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 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

 CENTERS FOR DISEASE CONTROL

 NATIONAL INSTITUTE FOR OCCUPATIONAL

 SAFETY AND HEALTH 

 + + + + +

 ADVISORY BOARD ON RADIATION AND

 WORKER HEALTH 

 + + + + +

 WORK GROUP ON TBD-6000

 + + + + +

 TUESDAY

 AUGUST 28, 2012

 + + + + +

 The Work Group convened in the

Zurich Room of the Cincinnati Airport

Marriott, 2395 Progress Drive, Hebron,

Kentucky, at 9:00 a.m., Paul L. Ziemer,

Chairman, presiding.

PRESENT:

PAUL L. ZIEMER, Chairman

JOSIE BEACH, Member

WANDA I. MUNN, Member

JOHN W. POSTON, SR., Member
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ALSO PRESENT:

TED KATZ, Designated Federal Official

DAVE ALLEN, DCAS

ROBERT ANIGSTEIN, SC&A

PATRICIA JESKE*

JOSH KINMAN, DCAS*

JOHN MAURO, SC&A*

DAN McKEEL*

JIM NETON, DCAS

L. MICHAEL RAFKY, HHS*

JOHN RAMSPOTT*

WILLIAM THURBER, SC&A*

*Participating via telephone
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 T-A-B-L-E O-F C-O-N-T-E-N-T-S

Welcome and Roll call...................... 4

SC&A Surrogate Data Review for the General

Steel Industries SEC Petition 00105 and DCAS

Responses: Related SC&A Recommendation for the

Use of GSI Data and DCAS Responses

Bob Anigstein............................. 8

John Mauro.............................. 40

Dave Allen............................ 45 45

GSI Petitioner Comments and Responses

Dan McKeel............................... 82

Patricia Jeske........................... 96

Work Group Discussion and Recommendations on

the Use of Surrogate Data and/or Alternative

Approaches............................... 235

Status of Remaining TBD Issues and Discussion

of Open Issues as Time Permits........... 269

Adjournment.............................. 274
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1 P-R-O-C-E-E-D-I-N-G-S

2 (9:00 a.m.)

3 MR. KATZ: Good morning, everyone. 

4 This is the Advisory Board on Radiation and 

5 Worker Health, TBD-6000 Work Group. 

6 Let's get started with roll call. 

7 We're dealing with a specific site, GSI, so 

8 also speak to conflict of interest. And we'll 

9 begin roll call with Board Members, with the 

10 Chair.

11 (Roll call.)

12 MR. KATZ: Okay. The agenda and 

13 related materials for the meeting that were 

14 received in time are posted on the NIOSH web 

15 site.

16 And, Paul, it's your agenda.

17 Please, for everyone on the line, 

18 mute your phones except when you're addressing 

19 the group. Press *6 to mute your phone, and 

20 press *6 again to take your phone off of mute. 

21 Thank you.

22 MS. JESKE: Excuse me. This is 
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1 Patricia Jeske. I was on mute and couldn't 

2 get it off on time. I'm the petitioner for 

3 GSI.

4 MR. KATZ: Oh, good to hear from 

5 you, Patricia. Welcome.

6 CHAIRMAN ZIEMER: Okay. Thank 

7 you, everyone, and I'll call the meeting 

8 officially to order. 

9 The business today focuses on the 

10 issue that came before the full Board at its 

11 last meeting. And I will just remind you of 

12 what the recommendation of the Work Group was, 

13 and this recommendation was approved by the 

14 full Board and it is this: we recommended 

15 that the discussions relating to the residual 

16 period and the desire of the Work Group to 

17 confirm the appropriateness of the use of 

18 TBD-6000 model of uranium site facilities as a 

19 surrogate for the handling of uranium at 

20 General Steel Industries, 

21 the Work Group recommends that the 

22 Board not take action on the SEC Petition 
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1 00105, but defer action until the next full 

2 Board meeting, and that this recommendation 

3 was based on the discussions that the Work 

4 Group had relating to the residual period and 

5 the desire to confirm the appropriateness of 

6 the use of the TBD-6000 model of uranium site 

7 facilities as surrogate for handling of the 

8 uranium at General Steel. And it was also 

9 indicated that this applies both to the 

10 operational period as well as to the residual 

11 period.

12 So, that recommendation was 

13 approved by the Board, and as a consequence of 

14 that, we are meeting today to focus on that 

15 issue and its implications. 

16 Also, I'll just remind you that 

17 the issue of the surrogate data focuses 

18 primarily on the uranium contamination part of 

19 the dose reconstruction; that is, the internal 

20 dose component for the operational period. 

21 And of course for the residual period, the 

22 internal dose would be the primary issue of 
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1 concern.

2 So we have asked SC&A to review 

3 the NIOSH use of surrogate data in this 

4 instance and SC&A has done that. We also have 

5 a response from NIOSH on SC&A's 

6 recommendations and we also have comments from 

7 the petitioner relative to this issue.

8 So we can begin with SC&A. And I 

9 know you all have seen the paper that Bob has 

10 developed on behalf of SC&A. 

11 And, Bob, you may want to 

12 highlight your findings and what SC&A's 

13 evaluation was. 

14 Then we'll have an opportunity for 

15 NIOSH to respond and also for the petitioner 

16 to make input on this issue.

17 And just a slight delay here. I 

18 think we're getting some information up on the 

19 screen here. Stand by a minute.

20 Okay, Bob.

21 DR. ANIGSTEIN: Yes. All right. 

22 So as Dr. Ziemer pointed out --
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1 CHAIRMAN ZIEMER: Can you speak 

2 loud, because the mics have to pick you up and 

3 the people on the phone need to hear you?

4 DR. ANIGSTEIN: Okay. I'll bring 

5 this maybe a little closer.

6 CHAIRMAN ZIEMER: Bob is fighting a 

7 cold. There might be a little difficulty here.

8 DR. ANIGSTEIN: Okay. My voice 

9 isn't quite as strong as usual. 

10 All right. Well, first, in all 

11 fairness, the original Appendix BB came out in 

12 year 2007. The uranium dust loading in the 

13 air and deposition was based on surrogate data 

14 which was taken from the TBD-6000 which had 

15 been issued the year before, which was a 

16 review of about five different sites and 

17 described the work practices at these sites, 

18 sites that handled uranium metal.

19 Subsequent to that, the Board 

20 issued -- actually, it was SC&A drafted and 

21 the Board adopted a set of five criteria for 

22 the use of surrogate data. So in all 
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1 fairness, the initial use of the surrogate 

2 data was several years before these criteria 

3 were issued. Nevertheless, that is the 

4 standard by which we will be reviewing it.

5 And the Criterion 1 is the 

6 hierarchy of data. First I'll give you a 

7 summary and then I'll go through in detail how 

8 each criterion was evaluated. And one 

9 critique we have is that there was data. In 

10 1993, there was a FUSRAP survey of the 

11 contamination of the floor of the old betatron 

12 building. It was a very detailed survey. And 

13 this was at the very end of the residual 

14 period, so it's contiguous to this period of 

15 operation. I mean, the entire period of 

16 evaluation starts in 1953, which is presumed 

17 to be the beginning of AEC operations at GSI, 

18 and it ends with the clean-up in, I think it 

19 was June, 1993, 40 years later. But anyone 

20 working during any of that period was 

21 potentially exposed to radioactive 

22 contamination/radiation and therefore subject 
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1 to have a dose reconstruction.

2 So there was one piece of data, 

3 one set of data that was not utilized. 

4 Furthermore, there were adjustments that were 

5 made to the surrogate data that was used that 

6 in our opinion were not appropriate for the 

7 uranium handling scenario with GSI, and I'll 

8 go into more detail. 

9 Criterion 2 is the exclusivity 

10 constraint. One of the subsets in that 

11 criterion is that any use of surrogate data 

12 needs to be stringently justified, that's the 

13 wording in the criterion, and we feel that 

14 they were not stringently justified.

15 Criterion 3 deals with site or 

16 process similarities, and we find there were 

17 dissimilarities. First, a scenario that was 

18 adopted by NIOSH was the stamping of slugs 

19 produced by powder metallurgy. Now this is 

20 quite different than the physical form, the 

21 metallurgical form of the uranium that was 

22 actually handled at GSI which were either 
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1 recast ingots, meaning first they had cast 

2 them -- they called derbies, smaller shapes, 

3 and then they were melted and cast into 

4 ingots, or they were directly reduced dingots, 

5 uranium tetrafluoride which reacted with 

6 magnesium to directly form uranium metal. 

7 Neither of these is similar to making slugs 

8 with powder metallurgy.

9 The processes. In the one case 

10 numbers were stamped on the slugs, and that 

11 was a source of uranium dust. And that again 

12 had no similarity to what's going on at GSI.

13 Next there were -- we say that, 

14 yes, NIOSH did review data at four additional 

15 sites. We just got this review last week. We 

16 performed some cursory review of these data, 

17 but not -- when I'm talking about use of 

18 surrogate data, I'm talking about the original 

19 slug stamping scenario, not the new data that 

20 NIOSH has just presented. 

21 And finally, there was not 

22 sufficient data about the surrogate site, 
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1 where were the stamping -- it was not 

2 identified where the slug stamping took place, 

3 and therefore we have no knowledge of that 

4 site. There was a -- earlier we had -- we 

5 were concerned about the temporal 

6 considerations, which is the time period of 

7 the measurement that was cited and the time 

8 period at GSI. And that has since -- we just 

9 needed a satisfactory explanation. And in 

10 fact, NIOSH has subsequently furnished such a 

11 satisfactory explanation, so that is no longer 

12 an issue.

13 The biggest issue is probably the 

14 plausibility of the model. We feel that the 

15 calculation of the surface contamination from 

16 the uranium aerosol, airborne uranium, was not 

17 scientifically plausible. And the statement, 

18 the assumption that the surface contamination 

19 resulted only from the slow deposition of 

20 aerosols did not conform to workplace 

21 plausibility. And we go on in detail.

22 Okay. Back to Criterion 1, 
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1 hierarchy of data. "Data should only be used" 

2 -- and I'm quoting. This is a quote. 

3 Everything in italics is quoted directly from 

4 the Board criteria. "Surrogate data should 

5 only be used if the surrogate data have some 

6 distinctive advantages over the available 

7 data, and then only after the appropriate 

8 adjustments have been made to reflect 

9 uncertainty inherent in their substitution."

10 Now normally to my mind, and this 

11 can be -- I would like verification from John 

12 Mauro on this, because he was the author of 

13 this. I would assume that the adjustment for 

14 certainty would mean an increase in the value. 

15 Well, we're not certain where it is, so we 

16 take the 95th percentile or some upper level. 

17 Is that -- John, am I correct in 

18 my interpretation?

19 DR. MAURO: Yes, the main thrust 

20 is that, you know, you're never going to get a 

21 perfect surrogate. And once you recognize the 

22 differences between your real situation that 
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1 you're dealing with and the surrogate 

2 situation, if at all possible, try to make 

3 accommodations to deal with that, one of 

4 which, of course, you just pointed out, has to 

5 do with, let's work with the high-end values 

6 to be sure that we're not missing. But there 

7 may be other factors. But there's a lot of 

8 judgment made, and this is what makes the 

9 surrogate process difficult and, you know, 

10 when have you struck that balance? But 

11 anyway, yes, you're correct.

12 DR. ANIGSTEIN: Okay. Thank you. 

13 And then the other is that there is -- here 

14 are the data that were available. There was 

15 no monitoring. We all agree there was no 

16 monitoring of the uranium intake at GSI. The 

17 only hard data is the duration of uranium 

18 handling operations, which is based on the 

19 Mallinckrodt purchase orders. 

20 The Mallinckrodt purchase orders 

21 said, we're going to pay you so much during 

22 this particular time period, say $500 or --
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1 I'm just making it up -- one number that was 

2 cited -- for doing radiography during these 

3 three months and we're going to pay you at the 

4 rate of $16 an hour. So it's easy to estimate 

5 the hours, simply taking the total amount and 

6 dividing it by the hourly rate. So that is on 

7 firm ground.

8 However -- and then there were 

9 interviews with former workers, a number of 

10 interviews. NIOSH was involved. SC&A 

11 conducted additional ones to get an idea of 

12 the uranium handling operation. However, the 

13 data on the -- the very thorough survey of the 

14 old betatron building, the only place where 

15 uranium contamination was found, was not 

16 utilized by NIOSH, and that should have been 

17 part of the hierarchy of data.

18 Now the adjustment --

19 MEMBER POSTON: Before you go on, 

20 and maybe John would like to jump in, isn't 

21 what you've said so far really a subjective 

22 judgment? I mean, it's like arguing over 
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1 which baby is the cutest, I mean, in terms of 

2 --

3 DR. ANIGSTEIN: Well, 

4 unfortunately it is subjective, but the data, 

5 the site-specific data should take precedence 

6 over data that was borrowed from another site. 

7 And these site- specific data were not 

8 utilized by NIOSH.

9 MEMBER POSTON: I was talking 

10 about the appropriateness of the statement 

11 that you added to that.

12 DR. ANIGSTEIN: The appropriate --

13 well, I will get to -- oh, yes, let me get to 

14 it. That's on the next slide.

15 MEMBER POSTON: And the fact you 

16 talk about the uncertainty in here and then 

17 the substitution. I mean, those are 

18 subjective things as far as --

19 DR. ANIGSTEIN: Yes, but this is 

20 the Board criteria. This was adopted by the 

21 Board.

22 MEMBER POSTON: I understand.
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1 DR. ANIGSTEIN: So I'm saying --

2 perhaps that might be clarified, because the 

3 point is the uncertainty -- this is what they 

4 said: There should be some adjustment for it, 

5 for uncertainty. However, the adjustment that 

6 was made by NIOSH was actually to take the 

7 values and substantially lower them. So 

8 that's not a question -- that's uncertainty --

9 usually my understanding is that when there 

10 is an uncertainty, you resolve it in a 

11 claimant- favorable manner, meaning if you're 

12 not sure of the dose, you either use the range 

13 or you give it some like 95th percentile of 

14 the range, some upper amount.

15 Here the value was actually 

16 substantially reduced over the measured value, 

17 the measured reported value. So that's why 

18 I'm questioning the appropriateness --

19 MEMBER POSTON: Okay.

20 DR. ANIGSTEIN: -- of the -- okay. 

21 So even though it's not given in the report, 

22 actually this does appear in TBD-5000, which 
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1 TBD-6000 refers to. And there is an equation, 

2 which I -- actually, I derived it separately 

3 from a statistics textbook, for the 

4 relationship between -- if you have a log 

5 normal distribution, there is a -- you can 

6 calculate the geometric mean and you can also 

7 calculate the arithmetic mean, and this 

8 equation gives you the relationship between 

9 the two. Anyone who has the earlier -- the 

10 actual report that was issued last month, 

11 there was an error had to be corrected, we 

12 left out the parentheses squared part.

13 So anyway, the geometric mean 

14 calculated by this formula using the 

15 arithmetic mean of 590, this was what was 

16 reported in the Harris and Kingsley report on 

17 the slug stamping scenario, but this form --

18 but then the geometric mean is only 162 if you 

19 assume a geometric standard deviation of 5, 

20 which again is -- you can call it surrogate 

21 data because its base is an assumption used by 

22 NIOSH, but it's certainly not relevant here 
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1 necessarily. There's no basis for applying it 

2 here. It's just a default assumption in 

3 TBD-6000. 

4 So if you do that, however, 

5 because of an error in arithmetic in all of 

6 the TBD-6000 -- as a matter of fact, 

7 fortuitously I made the same error and I left 

8 out the square here and they got to 264 by 

9 leaving out the, you know, sigma, log sigma g 

10 squared. So that was an error and I believe 

11 NIOSH confirmed that that was an error. 

12 So if we continue the calculation 

13 as described by NIOSH, this is a statement 

14 that I took -- I quoted from the recent NIOSH 

15 report, that "the use of the geometric mean is 

16 an attempt to prevent the value from being 

17 unrealistically high." Again, we don't agree 

18 that this is a valid adjustment. I just 

19 simply say we don't -- we think this value of 

20 590 is too high, so we're going to calculate 

21 another value that's lower. And the problem 

22 we have with that is a single number was 
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1 reported. The only number that was reported 

2 was 590. Whether that's an average or a 

3 single measurement, we're not sure. More 

4 likely it was a single measurement, from my 

5 reading of the original source document.

6 However, what NIOSH assumed is, 

7 well, we're going to say this is an arithmetic 

8 mean. And because we tend to use log normal 

9 distributions, we'll derive a log normal 

10 distribution from that. Well, that's possibly 

11 defensible. But what is not defensible in our 

12 opinion is to then say we're going to use a 

13 single value of this artificial geometric mean 

14 that was from this -- derived from this 

15 geometric, this log normal -- the whole thing 

16 comes out of one number. You have one number 

17 and suddenly you're getting all of these 

18 values coming out of that. We feel that this 

19 is the number that you have. You have the 

20 590. That's the number you use. If you need 

21 to use a value, you use the value that was 

22 reported.
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1 And then the next adjustment that 

2 NIOSH made was to say that the operator was 

3 exposed only 75 percent of the time. Well, 

4 and the purpose of TBD-6000, if you're looking 

5 at an eight- hour exposure -- I'm not going to 

6 state an opinion, you know, state a position 

7 on that, but it's plausible. You know, the 

8 guy's not going to be at his station where the 

9 maximum concentration appears all of the time. 

10 He goes away. He does other duties, 

11 whatever. But that's like for an eight-hour 

12 day.

13 Here the operation was assumed by 

14 NIOSH to only take half the time. So if we 

15 calculate - - and I'm just making up a number, 

16 say one hour a month of this actual uranium 

17 handling based on the purchase orders, then 

18 they say, ah, but only half an hour is 

19 actually spent handling the uranium. The 

20 other half hour is spent in the control room 

21 while they're doing the radiographic exposure 

22 with the betatron. I don't necessarily agree 
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1 with that, but even then -- so you're already 

2 reducing it by half. You don't take 75 

3 percent of that 50 percent. That seems again 

4 an unreasonable reduction in the exposure. 

5 This was done just to be consistent with 

6 TBD-6000, but it does not apply -- or we don't 

7 feel it applies here. So this is -- Criterion 

8 1, we feel is not justified.

9 The exclusivity constraint of 2 is 

10 -- this would simply suggest that simply 

11 selected there were five scenarios in 

12 TBD-6000, and for Appendix BB, the one that 

13 produced the lowest concentration was selected 

14 because it is the lowest concentration. 

15 Again, that does not appear to be stringently 

16 justified, and I believe that I read the 

17 report that was recently issued where NIOSH 

18 agreed that it's not stringently justified.

19 The next is the site or process 

20 similarities. First of all, the uranium slugs 

21 produced by powder metallurgy simply do not 

22 have the same metallurgical properties as the 
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1 cast uranium ingots or the dingots. We have 

2 actually two -- these two forms are different, 

3 but they were both handled at -- they were 

4 both produced at Mallinckrodt, so we assume 

5 they were both handled at GSI, but neither of 

6 these conform to powder metallurgy.

7 Then the next part of this 

8 criterion is: are there other sources of 

9 surrogate data that were not used? So NIOSH 

10 has since reviewed the four additional types. 

11 I think actually that three sides were --

12 measurements were reported and a fourth one 

13 which was done for a temporal time curve.

14 Finally, are there adequate data 

15 characterizing the site -- assume the site 

16 that was selected, the site where the powder 

17 -- the slug sampling took place, to support 

18 its application? And the work site is not 

19 identified clearly. I think there was a 

20 suggestion it may have been Fernald, but it's 

21 not -- Harris and Kingsley list a number of 

22 operations and they list a number of sites, 
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1 but they don't say which operation was at 

2 which site.

3 And then finally, the criterion, 

4 do surrogate data reflect the type of 

5 operations and work practices at the facility 

6 in question, meaning GSI in our opinion? No, 

7 it does not. So we feel that criterion 3 is 

8 not satisfied. 

9 Criterion 4, I'll skip over 

10 because that's been resolved. The dates are 

11 rather different. It was earlier, but NIOSH 

12 made the argument that since there were no 

13 particular measures taken to reduce the 

14 exposure to uranium dust at GSI, there is no 

15 reason to believe that that would be different 

16 and that's -- we agree that that's not a 

17 significant issue. I'm just mentioning it for 

18 the sake of completeness.

19 And finally, the one about the 

20 plausibility. Now I have to briefly go over 

21 the NIOSH model. The NIOSH model is that 

22 somebody comes into the room, let's say the 
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1 old betatron building, that's where we took 

2 measurements, I mean, it could be anyplace, 

3 and starts handling the uranium. Then the 

4 moment the time, the clock starts with the 

5 uranium handling, immediately a dust cloud 

6 appears. Some aerosol is generated and it 

7 starts at that moment. The uranium handling 

8 goes on for half an hour. It gets repeated 

9 periodically, but at any one time it's half an 

10 hour, again according to the scenario that's 

11 provided in Appendix BB. So for half an hour 

12 this dust is suspended in the air. It's 

13 inhaled by the workers performing this work. 

14 And most important, it settles to the ground, 

15 but it only settles to the ground for 30 

16 minutes. 

17 So if you know the concentration, 

18 this assumed concentration based on TBD-6000, 

19 and then you take the settling velocity of I 

20 believe it's 7.5 times 10 the minus 4 meters 

21 per second, then you can tell that during this 

22 time so much dust has settled. Basically it's 
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1 like a belt that the thickness of that belt 

2 would be the speed times the time. How far 

3 can a uranium particle travel during this 

4 time? And it's that and only that amount of 

5 uranium that settles to the floor. Because at 

6 the end of 30 minutes, poof, it's gone. So 

7 that's not a realistic scenario. 

8 If we assume that this five-micron 

9 AMAD is the average -- the mean particle size 

10 and we agree that 7.5 times 10 to the minus 4 

11 meters per second is the settling velocity, 

12 and if the dust was to extend to the roof of 

13 the old betatron building, it would take about 

14 4 hours for it to settle. And this is not as 

15 absurd as it may seem, because, going back 

16 over some of the documents and worker 

17 recollection, there were heaters well high up 

18 on the wall which would have created an 

19 updraft with the space heaters, and they said 

20 there was an updraft -- so that there would 

21 have been some vertical movement of the air, 

22 so that the dust may very well have gone 
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1 certainly higher than a few feet, which would 

2 be the 30-minute settling time. So more dust 

3 would have settled to the floor than would 

4 have been calculated by that model.

5 And then more recently, in the 

6 latest report -- I'm not going to put up it 

7 right now, but there was a figure, a curve 

8 from Simonds Saw which shows how the air 

9 concentrations changed. And this is in the 

10 NIOSH response to our report. How the air 

11 concentration changed -- function of time. 

12 And it took days for it to go away, not half 

13 an hour. Because they showed a significant 

14 concentration after about two days later 

15 still, maybe one-third as much. And then in 

16 TBD-6000, there is a statement that it takes 

17 30 days to achieve equilibrium between dust --

18 that's not during dust generation. But if 

19 there's dust on the floor and you stir it up, 

20 of course it gets resuspended. Then it starts 

21 settling again and there is a constant back 

22 and forth. It goes up, it goes down. And it 
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1 takes about 30 days to achieve equilibrium. 

2 So that's certainly not inconsistent with 

3 saying that it happens in 30 minutes.

4 And then the other problem with 

5 the model that we have is that the surficial 

6 contamination is based on deposition during 

7 one year. First it's the year, because at the 

8 very beginning there seems to be an increase 

9 in the frequency of radiography. Then there 

10 is a maximum year of July '61 to June '62. 

11 And so then NIOSH assumes whatever deposit 

12 during that year is constant for all time 

13 afterwards. No increase, even though there's 

14 additional uranium being handled and no 

15 decrease. So we just think this is not a 

16 scientifically-correct model. It needs to be 

17 -- I mean, the one year, if there is a basis 

18 for it, that this should be demonstrated.

19 Then the final --

20 MEMBER POSTON: Can I interrupt 

21 you just for a second?

22 DR. ANIGSTEIN: Yes.
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1 MEMBER POSTON: I think you 

2 misspoke, and I want to clarify. You said 

3 it's not inconsistent with 30 minutes, and I 

4 don't think you meant that.

5 DR. ANIGSTEIN: It's inconsistent 

6 with the 30 minutes. 

7 MEMBER POSTON: Okay.

8 DR. ANIGSTEIN: A double negative. 

9 Thank you. 

10 MEMBER POSTON: Because that would 

11 mean, if it's not inconsistent --

12 DR. ANIGSTEIN: I thank you very 

13 much.

14 MEMBER POSTON: And you said that, 

15 I'm pretty sure.

16 DR. ANIGSTEIN: I'm sorry. Thank 

17 you for the correction.

18 And then finally, the workplace 

19 plausibility; because these are the two in the 

20 Criterion 5, is: are the assumed processes and 

21 procedures plausible for the facility in 

22 question? Have all the factors that could 
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1 significantly impact exposure been taken into 

2 account? Is adequate information available 

3 about the facility in order to make a fair 

4 assessment?

5 So again, we feel that the aerosol 

6 levels from the handling of uranium ingots are 

7 not comparable to uranium slug stamping. We 

8 also feel that the surface -- that even if we 

9 didn't have other problems with the model, the 

10 surficial concentration cannot be calculated 

11 from the airborne concentration because the 

12 settling of the aerosol is not the only 

13 source. You have these uranium ingots coming 

14 in. There would be loose contamination on the 

15 surface, contamination meaning -- it's not 

16 really contamination. It's just uranium, 

17 uranium oxide, and you could have large flakes 

18 falling down during the handling.

19 Now these flakes would not 

20 contribute to the inhalation of the worker 

21 that's doing the handling. However, they 

22 would contribute to the amount of uranium on 
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1 the floor. And immediately afterwards, that 

2 would not become airborne because it's strong. 

3 But here you have these little pieces of 

4 uranium lying around. Eventually they get 

5 ground underfoot. The forklift trucks go back 

6 and forth. We have a picture of trucks 

7 actually being used inside the extruding room. 

8 And this contributes to the resuspendable 

9 surface contamination layer. So again, we 

10 believe that this is not fully -- and then I 

11 show the 30 days required for equilibrium, 

12 which I mentioned before. So we feel that 

13 this plausibility, workplace plausibility 

14 criterion is not satisfied.

15 So the one alternate scenario 

16 before seeing the recent information from 

17 NIOSH is -- as we were directed, we looked at 

18 the other five scenarios in TBD-6000 and they 

19 also were not applicable to GSI. However, we 

20 did find there was the Adley report on the 

21 handling of uranium -- of the melt plant 

22 building at Hanford. And here you had a 
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1 series of operations which were simply 

2 handling uranium rods. No machining. No 

3 bending. Later on they were bent, they were 

4 straightened. But here was just the pure 

5 handling. And simply unloading the rods from 

6 the truck with a forklift gives you a far 

7 higher concentration. 

8 This is the measured concentration 

9 now. So 3,900 dpm opposed to, what was it, 

10 590 -- 560, I think, in TBD-6000. So we have 

11 6 times as high and 20 times as high as the 

12 value that was actually used by NIOSH, 198. 

13 So this would be a more limiting scenario and 

14 simply unloading uranium rods. Well, that's 

15 probably as close as we could find. I'm not 

16 saying we did an exhaustive study of the 

17 literature. This is something that we just 

18 came up with. That was far more restrictive. 

19 So, and even if this was to be adopted, we 

20 would still have concerns about the model that 

21 was used.

22 So shall I go on now to the 
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1 alternate model or, any other discussion?

2 CHAIRMAN ZIEMER: Let's stop for a 

3 minute to see if there are any questions that 

4 the Work Group Members have on any of the 

5 items that you covered here so far. John?

6 MEMBER POSTON: Two questions: 

7 one, these are all measured values, you say? 

8 Was that what you said?

9 DR. ANIGSTEIN: Say again?

10 MEMBER POSTON: The values you're 

11 showing there on this table, are they all 

12 measured values?

13 DR. ANIGSTEIN: Yes.

14 CHAIRMAN ZIEMER: These are the 

15 Hanford values?

16 DR. ANIGSTEIN: Yes. 

17 MEMBER POSTON: Yes.

18 DR. ANIGSTEIN: Yes, this is 

19 correct. Yes, that is in the Adley report. 

20 These are the measured values.

21 MEMBER POSTON: Can you help me 

22 understand, I'm assuming that the third entry 
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1 where the concentration is 88, these rods have 

2 been straightened and --

3 DR. ANIGSTEIN: Yes.

4 MEMBER POSTON: -- perhaps 

5 machined.

6 DR. ANIGSTEIN: I believe, yes.

7 MEMBER POSTON; So they have no 

8 surface?

9 DR. ANIGSTEIN: Right. That's 

10 probably the case.

11 MEMBER POSTON: Yes. But what's 

12 the difference between the first entry and the 

13 second entry?

14 DR. ANIGSTEIN: I can't tell you. 

15 This was simply -- it was not identified in 

16 the report.

17 MEMBER POSTON: Because they both 

18 say unloading the truck.

19 DR. ANIGSTEIN: One is unloading 

20 and the other is -- I think there were two 

21 different work locations. One is unloading 

22 the truck with a forklift and the other one is 
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1 I guess; I'm speculating now, the rods will be 

2 transferred with a forklift and to another 

3 location. And then there will be another 

4 monitoring at that location where they were 

5 received.

6 MEMBER POSTON: Would you 

7 speculate that --

8 DR. ANIGSTEIN: This is simply 

9 taken -- there was no further information 

10 there. This is many pages of tables in that 

11 report of many measurements during many 

12 operations and this was the one set of 

13 measurements --

14 MEMBER POSTON: Were these the 

15 maximum values?

16 DR. ANIGSTEIN: And I believe 

17 these were simply single values.

18 MEMBER POSTON: You didn't answer 

19 my question.

20 DR. ANIGSTEIN: Excuse me?

21 MEMBER POSTON: You said there 

22 were multiple tables with lots of data --
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1 DR. ANIGSTEIN: Oh, oh -- 

2 MEMBER POSTON: And I asked you --

3 DR. ANIGSTEIN: No, no. I'm 

4 sorry. There were --

5 MEMBER POSTON: -- if these were 

6 the maximum values selected from those tables.

7 DR. ANIGSTEIN: No, these were 

8 selected on the basis of -- everything else 

9 involved melting uranium and handling -- you 

10 know, this was the one was selected as were 

11 simply handling cold uranium metal as opposed 

12 to uranium being heated, uranium being melted. 

13 So out of these numerous tables these would 

14 be the ones --

15 CHAIRMAN ZIEMER: You felt this 

16 was more like GSI?

17 DR. ANIGSTEIN: Pardon?

18 CHAIRMAN ZIEMER: This was more 

19 like GSI, is what you're saying?

20 DR. ANIGSTEIN: Right, this was 

21 the closest. My colleague Bill Thurber, who's 

22 not on the line, went through other sources 
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1 and found -- this was the one place he found 

2 that was the closest in this particular 

3 report. This is again one of the reports that 

4 was the basis for TBD-6000.

5 MEMBER BEACH: So this isn't 

6 something that SC&A came up with? This is one 

7 of the scenarios that NIOSH put out, correct?

8 DR. ANIGSTEIN: No, no, no.

9 MEMBER BEACH: No?

10 DR. ANIGSTEIN: No, this is SC&A. 

11 This is SC&A looking at alternative -- the 

12 original NIOSH scenario was simply the slug 

13 stamping, the uranium slugs that had been 

14 produced by powder metallurgy, where you 

15 simply took a powder and pressed it together 

16 under high pressure and temperature and then 

17 stamping numbers on it. That's the scenario 

18 that NIOSH took. We explored alternatives and 

19 we came up with one alternative that was both 

20 more -- a better surrogate and also more 

21 claimant- favorable.

22 CHAIRMAN ZIEMER: Other questions?
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1 MR. ALLEN: I got one comment I 

2 would make. That Adley -- that report 

3 includes a map and then the area there. And I

4 mentioned in my White Paper response to SC&A's 

5 thing is, one of the issues with trying to 

6 find this kind of information is that you have 

7 much higher airborne causing evolutions in the 

8 air.

9 CHAIRMAN ZIEMER: Other things 

10 going on.

11 MR. ALLEN: And there is a map in 

12 Adley that shows that this is a fairly small 

13 area. And as Bob shows -- or mentioned, 

14 there's quite a bit of airborne samples from 

15 other operations that are quite a bit higher 

16 than that. It's really impossible to say that 

17 this is the kind of airborne you get from cold 

18 metal uranium handling --

19 CHAIRMAN ZIEMER: Per se.

20 MR. ALLEN: Per se. I mean, it 

21 could very easily be interference from these 

22 even higher airborne samples 20 feet away. 
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1 And as far as temporal, whether this happened 

2 while the other stuff was going on, it's hard 

3 to say. I mean, that's the bottom line, is 

4 you really can't say. You don't know.

5 MEMBER BEACH: So it's just 

6 another best guess?

7 MR. ALLEN: Yes, but you -- in 

8 this particular case and in so many others, 

9 you have a very reasonable chance that there's 

10 a lot of interference from something happening 

11 in open air. And the Adley report does 

12 mention summertime, doors and windows open for 

13 ventilation. And you know there was, you 

14 know, higher airborne measured. And these are 

15 20, 30, 40 feet away from higher airborne 

16 causing evolutions. It's really not a good 

17 set of data to use.

18 DR. ANIGSTEIN: Well, actually 

19 that's why we were suggesting, and I'll get to 

20 it, an alternative model which doesn't -- we 

21 realize that whatever surrogate data is out 

22 there, at least that NIOSH has come up with 
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1 that we've found, is probably not that good.

2 CHAIRMAN ZIEMER: John?

3 DR. ANIGSTEIN: And that's why we 

4 think that a model based only on site-specific 

5 data with just a couple of default parameters 

6 based on observations in many other places 

7 would be more defensible and 

8 claimant-favorable, more like a plausible 

9 upper -- I'm already jumping ahead.

10 CHAIRMAN ZIEMER: John, were you 

11 making a comment? John Mauro?

12 DR. MAURO: Yes, I was going to 

13 sort of step back a little, because I think a 

14 lot of information has been put on the table 

15 right now. It's always good to sort of pause 

16 and say, well, you know, what's all this 

17 saying, speaking to us? 

18 I think that what we're hearing is 

19 the starting point for the surrogate model 

20 that NIOSH used, this, the slugs and the 

21 stamping goes back a long ways. At the time 

22 SC&A was supportive of it. I was the one who 
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1 said, yes, that's probably okay, because in 

2 all likelihood the handling of these ingots

3 was not going to be as aggressive as the 

4 slugs. So, and we say, yes, that's probably 

5 going to bound it. And that was the end. 

6 That was the extent, especially at the time. 

7 All the attention, of course, was on the 

8 betatron and the radium. And the last thing 

9 in terms of the hierarchy of important issues 

10 and scenarios was this residual dust. 

11 So we sort of started out 

12 accepting that. But, you know, as we focused 

13 in, we said, well, we'll take a little closer 

14 look. And I think the important message that 

15 comes out of what we just talked about was a 

16 starting point is the key. Starting with the 

17 dust loading of -- I think it was 550, was the 

18 number you cited that came out of the backup 

19 documents, the TBD-6000, Harris and Kingsley. 

20 And so I think the first place to look is, is 

21 that a good starting point, or are there 

22 better starting points if you're going to go 
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1 with the surrogate model? That's really the 

2 question. 

3 And of course the conversation 

4 we're just hearing now is, well, there are 

5 other starting points that we might want to 

6 consider in light of everything we just talked 

7 about. Now, it's important to separate the 

8 starting point from then the mechanics. Given 

9 this starting point -- you heard a lot of 

10 discussion -- whatever starting point you 

11 decide to pick, if you decide to go with the 

12 surrogate approach, then there are the 

13 mechanics of it. And what do we do with that 

14 number? 

15 And you heard a lot of criticism 

16 of the approach, the mechanics used in taking 

17 the single number and then, you know, assuming 

18 it's a geometric mean, then applying some 

19 factors to get -- or assuming it's an 

20 arithmetic mean, then applying some factors to 

21 get it to a geometric mean, and so on and so 

22 on and so on. And there's all this mechanical 
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1 treatment of that one number that we started 

2 with. I think that's a separate question. So 

3 it's important to separate are we happy with 

4 the starting point, you know, or are there 

5 better starting points? 

6 And the other question is once we 

7 -- if we do find the place where, you know, we 

8 sort of like this starting point better, then 

9 the mechanics of how you treat it and what do 

10 you do with that number, I think that's a 

11 separate subject. And I think the -- you 

12 know, and it's important to separate those 

13 two, because in one case, if you can't find a 

14 good starting point you're really in trouble 

15 if you have no starting point. If you can, 

16 you've got a tractable problem. It's just a 

17 matter of now agreeing on the mechanics we're 

18 going to use, the mathematics, the assumptions 

19 in order to come up with a reasonable dust 

20 loading.

21 Now, we're about -- I'm only doing 

22 this sort of to set the table a little better. 
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1 If it's determined that you're not very happy 

2 with the starting point, Bob has come up with 

3 a whole different approach which comes in from 

4 a different direction entirely where you don't 

5 use surrogate data. But then the question 

6 becomes: what's the strength of that approach? 

7 So in effect, there are two 

8 different strategies before the Work Group. 

9 One is to try to start with a surrogate point, 

10 the surrogate data as your starting point that 

11 you feel is reasonable and understanding all 

12 the strengths and limitations of it. 

13 The other approach that you 

14 haven't heard from yet is, well, there's a 

15 whole different approach that could start --

16 your starting point, instead of being 

17 surrogate data, it could be some real data 

18 that we have in the 1990s of what was residual 

19 and then work with that. 

20 The reason I only mention this is 

21 I like to sort of sometimes step back and 

22 collect everything up so that we can move 
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1 forward from the same perspective. I hope 

2 that's helpful. 

3 CHAIRMAN ZIEMER: Yes. Okay. 

4 Thanks, John.

5 Why don't we go ahead and hear 

6 from NIOSH? And have before us their 

7 responses and their view on the extent to 

8 which the approach that they're proposing 

9 meets the criteria. Dave, you want to -- we 

10 have your document. You want to highlight 

11 some issues or amplify some things --

12 MR. ALLEN: Okay. Well, I mean --

13 CHAIRMAN ZIEMER: -- in response 

14 to what Bob has said?

15 MR. ALLEN; Well, I mean, I 

16 started that document off with trying to give

17 a background -- this is handling cold uranium 

18 metal. This is nothing really specific to one 

19 particular site or one particular era. It is 

20 a very common task that's done in a lot of 

21 different areas. Unfortunately, when you go 

22 to all those sites where this was done, 
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1 there's not a lot of air samples for handling 

2 of uranium metal, and largely because it's not 

3 much of an airborne- causing evolution.

4 I worked myself at a uranium 

5 foundry for 14 years and I know for a fact you 

6 can handle uranium metal and move it around 

7 with a fork truck, et cetera, and there's just 

8 not much airborne caused by this. 

9 Unfortunately, like I said, it's difficult to 

10 show because, you know, a few air samples and 

11 everybody's convinced there's nothing and they 

12 don't take any more. So there's not a lot out 

13 there. 

14 I pointed out some of the 

15 problems. In my White Paper I pointed out 

16 some of the problems, you know, number one, 

17 there's not a lot of air samples because of 

18 that. People concentrated on the more 

19 airborne-causing evolutions in the area. And, 

20 two, when they did take a sample or somebody 

21 unloading something or handling cold uranium 

22 metal often they were unloading it for a 
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1 reason, and that's for, you know, putting it 

2 in a furnace or some other manipulation that 

3 ends up causing quite a bit more airborne in 

4 the vicinity. Those two things cause a lot of 

5 trouble trying to find the information.

6 What we did with TBD-6000 and for 

7 GSI, we used that slug production. And one 

8 way of looking at this is, we used that slug 

9 production, which also included other 

10 evolutions with uranium or airborne-causing 

11 evolutions, and the table in Harris and 

12 Kingsley demonstrates other operations. Some 

13 were causing higher airborne and some were 

14 not. And part of that -- one step of that 

15 task included handling an ingot of uranium 

16 metal. And made the assumption that the other 

17 tasks were going to be higher airborne-causing 

18 evolutions and therefore took the median of 

19 the -- all the airborne in the vicinity. 

20 Actually, it was the median of the 

21 higher one, which ended up being somewhat of a 

22 median of all those tasks and said that the 
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1 task of handling uranium metal is on the lower 

2 half of all the steps in this process. 

3 Therefore, we used the median as a constant. 

4 That's not a real mathematical or scientific 

5 argument there. It's, like I said, some means 

6 of trying to keep it from being implausibly 

7 high, which is yet another criterion we had to 

8 deal with. In my --

9 CHAIRMAN ZIEMER: So this is a 

10 judgment that says --

11 MR. ALLEN: It's a judgment.

12 CHAIRMAN ZIEMER: -- typically, as 

13 I understand it, typically in addition to any 

14 handling of the type done at GSI, most of the 

15 other data available is handling plus 

16 something else?

17 MR. ALLEN: Right.

18 CHAIRMAN ZIEMER: So the values 

19 that you have available would tend to 

20 overestimate the handling part because there 

21 are other operations. Is that what you're 

22 saying?
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1 MR. ALLEN: Yes.

2 CHAIRMAN ZIEMER: Okay.

3 MR. ALLEN: So they took one 

4 operation that included handling, which all of 

5 them inherently include handling.

6 CHAIRMAN ZIEMER: Right.

7 MR. ALLEN: And decided that 

8 essentially the median -- it couldn't be --

9 the whole encompassing part of the cold 

10 uranium metal handling could not be as high as 

11 the median of the other -- the entire task, is 

12 what it amounts to. 

13 In my White Paper response, I 

14 pointed out -- I went through a number of 

15 places looking for some air samples, most of 

16 which have some issues. Like I said, either 

17 don't take air samples or take them in the 

18 vicinity of other operations. And I pointed 

19 out about three -- I think it was three sites 

20 where we found some that were -- you know, 

21 it's not a great deal of information, but it's 

22 somewhat relevant to the conversation anyway 
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1 and gives you some idea of what I'm talking 

2 about. 

3 The one that I thought was the 

4 most pertinent to GSI, that was only three 

5 samples, is the last one. It's the last page, 

6 I believe, of my White Paper where it's a BZ 

7 of an operator hooking a hoist to a billet and 

8 placing it on this machine. And it shows 

9 three air samples. One is nine dpm per cubic 

10 meter. The other two are non-detectable, so 

11 they're even less than the nine. That is the 

12 kind of airborne I was used to seeing from 

13 handling cold uranium metal. 

14 I did have some other ones. They 

15 had their own issues where there was other 

16 operations going on, but they show still well 

17 below -- or at least below -- even the highest 

18 one is below what we were using in Appendix 

19 BB, but it does demonstrate uncertainty. 

20 There is uncertainty with what the number is 

21 because there was not a lot of samples, 

22 because the samples we do come up with end up 
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1 having operations in the area, you know, 

2 often, or more important, you'll know whether 

3 there's another operation going on. 

4 So it is looking at these. And 

5 from past experience and from the logic I'm 

6 seeing with the slug production from TBD-6000, 

7 I think using that median as a constant seems 

8 to be a bounding approach, probably high, but 

9 there's enough uncertainty with the limited 

10 number of samples of where it's justified to 

11 use that kind of a number. 

12 CHAIRMAN ZIEMER: Okay. Board, 

13 you have any comments or questions? 

14 DR. ANIGSTEIN: I have two 

15 comments, and one is the -- I don't want to 

16 sound overly pedantic, but again, using the 

17 median as a constant there are two 

18 assumptions: one, there is an assumption that 

19 the single value that is reported is in fact 

20 an arithmetic mean which is a single value and 

21 that there is an underlying log normal 

22 distribution with a GSD, geometric standard 
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1 deviation, of five that contributes to that 

2 arithmetic mean and that you can then 

3 calculate the geometric mean, which also for 

4 the log normal distribution is the median, 

5 from that. These are simply not supported by 

6 the information. 

7 I mean, this is just -- I don't 

8 mean to -- there is a fourfold decrease from 

9 the corrected value if you account for the 

10 arithmetic error. There is a fourfold change 

11 from the reported value to the value that 

12 would be used if that calculational error was 

13 corrected. And there just does not appear to 

14 be just a -- I mean, that should be -- making 

15 an argument, plausibility argument, well, we 

16 think that it should be lower because there 

17 are some other -- there are some additional 

18 mechanical agitation going on. So we think it 

19 should be lower. 

20 Well, you can think it should be 

21 lower, but you cannot make a number out of 

22 that, with this kind of a manipulation, 
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1 without a sound scientific basis. We just 

2 don't feel that. I mean, I would say if 

3 anything, use the number and say, well, this 

4 is a bounding upper value because we really 

5 think it should be lower, but we're going to 

6 use this as an upper bound. So that's fine. 

7 You can use a number and then make a 

8 qualitative statement that this is a 

9 conservative number because here the following 

10 number should be lower. But not to then say 

11 we think it should be lower, so we're going to 

12 find some mathematical manipulation to just 

13 lower it to where we think it should be. Then 

14 you might as well pick the number out of a hat 

15 in the first place. And also --

16 CHAIRMAN ZIEMER: You feel it's 

17 still considered plausible if it includes --

18 DR. ANIGSTEIN: Say again?

19 CHAIRMAN ZIEMER: In your mind, do 

20 you still consider it to be a plausible number 

21 even if it includes --

22 DR. ANIGSTEIN: No.
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1 CHAIRMAN ZIEMER: -- the --

2 DR. ANIGSTEIN: Pardon me?

3 CHAIRMAN ZIEMER: -- things beyond 

4 the handling? You're saying use the --

5 DR. ANIGSTEIN: No, I'm saying 

6 that the -- I'm arguing at several levels at 

7 once, which is a little difficult. It's a 

8 little bit difficult to maintain that 

9 position.

10 MEMBER POSTON: It's harder to 

11 understand.

12 DR. ANIGSTEIN: Pardon?

13 MEMBER POSTON: And harder to 

14 understand.

15 DR. ANIGSTEIN: Oh, okay. I'm 

16 sorry.

17 CHAIRMAN ZIEMER: Well, I think 

18 that SC&A is --

19 DR. ANIGSTEIN: But I mean they 

20 keep going back to -- first of all, the slug 

21 stamping scenario is not necessarily a good 

22 surrogate. Second of all, the way it's used 
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1 -- I guess the way I'm doing it because my 

2 charge was to compare it to the five criteria 

3 and one of the criteria is: were the 

4 appropriate adjustments made? And I feel 

5 that, no, the adjustments that were made were 

6 not appropriate. 

7 And also, to jump ahead to 

8 something else that Dave said about the other 

9 sites that he looked at, one of the ones in 

10 his Figure 3, the Chambersburg Engineering --

11 it's a little hard to read. I dug out the 

12 original document. If you were to use the 

13 same philosophy that TBD-6000 used, and they 

14 picked, for instance, for the slug stamping, 

15 they did not the average, but they took --

16 there were like -- in Harris and Kingsley 

17 there were maybe five different values 

18 reported; I'm just going from my memory, and 

19 they picked the highest one.

20 Well, if you look at the 

21 Chambersburg and you pick -- and they give you 

22 high, low, and average for nine operations. 
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1 And if you pick the highest -- never mind the 

2 highest value, just the highest average value 

3 of those nine, it's 895 dpm per cubic meter. 

4 So that's not -- that belies, that contradicts 

5 that, oh, well, all of these other operations 

6 were lower. This is higher. The reported 

7 value is higher than the one, the slug 

8 stamping operation of 560, which is a single 

9 value, so it's taken to be the average. So 

10 here they give you the average and it's about 

11 one and a half times higher. 

12 MR. ALLEN: Bob, that is for 

13 controlling the impactor. That's after it 

14 comes out of the furnace and is forged. 

15 DR. ANIGSTEIN: Oh, okay. 

16 Impactor. Yes, and these are the inspector. 

17 No, I read the document, the discussion in the 

18 document. And they said, yes, this is 

19 interesting that the inspector gets a higher 

20 exposure than the actual workers.

21 MR. ALLEN: Well, I doubt that 

22 says inspector. I think it says impactor 
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1 operator.

2 DR. ANIGSTEIN: If you were to 

3 read the document, it says "inspector." I'm 

4 sorry, "impactor." I'm sorry, the inspector 

5 is somewhere else. I take it back. I stand 

6 corrected.

7 DR. MAURO: This is John. I'd 

8 like to jump in a minute. 

9 I think that where we are is --

10 you know, we think that the starting point; 

11 that is the stamping of the slugs, when all is 

12 said and done, which launches your surrogate 

13 approach. The process we just went through, 

14 both SC&A and NIOSH, in asking ourselves the 

15 question: are there better surrogates out 

16 there? And I think that where we're coming 

17 out is, it certainly appears that there are. 

18 What I mean by better, that is other data 

19 that's out there as a starting point that 

20 would appear to be closer to the kinds of 

21 handling materials that are associated with 

22 GSI. 
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1 So it then becomes a matter of, 

2 among the suite of alterative starting points 

3 for a surrogate are there any that fall into 

4 place. And this is how I'm looking at it, that 

5 seem to become -- and this is where the 

6 judgment comes in -- that seem to be a more 

7 reasonable starting place -- starting point? 

8 And then once you're -- if you could come to 

9 that place. And that's a simple question. If 

10 you can't come to that place, well, the whole 

11 surrogate approach, you know, then comes in 

12 question. Notwithstanding the mechanics that 

13 follow; the geometric mean, the arithmetic 

14 mean, the occupancy times, et cetera, et 

15 cetera, you know, that all becomes moot if you 

16 can't find the starting point. 

17 So I think it's important that now 

18 that we have a fairly nice collection of other 

19 starting points, some of which sound as if 

20 they're pretty close to the kinds of things 

21 that were done at GSI in terms of handling 

22 ingots or handling bars, that's really -- if 
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1 you can't get past that, we're really -- we 

2 can't make too much progress. But if we can 

3 find it, a place that people feel, well, this 

4 looks reasonable, then after that it becomes a 

5 matter of, okay, what do we do with that 

6 number next in order to make sure we're 

7 comfortable with it as it applies, as we go to 

8 use it at GSI. 

9 And I think that it's so easy to 

10 get lost in bouncing back and forth between 

11 these two subjects. I think we got to get 

12 through the first one. If we take it through 

13 the first one, it doesn't even make sense to 

14 talk about the mechanics that follow. 

15 DR. ANIGSTEIN: If I can add 

16 something to the question about the use of the 

17 Chambersburg data, I agree, I confused the 

18 inspector and the impactor. Nevertheless, 

19 what they handled at Chambersburg were 

20 half-inch by three- quarter-inch slugs. 

21 Little tiny pellets, half an inch diameter, 

22 three-quarters of an inch long. The total 
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1 quantity of uranium handled over a two-day 

2 period was 75 pounds. And the smallest piece, 

3 the slices, for instance, that they would have 

4 done at GSI would have been hundreds of 

5 pounds. If they had been whole ingots, that 

6 would be even higher. So these are not --

7 again, this is not a comparable operation.

8 CHAIRMAN ZIEMER: As far as 

9 handling is concerned is what you're saying?

10 DR. ANIGSTEIN: Yes.

11 CHAIRMAN ZIEMER: Yes.

12 DR. ANIGSTEIN: I mean, the 

13 material itself.

14 CHAIRMAN ZIEMER: Now my 

15 understanding, Dave, is that your selection of 

16 the geometric mean was focused on the 

17 plausibility issue that if you use the main --

18 or the tail end value, you would get an 

19 implausibly high number. Is that -- am I 

20 understanding correctly?

21 MR. ALLEN: Yes.

22 CHAIRMAN ZIEMER: And then we get 
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1 into this judgment issue of: what is it you 

2 select? Because that slug operation that 

3 you're using as a surrogate, which is the 

4 lowest in that hierarchy of possible 

5 applications in TBD- 6000, is still not just 

6 handling alone. It's handling plus something 

7 going on. And in the handling part, I mean, 

8 everybody agrees, is really at the very low 

9 end of all of this. And you're saying that if 

10 I use the slug thing, I'm implausibly high if 

11 I use the numbers as they are because they are 

12 handling plus something. Is that correct?

13 MR. ALLEN: Yes.

14 CHAIRMAN ZIEMER: Now, I suppose 

15 one could argue, but nonetheless they are 

16 still bounding. But then you have that 

17 plausibility issue which you're dealing with, 

18 and I sort of want to ask SC&A, because I 

19 started to ask you, Bob, do you consider it 

20 plausible to use the tail end value, the upper 

21 value of that? Or, John, if you want to chime 

22 in. 
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1 Or -- because it's not the 

2 stamping per se that is the issue. It's the 

3 handling. Now, the stamping thing is stamping 

4 plus handling. We're trying to get a handle 

5 on the handling part. Is there a way to get 

6 that? What would really make me uncomfortable 

7 is to say we know something is very low. And 

8 dose-wise we know that even if you use the 

9 implausibly high one, it's a very small 

10 fraction of the doses you assign from the 

11 external exposures. I don't recall the 

12 numbers. 

13 MR. ALLEN: It would vary with 

14 different organs.

15 CHAIRMAN ZIEMER: Yes, it varies 

16 in different organs. But anyway, is there a 

17 way to get a handle on that and meet the 

18 criteria?

19 DR. ANIGSTEIN: Now, see, the 

20 additional problem is it's not just the 

21 airborne exposure during the handling. There 

22 is the accumulation of the uranium dust on the 
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1 floor or uranium chunks which become grown 

2 into dust and the resuspension. So what isn't 

3 mentioned here is also the fact that we 

4 disagree with the resuspension factor. I 

5 mentioned that earlier. Ten to the minus six 

6 is not a plausible number for an active area 

7 where people, whether it was foot traffic or 

8 vehicular traffic -- it should be much higher.

9 And we disagree with the model. 

10 Regardless of what number you use, the model 

11 of how the uranium concentration builds up. 

12 We think it could be higher. So the argument 

13 NIOSH made is, well, this is not an important 

14 contribution, the resuspension. Not according 

15 to their model. But we would argue that it is 

16 in fact, becomes an important contribution if 

17 it's treated in a different manner and in a

18 way that we think is more defensible.

19 CHAIRMAN ZIEMER: Well, I don't 

20 think you're using 10 to minus 6 in the --

21 MR. ALLEN: Yes, we don't.

22 CHAIRMAN ZIEMER: For both 
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1 periods?

2 MR. ALLEN: For resuspension, yes.

3 CHAIRMAN ZIEMER: For the active 

4 period as well?

5 MR. ALLEN: Yes.

6 DR. MAURO: This is John. The 

7 plausibility, I think that that's causing 

8 difficulties for us all. When the 

9 plausibility clause, the last one, was added, 

10 the reason it came in; bear with me a little 

11 bit on this, is not for the reasons we're 

12 talking about now. It came in because there 

13 was a time when we were doing Texas City where 

14 there was an operation going on that in many 

15 respects was similar to what took place at 

16 Blockson in terms of using -- making uranium 

17 yellowcake. 

18 And the reason the plausibility 

19 clause came in; and this came in late, was, 

20 Blockson was being used as a surrogate for 

21 Texas City. Blockson was handling thousands 

22 and thousands of pounds of uranium. And the 
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1 whole idea was, while Texas City only handled 

2 300 pounds over a short period of time -- what 

3 I'm getting at was, plausibility did not 

4 relate to the model. 

5 We're talking about -- Bob, you 

6 used the term "plausibility," that the model 

7 was not plausible. I just want to make -- let 

8 everyone understand, when we came up with the 

9 term "plausibility" was the site you picked, 

10 the operations that you picked were -- and 

11 when this originally happened was -- you 

12 really can't use Blockson as a surrogate for 

13 Texas City. Because the amount of material 

14 that was being handled at Blockson was perhaps 

15 a factor of a thousand times higher over a 

16 different time period and it was very 

17 unrelated and it would be inappropriate to 

18 just throw some big number like Blockson at 

19 Texas City. And it was not a plausible 

20 scenario that somehow Blockson could be used 

21 as surrogate for the Texas City because of the 

22 -- just the sheer quantity of material that 
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1 was handled at Blockson. 

2 Now we're here today many years 

3 later and the plausibility clause is here. 

4 And I think that, Bob, you're referring to the 

5 model itself, the way in it's structured as 

6 being implausible. And I think that's true, 

7 but that wasn't really the intention. I think 

8 "implausible" means that you just can't use 

9 this particular facility as a surrogate for 

10 another facility, or that this exposure level 

11 of dust -- for example, you can't pick a level 

12 of dust that's very, very high, 

13 extraordinarily high and say it's bounding if 

14 it was implausible. And I think really that 

15 went to the heart of the whole plausibility 

16 issue. 

17 You just can't pick some very, 

18 very big number and say that, well, it's so 

19 big we know it could never have reached that, 

20 and then you walk away and you say, okay, no 

21 SEC because you can bound it. Well, that was 

22 the real reason it wasn't plausible to assign 
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1 such a high number and walk away and say 

2 everything is fine. 

3 I think it's inappropriate then to 

4 then extend the plausibility argument, at 

5 least as it was originally invented to, oh, 

6 you didn't model it the best way you could 

7 have modeled it. So I want to help out a 

8 little bit there. If we have a dispute over 

9 the model, I think we should discuss that, 

10 because that's solvable, you know, but -- and 

11 not refer to it as a plausibility issue. I 

12 think the plausibility issue is throwing some 

13 very, very big number and saying everything's 

14 fine. We got a big number we know is going to 

15 bound this, if it's impossible that that 

16 circumstance could have ever existed at GSI. 

17 And I think the stamping operation 

18 itself is just not applicable. And it 

19 certainly sounds to me that a number of other 

20 operations have been identified that seem to 

21 be a lot better. They also have their 

22 weaknesses, but they certainly appear to be 
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1 better. And to try to force-fit the stamping 

2 operation onto GSI seems to be a stretch.

3 CHAIRMAN ZIEMER: Any comments?

4 MEMBER MUNN: Yes.

5 CHAIRMAN ZIEMER: Okay, Wanda?

6 MEMBER MUNN: This entire 

7 discussion is extremely difficult. And one of 

8 the reasons it's so difficult is because we 

9 are talking as if we are dealing with an 

10 extremely hazardous material for which any 

11 exposure is problematic. 

12 In point of fact, the science 

13 surrounding uranium is quite well established. 

14 We know a lot about uranium. We know a lot 

15 about exposures that are subsequent to it. We 

16 know a lot about its suspend-ability. We know 

17 a lot about sizes of particulates that are 

18 necessary in order to create a biological 

19 hazard. And yet, we settle upon 

20 administrative issues surrounding processes 

21 that we've established here in the Board's 

22 deliberations at one time or another. 
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1 We're looking at details 

2 surrounding a possibility that is dependent 

3 directly upon an element we know a great deal 

4 about and that we can make legitimate 

5 statements about, supposedly without having to 

6 prove time and time again that something did

7 not happen. It is -- I'm unsure how to focus 

8 this discussion on large known issues 

9 surrounding the processes we're talking about, 

10 the physical processes we're talking about as 

11 opposed to the details of whether models are 

12 correct, whether activities did or did not 

13 generate dust, what kind of dust, how much, 

14 was it resuspended, was it not, what happened 

15 after the picture was taken? These are 

16 debates that assume there is a significant 

17 hazard in handling this material. 

18 And if we can't come to some 

19 reasonable assertion with respect to how to 

20 approach the larger questions rather than 

21 spending such a great amount of effort 

22 focusing on small issues, as we are right now 
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1 -- I recognize, the normal response of that 

2 is, well, the devil's in the details. Yes, 

3 that's true. One can't argue that. But we 

4 really are focusing here on whether or not 

5 we're dealing with models and minutiae, and 

6 I'm unsure how to get us off that. 

7 But plausibility is something that 

8 is not limited to surrogate data. 

9 Plausibility is a matter that we dealt with at 

10 the Board level and not always satisfactorily 

11 to the perception of all. I'm not sure that 

12 we can ever do anything about that, but we 

13 have done a remarkable job of holding up each 

14 one of these issues to the light and looking 

15 at it. I don't know how much longer we can 

16 continue to debate it. That's all I have to 

17 say.

18 CHAIRMAN ZIEMER: Okay. Well, 

19 yes, thank you for those comments. 

20 Nonetheless, we're going to have to deal with 

21 --

22 MEMBER MUNN: No solution.
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1 CHAIRMAN ZIEMER: -- the issue 

2 before us.

3 MEMBER MUNN: Yes.

4 CHAIRMAN ZIEMER: For example, on 

5 this first item I think we Work Group Members 

6 and eventually Board Members will have to 

7 decide whether they believe that the use of 

8 the stamping operation scenario or some other, 

9 if NIOSH wishes to propose something else, is 

10 a suitable surrogate. And you justified the 

11 surrogate in terms of using that versus some 

12 later data and back-extrapolating.

13 MEMBER BEACH: The 1993?

14 CHAIRMAN ZIEMER: The 1993 data 

15 and those kind of things. So the Board will 

16 need to decide whether or not that is a 

17 parameter, on the hierarchy of data, whether 

18 surrogate data is better in this case than 

19 actual data. That's on this --

20 MEMBER BEACH: Well, actual data 

21 from 40 years past.

22 CHAIRMAN ZIEMER: Right, 40 years 
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1 up the chain and --

2 MEMBER BEACH: And possible 

3 cleaning in between, so --

4 CHAIRMAN ZIEMER: Right. Right.

5 MEMBER BEACH: Yes.

6 MEMBER MUNN: You see, again --

7 DR. ANIGSTEIN: I guess, would 

8 this be a good time to -- because the 

9 alternative model is not just throw everything 

10 out and start from scratch. It shows -- it 

11 builds on the discussion we've had now. And I 

12 think I could bring this to a conclusion by 

13 showing how it compares to the other --

14 CHAIRMAN ZIEMER: Well, I'm 

15 concerned that we -- if the Advisory -- or if 

16 the Work Group here decides to recommend the 

17 use of the NIOSH approach, then that becomes a 

18 moot point, I suppose.

19 DR. ANIGSTEIN: I see. Okay. 

20 DR. MAURO: This is John.

21 CHAIRMAN ZIEMER: Yes. 

22 DR. MAURO: One thing, in working 
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1 with Bob along this and reading David's 

2 response, the light went on for me that said, 

3 you know, Bob's work, which we'll eventually 

4 get to, in a way could be looked at not as a 

5 replacement for, but as a validation. What I 

6 mean by that is we have this -- now we have a 

7 number of different starting points for 

8 surrogate data. We have the mechanics of 

9 processing that, modeling it, for better or 

10 worse, maybe improving on the model, and in 

11 the end coming up with some estimate with 

12 certainly a degree of uncertainty, for the 

13 airborne dust loading as a function of time 

14 using a surrogate data approach. 

15 And I like the idea that, okay, 

16 Bob comes and says, you know, wait a minute, 

17 there's a whole other way to come at this 

18 thing. And I'm thinking that that's not a 

19 replacement for -- and, Bob, you may not agree 

20 with me, but it's -- let's look at it more as 

21 where do we come out if we come at the problem 

22 from this direction, and do we come within an 
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1 order of magnitude when we come in from the

2 other direction from the range of values that 

3 we're looking at from the surrogate?

4 I almost see the two complementing 

5 each other, not being antagonistic to each 

6 other and I think that -- you know, so I've 

7 been looking at more as a whole picture and 

8 how does all this -- once you're done with all 

9 of this, something emerges from it and you 

10 start to get a degree of comfort that these 

11 independent lines of inquiry, different 

12 starting points, different assumptions. And 

13 then coming up with that -- do they all start 

14 to ring true and bring you to a central 

15 attractor in all this chaos that seems to say, 

16 yes, no, this is not a bad number?

17 Anyway, I wanted to preface that 

18 if we do move into Bob's work, because we 

19 could look at it from that perspective.

20 CHAIRMAN ZIEMER: Well, I guess 

21 I'd like to hear from NIOSH on the other 

22 criteria, too, and any comments you want to 
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1 make on any of those, Dave or Jim.

2 MR. ALLEN: Let me get to my report 

3 here and see what the --

4 CHAIRMAN ZIEMER: Well, on 

5 exclusivity constraints. 

6 MR. ALLEN: Yes, exclusivity 

7 restrain -- constraints. If -- and correct me 

8 if I'm wrong, if I remember right, the main 

9 comment on that was that the use of surrogate 

10 data was not stringently justified in Appendix 

11 BB, and we agree. We didn't think that small 

12 of a source needed much justification, but it 

13 definitely didn't use the criteria that was 

14 developed after the fact. And any revision in 

15 the future does need to include more of a 

16 justification for that use, so I don't 

17 disagree with that. The framework for that 

18 justification is right now intended to be this 

19 White Paper. 

20 As far as the site processes, 

21 we've pretty much discussed that before. 

22 There is no task of -- you know, process of 
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1 moving cold uranium metal. It is inherently 

2 included in any -- almost anything you do with 

3 uranium metal. And we can discuss it more if 

4 you want, but I think we've kind of discussed 

5 that one to death already.

6 The temporal considerations, I 

7 think Bob said he now agrees. And as I 

8 pointed out there, it's a physical property of 

9 uranium metal. It's not really site- or 

10 era-specific. 

11 And then the plausibility again. 

12 That's -- you know, we've --

13 CHAIRMAN ZIEMER: We've been 

14 discussing that.

15 MR. ALLEN: We've been discussing 

16 that one, so --

17 MEMBER POSTON: Paul, I think --

18 CHAIRMAN ZIEMER: Yes, John?

19 MEMBER POSTON: I think we have to 

20 recognize that we've just been re-calibrated 

21 by Wanda. Because if you think about uranium, 

22 it's not the dose that really plays the role. 
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1 I know that's the important thing because 

2 that's what the legislation says, but we're 

3 talking about damage to the kidneys. That's 

4 the important thing. And that has nothing to 

5 do with radiation at all. And so we're 

6 arguing --

7 CHAIRMAN ZIEMER: Well, it's 

8 chemical hazard, right.

9 MEMBER POSTON: So we're arguing 

10 about insignificant kinds of things, if you 

11 really want to get down it, and not focusing 

12 on the details that we need to be. Because we 

13 know what happens when you ingest or inhale 

14 uranium. We know where it goes. We know what 

15 the organs are at risk, and those are the 

16 kidneys from the nephrotoxicity of the 

17 uranium, not from the radiation dose. So 

18 we're arguing about things that, in a lot of 

19 ways, are not important.

20 MEMBER MUNN: Because they're 

21 outside the scope of the --

22 MEMBER POSTON: They're outside the 
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1 --

2 MEMBER MUNN: Of our charter.

3 MEMBER POSTON: So it seems we 

4 ought to be able to resolve this thing.

5 CHAIRMAN ZIEMER: It's true, but 

6 nonetheless NIOSH, for example, has to do 

7 something. 

8 MEMBER POSTON: Well --

9 CHAIRMAN ZIEMER: If there is an 

10 SEC, then it goes one way. If there's no SEC, 

11 they have to be able to reconstruct that part 

12 of the dose.

13 MEMBER POSTON: Yes. 

14 CHAIRMAN ZIEMER: And --

15 MEMBER POSTON: Well, you cut me 

16 off -- 

17 CHAIRMAN ZIEMER: And --

18 MEMBER POSTON: I said we should 

19 be able to resolve this.

20 CHAIRMAN ZIEMER: Right.

21 MEMBER POSTON: We spent a lot of 

22 time discussing models and, I mean, the data 
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1 that Bob showed, if you look at the three 

2 values that he showed under different 

3 situations, they vary almost by a factor of 50 

4 because they go from 88 to 

5 3,900-and-something. So how do you -- I mean, 

6 are we going to just pick blindly a value or 

7 something? I mean, Dave's picked a value and 

8 tried to justify it based on his 20 years of 

9 experience. And I'm not willing to argue with 

10 him because I have no experience in terms of 

11 the rolling and dealing with uranium. And I 

12 have been in a couple plants, but just on 

13 tour. So I can't argue that he's not 

14 justified those numbers simply based on his 

15 experience. Experience has to play a role 

16 here. And I'll shut up now.

17 CHAIRMAN ZIEMER: Okay. Other 

18 comments?

19 MEMBER BEACH: But that's also why 

20 we have the criteria to verify what surrogate 

21 data is being used. I mean, that has to come 

22 into play, too, which is why we're having this 
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1 discussion.

2 MEMBER POSTON: I agree. I agree. 

3 I understand that.

4 CHAIRMAN ZIEMER: Okay. We need 

5 to -- yes, before we discuss further, we need 

6 to give the petitioner an opportunity to 

7 comment on the SC&A document and on Dave's 

8 document. We need a break first.

9 Dan? Are you there, Dan McKeel?

10 DR. McKEEL: Yes, sir, I'm here.

11 CHAIRMAN ZIEMER: Yes, I didn't 

12 realize the time. We're going to take a 

13 15-minute break and then, if you would be 

14 prepared to address your issues on the 

15 surrogate data.

16 DR. McKEEL: That would be 20 

17 minutes of nine? I mean --

18 CHAIRMAN ZIEMER: Yes, about 20 

19 of. Yes. Yes.

20 DR. McKEEL: That would be 15 

21 minutes from now?

22 CHAIRMAN ZIEMER: Yes.
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1 MR. KATZ: And we have Patricia on 

2 the line, too. So she has the opportunity, 

3 too.

4 CHAIRMAN ZIEMER: Right. Sure. 

5 Sure. Okay. Thank you.

6 (Whereupon, at 10:26 a.m., the 

7 above- entitled matter went off the record and 

8 resumed at 10:41 a.m.)

9 MR. KATZ: The TBD-6000 Work Group

10 is back from a short break.

11 CHAIRMAN ZIEMER: Okay. We want 

12 to have an opportunity to hear from the 

13 petitioners on the surrogate data issue. And 

14 actually both Patricia and Dan -- and John 

15 Ramspott of course, as a site expert, may also 

16 want to comment. But in the -- Dan, I know 

17 you -- we have a number of comments we've 

18 received in writing from you, and I think all 

19 of us have those, but why don't you go ahead 

20 and add whatever comments you want to at this 

21 time on the issue of the surrogate data?

22 DR. McKEEL: Paul, this is Dan 
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1 McKeel. I guess I've got to say this: the 

2 remarks that I've prepared today were on the 

3 materials that were sent to me, which is the 

4 7/16 SC&A paper, the 7/25 alternate model 

5 paper.

6 CHAIRMAN ZIEMER: Right.

7 DR. McKEEL: And then I also sent 

8 a set of new data about the residual period.

9 CHAIRMAN ZIEMER: Right. 

10 DR. McKEEL: And --

11 CHAIRMAN ZIEMER: I think we all 

12 have those.

13 DR. McKEEL: Yes. And really my 

14 comments address all of those. So I'll try 

15 not to dwell on the alternate model because I 

16 understand that that has not really been 

17 discussed in detail, but the comments I have 

18 overlap all the things that we were talking 

19 about this morning. And I do want to get 

20 before you all the new information about the 

21 residual period, because I think it has an 

22 important bearing on how dose reconstruction 
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1 is done.

2 So my overall conclusion about the 

3 surrogate data findings by SC&A are that I 

4 agree with SC&A. And I have said since 2008 

5 actually that the slug facility does not meet

6 the criteria. And basically it's amazing to 

7 me that this issue has arisen so late in the 

8 game, but I'm glad it did.

9 I also want to comment that it's 

10 my opinion that the motion to examine 

11 surrogate data use at GSI was really too 

12 limited. It's been my opinion, still is, that 

13 the models that are based on computer codes 

14 and not validated by real measured data, which 

15 is very scant at GSI, are themselves instances 

16 of surrogate data and they should have been 

17 scrutinized as such.

18 I heard this morning a lot of 

19 discussion of uncertainty and I just need to 

20 add again for the record that, yes, there's a 

21 tremendous amount of uncertainty, but 

22 statisticians have developed a very formal 
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1 discipline of uncertainty analysis that can be 

2 applied to a variety of situations just like 

3 the things we've been discussing again today. 

4 In order to do that and to make it a 

5 plausible analysis, you have to have real data 

6 to base it upon or you really can't define the 

7 uncertainty components. And my strong feeling 

8 is that there is not the data needed to define 

9 uncertainty by any technique at GSI.

10 Dr. Poston just pointed out that 

11 even using the grouped surrogate data from 

12 other sites that NIOSH has recently collected 

13 and that Dr. Poston -- I mean that Dr. Mauro 

14 mentions as, you know, much better than what 

15 was used in Appendix BB, even there, there is 

16 a very large range between the low and the 

17 high values.

18 The other thing I've go to say as 

19 a general comment to what's been talked about 

20 this morning is that I frankly as 

21 co-petitioner and speaking for the GSI work 

22 force, I'm shocked to hear uranium dose 
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1 considerations described by words like 

2 unimportant, trivial, that the science is well 

3 known, that the issues we're talking about 

4 this morning are insignificant, when in fact 

5 TBD-6000 is designed expressly to consider 

6 uranium doses at uranium metal facilities. So 

7 for this program that we're dealing with, 

8 EEOICPA 2000, uranium dose is central and 

9 certainly is not a side issue.

10 As far as the known-ness of 

11 information about uranium, my comment still is 

12 that that is true. And that being true, then 

13 a lot more certainty should have been achieved 

14 in the years we've taken discussing Appendix 

15 BB and SEC 00105 about exactly what the doses 

16 were at GSI from uranium exposure. And I 

17 would say that the -- Dave Allen's paper and 

18 his response, which I do want to comment 

19 about, ignores a lot of this hard data. In 

20 fact, it starts off ignoring the fact that, as 

21 he puts it, GSI dealt with uranium billets, 

22 when in fact they dealt with ingots, dingots, 
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1 a few billets and betatron slices.

2 Anyway, I have this comment about 

3 Dave Allen's response to the SC&A surrogate 

4 data findings: the first thing, which is 

5 extremely important for the Board in making 

6 their recommendation is that Dave Allen agrees 

7 that the slug facility uranium operations were 

8 not rigorously justified for comparability to 

9 GSI under Appendix BB, Rev 0. His argument, 

10 however, that this was acceptable because 

11 Appendix BB was issued before the surrogate 

12 data were -- criteria were ratified by the 

13 Board, I think is a -- that that analysis 

14 misses the point of what's going on here. 

15 The NIOSH uranium intake model for 

16 1953 to 1993 is getting its final assessment 

17 now as far as appropriateness of adhering to 

18 the Board's surrogate data criteria. That's 

19 in August of 2012, and that's a couple of 

20 years after the Board's surrogate data 

21 criteria were finalized. So I just think that 

22 Dave Allen's argument does not pass muster on 
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1 that point.

2 I want to make a comment about the 

3 SC&A new alternate intake model, and that is a 

4 point that I've made before, that while I 

5 understand that SC&A's job is to do 

6 evaluations, it seems to me that this clearly 

7 is development of a new model. And in spite 

8 of what John Mauro said, the intent of the new 

9 model is to replace the TBD-6000 NIOSH model 

10 to be used in surrogate data, and the paper 

11 actually says that. 

12 The SC&A new model is supposedly 

13 based entirely on GSI data, but it's not. And 

14 Dr. Anigstein actually alluded to that this 

15 morning, saying that a few parameters were 

16 borrowed from the literature. I would add 

17 that a few of the parameters used in the 

18 alternate model were not defined as to what 

19 their source were. Basically, the SC&A model 

20 relies on differential equations and there are 

21 constants in those equations that need to be 

22 defined pretty precisely in order to even 
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1 evaluate the model that SC&A proposes. 

2 Anyway, Dave Allen responded to 

3 both the surrogate data paper and to the 

4 alternate uranium intake model proposed by 

5 SC&A. And in that paper he dismissed the SC&A 

6 model in one sentence basically saying you 

7 cannot back- extrapolate data 40 years from 

8 1993. And while I agree with that statement 

9 wholeheartedly, Mr. Allen, in saying this, 

10 also invalidates NIOSH's own June 2007 

11 Appendix BB uranium intake model that relies 

12 partly on uranium activity associated with a 

13 small industrial vacuum sweeper that was back14 extrapolated from the ORNL DOE cleanup under 

15 FUSRAP in 1993 at GSI.

16 The new information that I'm going 

17 to present to you all on the residual period 

18 years 1978 to 1993 provides very compelling 

19 evidence, I believe, that bounding the 

20 airborne uranium at GSI with sufficient 

21 accuracy for SEC 00105 Class members will be 

22 difficult or impossible. Dave Allen says the 
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1 new SC&A model has way more uncertainty than 

2 the surrogate data model that NIOSH uses from 

3 the slug factory. However, in saying that, he 

4 ignores SC&A's findings that use of the slug 

5 facility data has failed the five Board 

6 surrogate data criteria. And then he employs 

7 -- and I don't mean to be impolite, but this

8 is a scientifically absurd argument and 

9 basically his argument was that if one has no 

10 or insufficient real intake data, as is 

11 definitely the case at GSI, then one can use 

12 inappropriate surrogate data that violates 

13 Board SD criteria to bound uranium intakes. 

14 Mr. Allen also does not mention 

15 application of NIOSH's own surrogate data 

16 criteria in OCAS IG-004 to the slug facility, 

17 nor does he capture any differences between 

18 the NIOSH criteria and the Board surrogate 

19 data criteria, and I find that hard to 

20 understand.

21 Finally in his paper, Dave Allen 

22 does offer some new surrogate data sites that 
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1 could possibly be substituted for the slug 

2 facility used in TBD-6000, but it's 

3 interesting to me that two of those facilities 

4 make slugs which have just been ruled out as 

5 passing the Board criteria, and one of the 

6 sites deals with uranium billets. Neither one 

7 of the three sites actually dealt with uranium 

8 ingots and dingots which have a thick outer 

9 crust, which have magnesium fluoride coating 

10 them, which was subject to the Puzier effect 

11 that's not been mentioned. 

12 And so there's a lot of 

13 incorrectness and inaccuracy in accepting 

14 anything except data measured from handling 

15 uranium ingots and dingots in the way they 

16 were handled at GSI along a long transport 

17 path with chains and cranes. And there was a 

18 lot of indefiniteness expressed this morning 

19 about uranium that's well known. For 

20 instance, Dr. Anigstein mentioned that ingots 

21 and dingots were heavier. Well, their weight 

22 is known. They weight 3,000 pounds apiece. 
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1 And so it required big chains, big thick 

2 chains and big cranes. 

3 And they were placed on railway 

4 transfer cars which were never cleaned. So 

5 those cars were contaminated. The rail tracks 

6 that passed through building 6 and 7 along the 

7 foundry, through 8, 9 and 10, then went into 

8 railroad tracks into the new betatron 

9 building, railroad tracks branched outside and 

10 went into the old betatron building, that 

11 entire pathway was contaminated with uranium 

12 and none of that was measured. The only thing 

13 that ORNL and DOE measured in their cleanup at 

14 the end of the residual period was data from 

15 the new betatron building -- or they looked 

16 for uranium in the new betatron building. 

17 Didn't find any. And they found some residual 

18 uranium in the old betatron building. 

19 So that brings us to the final 

20 point that I want to go over, and that is the 

21 new information that primarily Mr. Ramspott 

22 has developed about the GSI residual period 
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1 from 1978 to 1993. And I've gotten that 

2 together for you all and transmitted that to 

3 the Work Group and the full Board. 

4 In brief, there were two known 

5 extensive cleanups, power pressure washings 

6 and rewiring and renovation campaigns, to the 

7 new betatron building. 

8 The first was in August 1978 by 

9 Michigan Metals Processing, who had a 

10 three-year contract with National Steel. The 

11 new betatron facility was cleaned up, rewired 

12 and power washed by the Power Blasting Company 

13 in August of 1978 and used thereafter for 

14 offices and classrooms. The Michigan Metals 

15 Processing contract work also included 

16 cleaning up buildings 8, 9 and 10 during the 

17 three-year period. 

18 And had ORNL, in my opinion, 

19 surveyed what they should surveyed, they would 

20 have been able to measure residual 

21 contamination in those buildings as well, but 

22 they didn't even try to do that. Apparently 
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1 none of the MMP workers wore protective 

2 clothing or respirators and an eyewitness 

3 states the subject of possible uranium 

4 contamination during this cleanup work was not 

5 mentioned. 

6 There was also a power washing by 

7 the Power Blasting Company to the old betatron 

8 building interior in 1984. And it was 

9 illuminating to me, Mr. Ramspott has 

10 photographs before the power washing was done 

11 and during the 1990s cleanup by DOE, and 

12 interestingly in the early photographs you can 

13 see that the walls of the betatron building 

14 are painted white. And in the photograph from 

15 DOE in 1993 or thereabouts you see that the 

16 concrete walls have almost been entirely 

17 stripped of the white paint. So this was a 

18 powerful blasting operation and I'm sure that 

19 mightily disturbed the uranium that was in 

20 that building. 

21 We believe a company named 

22 Affiliated Metals occupied former GSI building 
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1 6 during part of the residual period and 

2 continued the steel pickling operation that 

3 Michigan Metals Processing had initiated in 

4 1978 through '81. Thus large areas of the 

5 former GSI building complex and both betatron 

6 facilities were extensively renovated, 

7 cleaned, power washed with sufficient force to 

8 strip paint from the walls, rewired, paneled 

9 in the new betatron building and re-purposed 

10 for classroom work and pickling operations. 

11 This must have created massive disturbance of 

12 the surface dust on floors, walls, ceilings 

13 and in air vent ducts. 

14 It is difficult to imagine that 

15 this entire scenario could be modeled 

16 accurately both along the uranium transport 

17 and the NDT betatron paths even if you had 

18 monitoring data. However, during the same 

19 time period no workers were badged and there 

20 was no monitoring for uranium done except for 

21 the ORNL DOE FUSRAP survey of the old and new 

22 betatron buildings.
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1 When they found some uranium in 

2 the old betatron facility, I think it's not 

3 surprising, knowing that all this was done, 

4 that they found no residual uranium in the new 

5 betatron building. The problem is there is no 

6 monitoring data, so you can't make conclusions 

7 about how the uranium levels varied during the 

8 residual period, and it would just be 

9 impossible to calculate the exposure to all 

10 the workers who worked at that plant from 

11 cessation of the AEC contract in 1966 through 

12 1993.

13 So my conclusions are that NIOSH 

14 has no acceptable uranium intake model for GSI 

15 after three attempts. NIOSH rejects the SC&A 

16 July 25th, 2012 alternate intake model for 

17 uranium. Airborne uranium levels varied 

18 widely because of renovation and cleanup and 

19 re-purposing work in the GSI betatron 

20 buildings and buildings 6, 8, 9 and 10. 

21 Therefore we believe the conditions described 

22 cannot be modeled absent -- almost complete 
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1 absence of measured data at GSI. 

2 And that would conclude what I 

3 have to say about everything that was put 

4 before me for this meeting.

5 CHAIRMAN ZIEMER: Okay. Thank 

6 you, Dan. I wonder if Patricia Jeske has any 

7 comments.

8 MS. JESKE: Actually I do, and 

9 this is news to Dr. McKeel and John Ramspott 

10 as well, because I just found out this 

11 morning. They are not sure about Affiliated 

12 Metals being there. I have a brother-in-law 

13 by the name of [identifying information 

14 redacted] that worked there at that time. I 

15 just got the information. And I don't know 

16 what building he was in, but he would walk

17 through the tunnel just like my dad did at the 

18 old Commonwealth. So it was on State Street, 

19 and they had to wear gas masks and they could 

20 not take them off until they were outside the 

21 buildings. We don't know why, but we'll find 

22 out. That's really all I have to say right 
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1 now. Thanks so much.

2 CHAIRMAN ZIEMER: Thank you. And, 

3 John Ramspott, did you have any other 

4 comments? Where's John? If you're 

5 commenting, you're probably on mute. We're 

6 not hearing you.

7 MR. RAMSPOTT: I'm sorry. Yes, I 

8 was. 

9 CHAIRMAN ZIEMER: Okay.

10 MR. RAMSPOTT: I was on mute. 

11 This is John Ramspott. The cleanup 

12 information that Dr. McKeel is referring to 

13 came to me from various sources, some of them 

14 known to this whole Board. One gentleman in 

15 1978 worked at Michigan Metals just happened 

16 to tell me this situation by pure accident at 

17 an automobile dealership that I was at for 

18 service. Found out that he worked at the old 

19 Commonwealth or GSI plant in 1978-81. And he 

20 was actually one of the cleanup people, power 

21 hose guys or the water blasting operation. He 

22 personally did it, and he is definitely 
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1 available for an interview. He has no claim, 

2 no connection to this program until I happened 

3 to meet him a month or so ago. 

4 And one of the issues he brought 

5 up was he did know another gentleman that did 

6 it there and that gentleman happened to be the 

7 son of the man we all know was the last 

8 employee at GSI who had told us this story. 

9 Because if we check transcripts I'm sure I 

10 said something about power washing in that 

11 betatron building probably four or five years 

12 ago. So this is not new news. This is just 

13 now totally again verified news. 

14 The second cleanup that Dr. McKeel 

15 was talking about in the new and old betatron, 

16 after I'd heard the story from this guy, I 

17 recalled that an individual, of course known 

18 to us again -- he was a Dow worker who then 

19 went to school at Granite City to be retrained 

20 as the result of a work reorganization at Dow. 

21 While he was there getting ready to do the 

22 wiring, actually had to shut down that wiring 
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1 the first day and had the building totally 

2 power washed, cleaned. And he's known to 

3 everybody, too. And I'll be glad to share 

4 those names off-line. I know you don't like 

5 to have them now. But that's absolutely no 

6 problem.

7 So there's three totally different 

8 people from different directions all telling 

9 the same story and at different times. And 

10 what's really important about the times, these 

11 are all prior to the FUSRAP cleanup. So what 

12 FUSRAP walked in and saw was definitely 100 

13 percent not what was there during the contract 

14 period and the residual period. 

15 And if I recall correctly, at our 

16 last meeting, and I think it was Dr. Ziemer 

17 along with others that pretty much agreed, I 

18 think Mr. Neton, you can't separate the 

19 contract period from the residual period when 

20 it comes to certain things. You just can't 

21 separate them when you're going to try and 

22 talk about surrogate and slug usage. 
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1 So these cleanups all have to do 

2 with the contract period as well as the -- you 

3 know, we're talking about a little shop vac 

4 vacuum with some residual in it and trying to 

5 use that as the basis. Something that dawned 

6 on me yesterday, we don't even know when that 

7 vacuum was put in there. We don't know if 

8 Michigan Metals put it in there. Did 

9 Affiliated put it in there? Who put that 

10 vacuum in there? There's no mention of it in 

11 the GSI auction listing in '74.

12 Now, I'm not saying there wasn't 

13 probably some sort of cleaning mechanism in 

14 there before because GSI workers told me how 

15 they just about slipped and broke their neck 

16 on little pellets and BBs and dust in the 

17 betatron building. So we don't have good 

18 information on the maybe vacuum sweeper. So, 

19 you know, that's just -- this cleanup thing 

20 really concerns me. And it's all unprompted 

21 from individuals from totally different walks 

22 of life. Thank you for your interest.
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1 CHAIRMAN ZIEMER: Okay. Thanks, 

2 John, for your input on that.

3 Okay. Now, Board Members, we need 

4 to now consider some alternatives as well. We 

5 did sort of commit to SC&A that we would 

6 listen to some ideas that emerged out of their 

7 initial study. And I do want to go on record 

8 as pointing out that neither Ted nor I tasked 

9 in advanced SC&A to come up with an alternate 

10 model. That alternate model, we were informed 

11 of that when they had completed their 

12 preliminary review that they had considered 

13 some other ways of looking at the surrogate 

14 data issue. And in the process had -- I don't 

15 know if you'd say developed, but at least 

16 thought about an alternate way of doing 

17 things. 

18 They were never tasked to come up 

19 with an alternate model. I just want to make 

20 sure on the record that that's clear because I 

21 think that there are some that think that 

22 somehow we had tasked them to do that. And 
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1 this alternate model I don't think has been 

2 fully developed, but it's an idea that 

3 apparently emerged out of their analysis of 

4 the surrogate data issue. And I don't know to 

5 what extent it has even morphed from its 

6 original version. It sounded like from what 

7 John Mauro was saying earlier on the phone 

8 that perhaps they're thinking of it more as a 

9 different version of the surrogate data 

10 approach. 

11 But in any event, Bob, do you want 

12 to kick this off and tell us what your 

13 thinking was on that?

14 DR. ANIGSTEIN: Okay. Thank you, 

15 Paul. Well said. Just what happened was as 

16 we were reviewing, I was reviewing the 

17 surrogate data as we were tasked to do, I 

18 started thinking, it seems like there was some 

19 -- there should be another way of approaching 

20 this that would solve some of the problems 

21 using some of the -- using all the information 

22 we knew. There seemed to be something that 
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1 was being overlooked. And the something that 

2 was overlooked was the recently adopted 

3 OTIB-70 which gives default assumptions --

4 recommends default assumptions regarding 

5 resuspension rate -- is why we first looked at 

6 it. And also about a decay rate, or a removal 

7 rate, should be said, not to confuse it with 

8 radioactive decay. 

9 And they recommended a removal 

10 rate. And the removal rate also has to be 

11 consistent with the resuspension rate. So 

12 here you have two numbers that are linked 

13 together. And the fact that there was this 

14 detailed -- because I don't believe there was 

15 any drastic changes made in the old betatron. 

16 It was well explained why there was no 

17 residual contaminated powder in the new 

18 betatron building because it had been cleaned 

19 up prior to the FUSRAP. But the old betatron 

20 building more than likely remained -- I mean, 

21 if there was any cleanup, it would only --

22 right. It seemed to me -- what I'm giving you 
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1 a preview was, we have found something that's 

2 internally consistent. 

3 So the -- oh, I'm sorry. Wrong 

4 slide. Okay. So here's a little picture I 

5 found. I didn't create it entirely. I 

6 modified it somewhat. Here's what happens in 

7 the typical -- with this -- this whole thing, 

8 it's very easy to talk about resuspension 

9 factor, re- deposition. What does it really 

10 mean?

11 So here you have a little house, a 

12 cartoon of a house and you have something 

13 coming in from the outside. Doesn't matter 

14 what it is. So it comes in by infiltration 

15 through the walls, tracking, which is really 

16 not relevant here. Might be somebody 

17 literally picks it up on their feet and tracks 

18 it in like somebody tracking mud into the 

19 house. So here's this contaminant. Now also 

20 there may be some coming from outside. There 

21 may be some generation which is really 

22 relevant here. 
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1 Some material is being -- airborne 

2 material is being generated. And this stuff 

3 gradually falls by deposition. And then you 

4 have resuspension, which is two-way actually. 

5 I added the other arrow to show it's going 

6 down and it's coming up again. Under 

7 equilibrium and absent anything else, these 

8 two would be the same. And then you have 

9 cleaning, ordinary housekeeping and 

10 exfiltration. You have a little bit on the 

11 person coming in. So this is how any material 

12 can accumulate inside the structure.

13 And to model it, we first go back 

14 and look at what comes in. Well, here are the 

15 uranium handling times based on the 

16 Mallinckrodt purchase orders. This is similar 

17 to what you find in Appendix BB, except maybe 

18 a couple of changes. They made an assumption 

19 that one of the later periods was -- they 

20 extrapolated one of the later periods back to 

21 the beginning. Since there are no purchase 

22 orders from 1953 until end of February 1958, 
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1 the conservative assumption is to assume that 

2 it's the highest rate of any of the years for 

3 which we do have purchase orders. 

4 We take that the handling -- we 

5 just take the number of hours in this -- any 

6 one of these periods and take the number of 

7 hours that Mallinckrodt was paying for. 

8 Divide one by the other and you get a 

9 percentage. So it ranks a maximum of almost 5 

10 percent and a minimum of 0.15 percent at the 

11 very end when there wasn't much going on.

12 And here's the mathematical 

13 formulation. I've just -- it can be -- it's

14 not as -- it's really simpler than it looks. 

15 This is simply the rate of change. This is a 

16 generic equation. This is the rate of change 

17 of the contamination level on the floor. And 

18 this is -- and there is some removal fraction; 

19 I called it the Greek letter mu, which is 

20 proportional to the rate of -- to what is on 

21 the floor, that some fraction is being 

22 removed. 
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1 And then there's a deposition that 

2 is a constant hourly rate or daily rate, just 

3 to keep the units consistent, which we don't 

4 know yet, but multiplied by the fraction of 

5 time. Well, the fraction of time is simply 

6 these fractions that are here for each time 

7 period. So this is different. So this is the 

8 sigma sub i. There's a number of time 

9 periods. Basically these 3, 6, 9, 11 time 

10 periods. So it's different for each time 

11 period, but we model each one separately. 

12 And this is the removal rate of 

13 6.7 times 10 to the minus 4 per day in OTIB-70 

14 that's recommended as the default removal 

15 rate, and it's based on several places where 

16 these measurements were made. And I don't 

17 have it in front of me, but they don't span 

18 that big a range. It's a pretty robust number 

19 because the numbers maybe change by a factor 

20 of two between the highest and the lowest. 

21 I'm just guessing now by memory. 

22 So then when we do the 
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1 mathematical manipulation of this to solve the 

2 equation, you come up with an expression for 

3 the contamination due to each of these time 

4 periods. Now so they're modeled separately 

5 and then we add them together. And this is 

6 the actual surface activity on the floor at 

7 any given time due to summing the contribution 

8 from all of these individual time periods.

9 Now you notice I said nothing here 

10 about how many -- or what is -- what fraction 

11 of the time it's actually being handled. 

12 Because of this here, we know -- this is the 

13 fraction of all -- this is the total handling, 

14 and NIOSH assumed 50 percent. We don't need 

15 to know that because we do know that it's 

16 simply -- this is how it varies from one year 

17 to another, which is all you really need to 

18 know for the purpose of this model. 

19 Then you need some real data. 

20 Okay. This is the drawing of the old betatron 

21 building. And they made measurements, two 

22 sets of measurements. The red -- I'm just 
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1 giving for matter of interest. This is the 

2 biased sample. This is where they went with a 

3 meter and said, wait a second, there's a hot 

4 spot here. And then they take their detector 

5 that will measure the alpha activity and make 

6 a measurement at that spot. So these are 

7 biased samples. They're deliberately looking 

8 for the high spots.

9 Then separately from that they 

10 took an unbiased. There is a procedure called 

11 MARSSIM. It stands for manual --

12 unfortunately I can't remember the exact 

13 acronym. It's a basic guide used by all the 

14 government agencies that contributed. NRC, 

15 DOE, EPA contributed to it. When you go in 

16 and you want to clean up a facility, how do 

17 you sample to see what the average activity 

18 level is? And there is a way of selecting 

19 locations. And these are the blue. These are 

20 the randomly selected locations that are 

21 designed to give you a cross-section, a 

22 representative picture. 
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1 You can't sample each and every 

2 spot, because we're talking about something 

3 with about three -- a little disc about 

4 three-and- a-half-inch radius. And based on 

5 these random samples, most of them albeit were 

6 below minimum detectable activity. Minimum 

7 detectable activity was assumed -- was 50 

8 dpm/100 cm2. The reason they use 100 square 

9 centimeters is because that happens to be the 

10 active area of the detector, 100 square 

11 centimeters. So it's how many dpm on a 

12 detector. 

13 MEMBER BEACH: Bob?

14 DR. ANIGSTEIN: So by standard 

15 procedure we assume that it's half. 

16 MEMBER BEACH: Excuse me.

17 DR. ANIGSTEIN: Yes?

18 MEMBER BEACH: Would you remind 

19 what date those samples were taken?

20 DR. ANIGSTEIN: Yes, these 

21 measurements were made in I believe June 1993. 

22 That's by definition the end of the residual 
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1 period because that's when they cleaned it up.

2 MEMBER BEACH: Thank you.

3 DR. ANIGSTEIN: However, they did 

4 get a number of real measurements. So if we 

5 take the MDAs and say, well, 50 is the least 

6 they could detect, so we'll just assume that 

7 it's half that; it's a pretty standard 

8 procedure, and we assign it to 25 dpm/100 cm2, 

9 then I convert it here to becquerels per 

10 square meter to be consistent with the model, 

11 it comes out to 43.6. You know, most of them 

12 were based on if we just took the ones where 

13 we had meaningful data, it would not be a very 

14 robust model.

15 So taking that, we can actually 

16 calculate the hourly rate of accumulation 

17 during the period of uranium handling 

18 operation during the intervals. And it comes 

19 out to -- knowing what this term is solving 

20 the equations, that it was June 7th, 1993; to 

21 answer your question, Josie, we find that the 

22 average -- that the measured was 43.6 
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1 becquerel per square meter. We find a 

2 deposition rate of about 1,200 becquerel per 

3 square meter per day. We prorated to a day. 

4 The actual operations take less than a day. 

5 So you could divide by 24 and have an hourly 

6 rate. 

7 And so now we know the rate at 

8 which it had to be deposited. And the only 

9 two things that go into this, the only two 

10 assumptions is that removal rate of 6.7 times 

11 10 to the minus 4 per day; that's one datum, 

12 and the other one is the 43.6 average activity 

13 at the end of the residual period. And with 

14 these two things you say this had to be, given 

15 the pattern of activity -- so much in one 

16 year, so much in another year, increasing, 

17 decreasing, all of these add up to a single 

18 number. 

19 And now with this number, we can 

20 say what would be in the air due to 

21 resuspension. Well, we know that 1 times 10 

22 to the minus 5 is a good resuspension factor. 
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1 There is a huge body of literature on 

2 resuspension factors. They vary a great deal. 

3 Ten to the minus six, which was used by 

4 NIOSH, was adopted by NRC for a facility that 

5 has already been cleaned up. It's a 

6 decommissioned facility that has been cleaned 

7 up to the extent practicable using the ALARA, 

8 as low as reasonably achievable, and they say 

9 that after it's been cleaned there's still 

10 going to be some residual on the floor and 

11 there will be some possibility of 

12 resuspension. And they picked 10 to the minus 

13 6 as a good number. 

14 But that's something -- the 

15 concept is important. There is very little 

16 resuspend- able material left. It's all, 

17 like, hardened. Everything that's easily 

18 resuspend-able -- because also the same could 

19 be swept up, vacuumed, washed off. So that's 

20 a number -- that's for an inactive facility. 

21 A facility where the stuff is being deposited 

22 every day or every few days, that's not a good 
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1 value. 

2 So 10 to the minus 5 seemed like a 

3 good compromise value, because, true, now some 

4 of the activity will be old because it's 

5 depositing year by year and there's some 

6 removal -- some unspecified removal mechanism. 

7 So it seems like a good, reasonable number. 

8 And I'll go a little further and demonstrate 

9 why it's a good -- it's not just our opinion.

10 And then there is a second source 

11 of activity, which is of course what happens 

12 -- this takes place all the time, you know,

13 every day of the year. This takes place only 

14 during the uranium handling period. And now 

15 that we know what we just derived are the rate 

16 of the accumulation, you just divide by the 

17 velocity, this average velocity of 10 to the 

18 minus -- 7.5 times 10 to the minus 4 and you 

19 can calculate what would be the activity due 

20 to the uranium handling. So during this time 

21 the actual activity in the area is the sum of 

22 these two. But in between the uranium 
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1 handling, you get only this. 

2 And then finally, what do we end 

3 up -- what's -- basically what's the bottom 

4 line? What is the intake? Well, we find that 

5 year by year -- we just did this in case --

6 just to show that this can be used for dose 

7 reconstruction. At the very beginning, at the 

8 first year there's very little resuspension 

9 because nothing has accumulated yet, not very 

10 much. So all the activity, almost all the 

11 activity is due to uranium handling as year 

12 after year, it accumulates on the floor. And 

13 now the resuspension becomes a bigger factor 

14 up until you get to about 1963 where it's the 

15 dominant factor because there is much less 

16 handling. 

17 And so how we come up against 

18 NIOSH, here is Appendix BB, the total dpm per 

19 calendar day, and we come up with more than 10 

20 times that during the very busy time up 

21 through about 1963. And then we start falling 

22 off. And then during the far part of the 
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1 residual period -- in the original report, 

2 it's tabulated every year. I condensed it 

3 here so it fits into one slide. So you start 

4 -- you end up by 1988 -- we actually end up 

5 with lower simply because NIOSH does not have 

6 this decline. They have it constant and we 

7 have the decreasing year by year. 

8 Now the -- why does this make --

9 why is this plausible? First we compare what 

10 would be the derived, that is before the --

11 during the actually handling operation? We 

12 calculate 11 -- by the way, we -- excuse me. 

13 Forget that. So we have 1,100 dpm per cubic 

14 meter. How does this compare with the 

15 measured value? Well, it's less than the 

16 unloading from the truck at Adley. 

17 But if you just take these three 

18 values and take a geometric mean, that makes 

19 sense because it's -- you know, when they're 

20 so different, it makes more sense to do a 

21 geometric mean rather than an arithmetic mean, 

22 563, well, within a factor of 2. For the 
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1 model starting out from that, not bad. And 

2 it's not that different, by the way, from the 

3 slug stamping operation, which also is 

4 somewhere around 560. So we're within the 

5 right ballpark.

6 Then next: a verification. This 

7 is not to -- this is only a verification 

8 calculation. What kind of an air exchange 

9 would you need if you were to assume a 

10 resuspension factor of 10 to the minus 5 and 

11 if you were to use the fractional removal rate 

12 of 6.7 times 10 to the minus 4 per day, and 

13 you were to assume no other removal; no 

14 cleaning, no washing, that the only removal 

15 was that the dust accumulation on the floor 

16 gets suspended in the air and the building 

17 ventilation takes it out? And you would get 

18 -- you would need an air exchange rate of 

19 approximately one-quarter of the volume per 

20 hour. 

21 For a large building that's not a 

22 bad estimate because the larger the building, 
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1 typically the lower the air exchange rate is 

2 simply because the air exchange rate depends 

3 on the wall area; the windows, the roof, the 

4 wall area. Now the surface -- the ratio of 

5 the surface to volume gets small with large 

6 buildings. So therefore, for a very large 

7 building, less than one-quarter of an exchange 

8 per hour is not unreasonable. A more common 

9 one is one per hour, but it would be for a 

10 smaller building. There have been buildings 

11 where as little as one-tenth of a volume per 

12 hour has been measured. Actual measurements.

13 So this looks -- all we can say 

14 is, you know, are these numbers -- you know, 

15 I'm shooting myself in the foot now, you know, 

16 are these numbers exact? No. It's not 

17 possible to have an exact number, but these 

18 are plausible upper bounds. And they're based 

19 on documented data, so it's not just something 

20 we like this -- we pull this number up out of 

21 a hat because we like it. 

22 And we think that this is a 
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1 reasonable way of approaching the problem 

2 which would give -- which would be bounding 

3 and yet not implausible. It gives you -- say 

4 this 1100 dpm per cubic meter for natural 

5 uranium corresponds -- I did the calculation 

6 -- to less than a milligram per cubic meter. 

7 That is not an unreasonable dose concentration 

8 for indoor air. They're on the order of 

9 micrograms up into the hundreds. This is 

10 already in the high end. It's not -- it 

11 doesn't get to the point where we had like 

12 with the Bethlehem Steel. I know we actually 

13 did calculations. It gets to a point you 

14 can't even see across the room it would be so 

15 thick.

16 So I'm just suggesting that this 

17 is a plausible model which is not dependent 

18 except for the air exchange, for the removal 

19 rate is not dependent on external 

20 calculations. That's it.

21 CHAIRMAN ZIEMER: Bob, what is the 

22 implications of the cleaning that Dr. McKeel 
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1 mentioned on this particular --

2 DR. ANIGSTEIN: I don't believe 

3 it's on the -- I believe they were referring 

4 to the new building, to the new betatron 

5 building. All of that -- I read over the 

6 material.

7 CHAIRMAN ZIEMER: I thought that 

8 they were all cleaned. Is that not correct?

9 MR. RAMSPOTT: Dr. Ziemer?

10 CHAIRMAN ZIEMER: Yes.

11 MR. RAMSPOTT: This is John 

12 Ramspott. Since I'm kind of the cleaning 

13 expert; the gentleman told me I could use his 

14 name, [identifying information redacted] from 

15 Dow was there in '84 and saw the cleaning of 

16 the old betatron building. He was also there 

17 in the same time frame and saw the cleaning of 

18 the new betatron building. The old 

19 betatron building, in looking -- well, Dr. 

20 Anigstein, his drawings up there, if you look 

21 at the one with the red dots, blue dots, it's 

22 pretty interesting. Take a look at that, if 
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1 you would. That's from the cleanup material, 

2 the FUSRAP cleanup material. If you notice 

3 that berm that's shown on there --

4 CHAIRMAN ZIEMER: Yes.

5 MR. RAMSPOTT: -- that wasn't 

6 there during the GSI dates. That came in 

7 after the fact, after that plant closed 

8 because they stored leaky electronic 

9 transformers in there. That's in the FUSRAP 

10 report. I kind of find it amazing there's 

11 nothing in there. Well, if I was there in '93 

12 and doing a cleanup for FUSRAP, I probably 

13 wouldn't want to climb in that 

14 PCB-contaminated oil that they built. And the 

15 berm was about an 18-inch wall. We have 

16 pictures of it from a DOE cleanup, some really 

17 good color photographs that was provided to 

18 myself and Dr. McKeel from the Department of 

19 Energy. That area, 25 percent of the shooting 

20 vault area, and it's not touched. No one's 

21 looked at it. 

22 Then the other series of red dots 
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1 over in the right-hand corner, I think from 

2 the FUSRAP drawings that's where the vacuum 

3 cleaner was. I kind of find it amazing that 

4 there's nothing in between that and the berm. 

5 That's where the guys worked. That berm is 

6 right in the work space. That's where 

7 according to FOIA drawings a lot of work was 

8 done. If they had a source, that's where they 

9 worked. That's where the betatron crane would 

10 hang. And there's nothing there. I find it 

11 kind of unusual because they wouldn't be 

12 examining those dingots on top of the vacuum 

13 sweeper. I guarantee you that. 

14 And then the other series of red 

15 dots on the railroad tracks, I find that kind 

16 of amazing too because the betatron doesn't go 

17 there. Those red dots got there somehow. And 

18 more amazing is they're in between the control 

19 room and the vault and the control room is 

20 shown as totally clean. Now if the guys 

21 walked through those red dots, I mean, every 

22 day, every moment into the control room, you'd 
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1 think there would be something in the control 

2 room. 

3 Now that building definitely, 

4 according to [identifying information 

5 redacted], was cleaned. And we had heard the 

6 story about the power cleaning from another 

7 gentleman, [identifying information 

8 redacted], [identifying information redacted]

9 is his nickname, who was the last guy at GSI. 

10 It was his son who did that cleaning with 

11 this other individual I happened to meet at 

12 the car dealer. 

13 So that building -- Dr. Anigstein, 

14 that building definitely was, according to 

15 [identifying information redacted], cleaned 

16 as well. And he explained the cleaning. 

17 [identifying information redacted] said they 

18 cut power to all the buildings. [identifying 

19 information redacted] was an electrician. 

20 They cut the power completely so they could 

21 squirt or power blast the roof, the walls --

22 or the ceiling, the walls, the floors. And 
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1 that -- now there was a major, major 

2 disheveling of the interior of that building. 

3

4 And also from FUSRAP they show two

5 betatrons sitting on the floor of that 

6 building. Those things weigh 4,000 pounds 

7 apiece. You don't just flip them around. I'm 

8 sure the second one that was in there came 

9 from the betatron building. We know that now. 

10 But there was only betatron in this old 

11 betatron building originally. You'd have to 

12 bring that in with a forklift, high lift, 

13 something. That floor had been -- that floor 

14 was definitely not what it was when GSI 

15 workers were working there during the contract 

16 period and the residual period. That changes 

17 everything.

18 CHAIRMAN ZIEMER: Right.

19 MR. RAMSPOTT: Because this whole 

20 alternative is somehow being based on 1993 

21 samples. That's a little late. So I 

22 appreciate it. I'm open to any questions. 
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1 And all of these people I'm talking about are 

2 willing to be interviewed. Thank you.

3 CHAIRMAN ZIEMER: Okay. Thanks, 

4 John. My understanding of this drawing is 

5 that these are the locations where they 

6 sampled. This is not necessarily where they 

7 found activity.

8 DR. ANIGSTEIN: No, the red ones 

9 --

10 CHAIRMAN ZIEMER: The red is a 

11 biased sample, which means they didn't select 

12 the location randomly. They selected it 

13 intentionally.

14 DR. ANIGSTEIN: Right. No, the 

15 red -- my understanding with the red ones, 

16 they went around with an alpha-beta -- with a 

17 beta- gamma meter --

18 CHAIRMAN ZIEMER: Okay.

19 DR. ANIGSTEIN: -- rapidly 

20 surveying. And where it chirped, then they 

21 would get out the --

22 CHAIRMAN ZIEMER: Oh, I got you.
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1 DR. ANIGSTEIN: -- detector and do 

2 it and take a reading.

3 CHAIRMAN ZIEMER: Got you. Okay. 

4 MR. RAMSPOTT: Dr. Ziemer?

5 CHAIRMAN ZIEMER: Yes?

6 MR. RAMSPOTT: There is another 

7 drawing in the cleanup report that really 

8 clearly shows the same red dots as being hot 

9 areas that had to be cleaned. And I might add 

10 that when we visited the site, Dr. McKeel and 

11 myself and some workers with the new owner who 

12 let us go in there and photograph it, those 

13 are parts of the floor that are definitely 

14 scarred. I mean, there was -- I assumed there 

15 had to be dust there, but some of that was so 

16 ground in they actually used a -- I think they 

17 called it scalping.

18 CHAIRMAN ZIEMER: Yes. Yes.

19 MR. RAMSPOTT: You could see the 

20 gouges.

21 CHAIRMAN ZIEMER: Got you. Yes. 

22 DR. ANIGSTEIN: Let me --
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1 CHAIRMAN ZIEMER: Yes, I see them. 

2 Yes. Thanks. Appreciate that clarification.

3 DR. ANIGSTEIN: John? Let me 

4 correct something, John.

5 MR. RAMSPOTT: Sure.

6 DR. ANIGSTEIN: John Ramspott. 

7 The red dot -- you're going to see the red 

8 dots there. I put the red dots there, the red 

9 and blue dots, to correspond to the readings 

10 on the table, that if you look on the next --

11 my -- you know, on another page where it has 

12 -- you have the original report. You don't 

13 have this one. The alpha activity 

14 concentration, you see sample locations north 

15 and east. So those are the coordinates of the 

16 locations where they made the measurements. 

17 And I simply plotted those coordinates on 

18 here. So this is a --

19 MR. RAMSPOTT: Ah, okay. I see.

20 DR. ANIGSTEIN: This is a 

21 composite.

22 MR. RAMSPOTT: Yes, I saw -- the 
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1 drawing is definitely in the cleanup report.

2 DR. ANIGSTEIN: I took the --

3 that's where I got it from.

4 MR. RAMSPOTT: Does that mean 

5 there's also a drawing just like this that 

6 shows the actual sites, not just numeric?

7 DR. ANIGSTEIN: Yes, there was 

8 harder -- but they were much harder to 

9 interpret, so I recalculated them.

10 MR. RAMSPOTT: The other one is 

11 more exact, I understand that, but the fact is 

12 the material is where your red dots are and 

13 the material is where the uranium was on the 

14 drawing that's in the cleanup.

15 DR. ANIGSTEIN: Right.

16 MR. RAMSPOTT: Okay.

17 DR. ANIGSTEIN: Yes.

18 CHAIRMAN ZIEMER: Okay. Thanks 

19 for clarifying that. 

20 Okay. Questions?

21 DR. McKEEL: Dr. Ziemer?

22 CHAIRMAN ZIEMER: Oh, yes?
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1 DR. McKEEL: This is Dan McKeel.

2 CHAIRMAN ZIEMER: Oh, yes, Dan. 

3 Go ahead.

4 DR. McKEEL: Could I just quickly 

5 say one sentence?

6 CHAIRMAN ZIEMER: Yes.

7 DR. McKEEL: So one thing that I 

8 need to emphasize, I listened to that very 

9 nice exposition by Dr. Anigstein of his 

10 alternate model, but my comment is that the 

11 SEC recommendation that the Work Group and the 

12 full Board must make, it is really based 

13 entirely on what NIOSH can bound with 

14 sufficient accuracy. 

15 So with all due respect, NIOSH and 

16 Dave Allen have already said in their response 

17 paper that they do not accept the SC&A 

18 alternate model and will not use it. And all 

19 NIOSH can recommend is that they will take the 

20 three additional sites, the two slug 

21 facilities and the billet facility, more 

22 surrogate data and make some kind of an 
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1 adjustment to a revised Appendix BB. 

2 And so really the bottom line is 

3 that -- and I hope you all will consider is 

4 that NIOSH will not accept the SC&A alternate 

5 model, however elegant it may be. And what 

6 the Board and the Work Group has to 

7 concentrate on is what can NIOSH do. And 

8 that's the sole criteria for making a 

9 recommendation about SEC 00105.

10 MR. KATZ: Well, Dan --

11 DR. McKEEL: Thank you very much.

12 MR. KATZ: Dan? Thanks, Dan. Let 

13 me clarify. That is actually not the Board's 

14 charge under the regulations, which is the 

15 Board's charge is to determine whether doses 

16 can be estimated with sufficient accuracy. 

17 There's no qualifier such as you're suggesting 

18 as to whether NIOSH's method is applied or any 

19 other method is applied. But the Board's 

20 charge is whether doses can be reconstructed 

21 with sufficient accuracy, end of statement.

22 DR. McKEEL: This is Dan McKeel. 
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1 I have to respond to that. We can't complete 

2 this argument, but I could not disagree more 

3 completely with what Mr. Katz just said and I 

4 think that it is very well understood that the 

5 role of the Board and the role of SC&A is to 

6 evaluate NIOSH's methodology.

7 MR. KATZ: Dan, I'm speaking from 

8 the regulations. We don't need to continue 

9 this discussion. But these are what the 

10 regulations specify and lay out for the Board.

11 CHAIRMAN ZIEMER: Okay. We're not 

12 going to discuss the regulations today. I 

13 think certainly we have to respond to NIOSH's 

14 proposal, and one of the things Board does is 

15 in fact indicate whether they agree or 

16 disagree. And we need to find out actually 

17 what NIOSH's approach will be. I mean, one of 

18 the reasons we meet is to hear each other's 

19 ideas. And historically in all of the sites, 

20 we try to come to some point of -- where we 

21 can agree, we'll agree. If we can't, we 

22 disagree. But, and I don't know if we're 
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1 there yet, but I don't think it's the 

2 petitioner's position to have to say what 

3 NIOSH will do. NIOSH will have to state what 

4 they will do. 

5 And so, Josie, you have a comment?

6 MEMBER BEACH: And just an 

7 addition to that, because I know Dave's going 

8 to speak here. I was wondering if you're 

9 going to use this new information on the 

10 facility cleanup, or are you going to consider 

11 it, and how?

12 MR. ALLEN: Well, right now the 

13 position I have in that White Paper was to 

14 essentially say the 198 dpm per cubic meter we 

15 used in Appendix BB is bounding. I tried to 

16 justify it by the surrogate data criteria and 

17 come up with a few other data points from 

18 other sites to point out that it is indeed a 

19 bounding value. 

20 We have not, despite what was said 

21 here, completely dismissed Bob Anigstein's 

22 model as a -- you know, a showstopper, but I 
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1 do think there's other sources of uncertainty 

2 in that model such as the cleanup which was 

3 pointed out which changes that depletion rate, 

4 not to mention the heterogeneity of the 

5 contamination after you do that cleanup. 

6 And I know he didn't use the 

7 biased samples. He used the random samples to 

8 try to avoid that, but I think there's still a 

9 lot of heterogeneity in cracks and crevices, 

10 expansion joints, railroad tracks, you know, 

11 et cetera, where power washing can drop all 

12 that in there and virtually fix it in there to 

13 where it doesn't change over a number of 

14 years. 

15 So currently I believe the 

16 surrogate data is a better approach, a more 

17 accurate approach. And I think the data that 

18 we've pulled up from the other sites that is 

19 limited, points to the idea that the numbers 

20 we are using are actually very conservative. 

21 And my intent at this point, my 

22 true intent at this point is to see what the 
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1 Work Group feels about this, you know? But my 

2 recommendation at this point is we use the 

3 same number that's in Appendix BB, the 198 dpm 

4 per cubic meter. There may be some 

5 adjustments if we want to discuss as far as 

6 how that it is used in a model, but as John 

7 Ramspott -- or, I'm sorry, as John Mauro said, 

8 the question is the starting point right now.

9 And then the other items we're 

10 talking about are the mechanics that are 

11 essentially -- you know, one's an SEC issue. 

12 And after that you're into the TBD issue part 

13 of it. And I don't think we've gotten really 

14 any feedback from the Work Group yet as to the 

15 starting point and whether it's worth pursuing 

16 the mechanics of it. Did that make any sense?

17 CHAIRMAN ZIEMER: Also, I just 

18 want to emphasize that whatever the Work Group 

19 does is simply recommendation, but the Board 

20 could go in another direction. So the Work 

21 Group doesn't speak for the Board 

22 specifically. Part of our function is to get 
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1 the parties together and talk about the issue 

2 so we can in part see if there is some level 

3 of common ground. I don't know that -- you 

4 know, what we say is not the final word on 

5 this. Certainly the Board will listen to the 

6 recommendation of the Work Group, but the 

7 Board is always independent of the Work Group 

8 in a sense and will make its own judgment.

9 But to the extent that we're able 

10 to find some common ground I think is always 

11 helpful to the Board, and that in part is why 

12 we want to look at some possibilities here. I 

13 think that, you know, the Board has the option 

14 of saying we'll go with an SEC for both 

15 periods, or we'll go with an SEC for one and 

16 not the other, or we'll go for dose 

17 reconstruction for both. There's a lot of 

18 possibilities here. 

19 But to the extent to which NIOSH 

20 and SC&A have some level of agreement -- and 

21 they certainly don't have to agree, but that 

22 also sometimes helps. And of course the -- if 
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1 the -- and I don't think it's necessary for 

2 the Work Group members to necessarily agree. 

3 We can have -- we see this in different ways, 

4 and so on. 

5 So what we want to be able to do 

6 though is to make sure that we can present 

7 clearly to the Board what the issues are. If 

8 there's disagreement, why it's there and what 

9 the options are. 

10 Now, Bob, do you have a comment? 

11 Or, Jim, I don't know if this sort of hits --

12 DR. ANIGSTEIN: I have a couple of 

13 comments.

14 CHAIRMAN ZIEMER: I don't want to 

15 put you on the spot, but I'd sort of like to 

16 hear from you sort of independent of Dave in 

17 terms of whether you think NIOSH would be in a 

18 position to utilize some of the ideas that 

19 have been brought forth by SC&A and either 

20 incorporating them or if you feel that they're 

21 not useful, or we need -- I think it would be 

22 helpful to know that as well.
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1 Bob?

2 DR. ANIGSTEIN: Yes, I've got an 

3 observation to make about the most recent 

4 development, and that is it's been five years 

5 now since SC&A, and on some occasions joined 

6 by NIOSH, has been interviewing mostly former 

7 GSI workers. One case a site expert was a 

8 contractor who worked on the GSI site. These 

9 were facilitated by John Ramspott, for which I 

10 -- to whom I'm quite grateful, because 

11 otherwise I would never have been able to have 

12 the kind of information about this site that I 

13 have. 

14 Even though this model is 

15 something we came up with just recently, 

16 nevertheless there was mention of the cleanup. 

17 As a matter of fact, in Appendix BB, there is 

18 a reference to measurements made in the old 

19 betatron building, slightly earlier in 1989, 

20 when it was first considered for FUSRAP 

21 cleanup. And it's even -- the measurement was 

22 cited as validation of the values that were 
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1 derived by NIOSH because it was I believe 

2 something like -- 1100 was the dpm per for 100 

3 square centimeters was the -- or I -- there 

4 was -- I don't want to start quoting numbers. 

5 I'm probably getting the units wrong. But 

6 there was a value that was used by NIOSH and 

7 they said, look, years later the highest value 

8 was about half that value, so that shows that 

9 this was a good assumption. And no one ever 

10 challenged that. There was no mention made of 

11 a cleanup.

12 Suddenly, after five years we're 

13 discovering -- we're finding a new person who 

14 has information on this and it seems like 

15 there's been a lot of time. There was a time 

16 when we would have had the opportunity; and 

17 I'm sure we're taking the opportunity, to 

18 interview these people on the telephone, 

19 perhaps even in person, get a better picture. 

20 Now we're getting a very last minute 

21 second-hand information of quoting someone. 

22 It seems a little late to be starting down 
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1 that path at this late stage. 

2 And the earlier -- at the time I 

3 developed this model, which was just a month 

4 ago, six weeks ago, my only information was 

5 that the new betatron building had been 

6 cleaned up. And that was plausible because, 

7 first of all, I know -- I already know that 

8 when the Granite City Steel acquired the 

9 property; not the business, but the property 

10 of GSI, of the -- it was then called the -- it 

11 had been formerly called the Commonwealth 

12 Foundry, they converted the new betatron 

13 building into an office space. Of course they 

14 would have cleaned it up. 

15 Whereas my understanding was that 

16 the new -- the old betatron was left off by 

17 itself. It was used -- that is correct. The 

18 two -- the other betatron instrument was 

19 brought in and it was just a storage. And I 

20 -- we don't know whether it was cleaned up or 

21 not. I'm really going to put it very bluntly. 

22 It would take a lot of investigation to find 
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1 out. And it would seem odd that there would 

2 be so much activity left if in fact there had 

3 been such a cleanup when the new betatron 

4 building was cleaned up, and they could not 

5 detect any.

6 And these measurements were made 

7 also to -- there was sort of an allegation of 

8 competence there. These measurements were 

9 made by the ORISE, the Oak Ridge Institute for 

10 Science and Education, which has been taking 

11 the lead on cleaning up and surveying --

12 actually they don't do the cleanup -- of 

13 surveying. They perfected this MARSSIM 

14 manual, which is the guide to all government 

15 agencies for cleaning up radioactive sites. 

16 And these were the -- they've given the 

17 training. These are the most competent people 

18 in the business, the most reputable, competent 

19 people in the business.

20 And the picture of theirs, the 

21 berm -- yes, the berm was -- it's well 

22 acknowledged the berm -- obviously the berm 
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1 was added later and -- but it does not affect 

2 the measurement on the other parts of the 

3 floor, because the other parts of the floor --

4 each one of these was a measurement of dpm per 

5 100 square centimeters. So you simply average 

6 over whether some of the areas could not be 

7 sampled. It's not 25 percent. It looks like 

8 -- to my mind it's looking more like 10 or 15 

9 percent, but that's a quibble. This looks 

10 like reliable data. I rest my case.

11 CHAIRMAN ZIEMER: Okay. Thank 

12 you. 

13 MR. RAMSPOTT: Dr. Ziemer, may I 

14 respond to that?

15 CHAIRMAN ZIEMER: Sure.

16 MR. RAMSPOTT: I'll keep it brief. 

17 MR. KATZ: Yes, go ahead, John.

18 MR. RAMSPOTT: We invited 

19 everybody to visit that site, just like we 

20 did. And I'm sure more information would have 

21 been found if those invitations had been 

22 taken, but I know people are busy and it just 
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1 didn't work out. 

2 But there was mention of power 

3 washing, and I'm sure I can find it in the 

4 transcripts from years past. And, you know, I 

5 think -- maybe I'm wrong, but I thought the 

6 law said if you find new information, you're 

7 supposed to submit it. I think I've seen that 

8 in the law. And that is what we're doing. 

9 And I also think that I saw all 

10 radiation must be considered in dose 

11 reconstructions. Well, I think that also is 

12 part of this argument, too. If there was a 

13 cleaning and that material was moved and what 

14 you're seeing now is what was there after that 

15 was done, how much was there before it was 

16 done? I mean, that's logical. 

17 And I did look at those drawings. 

18 They definitely are in the -- I'm looking at 

19 it now. They're definitely in the FUSRAP 

20 report and they show that material there. 

21 And, you know, I've talked to people that are 

22 familiar with concrete work. Now that berm, 
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1 you don't just put a berm in there. You got 

2 to clean the surface of the existing concrete 

3 in order to put new concrete on it, especially 

4 if you're going to hold oily matter, like 

5 transformer oil, which is exactly what this 

6 says. Transformer storage area. I'm looking 

7 at the drawing now. 

8 So I really can't agree. When you 

9 bring in, I guess, whatever it took to build 

10 that berm and you bring in another betatron 

11 from a new betatron building, you go down that 

12 walkway, those railroad tracks, you're going 

13 to disturb something. 

14 Now I respect -- or I guess the 

15 Oak Ridge National Lab, but in reviewing the 

16 cleanup documents again last night, if you 

17 look in there -- and, Dr. Bob, I know you used 

18 their drawing originally, too, they said there 

19 was a huge door in the new betatron building. 

20 And I'm just referring to the new betatron 

21 building not as part of this argument or this 

22 building. But they said the new betatron 
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1 building, the main door; that is their quote, 

2 is to the left of the drawing or photograph 

3 they have. And we all know now that hole was 

4 knocked in the wall well after the contract 

5 period. 

6 And we also note from their 

7 drawing there's -- they never even walked in 

8 the 10 building. That's where the uranium had 

9 to come in from. There was no other way to 

10 get uranium into that building except through 

11 10 building. 

12 So I think they did a fair job, 

13 but they were wrong. They weren't totally 

14 accurate. They weren't totally complete. 

15 With all due respect to them, if I was coming 

16 in 40 years later, I might have missed it, 

17 too, because they didn't have some site 

18 experts and some people to talk to and some 

19 workers. I guess I wonder why they didn't 

20 talk to any workers. They just talked to 

21 Granite City Steel management. If I'd had 

22 Granite City management -- those people were 
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1 probably kids when all this was going on. So

2 I don't think they did such a good job. I 

3 have to disagree with you. 

4 But, you know, I respect what they 

5 did. And I probably would have made the same 

6 mistakes, but now it's time to correct it. 

7 We've got people telling you the facts, you 

8 know? So I'm sorry, that's just the 

9 straight-up truth. Thanks a lot. I 

10 appreciate the chance to comment.

11 CHAIRMAN ZIEMER: Thanks, John. I 

12 want to give -- Jim, I'm kind of putting you 

13 on the spot, but do you have any sort of 

14 reflections on NIOSH's approach here in terms 

15 of what you heard so far today?

16 DR. NETON: Well, I think Dave's 

17 put together a pretty, I thought, compelling 

18 argument that the exposures associated with 

19 the movement of uranium, the sole activity of 

20 the handling and movement of uranium 

21 throughout a building is inherently -- is 

22 pretty low. The values are low. 
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1 I think the most compelling sample 

2 is the one that was at LeBlond where they were 

3 actually -- I think there were three BZ 

4 samples where they hooked a hoist to the 

5 billet and placed the billet into position on 

6 the machine. And then they removed it from 

7 the machine nine dpm per cubic meter. I think 

8 that's consistent with Dave's experience, and 

9 my experience has been working at a uranium 

10 foundry.

11 And the other two instances he's 

12 demonstrated that even though there were 

13 ancillary activities going on in addition to 

14 the movement, the values were still around 

15 less than 200 dpm per cubic meter, which is 

16 what we suggest.

17 There are other values out there 

18 that SC&A have raised that talk about movement 

19 of uranium where the much higher -- I think 

20 they're worth looking at, although the value 

21 of 3,000 I think is going to be rejected 

22 almost based on being really high. I've 
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1 looked at some values while we were talking 

2 and there are some air samples in Harris and 

3 Kingsley where your chiseling billets, just 

4 actively chiseling billets, and you get around 

5 4,000 dpm per cubic meter. I just find it 

6 implausible that you can generate fifty MAC 

7 air by just moving rods. I mean, that's 

8 higher than the values that were measured at 

9 Bethlehem Steel during active rolling 

10 operations in the 1951-52 period where they 

11 were taking heated uranium, you know, and 

12 moving and pushing it through machines. So I 

13 find that value to be a little bit out of 

14 range.

15 The 500 dpm ones, you know, I 

16 don't know. Maybe, you know, that's worth 

17 considering, I suppose, but I think we would 

18 all -- I believe that somewhere in there, in 

19 that range where we put -- Dave has suggested 

20 or maybe looking at another value is a 

21 bounding value. We know that movement of 

22 uranium generates some dust. And I think the 
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1 range is somewhere in those values, rejecting 

2 the -- I would reject the 3,000 one as being 

3 implausibly high.

4 I get -- SC&A hasn't said this, 

5 but I get the sense that they also somehow 

6 believe that it could be bounded in some way, 

7 whether we pick a value that's a better 

8 surrogate value or whether relying on their 

9 model, they believe -- I think it's their 

10 sense also that this activity can be bounded 

11 using the data that we have available to us.

12 DR. MAURO: Jim, this is John. 

13 DR. NETON: Yes?

14 DR. MAURO: I agree with that 

15 statement.

16 DR. NETON: Okay. So I think both 

17 SC&A and NIOSH agree that the value can be 

18 bounded. It's how you come about it and 

19 what's the appropriate exact value you use. I 

20 sense that SC&A's position is that 200 may be 

21 a little low for their comfort level. But 

22 again, I think we're in a situation where we 
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1 agree that it can be bounded somehow and the 

2 exact value maybe can be debated to some 

3 degree. But I think within a factor of two. 

4 I mean, I don't know. I think 200 is 

5 bounding, in my own opinion, but we're open 

6 for discussion on other values.

7 CHAIRMAN ZIEMER: John, did you 

8 want to expand on your comment there at all? 

9 John Mauro.

10 DR. MAURO: Yes. You see, we went 

11 through a process here which brings me to a 

12 place I said, listen, you know, we look for 

13 other starting points and we see a range of 

14 them that are in many -- in some cases not 

15 unreasonable as applied to the circumstances. 

16 I for one feel the stamping of these slugs is 

17 being not at all like the kinds of things. So 

18 we are troubled by the starting point.

19 Now the interesting thing is 

20 outcome. If you would -- let's say we'd start 

21 with that 500 number that in our opinion is 

22 really -- it's one number associated with the 
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1 type of operation that really is not analogous 

2 to what types of things that went on. So, you 

3 know, we are troubled by that as a surrogate, 

4 but there are others that are apparently --

5 certainly look better. And I agree with Jim, 

6 going to 3,000 doesn't ring true given the 

7 amount of information we have regarding the 

8 airborne dust loading associated in all types 

9 of operations. 

10 So it seems to me that if I were 

11 doing this, I would go with a different 

12 surrogate that perhaps -- and not go with the 

13 adjustments that were made and the way they 

14 were made. But I think that we can pick one 

15 that -- out of the data that now is available, 

16 something we didn't look at before. It wasn't 

17 until this process where we said, listen, can 

18 we find some better surrogate for handling of 

19 uranium? And it seems that we have some 

20 numbers out there are better as a starting 

21 point than the stamping process that -- for 

22 these slugs. And I have to say that I was 
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1 very pleased with the process that Bob went 

2 through to say, okay, let's go backwards in 

3 time. 

4 Now of course John Ramspott now 

5 brought up a point now, if he's correct. 

6 Let's see there was a thorough cleaning of 

7 this building before these measurements were 

8 made. Well of course, then you got to throw 

9 the model out. I mean, that's all there is to 

10 it. You know, you can't avoid the argument 

11 that, listen, if that's true that it had been 

12 scoured, what do you do with that? I don't 

13 know what you do with that. 

14 But if it wasn't, then Bob's 

15 approach leads you in a place that says, 

16 listen, this is another way to come at the 

17 problem that's reasonable. And it comes in at 

18 a place which -- what's interesting to us is 

19 that I think that there's a -- if you went 

20 over and looked at it and looked at the 

21 concentrations in air as a function of time, 

22 you know, the numbers that we're seeing are 
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1 compatible with these other numbers we've been 

2 talking about. 

3 So that's the reason I feel that 

4 we're converging into a place. And I think we 

5 can converge on a place that at least in my 

6 mind is one that would place a plausible upper 

7 bound on these exposure scenarios. So, yes, 

8 that's the reason I agree with Jim.

9 CHAIRMAN ZIEMER: Okay. Thank 

10 you.

11 DR. McKEEL: Dr. Ziemer, may I?

12 CHAIRMAN ZIEMER: Yes, is that --

13 DR. McKEEL: Dr. Ziemer, this is 

14 Dan McKeel.

15 CHAIRMAN ZIEMER: Yes, Dan, go 

16 ahead.

17 DR. McKEEL: I'm going to say 

18 three short things about what I was just 

19 thinking on. One is John Mauro just said that 

20 if -- if it was true that there was a 

21 heavy-duty power washing of the betatron 

22 building in 1984, as [identifying information 
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1 redacted] said there was, then they would have 

2 to throw the model out. And then we went on 

3 to explain how you could use the model. 

4 Well, I've got to speak for all 

5 honest, truthful, well-intentioned GSI and 

6 other workers in the entire nuclear weapons 

7 workforce who tried to give the Board their 

8 honest opinions on things. Dr. Anigstein 

9 criticizes us for bringing this information 

10 forward late in the game. Well, you know, you 

11 could do the same thing and criticize him for 

12 bringing the alternate model to everybody's 

13 attention here at the very last minute as 

14 well. 

15 But I've got to say this: 

16 [identifying information redacted] saw what 

17 [identifying information redacted] saw with 

18 his own eyes. That's not hearsay. That's not 

19 a secondary thing. The Board has heard from 

20 [identifying information redacted] before on 

21 the Dow SEC and they can pick up the telephone 

22 this afternoon and confirm what we just said. 
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1 So the fact is, whether it's convenient or 

2 not, the old betatron building was power 

3 washed in 1984.

4 The second thing I can do, and I'm 

5 sure either John will do it or I will do it 

6 immediately after this is over, is we will 

7 send you the proof photos which show GSI 

8 workers that we know were there during the 

9 operational and residual period and left in 

10 1973 inside the old betatron building showing 

11 the interior was painted with white paint, 

12 which John assures me in those days was white 

13 lead paint.

14 Now, for white lead paint to be 75 

15 percent, 80 percent removed, then a power 

16 washing has truly got to be what the name of 

17 the company implies, power blasting. And John 

18 Ramspott reminds me that these days; you know, 

19 that's later than 1984, that power washing as 

20 a technology in fact can be used to cut hard 

21 materials. So this is like a laser blade -- a 

22 laser beam that's cutting through things. And 
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1 it did demonstrably take off white lead paint 

2 that was coating the betatron doors -- I mean, 

3 the walls.

4 The other comment that I want to 

5 make is that throughout this discussion the 

6 comment that the only thing that happened to 

7 the uranium, the only thing that we need to 

8 consider is that this was, quote, cold uranium 

9 metal. Well, nothing could be farther from 

10 the truth. Because for half of its life at 

11 GSI, that may be true. It was cold uranium 

12 metal ingots, dingots, billets and betatron 

13 slices. 

14 However, the game changed 

15 completely and set this site apart from all 

16 other sites that are covered under EEOICPA in 

17 that the sole purpose of bringing the uranium 

18 to GSI was to irradiate it with a 24 to 25-MeV 

19 betatron beam. And the petitioners have sent 

20 this Board numerous articles from the 

21 literature, peer-reviewed, well-respected 

22 journals; they sent you another one actually, 
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1 that shows that around 6 to 10 MeV betatrons 

2 or linear particular accelerators operating in 

3 X-ray mode can cause both fission and 

4 activation of uranium, and do that. And they 

5 convert a measurable portion. Yes, it's only 

6 a few percent, but they convert uranium-238 

7 mass into daughter products of fission and 

8 activation.

9 And so for the latter half of its 

10 life at GSI this was not cold uranium metal. 

11 This was hot activated fissioned uranium 

12 metal, and that fact and those doses need to 

13 be factored into the dose reconstruction at 

14 GSI. And I understand that in the technical 

15 documents that have been produced so far that 

16 activation dose, the fission dose have been 

17 referred to -- this doesn't have the things 

18 that we don't know about the uranium exposures 

19 at GSI as trivial or insignificant. Well, all 

20 I can say to that is, in scientific terms, 

21 that's really not acceptable reasoning. 

22 OCAS-IG-003 and everybody's interpretation of 
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1 the Act says that during the operational 

2 period, you have to count all doses. So you 

3 just have to. 

4 And it's wrong today to talk about

5 uranium metal as being cold uranium metal. 

6 That's just not the truth except for 50 

7 percent of the time it was at GSI. The rest 

8 of the time it was quite hot. And to say that 

9 these doses -- try to dismiss them, which I 

10 hope nobody will do, as being insignificant, 

11 inconsequential, under the Act, they're highly 

12 consequential and they must be accounted for. 

13 And they must be accounted for by someone 

14 with sufficient accuracy, and I don't think 

15 the models that we've been hearing about today 

16 do that at all. So thank you very much.

17 CHAIRMAN ZIEMER: Dan, I just want 

18 to emphasize one point: when we talk about hot 

19 metal, we're not -- we're talking about 

20 thermally hot, which is a very different 

21 condition from the sort of jargon that nuclear 

22 people use, that is something being 
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1 radioactive as being hot. It's not thermally 

2 hot.

3 DR. McKEEL: I understand this --

4 CHAIRMAN ZIEMER: Well --

5 DR. McKEEL: -- and you have 

6 criticized me for such semantics --

7 CHAIRMAN ZIEMER: Well, it's --

8 DR. McKEEL: -- problems, but I'm 

9 telling you --

10 CHAIRMAN ZIEMER: It's not hot --

11 DR. McKEEL: -- let's take the 

12 word hot out of there.

13 CHAIRMAN ZIEMER: Well --

14 DR. McKEEL: Let's say that this 

15 has been -- the uranium has been previously 

16 fissioned. I don't think you could disagree 

17 with that.

18 CHAIRMAN ZIEMER: No. No.

19 DR. McKEEL: And it's been subject 

20 to betatron activation.

21 CHAIRMAN ZIEMER: Right.

22 DR. McKEEL: And that both of 
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1 those products generate new daughter products 

2 which are radioactive. And I don't think you 

3 could argue with that point.

4 CHAIRMAN ZIEMER: No, and we've 

5 agreed to that and --

6 DR. McKEEL: Okay.

7 CHAIRMAN ZIEMER: -- NIOSH has 

8 calculated those activities and the dose rates 

9 from them. It's in the external dose model, 

10 so they have accounted for that, and the 

11 internals as well.

12 Okay. We're going to take a break 

13 for lunch. You all have a lot to ponder over 

14 the next hour while we eat. And then we'll 

15 come back and try to move towards some sort of 

16 closure on these activities.

17 MR. RAMSPOTT: Dr. Ziemer?

18 CHAIRMAN ZIEMER: Yes?

19 MR. RAMSPOTT: I mean during your 

20 break --

21 CHAIRMAN ZIEMER: Yes?

22 MR. RAMSPOTT: -- I would actually 
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1 -- that word if really bothers me. I would --

2 about the power washing of the old betatron. 

3 That word if is a big word. If you guys would 

4 like, and you would allow it, I'd actually try 

5 to call [identifying information redacted] at 

6 home and ask him to call in on this meeting 

7 and you can hear it right from the individual.

8 CHAIRMAN ZIEMER: Well, I'm not 

9 personally disputing the -- I don't believe 

10 that's necessary. I'm not disputing the 

11 testimony that --

12 MR. RAMSPOTT: Excuse me, I'm just 

13 the carrier of the messages from the men. 

14 CHAIRMAN ZIEMER: Yes.

15 MR. RAMSPOTT: I know what they 

16 told me.

17 CHAIRMAN ZIEMER: Right.

18 MR. RAMSPOTT: And --

19 CHAIRMAN ZIEMER: I think --

20 MR. RAMSPOTT: -- working around 

21 these guys, this --

22 CHAIRMAN ZIEMER: I think the Work 
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1 Group accepts that the cleaning occurred. Is 

2 that not correct?

3 MEMBER MUNN: Yes, that's correct. 

4 Absolutely.

5 CHAIRMAN ZIEMER: Yes. Yes, I 

6 don't --

7 MR. RAMSPOTT: If you would reason 

8 the cleaning occurred in the old betatron, I 

9 heard John Mauro say he had to throw 

10 everything out.

11 CHAIRMAN ZIEMER: Well --

12 MR. RAMSPOTT: John, is that not 

13 --

14 DR. MAURO: I don't know, does 

15 anyone else have a perspective on this? I 

16 know -- Bob, would you agree with that? I 

17 mean, if the starting point has been cleaned 

18 up extensively that, you know -- I don't know. 

19 You know, I hate to step on your toes, Bob, 

20 but it seems to me common sense would dictate 

21 that.

22 DR. ANIGSTEIN: I was kind of 
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1 questioning his statement.

2 CHAIRMAN ZIEMER: Well, in any 

3 event, yes, you may have to ponder what the 

4 implications of that are, but certainly --

5 MR. RAMSPOTT: If [identifying 

6 information redacted] is available --

7 CHAIRMAN ZIEMER: Yes.

8 MR. RAMSPOTT: [identifying 

9 information redacted] has no ax to grind in 

10 this program.

11 CHAIRMAN ZIEMER: Yes. Well --

12 MR. RAMSPOTT: He worked at Dow. 

13 He didn't work at GSI.

14 CHAIRMAN ZIEMER: I don't think 

15 we're disputing his --

16 MR. RAMSPOTT: I haven't talked to 

17 him in a year until I --

18 CHAIRMAN ZIEMER: -- testimony 

19 that that had occurred, so --

20 MR. RAMSPOTT: -- talked to him 

21 about this matter here, because I remember him 

22 saying he was an electrician. I had no idea 
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1 he was involved in seeing the cleanup or how 

2 it was -- he named the guy from Water Blast by 

3 name because he went to high school with him.

4 CHAIRMAN ZIEMER: Yes.

5 MEMBER BEACH: John, this is 

6 Josie. We do appreciate your bringing that 

7 information forward. Thanks.

8 MR. RAMSPOTT: Thank you very 

9 much. These people, three, four people 

10 different people telling the same story 

11 different directions, don't talk to one 

12 another.

13 CHAIRMAN ZIEMER: Yes.

14 MR. RAMSPOTT: I try to 

15 triangulate everything I present to you. I 

16 always have. And I wouldn't have said it if I 

17 wasn't comfortable with it.

18 CHAIRMAN ZIEMER: Yes. 

19 MR. RAMSPOTT: Thank you very 

20 much.

21 CHAIRMAN ZIEMER: We thank you. 

22 Okay. Let's break for an hour and come back 
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1 at 1:15.

2 (Whereupon, the above-entitled 

3 matter went off the record at 12:15 p.m. and 

4 resumed at 1:17 p.m.)

5

6

7

8

9

10
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

2 1:17 p.m.

3 MR. KATZ: Good afternoon. This 

4 is the Advisory Board on Radiation and Worker 

5 Health, TBD-6000 Work Group. We're just 

6 reconvening after lunch. Let me check on the 

7 line for a few people.

8 John Mauro, are you back with us?

9 DR. MAURO: Yes, I am.

10 MR. KATZ: Great. And how about 

11 petitioners Dan McKeel and Pat Jeske?

12 DR. McKEEL: I'm here. This is 

13 Dan McKeel.

14 MR. KATZ: And, Pat, are you back 

15 with us, too?

16 (No audible response.)

17 MR. KATZ: And, John Ramspott, are 

18 you back with us?

19 MR. RAMSPOTT: Yes, I am. Thank 

20 you.

21 MR. KATZ: Great. All right then.

22 CHAIRMAN ZIEMER: Okay. What I'd 
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1 like to do here as we begin the afternoon 

2 session, I'm trying to get a feel for the 

3 extent to which there's some mutual ground 

4 between SC&A and NIOSH on the issue of 

5 surrogate data. I've gone back and looked at 

6 the five criteria. I believe, if I'm not 

7 mistaken, that there was already agreement now 

8 on criteria 2 and 4. Am I correct, either Bob 

9 or John Mauro, on criteria 2 and 4? You both 

10 have agreed with NIOSH's approach on those two 

11 items, is that correct? 

12 MR. ALLEN: I was going to say I 

13 think Bob said that on --

14 CHAIRMAN ZIEMER: Four was 

15 temporal.

16 DR. ANIGSTEIN: Four we agreed 

17 with.

18 CHAIRMAN ZIEMER: Well, and 2 had 

19 to do with a more robust analysis.

20 MR. ALLEN: Yes, I was going to 

21 say I think that's provisional or whatever.

22 CHAIRMAN ZIEMER: It's going to be 
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1 provisional. You would have to include that 

2 in the Appendix BB.

3 DR. ANIGSTEIN: Yes. No, we did 

4 not agree with No. 3.

5 CHAIRMAN ZIEMER: Oh, I didn't say 

6 3. I said 2.

7 DR. ANIGSTEIN: Oh, 2? I'm sorry.

8 CHAIRMAN ZIEMER: Yes. Now, what 

9 I want to ask now is on process, site or 

10 process similarities, did I understand that 

11 were NIOSH to use one of the other sites; 

12 maybe it's one that you guys cited, SC&A, that 

13 were the surrogate, that you might be 

14 comfortable with criteria 3? I'm just asking. 

15 I may have misinterpreted. 

16 And also that if that were to 

17 concur and you agreed that the process, site 

18 or process similarities were appropriate that 

19 you would feel more comfortable with using the 

20 surrogate data versus the later data which 

21 John now has indicated has some questions on 

22 because of the cleanup, so that you would 
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1 agree to the hierarchy issue as being -- that 

2 the surrogate data would be appropriate if it 

3 has distinct advantage. I'm just -- again I'm 

4 asking those two. 

5 And that if the appropriate site 

6 or process similarities issue was addressed, 

7 that plausibility might be more acceptable. 

8 I'm trying to get an extent to which -- you 

9 know, our starting point was has the criteria 

10 been met and I'm trying to see to what extent 

11 if these changes were made would that take 

12 care of that? We would still have to agree on 

13 what the surrogate data selections would be. 

14 And then we would still have to decide whether 

15 we want to accept surrogate data criteria or 

16 accept that for the two periods. 

17 So I'm trying to get a feel for 

18 that. 

19 DR. NETON: I would suggest 

20 criterion 1, the hierarchy data -- if it's 

21 true that the facilities were cleaned up, 

22 which it seemed to be, then SC&A would 
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1 probably agree that that criteria was 

2 fulfilled. If you can't use the FUSRAP data, 

3 then it can't be --

4 CHAIRMAN ZIEMER: It can't be 

5 better than the --

6 DR. NETON: We would have used the 

7 appropriate surrogate data -- it would have 

8 been appropriate to use surrogate data if the 

9 building was cleaned up.

10 DR. ANIGSTEIN: Well, but the 

11 adjustments are not -- were not made 

12 appropriately.

13 DR. NETON: What's that?

14 DR. ANIGSTEIN: No, under criteria 

15 1 the problem is that the adjustments -- are 

16 we talking about 1?

17 DR. NETON: Yes. 

18 DR. ANIGSTEIN: Okay. Under 

19 criteria 1 the main problem was that the 

20 adjustment was not appropriate. Going from --

21 first of all, there is a --

22 DR. NETON: Well, the Criteria 1 
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1 is --

2 CHAIRMAN ZIEMER: Hierarchy of 

3 data.

4 DR. NETON: -- is you only use 

5 surrogate data if there are no other suitable 

6 data to be found.

7 DR. ANIGSTEIN: And then only 

8 after appropriate adjustments have been made.

9 DR. NETON: Right.

10 DR. MAURO: Yes, Bob, I agree with 

11 you. 

12 Jim, I know you folks are headed 

13 -- there's -- I've come to a place now where 

14 in light of the stipulation that there was 

15 cleanup, that means the use of the hierarchy 

16 of data has been demonstrated. We can't go 

17 that route. The only data, site-specific data 

18 we had was this FUSRAP data and, you know, it 

19 sounds as if that there's agreement that 

20 there's good reason to believe that there was 

21 this cleanup which puts us in a place where, 

22 okay, now we have to resort to surrogate data. 
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1 And so therefore within that context, Jim, I 

2 agree.

3 DR. NETON: Right.

4 DR. MAURO: We now have moved into 

5 the realm where I think a justification has 

6 been provided that it's appropriate to use 

7 surrogate data. We've exhausted our effort to 

8 try to use site data. Of course now once you 

9 move into that realm. So if you want to call 

10 that agreement on 1. But as Bob points out, 

11 that's coupled up also with, you know, how you 

12 use that data. 

13 So but, yes, I understand what 

14 you're saying and I would agree that it's time 

15 to move off the model and move to the 

16 surrogate data strategy and talk about, okay, 

17 how do we get through that process and 

18 converge on agreement on what I would call the 

19 starting point with a good surrogate data set. 

20 And then of course the way in which you apply 

21 that data and the adjustments you make.

22 DR. NETON: Right. Okay. 
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1 CHAIRMAN ZIEMER: Now, the 

2 adjustment issue is only an issue if you were 

3 adjusting the data set --

4 DR. NETON: The slug data.

5 CHAIRMAN ZIEMER: -- the slug 

6 data, which you may not be doing if you end up 

7 selecting a better -- and I'll call it 

8 "better" for lack of a better term -- a 

9 different site. So which has --

10 DR. ANIGSTEIN: I don't know, I 

11 mean, the question of what John just said on 

12 the phone, there seems to be a disconnect 

13 between the level of contamination found in 

14 the old betatron building by -- during FUSRAP 

15 cleanup by ORISE and this aggressive cleaning 

16 that was being described. It just doesn't 

17 seem to make -- it doesn't seem to be 

18 plausible that they would have found the 

19 contamination levels that they did in the 

20 light of such a cleanup. Whereas the new 

21 betatron building, that was much earlier. It 

22 was stated that there was a cleanup and in 
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1 fact there was nothing found there. 

2 But the pattern of contamination, 

3 the fact that it was like along the -- around 

4 the railroad track, seemed to be consistent 

5 with the use of that building. And it just 

6 seems to be not consistent with the assumption 

7 of the cleanup of that -- of a very aggressive 

8 cleanup. That's just an observation which is 

9 -- I mean, we can't ignore.

10 DR. MAURO: Well, you know what; 

11 this is John, to get the process moving 

12 forward, I guess the question is do we want to 

13 stipulate? You know, it's a legal term that I 

14 thought to use. We understand that there are 

15 questions that -- in other words, I hear what 

16 Bob is saying. And there seems to be -- you 

17 know, if there was such a cleanup, why are we 

18 seeing what we're seeing, et cetera? But I 

19 think, you know, for the purpose of this 

20 meeting rather -- you know, all I could say is 

21 that rather than try to -- you know, we need 

22 to -- I think we need to accept John 
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1 Ramspott's and Dr. McKeel's argument that this 

2 is true. There was a cleanup. The degree of 

3 cleanup we -- it certainly occurred, it sounds 

4 like, and the degree of cleanup, and what the 

5 implications are. It really means it's hard 

6 to use our model. 

7 And then I'm -- you know, I'd like 

8 to be able to say, yes, we can use our model, 

9 but it seems to me we need to set that aside, 

10 unless you want to go down the path of digging 

11 into that, and I think that that will be a 

12 never ending task. I'd sooner think it's 

13 better to set our model aside, notwithstanding 

14 the fact that, you know, it may have some 

15 validity, but I think I would recommend to the 

16 Work Group that we pursue the surrogate line. 

17 Let that one go. It was our work. You know, 

18 we did the best we could. But I think that it 

19 served its purpose, but now I think it's time 

20 Kent Lambert, M.S., CHP

21 Director, Radiation Safety 

22 Drexel University

23

24 1601 Cherry Street, Suite 10444

25 Philadelphia, PA 19102

26 to let it go. I do think we should be working 

27 the surrogate data line. 

28 And whether or not we could find 

29 the starting point, and I say I think we can 

30 given what I've seen so far. And in light of 

31 -- once we have that starting point, I think 
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1 we could converge on an agreement of what 

2 types of adjustments and what types of models. 

3 How do we use that starting point? So I see 

4 a very tractable problem here. 

5 It certainly would have to -- so 

6 what I'm coming down to is that all of the 

7 issues associated with surrogate data, you 

8 know, we do have to go through the process 

9 now. You know, how do we converge and agree 

10 that, yes, you picked a good starting point? 

11 Yes, the adjustment factors are the 

12 appropriate ones, that sort of thing. And I 

13 think we could work through that.

14 CHAIRMAN ZIEMER: John, or John 

15 and Bob, if a suitable set of surrogate data; 

16 and I say "suitable" in terms of site or 

17 process similarities, were identified, and you 

18 have at least one that looks awfully close, 

19 does that in your mind also then to some 

20 extent address the plausibility issue? 

21 Because if it's an appropriate surrogate site, 

22 then in a sense it seems to me you're saying 
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1 that the values that you gain from that are 

2 plausible if the site in fact is a good 

3 surrogate for GSI. Does that follow in your 

4 mind logically? I'm asking John or Bob.

5 DR. ANIGSTEIN: Well, the 

6 plausibility criteria is not to the value of 

7 the -- you know, the particular value of the 

8 parameter, but it's the reasonableness of the 

9 assumptions. And the model -- it's a question 

10 of the models.

11 CHAIRMAN ZIEMER: And so --

12 DR. ANIGSTEIN: So here where we 

13 have --

14 CHAIRMAN ZIEMER: -- you couldn't 

15 address that until you knew more specifically 

16 how you were going to use --

17 DR. ANIGSTEIN: Yes.

18 CHAIRMAN ZIEMER: -- the surrogate 

19 data? Okay. 

20 I know -- I think, John, you 

21 pointed out in the past we've also thought of 

22 plausibility in terms of is it -- does it make 
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1 sense reasonably? Like dust loading of air 

2 can only reach so much and then a person can't 

3 breathe it anymore. 

4 DR. MAURO: Yes, let me -- in the 

5 historic use of plausibility the question that 

6 we would ask ourselves is we've picked a 

7 surrogate site where the starting point is 

8 some dust loading that's -- let's say it 

9 turned out to be -- let's say we picked, you 

10 know, Bethlehem Steel for a dust loading, 

11 okay, where they rolled steel. Okay? And you 

12 got these enormous dust loadings. The 

13 plausibility was meant for that purpose, that 

14 is originally. That's the original narrow use 

15 that we used when we started. That doesn't 

16 mean it's not evolving. And we would say, no, 

17 it's not plausible that -- and in fact they're 

18 plausible circumstances. 

19 Those circumstances did not exist 

20 at GSI. So therefore -- so I would argue the 

21 plausibility issue goes toward is it plausible 

22 to have dust loadings associated with -- you 
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1 know, is it a plausible circumstance that 

2 we're taking from one location to another? 

3 And you could have concentrations of that 

4 elevation.

5 So what I'm saying is once you 

6 pick a surrogate that represents a set of 

7 operations and their associated dust loadings, 

8 that seem to be plausible as applicable. 

9 Let's say applicable and -- plausible 

10 circumstances that -- and I say that I think 

11 that amongst the new ones we're looking at we 

12 have that. 

13 The broader interpretation of 

14 plausibility as used by Bob, and certainly not 

15 unreasonable to do that, but I typically don't 

16 do that, goes toward the plausibility of the 

17 model. In other words, in my world -- and Bob 

18 and I, you know, we're sort of showing -- you 

19 know, airing out our dirty laundry here, but I 

20 would not refer to that as plausibility. I 

21 would simply refer to that as, listen, you 

22 start -- you pick a good starting point. 
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1 And I think we can pick a good 

2 starting point. And then we have to agree on 

3 how do we model -- use that information to 

4 model the concentrations in the air as a 

5 function of time throughout the operational 

6 history of GSI during operations, and then of 

7 course during the residual period? And what 

8 models and assumptions should be used? I 

9 typically don't use that as a plausibility, 

10 but you can. Either way it's just semantics.

11 The question really becomes given 

12 -- we need to first and foremost agree on a 

13 starting point that we all agree that, yes, 

14 that particular dust loading is a set -- it 

15 represents a set of circumstances that is 

16 applicable to GSI and perhaps plausibly 

17 bounding. And then once we could agree on 

18 that, then we could talk about what would we 

19 do with that data, that starting point in 

20 order to feel confident that we are placing a 

21 plausible upper bound on the exposure that 

22 were experienced by or might have been 
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1 experienced throughout the operating life of 

2 the workers at GSI? 

3 So I mean, I think it's -- you 

4 know, the hard part is getting that starting 

5 point. After that it's just, you know, 

6 digging -- rolling up our sleeves and agreeing 

7 on the mechanics. How do you do the modeling? 

8 And Bob was very attentive, as you noticed, 

9 when he went through the back calculations at 

10 the starting point. But a lot of what he has 

11 described in terms of the mechanics is 

12 important; that is, that we had episodic 

13 generation of dust. 

14 And then of course it -- and it --

15 so I would say that this is all very tractable 

16 if we agree that there is a starting point. 

17 And I think that we have enough experience 

18 from handling of uranium metal at other 

19 facilities that we could pick one of those as 

20 being -- representing a plausible upward bound 

21 of what might have been experienced during the 

22 handling of the metal at GSI.
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1 CHAIRMAN ZIEMER: Okay. Thank 

2 you. Any other comments? Board Members, 

3 questions, comments? Dave or Jim?

4 MR. ALLEN: I was just going to 

5 reiterate what John was just saying. I was 

6 just looking at the Board's surrogate data 

7 criteria and it's kind of like we're saying 

8 it's an -- surrogate data is an SEC issue, and 

9 it's really both because the criteria deals 

10 with not only can we use surrogate data, but 

11 how is it used?

12 CHAIRMAN ZIEMER: Yes.

13 MR. ALLEN: And I think the only 

14 question here with this plausibility part is 

15 how we are using it, which is more of a 

16 TBD-type of issue, not an SEC-type issue. I 

17 don't know if that makes a lot of difference 

18 in our Work Group right now, but I think there 

19 is a -- I think that's what John's trying to 

20 say, is separating that slightly.

21 DR. ANIGSTEIN: Yes, the 

22 plausibility -- according to the Board 
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1 criteria, the plausibility refers not to the 

2 value, but to the manner in which -- I mean, 

3 yes.

4 MR. ALLEN: The manner that it's 

5 used.

6 DR. ANIGSTEIN: The manner in 

7 which the surrogate data are to be used must 

8 be plausible with regard to the reasonableness 

9 of the assumption that's made. 

10 DR. MAURO: And I'm okay with that 

11 broader interpretation.

12 DR. ANIGSTEIN: So it's the manner 

13 -- it's not the value. It's not the data. 

14 It's the use of it.

15 CHAIRMAN ZIEMER: Right. Okay. 

16 Thanks.

17 DR. ANIGSTEIN: That's how it --

18 whether this is right or wrong, this is what's 

19 in there.

20 CHAIRMAN ZIEMER: That's what it 

21 is, yes. Wanda?

22 MEMBER MUNN: What we've been 
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1 doing here is almost a poster child for the 

2 reason for the Appendix to begin with. This 

3 is why Appendix BB was put together, so that 

4 we would have -- not have to do what we have 

5 just been doing here for the last year or so 

6 in this Work Group. That Appendix was put 

7 together so that when you have an AWE or sites 

8 like this one where information is not clearly 

9 available, you have the weight of knowledge of 

10 the entire process and the entire background 

11 of nuclear knowledge with respect to these 

12 metals and how they behave. We have -- that 

13 knowledge is known to us and it's available to 

14 us. 

15 And that's why we have the 

16 Appendix so that we do not have to do the kind 

17 of detailed parsing that we attempt to do when 

18 we don't have adequate firsthand measurements 

19 to rely on. We already know what the material

20 does and we know how these processes affect 

21 it. So it is to our benefit to come to a 

22 conclusion on whether or not we will use that 
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1 material as it was I think intended to be used 

2 when we put the Appendix together.

3 MEMBER BEACH: Well part of our 

4 criteria also states that we have to use sites 

5 with process similarities. And I think at 

6 this site it's been brought up numerous times 

7 that there are dissimilarities between the 

8 processes. There's more equipment, the way it 

9 was sliced, cut, dingots, ingots. I mean, 

10 there's just more that I don't believe we 

11 know, and that's part of the reason we're 

12 talking about surrogate data. And part of our 

13 charter is to make sure that that surrogate 

14 data being used is similar. And I still don't 

15 feel that we have a good handle on what went 

16 on, how long it went on, what was cleaned up, 

17 what was not cleaned up at GSI.

18 MR. ALLEN: Well right now the 

19 models and et cetera, you know, other than 

20 that alternative model, don't count on that 

21 cleanup and everything else. But as far as 

22 the process similarities I don't think anybody 
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1 envisioned calling movement of metal a 

2 process. I mean at some point you cut the 

3 thing so thin that you have to say, well, you 

4 moved it with a Yale fork truck, but not a 

5 Ford fork truck. You know, I mean, at some 

6 point you got to say we have an overall task 

7 that includes these other items, issues.

8 MEMBER BEACH: I don't know if 

9 we've done that though completely. 

10 MEMBER MUNN: We have surrogate 

11 information from not just one site, but from 

12 multiple sites with respect to what the 

13 bounding doses could be for certain kinds of 

14 activities and certain kinds of metals. And 

15 of all the metals in the world that have been 

16 studied, uranium probably tops the list in 

17 terms of what we know with respect to bounding 

18 doses. And bounding doses ultimately are what 

19 we rely on to be able to say, yes, this was a 

20 hazardous environment for these workers or it 

21 was not.

22 CHAIRMAN ZIEMER: Okay. Other 
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1 comments?

2 DR. McKEEL: This is Dan McKeel, 

3 Dr. Ziemer.

4 CHAIRMAN ZIEMER: Yes, Dan?

5 DR. McKEEL: Well, I would like to 

6 comment on the comparability of the three 

7 sites that David Allen came up with and GSI 

8 and just comment that it seems to me that 

9 comparability of process and site also 

10 includes how the uranium metal -- not only was 

11 it transported, how it was picked up and 

12 transported from one site to another. 

13 I mean, you can say that that's 

14 all one operation, but in fact that's not 

15 true. I mean, there are different amounts of 

16 uranium released when a forklift picks it up 

17 with its sharp teeth and say when a grappling 

18 hook picks it up, or when a chain is wrapped 

19 around an ingot and picks it up. I don't 

20 believe that. And somebody mentioned data 

21 earlier today from one of the surrogate 

22 proposed sites where a forklift gave very high 
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1 numbers compared to the 590 dpm. I think it 

2 was 3,600 dpm. So this idea that there is 

3 uniform data about the airborne levels 

4 achieved after various types of handling, 

5 that's not true. 

6 So saying that no site can 

7 possibly pass the similar process test for --

8 and this is what I've been saying since 2008 

9 many times, is the fact that uranium for 

10 Mallinckrodt went over to GSI to be subjected 

11 to high-MeV betatron irradiation which caused 

12 fission and activation. And that was not the 

13 case at any of those other sites. It just 

14 wasn't. Two sites made slugs. That's the 

15 very reason -- the two sites that Dave Allen 

16 brought up made slugs. That's what they did.

17 And here today, in really an 

18 amazing, I want to say illogical manner -- but 

19 the logic of the surrogate data test has 

20 really -- you all have tried to bypass it and 

21 ignore it and not apply it. I mean, the SC&A 

22 findings were that the slug facility data 
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1 flunked all of the tests including 

2 plausibility and the only one that was really 

3 resolved to everybody's satisfaction was the 

4 temporal criterion. So that left four that 

5 were not satisfied. And I don't believe today 

6 that there has been a definitive coming 

7 together of the minds on that.

8 What you're now saying is -- John 

9 Mauro must have said a half a -- I mean, a 

10 half a dozen times, two dozen times that what 

11 we need to do is pick a starting point. Well, 

12 I don't think you can pick a starting point, 

13 because even though you might say that the 

14 billet production facility, No. 3, was pretty 

15 good; words like that have been used, and not 

16 bad; words like that, actually only a very 

17 small and unknown fraction of the uranium that 

18 was processed and handled at GSI was a billet, 

19 which was a smaller type of uranium object 

20 than the 3,000-pound ingots and the 3,000-

21 pound dingots. And none of the billets were 

22 subject to betatron irradiation and fission 
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1 and activation. 

2 So the idea that you could say 

3 that any of those other facilities came close 

4 to GSI, much less be stringently justified as 

5 being similar, it really defies all the 

6 intelligent reasoning that I've collected in 

7 the last 73 years. And I hope very much that, 

8 you know, there will be a consensus. This 

9 process similarity has just not been achieved 

10 and won't be achieved. And when John Mauro 

11 repeatedly says this problem is tractable and 

12 resolvable, then I challenge him. Show me 

13 another site where there's surrogate data 

14 where the airborne levels of uranium were 

15 actually measured, real data on uranium that 

16 had been subjected to high-MeV fission and 

17 activation. Please just show me that.

18 DR. MAURO: I think it's applied 

19 --

20 DR. McKEEL: A wide range of 

21 daughter products are generated during both of 

22 those processes and one of our objections; and 
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1 I'm talking about the petitioners' objections, 

2 to Appendix BB from the very beginning, in 

3 June 2007, was that it does not account for 

4 that full range of radionuclides that are 

5 produced. 

6 And we've repeatedly cited the 

7 paper by Dr. Ziemer and Guo where they 

8 subjected surgical instruments to a linear 

9 accelerator and showed a similar very wide 

10 range of activation products in those metal 

11 instruments. And NIOSH has not modeled all of 

12 those. They have not come up with good 

13 numbers. They've underestimated the amount of 

14 fission products and underestimated the number 

15 of activation products that are in every 

16 article that we've supplied to you by 

17 Sugarman, by Kuttemperoor, the most recent one 

18 by Crowley, who discovered promethium in 1945. 

19 His article, which I sent you the abstract 

20 of, all had a much wider ranger of 

21 radionuclides than you all have accounted for. 

22
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1 And I don't think any of those 

2 other sites that Dave Allen's come up with, or 

3 anybody's come up with, had anything to do 

4 with what went on at GSI. There was a graph 

5 shown from what happens to suspension at 

6 Simonds Saw before and after rolling mill 

7 operations. Well, that has nothing to do with 

8 GSI. Yes, it took 30 days for it to come down 

9 to a good level, but that was in a rolling 

10 operation. GSI didn't do rolling operations 

11 and they didn't do rolling operations on 

12 Mallinckrodt uranium.

13 So I would strongly disagree with 

14 John Mauro. I don't think there's a good 

15 starting point. And I think you should go 

16 back and rigidly apply the Board surrogate 

17 data criteria to each and every substitute 

18 surrogate data site that you say is good and a 

19 good starting point. And I think that it will 

20 flunk. All those sites will not pass the test 

21 on at least one or more of the surrogate data 

22 criteria. 
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1 And if you tell me that it's 

2 plausible to use a site that has no betatron 

3 fission and activation as a surrogate for a 

4 site that does, where that's the sole purpose, 

5 and you tell me that's plausible and passes 

6 the plausibility test, I'd say the criteria 

7 are basically worthless. And I don't think 

8 they are worthless. I heard all those 

9 discussions. I know why plausibility was put 

10 in there. There was some disagreement about 

11 exactly what they meant. But I would point 

12 out to you right now that 10 years after this 

13 program in EEOICPA was instituted, there's 

14 still an argument about defining sufficient 

15 accuracy, a core principle that governs dose 

16 reconstruction. That's still not defined 

17 carefully, nor is plausibility.

18 So I'm saying that in the ordinary 

19 way that human beings and scientists and 

20 trained scientists and intelligent scientists 

21 use the word "plausibility" -- that to say 

22 that a slug production facility, a billet 
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1 production facility that had no radiographic 

2 examination of that uranium is comparable to 

3 GSI, it is just logic that's too tortured and 

4 it's certainly not defensible in my view. So 

5 I guess that's all I want to say.

6 DR. MAURO: This is John. I do 

7 have to help clarify a couple of things I 

8 think that are very important.

9 The real question we're asking 

10 ourselves -- there's a metal that we're 

11 handling, uranium, and when you're handling 

12 it, you're going to have the potential to 

13 generate aerosols. What Dr. McKeel pointed 

14 out is we're really asking can we -- are there 

15 handling -- metal -- uranium handling 

16 operations where we've measured the number of 

17 milligrams or micrograms of uranium in the air 

18 while that metal was being handled? And could 

19 we just say that those represent a plausible 

20 bound for the uranium handling that took 

21 place, the metal uranium handling that took 

22 place at GSI? 
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1 The composition -- now, here's --

2 and, Dr. McKeel, please, here's where I have 

3 to disagree with you. You're really posing a 

4 question regarding the composition of that 

5 metal. In other words, the fact that it has 

6 been irradiated means that, yes, you might 

7 actually have some activation products. So 

8 it's not just uranium that's airborne anymore. 

9 It's uranium with perhaps some fission 

10 products, all of which was modeled and in a 

11 way that I think we've been through. So 

12 really we have to separate the two. It's very 

13 important to make a distinction.

14 DR. McKEEL: Yes, but --

15 DR. MAURO: The only question 

16 we're asking ourselves -- let me finish and 

17 then I'll stop --

18 DR. McKEEL: All right.

19 DR. MAURO: -- is are there metal 

20 -- are there uranium metal handling activities 

21 out there that we could say are of a nature 

22 that generates aerosols that we could say are 
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1 plausibly bounding? The only problem we're 

2 having is that most of the metal handling 

3 operations out there are too high. That is 

4 because not only do they handle the metal, 

5 they also machined it and they also did other 

6 things with it that would generate even more 

7 aerosols. And that's -- you know, so that's 

8 one of our dilemmas. 

9 But I think that David and SC&A 

10 have found a few where we could say, well, 

11 this looks like some -- a place where it was 

12 primarily handling the uranium metal. And 

13 granted, it's not exactly the circumstances, 

14 whether they handle it with a chain or a 

15 forklift, or how many times a day did they 

16 turn it around? I mean, there's always a 

17 place you could find where you could parse it 

18 and say, well, you don't really have a 

19 comparable circumstance. And that's up to the 

20 judgment of certainly the observer; yourself, 

21 the Board. But in my mind if you can't find a 

22 surrogate for handling uranium; and I'm going 
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1 to be a little outrageous, you can't find a 

2 surrogate for anything. This is as classic, 

3 as simple a problem as you could have in terms 

4 of looking for surrogate data. 

5 Unfortunately, in the original 

6 start of this whole process NIOSH picked what 

7 I -- we now -- SC&A believes is a poor 

8 surrogate. It was not really uranium metal 

9 handling. It was a different kind of thing. 

10 But that doesn't mean we can't find one. And 

11 I think we've already found one. And if we 

12 look harder we could probably find more. But, 

13 boy, we're talking about the simplest of 

14 things, handling uranium metal. So I for one 

15 feel strongly that we could find and agree 

16 upon a surrogate for the GSI handling of those 

17 ingots. And the fact that they were 

18 irradiated with the betatron is not relevant 

19 to this question that we're talking about 

20 right now.

21 DR. McKEEL: I would like to 

22 reply, please.
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1 CHAIRMAN ZIEMER: Sure.

2 DR. McKEEL: No, you're not 

3 getting what I'm saying correct. I am saying 

4 that that's part of the equation, the fission 

5 and the activation. But what I'm also saying 

6 is the metal itself -- there is a difference 

7 between a slug, a billet and an ingot and the 

8 dingot. And what is the difference? The 

9 difference is that the ingots and the dingots 

10 that were sent over from Mallinckrodt had not 

11 been cropped, had not been shaved on a 

12 vertical lathe. They still had their bomb; 

13 and I'm using that as the furnace bomb that 

14 was used to produce those metal -- those 

15 uranium metal forms. And as you know, as we 

16 all know, and as is inadequately treated in 

17 TBD-6000, which I pointed out when this Work 

18 Group was revising that document, still not 

19 treated correctly in TBD-6000 Rev. 1. There 

20 is an irregular magnesium fluoride crust that 

21 has various impurities in it, including a 

22 small concentration of thorium which 
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1 accumulates at the surface. 

2 So in several different ways an 

3 ingot and a dingot compositionally, chemically 

4 and physically, the surface of them is 

5 different from a clean pure uranium metal 

6 product. And a slug is a good example of a 

7 pure clean uranium metal product. It doesn't 

8 have a magnesium fluoride crust. And you know 

9 that that magnesium fluoride crust doesn't --

10 it has different compositions. I suspect it's 

11 not as hard a metal. It's not as hard a 

12 substance as the inner uranium core, which is 

13 very hard -- when they sent uranium through a 

14 extrusion press and heated it, one of the big 

15 problems is it would fragment. And the people 

16 at Dow knew that. They could tell when 

17 uranium was being processed. Even when the 

18 name of the metal was hidden from them, by its 

19 characteristics in an extrusion press it would 

20 fragment. It was difficult to do.

21 So, no, I'm not at all saying this 

22 is not one of the simplest things that you can 
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1 model. And in all due respect to everybody, 

2 including Wanda Munn, I have also given you 

3 all data of a nice campaign that was done 

4 where they were studying uranium dingots from 

5 Mallinckrodt that were sent to Hanford for the 

6 Hanford reactors, where she worked, and they 

7 had done various things to those dingots. 

8 They had various amounts of trace metals that 

9 were added to them to see if they could change 

10 the structural stability of those ingots in 

11 the reactors themselves. And eventually they 

12 abandoned them.

13 So, you know, but there was a 

14 beautiful table in the data that I sent you 

15 all that showed the individual variances of 

16 individual dingots, and they varied quite a 

17 bit. And some of them worked and some of them 

18 didn't work, and some of them deformed and 

19 some of them didn't deform. You know, so this 

20 idea that it's one product and it's simple is 

21 absolutely contrary to what the scientific 

22 literature shows. And I agree with Wanda 
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1 Munn. I like to stand on published peer2 reviewed scientific literature.

3 And I would say this: I don't 

4 think there is a site where you can produce a 

5 paper of scientifically peer-reviewed 

6 literature that has a process where they are 

7 handling fission and photo-activated uranium 

8 that's been produced as an ingot or a dingot 

9 by a derby melting two-step process or a 

10 one-step dingot process like it was from 

11 Mallinckrodt Destrehan Street and later from 

12 the Weldon Spring Plant in Saint Charles 

13 County. 

14 So, no, I respectfully disagree. 

15 I don't think this is the simplest product and 

16 I don't think it's the simplest situation. 

17 And I would say because of the outer bomb 

18 crust that was adherent to the ingots and the 

19 dingots, then you have to pick a surrogate 

20 data site that processed ingots and dingots. 

21 And so the three sites that Dave Allen came up 

22 with wouldn't pass that test. They made slugs 
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1 and billets. So that's my comment.

2 CHAIRMAN ZIEMER: Thank you. Yes, 

3 Bob?

4 DR. ANIGSTEIN: Okay. First, as 

5 far as the nature of the uranium, starting off 

6 with the irradiation of the uranium, starting 

7 off with the fact that the uranium was 

8 irradiated, a microscopic, submicroscopic 

9 fraction of the uranium atoms are actually 

10 involved. We're talking about activities with 

11 short term -- yes, there is some radioactive 

12 radioisotopes. Two of them actually are 

13 uranium isotopes, so they would have the same 

14 physical properties as the natural 

15 constituents of uranium in terms of -- so say 

16 mechanical properties. 

17 The fission products we have 

18 calculated. They are in the -- absolutely in 

19 the minuscule range. I can't quote you a 

20 number right now, but they're order -- many, 

21 many orders of magnitude below unity, below 

22 the concentration of uranium, though there is 
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1 just not enough there. They are far lower 

2 than the ordinary impurities in the uranium 

3 metal. So that is not an issue. 

4 It's an issue for reconstructing 

5 doses, and as it turned out, it's a very small 

6 amount. We have mathematically derived that 

7 and we have used all of the latest physics 

8 models. We don't have to go back to papers 

9 from 1945. We have the very latest. So that 

10 is simply not an issue. I mean, you can --

11 this can be brought -- any issue can be 

12 brought up just to try to discredit what's 

13 being done. But that is not a valid issue.

14 As far as the uranium coming with 

15 slag and with fluoride, with magnesium 

16 fluoride attached to it, there is no basis for 

17 believing that except the assertion that is 

18 being made now that because that is how it was 

19 produced, it is being assumed and asserted 

20 that that's how it was shipped to GSI. 

21 The literature --

22 DR. McKEEL: Dr. Anigstein --
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1 DR. ANIGSTEIN: Excuse me. Let me 

2 finish, if I may. The reports that we have 

3 read are that the slag and the fluoride was 

4 cleaned off and knocked off immediately after 

5 it was made. The purpose for shipping it to 

6 GSI were two -- there were only two reasons 

7 for shipping it to GSI: There was the slices 

8 where they were looking for imperfections in 

9 the center of the metal which would affect 

10 later on when it was being rolled into rods, 

11 and it was also to look at how much of an 

12 imperfect end could be sawed off. 

13 The only firsthand information 

14 about the end shots was from one worker whom I 

15 interviewed who came in on this day shift and 

16 he said the night shift had told him they were 

17 doing these corner shots. And I made a 

18 drawing in response to his account and sent it 

19 back to him and said is this what you meant? 

20 And the only -- the corner shots would be to 

21 just determine how much of this imperfect 

22 metal that you get at the end -- you always 
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1 get that in a casting. There is air, there is 

2 -- slag gets included and they have to saw it 

3 off. They don't want to saw off too much, so 

4 they cut off on a band saw. And they did the 

5 radiograph to tell them how many inches from 

6 the end to cut off. 

7 The lathing on the vertical lathe 

8 would have been done. That is -- you cannot 

9 -- unless you take hundreds of radiographs you 

10 would not know how much to take off on the 

11 lathe. And there's no need to, because the 

12 machinist sees it. When he's bare metal, he 

13 quits. 

14 So that assertion is being made 

15 without any firsthand information, even any 

16 firsthand testimony. This is just an 

17 assertion to try to say you can't model this 

18 because this is how it was shipped. It was 

19 not the way it was shipped, because our 

20 metallurgist who has worked with uranium said 

21 this made no sense whatsoever. This is not 

22 the way things would have been -- this is not 
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1 the way uranium would have been fabricated.

2 DR. McKEEL: Dr. Anigstein, this 

3 is Dan McKeel. Do you have firsthand 

4 information from any source about the 

5 condition of a dingot that -- I sent you a 

6 letter from within the Atomic Energy 

7 Commission that that -- actually it was from 

8 the -- it was from the ORNL cleanup program 

9 that was talking about -- that the primary 

10 product that was sent from Mallinckrodt to GSI 

11 was dingots. Do you have any information that 

12 those dingots had been cleaned off before they 

13 went over to --

14 DR. ANIGSTEIN: Yes, there was the 

15 report on the Mallinckrodt site which 

16 described the processes.

17 DR. McKEEL: And it said that --

18 no, I don't believe so because -- I wish Mr. 

19 Ramspott would weigh in on this. He has a 

20 report from Mallinckrodt that says just the 

21 opposite, that one of the purposes of sending 

22 the uranium over there was to define that 
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1 slag/uranium interface. So I don't think --

2 DR. ANIGSTEIN: The ends. The 

3 ends, not the surface. And there is --

4 DR. McKEEL: Well, we --

5 DR. ANIGSTEIN: I cannot produce 

6 this at this moment.

7 DR. McKEEL: Well, we have a 

8 picture that we also sent you recently of --

9 you're right, of uranium dingots over at 

10 Weldon Spring from the Weldon Spring 

11 Interpretive Site Museum. And this is -- who 

12 knows how long that dingot has been made, but 

13 you know, it's quite clear that the outer 

14 surface is rough coated slag and not smooth 

15 shiny uranium. 

16 So I believe that you're making an 

17 assertion and I believe -- and, you know, 

18 that's why we write all this down in our 

19 technical papers. I can't go back and 

20 reconstruct every single bit, and I think it's 

21 wasting the Board's time to do that. We have 

22 provided that information. We believe that 
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1 based on technical reports that we've 

2 furnished that one of the main reasons -- that 

3 has been ignored by SC&A and by NIOSH, that 

4 those dingots and ingots were sent over to 

5 Mallinckrodt -- I mean, from Mallinckrodt to 

6 GSI was to define that interface. 

7 And so, regardless of what Dr. 

8 Thurber says and your metallurgy experts and 

9 so forth, that's their opinion. We have our 

10 opinion. I think we've backed it up. And so, 

11 I think the Board will have to decide. Thank 

12 you.

13 MR. RAMSPOTT: Dr. Ziemer, this is 

14 John Ramspott. May I add to this a moment?

15 CHAIRMAN ZIEMER: Sure.

16 MR. RAMSPOTT: I actually do have 

17 that article. Matter of fact, I'm looking at 

18 it and wrestling with it a little -- with my 

19 email right now. So I will get this again 

20 forwarded to Mr. McKeel so he can send it to 

21 you. But it actually states in here -- and I 

22 have shared this actually with this Work 
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1 Group, with the Board, with SC&A, with NIOSH. 

2 It clearly states in here the reason -- you 

3 use high -- it's actually the symposium -- let 

4 me get the exact -- you can pull it up, too. 

5 It's online. Non-destructive Test in the 

6 Field of Nuclear Energy. And they actually 

7 state you use high-energy X-rays in order to 

8 figure out how thick the crust is so it can be 

9 taken off with the lathe. I mean, there's no 

10 doubt about it. 

11 We also visited Weldon Spring. We 

12 have a picture of a dingot.

13 DR. McKEEL: Okay.

14 MR. RAMSPOTT: It still has the 

15 crust on it. No ifs, ands or buts, it's on 

16 there. But I'm going to come back to one --

17 if I could, just one important comment, and it 

18 goes to everybody. We're talking about 

19 surrogate material. You mentioned one site 

20 that had 75 pounds of uranium over, I don't 

21 know what the period of time was, and that was 

22 one of the surrogate sites. Chambersburg, I 
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1 believe. I have a more serious question for 

2 you: Look at all those purchase orders. Do 

3 any of those purchase orders tell you how many 

4 pounds of uranium went to General Steel? 

5 DR. ANIGSTEIN: No, John, you know 

6 they do not because you --

7 MR. RAMSPOTT: That's correct.

8 DR. ANIGSTEIN: -- have them.

9 MR. RAMSPOTT: Correct. How can 

10 -- I'm going to back extrapolate this a little 

11 bit. How can you pick out a surrogate data 

12 for GSI when you don't even know what GSI had? 

13 How do you do that?

14 Now one ingot was 3,000 pounds. A 

15 slice is maybe one-fifth of that. You don't 

16 know many ingots, dingots, slices went to GSI. 

17 You don't know much they weighed. Are you 

18 going to take 75 pounds of uranium and 

19 whatever was with that, take that times 50,000 

20 in order to get GSI's magic number? If you 

21 don't know what was at GSI, how can you use 

22 any surrogate data? I don't care what site, 
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1 you don't know what went to GSI. 

2 I know some hours. And I question 

3 the hours because nobody has ever broken down 

4 by year the steel worker's salary. We've 

5 taken some generalities, given out by 

6 employees. They were guesses. They don't 

7 know. They got a paycheck for 500 bucks.

8 DR. ANIGSTEIN: Excuse me. I just 

9 want to clarify that point. I don't want to 

10 interrupt you. It wasn't -- it had nothing to 

11 do -- John, it had nothing to do with the 

12 salary. The purchase order said we will pay 

13 you $16 an hour for your -- for the 

14 radiography and we will pay you $500 for three 

15 months. So they specified -- it had nothing 

16 to do with what the workers actually got. 

17 This was the charge that was negotiated 

18 between GSI and Mallinckrodt, so they simply 

19 presumably would submit a record. We spent so 

20 many hours and this is how much we charge you 

21 at $16 an hour. It was always $16 a hour.

22 MR. RAMSPOTT: -- matter because 
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1 you eat up $150 pretty quick if it's $20 an 

2 hour. You don't eat it up very quick if it's 

3 $1 an hour.

4 DR. ANIGSTEIN: Where do you get 

5 -- they said -- $16 an hour was on every 

6 single purchase order except the very last one 

7 or two when it went to $35.

8 MR. RAMSPOTT: Yes, but you don't 

9 have any purchase order for the early years. 

10 The workers told me they made two bucks an 

11 hour over there, three bucks an hour.

12 DR. MAURO: It's important not --

13 MR. RAMSPOTT: It's very 

14 important.

15 DR. MAURO: No, no. It's 

16 important not to get lost in the woods. 

17 MR. RAMSPOTT: John, the biggest 

18 item that I'm bringing up, you don't know how 

19 much uranium was at GSI.

20 DR. MAURO: I would say -- I 

21 postulate this for consideration by the Work 

22 Group. The real question is how many hours a 
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1 day, how many days per year were people 

2 handling uranium metal? The uranium metal 

3 could be a dingot, which is a large object. 

4 It's very big. Or they could be handling a 

5 large number of rods or billets, or other 

6 forms, physically shaped forms. So I would 

7 say that it's really -- we have to make sure 

8 we got a pretty good handle on -- you know, if 

9 you assume the person is doing it full time. 

10 The real question is when people 

11 are handling uranium metal there is airborne 

12 dust. Okay? And so this business of the --

13 whether it's the tons and pounds, that's not 

14 -- I don't -- in my opinion, I think the real 

15 question is when you're handling metal, there 

16 are a lot of different kinds and shapes and 

17 sizes of uranium metal that you could handle.

18 But I do believe that the question 

19 that Dr. McKeel raised, well, isn't --

20 sometimes we don't really -- there may -- I 

21 will say at this point that certainly some of 

22 that metal may have had some type of oxide or 
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1 dolomite scale to it. Some of it may not. 

2 Some portions of it may. Some portions of it 

3 may not. And in theory that surface of the 

4 metal could be influential in the degree to 

5 which you could get aerosols generated.

6 For example, if you've got pure 

7 uranium metal that is -- and it's -- you know, 

8 we know that it has the potential to flake, 

9 cause oxides. On direct -- some conditions 

10 you get sparking. If you've got the outside 

11 coating -- I don't know if Bill Thurber's on 

12 the line. He may have a sense for it. But if 

13 you have this coating on the outside that's 

14 associated with the originally formed; I guess 

15 it would be a derby or a dingot, it may 

16 actually have a different type of surface. 

17 And I would be the first to say, yes, there 

18 may be a difference in that. So I concur that 

19 that's worthy of deliberation.

20 And the degree to which by using 

21 the surrogate data that we currently have 

22 before us, the degree to which that might be 
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1 non- representative of let's say handling a 

2 dingot, I think that's -- and so I like to try 

3 to keep complete open and clean on this.

4 So, I don't know, Bill, are you 

5 --

6 DR. THURBER: Yes, I'm on.

7 DR. MAURO: Did you have -- I know 

8 that you've looked at this a bit. We've 

9 talked about this in the past. 

10 DR. THURBER: I haven't been privy 

11 to all the conversation today; I'm sorry, but 

12 I would make one or two comments.

13 If you look at the worker surveys 

14 that were done at the places that -- where the 

15 bomb reduction was done, one of the operations 

16 and one of the dirty operations was the 

17 chipper. And obviously the chipper was the 

18 guy who was cleaning up the surface of these 

19 dingots or ingots before they were moved for 

20 further processing. So, you know, it seems to 

21 me that any product that goes out the door has 

22 already had some chipping and cleaning of the 
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1 surface to remove easily friable material, if 

2 you will. 

3 And of course the other question 

4 is, well, what is the composition of that 

5 material? I mean, nominally it's a magnesium 

6 fluoride. So those are a couple comments I 

7 would make.

8 DR. MAURO: And let me close the 

9 loop a little. What we have here is a very 

10 good question. It goes toward, well, what are 

11 we going to use for the surrogate, because we 

12 have data that just about captures every 

13 aspect of every -- of operations of uranium 

14 under every circumstance. I'm thinking the 

15 Adley report is a great example, and there are 

16 many others by Christifano and Harris, Harris 

17 and Kingsley. There's a collection of an 

18 immense amount of information of uranium in 

19 various stages being handled under different 

20 conditions. 

21 The real question is -- and, Dr. 

22 McKeel, I appreciate your pointing this out, 
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1 because there may be some question as to the 

2 material. And I can't say for certain whether 

3 there's a question or not, but there may be 

4 reasonable questions. Was this dingot or 

5 ingot or this slice -- it may have -- actually 

6 the -- for example, the slice. The slice may 

7 -- of course on one surface be the uranium 

8 metal that's without any scale, but the 

9 outside edge may very well have had some. So 

10 what you're really posing; and this is a good 

11 conversation, what are we going to choose as a 

12 surrogate? 

13 For example, all we're really 

14 doing now is going a little deeper. Because 

15 when we started out, SC&A was concerned with 

16 the slug and the stamping. Well, what you're 

17 saying is, well, let's be -- okay. Good. 

18 Let's -- this is SC&A talking now. You know, 

19 if we -- SC&A would say, well, listen, the 

20 slug and the stamping, we don't think that's a 

21 very good starting point. Not that the number 

22 you come out with at the end is a bad number, 
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1 but to start with that number, it seems that 

2 really is very little parity in the way in 

3 which the uranium is being handled. And it 

4 seems that there are other places, other 

5 handling operations that might be more 

6 analogous to the handling operations.

7 And so now we're getting -- we're 

8 sharpening the analysis further. What you're 

9 saying is, okay, we're with you. And you're 

10 saying, Dr. McKeel, that, well, we don't 

11 especially like the fact that you're using 

12 these particular cases, the ones that we've 

13 cited earlier, discussed earlier. There may 

14 be better ones. And I would be the first to 

15 say, yes, there might be better ones. But I 

16 think there are --

17 DR. McKEEL: No, I didn't say 

18 that. I said I don't think are any others 

19 that are comparable.

20 DR. MAURO: Fair enough. You 

21 know, all I could say is that when I reviewed 

22 that literature, and let me -- I spent eight 
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1 years diving into that literature. It's out 

2 there. And right now I could say that if it's 

3 bare uranium metal, we already have a few that 

4 we've identified. And now you're saying, 

5 well, let's assume, no, it's something that 

6 might have some kind of dolomite crust on the 

7 outside. You know, we'd go into the 

8 literature, find -- you know, and see how we 

9 can do -- if that turns out to be the 

10 predominant form, yes, this is an uncertainty. 

11 Is it manageable within the 

12 context of dose reconstruction or sufficient 

13 accuracy? Certainly once we come up with our 

14 case, our arguments, I think all we've managed 

15 to explore at this point is that you're 

16 raising a question regarding this alternative 

17 surrogate, just like we did. We did the same 

18 thing when we started this out. We raised a 

19 question regarding the stamping operation. 

20 What you're doing now is you're raising a 

21 question regarding the bare metal. And I 

22 think that's a reasonable question to ask, you 
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1 know, and it needs to be answered.

2 MR. RAMSPOTT: Dr. Ziemer, may I 

3 --

4 DR. McKEEL: John?

5 MR. RAMSPOTT: -- finish my 

6 original --

7 DR. McKEEL: Can I make a comment 

8 just to follow on, because I --

9 DR. MAURO: 

10 CHAIRMAN ZIEMER: Hang on.

11 DR. McKEEL: -- think I need to 

12 keep this thread in continuity.

13 CHAIRMAN ZIEMER: Go ahead.

14 DR. McKEEL: I need to respond. I 

15 appreciate what Dr. Mauro just said. I need 

16 to respond to what Bill Thurber had to say. 

17 And that was that we agree, there was a job 

18 called a chipper. And when the bomb reduction 

19 was completed and it cooled down enough to be 

20 opened, which could take quite a while, 

21 somebody had to clean the loose crust, slag, 

22 scale; it's been called different things, but 
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1 the magnesium fluoride had to come off. And 

2 some of it was easy to take off, or relatively 

3 easy, and other of it was tightly adherent to 

4 the surface of the uranium metal. And that's 

5 the point I tried to make.

6 Bill Thurber said it quite well: 

7 Some amount of the magnesium fluoride had been 

8 removed. But the point we're trying to make 

9 is in all the pictures that we've seen it was 

10 not completely removed by the chipper. And 

11 that's the reason why in that symposium on 

12 non-destructive testing of uranium metal the 

13 comment was made that there needed to be some 

14 radiographic guidance as to where the 

15 interface was. 

16 And I believe that same chapter 

17 goes on to describe that, you know, when you 

18 were going through with a vertical lathe, 

19 sure, you could take extremely small cuts, 

20 millimeters, but time was money then as it is 

21 now, and they wanted to get through more 

22 quickly. And if they had a radiograph, it 
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1 would define the crust thickness, both at the 

2 top and the bottom. And the bomb was adhering 

3 around the sides, too, not just at the top. 

4 So they had to do a top crop and a side crop 

5 and a bottom crop. And we're saying that 

6 that's what took place.

7 So I'm saying that a long time ago 

8 we introduced that information. Three years 

9 ago at least we introduced that information. 

10 And I've thought all along, it won't be 

11 possible, from what I know, to find a site 

12 that did similar things for similar reasons, 

13 because I don't know of a site that we're 

14 defining -- Fernald would be a good one. We 

15 don't know how it was defined at Fernald. I 

16 think that would be interesting. We've 

17 suggested looking into that. Was there a 

18 betatron at Fernald, et cetera? I don't know 

19 now the answer to all those questions.

20 But the other point, huge point 

21 that I want to make today is John Mauro is 

22 saying that we can work this out, but the vote 
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1 that's supposed to take the recommendation of 

2 this Work Group is supposed to take place 

3 today, in a few minutes. And I don't think 

4 there's any more time to do that. I think 

5 that you should make your recommendation based 

6 on a solid method that you have now, that 

7 you're convinced will allow NIOSH to bound 

8 with sufficient accuracy all -- all doses 

9 during the operational period and the residual 

10 uranium doses during the residual period and 

11 all of the doses during the operational 

12 period.

13 And so, you know, I don't think 

14 there's time to explore around and look for 

15 other data. And I would suggest this: If 

16 nobody has found an exact comparable site to 

17 GSI and what they did in the seven years since 

18 2005 when all of us have been aware of the 

19 betatrons and what was done at GSI, if nobody 

20 has been able to do that in seven years, it's 

21 highly unlikely that that's going to be done 

22 in the foreseeable future. I have email from 
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1 -- between John Ramspott and John Mauro that 

2 exploring a betatron model was something that 

3 was underway at SC&A as far back as 2006. 

4 So I'm saying that today is the 

5 day. There needs to be a recommendation. I 

6 think the recommendation is there is no solid 

7 model for calculating intakes. The Work Group 

8 certainly can decide that the intake model 

9 that NIOSH proposed in Appendix BB is 

10 satisfactory. But against that, I think they 

11 have to say is the very solid recommendations 

12 of SC&A before this discussion began today. 

13 And what was written down in the work that 

14 they were supposed to do for the Board was to 

15 see whether the surrogate data criteria were 

16 appropriately used for the slug facility in 

17 TBD-6000, and the answer was, no, it was not. 

18 And I don't think there's any more new data 

19 that's been presented today since the data 

20 about what happened during the cleanup period. 

21 And I am pleased and think it's 

22 important that it has been stipulated in a 
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1 legal sense by both sides that the GSI old 

2 betatron building was power washed to an 

3 extensive extent in 1984, at least. 

4 And so I think that's where things 

5 are today and I do appreciate the time to 

6 address the Work Group. 

7 DR. THURBER: This is Bill 

8 Thurber.

9 CHAIRMAN ZIEMER: Go ahead, Bill.

10 DR. THURBER: Dr. McKeel said, 

11 well, this magnesium fluoride slag or whatever 

12 it is did go through a chipping process and 

13 what was left was very adherent. If what was 

14 left was very adherent, then the likelihood of 

15 it being removed during handling was of course 

16 substantially diminished, or it would have 

17 been removed. 

18 The second point I would make, Dr. 

19 McKeel said, well, it's very important to the 

20 production to be able to take cuts as deeply 

21 and quickly as possible. That fails to 

22 recognize that it takes some pretty robust 
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1 equipment to these vertical lathes. And the 

2 question is, well, how much of a cut can you 

3 take at a time and how much are you going to 

4 be saving in productivity if you knew if there 

5 was some way that the X-rays would show you 

6 the depth of contamination that you couldn't 

7 discern by eyeballing the surface?

8 CHAIRMAN ZIEMER: Okay. Thank

9 you.

10 DR. McKEEL: Well, all we know is 

11 that there is the Non-Destructive Testing 

12 Symposium book that says that's exactly why 

13 radiographic NDT examination of uranium was 

14 done. And so --

15 DR. THURBER: Was that --

16 DR. McKEEL: -- I guess the answer 

17 is --

18 DR. THURBER: Excuse me. You 

19 know, I'm not familiar with that, but was that 

20 symposium- specific --

21 DR. McKEEL: Well, it's a major 

22 publication. I mean, I --
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1 DR. THURBER: Excuse me.

2 DR. McKEEL: You know, we have 

3 presented that.

4 DR. THURBER: I beg your pardon. 

5 May I finish, please? 

6 DR. McKEEL: Of course.

7 DR. THURBER: I was asking the 

8 question about something that I wasn't 

9 familiar with. I'm not familiar with 

10 everything that's gone on with GSI. I've been 

11 working on other things. But I would ask you 

12 this question: To what extent was that 

13 symposium which you've quoted several times 

14 specifically connected with the work that was 

15 done at GSI? 

16 MR. RAMSPOTT: Dr. Thurber?

17 DR. THURBER: I don't know. I'm 

18 asking for information.

19 MR. RAMSPOTT: Dr. Thurber, may I 

20 answer that for you?

21 DR. THURBER: Surely.

22 MR. RAMSPOTT: That document 
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1 actually names Mallinckrodt. And I'm going to 

2 put that -- matter of fact, that's not the 

3 only information. The chipper -- you're the 

4 first guy I ever heard talk about a chipper 

5 knocking the slag off, and you are 100 percent 

6 correct. I have a picture of that person 

7 doing that at the Weldon Spring site, which 

8 would be dingots, where the Mallinckrodt 

9 chipper is knocking the big heavy slag off of 

10 the bomb with the uranium laying on the ground 

11 and it shows him chipping. Then -- and that's 

12 in the Post-Dispatch 1959 article that I have. 

13 It's about a four-page article. It's really 

14 great. I'll get you a copy of that.

15 I also then have the book that 

16 we're talking about, the non-destructive 

17 testing one. And they again -- they name 

18 Mallinckrodt in there. They name a lot of 

19 other sites. That's why this thing is not 

20 just applicable to GSI. But they name 

21 Mallinckrodt. They name the -- or they 

22 actually state that high-intensity X-rays are 
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1 used to figure out how much crust is left on 

2 there.

3 DR. THURBER: Does the article 

4 speak to specifics of what can be done, or is 

5 it a generic comment that it would be --

6 MR. RAMSPOTT: No, it goes into 

7 specifics. And then there's an additional 

8 magazine that I found as a result of that that 

9 goes with it and it actually shows those 

10 dingots having the crust taken off by a turret 

11 lathe. Mallinckrodt is named again in that 

12 article.

13 DR. THURBER: Right.

14 MR. RAMSPOTT: There's three 

15 different articles that will confirm 

16 everything we're saying. And the one that you 

17 brought up is 100 percent correct. And what 

18 Dr. McKeel is saying apparently is 100 percent 

19 correct. And I gathered that information and 

20 I'm going to put it together again. I was 

21 looking at it the other night and one thing 

22 they said, where the chipper was at Weldon 
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1 Spring there were extensive, I think is the 

2 word they used, exhaust systems at Weldon 

3 Spring for that. And I know you guys have 

4 been involved with Weldon Spring, so you may 

5 have seen these. But I'm going to put 

6 together that package. I'll do it in the next 

7 day and get it to everybody because it comes 

8 directly to what we're talking about right 

9 now.

10 DR. MAURO: Let me say something. 

11 It's so easy to lose sight of what we're 

12 trying to do. It's too easy to happen. If 

13 the folks on the phone are saying that, well, 

14 there are aspects to this operation -- let me 

15 give you an example: Let's make believe that 

16 there was some chipping going on at GSI. I'm 

17 not saying there was. You could -- I don't --

18 see, what I was getting at is whatever you 

19 want to postulate, well, they may have been 

20 doing some cutting, they may have been --

21 whatever it is, that it was dolomite crust, it 

22 wasn't, it was naked, it was heated, it wasn't 
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1 heat. Whatever you want to postulate as being 

2 a possible scenario that took place at GSI, I 

3 could say right now we will find a bounding 

4 surrogate to apply to that circumstance. 

5 That's all I'm trying to say. 

6 You brought up that, well, it was 

7 this. No, it was that. Well, whatever it 

8 was, there's so much data on airborne dust 

9 loading associated with every type of 

10 operation you could dream of on uranium that 

11 once you tell -- if there's uncertainty as to 

12 what exactly -- what was handled and how it 

13 was handled, we will then go the next step up 

14 the ladder and pick a little worse scenario 

15 that we would say plausibly bounds that 

16 circumstance. That's why I say it's a 

17 tractable problem.

18 MR. RAMSPOTT: John, when I was 

19 speaking before when you first entered that 

20 thought, there's one thing I got to come back 

21 to, and I have to respectfully disagree with 

22 you on the size of the uranium object can 
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1 determine the amount of dust. The example I'm 

2 thinking of; you tell me if I'm wrong, you got 

3 a slice, you got a dingot. You have a cup of 

4 flour, you have a bucket of flour. You drop 

5 the cup, you drop the bucket at the same time, 

6 where do you get the most dust? Where do you 

7 get the most flour?

8 DR. MAURO: It's really the 

9 surface area, not the weight.

10 MR. RAMSPOTT: Oh, no, I'm not 

11 talking -- I'm talking about surface area. 

12 There's more surface in a bucket than there is 

13 in a cup.

14 CHAIRMAN ZIEMER: John, we 

15 understand that point. I don't think we have 

16 to belabor it.

17 I want to make one other comment 

18 on this in terms of the idea of looking for a 

19 surrogate, that in my mind it does not have to 

20 be a process where the uranium is irradiated 

21 with a betatron or anything else. I fail to 

22 see how that has any impact on what the 
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1 surface properties will be in terms of what 

2 can be removed. The amount of atoms changed 

3 in that surface is so minute in that 

4 activation process, it's virtually impossible 

5 to change the properties. So that the idea of 

6 how much uranium can be removed is not related 

7 to the fact that it's been irradiated with a 

8 betatron.

9 DR. McKEEL: Dr. Ziemer, do you 

10 agree that a surrogate site would have to have 

11 employed ingots and dingots --

12 CHAIRMAN ZIEMER: Oh, sure. Yes.

13 DR. McKEEL: -- and slugs and 

14 billets?

15 CHAIRMAN ZIEMER: I think we have 

16 to take into consideration both the size and 

17 the kinds of surface materials, but not the 

18 fact that they had been irradiated, yes.

19 DR. McKEEL: Okay. Well, then 

20 let's not forget the size and the volume then.

21 CHAIRMAN ZIEMER: Yes, okay.

22 DR. McKEEL: That's also 
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1 important.

2 MR. RAMSPOTT: Dr. Ziemer, that's 

3 my question: Would you agree that the size --

4 you just said volume. Would you mean size?

5 CHAIRMAN ZIEMER: Well, 

6 generically I think --

7 MR. RAMSPOTT: Or quantity.

8 CHAIRMAN ZIEMER: -- we're all in 

9 the same boat on that. And generally you're 

10 looking for similar kinds of operations. I 

11 don't know if we're going to reproduce size 

12 exactly, but it would certainly make a 

13 difference if you're talking about a few 

14 pounds of uranium versus these big ingots and 

15 dingots. So, yes, it would help.

16 MR. RAMSPOTT: Doctor, that's the 

17 point I was trying to get to. At GSI you 

18 don't know what was there.

19 CHAIRMAN ZIEMER: Yes, but you can 

20 assume --

21 MR. RAMSPOTT: You don't have any 

22 quantities. You don't have any shipping 
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1 manifests. You know nothing about the uranium 

2 that was at GSI in terms of quantity.

3 CHAIRMAN ZIEMER: No, but we do 

4 have the possibility of knowing what kind of 

5 activities are generated by other facilities 

6 that handled similar kinds of materials.

7 MR. RAMSPOTT: My understanding 

8 was Weldon Spring was the only one that had 

9 dingots. You guys will have to correct me if 

10 I'm wrong.

11 CHAIRMAN ZIEMER: No, we don't 

12 know. I don't know. Anyway --

13 MR. RAMSPOTT: I had an article 

14 that said that.

15 MEMBER POSTON: It's 2:30 and --

16 CHAIRMAN ZIEMER: Yes, we need to 

17 --

18 MEMBER POSTON: -- we still 

19 haven't had a Work Group discussion.

20 CHAIRMAN ZIEMER: Yes, we need to 

21 -- well, we've been discussing, but we --

22 MEMBER POSTON: No, we haven't had 
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1 a Work Group discussion.

2 CHAIRMAN ZIEMER: We do need to 

3 reach a point where we have a recommendation 

4 for the Board of some sort for the full Board 

5 meeting. That recommendation can take the 

6 form of accepting in some way the NIOSH 

7 approach. It can take the form of disagreeing 

8 with -- what I'm calling the NIOSH approach 

9 now I believe is sort of a modified picture of 

10 this surrogate thing that you presented in 

11 terms of some modifications of the -- looking 

12 at which one it is here -- of the criteria 3. 

13 And I think -- I believe that's what SC&A was 

14 agreeing to as well, that if you could -- it's 

15 basically the starting number issue.

16 Now, if you were to make that 

17 recommendation, I think what Dr. McKeel says 

18 is true, that that would have the effect of 

19 extending things, because we're not at a --

20 you know, we don't have something specific 

21 then at that point. Although, if the Work 

22 Group felt it was a tractable problem, then it 
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1 no longer becomes an SEC issue.

2 MEMBER POSTON: Right.

3 MEMBER MUNN: Well, the key to 

4 what we've been discussing boils down I 

5 believe to its essence; perhaps it's being 

6 missed here by me, is whether we will or will 

7 not continue to rely on any information that 

8 we have received from the FUSRAP data as to 

9 whether or not that is the basis for what John 

10 calls the beginning point, or whether we will 

11 use -- we will request that NIOSH consider the 

12 possibility of using surrogate data in a 

13 different manner than has been proposed.

14 CHAIRMAN ZIEMER: Well, I think we 

15 need to ask NIOSH directly in terms of what 

16 you heard today and what is your position, or 

17 are you prepared to say --

18 DR. NETON: Well, this mag 

19 fluoride issue with the dingots, I'm not sure 

20 where that will take us. In my opinion, if 

21 there's a mag fluoride crust on there that has 

22 lessened amounts of uranium, the potential for 
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1 inhalation of uranium goes down --

2 CHAIRMAN ZIEMER: Yes.

3 DR. NETON: -- because you 

4 diminish the source term. You protect the 

5 uranium metal itself. And in my opinion, the 

6 bare uranium metal is probably the highest 

7 source term potential there is. So I don't 

8 know what fruitfulness there would be in 

9 researching exposures from dingots. I think 

10 you've bounded it using a bare uranium metal 

11 source term.

12 DR. MAURO: And, Jim, you know, 

13 earlier --

14 CHAIRMAN ZIEMER: What I was 

15 asking about -- or I think Wanda was asking --

16 DR. NETON: Hold on. Hold on, 

17 John.

18 CHAIRMAN ZIEMER: Hold on, John. 

19 I think Wanda was asking about the data from 

20 the cleanup, whether --

21 DR. NETON: Well, I think we need 

22 to separate two things: One is can we 
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1 reconstruct the dose during the covered 

2 period? 

3 CHAIRMAN ZIEMER: Right. 

4 DR. NETON: I think that needs to 

5 be established first. If we can't, that 

6 brings another issue into the cleanup period. 

7 So I think we need to maybe go in a step-wise 

8 fashion and say can we or can we not 

9 reconstruct the dose during the contract 

10 period? And then we could take on the second 

11 issue, which would be can we do anything 

12 during the cleanup?

13 John, you were saying something 

14 about --

15 DR. MAURO: Well, I was saying 

16 that I think the slices are a good example of 

17 the dilemma we're dealing with. Once the face 

18 of the slices are in all likelihood bare 

19 uranium metal, not unlike the bare uranium 

20 metal at other places that are handling rods 

21 and slugs, not unlike other bare uranium 

22 metal. Then you have the edges which may or 
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1 may not -- and I -- it sounds like that some 

2 of them may have had some of the dolomite. I 

3 think that's magnesium fluoride crust on the 

4 outside. And so, I mean, we're dealing with 

5 -- that's what we're dealing with.

6 DR. NETON: But, John, that's not 

7 radioactive. That's --

8 DR. MAURO: No, no, I'm just about 

9 to say that. Now that is -- so, you know, one 

10 could argue that the -- that's -- if it's --

11 you know, if you got this crust, you probably 

12 reduce the potential. But, no, I hate to be 

13 the one to say that, because I'd be just 

14 speaking from what I would say first 

15 principles, but without any direct knowledge 

16 of this.

17 But, so, you know, we have both 

18 these circumstances. And if -- you know, and 

19 where we are right now is -- whichever the 

20 circumstances are, if it is judged at the end 

21 of this process that the bare metal has more 

22 likelihood to spark and make airborne aerosols 
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1 than let's say the dolomite crust, well, we 

2 have surrogates for that. And if it turns out 

3 that a case could be made that, yes, the 

4 dolomite crust might be a little more friable, 

5 I don't know if it is, but it isn't uranium. 

6 It would be a little uranium. 

7 So, I mean, you know, at some 

8 point you've got to say can we wrap our arms 

9 around and wrestle this thing to the ground or 

10 not? And I'll say it again: With the data we 

11 have out there, you know, we have a way to 

12 bound it. It may be simply that let's go with 

13 some bare metal that has been handled. And we 

14 have examples right now that we've been 

15 talking about when we started this 

16 conversation as perhaps being the one that is 

17 bounding one of those cases. The dolomite 

18 issue, I think it's a red herring.

19 DR. NETON: Yes.

20 CHAIRMAN ZIEMER: Other comments?

21 John Poston, no comments?

22 MEMBER POSTON: I think we ought 
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1 to move forward.

2 CHAIRMAN ZIEMER: What does that 

3 mean? What are you recommending?

4 MEMBER POSTON: Do what --

5 CHAIRMAN ZIEMER: I'm looking for 

6 a recommendation from the Members of --

7 MEMBER POSTON: We have a 

8 suggestion to try to bring these two together.

9 MR. RAMSPOTT: Dr. Ziemer?

10 MEMBER POSTON: I know it's extra 

11 work, but --

12 CHAIRMAN ZIEMER: Yes?

13 MR. RAMSPOTT: If I can make a 

14 quick comment, I'm asking you to please 

15 double- check, I believe dingots are a product 

16 of Weldon Spring. That would mean 1958. I 

17 think ingots from Mallinckrodt Chemical Works 

18 are what went to GSI. I think there's a clear 

19 distinction. '53 to '58 I believe dingots 

20 plus other items -- or I'm sorry, ingots plus 

21 other items, slices. But I'm pretty sure --

22 and I've seen the literature and I'll look for 
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1 it again. And I know you guys can find it. 

2 You guys know Weldon Spring better than I do. 

3 You think that's where the dingots got 

4 started.

5 CHAIRMAN ZIEMER: Okay. Thank 

6 you.

7 MR. RAMSPOTT: If you're talking 

8 about the dolomite or whatever crust and how 

9 that changes, you need to take that into 

10 consideration, I think. I might be wrong. 

11 But I still come back to the quantity. You 

12 don't know how many dingots, ingots or slices.

13 CHAIRMAN ZIEMER: Okay.

14 DR. ANIGSTEIN: Yes, according to 

15 the Technical Basis Document for Mallinckrodt 

16 dingots were made at Mallinckrodt. I didn't 

17 say exclusively, but they were made at 

18 Mallinckrodt. There's a very detailed 

19 description of how it is removed from the 

20 bomb, allowed to cool off and how the slag is 

21 chipped off and reused, conveyed away on a 

22 conveyor belt.
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1 MR. RAMSPOTT: At Mallinckrodt?

2 DR. ANIGSTEIN: This is at 

3 Mallinckrodt. I have not read the Weldon 

4 Spring report lately.

5 MR. RAMSPOTT: Okay. I'll 

6 double-check my literature and I'd ask you to 

7 do the same, if you would, please.

8 CHAIRMAN ZIEMER: Go ahead, John.

9 MEMBER POSTON: I know that SC&A, 

10 wherever you are, is supposed to be working 

11 for the Board and NIOSH is also -- has their 

12 responsibility, but it seems to me that we've 

13 got enough discussion and enough interest in 

14 doing this that we ought to ask them to get 

15 together and provide a solution to this 

16 conundrum that we have.

17 CHAIRMAN ZIEMER: A solution in 

18 terms of the issue of what would be a suitable 

19 surrogate? 

20 MEMBER POSTON: Yes.

21 CHAIRMAN ZIEMER: Is that what 

22 you --
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1 MEMBER POSTON: Yes, exactly. 

2 CHAIRMAN ZIEMER: And if we were 

3 to ask that, what is your recommendation or 

4 what we would recommend to the Board at our 

5 next meeting?

6 MEMBER POSTON: Well, 

7 unfortunately the Board meeting's coming up 

8 here.

9 CHAIRMAN ZIEMER: Because 

10 time-wise I -- and keeping in mind there's a 

11 holiday coming up and then both groups are 

12 getting ready for the meeting itself with 

13 other preparations, so this is not something 

14 that's likely to occur before our full 

15 meeting, I don't believe, if we were to do 

16 this. I don't know if you're making that as a 

17 motion or just getting the idea on the floor, 

18 but --

19 MEMBER POSTON: Well, I will make 

20 it then as a motion, but my concern is not 

21 whether or not the Board is meeting or not. I 

22 mean, I think that we ought to do this 
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1 correctly once and for all and have something 

2 that we can stand by and recommend to the 

3 Board. And it takes until the next Board 

4 meeting in whenever it is, December or 

5 whatever, then so be it. But I don't think it 

6 makes any sense to rush through something 

7 because we have to have something from the 

8 Board. We can give them an update on what's 

9 going on, tell them about our discussions that 

10 we've had, the disagreements and trying to get 

11 things together to reach something that's 

12 useful. But if you want a motion, I'll --

13 CHAIRMAN ZIEMER: Well, I think we 

14 need a motion to get some of these specifics 

15 here and get some -- to go on record. So I'm 

16 not sure I got the full motion, but I got --

17 MEMBER POSTON: I've moved every 

18 part I could. All right. Let me think.

19 MR. ALLEN: If I can just make one 

20 comment. I mean, I came into this meeting 

21 thinking that the White Paper basically 

22 justified that the 198 dpm per cubic meter I 
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1 used was a bounding estimate. And I --

2 speaking for Bob; and he can correct me if I'm 

3 wrong, I think he came into the meeting 

4 thinking the alternative method was probably 

5 the best thing on the table at that point. If 

6 I'm not mistaken, the Work Group, at least 

7 from the discussion, seems to have shot both 

8 of those down. 

9 CHAIRMAN ZIEMER: Well, I think 

10 the -- I believe that in a sense SC&A has 

11 withdrawn that position because of the

12 cleanup.

13 MR. ALLEN: Okay.

14 CHAIRMAN ZIEMER: And I think I 

15 heard John Mauro say that.

16 DR. MAURO: If we stipulate -- and 

17 I use the term "stipulate" -- simply means, 

18 you know, that that being the case, I think we 

19 can't use the model.

20 CHAIRMAN ZIEMER: Yes, that is --

21 DR. MAURO: So, I mean, I don't 

22 think anyone would disagree with that.
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1 MEMBER BEACH: Well, I don't know 

2 if Bob agrees 100 percent with that.

3 DR. MAURO: Well, no, I think if 

4 he -- Bob, would you agree that if it turns 

5 out there wasn't --

6 DR. ANIGSTEIN: If that were the 

7 case -- we just heard -- it was just in the 

8 past few days that we heard about the cleanup 

9 at the old betatron. I certainly would not --

10 if there had been evidence of cleanup at the 

11 old betatron, then we certainly wouldn't have 

12 gone down the path we did.

13 DR. MAURO: That's all I --

14 DR. ANIGSTEIN: I think that to 

15 make such a radical abrupt change in direction 

16 I think that this cleanup needs to be looked 

17 into, just like -- I mean, we spent -- and I 

18 guess I should say I -- with all due modesty, 

19 I can say I spent a good portion of the last 

20 five years tracking down what went on at GSI, 

21 and I think we got a pretty good picture. 

22 Speaking -- I spoke to a number -- I mean, I'm 
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1 not talking about this particular thing. I'm 

2 just saying in general I spoke with a number 

3 of people, two of whom are no longer with us, 

4 who gave different views, not always the same, 

5 not always identical. But you talk to enough 

6 people over a long enough period of time, you 

7 get a pretty fair picture. You get to the 

8 point where you're 90 percent sure I think 

9 this is most likely what happened, even though 

10 there may be one or two disparate opinions. 

11 And here we have not gone down 

12 that route. We have just been shown this 

13 information, been -- not shown, been told this 

14 information very, very recently, had not had a 

15 chance to look into it, and I think it's a 

16 little fast. Because as I said, my problem is 

17 not that I take ownership of my model, but 

18 that to say there was a -- this -- I said this 

19 earlier, that it was this aggressive cleanup 

20 just does not seem to be consistent with any 

21 model and the ORISE survey data, the 

22 independent verification data. It just --
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1 it's simply -- when things don't add up, one 

2 has to look at the information and say which 

3 of it -- you know, how do we deal with it? 

4 And we have not had the opportunity to do that 

5 here. 

6 Here is a sudden new piece of 

7 information or a report, a secondhand report 

8 which is given to us which we have not had a 

9 chance to investigate, to consider, just like 

10 we do all the other information, the 

11 plausibility, the correctness of it. So I 

12 would not want to be that hasty, because the 

13 fact is that this model or some other -- you 

14 know, I'm open to suggestions. There may be 

15 another approach. There may be some other 

16 assumptions. There may be some modifications 

17 possible to it. But a model that is based on 

18 site data gets away from all of this -- all of 

19 these questions of how many tons of uranium 

20 were there? What was the exact shape? What 

21 was the exact -- all of that is -- all of 

22 these questions are eliminated. 
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1 All we need to know is what was 

2 the concentration at some period of time and 

3 what was the time history, the temporal 

4 history of how much was done in each year? 

5 Because if it was all done in the last year, 

6 it would be very different than if it was all 

7 done the first year. But we know how with a 

8 reasonable -- as well as we can do, with a 

9 reasonable degree of assurance how it was 

10 spread out over the various years. And the 

11 idea of the model solves some of these 

12 dilemmas. 

13 And the fact that the parameters 

14 can be put together to give us a ventilation 

15 rate which is plausible, I mean, it's not that 

16 it's the answer. To my mind it's a plausible 

17 upper bound. I think it's on the high side. 

18 I think it's probably likely higher than what 

19 was experienced, but it's a plausible upper 

20 bound that if you adopt something like this or 

21 some variant of that, you're not going to 

22 appreciably underestimate anyone's dose.
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1 CHAIRMAN ZIEMER: So, John, I 

2 think your colleague is saying that he's a 

3 little nervous about accepting that right 

4 away.

5 DR. MAURO: Oh, and I understand 

6 exactly where he's coming from. I hate to 

7 abandon a perfectly good model prematurely, 

8 but you know, it sounded like, you know, if 

9 we're going to -- now we have two --

10 unfortunately, Paul, we have two paths. One 

11 is can we -- in other words, given that NIOSH 

12 would say, well, perhaps we could find a 

13 better surrogate. And I'm not sure if they're 

14 ready to say that. But if they were, then 

15 we'd have to go down that road and find a 

16 better surrogate. And that was where we were 

17 sort of headed.

18 However, listen, if we're not --

19 all I said is if you want -- if you stipulate 

20 and say, no, we're going to accept it as true 

21 there was an aggressive cleanup, well, of 

22 course we have to abandon our model. But Bob 
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1 brings up a good point, the point being why 

2 are we ready to abandon this model based on 

3 what we just heard today? You know, maybe 

4 we're abandoning it prematurely. This is 

5 really a call that the Work Group has to make, 

6 you know, to pursue both lines a little 

7 further. You know, are both worth pursuing, 

8 not just the surrogate data question?

9 CHAIRMAN ZIEMER: I think the Work 

10 Group has already agreed that they were 

11 accepting that the cleanup occurred. 

12 DR. MAURO: Okay.

13 CHAIRMAN ZIEMER: I'll ask again. 

14 John and Josie? 

15 MEMBER BEACH: Yes.

16 CHAIRMAN ZIEMER: I think Wanda 

17 said she accepted that and I do. So --

18 MEMBER POSTON: Accepting what?

19 CHAIRMAN ZIEMER: We're accepting 

20 that the cleanup occurred.

21 MEMBER POSTON: Oh, okay. I see. 

22 All right.
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1 CHAIRMAN ZIEMER: I mean, one 

2 might get into details on how aggressive it 

3 was and so on, but I think on that basis we're 

4 going to proceed.

5 MR. RAMSPOTT: Dr. Ziemer, could I 

6 add something on cleanup?

7 CHAIRMAN ZIEMER: No, John, we're 

8 trying to come to closure. We've already 

9 accepted that it's occurred, so --

10 MR. RAMSPOTT: I just wanted to 

11 correct Dr. Anigstein -- a few months ago --

12 I'm going to read the transcript note. I'm 

13 looking at it.

14 CHAIRMAN ZIEMER: No, John, we --

15 MR. RAMSPOTT: Yes?

16 CHAIRMAN ZIEMER: You don't need 

17 to do that. Okay?

18 MR. RAMSPOTT: All right.

19 CHAIRMAN ZIEMER: Yes.

20 MR. RAMSPOTT: Well, it's there.

21 CHAIRMAN ZIEMER: Okay. So I 

22 would like to get something specific from the 
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1 Subcommittee on a recommendation for the 

2 Board. If you want me to recommend that we 

3 ask NIOSH and SC&A to try to collaborate on a 

4 better surrogate or a more appropriate 

5 surrogate, we can do that. If you want to 

6 recommend something else, we can do that.

7 MEMBER BEACH: Paul, let's be 

8 clear that surrogate data is for what time 

9 period?

10 CHAIRMAN ZIEMER: Well, it would 

11 first of all have to cover the main --

12 MEMBER BEACH: The main time 

13 period?

14 CHAIRMAN ZIEMER: -- the covered 

15 period because there is a contamination 

16 component there.

17 MEMBER BEACH: Right. 

18 CHAIRMAN ZIEMER: I mean --

19 MEMBER BEACH: So it would --

20 CHAIRMAN ZIEMER: -- previously we 

21 had already in a sense recommended that we go 

22 ahead, or that we --
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1 MEMBER BEACH: Right.

2 CHAIRMAN ZIEMER: -- recommended 

3 to the Board that the covered period -- that 

4 we accept the NIOSH approach. That was before 

5 this whole issue came up. But this issue 

6 covers both periods, the issue of surrogate 

7 data. So we would first have to establish it 

8 for the covered period. If we can't for the 

9 covered period, then that already has 

10 implications for the residual period, I guess. 

11 Yes. So, I think it would have to be both. 

12 It basically, you know, in my mind reopens the 

13 whole issue of the earlier period in terms of 

14 a recommendation, because we can't recommend 

15 to the Board that the SEC be denied for the 

16 earlier period if we have this open issue on 

17 that component. So I think it's both. Do you 

18 agree, Jim?

19 DR. NETON: Yes, any model that 

20 would be developed for exposure handling the 

21 uranium would ultimately end up being the 

22 basis for some model of the residual period --
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1 CHAIRMAN ZIEMER: Whether it was 

2 -- yes.

3 DR. NETON: There would be no more 

4 handling of the uranium material because 

5 that's all gone, but it would --

6 CHAIRMAN ZIEMER: It would be the 

7 start of the --

8 DR. NETON: -- be the basis for 

9 the starting point for the resuspension of 

10 material in the building.

11 CHAIRMAN ZIEMER: Right. So you 

12 heard sort of a vague suggestion from John. I 

13 say sort of vague because --

14 MEMBER POSTON: Yes, I'm not quite 

15 clear. I don't think we've ever done that, 

16 this joint approach before. I'm a little --

17 CHAIRMAN ZIEMER: I think you're 

18 -- are you thinking of it more like a 

19 technical meeting, or -- I mean, why would 

20 they meet apart from the Work Group? 

21 MEMBER POSTON: Well, I want to 

22 understand a little bit better what is the 
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1 most appropriate surrogate data to use. I 

2 want to understand what model is going to be 

3 used. You know, we have two models basically. 

4 We have David's model and Bob's model. And 

5 maybe --

6 CHAIRMAN ZIEMER: Well, Bob's 

7 model will be off the table --

8 MEMBER POSTON: Yes, all right. 

9 CHAIRMAN ZIEMER: -- if we would 

10 agree that the cleanup occurred --

11 MEMBER POSTON: Yes. Okay. 

12 CHAIRMAN ZIEMER: -- which I think 

13 we've agreed to.

14 MEMBER POSTON: I understand that, 

15 but there may be components of Bob's model 

16 that may be --

17 DR. NETON: Well, I think what 

18 John was saying earlier, we have to pick a 

19 starting point. We have to decide is there 

20 some data available that can be used as a 

21 starting point to bound the exposure of the 

22 workers based on whatever source term type 
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1 material was there.

2 MEMBER POSTON: Yes, I agree.

3 DR. NETON: And the rest will fall

4 into place after that. The specifics of the 

5 -- like the -- as Bob was talking about, the 

6 resuspension model and everything will just 

7 fall out from that. But I think it would be 

8 -- SC&A and NIOSH would need to agree or 

9 should agree at some point that there are data 

10 available, surrogate data available that could 

11 be used, and what is that? What's the 

12 starting point?

13 CHAIRMAN ZIEMER: Well, let me 

14 propose something to the Work Group. At this 

15 point I guess I would report to the Board two 

16 things: One is that SC&A's review of the 

17 surrogate data issue was that they do not 

18 believe that NIOSH met the surrogate data 

19 requirement, at least on three or four of 

20 those issues, certainly on three for sure, 

21 maybe on the fourth, number one.

22 DR. NETON: For the specific value 
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1 we propose.

2 CHAIRMAN ZIEMER: Right. Number 

3 two, that we have an extensive discussion 

4 about what would constitute an appropriate 

5 surrogate, and that in the process of the 

6 review and the response by SC&A some 

7 additional potential surrogates have arisen 

8 that need to be looked and that this covers 

9 both periods, the covered period and the 

10 residual period, and that we would like NIOSH 

11 to -- I think the ball's in NIOSH's court then 

12 to specifically tell us whether there is a 

13 different surrogate group that they can 

14 recommend or not. And once that's done, then 

15 I think SC&A would have to come aboard also 

16 and say, okay, we'll look at that, too, then. 

17 But I think we've all --

18 DR. ANIGSTEIN: I mean, if we had 

19 -- are you saying --

20 CHAIRMAN ZIEMER: I don't think 

21 you do it in -- I think NIOSH does it and --

22 DR. ANIGSTEIN: Sure.
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1 CHAIRMAN ZIEMER: -- then --

2 DR. ANIGSTEIN: And then we would 

3 then go back and review it against the Board's 

4 criteria.

5 CHAIRMAN ZIEMER: Which means this 

6 is going to extend this out, but it does -- it 

7 reopens everything for both the covered period 

8 and the extended period. 

9 MEMBER BEACH: Or we could go to 

10 the Board and just suggest that we vote on an 

11 SEC for the early period, which would be --

12 CHAIRMAN ZIEMER: Right, we --

13 MEMBER BEACH: -- my vote.

14 CHAIRMAN ZIEMER: We can --

15 MEMBER BEACH: Because I think 

16 we've gone over and over this.

17 CHAIRMAN ZIEMER: Right.

18 MEMBER BEACH: So --

19 CHAIRMAN ZIEMER: And so, I would 

20 simply report that to the Board, that that's 

21 what SC&A -- that's what their report was, 

22 that this is a possibility, or that the Board 
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1 can decide if they want to go ahead and vote 

2 now on the issues. And I don't know if this 

3 Board right now, if you want to make a 

4 specific recommendation or simply have me 

5 report that. And certainly at the meeting if 

6 -- and Josie is -- you can certainly make the 

7 motion. I mean, I don't personally object to 

8 having the motion made, if you want to make it 

9 at the meeting.

10 MEMBER BEACH: Right.

11 CHAIRMAN ZIEMER: Or I'll simply 

12 report that, unless you all want to vote here. 

13 We can take a vote here on whether or not --

14 well, number one, is everybody comfortable if 

15 I report it that way?

16 MEMBER MUNN: Yes.

17 CHAIRMAN ZIEMER: Because I'll 

18 just report what we did.

19 MEMBER MUNN: Yes.

20 CHAIRMAN ZIEMER: Number two, to 

21 give the Board -- say you have an option. If 

22 you would like NIOSH to proceed and focus on a 
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1 better surrogate, then you can say so. Or you 

2 can move to close this and vote for --

3 MEMBER MUNN: And I would prefer 

4 not to vote it, because I understand what 

5 you're saying, Josie, but by the same token 

6 what we did here today was to agree that 

7 reliance on the FUSRAP data was not going to 

8 be as desirable as we had originally intended 

9 because of the cleanup, the magnitude --

10 MEMBER BEACH: The potential 

11 cleanup.

12 MEMBER MUNN: -- of the cleanup 

13 activities that went on --

14 CHAIRMAN ZIEMER: Which was new 

15 information.

16 MEMBER MUNN: -- in between that 

17 time; this was new information, and has fallen 

18 out of the activities that are going on and 

19 the exchange of information that's occurred 

20 between NIOSH and SC&A during the last 

21 activity period.

22 MEMBER BEACH: Well, and on top of 
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1 that I didn't agree with using 1993 data to 

2 back extrapolate it --

3 CHAIRMAN ZIEMER: Anyway --

4 MEMBER MUNN: Yes.

5 MEMBER BEACH: -- anyway.

6 MEMBER MUNN: Yes, so --

7 MEMBER BEACH: So, regardless.

8 MEMBER MUNN: -- that is now -- as 

9 I understand it generally, based on what the 

10 conversation has been here, has been set 

11 aside. 

12 The position that I was trying to 

13 make and the few comments that I made was that 

14 we know an awful lot about the uranium metal 

15 and how it operates and all of the proposed 

16 concerns that people have with regard to what 

17 transpired in this particular site. We know a 

18 great deal that has -- we have not relied upon 

19 because we have been looking in a different 

20 direction to extrapolate information that we 

21 did have. 

22 And now we're talking about going 
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1 to look specifically for the kinds of 

2 surrogate information that is on record for 

3 sites that have handled this same type of 

4 uranium over a period of something like 50 

5 years. Knowing that information creates a 

6 different basis for making the decision. And 

7 until we have specifically requested NIOSH to 

8 go that direction, we don't have that 

9 information. We have it, but it has not been 

10 finalized and it has not been placed before us 

11 in a rigorous manner. I would prefer to have 

12 that done, because we do know a lot about 

13 uranium and we can do this. It can be done.

14 CHAIRMAN ZIEMER: Okay. Other 

15 comments? John, are you okay with that as a 

16 general report?

17 MEMBER POSTON: Yes, I agree with 

18 Wanda. Wanda said it --

19 CHAIRMAN ZIEMER: And, Josie?

20 MEMBER BEACH: I still say that we 

21 should bring it to the Board also with the 

22 third option of voting for an SEC. 
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1 CHAIRMAN ZIEMER: Yes, I would be 

2 glad to present that as an option. I mean, I 

3 understand that I'm going to report what we 

4 did here, indicate that as an option. I think 

5 the options are to proceed to have SC&A --

6 NIOSH -- yes, I know, hard to tell them apart. 

7 Yes, right. Have NIOSH proceed and see if 

8 they can identify a more suitable surrogate 

9 data set. But if the Board wishes, it can 

10 proceed to vote yea or nay, up or down, 

11 without going any further. 

12 MEMBER BEACH: So will you go 

13 further from now, or will you wait until after 

14 the Board meeting, Dave, just as a curiosity?

15 MR. ALLEN: I'll start now. I 

16 don't think it will -- you'll have anything 

17 before the Board meeting.

18 MEMBER BEACH: Okay.

19 CHAIRMAN ZIEMER: Yes, you're not 

20 going to have that much time with other 

21 things --

22 MR. ALLEN: I've got other Work 
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1 Groups, too, you know?

2 DR. ANIGSTEIN: And we certainly 

3 won't have time to review it.

4 CHAIRMAN ZIEMER: Let's see. So 

5 we're all agreed to proceed on that basis?

6 MEMBER POSTON: Yes.

7 MEMBER MUNN: I think that's 

8 unfortunate, personally, but then the Board 

9 voted with incomplete information before.

10 MR. KATZ: So is there a need, 

11 Paul, for -- so that lays out a presentation 

12 by you --

13 CHAIRMAN ZIEMER: Right.

14 MR. KATZ: -- to summarize what's 

15 been done today.

16 CHAIRMAN ZIEMER: Right.

17 MR. KATZ: You need -- I mean, 

18 right now we have lined up things as we did 

19 with the last Board meeting where SC&A as well 

20 as DCAS had opportunities to present, as well 

21 as you. Do you want that supporting them at 

22 this --
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1 CHAIRMAN ZIEMER: Well, I will 

2 summarize what we did. I'm trying to think 

3 whether or not we need any further 

4 presentations.

5 MEMBER MUNN: We gave a pretty 

6 complete presentation last Board meeting.

7 CHAIRMAN ZIEMER: Yes, I think 

8 they can be available for questions. I don't 

9 know -- and I think the Board has all been 

10 kept apprised of all the documents, including 

11 the petitioners' and our documents as well. 

12 So the Board should have a pretty complete set 

13 of --

14 DR. ANIGSTEIN: So, we don't need 

15 to go.

16 MR. KATZ: No, no, I think you 

17 need to be available at least --

18 CHAIRMAN ZIEMER: At least by 

19 phone.

20 MR. KATZ: -- by phone. You need 

21 to be available to answer the questions of the 

22 Board.
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1 CHAIR ZIEMER: But I mean I don't 

2 think you need to make a presentation.

3 MR. KATZ: You don't need to make 

4 -- that's what I was trying to get clear. So 

5 if you don't need -- you don't need to make a 

6 presentation and --

7 DR. ANIGSTEIN: I see. But I 

8 already have my ticket, so should I go, or 

9 just cash it in and --

10 MEMBER POSTON: Sure. Good 

11 skiing.

12 DR. ANIGSTEIN: I think I got to 

13 go.

14 MR. KATZ: You can choose.

15 DR. ANIGSTEIN: Okay.

16 MR. KATZ: It just depends on 

17 whether you're comfortable answering questions 

18 by phone. But you're not giving a 

19 presentation.

20 DR. ANIGSTEIN: Yes, okay.

21 MR. KATZ: Okay?

22 CHAIRMAN ZIEMER: Now, the other 
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1 thing we said we would do as we have time, and 

2 we're already at the 3:00 hour, I do want to 

3 point out just before we leave as far as the 

4 matrix or the matrices; there are two of them, 

5 but the SEC --

6 MEMBER BEACH: The last day was 

7 June 1st, correct, on that one? Yes.

8 CHAIRMAN ZIEMER: June 1st was the 

9 last update. And just very quickly, I'm 

10 telling you you can look -- if you have your 

11 report, it's on page 45 of the status summary. 

12 Issue 1 had been previously closed. Issue 2 

13 actually -- and all of these are -- the open 

14 ones were all transferred to the Appendix BB 

15 matrix, but they don't show up specifically on

16 Bob's latest version, which is the July 28th 

17 version. They don't show up there. But I'm 

18 just telling you that issue 2 of the SEC 

19 matrix, as far as I can tell, is part of issue 

20 1 on the other matrix. So if you want to make 

21 a note of that and --

22 MEMBER BEACH: Well, if you go 
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1 into the body of these, the end is the ones 

2 that he transferred. Like issue 2, it says on 

3 3/28/12, transfer to Appendix BB.

4 CHAIRMAN ZIEMER: Right, but --

5 MEMBER BEACH: He didn't write it 

6 on the summary though.

7 CHAIRMAN ZIEMER: It doesn't show 

8 up on Appendix BB.

9 MEMBER BEACH: Right.

10 CHAIRMAN ZIEMER: But I'm telling 

11 you that it --

12 MEMBER BEACH: So you're going to 

13 ask --

14 CHAIRMAN ZIEMER: -- it's covered 

15 by issue 1 of Appendix BB.

16 MEMBER BEACH: So are you going to 

17 ask him to converge these?

18 CHAIRMAN ZIEMER: Well, yes, I'll 

19 make up a chart to do that. 

20 Issue 3 we closed. Issue 4 is 

21 closed. Issue 5 is closed. Issue 6 really 

22 becomes part of issue 11 of Appendix BB. But 
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1 in essence the recommendation was to transfer 

2 it. And we hadn't officially closed it, but 

3 it, you know --

4 MEMBER BEACH: And go back to 3. 

5 Three was actually transferred to BB, not 

6 closed.

7 CHAIRMAN ZIEMER: Well it says 

8 here it was recommended moving it and closing 

9 it. 

10 MEMBER BEACH: It was recommended, 

11 but we didn't actually officially do that.

12 CHAIRMAN ZIEMER: Oh, we may have 

13 to actually do that. I thought in doing the 

14 recommendation that we were closing it, but we 

15 can formalize that. 

16 MEMBER BEACH: Not to confuse this 

17 anymore than it is.

18 CHAIRMAN ZIEMER: Right. We have 

19 to do the same on issue 6.

20 MEMBER BEACH: Yes.

21 CHAIRMAN ZIEMER: Issue 7, it 

22 shows it in progress. Essentially we closed 
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1 it, but NIOSH has to actually show the update 

2 in their new version before we officially 

3 close that. 

4 Issue 8 was recommended to be 

5 closed, but right now it's simply transferred. 

6 It's one of those again transferred and had 

7 been recommended that it was closed. 

8 And issue 9 as far as I can see 

9 becomes part of issue 6, and that should be 

10 closed as well.

11 The other thing I'll just point 

12 out, if you look at the SEC findings, there 

13 were no specific findings on the residual 

14 period. 

15 MR. KATZ: Right.

16 CHAIRMAN ZIEMER: So all of these 

17 findings have to do with early period. But 

18 there are still some items open on TBD-6000 

19 that I think we can close most of. Some of 

20 them are fairly straightforward, but to some 

21 extent it will depend on our time. We need to 

22 focus on this SEC, but I just wanted to make 
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1 sure that we're on the same page on the issues 

2 matrix. But even though they showed 

3 transferred, they haven't shown up as specific 

4 separate items. 

5 Okay. Any other questions before 

6 we leave?

7 MR. KATZ: So, Paul, do you want 

8 SC&A to amend the matrix accordingly, or --

9 CHAIRMAN ZIEMER: I think they 

10 should amend it, but I want to make sure -- I 

11 think I'll interact -- I think I'll prepare a 

12 little chart and what I --

13 MR. KATZ: Yes, I'll wait for you 

14 to have -- for your chart.

15 CHAIRMAN ZIEMER: Right.

16 MR. KATZ: And then I'll send that 

17 along to SC&A.

18 CHAIRMAN ZIEMER: This is where I 

19 think they go and make sure we're on the same 

20 page. 

21 MEMBER MUNN: It would be helpful 

22 --
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1 CHAIRMAN ZIEMER: And then I'll 

2 ask them to update it.

3 MR. KATZ: That sounds good.

4 MEMBER MUNN: No, I thought it 

5 would be helpful, but this is getting awfully 

6 cumbersome.

7 CHAIRMAN ZIEMER: Right. Well, see 

8 there's a lot of these findings that look 

9 similar but they're worded slightly 

10 differently. So there's a fair -- there's 

11 always overlap between SEC issues and TIB 

12 issues.

13 Okay. With that we stand 

14 adjourned. Thank you. Thank you everyone on 

15 the phone for your input today and we'll hope 

16 to hear from you all at the full Board 

17 meeting. You'll have an opportunity again to 

18 have input there.

19 MEMBER MUNN: Oh, you're not going 

20 to make an effort to schedule another meeting 

21 at all?

22 CHAIRMAN ZIEMER: Well, yes.
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1 MEMBER MUNN: I mean, not knowing 

2 what we're waiting for.

3 MR. KATZ: I think it makes sense 

4 to wait.

5 CHAIRMAN ZIEMER: I think we need 

6 to know where -- yes, what --

7 MEMBER MUNN: Who's on first.

8 CHAIRMAN ZIEMER: -- action the 

9 Board takes, number one. And then we'll find 

10 out what NIOSH's stand on it is. 

11 MEMBER MUNN: Timeline for that, 

12 yes.

13 CHAIRMAN ZIEMER: I think we're 

14 going to be talking probably into November 

15 before we --

16 MEMBER MUNN: I would imagine so.

17 CHAIRMAN ZIEMER: Yes, we're 

18 adjourned.

19 (Whereupon, the meeting was 

20 adjourned at 3:09 p.m.)