'll fix 

12 it.

13 The table refers to inhalation and it 

14 should be listed as ingestion. 

15 The main table itself, the header is 

16 correct. If you look at the table, the C.5 says 

17 ingestion intake for uranium. But then if you look 

18 on the table itself where it gives dpm per day it 

19 refers to inhalation and that's clearly a cut and 

20 paste error. That should say ingestion. 

21 And we will certainly fix that. That's 
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1 on us to fix.

2 And then observation 4 has to do with 

3 the thoron concentration. And that's really more 

4 of an explanatory issue.

5 The values in the table are actually 

6 correct, but what we say in the document, in the 

7 Appendix C is that the values were based on those 

8 in Addendum 2 to the Evaluation Report.

9 And in fact, if you look at the 

10 Evaluation Report Addendum 2, the 95th percentile 

11 value, the geometric mean is correct and the 

12 geometric standard deviation is correct, but the 

13 calculation of the 95th percentile is incorrect.

14 And that was identified earlier on by 

15 SC&A in the review of the addendum. So we've used 

16 the correct value here -- calculated the correct 

17 95th percentile value. So it doesn't match the 

18 95th percentile in Addendum 2, but that value is 

19 actually incorrect.

20 So, I don't think there's anything to 

21 fix here other than maybe -- it didn't seem 
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1 appropriate to go into a discussion in the Appendix 

2 as to why the 95th percentile in Addendum 2 was 

3 actually incorrect. I guess that's a judgment 

4 call. 

5 And that's an observation anyway. We 

6 can add some language if need be to support that. 

7 Or maybe just put the calculation in there to show 

8 how it was done.

9 MR. GORDEN: This is Milton from SC&A. 

10 Yes, I think it would just -- I was looking at it 

11 more as just a referencing issue.

12 DR. NETON: Right.

13 MR. GORDEN: I don't know if you need 

14 your report so you can reference to the SC&A review 

15 report or not. So that I guess would be one option 

16 to fix it.

17 DR. NETON: It might be cleaner I think 

18 if we just said that the geometric mean and 

19 geometric standard deviation is this which is 

20 what's correct in that table.

21 And then if you calculate the 95th 
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1 percentile which is the GSD to the 1.645 power times 

2 the geometric mean, show that calculation, you come 

3 up with the right number.

4 That's what doesn't track in the 

5 Addendum. They're sort of separate.

6 But that to me is something that we can 

7 fix. It doesn't have to be fixed right away 

8 because the number itself is correct. It doesn't 

9 change any of the calculations.

10 DR. MAURO: This is just a housekeeping 

11 issue. I don't think how it's resolved, whatever 

12 is most expedient.

13 DR. NETON: I think when we go in to 

14 change the header. We're probably not going to 

15 reopen the whole document right now, but the next 

16 time we change it we'll change that one header and 

17 maybe put in that equation to make it clearer how 

18 that 95th percentile value was generated.

19 I don't think we're going to issue a 

20 revision just for that reason at this point.

21 And if that's okay then observation 5 
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1 talks about Section 250 to be updated correctly for 

2 Table C.7, 8 and 9. 

3 We agree. It's a typographical error 

4 so we can correct it in the next revision.

5 The observations I think were pretty 

6 straightforward. So that's all I have to comment 

7 on. If there's any discussion I'd be happy to 

8 answer any questions.

9 CHAIRMAN MELIUS: Any Board Members 

10 have any comments or questions for Jim?

11 MEMBER ROESSLER: This is Gen. Am I 

12 off of mute?

13 CHAIRMAN MELIUS: Yes, you are. We 

14 can hear you.

15 MEMBER ROESSLER: Good. I forget 

16 whether I'm on or off often.

17 I would like to -- on finding 2, all the 

18 others SC&A said okay, we agree.

19 And on finding 2 I guess I'd just like 

20 to have a verbal statement from John or someone that 

21 there was an error. However, it's not important 
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1 because it's not used in Appendix C so everything 

2 is okay on that one.

3 DR. MAURO: I'm going to have to defer 

4 to Milton because I didn't personally check this 

5 number.

6 And the explanation certainly sounded 

7 reasonable. Milton, are you comfortable with that 

8 explanation?

9 MR. GORDEN: Yes, yes, I'm comfortable 

10 with that.

11 MEMBER ROESSLER: Okay, good.

12 MR. GORDEN: I did have a question on 

13 -- going back to Table C.4. I'm just thinking off 

14 the top of my head here.

15 Being the approach that you take in 

16 Table C.4 in determining the labor inhalation rate, 

17 would that change the approach taken in Table C.5 

18 for the ingestion?

19 Because in ingestion the labor is 50 

20 percent of the operator. So I don't know if it 

21 should really mirror the ratio that's used for the 
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1 inhalation too.

2 DR. NETON: Good question. I haven't 

3 looked at that table.

4 MR. GORDEN: C.5 does explicitly rely, 

5 I believe, on I think it's C.1. 

6 DR. NETON: 1961. The ingestion is 

7 based on this 20 percent of the observed air 

8 concentration. 

9 MR. GORDEN: Right.

10 DR. NETON: So, no, that number would 

11 be correct because ingestion is not based on the 

12 daily weighted average of the -- it's 20 percent 

13 of the actual air concentration in the plant. 

14 Right? The 0.2.

15 I'd have to go back and look at that. 

16 I don't know. I didn't look at that in any detail.

17 MR. GORDEN: Okay. Well, you're 

18 probably right, I just, just off the top of my head 

19 when you were giving the explanation for the 

20 inhalation in C.4 I didn't know whether you're 

21 ingesting -- I guess I have to think about it too 
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1 because it's been awhile since I looked at a couple 

2 of these tables.

3 DR. NETON: I didn't look at the 

4 ingestion path because it didn't come up. 

5 But certainly, I think C.4 for 

6 inhalation is fine.

7 Ingestion is calculated somewhat 

8 differently, but I'd have to go back and refresh 

9 my memory as to how those categories are 

10 apportioned. So I can't answer that question 

11 right now.

12 DR. MAURO: Jim, this is John. In a 

13 related matter when I was rereading this document 

14 this morning one of the thoughts that came to me 

15 was the ingestion during the residual period.

16 As you may recall, we ran into the 

17 circumstance before where you really can't use the 

18 0.2 approach, the OTIB-009 I believe it is approach 

19 for the residual period.

20 You have to go to what I call the Charlie 

21 Yu approach, the hand to mouth approach for 
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1 ingestion.

2 Just a question, really. This is not 

3 a finding or a comment or anything. 

4 But when you did the residual period 

5 ingestion did you use the 0.2 approach? Because 

6 I thought we've already discussed that and that 

7 would have been problematic. I don't know if 

8 you're following.

9 DR. NETON: No, the 0.2 approach is 

10 okay here, John, because you've got a source 

11 generator that's depositing material, you know, we 

12 have an airborne concentration that's based on a 

13 source generation -- generating a source, source 

14 term.

15 DR. MAURO: Okay.

16 DR. NETON: Where that falls apart in 

17 the 0.2 is if you're getting an airborne based on 

18 resuspension.

19 The resuspension here is based on the 

20 airborne that deposited the material in the first 

21 place. I think it's okay.
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1 DR. MAURO: Okay. I have to admit I'm 

2 having a little trouble making the distinction, but 

3 I'll take another look at that.

4 Like I said, this was something that 

5 came to mind while I was reading it. And I thought 

6 we may have had the same circumstance.

7 So you're saying there's a nuanced 

8 difference between the other case where we 

9 encountered this problem in this case.

10 DR. NETON: Yes.

11 DR. MAURO: Okay.

12 CHAIRMAN MELIUS: Any other questions 

13 or comments? 

14 MEMBER ZIEMER: Just a question. This 

15 is Ziemer. What is the resolution going to be on 

16 this question that was raised, that Gordon raised? 

17 Is Jim going to go back and look at something?

18 DR. NETON: Yes, I think I need to go 

19 back and look at Table C.5 and verify that the 

20 laborer intake calculation was done properly.

21 MEMBER ZIEMER: Well, I'm wondering 
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1 since this isn't a finding maybe at some point Jim 

2 can just let the Work Group know what the finding 

3 is, and maybe get a confirmation from Gordon that 

4 SC&A is comfortable with that.

5 CHAIRMAN MELIUS: Yes, I was about to 

6 suggest the same thing, Paul. I think that makes 

7 sense to do that.

8 Okay with that? So when you have the 

9 opportunity, Jim, if you could do that. 

10 DR. NETON: That shouldn't take too 

11 long.

12 CHAIRMAN MELIUS: Yes, fine. If no 

13 one else has comments I believe, Dan McKeel, you 

14 wanted to say something?

15 DR. MCKEEL: Dr. Melius, yes, thank 

16 you. I just have a couple of comments.

17 The one is about finding number 1. And 

18 the discussion this morning concerns the fact of 

19 the lower ten to the minus six resuspension factor 

20 being appropriate because there's a cleanup the 

21 various extrusion and rod-straightening 
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1 campaigns.

2 Well, the rod straightening probably 

3 leads to very little dust accumulation and 

4 resuspension. 

5 But I think there is abundant evidence 

6 on the record for Dow Madison that it's a completely 

7 different story for the extrusions.

8 To do the extrusions for both uranium 

9 and thorium of course they had to be heated to very 

10 high temperatures. 

11 Then it went through the extrusion 

12 presses which there were numerous -- nine I think 

13 at the plant.

14 The very key factor here is that, unlike 

15 lots of other plants, there were no vacuum hoods 

16 installed in the extrusion building at Dow Madison 

17 to collect the fumes, the gases, and so forth.

18 And so if one postulates that all of the 

19 dust from the extrusions was cleaned up there is 

20 an unchallengeable fact that shows that that's 

21 simply not true.
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1 And that is that there was a FUSRAP 

2 cleanup of that site, particularly confined, 

3 really, to the extrusion building.

4 And a finding -- that was in the year 

5 2000, now. So decades later they're cleaning up 

6 this building and they find mixed -- admixed 

7 thorium and uranium residues in the rafters up 

8 above the extrusions, way up above the extrusion 

9 presses.

10 And many operators of those extrusion 

11 presses gave testimony that there was a tremendous 

12 amount of dust and fumes being kicked up during 

13 those operations. 

14 So, the idea that some cleanup 

15 operation, I think the cleanup operation that 

16 they're talking about was picking up the extrusion 

17 fragments and scraps off the floor, probably 

18 scraping them into a wastebasket or something.

19 But I don't think there was any cleanup 

20 of the dust hosed down and things like that, and 

21 there certainly weren't any vacuum hoods.
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1 So, I just think that's an incorrect --

2 all the assumptions that you all mentioned this 

3 morning are belied by the fact that there was 

4 significant dust in the rafters that led to the 

5 FUSRAP cleanup. That's the whole point of the 

6 cleanup.

7 Now, what's interesting in the cleanup 

8 is, of course, they cleaned up the uranium, but they 

9 felt like the thorium was all from commercial 

10 operations and therefore the FUSRAP team did not 

11 touch the contaminating thorium which was still in 

12 the rafters in 2006 when Pangea Group came and 

13 finally cleaned up some of that other contaminating 

14 material.

15 So, I think for finding 1 I believe that 

16 10 to the minus fifth should be used.

17 And since extrusion of various metals 

18 went on after 1960, you know, there was still a lot 

19 of dust going on. And I understand that that would 

20 not be uranium, presumably.

21 The other point I wanted to point out 
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1 is my problem with Appendix C Rev 1 and the NIOSH 

2 comments about it today, and the SC&A review of it 

3 back in April of 2014 is that there were a lot of 

4 -- if you look on page 1 of Appendix C Rev 1 in that 

5 record of issue revisions you'll see there, and I'm 

6 going to read this. It's very short, but it's very 

7 important.

8 And it says that the characteristics of 

9 Rev 1 were it was revised to incorporate changes

10 made during the revision to the base document 

11 TBD-6000. 

12 And one of those -- there really weren't 

13 mentioned this morning exactly what was included.

14 But the revisions include changes to 

15 inhalation values during uranium operations, 

16 increased photon dose from contamination based on 

17 30-day deposition, and added beta dose values based 

18 on contamination. 

19 Residual period uranium inhalation 

20 values increased. The OTIB-70 technique was used 

21 during the residual period. 
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1 And finally, it says the basis for 

2 residual period ingestion values changed to use 

3 operational period airborne value and TIB-009 for 

4 the first year.

5 Now, my opinion is that it was SC&A's 

6 job to review all of those touted changes that 

7 characterized Appendix C Rev 1 and I don't think 

8 that was really done. 

9 I don't think it was done in the written 

10 review. I don't think it was done today in this 

11 discussion.

12 So, I certainly think the record is 

13 really incomplete on this Appendix where the 

14 overview if you will says that there are a number 

15 of changes made that might increase the dose, and 

16 yet we all know that when the PER-058 was issued 

17 for this Appendix C Rev 1 it reviewed 80 cases from 

18 Dow and none of the PoCs changed to be equal to or 

19 greater than 50 percent.

20 So I think to be fair to those workers 

21 whose compensation was at stake, that the SC&A 
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1 review should include all those factors.

2 In other words, they ought to go through 

3 those changes that I've mentioned and 

4 systematically state yes, we agree with NIOSH that 

5 these changes were appropriate and that the 

6 calculations are done correctly and so forth.

7 And to me, what they actually came up 

8 with was one finding which I think is based on 

9 incorrect assumptions as being closed and okay to 

10 stand as is at ten to the minus six instead of ten 

11 to the minus fifth.

12 I think ten to the minus fourth could 

13 be considered when you realize that there was so 

14 much uranium left in the year 2000 on the rafters 

15 above those extrusion presses.

16 Regardless of how many days it was used 

17 that physical amount of uranium was still all over 

18 the roof beams of that plant. 

19 So I guess that's where I would leave 

20 it, and I thank you very much for letting me chime 

21 in.
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1 CHAIRMAN MELIUS: Okay. Thank you, 

2 Dan. Any further follow-up on the Appendix C 

3 review and the SC&A review?

4 If not, the second item on our agenda 

5 is a quick update here on the guidelines for 

6 coworker dose models.

7 Jim and I emailed to each other a few 

8 weeks ago just to update. I don't know, Jim, if 

9 you want to just sort of repeat what you said?

10 You were reviewing comments that came 

11 in on the guidelines, and then were thinking about 

12 -- remember we had decided that we would -- before 

13 finalizing the guidelines sort of take an example 

14 coworker model to review using the guidelines. 

15 Sort of to fine-tune those.

16 So, Jim, do you want to give us an update 

17 on where that stands?

18 DR. NETON: Yes. I can do that. I 

19 presented the most recent revision of course at the 

20 last Board meeting and the Board was asked to 

21 comment by April 30 on that revision.
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1 I didn't receive any comments from the 

2 Board by April 30. But I did on May 7 receive a 

3 fairly detailed commentary from Knut Ringen who is 

4 the senior science advisor for the Center for 

5 Construction Research and Training.

6 He provides very thoughtful comments, 

7 some editorial, and a number of very specific 

8 comments, six pages in total, that I believe I will 

9 respond to.

10 It's going to take some time because of 

11 the specific nature of the comments.

12 I'm going to do that. I'm not sure 

13 exactly whether to share this broadly. I don't 

14 know, Dr. Melius. I was going to ask your opinion 

15 on this.

16 CHAIRMAN MELIUS: Well, I don't think 

17 it's any problem sharing it broadly.

18 DR. NETON: Yes. Because it did come 

19 in. Well, I can share that along with my 

20 responses. 

21 I think it will result in some changes 
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1 to the document, but nothing I don't think that 

2 would substantively change the approach that's 

3 been outlined.

4 Given that, some of the comments 

5 provided by Dr. Ringen were more -- asking for more 

6 specificity which I really don't, you know, we 

7 talked about. Really didn't think it needed to be 

8 in there.

9 And some of them were clarifications of 

10 usage of terms which I'm happy to give.

11 But anyway, given that and nothing 

12 substantively changes we are going forward with 

13 trying to implement it on a trial basis, or a pilot 

14 basis I guess is a better word at two sites, the 

15 Idaho National Laboratory and Savannah River Site. 

16 So we are moving forward with that and 

17 we've received from the DSHEFS, another division 

18 that has done research at Idaho, their entire staff 

19 data file which includes a very cleaned up copy of 

20 the database for the bioassay and the external 

21 dosimetry.
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1 We're going to use that as part of our 

2 data quality approach for INL.

3 And we started to look at Savannah River 

4 Site. And in fact, we've already discovered that 

5 there's at least one set of building trade workers 

6 who probably need to be segregated from the main 

7 data set because of their incident-based sampling 

8 campaign.

9 And we're working trying to figure out 

10 how to deal with that, whether or not the data 

11 collected on them is sufficient for a coworker 

12 model or not.

13 So we're moving forward to that end. 

14 It's a major project. It's not going to happen in 

15 a couple of weeks, but we are working towards that 

16 end. 

17 Hopefully I can share some of the 

18 progress we've made at the upcoming Board meeting 

19 at the end of July.

20 CHAIRMAN MELIUS: Good.

21 DR. NETON: That's all I have.
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1 CHAIRMAN MELIUS: Thank you. Just to 

2 let you know, Jim, I concur with your assessment 

3 of Dr. Ringen's comments. 

4 I don't think they'll -- there's some 

5 things that might help to clarify. I don't think 

6 they substantially change the basic guidelines.

7 And I agree with you on -- getting more 

8 specific is very hard given the diversity within 

9 the sites that we're looking at and situations. 

10 It's very difficult to generalize into specific 

11 kind of criteria.

12 DR. NETON: Right.

13 CHAIRMAN MELIUS: Any questions on 

14 that? 

15 MEMBER ZIEMER: Jim, this is Ziemer. 

16 I don't remember seeing Dr. Ringen's comments. 

17 Were those distributed?

18 CHAIRMAN MELIUS: No, they weren't. 

19 I'll get a set to Ted to circulate.

20 MEMBER ZIEMER: Okay, thank you.

21 CHAIRMAN MELIUS: Yes, they only came 
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1 in relatively recently.

2 DR. NETON: May 7th, I think, or around 

3 that timeframe.

4 I wasn't sure whether to circulate 

5 them, but I think it's a good idea. They're public 

6 comment on a document.

7 And I do intend to respond to the 

8 comment. I'm not just going to let it sit because 

9 he put a lot of thought into it and it deserves a 

10 thoughtful response.

11 MEMBER BEACH: Yes, and I felt -- this 

12 is Josie -- at a disadvantage. I mean, I knew the 

13 comments had gone in, but not having seen them it's 

14 hard to understand what the discussion is.

15 CHAIRMAN MELIUS: We have time for 

16 further discussion, so at a later point. Okay.

17 Any other questions? 

18 MR. BARTON: Yes, this is Bob Barton. 

19 Jim, I think at the last meeting we had 

20 sort of a lengthy discussion about how you treat 

21 -- in an internal program how you treat those values 
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1 that may be less than one-half the MDA.

2 And I think what we sort of left it at 

3 that point was that SC&A and NIOSH sort of had 

4 agreed to disagree at that point, but that I think 

5 there was maybe one reference that we wanted to 

6 point to that maybe might sway or change your mind 

7 a little bit.

8 At this point, I mean where does NIOSH 

9 stand on that particular issue?

10 DR. NETON: Well, we haven't changed 

11 our opinion on that issue, but to be honest I have 

12 not -- that is an open finding from the review of 

13 -- I can't remember the document now -- TIB 73 or 

14 whatever the number is.

15 And that one required response from us. 

16 I believe that SC&A, Joyce in particular I think 

17 cited an NCRP review that said you shouldn't do 

18 that.

19 And it's on us to respond. And we 

20 haven't done that. There's been other competing 

21 things going on.
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1 But we do need to take that up and 

2 address it.

3 MR. BARTON: Okay. I just wanted to 

4 see if there was any new information. Thank you.

5 DR. NETON: Nothing new on that front, 

6 unfortunately.

7 CHAIRMAN MELIUS: Okay. If no further 

8 comments I believe we can adjourn.

9 MR. KATZ: Yes, thank you, everybody.

10 CHAIRMAN MELIUS: Thanks, everybody, 

11 and we'll I guess talk to you in, what, a couple 

12 of weeks now is our next Board call.

13 Okay, thank you.

14 (Whereupon, the above-entitled matter 

15 went off the record at 10:51 a.m.)

16

17

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19

20