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transcript is for information only and is subject to change.

1

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH

+ + + + +

ADVISORY BOARD ON RADIATION AND

WORKER HEALTH

+ + + + +

SUBCOMMITTEE ON PROCEDURES REVIEW

+ + + + +

THURSDAY

AUGUST 28, 2014

+ + + + +

The Subcommittee convened via 

teleconference at 11:00 a.m., Eastern Daylight 

Time, Wanda I. Munn, Chair, presiding.

PRESENT:

WANDA I. MUNN, Chair

JOSIE BEACH, Member

PAUL L. ZIEMER, Member

NEAL R. GROSS

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2

ALSO PRESENT:

TED KATZ, Designated Federal Official

MATT ARNO, ORAU Team

BOB BARTON, SC&A

HANS BEHLING, SC&A

KATHY BEHLING, SC&A

RON BUCHANAN, SC&A

BOB BURNS, ORAU Team

HARRY CHMELYNSKI, SC&A

DOUG FARVER, SC&A

STU HINNEFELD, DCAS

LORI MARION-MOSS, DCAS

STEPHEN MARSCHKE, SC&A

JOHN MAURO, SC&A

JAMES NETON, DCAS

STEVE OSTROW, SC&A

SCOTT SIEBERT, ORAU Team

MATTHEW SMITH, ORAU Team

DANIEL STANCESCU, DCAS

JOHN STIVER, SC&A

ELYSE THOMAS, ORAU Team

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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3

T-A-B-L-E O-F C-O-N-T-E-N-T-S

PAGE

Welcome and Roll Call ..................... 5

Review off-line BRS changes ............... 6

ALL

Paper-contaminant cleansing of

localized skin exposure .................. 23

NIOSH

PER-0031-Report review - Carryover ....... 32

NIOSH

Summary clarification of AP wording -

IG 001 Finding 25 ........................ 44

NIOSH

Criteria for AIC/Weibull distribution

IREP V. 5.7 .............................. 51

NIOSH

OTIB-83 - Findings report - Carryover .... 77

NIOSH

OTIB-34 Rev 0, Finding 4 ................. 84

SC&A

OTIB-34 Rev 1, Finding 7, 8 ............. 123

NIOSH

Status - PER-0038 case audits ........... 145

NEAL R. GROSS

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4

SC&A

OTIB-54 - Reactor modeling report ....... 145

NIOSH

OTIB-54 - Response status Findings

1-4, 5, 8, 10 ........................... 146

NIOSH

New PER reviews - 42, 43, 45 ............ 152

SC&A

Prioritized list of PER

recommendations.................... 231

SC&A

Administrative detail carryovers

- Status RPRT 53, PER-0037,

PER-0011, PER-0018, PER-0033....... 243

SC&A

- PPG status comment for record.... 254

- Next meeting..................... 254

Adjourn ................................. 259

NEAL R. GROSS

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5

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

2 (10:58 a.m.)

3 MR. KATZ: So this is the Advisory 

4 Board on Radiation and Worker Health 

5 Subcommittee on Procedures Review. There are 

6 materials for this meeting that are posted on 

7 the NIOSH website along with the agenda under 

8 the Board section under meetings, today's date. 

9 So people can also follow along with some of the 

10 materials that we'll be talking about which are 

11 posted there.

12 Let's do roll call. As far as 

13 conflict of interest is concerned, there 

14 shouldn't be any material that relates to 

15 conflicts in today's agenda. But I just remind 

16 my Board Members to just keep that in mind in 

17 case something comes up related to a site you 

18 have conflict with.

19 And so let's go with the roll call 

20 for Board Members.

NEAL R. GROSS

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6

1 (Roll Call)

2 MR. KATZ: Very good. Wanda, it's 

3 your agenda.

4 CHAIR MUNN: Thank you much, and 

5 thanks to everybody who is joining us today, and 

6 thanks especially to those of you who submitted 

7 papers for us to deal with today. After that 

8 long hiatus, I hope you're all ready to attack 

9 these issues again.

10 And let's start with very quickly 

11 taking a look at what Steve has up on the screen 

12 for us. Thank you, Steve, for being 

13 johnny-on-the-spot getting the material in 

14 front of us to look at.

15 And let's take a look at what you and 

16 Lori have posted to the BRS that we discussed 

17 at our last meeting but was going to be taken 

18 care of offline. Steve, you want to lead off 

19 on that and Lori if you can follow afterwards?

20 MR. MARSCHKE: I'm not aware of 

NEAL R. GROSS

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7

1 anything that was really we needed to be posted, 

2 Wanda. Let me see, up to the last --

3 CHAIR MUNN: I just thought there 

4 were one or two things that were so wordy that 

5 you were going to take care of it after the 

6 meeting. But perhaps you did it before we ever 

7 got offline last time.

8 Lori?

9 MR. MARSCHKE: If I did I -- I'm 

10 sorry, Wanda. I mean if I did, I did it right 

11 after the meeting which was, you know --

12 CHAIR MUNN: So long ago.

13 MR. MARSCHKE: So long ago that 

14 I've forgotten. And I went back and looked at 

15 the transcript to see if there were any SC&A 

16 action items which were expected of me and I 

17 didn't see any.

18 CHAIR MUNN: All right. That's 

19 fine. Lori?

20 MS. MARION-MOSS: Yes, Wanda. I 

NEAL R. GROSS

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8

1 do believe the only thing that's been updated 

2 since that time is the findings that I sent out 

3 to the Committee the other day. And I do 

4 believe Steve Ostrow had updated the BRS with 

5 some responses to OTIB-54 findings since our 

6 last meeting.

7 DR. OSTROW: This is Steve. 

8 That's correct. I had updated that. Right 

9 after the meeting I updated the BRS on OTIB-54.

10 CHAIR MUNN: So can we take a look 

11 at OTIB-54 and that update to make sure that it 

12 meets the expectations of the Board Members? 

13 Here we are.

14 DR. OSTROW: Wanda, this is Steve 

15 again. The updating I did was on April 16th to 

16 all the open findings and I said the exact same 

17 thing in each one. This finding in OTIB-0054 

18 Rev 1 also applies to Revision 2.

19 CHAIR MUNN: Yes.

20 DR. OSTROW: Because subsequently 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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9

1 to my making the comments on Rev 1, NIOSH 

2 released Rev 2. And I reviewed Rev 2 and didn't 

3 see any material change between Rev 2 and Rev 

4 1.

5 CHAIR MUNN: Excellent.

6 DR. OSTROW: So I just basically 

7 said that all of the findings apply to Rev 2.

8 CHAIR MUNN: Good. Any thoughts 

9 from anyone else? If not, thank you for that 

10 Dr. Ostrow. And --

11 MS. MARION-MOSS: Wanda?

12 CHAIR MUNN: Yes?

13 MS. MARION-MOSS: Lori. I would 

14 just like to point out to the Board, 

15 Subcommittee Members, that the BRS looks a 

16 little different since the last time --

17 CHAIR MUNN: Yes, it certainly 

18 does. It was a surprise.

19 (Simultaneous speaking)

20 MS. MARION-MOSS: The major change 

NEAL R. GROSS

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10

1 here that we have is actually the display on the 

2 screen and the option of being able to change 

3 your font size. And that's basically the 

4 biggest change.

5 CHAIR MUNN: That's very 

6 convenient though, and I certainly approve. I 

7 don't know whether anyone else has had an 

8 opportunity to play with it a little bit. I 

9 pulled it up for the first time day before 

10 yesterday, I guess.

11 So I looked at it a little bit 

12 yesterday and looked at the report sheets to see 

13 what our figures were looking like, so, but was 

14 very pleased with the look of the current index. 

15 It seems to be easy to work with.

16 If anyone else has a comment in that 

17 regard, please join in.

18 MEMBER BEACH: Yes, Wanda, this is 

19 Josie. I also was playing with the BRS the last 

20 couple of days, and I really like the changes 

NEAL R. GROSS

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11

1 that were made. So thank you.

2 CHAIR MUNN: Good, yes. True. 

3 And if we have any other comments, I'm assuming 

4 that Josie, you and Paul both have seen Lori's 

5 email and the changes that she listed there.

6 MEMBER ZIEMER: Yes.

7 MEMBER BEACH: Yes.

8 CHAIR MUNN: All right. No 

9 question about any of that. If not, then thank 

10 everyone who was involved in that and let's move 

11 on to our first item other than the BRS.

12 MS. K. BEHLING: Wanda?

13 CHAIR MUNN: Yes?

14 MS. K. BEHLING: This is Kathy 

15 Behling. I was just going to ask a question. 

16 Because I was attempting, or I was going to 

17 attempt to put the findings in from our review 

18 of the DCAS PERs that we're going to be 

19 discussing today, 42, 43, and 45.

20 And I'm not sure that I have 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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12

1 authorization to do that because, and if I do 

2 I don't know how to do it. I assume that 

3 perhaps NIOSH needs to enter those PERs for us 

4 first and then I would be able to put the 

5 findings in because I don't know how to actually 

6 enter a new document.

7 CHAIR MUNN: Oh. And we don't have 

8 those three PERs in yet?

9 MS. K. BEHLING: I didn't see them. 

10 Maybe they are. Did I miss them?

11 MR. MARSCHKE: Actually, they're 

12 in the unassigned queue. I guess we've got to 

13 figure out how to take them from the unassigned 

14 queue. I mean you can look and see on the 

15 screen now, this is the unassigned queue. And 

16 there's 42, 43 --

17 CHAIR MUNN: 43 and 45.

18 MR. MARSCHKE: -- and 45 are there. 

19 Now we have to basically take them from the 

20 unassigned queue and bring them over into the, 

NEAL R. GROSS

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13

1 assign them, I guess, to the Subcommittee, and 

2 I'm not sure how you do that.

3 CHAIR MUNN: Yes, that sounds 

4 reasonable. Lori, is this an activity that 

5 we've gone through before behind the scenes and 

6 that the rest of us are aware of?

7 MS. MARION-MOSS: Yes, but Steve 

8 should be able to do that. If you will, Steve, 

9 click on PER-0042 and let's see what happens.

10 You clicked on it?

11 MR. MARSCHKE: I clicked on it. Do 

12 you want it expanded?

13 MS. MARION-MOSS: Yes.

14 MR. MARSCHKE: Okay, Assign to Work 

15 Group. Okay, basically what I should do --

16 MS. MARION-MOSS: First, select 

17 our committee.

18 MR. MARSCHKE: Subcommittee, and 

19 then that's it. Pretty simple.

20 MS. MARION-MOSS: That's, 

NEAL R. GROSS

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14

1 hopefully.

2 MR. MARSCHKE: Are you sure you 

3 would like to assign one --

4 (Simultaneous speaking.)

5 MR. MARSCHKE: Okay, and then 

6 basically we go down to, 45 is here.

7 DR. MAURO: We've come a long way, 

8 baby.

9 CHAIR MUNN: We certainly have. 

10 That's marvelous.

11 MR. MARSCHKE: And 43 is here. 

12 That's the last one, right? Kathy?

13 MS. MARION-MOSS: Yes, it is. 

14 Yes.

15 MS. K. BEHLING: 42, 43, 45.

16 CHAIR MUNN: 45.

17 MR. MARSCHKE: Okay, so now they, 

18 okay, let me get this one done.

19 CHAIR MUNN: Steve and Lori have 

20 now accomplished digital magic for us. And 

NEAL R. GROSS

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15

1 Kathy, hopefully the next time you attempt 

2 this, maybe even yet today, you may be able to 

3 do what you wanted to do.

4 MS. K. BEHLING: Very good. Thank 

5 you.

6 CHAIR MUNN: You bet. That's 

7 wonderful. Ah yes, this is moving the way it 

8 should. That's excellent. Thank you so much.

9 MR. MARSCHKE: PERs, right?

10 CHAIR MUNN: PERs.

11 MS. MARION-MOSS: Steve, you're in 

12 the wrong committee. You're in the PR 

13 Subcommittee.

14 MR. MARSCHKE: Oh, I'm in the 

15 Construction and they don't have any PERs.

16 CHAIR MUNN: Which is a good thing.

17 MR. MARSCHKE: Evaluation for 

18 PERs.

19 CHAIR MUNN: Here we are.

20 MR. MARSCHKE: 42, 45 and 43.

NEAL R. GROSS

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16

1 CHAIR MUNN: Do you see them? I 

2 don't see them on my screen yet, but yes. Yes, 

3 there they are. There's 43.

4 MR. MARSCHKE: We've already got 

5 them so we can basically --

6 CHAIR MUNN: 43 and 44?

7 MR. MARSCHKE: Yes.

8 CHAIR MUNN: Yes. 42 for some 

9 reason is out of --

10 (Simultaneous speaking)

11 CHAIR MUNN: But that's all right. 

12 We don't care. We know where it is.

13 DR. MAURO: Hey Wanda, this is 

14 John. Quick question. How far have we gone on 

15 the interconnectedness between the 

16 Subcommittee and Work Groups and et cetera, et 

17 cetera? You know, the grand dream that started 

18 about five or six years ago, are we moving in 

19 on that?

20 CHAIR MUNN: I think my experience 

NEAL R. GROSS

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17

1 has been it just depends almost entirely on the 

2 Chair of the individual Work Group or the 

3 Subcommittee. If the Chair is active about 

4 this, then it's moving forward slowly but 

5 surely. For Chairs that are not particularly 

6 enthusiastic or don't feel comfortable with the 

7 process --

8 DR. MAURO: But the wherewithal 

9 exists that is within the framework --

10 CHAIR MUNN: Yes.

11 DR. MAURO: -- like we're looking 

12 at right now can accept that if so desired by 

13 the Chair?

14 CHAIR MUNN: That is my 

15 understanding and that's been my experience. 

16 Perhaps someone else has a different 

17 experience? If so, please let us know.

18 MR. HINNEFELD: Well, this is Stu 

19 at NIOSH. And we intend going forward when we 

20 get, like we start a new site fresh, to put 

NEAL R. GROSS

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18

1 findings in the BRS. And particularly, I know 

2 we did that with the Pacific Proving Ground 

3 findings from the Site Profile Review of 

4 Pacific Proving Ground.

5 And then I believe, well, it's my 

6 intention that we hope to do the same with some 

7 of the more recent Site Profile reviews that 

8 we're now working on responses to. But before 

9 we get down this pathway very long I'd like to 

10 get those documents.

11 And I'm thinking of putting things 

12 like, I think there's a W.R. Grace, a NUMEC, 

13 maybe Ames. I forget. And so our hope is to 

14 enter those in the appropriate Subcommittee or 

15 Working Group or with its own Working Group if 

16 one's established for those. And so then just 

17 kind of move people on to this.

18 Now in reality, we recognize that 

19 findings and responses will probably still have 

20 to be shared as they traditionally have been for 

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19

1 certain people's comfort level, but we think 

2 using the BRS will make it easier to collect the 

3 record of the discussion that's done at those 

4 meetings.

5 CHAIR MUNN: So perhaps a more 

6 accurate response to your question, John, is 

7 that in any case NIOSH will use this as the real 

8 honest-to-goodness basis of where we are and 

9 for their own tracking whether or not the 

10 individual Work Groups participate in it.

11 MR. KATZ: Yes, this is Ted. NIOSH 

12 and SC&A both will actually do that, enter their 

13 findings and so on. So yes, as Stu was saying, 

14 so for everything new, for all new work. So 

15 something like SRS that's been going on a long 

16 time, the SEC, we're not going to change horses 

17 midstream. For everything new we'll work this 

18 way.

19 MR. STIVER: Wonderful. Yes, this 

20 is John Stiver. I had a question for Stu. 

NEAL R. GROSS

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20

1 Back to over a year ago, we had the occasion to 

2 talk about maybe adjusting the BRS a bit where 

3 it could handle the Dose Reconstruction 

4 Subcommittee findings as well. And I was 

5 wondering, where are we on that? I don't quite 

6 remember where that stands.

7 MR. HINNEFELD: I don't go to that 

8 Subcommittee meeting anymore very much, so I'm 

9 not really tuned in to what's proceeding there. 

10 I would think that at any time, I think the best 

11 place to start might be with a new set of 

12 findings when there's a new set of dose 

13 reconstruction reviews done.

14 MR. STIVER: Yes, that makes sense. 

15 I think I recall we were going to go ahead and 

16 finish out the 13 sets using the matrices and 

17 then to migrate over after that.

18 MR. HINNEFELD: Yes, I think the 

19 intention was that it could be done, and I think 

20 we roughed out some sort of business logic --

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21

1 MR. STIVER: Right, right, right.

2 MR. HINNEFELD: -- on terms of what 

3 would be the document reviewed and, you know, 

4 those kinds of things. And so as far as I know 

5 we could probably start using it at any time, 

6 but I would think we would want to start with 

7 a set of reviews that the discussion has not yet 

8 started on.

9 MR. KATZ: Yes, Stu, I think if we 

10 could get, if your folks could start loading on, 

11 I guess, Set 14, 15, because those ones you're 

12 starting to review and respond to, I think, even 

13 though the Subcommittee hasn't gotten to them 

14 yet.

15 CHAIR MUNN: Yes, I think that's 

16 true. And the Subcommittee Chair has been 

17 trying very hard to close out all of the last 

18 remaining issues from the older sets so that we 

19 can start with a reasonably fresh slate with the 

20 new group.

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22

1 MS. MARION-MOSS: This is Lori. 

2 Steve, if you could, to kind of address John 

3 Stiver's question, if you can on the string 

4 there go to the DR Subcommittee Work Group 

5 filter.

6 As a result of that meeting, John, 

7 efforts were made to put in some of the matrix 

8 for the DR Subcommittee so that, I believe it 

9 was Doug Farver, I believe, that attended that 

10 meeting that had some questions.

11 We went ahead and put in some sets 

12 for the DR Subcommittee, and we wanted to give 

13 the Committee an opportunity to take a look at 

14 how that information was entered to see if there 

15 was any adjustments that needed to be made to 

16 fit the committee's needs.

17 And so far that's the last I've 

18 heard of it, so what you see here now on the 

19 screen is what was done as a result of that 

20 meeting.

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23

1 MR. MARSCHKE: I'm seeing for the 

2 eighth set there. But I'll go talk to Doug 

3 offline. I'm spending a lot of time on this 

4 right now with reviewing an upcoming DR 

5 Subcommittee meeting that might be a topic of 

6 discussion there.

7 MR. KATZ: Yes. Well, and I'm just 

8 thinking, there won't be a lot of time in that 

9 Subcommittee meeting for talking about these 

10 other matters either.

11 But just if you guys, John and Doug, 

12 if you look at it and it's making sense to you, 

13 I think that's probably enough to say to the 

14 folks, Stu's folks, that it's okay, why don't 

15 we upload, you know, 14 and 15 findings.

16 MR. MARSCHKE: Okay, I'll touch 

17 base with Doug on it.

18 MR. KATZ: Yes, thank you.

19 MR. MARSCHKE: All right.

20 CHAIR MUNN: All right, thank you 

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24

1 very much. I think we should all be pleased. 

2 Thanks very much to those of you who are working 

3 behind the scenes on the BRS. It is looking 

4 very good and I think you should all put a 

5 feather in your caps. We're making progress. 

6 Thank you.

7 Now moving on to our first item, we 

8 were going to have some information from NIOSH 

9 continuing our discussion about the 

10 contaminant cleaning and localized skin 

11 exposure.

12 Stu?

13 MR. HINNEFELD: Yes, I think Jim's 

14 going to talk about that.

15 CHAIR MUNN: Oh good.

16 DR. NETON: Yes, this is Jim, 

17 Wanda.

18 CHAIR MUNN: Yes, good. Glad 

19 you're here, Jim. Thank you.

20 DR. NETON: Thank you. This issue 

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25

1 is related to overarching Concern Number 9, 

2 overarching Issue Number 9, I believe it's 

3 Concern Number 1.

4 And that is that we had agreed in 

5 principle with SC&A about adding skin 

6 contamination to certain workers under certain 

7 circumstances, but the concern was raised about 

8 the efficacy of washing off a skin 

9 contamination. That is, it lasts just eight 

10 hours and it was showered off, or did it persist 

11 for, you know, a 24-hour time period to some 

12 degree?

13 And it was our opinion, based on 

14 just observations from working at uranium 

15 facilities, that uranium is particularly 

16 readily cleaned off with regular showering, 

17 soap and water. And that was certainly Stu's 

18 opinion having spent years working at Fernald, 

19 and we sort of almost thought it was sort of 

20 common industry knowledge.

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26

1 Well, SC&A didn't necessarily 

2 disagree, but they said you need to provide some 

3 backup evidence to support that position. So 

4 I've spent some time looking through the 

5 literature trying to find some documentation 

6 that would support that position.

7 I've looked through a number of 

8 documents including NCRP 161 which is 

9 Management of Persons Contaminated with 

10 Radionuclides. There is a DOE guidance for 

11 good practice at uranium facilities and there's 

12 some WHO guidance out there, none of which 

13 specifically talk about uranium contamination.

14 Well, the DOE guidance for good 

15 practices does, but all of them start with the 

16 suggestion that the contamination should be 

17 started to be cleaned with soap and water. 

18 That's always the recommended practice, and 

19 then you follow up with more aggressive 

20 treatment modalities later.

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27

1 And none of them make the case that 

2 the uranium was particularly recalcitrant to 

3 cleaning, but none of them also said that it was 

4 readily cleansed.

5 I dug a little deeper and I 

6 discovered a DTRA report that was produced 

7 actually by SENES, DTRA Report TR-09-16, which 

8 talks about radiation doses to skin from dermal 

9 contamination as specifically written for 

10 handling the DTRA cases, which of course would 

11 be directly relevant to fallout deposition.

12 There's a very lengthy treatment of 

13 skin contamination on these cases and how they 

14 deal with it but what caught my eye was a paper 

15 that was referenced from 1958, where there was 

16 actually an experiment done with what they 

17 called simulated fallout.

18 And they actually created a mixture 

19 of soil with a known particle size distribution 

20 and labeled it with lanthanum-140, which is not 

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28

1 uranium but it is radioactive, and applied it 

2 to the skin of various test subjects and 

3 evaluated the efficacy of removal with various 

4 treatment regimes.

5 It turns out that for that 

6 particular experiment almost 95.8 percent was

7 removed with a single washing with just regular 

8 soap and water. So that's not uranium, but it 

9 is indicative that the material can be readily 

10 cleansed with soap and water. I didn't think 

11 that was going to, you know, that was suggestive 

12 evidence but it wasn't uranium.

13 I searched further and just 

14 recently, actually, found a paper that was done 

15 in 1959 written by some folks from Los Alamos 

16 where they published this in the American 

17 Industrial Hygiene Association Journal, and 

18 the title of that document, "Surface 

19 Contamination Control with Uranium 

20 Operations."

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29

1 It's amazing to me that they 

2 actually did this. Los Alamos evaluated some 

3 uranium rolling operations in the late '50s 

4 where they actually used, if you recall, the 

5 salt bath method which is an extremely messy 

6 form of rolling uranium. Or not extremely 

7 messy, but it's pretty messy, where you dip the 

8 uranium in a salt bath, heat it up and then roll 

9 it, and it creates a lot of scaling and 

10 particulate contamination.

11 Well, the point of the article is 

12 really how you address contamination control in 

13 the facility, and they did a lot of surveys and 

14 evaluation of anti-Cs and such. But one aspect 

15 of the study, they actually monitored personnel 

16 before they left the area for contamination, 

17 both their clothing and their bodies.

18 And where they did find 

19 contamination they allowed the personnel to 

20 wash with soap and water and then surveyed them 

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30

1 again. And conclusion of their study, that 

2 little study, was washing with soap or 

3 detergent, it says, usually removes any 

4 personal contamination with skin.

5 In other words, they didn't find any 

6 real difficult contamination to remove at least 

7 in this experiment, which I believe is fairly 

8 relevant because it's at an actual uranium 

9 rolling operation.

10 So the point of all this discussion 

11 is I'm getting close to writing up something 

12 that would sort of end up being a weight of the 

13 evidence approach. I don't have any direct 

14 data though. I was really hoping to find some 

15 personal contaminations where they were, you 

16 know, before and after using soap and water, 

17 which is typically what's used, and I was not 

18 able to find any of those. So 

19 that's where I'm at on this finding. I intend 

20 to write this up as a brief White Paper to 

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31

1 document what I just discussed with the 

2 Subcommittee. That's it.

3 CHAIR MUNN: Thank you, Jim. 

4 We'll look forward to seeing that. Does SC&A 

5 have any comment?

6 DR. OSTROW: Yes, this is Steve 

7 Ostrow. Just a brief comment. I just got 

8 finished reading a bunch of site interviews at 

9 Idaho, INL. We just conducted lots of site 

10 interviews there with former workers.

11 And a number of them mentioned for 

12 skin contamination, especially in the earlier 

13 days, they just used sort of a crude bleach 

14 solution to take off the contamination. But I 

15 didn't really see any record of, you know, 

16 before and after readings. But that would seem 

17 to be the common method they were using to 

18 decontaminate, you know, things like hands that 

19 became contaminated.

20 DR. NETON: Right. That would 

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32

1 have been for what was going on at Idaho, and 

2 I hear what you're saying. This particular 

3 finding though, I believe we were focused more 

4 on the early years of uranium processing 

5 operations --

6 DR. OSTROW: Right.

7 DR. NETON: -- where they rolled 

8 uranium, and, you know, these people had no 

9 monitors. There was no contamination surveys. 

10 No way to really tell if people contaminated. 

11 And, you know, the idea was, well, 

12 if they were contaminated and took a shower did 

13 it clean it off or not, or should we assign this 

14 for 250 days and sort of 24 hours a day kind of 

15 thing.

16 DR. OSTROW: Right.

17 DR. NETON: And again it's been our 

18 experience that uranium's fairly readily 

19 washed off with soap and water. The Los Alamos 

20 study seems to indicate that. So I'm not sure 

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33

1 where to go from here other than sort of provide 

2 the weight of the evidence that we have.

3 DR. OSTROW: Okay, thank you.

4 DR. NETON: I think we should look 

5 at it.

6 CHAIR MUNN: Probably wise. My 

7 guess would be that the Idaho workers like in 

8 most complexes, certainly in later years, were 

9 receiving hand and foot monitoring frequently 

10 throughout the day when they were in 

11 contaminated areas.

12 And I don't know that it was a common 

13 practice to record quantitatively what was 

14 happening on site as they came out, but they 

15 were usually monitored very carefully, I think. 

16 We'll look forward to that paper.

17 One comment that I neglected to make 

18 before we started was the fact that those of you 

19 who may have taken a look at the transcript from 

20 last time may be aware of the fact that we seem 

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34

1 to have dropped our conversational tones, our 

2 pace, at some juncture fairly frequently during 

3 our last meeting so that the transcriptionist 

4 had a hard time picking up our full comments.

5 It's something that's easy to 

6 forget because we get so conversational on 

7 these sessions. It is wise to remind ourselves 

8 from time to time, we do need to be very careful 

9 in our articulation as we are speaking if we 

10 want to rely on the transcripts later for 

11 accurate information about what was actually 

12 said and what we discussed.

13 Having said that we are on to 

14 PER-0031, a carryover from last time. Do we 

15 have a report from NIOSH?

16 MR. HINNEFELD: Yes, this is Stu. 

17 To be honest, I've been trying to figure out 

18 exactly what instructions we've given to our 

19 contractor on that. And because the issue, I 

20 think, in front of us, this is the Y-12 PER, and 

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35

1 that PER was written because of some other 

2 changes, some changes were made to the Site

3 Profile.

4 But in reviewing the PER, SC&A 

5 pointed out that hey, you know, this Site 

6 Profile says that you're going to do thorium 

7 internal dose assessment based on in vivo 

8 monitoring after some year, and they used 

9 essentially the same in vivo monitoring 

10 technology that Fernald did.

11 They reported results in milligrams 

12 the way Fernald did, and at Fernald we 

13 determined that you couldn't really interpret 

14 those readings. So how does that, you know, 

15 what effect does that have on Y-12? 

16 And so the effort has to be put into this 

17 so it really becomes a Y-12 Site Profile issue 

18 that we intend to pursue. And I'm just trying 

19 to figure out now, you know, how far along or 

20 have we even gone very far down this path at all 

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36

1 in terms of determining what might be possible.

2 We do know that they have a lot of 

3 air monitoring data from Y-12, a quite a bit of 

4 it which we think is thorium air monitoring data 

5 for the period in question. And so there might 

6 be techniques other than in vivo if in fact we 

7 decide the in vivo isn't appropriate. There 

8 may be a way to determine the in vivo monitoring 

9 is appropriate and maybe you can interpret 

10 those results. So I don't think we're very far 

11 down that path but we intend to go down that 

12 path.

13 So, but with respect to the actual 

14 PER-0031, you know, it would be okay for the 

15 Subcommittee and SC&A to finish reviewing 

16 PER-0031 with respect to seeing was this PER 

17 done correctly, meaning were the changes that 

18 were incorporated into the Y-12 Site Profile, 

19 were those adequately considered when, were 

20 cases adequately reconsidered as a result of 

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37

1 those changes?

2 So I mean it would be feasible if the 

3 Subcommittee wanted to proceed with PER-0031, 

4 you know, either worry about these findings 

5 later or transfer them to Y-12 Work Group and 

6 finish the PER-0031 work essentially, and, you 

7 know, if that were what you wanted to do. 

8 Alternative thought is depending on 

9 how this works out, there could be another PER 

10 for Y-12 and maybe we'll just take a look at 

11 claims at that point.

12 CHAIR MUNN: Now you've confused 

13 me, Stu.

14 MR. HINNEFELD: Well, the PER-0031 

15 was written for a specific purpose. I haven't 

16 prepared myself very well or I'd know what that 

17 was. And that, you know, PER-0031, the reason 

18 it was written had nothing to do with in vivo 

19 monitoring. It was some other change that was 

20 made.

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38

1 CHAIR MUNN: Do we have any 

2 knowledge of what that change was?

3 MR. HINNEFELD: Yes, I'm looking 

4 for it. Here, hang on just a minute.

5 DR. MAURO: Wanda, this is John. I 

6 might be able to help a little bit out with 

7 regard to what, we've encountered the 

8 circumstance in the past. That is, everything 

9 we do is a living process, whether it's a Site 

10 Profile Review or it's a PER review.

11 And what we have now on the record 

12 is a PER review based on certain activities that 

13 took place and changes to the Site Profile, the 

14 procedures that took place up to that point in 

15 time, and of course SC&A then reviewed the PER 

16 with respect to that.

17 As life goes on, we always find that 

18 maybe things change again. In the past it's 

19 been our position that we just keep grinding. 

20 That is, yes, we have a PER that's been 

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39

1 reviewed. We have comments.

2 The fact that there's a new round of 

3 possible PERs that may emerge that we'll deal 

4 with that when that happens, but let's grind 

5 through and put to bed the ones that we have 

6 before us now. That's how we've handled it 

7 before. That doesn’t mean we have to continue 

8 in that mode.

9 CHAIR MUNN: Thank you, John.

10 MR. HINNEFELD: Yes, this is Stu. 

11 Wanda, this is Stu. And I guess I spoke naively 

12 a while ago. This PER was actually performed 

13 because there was, you know, the technical 

14 documentation was changed to change the 

15 equilibrium ratio for a couple thorium 

16 isotopes, thorium 228 to 232, and that was 

17 changed from 100 percent to 80 percent 

18 assumption, and so that would raise certain 

19 doses. And because of that we did the PER, so 

20 it was an in vivo PER.

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40

1 But the additional question of can 

2 this even be interpreted at all, that's really 

3 a Site Profile question rather than a PER 

4 question.

5 DR. BUCHANAN: Yes, this is Ron 

6 Buchanan with SC&A, and that's correct. 

7 PER-0031 was issued because of the change in 

8 ratio of equilibrium, and I'm the one that did 

9 the review and the finding on that. And so Stu 

10 is right that that is, the end result was that 

11 we found that this then actually decreased the 

12 dose if you applied it strictly the way the PER 

13 stated it and the TBD stated it.

14 And so we questioned, you know, 

15 whether we could even use this data. And so Stu 

16 went back and said, okay, we're going to need 

17 to look at this and see if we can, because it 

18 was a problem at Fernald and it's the same model 

19 as Fernald used.

20 Basically, I looked and seen I did 

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41

1 carry through with a PER then to see if it was 

2 done correctly, on the other hand, and I found 

3 that the dose -- I'd have to go back. I didn't 

4 look for stuff this morning, all the doses I 

5 looked at, all the cases.

6 But the cases I looked at is that it 

7 was not applied uniformly. This 80 to 100 

8 change was not applied uniformly then in the new 

9 DR. So when we ran into the fact that this was 

10 maybe not the way to do dose reconstructions or 

11 it needed some attention, I think that kind of 

12 stalled that progress of saying okay, even 

13 though we had this revision in the TBD it's not 

14 being applied uniformly, and so that's where it 

15 kind of stands at this point.

16 MR. KATZ: So this is Ted. I think 

17 what I would suggest, Stu, since we don't have 

18 an active Y-12 Work Group, I realize there was 

19 one once upon a time --

20 CHAIR MUNN: Yes, but --

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42

1 MR. KATZ: Yes, exactly. But 

2 since we don't have one active now, I mean I 

3 don't see any reason why we can't just move 

4 forward this under the PER process.

5 CHAIR MUNN: It seems most 

6 expedient to me, especially in light of the 

7 current status of Work Groups for Y-12. I 

8 would hate to see this languish any longer on 

9 the vine, and it seems to me that we are the 

10 logical venue at this point to address it.

11 MR. KATZ: Right. If we had a Work 

12 Group we'd shift it over to them, but since we 

13 don't it just seems like it'll be fine. You 

14 have good representation on this Work Group. I 

15 think you can grind through the issue with the 

16 Subcommittee.

17 CHAIR MUNN: I certainly agree with 

18 that interpretation.

19 Paul, any feedback from you and 

20 Josie?

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43

1 MEMBER ZIEMER: Well, (telephonic 

2 interference).

3 CHAIR MUNN: You're breaking up for 

4 me, Paul. I don't know if you are for others.

5 MEMBER ZIEMER: I was on speaker 

6 and maybe it, I'm getting an echo. I hear 

7 myself. In any event --

8 CHAIR MUNN: That's much better, 

9 thank you.

10 MEMBER ZIEMER: -- I just wanted 

11 to ask a question. This doesn't apply just to 

12 Y-12 though does it?

13 MR. HINNEFELD: Yes, this is Stu. 

14 The question, well, it would apply where --

15 anyplace in vivo results are reported in 

16 milligrams rather than in the activity of the 

17 various isotopes that are being --

18 MEMBER ZIEMER: Right.

19 MR. HINNEFELD: -- added. So the 

20 question arose at Fernald and was actually the 

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44

1 basis for an SEC Class up through roughly '78 

2 for about a ten-year period when the in vivo, 

3 when they used the mobile counter. Now Y-12 

4 didn't use the mobile counter but they used the 

5 same type of system and the same reporting.

6 So anyplace where in vivo counting 

7 was reported in units of milligrams rather than 

8 activity of the radionuclides being counted, 

9 you're going to face this question, is this data 

10 interpretable.

11 But I don't know of any place other 

12 than Y-12 and Fernald where there was thorium 

13 exposure that was measured by in vivo. 

14 Certainly the mobile counter went to the 

15 gaseous diffusion plants, but I don't believe 

16 there was thorium exposure at those plants.

17 CHAIR MUNN: Well, I'm beginning to 

18 remember a little bit about the original review 

19 of this PER now. And that's helpful to know 

20 that it wasn't just Y-12, because it helps us 

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45

1 to see that it's not truly site specific.

2 MR. HINNEFELD: Yes, I don't think 

3 I've encountered this reporting at anyplace, 

4 you know, for thorium exposure other than at 

5 Y-12 and Fernald.

6 CHAIR MUNN: Well, in any case, 

7 does that answer your question, Paul?

8 MEMBER ZIEMER: Yes. I think we 

9 could just proceed within the committee here.

10 CHAIR MUNN: Yes.

11 MEMBER BEACH: So Wanda, this is 

12 Josie.

13 CHAIR MUNN: Yes.

14 MEMBER BEACH: I have a comment and 

15 question. So I agree that we should proceed 

16 with this finding, but my question is kind of 

17 an overall. Y-12 has a couple other OTIBs that 

18 have been reworked and reissued recently. I 

19 think the last one I looked at was 0064. 

20 And if we take on this one issue, 

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46

1 what happens to these other TBDs that have been 

2 updated that haven't been looked at? I guess 

3 this is probably a Ted question.

4 MR. KATZ: Right. Well, at some 

5 point, Josie, I mean we'll assign other, I mean, 

6 you know, TBDs are getting updated for 

7 different sites all the time.

8 MEMBER BEACH: Right.

9 MR. KATZ: So at some point we'll 

10 have more assignments to review new versions or 

11 new TBDs. But that has to be done first and 

12 SC&A then would then have to do its work first.

13 MEMBER BEACH: Right. Okay.

14 CHAIR MUNN: All right, any other 

15 questions, Josie?

16 MEMBER BEACH: No.

17 CHAIR MUNN: Okay, it sounds to me 

18 as though we have a general consensus that we 

19 need to address the PER-0031 issues here in the 

20 Procedures Subcommittee. Not having heard any 

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47

1 comment to the contrary, we will proceed with 

2 that, I think, appropriately.

3 This means from my perspective that 

4 we will anticipate feedback from NIOSH on each 

5 of the findings that we have next time. Is that 

6 appropriate, Stu? I hate to make that 

7 statement without a commitment from you.

8 MR. HINNEFELD: Well, we don’t have 

9 feedback on all these findings. I can't 

10 promise next time.

11 CHAIR MUNN: Okay, we'll carry it 

12 over and question it next time.

13 MR. HINNEFELD: Yes, right.

14 CHAIR MUNN: All right, fine. And 

15 then let's move on to the summary clarification 

16 of the IG-001 Finding.

17 NIOSH?

18 MR. HINNEFELD: Yes, this is us 

19 again, Stu, one more time. I don't know, 

20 Steve, can you maybe pull this up? We'll maybe 

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48

1 look at what the finding is? I don't know if 

2 that's going to matter or not though.

3 The issue here, just to refresh 

4 everyone's memory, is that IG-001 has a 

5 paragraph and has a section that's kind of 

6 disjointedly written but the information's in 

7 there.

8 And it has this, the section refers 

9 to dose correction factors as a function of the 

10 geometry whether it's AP rotational or 

11 isotropic geometry, et cetera. For most 

12 organs, AP geometry is the most favorable and 

13 so it's appropriate to default to AP.

14 There are, I think, four target 

15 organs, blood surface, blood bone marrow, bone 

16 surface, bone marrow, I think it's lung and

17 esophagus for which AP is not more favorable 

18 than say rotational which seems like that could 

19 be a likely one in some kinds of jobs, or 

20 isotropic which seems like that might be a 

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49

1 little less likely.

2 And so there's a statement in there 

3 that says that since, for these four target 

4 organs, one of these other geometries is more 

5 favorable you should default to those unless 

6 you have a reason to use AP. If you think a 

7 person's job would be such that they were 

8 probably exposed in AP geometry most often, 

9 then you can use AP.

10 And so from that I think it's a 

11 logical conclusion that says that if you 

12 choose, you know, since there's a default 

13 that's, say, rotational and if you choose to use 

14 AP in your dose reconstruction you should 

15 explain that you chose to use that and why. And 

16 that's what's being done now, but it wasn't done 

17 for a while.

18 And so the question in front of us 

19 is, there are two questions in front of us. 

20 First of all, do we think the wording in IG-001 

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50

1 is okay as it is, and the answer to that question 

2 in my opinion is yes. It pretty much says what 

3 we want it to say.

4 And the second question is are we 

5 going to go back and do a PER or a PER-like look 

6 at cases that were done previously before we 

7 overtly started making dose reconstructors say 

8 yes, this should be an AP case and here's why, 

9 because that wasn't done originally. 

10 Should we go back and look at those cases 

11 that were done beforehand and say is AP in fact 

12 the appropriate one to select there if the dose 

13 reconstructor used AP.

14 So we do think we do have that 

15 look-back work to do, and it would be our 

16 preference though to do that in conjunction 

17 with a PER that we know is coming having to do 

18 with the new ICRP, I think it's 116, 

19 recommendations for dose conversion factors. 

20 That document’s been out for a 

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51

1 little while. We've done some comparisons of 

2 what would be done, you know, having the ICRP, 

3 dose conversion factors compared to the 

4 previously published ones that we're using now. 

5 There will be quite a number of changes. Some 

6 organs will go up, some organs will go down.

7 So it looks like we're going to have 

8 to do a relatively large PER to incorporate the 

9 new dose conversion factors from ICRP 116. And 

10 so it would be our view that the best time to 

11 take care of this PER-like activity from this 

12 IG-001 statement would be when we have to do 

13 that whole wrap-up anyway or that whole look 

14 from ICRP 116.

15 So that's kind of where we are on our 

16 position on this. I don't think I have entered 

17 that into the BRS yet, but I think we can 

18 probably do that.

19 CHAIR MUNN: Yes.

20 MEMBER ZIEMER: This is Ziemer. I 

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52

1 thought what happened last time were that NIOSH 

2 indicated that they didn't feel there was any 

3 need to revise it, just that they would have a 

4 response to the IG --

5 CHAIR MUNN: That was my 

6 expectation. I thought we were going to have 

7 --

8 MEMBER ZIEMER: But he just 

9 described it. I thought we had actually put it 

10 to bed and were going to do what Stu just 

11 described.

12 CHAIR MUNN: Yes. What I had 

13 expected was a paragraph clarifying the wording 

14 and essentially saying what Stu just said. I 

15 think if memory serves, I can't remember for 

16 sure, I think we expected last time that we 

17 would have a small written paper so that we 

18 could just reference that in the BRS.

19 But is that your understanding, 

20 Josie?

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53

1 MEMBER BEACH: Yes, absolutely. 

2 NIOSH had the action just to add wording to 

3 indicate the process.

4 CHAIR MUNN: I thought we were just 

5 going to have a summary, just a paragraph 

6 summary.

7 MR. HINNEFELD: Well, I apologize 

8 for not getting that done before the meeting, 

9 but I'll get it done shortly after, today.

10 CHAIR MUNN: Okay, good. If you do 

11 that then I think, certainly my understanding 

12 is we don't have any firm knowledge of when 

13 we're going to have to address the ICRP 116 

14 issues and it would be much nicer if we could 

15 get this one off the books and look forward to 

16 what's coming down the pike when it comes down 

17 the pike instead of holding this in abeyance.

18 Good. If you'll get us a very brief 

19 summary, it doesn't have to say much more than 

20 what you just said, I think that will satisfy 

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54

1 this Subcommittee and we'll look for that next 

2 time.

3 MR. HINNEFELD: All right, thank 

4 you.

5 CHAIR MUNN: Okay. And don't go 

6 away, we still have you on deck for the Weibull 

7 distribution criteria. We were going to hear 

8 something about that that would hopefully close 

9 that for us this time.

10 MR. HINNEFELD: Yes, I'm going to 

11 volley that one over to Jim also.

12 CHAIR MUNN: Okay.

13 DR. NETON: Okay. Thanks, Stu. 

14 This is not really a finding anywhere from the 

15 Subcommittee, and I forgot exactly how it came 

16 up. But I believe it just arose in discussions 

17 during the last Procedures Subcommittee 

18 meeting.

19 CHAIR MUNN: Yes, before that 

20 actually. We addressed it during the last --

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55

1 (Simultaneous speaking)

2 DR. NETON: Sort of surprised to 

3 see us using the Weibull distribution, and then 

4 we had a general conversation about when did we 

5 start using it, why are we using it and how do 

6 we decide which distribution --

7 CHAIR MUNN: Yes, that's correct, 

8 Jim. The question as I recall was raised, I 

9 believe, at our February meeting, and then 

10 there was some discussion about it in our April 

11 meeting. At that time, I believe that we 

12 committed to providing a brief written criteria 

13 so that SC&A could sort of mull that over.

14 DR. NETON: And we've done that. 

15 The Subcommittee should have received, I think 

16 from Lori, a paper that was written by Daniel 

17 Stancescu our staff statistician. It's titled 

18 "Fitting Distributions to Dose Data."

19 CHAIR MUNN: Yes.

20 DR. NETON: And it's a short paper 

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56

1 that tries to address the issues I just 

2 mentioned that, you know, how do we determine 

3 what's the best fit for a distribution that 

4 we're going to use? Why do we use that 

5 criteria?

6 And it goes through, I think it's a 

7 nice little write-up about the different types 

8 of statistical tests that are out there and why 

9 we've chose to go with these more modern 

10 approaches that evaluate the information 

11 criteria.

12 CHAIR MUNN: It is a good paper, and 

13 specifically --

14 DR. NETON: Actually, you know, it 

15 discusses why we use, I believe it's Akaike 

16 Information Criteria as our test statistics. 

17 So that's covered.

18 And then it goes on to specifically 

19 talk about the Weibull distribution and how we 

20 came to use it during the development of the CLL 

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57

1 Probability Model. A lot of those 

2 distributions that we used from the literature 

3 were Weibull distributions so we were sort of 

4 forced into it.

5 But once a distribution was 

6 available, and it is now one of the eight 

7 distribution types that can be selected as an 

8 IREP input, it's out there and it has been used 

9 in some other instances other than CLL fitting.

10 And primarily it's used in the 

11 fitting of external dosimetry data. For 

12 example, when you have a badge result that has 

13 an uncertainty associated with it that's 

14 normally distributed, like plus or minus 20 

15 percent, and then I always fold in some dose 

16 conversion factor, for example, DCF for 

17 conversion of that badge reading to the dose to 

18 the liver.

19 And those distributions, the dose 

20 conversion factors tend to be distributions 

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58

1 that are triangular in nature and have some 

2 unique shapes to them.

3 Well, when you use Monte Carlo 

4 techniques and you fold in a normal 

5 distribution with the triangular, you end up 

6 with a hyper-distribution that doesn't often 

7 fit the normal or log-normal distribution very 

8 well.

9 And we've found from experience 

10 that the Weibull distribution accommodates 

11 those fits better. It tends to be a little bit 

12 of a chameleon. You can go through and read the 

13 paper, but there are three factors that can be 

14 used to modify the Weibull distribution, the 

15 shape, scale and location. And as 

16 indicated in Figure 2 of Daniel's paper, it 

17 shows you the range and types of distributions 

18 that could be generated. And when the Weibull 

19 is used and compared to a log-normal, then we 

20 would use that AIC criterion to determine which 

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59

1 is the best fit based on just a numerical value 

2 that is generated using that technique, using 

3 the AIC test.

4 So it's there in a nutshell. I know 

5 it came out fairly late. Even though it was 

6 written in May, I didn't get it distributed 

7 until fairly recently.

8 I will say that the version that was 

9 distributed to the Subcommittee says that it 

10 may have Privacy Act information. Of course 

11 there is none in there. I just didn't get a 

12 chance to have it formally cleared before it got 

13 distributed. It has since been reviewed and 

14 that footnote has now been modified to say that 

15 it's been cleared for review for Privacy Act 

16 issues and it's cleared for distribution.

17 That version is out there on the 

18 website under the Board's meeting, today's 

19 meeting. It went out there yesterday morning, 

20 I believe, or this morning. I forgot. But 

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60

1 it's out there, I checked this morning.

2 So that's a brief summary of what's 

3 there. I know people haven't had a chance to 

4 read it, but I think it covers the issues that 

5 we were asked to describe fairly well.

6 CHAIR MUNN: It does indeed, and 

7 thank you very much for that Jim. And I have 

8 certainly had an opportunity to read it, and I 

9 suspect that our other Board Members have as 

10 well since we did get it time to peruse it and 

11 it's well written.

12 Thanks to Dr. Stancescu for having 

13 compiled this, because even the lay 

14 statistician can follow it quite well and it's 

15 appreciated.

16 Any questions or comments from SC&A 

17 or from any of the Board Members with respect 

18 to the fitting distributions to dose data?

19 DR. FARVER: Wanda, this is Doug 

20 Farver.

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61

1 CHAIR MUNN: Yes, Doug.

2 DR. FARVER: I just have a 

3 question, and I really have no questions about 

4 the paper itself. It was an explanation of the 

5 distribution and that's fine. Mine is more 

6 practical.

7 On the IREP table you have a list of 

8 Parameters 1, 2, and Parameters 3, and that is 

9 how they determine a dose, or one of those or 

10 more of those values determine the dose. For 

11 example, for a normal distribution the dose is 

12 under Parameter 1. For triangular, the dose is 

13 under Parameter 2. Now for the Weibull it 

14 appears that it's the sum of Parameter 2 and 3. 

15 Is that true?

16 DR. NETON: I'm not sure what 

17 you're asking, Doug. If you select Weibull, 

18 there's always three boxes to fill in. And 

19 what you fill in will be determined based on 

20 what distribution you selected.

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62

1 DR. FARVER: Right. I mean when 

2 you look at the IREP table that you, the final 

3 one that goes into the IREP program.

4 DR. NETON: Okay.

5 DR. FARVER: Okay. At the very 

6 right hand side it lists a Parameter 1, a 

7 Parameter 2 and a Parameter 3.

8 DR. NETON: Right.

9 DR. FARVER: When there's a normal 

10 distribution Parameter 1 has the dose value.

11 DR. NETON: And Parameter 2 should 

12 have the uncertainty.

13 DR. FARVER: Correct. And when 

14 there’s a triangular distribution Parameter 2 

15 has the dose value. Now for the Weibull 

16 distribution it looks like the dose is the sum 

17 of Parameter 2 and Parameter 3. That's what’s 

18 used to total the dose. Is that true?

19 DR. NETON: Well, Daniel's on the 

20 phone. Daniel, can you help me out there? I'm 

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63

1 not sure.

2 MR. STANCESCU: Yes, this is Daniel 

3 Stancescu from NIOSH. So the three parameters 

4 that you see is equal parameters for the Weibull 

5 distribution in IREP. The first one 

6 corresponds to the shape. The second one 

7 corresponds to the scale, and the third one 

8 corresponds to the location.

9 If the Weibull distribution, unlike 

10 the normal and log-normal distribution, it has 

11 a different formula to compute the mean. The 

12 mean of the Weibull distribution is a function 

13 of the shape, scale and location. So it's not 

14 as easily calculated as for the normal.

15 So for the normal, the mean is the 

16 first parameter. For the log-normal, you 

17 know, the geometric mean is the median. For 

18 the Weibull you can compute the mean. There is 

19 a formula which involves these three 

20 parameters. So we don't have a parameter for 

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64

1 the mean of the Weibull distribution.

2 DR. FARVER: No, I understand. 

3 I'm asking you how you determine the dose. 

4 Which parameter?

5 MR. STANCESCU: You mean which of 

6 these parameter is the most significant 

7 corresponding to the mean of the distribution?

8 DR. FARVER: No, which value equals 

9 the dose for a given year? Like 1963, photon 

10 dose, external. There's got to be a dose value 

11 in that IREP table.

12 MR. SIEBERT: I'm sorry, let me 

13 interrupt. This is Scott Siebert from ORAU 

14 Team. I think what Doug is referring more to 

15 is not necessarily the dose because the dose is 

16 actually the full distribution.

17 But Doug, you're actually referring 

18 to the dose as we refer to it in a dose 

19 reconstruction report, correct?

20 DR. FARVER: Yes.

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65

1 MR. SIEBERT: Okay, and I think 

2 that's the basis of the confusion on the 

3 question. When it comes to the report, as 

4 Daniel said, there is no simple way to calculate 

5 the mean for each of the years so that we could 

6 report the mean for the dose for each of those 

7 years.

8 So you are correct. What we have 

9 done as a reporting consideration is to add 

10 Parameter 2 and Parameter 3 which gets us in the 

11 same general location as the mean. It's not 

12 exact, if I recall correctly, but it's in the 

13 same general location as where you would have 

14 the mean.

15 That's what we were trying to create 

16 for a reporting scheme, rather than having 

17 someone have to use all three parameters for the 

18 Weibull distribution, calculate the actual 

19 mean which you could never directly get from the 

20 IREP sheet. Whereas, the approximation of 

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66

1 Parameter 2 and Parameter 3 got us into the 

2 right location so you're using that as the 

3 reported dose for the reports.

4 DR. FARVER: Okay, but it's the sum 

5 of 2 and 3?

6 MR. SIEBERT: Yes, that is correct.

7 MR. STANCESCU: Okay, and if I can 

8 mention here, the reason. So it is the sum of 

9 Parameters 2 and 3 which is the scale and the 

10 location and it can be proved theoretically 

11 that the sum of the scale and location for a 

12 Weibull distribution is equal to the 63rd 

13 percentile of the distribution.

14 So it's kind of close to the mean 

15 value, somewhat so, and that was an easy way to 

16 report a value that is kind of representative 

17 for the distribution.

18 DR. FARVER: Okay. And Parameter 

19 3 can be both positive or negative?

20 MR. STANCESCU: Yes, that's 

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67

1 correct.

2 DR. MAURO: This is John Mauro. 

3 Again from a practical standpoint, so if I'm 

4 filling out the IREP input table and they’re all 

5 line items, and let's say I'm doing the external 

6 dose to some organs, and somehow to get to that 

7 external dose the Weibull distribution was used 

8 because it's a combination of, let's say, some 

9 film badge data combined with some triangular 

10 which might be log-normal and some other data, 

11 like the dose conversion factor, which is 

12 triangular, and the two of course are 

13 multiplied together and then the outcome is 

14 some distribution. Now that's a Weibull 

15 distribution as I understand that is the 

16 selection now because it's an improvement on 

17 the fit.

18 Now in the input to IREP I will put 

19 in the word "Weibull" as the distribution that 

20 applies. I haven't done this but I'm assuming 

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68

1 this is the case. Then to the right of that 

2 there will be columns that will open up that 

3 might be Parameter 1, 2 and 3 as described 

4 earlier.

5 Now somehow those parameters have, 

6 there's some very specific instructions what 

7 you put in under what would be called Parameter 

8 1, 2 and 3. There's some number that has to go 

9 in there.

10 And unlike what we used to do where 

11 we would put in the geometric mean in the first 

12 one, or we'd put in the arithmetic mean and then 

13 next to that we would put in the geometric 

14 standard deviation if we're dealing with 

15 log-normal, here you're saying that what we 

16 actually put into the boxes to the right of 

17 where we say Weibull, there's some other things 

18 we put in.

19 Is that all straightforward now? I 

20 mean in other words are the instructions on how 

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69

1 to load the input to IREP straightforward so 

2 that we do it right and we don't put the wrong 

3 numbers in those boxes?

4 MR. STANCESCU: I think it is. If 

5 you go to the IREP website and if you try to 

6 enter the doses, if you click on the menu it's 

7 going to show you the order of the parameters 

8 for each of the distributions. So, for 

9 example, for triangular the order is the 

10 minimum more than the maximum.

11 DR. MAURO: Right. And we 

12 understand that so, you know, we've learned to 

13 do that.

14 MR. STANCESCU: Yes, and for the 

15 Weibull it showed that the first one is going 

16 to be the shape, the second is the scale, and 

17 the third one is the location.

18 DR. MAURO: Bingo. That's what I 

19 was looking for. Thank you.

20 MR. STANCESCU: Yes.

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70

1 DR. MAURO: Good, you've answered 

2 my question.

3 MR. STANCESCU: Okay.

4 DR. FARVER: Okay, this is Doug 

5 again. I've just got a couple more just, and 

6 the reason I have these questions is we were 

7 having difficulty matching the NIOSH number, 

8 and so we were scratching our heads a little.

9 For CLL cancers, Parameter 3 seems 

10 to be much larger when compared to Parameter 2. 

11 And I've only seen positive numbers for that. 

12 Is that just coincidence or --

13 DR. NETON: This is Jim. I can't 

14 exactly speak from experience in looking at 

15 those parameters recently, but yes, I would 

16 assume it's just the way the --

17 DR. FARVER: Okay.

18 DR. NETON: The way the fit works 

19 out for the CLL cases. They tend to be a little 

20 bit different because of the various 

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71

1 distributions that, you know, there's a lot of 

2 distributions that are combined to get that 

3 final product.

4 DR. FARVER: Okay. But the 

5 Parameter 3 seems to be more significant. 

6 Because if we excluded Parameter 3 and just 

7 added up Parameter 2, much farther off from the 

8 NIOSH value. So it seems more significant. I 

9 don't know if that's true or not.

10 DR. NETON: Well, in what's the 

11 third parameter's location?

12 DR. FARVER: Yes.

13 DR. NETON: Yes. Well, I'm 

14 assuming the location, you know, the tripping 

15 of that curve on the X-axis is significantly 

16 different for CLL cases.

17 And remember, CLL cases are very 

18 different than the ones you would see for 

19 external dose calculation. I mean you're just 

20 folding in a triangular and a normal. In CLL 

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72

1 you're folding in a lot of distributions.

2 So the shape of, that's one thing 

3 about the Weibull is it can have a lot of 

4 different shapes and locations on the curve. 

5 So I think that's all you're seeing is an 

6 artifact of the CLL model itself.

7 DR. FARVER: Okay. One final 

8 question. Scott, is there any instructions 

9 given to the dose reconstructors along these 

10 lines about so they can check their work?

11 MR. SIEBERT: There's does not need 

12 to be because Weibull is only used in best 

13 estimate claims where the tool creates the fit 

14 and the tool directly imports that information 

15 into IREP.

16 The dose reconstructor never had 

17 the option to pick a Weibull distribution 

18 because it's not a general distribution to use 

19 unless it's coming out of a best estimate Monte 

20 Carlo calculation.

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73

1 DR. FARVER: Okay, and we'll never 

2 go in and sum up his doses just to make sure his 

3 numbers match?

4 MR. SIEBERT: Oh, you're talking 

5 about for summing the dose. We have tools that 

6 do that for us so the dose reconstructor doesn't 

7 have to go by hand and do the addition.

8 DR. FARVER: Okay. We've run into 

9 situations before where there have been doses 

10 omitted and it'd be better if they went and 

11 checked the final doses. That's a suggestion. 

12 But I understand what you're saying.

13 Okay, my main concern was that 

14 Parameter 2 and Parameter 3 are totaled up to 

15 give the dose. So that's good. Thank you.

16 CHAIR MUNN: Any other questions or 

17 comments?

18 DR. CHMELYNSKI: Yes, this is Harry 

19 Chmelynski from SC&A. From what I had just 

20 heard in a discussion, the Weibull is only being 

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74

1 used internally to model results of simulation 

2 programs, and generally when you do that you 

3 don't have non-detects.

4 I was wondering, is it also used 

5 anywhere to fit data where you have 

6 non-detects?

7 DR. NETON: This is Jim. I don't 

8 know offhand if we've done that. Does anyone, 

9 Scott or Daniel?

10 MR. STANCESCU: I'm not sure how 

11 it's used in practice. I know that ORAU is 

12 using the VOS Tool and I think the Weibull can 

13 feed the data with the sensor values. But I'm 

14 not sure if this was used in practice. If 

15 somebody is familiar with the VOS Tool maybe 

16 might know this answer.

17 MR. SIEBERT: Well, this is Scott. 

18 My understanding is the fact that we are only 

19 using this for the combination of different 

20 distributions that are already set, and in 

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75

1 combining those distributions we're not using 

2 the Weibull, as far as I understand, to fit any 

3 raw data which would include detects and 

4 non-detects.

5 It would be multiplying a 

6 triangular distribution by a log-normal 

7 distribution by a normal distribution by those 

8 weird distributions that are in CLL, not 

9 actually fitting back to the raw data. Is that 

10 your concern?

11 DR. CHMELYNSKI: Okay, that 

12 answers my question then. If we're not going 

13 to have non-detects it's not a problem.

14 DR. NETON: Okay. Yes, because I 

15 can't think of any coworker model we've ever 

16 developed that's anything other than a normal 

17 distribution, if that's what you're getting at 

18 maybe. I mean a log-normal distribution. 

19 Okay.

20 CHAIR MUNN: Any other thoughts or 

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76

1 comments?

2 MEMBER ZIEMER: Hi, this is Ziemer. 

3 I sort of followed the logic here, and, you 

4 know, the statistics are beyond my capacity. 

5 But I just want to ask what action do we need 

6 to take as a Subcommittee, if any?

7 CHAIR MUNN: I didn't believe that 

8 we had any action. I thought we were 

9 attempting to satisfy SC&A's curiosity about 

10 why the Weibull distribution was used and how 

11 it is used.

12 And it was my understanding that if 

13 this discussion met the criteria of the 

14 original questioners that we had no further 

15 work to do.

16 MEMBER ZIEMER: Okay.

17 CHAIR MUNN: Am I incorrect in 

18 that, SC&A?

19 I don't hear any.

20 MR. KATZ: This is Ted. I'm not 

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77

1 SC&A, but that is correct. This was raised by 

2 SC&A for reasons that have been talked about, 

3 and if there is no further issue then you're 

4 finished with it.

5 CHAIR MUNN: Yes, that was my 

6 expectation. Is that correct for you, Paul?

7 MEMBER ZIEMER: Yes. I didn't 

8 know that we had to take any specific action. 

9 I guess we have to confirm that SC&A is 

10 comfortable with this.

11 CHAIR MUNN: Yes, and that's --

12 MEMBER ZIEMER: I think as I 

13 understand the discussion, it appears that SC&A 

14 is okay on this. Is that correct? I don't 

15 want to presume it.

16 CHAIR MUNN: I don't know, but I 

17 don't think we can presume it. Is there anyone 

18 on the call from the original questioning group 

19 that has any further concern, or can we assume 

20 that your concerns have been adequately 

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78

1 addressed?

2 DR. FARVER: This is Doug, Wanda.

3 CHAIR MUNN: Yes, Doug.

4 DR. FARVER: They addressed my 

5 concerns about, you know, what parameters were 

6 used, so now we can move on with that. I'm a 

7 little concerned that the distribution is not 

8 mentioned anywhere in their technical 

9 documents or in their TBDs.

10 And I don't know if that'll cause 

11 conflicts later on such as they might have it 

12 written in their TBD where it says you'll use 

13 a normal distribution and add in, you know, 

14 geometric -- for deviation. I'm not sure if 

15 there will conflicts with that later on.

16 But I'm okay, since I believe we 

17 brought up the original question about what's 

18 it doing here, why is it being used and how is 

19 it being used was the big thing. So I 

20 understand it from a dose reconstructor's point 

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79

1 of view.

2 CHAIR MUNN: Thank you, Doug. My 

3 question to NIOSH then is do we have any 

4 internal documents, workbooks, anything of 

5 that sort that help address the concern here?

6 DR. NETON: This is Jim. I don't 

7 know what internal workbooks it would be. I 

8 mean there are eight separate distributions 

9 that are listed in the IREP input line for dose 

10 inputs.

11 There's triangular, log uniform, 

12 uniform, constant, I mean they're all there. I 

13 think when we do use a particular distribution 

14 it is discussed and documented as such, such as 

15 in the CLL model. So I don't know where else 

16 we would document use of it other than when we 

17 do use it. You know what I'm saying?

18 CHAIR MUNN: Yes, we certainly 

19 don't. But is that comfortable for you, Doug?

20 I'm not hearing a response. Are 

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80

1 you muted, Doug?

2 MEMBER ZIEMER: While Doug is 

3 trying to get off mute, this is Ziemer again. 

4 Will the White Paper itself, that is, the 

5 putting distributions to dose data, will that 

6 be attached to any of our documents in the 

7 database?

8 CHAIR MUNN: You know, I'm not sure 

9 exactly what we could attach it to --

10 MEMBER ZIEMER: Well, that's why 

11 I'm asking.

12 CHAIR MUNN: -- Paul.

13 MEMBER ZIEMER: It didn't arise in 

14 connection with a particular finding then.

15 CHAIR MUNN: No, it did not. It 

16 was a general question from the contractor, and 

17 I wouldn't know where we would logically do 

18 that. It is a part of the permanent record now, 

19 having been posted online so that it's easily 

20 referenceable by anyone who has a concern.

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81

1 And from my perspective, being a 

2 part of the public record should be adequate for 

3 it since it is not connected to a specific 

4 finding that we were addressing in Committee. 

5 Does anyone have feelings otherwise 

6 with regard to this very nicely done paper?

7 DR. BUCHANAN: This is Ron 

8 Buchanan. Where can we find this paper?

9 CHAIR MUNN: You can find it --

10 DR. BUCHANAN: I'm not looking at 

11 my screen now, but where is it located?

12 CHAIR MUNN: It's online under 

13 today's agenda in the Office of Compensation 

14 Analysis website.

15 DR. BUCHANAN: Okay, thank you.

16 CHAIR MUNN: Yes.

17 MEMBER ZIEMER: Well, that being 

18 the case, I think we've satisfied SC&A's 

19 concern and the document is available. I don't 

20 know that we need an action, but I think that 

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82

1 we have closed the item in a sense.

2 CHAIR MUNN: We have from my 

3 perspective. Josie, do you agree?

4 MEMBER BEACH: Yes, Wanda, I do 

5 agree with that.

6 CHAIR MUNN: Very good. Let's 

7 consider that item closed and we'll move on to 

8 OTIB-83, the findings report. That was a 

9 carryover that NIOSH was going to have for us 

10 today.

11 DR. NETON: Okay, this is Jim.

12 MR. HINNEFELD: This is Stu, and 

13 once again I think I'm going to defer to Jim on 

14 this discussion.

15 CHAIR MUNN: Thank you, Stu.

16 DR. NETON: Yes, this is Jim. I've 

17 got this one. Well, I've had quite a bit of 

18 time to reflect on this, and I went back and 

19 reread both documents again, you know, the 83 

20 and the SC&A review.

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83

1 And at this point, NIOSH does agree 

2 with the comments made by SC&A that the target 

3 audience is not well defined. There's a 

4 discussion of this Type L plutonium. Just for 

5 background reference, the review had to do with 

6 how we would treat plutonium-238 exposures, 

7 internal exposures, essentially on a 

8 complex-wide basis which is implied for this 

9 TIB.

10 SC&A raised a number of concerns 

11 about who exactly this would be applied to and 

12 also questioned the general applicability of 

13 the so-called Type L model that was developed 

14 since it was only developed on selected cases, 

15 I believe five cases of exposure at the Mound 

16 facility.

17 We do agree that this needs to be 

18 fleshed out better. Unfortunately it's going 

19 to take a while because we are going to go back 

20 and review the other Mound cases for possible 

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84

1 incorporation into the model.

2 We used five. I believe there's at 

3 least around 40 different cases that could have 

4 been evaluated. It turns out the five we 

5 thought were the best and, you know, for 

6 expediency purposes we used the five figuring 

7 they were representative, but at this point we 

8 agree that we need to go back and demonstrate 

9 that to some extent.

10 So we're going to back, rebuild the 

11 model based on the cases at Mound. But as 

12 importantly, I think we need to also 

13 demonstrate at least documentation-wise that 

14 the types of exposure, the Type L exposures are 

15 fairly standard anywhere plutonium-238 is 

16 handled. That to me is not clearly defined in 

17 this document.

18 It's understood like plutonium-238 

19 behaved differently, at least is conjectured 

20 because of a high specific activity, but if it's 

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85

1 not clear to me, although it seems to be, some 

2 people think it's general knowledge that it's 

3 not maybe that Type L is specific to the type 

4 of microspheres that were being produced at 

5 Mound.

6 I'm not sure, but we need to go back 

7 and we'll add a section of this document that 

8 defines the scope and specifically under which 

9 exposure conditions we can expect this Type L 

10 material to be present. And if it's 

11 universally potentially present, no matter 

12 what type of plutonium-238's there we will make 

13 sure that's demonstrated and documented. 

14 So we've got quite a bit of work to do to 

15 shore up some of the pieces of this, so we're 

16 going to put this on our program planning 

17 schedule and work through the issues. But at 

18 this point we do accept SC&A's critique of the 

19 document itself.

20 CHAIR MUNN: How many findings do 

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86

1 we actually have?

2 DR. NETON: Well, I believe there 

3 are nine findings, but in my opinion many of 

4 them tend to be related to the same issues.

5 MEMBER BEACH: I thought there were 

6 14.

7 DR. NETON: Right, 14. There's a 

8 lot of findings, but a lot of them have to do 

9 with the representativeness of the Type L model

10 and who this model is going to be applied to. 

11 And those are the two major issues.

12 MEMBER BEACH: Yes, four key items 

13 in the findings.

14 MR. MARSCHKE: I agree. This is 

15 Steve Marschke with SC&A. I agree with Jim 

16 that's basically there's a lot of findings but 

17 there's a lot of duplication in some of the 

18 findings. And so I think they do collapse down 

19 to maybe four or five.

20 CHAIR MUNN: Is it possible that we 

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87

1 could request SC&A to take a look at that and 

2 see if we could eliminate some of the extraneous 

3 findings? If we can combine them into a single 

4 one it would be expedient, I think, from our 

5 point of view, and I think it would be helpful 

6 for NIOSH.

7 Am I speaking out of turn, Jim?

8 DR. NETON: Oh no, absolutely. I 

9 mean it would be a lot easier for us. I think 

10 the two issues I summarized do cover most of 

11 them. I'll not say all. There may be a couple 

12 other ones. But yes, that would be extremely 

13 helpful to us.

14 MR. MARSCHKE: Yes, I'll work with 

15 Joyce. Joyce was the primary reviewer on this, 

16 and I can work with Joyce and try and get, you 

17 know, combine some of these together.

18 CHAIR MUNN: Okay.

19 DR. NETON: And we'll put this on 

20 the schedule and I should be able to report, you 

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88

1 know, where we are on this once we get on the 

2 schedule and move forward.

3 CHAIR MUNN: Good. Could we make 

4 the request that next time SC&A will bring us 

5 suggestions for combining the findings and 

6 NIOSH will provide us with their anticipated 

7 rough schedule for addressing them?

8 DR. NETON: Sure.

9 MR. KATZ: Yes, and this is Ted. 

10 If I could just suggest, SC&A, feel free to chat 

11 with Jim in doing that so that you can sort of 

12 get to the endpoint before the Subcommittee 

13 meeting.

14 DR. H. BEHLING: Yes, Ted. We will 

15 do that.

16 MR. KATZ: Thanks a lot.

17 CHAIR MUNN: Okay, that's great. 

18 What is your desire? This would be a good 

19 opportunity, I think it looks like a good point 

20 in the agenda to break for lunch. But I don't 

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89

1 want to do that if you would prefer to keep going 

2 for another half hour.

3 How do you folks who are on the east 

4 coast feel about that? Would you prefer to go 

5 to lunch now or to keep moving through the 

6 agenda?

7 MEMBER ZIEMER: This is Ziemer. I 

8 wouldn't mind keeping moving a little bit, but 

9 I'm flexible.

10 CHAIR MUNN: All right. NIOSH, do 

11 you want to stick with it?

12 MR. HINNEFELD: It doesn't 

13 particularly matter to me. I can always eat 

14 lunch or I can --

15 CHAIR MUNN: Okay, then let's go 

16 ahead and address OTIB-34 then because I think 

17 some of the PER findings may take us longer this 

18 afternoon. So let's take a look at OTIB-34. I 

19 believe that's SC&A's Finding 4 and Rev 1, 

20 Finding 7 and 8.

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90

1 DR. H. BEHLING: Okay, that's mine. 

2 This is Hans Behling. And I just want to play 

3 catch up with some of the people who may not 

4 recall that Finding 4, really, was the finding 

5 that was identified by SC&A in our previous 

6 review of OTIB-34 Rev 00.

7 And so it was really not an integral 

8 part of the more recent review of the revised 

9 OTIB-34 among the findings that I identified 

10 there, but I'll go over it.

11 In our original review of OTIB-34 

12 Rev 0, the finding was as follows, and I'll just 

13 read it. The assumed and predicted intake fits 

14 versus the values in the first approximately 

15 five years are much less, from about 3,800 days 

16 to 7,200 days. The model fit is much higher, 

17 indicating that the percentile used for 

18 deriving the intake should be greater. This in 

19 turn would be more claimant favorable.

20 And you'll see what this refers to 

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91

1 in a second. In response to that finding, the 

2 original finding in our 2007 review, NIOSH 

3 responded and it's unclear what is meant by this 

4 comment. In the fit to the early data there are 

5 eight results above the line of fit and eight 

6 points equally below, which would seem to 

7 indicate an adequate fit.

8 And if I can draw your attention to 

9 what's on the screen, you will see at this point 

10 the exact statement and how they fit into the 

11 picture.

12 When you look at Figure A-28, you 

13 will see the blue dots and those indicate the 

14 actual integral measurements at the 50 

15 percentile value for data up to around 6,000 and 

16 some odd days after 1968.

17 And if you count the blue dots, you 

18 will see the blue dots on the left hand side, 

19 there will be eight dots above the best fit line 

20 up to the point of about 3,600 days, and then 

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92

1 there are eight dots below the line beyond that. 

2 And that was the issue here. And I 

3 looked at the information, and I guess I agree 

4 with NIOSH that this is the fit that was 

5 established by IMBA. And it's obviously that 

6 you're not following a clear cut pattern of the 

7 actual empirical data points that define that 

8 fit, but if that's the best fit that was 

9 established then there's very little one can 

10 do.

11 In the end, it's a fit that involves 

12 a large number of people who were monitored over 

13 this period of time. And if that's the best 

14 fit, then I'm not sure I know what one can do 

15 to say it shouldn't be used as such.

16 Now I will say this. In looking at 

17 this whole issue, I have a certain question in 

18 terms of how IMBA can be used to actually do 

19 this. And I'm only throwing this out without 

20 necessarily saying I'm right or wrong and I'm 

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93

1 looking for answers.

2 It is my understanding that IMBA 

3 really is not intended to be used in this kind 

4 of capacity. In the end, IMBA, as we normally 

5 view IMBA, is used to take bioassay data for a 

6 given one individual over a period of time, and 

7 then on the various assumptions that says this 

8 person was subjected to chronic intake 

9 throughout this whole period, let's say it's a 

10 10- or 20-year period and this is what we best 

11 assume was the intake that caused -- daily 

12 intake, using a chronic assumption exposure 

13 intake -- this is the best results that we can 

14 take in terms of saying what is the daily 

15 intake, from which we then estimate our dose to 

16 a particular organ in question.

17 Now how IMBA can be used to do the 

18 same thing in behalf of an entire large group 

19 of people that are part in this case from '68 

20 to '84, is something that I'm not able to 

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94

1 comprehend. Because as is clear, when we have 

2 a chronic intake for a radionuclide that 

3 persists in a body long, for long periods of 

4 time, there is successive accumulation of 

5 radioactivity in that organ so that the intake 

6 that occurred five years before the next 

7 particular assessment will contribute and 

8 continue to contribute.

9 And when you have a dynamic 

10 population where people come in and out of that 

11 population at will, which you don't know, I'm 

12 not sure how you can use IMBA.

13 After all, IMBA is really a 

14 sophisticated model that implements the 

15 International Commission on Radiological 

16 Protection, various models involving the 

17 respiratory tract, the GI tract, tissue 

18 dosimetry and all the other biokinetic and 

19 bioassay models that are adopted into IMBA.

20 How that applies to a group of 

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95

1 individuals is something that I'm not able to 

2 understand, and how IMBA can be used to actually 

3 establish a best fit for an entire worker group 

4 over a period of time.

5 And so I'm throwing this question 

6 out. So my question transcends, actually, the 

7 issue that was identified in this particular 

8 finding, and I'm hoping that somebody can 

9 answer my question.

10 MS. K. BEHLING: And just for 

11 clarification, OTIB-34 is the internal 

12 dosimetry coworker data for X-10, just to 

13 remind everyone.

14 CHAIR MUNN: Thank you, Kathy. 

15 Thank you, Hans. NIOSH, respond to Hans' 

16 question?

17 MR. HINNEFELD: Well, I don't know 

18 that --

19 DR. NETON: This is Jim. I wasn't 

20 prepared to talk about this.

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96

1 MR. HINNEFELD: Maybe Jim can make 

2 some comments.

3 DR. NETON: Is that Stu?

4 MR. HINNEFELD: Jim, yes, that was 

5 me. I was talking, but I don't have anything 

6 particular to say here. Maybe you can comment 

7 on it?

8 DR. NETON: No, again I wasn't 

9 prepared. This is a fairly general 

10 overarching type discussion to your point, but 

11 I think what you need to look and just think 

12 about or a person needs to think about is, is 

13 the 50th percentile of the distribution of the 

14 monitored workers representative of what the 

15 exposures were in that facility?

16 So we're modeling, that fit goes 

17 through the 50th percentile of the bioassay 

18 points, the 50th percentile of the bioassay on 

19 a year-by-year or whatever selected period 

20 basis.

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97

1 And if you can convince yourself 

2 that that's representative of what the 

3 workforce was exposed to, then I don't see, 

4 there's nothing special about IMBA or a single 

5 person versus the 50th percentile distribution 

6 being used.

7 DR. H. BEHLING: Well, what it 

8 comes down to, I believe, is the following. 

9 You establish the 50th percentile value which 

10 represents each of those blue dots using IMBA. 

11 In other words, you probably took --

12 DR. NETON: IMBA did not establish 

13 that 50th percentile dot. That is the 50th 

14 percentile of the measured data.

15 DR. H. BEHLING: The measured data.

16 DR. NETON: Bioassay data. And 

17 then IMBA decides what type of intake is needed 

18 to make those dots exist like that. The y-axis 

19 is excretion in dpm per day. That is actually 

20 the urinary excretion of the worker.

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98

1 DR. H. BEHLING: Yes, I understand 

2 that. I understand that.

3 DR. NETON: IMBA doesn't come into 

4 play in that at all.

5 DR. H. BEHLING: Well, to me it 

6 sounds much like a very primitive fit line that 

7 you would be able to establish using such as a 

8 least square or something else, and would have 

9 very little to do with IMBA.

10 DR. NETON: Well, no, but IMBA, you 

11 have to estimate what the chronic intake was in 

12 order to get those bioassay data points, right?

13 DR. H. BEHLING: I understand that.

14 DR. NETON: How much does a person 

15 have to inhale every day of every work day in 

16 order to see this straight line excretion 

17 function? Now what happens though, in the

18 beginning of the excretion period it has to 

19 start at zero necessarily because there is no 

20 intake, right? So that means --

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99

1 DR. H. BEHLING: Yes.

2 DR. NETON: -- you ramp up a little 

3 bit and then go through. But on average it 

4 gives you the right value.

5 DR. H. BEHLING: Well, I fully 

6 understand what you're saying, but I will 

7 disagree with it because when I look at the 

8 curve, in other words at Time Zero or close to 

9 zero whenever that first blue dot appears, 

10 there was a fairly high excretion rate that 

11 corresponds to an intake value that doesn't 

12 match the fit line. And I'm just not --

13 DR. NETON: But then you also have 

14 to think about what happens, we tend to model 

15 periods of time that have a similar pattern, 

16 like you see the blue dots on the screen there. 

17 Those seem to be a similar excretion constant 

18 pattern.

19 It will drop over different periods 

20 of time, so then the next model period will 

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100

1 start from zero again and move up, but it 

2 doesn't account for any of the residual 

3 excretion that is still occurring from that 

4 previously modeled period.

5 So in essence, what happens is if a 

6 person worked in both model periods, they would 

7 receive the first model period intake, the 

8 second model period intake, but they would also 

9 continue to receive any inhalation that's 

10 residual from the first period that's not even 

11 included in there. It tends to overestimate 

12 the doses quite a bit for intakes.

13 DR. H. BEHLING: The real question 

14 is that for other radionuclides those kinds, 

15 the distribution seems to have fragmented into 

16 multiple time periods. In this case for 

17 americium we only have two periods. One that 

18 goes from '68 to '84, and the second one for the 

19 shorter period, basically from '85 to '88. 

20 And why wouldn't you choose to have

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101

1 perhaps a more, a higher number of time periods 

2 to segregate that distribution between '68 and 

3 '84, because you did that for plutonium?

4 And I don't know, it seems so 

5 arbitrary to essentially establish a fit for 

6 the '68 to '84 in the case of americium and have 

7 more discrete periods for which an intake was 

8 developed before that same period. You could 

9 have easily --

10 DR. NETON: Well, if you look at the 

11 data that are on the screen though, it does 

12 appear that it was a fairly constant, chronic 

13 excretion going on there.

14 So you can, you know, if the 

15 excretion rates are fairly constant over time 

16 you're going to fit that as long as you can, 

17 because that's what you're trying to model is 

18 a chronic scenario. You wouldn't want to break 

19 it up into multiple periods because it doesn't 

20 make any sense.

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102

1 DR. MAURO: This is John. I always 

2 try to get things down to something that I can 

3 simply understand. You've got a dpm per day 

4 y-axis with a blue dot, the very first blue dot 

5 for this americium which is 0.12 dpm per day.

6 DR. NETON: Right.

7 DR. MAURO: That's an excretion 

8 rate for a single person or for the average 

9 number?

10 DR. NETON: It's the 50th 

11 percentile results for the population in that 

12 --

13 DR. MAURO: Okay, so you've got a 

14 population of workers where you have collected 

15 excretion data, and the 50th percentile 

16 geometric mean is that number, that 0.12. 

17 Then you have taken, I guess, at another 

18 time period which may be the same population of 

19 workers or a mix of some new and some old and 

20 so forth, and you have another number. And so 

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103

1 in effect what we're looking at is the geometric 

2 mean of the excretion rate or of americium in 

3 a group of workers at different time periods in 

4 sequence.

5 Now to go back to Hans' question. 

6 Now if you're saying to him, okay, I have some 

7 data on different time periods and what people 

8 are seeing, and I would agree just from a common 

9 sense point of view it looks like, gee, you've 

10 got all these groups of people over this time 

11 period which covers a number of years, 

12 apparently, they're all around, you know, 

13 anywhere from about 0.09 to 0.12 dpm per day.

14 So as far as I'm concerned, what 

15 this says is that each, and notwithstanding 

16 whether you run IMBA or whatever you have, it's 

17 almost like let's walk away from that for a 

18 second. All you're really saying here is that 

19 the concentration or the excretion rate of 

20 americium in each cluster of people on that day 

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104

1 when that sample was collected from those 

2 people, they're all the same. I mean to me the 

3 difference between, well, within a factor of 2.

4 So as far as I'm concerned given the 

5 uncertainty in all these things we talk about, 

6 what you're really saying here is every time we 

7 grabbed a group of people over this time period, 

8 which covers many years, those group of people 

9 always had the same excretion rate. And that 

10 transcends IMBA. All that says is that's what 

11 we see. We're not seeing anything's changing.

12 Now, so in my mind, I guess maybe I 

13 go back to Hans' concern, and maybe I'm 

14 referring to it correctly is, where does IMBA 

15 come in? All you're really saying is, look, 

16 hey, we've got all these people, we've got all 

17 this data. A lot of data over a lot of years. 

18 I don't know how many people are represented in 

19 each dot but it could be a lot of people. And 

20 they always have the same excretion rate. 

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105

1 And to me a difference of between 0.09 and 

2 0.15, to me as a biologist that means nothing 

3 to me. That means there's no difference. 

4 Maybe there are those who see that as important. 

5 I don't.

6 So now I know that over that time 

7 period, everybody that you were looking at had 

8 this chronic excretion rate that was always 

9 around, you know, 0.1, 0.12 dpm per day. And 

10 then the next question is, okay, what type of 

11 chronic intake rate by all these people over all 

12 this time would give you that excretion rate? 

13 And you're done. And that of course is where 

14 IMBA would come in.

15 DR. NETON: And that's what we've 

16 done. If you go back down to the graph at the 

17 bottom there, the chart.

18 DR. MAURO: Yes.

19 DR. NETON: Go back. Could you go 

20 down to the table?

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106

1 DR. MAURO: Yes.

2 DR. NETON: There's a table, and it 

3 said between 1968 and '84 a person would have 

4 to have inhaled 6.673 picocuries per day?

5 MR. MARSCHKE: Disintegrations per 

6 minute per day.

7 DR. NETON: Dpm per day. They have 

8 to have inhaled that much per day in order to 

9 get that curve.

10 DR. MAURO: Right, and not even a 

11 curve.

12 DR. NETON: That's the intake per 

13 period --

14 (Simultaneous speaking)

15 DR. NETON: What's the printed --

16 DR. MAURO: Yes. I have to say in 

17 the simplest terms, what you're simply saying, 

18 listen, all these people are more or less being 

19 exposed to the same concentration, having the 

20 same intake over all this time period, which is 

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107

1 very surprising. So it's a very stable, 

2 chronic situation, and you could very well 

3 back-calculate out what the intake rate was.

4 Now of course --

5 DR. NETON: That black curve there 

6 is the IMBA curve that was fit for those data 

7 points for a chronic exposure and that's the 

8 best fit for the data that said what chronic 

9 exposure would give you those data points, and 

10 that's what we came up with.

11 DR. MAURO: As if it was a single 

12 person that had this data?

13 DR. NETON: No, the 50th percentile

14 person had the data. All these data points are 

15 for the 50th percentile person.

16 MR. MARSCHKE: It's a single 50th 

17 percentile. It's a single person. I mean 

18 IMBA runs on a single person. So it's really 

19 a single person who has the 50th percentile 

20 excretions.

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108

1 DR. NETON: Each point is the 50th 

2 percentile of each year. So it's a 50th 

3 percentile excretion value of the distribution 

4 for each year.

5 DR. MAURO: Got it. But as I said 

6 before --

7 DR. NETON: Then you fit a curve to 

8 that and say what would you have to inhale every 

9 day in order to maintain that type of excretion 

10 pattern if you were the 50th percentile worker?

11 DR. MAURO: Now why wouldn't you do 

12 something much simpler and simply say, listen, 

13 I have all of these data points, it looks to me 

14 that, you know, for any group of people, the 

15 excretion rate, the highest we see for a given 

16 group was 0.15, and you say to yourself, well, 

17 that certainly would be an upper bound of what 

18 an excretion rate would be for all these people 

19 over all this time.

20 We know that most of them had less 

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109

1 than that. All of them had less than that. 

2 And why wouldn't you simply say, given that I 

3 have a person that has been chronically exposed 

4 over all this time and he continuously had a 

5 constant excretion rate of 0.15 picocuries, I'm 

6 sorry, dpm per day, then ask myself the question 

7 and run IMBA, what would my chronic intake rate 

8 be that I would have --

9 (Simultaneous speaking)

10 DR. NETON: What you're saying, 

11 change all of those points to 0.15. All the 

12 blue dots become 0.15?

13 DR. MAURO: Yes. I mean I'm not 

14 saying you should do that.

15 DR. NETON: You're ignoring the 

16 data. I mean why bother? It doesn't make any 

17 sense to me to pick the highest value --

18 DR. MAURO: I just picked that to 

19 say, if anybody wanted to say, listen, how bad 

20 could it have been --

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110

1 (Simultaneous speaking)

2 DR. NETON: But the point is John we 

3 have the data. These are the data. They fit 

4 a fairly straight line across, which indicates 

5 a chronic exposure pattern and we fit a chronic 

6 exposure model, the best fit that IMBA can 

7 produce, and got that result.

8 DR. MAURO: You know what it is? I 

9 think it may be, the thing that's confusing me, 

10 and it's just probably my own lack of knowledge, 

11 is, you know, why wouldn't you simply take all 

12 those data points, come up with the geometric 

13 means and standard deviations, say okay, here 

14 is the, for this population of workers over all 

15 this time, they're all, you know, this 

16 represents what the excretion rate has been, 

17 chronically, as a reasonable geometric mean or 

18 upper bound, say --

19 DR. NETON: You don't have to fit 

20 IMBA to it to come up with an intake.

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111

1 DR. MAURO: Then I would run IMBA 

2 after that. See, I don't understand how these 

3 numbers, like Hans brought up initially, I 

4 understand Hans question. He says why would 

5 you somehow need to use IMBA to represent what 

6 these dots mean? I guess I'm having trouble 

7 with that --

8 DR. NETON: You have to use IMBA to 

9 come up with an intake.

10 DR. MAURO: Yes --

11 DR. H. BEHLING: But Jim, this is 

12 what I'm constantly going to ask is, you're not 

13 using IMBA the way it was intended to be. 

14 You're looking at the 50th percentile value for 

15 each of the time frames that represent the dots 

16 and then you're trying to use an IMBA fitting 

17 for those.

18 I mean to me, if I look at those blue 

19 dots, you would almost, if you did a least 

20 square on those blue dots you would end up with 

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112

1 a value somewhere around 0.12 dpm per day 

2 excretion.

3 And rather than a ramping up, I 

4 don't see the ramping up here. This is what 

5 IMBA would suggest --

6 DR. NETON: But Hans, that's a 

7 function of the assumption of using a chronic 

8 exposure model. A chronic exposure model can 

9 start at zero at some point by definition.

10 DR. H. BEHLING: Of course. I 

11 understand how IMBA works for a single 

12 individual. I do not understand how it applies 

13 to a collective group of individuals.

14 DR. NETON: We're trying to 

15 estimate what the unmonitored workers' 

16 exposures were, not what these monitored 

17 workers were exposed to, period. Right? This 

18 has nothing to do with what the monitored 

19 workers' exposure was. Totally irrelevant. 

20 This is trying to estimate what our 

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113

1 best estimate for someone who had zero 

2 monitoring that could have been potentially 

3 exposed, what they could have received. And 

4 our approach, this has been this way for over 

5 12 years, is that the 50th percentile of the 

6 monitored worker distribution can be used to 

7 establish a chronic exposure scenario and 

8 that's what we do.

9 I mean I don't --

10 MR. STIVER: This is John Stiver. 

11 If I could jump in for a second here. I mean, 

12 you know, John and Hans, this is the classic 

13 pooled data coworker model approach that we 

14 looked at many, many different times, where 

15 NIOSH will pull together a series of 50th 

16 percentiles and that look to be kind of a 

17 homogenous representative of a given intake 

18 regime, if you will.

19 And it really, the IMBA is basically 

20 being used to model, as Jim said earlier, the 

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114

1 50th percentile individual which will then be 

2 used to assign a coworker dose. And each one 

3 of these is looked at as though it's a single 

4 intake with no previous contribution from an 

5 earlier intake regime. And, you 

6 know, we talked about this a lot and I'm pretty 

7 sure that we've come to a general agreement, I 

8 mean without regard to the OPOS application and 

9 so forth. But this type of approach to 

10 coworker modeling is okay and appropriate. 

11 I may be missing something but it's 

12 been my general understanding.

13 MR. BARTON: This is Bob Barton. 

14 Could I make a comment here? I think from what 

15 I'm hearing, and Hans, correct me if I'm wrong, 

16 I think part of what his concern is is that when 

17 you fit this line here, I mean you kind of 

18 assume, basically, what this modeling is, this 

19 is your average worker if he was chronically 

20 exposed from 1968 to 1984.

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115

1 Now how you select that time period 

2 as I understand it is sort of in the eye of the 

3 beholder. You kind of take a look at it and you 

4 try to group bioassay results together, but 

5 there's really no guidelines as to how you 

6 select that, as John just put it, intake regime.

7 I mean if took these blue dots and 

8 instead of fitting a line through all of them, 

9 let's say we just arbitrarily cut them in half, 

10 that's going to increase what intake that IMBA 

11 would model.

12 So I guess I would add is there any 

13 way we could, I mean are there guidelines as to 

14 how you select the actual intake regime or how

15 you group these bioassay results together? 

16 Because this is modeling a chronically exposed 

17 worker for this large time period, but if you 

18 were to model any one of these individual data 

19 points, obviously the intake is going to be 

20 fundamentally higher. Hans, did I get 

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116

1 that correctly?

2 DR. H. BEHLING: Yes. As I said, 

3 I'm just not sure why this time period is only 

4 one large time period and a very small second 

5 time period, when I compare that to the data 

6 involved in Figures A-26 and 27, which are dose 

7 for plutonium-239 where we have, I guess, four 

8 time periods which are modeled here and the data 

9 doesn't look all that different.

10 (Simultaneous speaking)

11 DR. NETON: I can't see them. I'm 

12 sorry.

13 DR. MAURO: Could we scroll up?

14 (Off the record comments)

15 DR. H. BEHLING: I didn't ask for 

16 that, but in addressing this issue, which by the 

17 way as I said was not an issue that I identified, 

18 I'm only responding to --

19 DR. NETON: Oh, we're passed it 

20 now. Anyway the bottom line is, it is as Bob 

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117

1 Barton said. There is a professional judgment 

2 involved when you do any kind of an intake 

3 assessment like this, and it has to do with the 

4 patterns.

5 I mean you can see on A-24, there's 

6 apparently a clear reduction here in the amount 

7 of material being excreted as compared to the 

8 first time period.

9 DR. H. BEHLING: Yes.

10 DR. NETON: And that's what's done. 

11 I mean I don't know how you could do it any 

12 better than say, you know, it's, I don't know. 

13 I don't know if you can create quantitative 

14 criteria on exactly how many years’ worth of 

15 data are fit.

16 In general you will see that there 

17 are trends in the data that seem to follow 

18 along. You'll see like a certain period where 

19 it looks like it's fairly uniform and then it'll 

20 drop. Maybe the project, some project was 

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118

1 terminated and the chronic exposures went way 

2 down. Well, then you would model that chronic 

3 exposure as a separate time period.

4 MR. STIVER: Okay, Hans, could I 

5 just jump in? This is John Stiver again. 

6 You'd mentioned earlier that like if this was 

7 a radionuclide you'd have different exposures. 

8 And, I guess, correct me if I'm wrong, I'm 

9 trying to interpret what you're getting at. 

10 You're saying that there's a lack of 

11 consistency if you were indeed getting both of 

12 those nuclides in a chronic exposure over a 

13 given period of time then you should be using 

14 the same intake regime as opposed to having 

15 different regimes.

16 But, you know, if you had different 

17 types of campaigns where different materials 

18 were being used, then I think you'd have to set 

19 your intake regimes that would correspond to 

20 the exposure scenario under question of the 

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119

1 particular nuclide.

2 I kind of, is that what you were 

3 really getting at or am I off base on that?

4 DR. H. BEHLING: I'm not looking to 

5 make a change here in the way we assess a worker, 

6 coworker model. I realize there are 

7 limitations.

8 And I guess the coworker model as 

9 it's being used I would consider much more 

10 credible if that coworker model consisted of a 

11 fixed group of people that were there in exact 

12 numbers and same people not coming in and out 

13 of the workforce, so that it would, in essence, 

14 simulate an individual who was there and whose 

15 data we were assessing on an individual basis 

16 as opposed to a group of individuals.

17 I guess the weakness of a coworker 

18 model is that that similarity between multiple 

19 bioassays for a given individual as opposed to 

20 many bioassays for a group is kind of lost when 

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120

1 you realize there's a certain amount of dynamic 

2 movement in terms of the size of the work force, 

3 people coming in and out, retiring, entering 

4 the work force, where these data are not 

5 necessarily what IMBA intended to do here.

6 And I'll accept the fact that this 

7 is not going to change. It's the best we can 

8 do. But there are some issues here that I guess 

9 are subject to criticism when you use IMBA.

10 DR. NETON: I understand all the 

11 points you're making, Hans. But I like to 

12 think about it this way, is that we're not, 

13 we're trying to say what was the potential 

14 exposure for a person who wasn't monitored.

15 DR. H. BEHLING: Yes.

16 DR. NETON: And so I think we might 

17 agree, I would hope at some point, that for an 

18 unmonitored worker could have received about 

19 the 50th percentile of what the workers were 

20 experiencing on an every-year basis, right?

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121

1 I mean it's not that worker, but if 

2 he were in the work force he couldn't have 

3 probably been exposed to more than what the 50th 

4 percentile worker was exposed to every year.

5 So it doesn't matter whether it's 

6 the same worker or not, if I am an unmonitored 

7 worker I could have been exposed to about the 

8 50th percentile. And then we fit that curve. 

9 So it's not so much about what individual worker 

10 exposure was, but if I was not monitored and I 

11 worked in the plant, I don't believe that the 

12 worker would have received more, have had 

13 excreted more than what the 50th percentile 

14 worker excreted and been unmonitored. That's 

15 all we're trying to say here.

16 I think it's a little different way 

17 of looking at than saying we're trying to 

18 exactly reconstruct the dose to every single 

19 worker during that time period. We're not. 

20 We're trying to say what was the potential 

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122

1 exposure experience of an unmonitored worker? 

2 And I would submit that it's 

3 unlikely that an unmonitored worker would have 

4 received more than a 50th percentile excretion 

5 value every single year of that time period. 

6 And then that begs the question what that 

7 included intake could have been and that's 

8 where IMBA comes in. So I don't know.

9 DR. H. BEHLING: No, I'm going to 

10 cut this short. I wasn't looking to change the 

11 way we do business and I accept that the numbers 

12 that correspond to that table. I'm talking 

13 about Table A-12, which as you already 

14 mentioned would suggest that the average daily 

15 intake rate for americium-241 is 6.673 dpm per 

16 day, and I think that's not an unreasonable 

17 approach.

18 I'm just trying to satisfy the 

19 initial concerns that were raised back in 2007, 

20 and I did have some questions about the use of

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123

1 IMBA, but I think this is as good as we can do. 

2 DR. NETON: I appreciate that. 

3 Thanks.

4 MR. BARTON: This is Bob again. I 

5 think, fundamentally, and we could all agree 

6 that the finer you parse the intake assessments 

7 the higher the actual calculated intakes would 

8 be. As I said, Figure A-28 is essentially 

9 modeling as if you were chronically exposed 

10 from '68 all the way to '84.

11 Now let's say if you worked for a 

12 shorter period of time and still had that 

13 average excretion rate, you know, whatever the 

14 time period it is, the actual intake would be 

15 higher.

16 And I don't know if there's a way 

17 around, I don't know, sort of adjusting the 

18 coworker model for workers who were there on a 

19 shorter duration but might have had that 

20 average excretion rate which would actually 

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124

1 represent a higher intake. Because the more 

2 bioassay results you group together the lower 

3 the actual calculated intake will be, if I'm 

4 correct.

5 DR. NETON: Well, the more you 

6 slice the salami the more you start talking 

7 about incident modeling, Bob.

8 MR. BARTON: Right.

9 DR. NETON: And you've agreed that, 

10 well, we have adopted a chronic exposure model 

11 here and we're not doing incident modeling at 

12 all. I mean ideally if you do it on a 

13 day-by-day basis it's essentially acute 

14 exposures.

15 MR. BARTON: Well, we're not 

16 talking day-by-day. We're talking about a 

17 16-year period here. I don't know. And 

18 again, professional judgment has to come into 

19 it because you have to try to select a period 

20 to model.

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125

1 I just, I don't know if it would be 

2 possible to sort of develop criteria for how you 

3 select it or if we're kind of stuck where you 

4 just have to leave it to, I guess, visual 

5 inspection. You use bioassay results and 

6 let's see what they're about to say, and so 

7 we're going to group them all together.

8 It's just very, you know, as I said, I mean 

9 if you broke this time period from '68 to '84 

10 in half, your calculated intake's going to be 

11 much higher for both intake regimes. I mean 

12 we're not talking about days here, we're 

13 talking about many years.

14 DR. NETON: Again the whole premise 

15 of the chronic exposure, if I look at those blue 

16 points, to me it looks like people are excreting 

17 about the same amount during that entire time 

18 period indicating a chronic exposure model 

19 would be appropriate.

20 DR. MAURO: Jim, I'm not disputing 

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126

1 any of that. The only thing that I've got is 

2 this little knot in my head that said what does 

3 that black line mean? In other words you have 

4 all these blue dots --

5 DR. NETON: That is the IMBA fit to 

6 that data point.

7 DR. MAURO: Yes, I understand. 

8 And to me, as Hans pointed out, they don't have 

9 anything to do with each other. In other words 

10 the IMBA, in other words to me --

11 DR. NETON: Because the chronic 

12 model starts out at zero, right? You can't be 

13 chronically, you start excreting, you know, on 

14 Day Zero, Time Zero, you have zero excretion and 

15 then you start breathing six picocuries per day 

16 and that's what that shows.

17 As you keep breathing six 

18 picocuries per day it goes up. What it doesn't 

19 show is previous monitoring periods where it 

20 was also modeled and there's some residual 

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127

1 carried over into that period that's not shown 

2 here.

3 DR. MAURO: You know, I would agree 

4 with that if every dot was the same person. In 

5 other words, every one of those dots was the 

6 excretion rate we measured on a given person on 

7 that day and then the next, and then you have, 

8 and that's the data that came out.

9 DR. NETON: But John, we're not 

10 modeling people. We're modeling a 

11 distribution because we're trying to figure out 

12 what the potential missed intakes would have 

13 been from an unmonitored worker.

14 And all I'm saying is if they 

15 excrete the 50th percentile of all the 

16 monitored workers, I think that's a fair

17 bounding representation of their intake during 

18 that period of time. They weren't monitored, 

19 remember? We're not talking about 

20 reconstructing monitored workers' doses. It 

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128

1 has nothing to do with that.

2 MR. STIVER: You know, this is John 

3 again. I think we may be sort of straying far 

4 afield from, you know, the --

5 DR. NETON: I agree.

6 MR. STIVER: -- maybe the Procedure 

7 Subcommittee and getting more of the 

8 overarching issues about coworker modeling in 

9 general. And maybe we ought to try and get back 

10 down to the --

11 DR. MAURO: Yes, let me back out of 

12 this, because I'm just looking at the graph and 

13 I'm trying to make it make sense to me why an 

14 IMBA black line is on there.

15 DR. NETON: John --

16 (Simultaneous speaking)

17 DR. NETON: -- for 12 years.

18 DR. MAURO: Clearly you're 

19 comfortable with that --

20 DR. NETON: I guess you just woke up 

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129

1 and saw them or something.

2 CHAIR MUNN: So is the upshot of 

3 that discussion that we can or cannot accept the 

4 response that NIOSH has given to the finding?

5 DR. H. BEHLING: If I can weigh in 

6 on this issue, I would say I will accept NIOSH's 

7 explanation that there are eight points above 

8 the line, eight points below the line, and on 

9 average the numbers will somehow or other do 

10 justice to the unmonitored person by assigning 

11 him the intake values that are identified in 

12 Table A-12.

13 I mean it's not a perfect approach 

14 to doing this, but in the absence of data that's 

15 as good as we're going to get.

16 CHAIR MUNN: Thank you, Hans. 

17 That's appreciated. Can we then identify 

18 Finding 4 of Rev 1 as having been discussed and 

19 agreed in Committee, and the Committee 

20 recommends closure. Is that appropriate?

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130

1 DR. H. BEHLING: I think so.

2 CHAIR MUNN: All right.

3 Paul?

4 MEMBER ZIEMER: Yes, I'm agreed.

5 CHAIR MUNN: Josie?

6 MEMBER BEACH: I agree also.

7 CHAIR MUNN: Steve, can you input 

8 that finding for us?

9 MR. MARSCHKE: A lot more names in 

10 here than we had before.

11 CHAIR MUNN: We're getting very 

12 popular with this system.

13 DR. MAURO: Hey, Steve, my wife 

14 used to be a typist and she could do 120 words 

15 a minute, all right?

16 MR. MARSCHKE: I do 12.

17 MR. KATZ: That's good, John.

18 CHAIR MUNN: That was when we 

19 called it typing, now it's keyboarding. 

20 That's different, John.

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131

1 DR. OSTROW: This is Steve. I can 

2 do about 50 words a minute but not all of them 

3 are correct.

4 CHAIR MUNN: Thank you very much.

5 MR. MARSCHKE: Okay, that's what I 

6 put in.

7 CHAIR MUNN: It's fine with me. 

8 Any problem with that from anyone? If not, 

9 that's the way it will be and we will close this 

10 finding for Rev 0. And we will go on to Rev 1, 

11 Findings 7 and 8. I believe that's a NIOSH 

12 comment?

13 MS. MARION-MOSS: Hi Wanda, this is 

14 Lori. For Finding Number 7, I think since the 

15 last time the Committee addressed this 

16 particular finding, I believe we have revised 

17 Document OTIB-34. We are currently on OTIB-34 

18 Rev 3.

19 So to bring the Committee up to 

20 speed on how we've addressed this, I'm going to 

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132

1 ask Joe Guido to get the Committee an update on 

2 the proper selection of the 95th percentile.

3 Are you on, Joe?

4 MS. THOMAS: Lori, this is Elyse. 

5 Joe was on and he had another call, so let me 

6 try to get him back on to address that. It 

7 might take a few minutes. He just got off for 

8 a 1 o'clock call, but I'll see if I can get him 

9 on.

10 MR. HINNEFELD: Well, now this is 

11 Stu. I mean our response, our latest response 

12 just says that we've added wording to the Rev 

13 2, which I think is still there in Rev 3 of this 

14 document that describes when to use the 95th 

15 percentile. I don't know if anybody's looked 

16 at that or not.

17 I mean then I look, let's see, we're 

18 on Finding 7, right?

19 CHAIR MUNN: Finding 7, correct, of 

20 Rev 1.

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133

1 MR. HINNEFELD: Okay, expand that. 

2 Yes, our latest entry is additional guidance on 

3 assigning that 95th percentile has been added 

4 to Section 5 of the OTIB. And then what that 

5 OTIB said, I had it open. What Section 

6 5 says is in most cases, doses for individuals 

7 who are potentially exposed routinely should be 

8 calculated from the 50th percentile intake 

9 rates by assuming the solubility type that 

10 results in the largest Probability of 

11 Causation.

12 GSD values have been not less than 

13 three, et cetera, et cetera. For cases in 

14 which there's justification that the 

15 individual might have had larger intakes than 

16 the 50th percentile intake, the dose 

17 reconstructors should use the 95th percentile 

18 intake rate input into IREP as a constant.

19 So there is, you know, there's 

20 instruction there, and I don't think that 

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134

1 there's a lot of hope of identifying the 

2 specific cases when, and a priori or in advance 

3 what specific conditions would put people in 

4 that situation.

5 I think you'd have to evaluate the 

6 claim individually to determine that hey, this 

7 person looks like maybe they shouldn't be in the 

8 50th percentile, but rather should be in the 

9 95th.

10 DR. H. BEHLING: Well, that was my 

11 concern from the very beginning. It's nice to 

12 have the option, but in the absence of defining 

13 the specific incidents when the 95th percentile 

14 applies, it is too arbitrary on the part of the 

15 dose reconstructor to make that decision.

16 And one of the things I've always 

17 been concerned about is the option or the 

18 nonprescriptive approach when you do dose 

19 reconstruction, which for one instance, for one 

20 dose reconstructor means I think this person 

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135

1 qualifies for the 95th, and the other instance 

2 for dose reconstructors is no, he's 50th 

3 percentile.

4 And consistency is a big issue that 

5 I always want to look at when I assess a dose 

6 reconstruction and I sort of say is it the luck 

7 of the draw that defines whether or not the 

8 person goes over the 50th percentile. And I 

9 would like to see a very, very prescriptive 

10 approach to avoid that issue out of fairness.

11 MR. HINNEFELD: Well, that's a 

12 valid point. The consistency question is a 

13 valid point. I still though, I think that 

14 there would almost have to be a finding, a 

15 programmatic finding that there's a category of 

16 worker at -- and this is what, X-10 -- that was 

17 heavily exposed but not monitored and in that 

18 case they should be put into this.

19 So I don't know that we've made a 

20 finding like that at X-10, but it's a 

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136

1 possibility that we could.

2 DR. H. BEHLING: Let me offer, for 

3 instance, an example so as to at least give some 

4 limited guidance. I would say the 95th

5 percentile would be very appropriate for a 

6 worker who is an operator, in-plant operator 

7 that is considered to be a high risk, but for 

8 some reason or another his dose records, we know 

9 his employment period coincides with potential 

10 high exposures involving other people who were 

11 operators, but for some reason his dosimetry 

12 records are missing that we can't account for.

13 I would say that would be a perfect 

14 example to say we must give him the benefit of 

15 the doubt based on the time period of exposure, 

16 his job description as a high risk individual 

17 but there are no data.

18 I think this would be a perfect 

19 example for saying this is when you should 

20 consider 95th percentile in lieu of the 50th 

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137

1 percentile that might be very, very fair for the 

2 other average people for whom we have no data.

3 MR. HINNEFELD: Yes, that's a good 

4 point.

5 DR. MAURO: This is John. Let me 

6 add a little richness to this too, which is a 

7 little contrary to what Hans is saying, with all 

8 due respect.

9 I've reviewed mainly AWEs. I don't 

10 know how many now, and I can't think of a time 

11 when the judgment was made, there was 

12 discretion to be used by the dose reconstructor 

13 in what airborne concentration should be 

14 assumed.

15 And in my opinion it was always an 

16 overestimate. In other words, so my 

17 experience with AWEs is that when push came to 

18 shove and the dose reconstructor had to make a 

19 judgment, he always erred on the side of the 

20 claimant. That's AWE world.

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138

1 So I mean, I'd like to speak, you 

2 know, in a positive sense here. Those 

3 judgments have been made in a prudent way, if 

4 not a very claimant favorable way, for the dose 

5 reconstructions that I've been involved in, 

6 mainly AWEs.

7 DR. H. BEHLING: Well, John, this 

8 is not an AWE. This is for the X-10 worker.

9 DR. MAURO: There you go, I mouthed 

10 it off prematurely. Okay.

11 (Simultaneous speaking.)

12 DR. MAURO: Okay, okay.

13 MR. BARTON: Well, actually, John, 

14 I mean I can give some sort of, an example of 

15 precedence is Simonds Saw and Steel in which the 

16 decision hasn't come out but I essentially 

17 agreed in principle that the 95th percentile is 

18 going to be applied to the plant workers, or 

19 essentially who would be assigned as a 

20 radiological worker.

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139

1 And the 50th percentile of the GSD 

2 would be assigned to sort of like the ancillary 

3 workers, you know, that may have been in the 

4 plant briefly but weren't actually working 

5 inside Simonds.

6 So I think that's what Hans is 

7 saying is you want to take out the judgment 

8 call. Essentially, you can't be prescriptive 

9 for every situation, but that's only an example 

10 of where we say, okay, the 95th percentile is 

11 appropriate if you were an unmonitored plant 

12 worker at Simonds. And that's --

13 DR. NETON: I've got this task at 

14 hand right now to do the implementation guide 

15 for coworker models, and that's one of the 

16 issues that I'm wrestling with in that draft 

17 document right now.

18 And we talked a little bit about it 

19 at the Idaho SEC Work Group meeting, SEC Issues 

20 Work Group meeting. And, you know, I think 

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140

1 that's the appropriate place to put this, the 

2 guidance, and I think it'll be fleshed out over 

3 time as that document becomes closer to 

4 completion.

5 We've had lists before, and I know 

6 there are some documents that do mention some 

7 Classes of workers as being appropriate to have 

8 the 95th percentile. I've forgotten which 

9 ones.

10 MR. MARSCHKE: Jim, this is Steve 

11 Marschke. I think if you look at OTIB-20, when 

12 we were reviewing the construction trade 

13 workers we had a sentence that was added to 

14 OTIB-20 which basically identified 

15 construction trade workers, in particular 

16 pipefitters, that basically should be applied 

17 to these.

18 DR. NETON: So this has resurfaced 

19 periodically and --

20 MR. MARSCHKE: It has. And if I 

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141

1 recall from some of those discussions, and to 

2 paraphrase NIOSH, what I remember as being 

3 NIOSH's position was that these assignments of 

4 percentiles are not the sole, or, you know, the 

5 dose reconstructor is not the endpoint on these 

6 assignments. They get reviewed multiple 

7 times.

8 DR. NETON: They do. But I do 

9 agree with Hans' issue on consistency. My 

10 problem is when you start naming a couple 

11 categories of workers, which we have in the 

12 past, then people say, well, what about this 

13 Class and this Class? Because there's a lot of 

14 workers out there that probably were more 

15 heavily exposed than you would think just based 

16 on their job classification.

17 So I'm reluctant to have a 

18 definitive list. I do agree that someone like 

19 a chemical operator who clearly should have 

20 been monitored and his dose records were lost, 

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142

1 that's a no-brainer. But beyond that I'm not 

2 quite sure.

3 Anyway I think the place to address 

4 this and maybe to carry this on is in this 

5 implementation guide that I'm putting 

6 together, and it's certainly one of the issues 

7 that have to be addressed.

8 MR. HINNEFELD: Okay, so if we 

9 enter another response that says that this is 

10 being addressed in an implementation guide for 

11 use in coworker models and we expect some 

12 additional guidance to come out of that, would 

13 that kind of put this to be in abeyance or

14 something for now?

15 MR. MARSCHKE: Or would it be 

16 transferred?

17 CHAIR MUNN: Well, I don't believe 

18 it would be transferred. I believe it would be 

19 in abeyance, if that is in fact agreeable to the 

20 rest of the parties here. Would the addition 

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143

1 of this information in an implementation guide 

2 be acceptable to SC&A?

3 DR. H. BEHLING: I would be 

4 agreeable if the current wording hasn't been 

5 changed the way Stu read them would be just 

6 slightly amended with a single example.

7 As I said, I'm not looking for to 

8 broaden the scope by which 95th percentile is 

9 assigned. For an unmonitored worker, I think 

10 it's reasonable to conclude what NIOSH has 

11 always stated that if you weren't monitored you 

12 were probably not among the high end exposed 

13 individuals. I agree with that.

14 What I do want to say, when it is 

15 used at the discretion of the dose 

16 reconstructor that it's used properly not 

17 whimsically. And it should be probably highly 

18 restricted when the 95th percentile is used and 

19 correspond to unusual circumstances like the 

20 one I said.

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144

1 An operator who's been there for 

2 many years whose coworkers are among the people 

3 who were maximally exposed but for some reason 

4 that workers' dose records have been lost, I 

5 think that's a no-brainer, and I think the kind 

6 of limited situation that the 95th percentile 

7 should be used.

8 CHAIR MUNN: So if we, of course 

9 when the change has occurred it comes back to 

10 us to agree that it meets the criteria 

11 anticipated.

12 So is it amenable for all concerned 

13 for us to indicate this particular Finding 7 for 

14 Rev 1 is in abeyance awaiting a NIOSH 

15 implementation guide which addresses the 

16 concern?

17 DR. H. BEHLING: Yes.

18 CHAIR MUNN: Very good. Steve, 

19 can you make the change for us? Just after 

20 discussion? Will be addressed in

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145

1 implementation guide. Excellent. Is that 

2 wording acceptable to all involved?

3 DR. H. BEHLING: Yes.

4 CHAIR MUNN: Very good. Thank 

5 you, Steve. Appreciate it.

6 MEMBER ZIEMER: There's a spelling 

7 error, did you catch that? The last phrase?

8 Yes, there you go. Okay, you've got it.

9 CHAIR MUNN: Now let's move on to 

10 Rev 1 Finding 8.

11 MR. HINNEFELD: Well, this is Stu 

12 Hinnefeld and I'll start here once again. And 

13 this had to do with is there additional evidence 

14 that this particular data column is a daily 

15 24-hour excretion?

16 And there is response here, refers 

17 to a document in SRDB which is the data 

18 dictionary for the database and a description 

19 of it, and that is attached. That SRDB 

20 document is attached and it's Pages 12 and 13. 

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146

1 So if you scroll down to the, see, 

2 there's the data field disintegrations per 

3 minute for 24 hours, and then I think the 

4 description's on the next page. No, this is 

5 the one. This is actually the one I was 

6 thinking of.

7 The next to the last entry there, 

8 position 70 to 78 as a numeric value for the 

9 disintegrations per minute for 24 hours to one 

10 decimal place." And so this was, I think, the 

11 database that the data was drawn from and this 

12 is the data dictionary for that database.

13 And so we felt like this is 

14 sufficient evidence that it's a 

15 disintegrations per minute for 24 hours' 

16 excretion and that the data are presented, you 

17 know, essentially to one decimal place. And so 

18 you essentially have to insert that in the way 

19 you look at the data.

20 Now if Joe's on, he can probably say 

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147

1 I did it wrong. But I don't know if he's on the 

2 phone yet or not.

3 CHAIR MUNN: Do we have Joe yet?

4 Apparently not.

5 MS. THOMAS: This is Elyse. Yes, I 

6 think he's on that other call, but Matt Arno may 

7 be on. Matt, are you on?

8 MR. ARNO: Yes, I'm on.

9 MS. THOMAS: Okay, yes. Can you 

10 explain?

11 MR. ARNO: Yes, that was an 

12 accurate explanation of what the data 

13 dictionary means and how we interpreted it.

14 MR. HINNEFELD: So anyway, so 

15 that's we presented and that's what we put in 

16 the database as our response, so we feel like 

17 there is adequate information to give us 

18 confidence that that data is dpm per day.

19 CHAIR MUNN: Is that acceptable for 

20 SC&A?

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148

1 DR. H. BEHLING: I guess what 

2 prompted this, and I'm not sure I can reconcile 

3 what I just saw on the screen here. But what 

4 prompted me to raise the question were data that 

5 I collected. Just sampling data that go back 

6 to 1951, where in the first column was the dpm 

7 per sample which turns out to be identical to 

8 the dpm per 24-hour period. And this is for 

9 1951.

10 And I mean that raised the question, 

11 does a dpm per sample necessarily equate, 

12 unless one were to sample in the case of 

13 reference man at 1,400 mL urine sample in saying 

14 this is what we saw in that sample. If it was 

15 a fraction of the 24-hour urine excretion value 

16 then I would have to say that does not apply.

17 And so I'm not really sure how that 

18 applies to other years, I only took a sample. 

19 So when I raised that question and I raised the 

20 question as a conditional question, I was 

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149

1 basically looking at 1951 data that only 

2 identifies, and I assume the primary source of 

3 that data really represents the dpm per sample 

4 which then is presumably transferred to mean 

5 the dpm per 24 hours.

6 And this is what my question was, 

7 can you be reasonably sure that a sample, that 

8 the activity per sample corresponds to a 

9 24-hour sampling of volume?

10 MR. HINNEFELD: Matt, do you have 

11 anything more to add?

12 MR. ARNO: That was the general 

13 practice at Oak Ridge National Lab was to 

14 collect a 24-hour urine sample. Per sample is 

15 per 24 hours regardless of volume that is the 

16 person's actual excretion over 24 hours.

17 MR. BARTON: This is Bob Barton. 

18 Just an observation. That reference that we 

19 were just looking at, it appeared as if there 

20 were two columns. One was the dpm per sample, 

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150

1 and then the next column over, after I get some 

2 filler space, was the dpm per day.

3 So it seemed like they were adding 

4 them both, both the per sample activity and then 

5 they were converting it over to dpm per day. So 

6 it looked like both values were there.

7 MR. ARNO: I mean pretty much the 

8 only exception to the 24-hour samples on these 

9 was tritium, so if you're looking at tritium 

10 data you'll see the difference, but for 

11 everything else pretty much per sampling per 

12 day are equal.

13 CHAIR MUNN: So is the feeling that 

14 the response is adequate? May we close this 

15 item?

16 DR. H. BEHLING: Well, I guess on 

17 the assumption that the care was taken, I can't 

18 imagine that all these urine samples were 24 

19 hours. Normally, you know, if a person shows 

20 up to work and you take a sample, if it's only 

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151

1 a partial 24-hour volume just adjust it or 

2 standardize.

3 So if a person at the end of a shift 

4 submits a urine sample for analysis and it turns 

5 out to be, let's say, 300 mL, you would then 

6 simply take the activity and then standardize 

7 it to 1,400 mL and say okay, that would be what 

8 you would see in a 24-hour sample. I just don't 

9 know if that was done. At this point I can only 

10 assume that that care was taken.

11 MR. BARTON: Couldn't they 

12 possibly have been overnight samples? I mean 

13 sometimes they, I could say, you know, give you 

14 a kit to take home.

15 DR. H. BEHLING: Yes. I mean 

16 that's a cumbersome approach to doing 

17 urinalysis is to ask people to walk around 24 

18 hours for a given day to collect this urine. 

19 I've done it myself. It's not very nice if 

20 you're obviously doing anything other than 

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152

1 staying at home.

2 So I always question when we talk 

3 about an activity for sample as representing a 

4 24-hour void. To me it's suspicious, because 

5 as I said it's not a very easy thing to do.

6 And I know that from experience in 

7 other areas we had serious problems, because I 

8 remember in some instances where people were 

9 trying to tell us that a 400 mL sample 

10 represented a 24-hour urine void sample, it's 

11 obviously not likely we were getting the truth.

12 MR. HINNEFELD: I could be 

13 facetious here and say that in Oak Ridge in 1951 

14 there was nothing to do except go home.

15 CHAIR MUNN: That's probably not 

16 too facetious. It's very close to reality.

17 DR. H. BEHLING: Well, given the 

18 uncertainty, I guess we will just have to give 

19 the benefit of the doubt to the people who were 

20 doing this that a 24-hour urine sample is also 

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153

1 representative by dpm per sample, and just 

2 assume that they obviously took all those 

3 variables into consideration.

4 CHAIR MUNN: All right, does anyone 

5 else have any further comment? If not, Steve, 

6 may we close this item? If so, Steve, will you 

7 please indicate that the issue was discussed 

8 and it was agreed to close the item at this 

9 meeting.

10 Is that okay with the other Board 

11 Members? Paul?

12 MEMBER ZIEMER: Yes, that's okay 

13 for me.

14 MEMBER BEACH: Yes, that's okay 

15 with me.

16 CHAIR MUNN: All right. Steve, 

17 can you accommodate us?

18 Thank you very much, Steve. If 

19 there's no further comment we will thank you 

20 very much for clearing up OTIB-34. We're going 

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154

1 to take our lunch break now, and due of the fact 

2 that we're running a little behind time, is 

3 there any objection to resuming on the hour?

4 Do you need longer than 35 minutes 

5 for your lunch?

6 MEMBER ZIEMER: Well, I don't.

7 MEMBER BEACH: I don't either.

8 CHAIR MUNN: All right, then let's 

9 resume at the next hour, whatever that is 

10 wherever you are, and we will see you back at 

11 that time. Thanks so much and have a nice 

12 lunch.

13 (Whereupon, the above-entitled 

14 matter went off the record at 1:26 p.m. and 

15 resumed at 2:03 p.m.)

16 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

17 (2:03 p.m.)

18 CHAIR MUNN: Our next item is our 

19 2:30 agenda item. Status on PER-0038 case 

20 audits. SC&A?

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155

1 MS. K. BEHLING: This is Kathy 

2 Behling. That is work in progress. 

3 Unfortunately I did not get that completed. 

4 It's been a busy month here. Sorry about that.

5 CHAIR MUNN: That's all right. 

6 That will be a carryover for next time.

7 MS. K. BEHLING: That was the 

8 Hooker Site Profile revisions and there were 

9 three cases that were selected for review. As 

10 I said, work is in progress.

11 CHAIR MUNN: Very good. We'll 

12 carry it over until next time, and we'll move 

13 on to OTIB-54, the reactor modeling report. 

14 NIOSH?

15 MR. HINNEFELD: Jim, that's you, 

16 isn't it?

17 DR. NETON: What's that, Stu?

18 MR. HINNEFELD: The reactor. The 

19 report.

20 DR. NETON: I thought ORAU was

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156

1 going to handle that with, who is it, Morris or 

2 --

3 MS. THOMAS: Bob Burns is on. This 

4 is Elyse.

5 MR. BURNS: All right. Well, for 

6 the reactor modeling report, internally that's 

7 our Report 67. That has been approved by DCAS 

8 and I believe issued as an official project 

9 document. So I'm not sure as to the status of 

10 it. I don't know if I have much more to add 

11 beyond that.

12 DR. OSTROW: Hi Bob. This is Steve 

13 Ostrow. I haven't seen the report so it's out 

14 of ORAU whenever, but I don't think it's hit the 

15 street yet.

16 MR. BURNS: Okay.

17 MS. MARION-MOSS: Steve, this is 

18 Lori. The report has just been approved by 

19 NIOSH and it's in the process of being published 

20 to the public.

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157

1 DR. OSTROW: Okay, great, so we 

2 should see it soon. Okay, the way I understand 

3 it, the reactor modeling report covers the 

4 Findings 1 through 4, so that'll be good to see. 

5 I think NIOSH also had action items from the 

6 last meeting and was supposed to respond to 

7 Findings 5, 9 and 10 also.

8 CHAIR MUNN: Yes, that's correct. 

9 That's our next item. So do I understand 

10 correctly that next time we will have the 

11 reactor modeling report which as pointed out 

12 covers Findings 1 through 4?

13 MS. MARION-MOSS: Correct.

14 CHAIR MUNN: Very good. It's on 

15 the schedule for carry-on next time.

16 DR. OSTROW: Maybe I can say 

17 something, Wanda, also. After the last 

18 meeting we had, I think which was April 16th, 

19 we had a technical call, SC&A, ORAU and NIOSH, 

20 on May 13th on Findings 5 and 10.

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158

1 And just a brief summary, that SC&A 

2 recommended that we close Finding 10. And 

3 Finding 10 had one part in it where it referred 

4 to Finding 5 about release fractions, but we 

5 wanted -- NIOSH and ORAU agreed that release 

6 fractions will be handled in Finding 5 and 

7 whatever's left for Finding 10 we agreed to 

8 close it.

9 CHAIR MUNN: That's good 

10 information, we appreciate it. I see nothing 

11 is on my screen being shared.

12 DR. OSTROW: Finding 5 is still 

13 open. That's release fraction. And Finding 9 

14 is still open. It has to do with the workbook 

15 tool.

16 Scott Siebert had updated the BRS on 

17 August 22nd with a comment on that, a long 

18 comment, and I don't want to speak for NIOSH and 

19 ORAU. But it seemed to me that the basic thrust 

20 was that the workbook tool works now.

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159

1 We didn't check it out yet, but we 

2 had a few comments on it last time. So we would 

3 like to take a little time and just check it out 

4 to see if it does work correctly now.

5 CHAIR MUNN: So SC&A is going to 

6 respond to Item 9 next time?

7 DR. OSTROW: Yes.

8 CHAIR MUNN: Is that correct?

9 DR. OSTROW: Yes, we'll go ahead 

10 and do it. I think Ron Buchanan had looked at 

11 the workbook tool last time and we had a few 

12 comments that the workbook tool wasn't totally 

13 updated from the last revision of the OTIB. 

14 And Scott Siebert seemed to 

15 indicate that it has been updated correctly, 

16 but we'd like to take a look at it and report 

17 back to you guys just to make sure that it works 

18 now correctly.

19 CHAIR MUNN: All right. So my list 

20 tells me now that we're going to see the reactor 

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160

1 modeling report next time, and next time we're 

2 going to see Finding 5 and SC&A will report on 

3 the remainder of Finding 9. And right now we 

4 are going --

5 DR. OSTROW: We'd like to close 10. 

6 We recommend that we close 10.

7 CHAIR MUNN: We will do that right 

8 now. We just need to find it. And we're on our 

9 way.

10 DR. OSTROW: Here, Finding 10 

11 referred to a large generic one. I think John 

12 Mauro had brought that up originally that the 

13 question that we sort of believe that the OTIB 

14 is conservative, worker-friendly and all that, 

15 claimant-friendly, but we weren't sure on 

16 whether it reflected reality or whether it was 

17 too claimant-friendly or whatever.

18 But after some discussions with 

19 NIOSH there's nothing very specific to point to 

20 so we'd like to drop Item 10, Finding 10.

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161

1 CHAIR MUNN: All right. So we're 

2 correct, that Item, actually 36 --

3 (Simultaneous speaking)

4 CHAIR MUNN: Correct?

5 DR. OSTROW: Right.

6 CHAIR MUNN: And it's been 

7 discussed by the contractor and the agency as 

8 well as the Subcommittee.

9 DR. OSTROW: Yes, and that was on 

10 April 13th we had that technical call. May 

11 13th, excuse me. May 13th.

12 CHAIR MUNN: All right. Okay, 

13 then I see the way we have this broken out, 

14 Steve, we have multiple sections. I don't know 

15 if we have one Finding 10. We have their 

16 response there which is --

17 DR. OSTROW: Yes. The one from May 

18 14th which is right in the middle of the screen. 

19 Don't move it, Steve Marschke. Keep it.

20 CHAIR MUNN: Yes, it's right there. 

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162

1 Yes, it's there. And it's recommended the 

2 issue be closed. And Paul, Josie? Any 

3 negative response to that suggestion?

4 MEMBER BEACH: No, I don't have any 

5 negative responses, Wanda.

6 CHAIR MUNN: All right. Paul?

7 MEMBER ZIEMER: And I agree it 

8 should be closed.

9 CHAIR MUNN: All right, very good. 

10 Let's just indicate on this date that the 

11 Subcommittee agrees the item is closed.

12 Yes, I think that's all we need.

13 DR. OSTROW: Looks good to me.

14 CHAIR MUNN: Very good. That tops 

15 off our list, and I believe that the only thing 

16 we have of OTIB-54.

17 DR. OSTROW: That's correct.

18 CHAIR MUNN: Very good. Let's 

19 move on then to Kathy's PER reviews. Kathy, 

20 you want to start us off with PER-0042?

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163

1 MS. K. BEHLING: Actually, Hans is 

2 going to do the PER reviews.

3 CHAIR MUNN: All right, very good.

4 DR. H. BEHLING: In fact I'm stuck 

5 with three PERs, so you can love me or hang up.

6 CHAIR MUNN: Hans, we love you. We 

7 wouldn't hang up for all the tea in China. 

8 Please carry on.

9 DR. H. BEHLING: Well, we'll talk 

10 about that after the last PER is discussed.

11 CHAIR MUNN: All right, thanks.

12 DR. H. BEHLING: Okay, we'll start 

13 out with PER-0042 which is the Linde Ceramics 

14 Plant TBD revision. And just as a brief 

15 update, the Linde Ceramic Plant was actively 

16 producing uranium oxide as a coloring agent 

17 before it was contracted to the AEC to produce 

18 or refine uranium materials and both from 

19 domestic ores and foreign ores.

20 And one of the things that sort of 

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164

1 complicated the whole description of what took 

2 place was the fact that there were numerous 

3 periods, and also in addition to the fact that 

4 it was an AWE, there was also a component of 

5 Linde Ceramics that was considered a DOE 

6 facility known as Tonawanda Laboratory. 

7 Anyway let me just briefly discuss some 

8 of the issues of relevance here. The PER-0042, 

9 in essence, considered changes that were made 

10 between the current revision, which is Revision 

11 3, and all previous revisions to the TBD. And 

12 in total there were a total of five revisions 

13 following the initial.

14 And as part of the original Rev 0 of 

15 the TBD which SC&A reviewed, we were also party 

16 to all the changes. And one of the things that 

17 has to be kept in mind here is that this PER 

18 somehow differs from previous PERs.

19 The successive revisions into Rev 1 

20 were changes that either increase, decrease or 

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165

1 both increase and decrease estimates of dose. 

2 But the most important changes that occurred 

3 were the decrease in potential internal 

4 exposures due to insufficient monitoring data 

5 that ultimately led to three SEC Classes that 

6 span from the period of October 1, 1942 through 

7 December 31st, 1969. So you have a very 

8 lengthy residual time period during which was 

9 covered the SEC petitions of Classes. The 

10 changes that occurred throughout this time 

11 period to the TBD involved revisions and 

12 changes that were extensively discussed and 

13 resolved in the total of 20 different 

14 conference and teleconference meetings that 

15 occurred over a five-year period.

16 And these meetings were conducted 

17 by the Board's Linde Ceramics Work Group but was 

18 heavily patronized by the people from NIOSH and 

19 our contractor SC&A personnel.

20 And I want to just emphasize a 

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166

1 couple statements here. During the last 

2 teleconference that occurred in June 2012, the 

3 Linde Work Group, NIOSH and SC&A agreed that all 

4 TBD issues had been resolved.

5 And Revision 3 of the TBD, Linde 

6 Ceramic TBD, was issued six weeks later on July 

7 26, 2012, and was followed up by the DCAS 

8 PER-0042 on November 16th, 2012.

9 So the prompting of the SEC petition 

10 was really based on the successive changes to 

11 the original TBD that occurred in 2005 and 

12 culminated in the revised Rev 3 that was issued 

13 in 2013.

14 With regard to the Subtask 1 that we 

15 normally address in our review of the PER, SC&A 

16 has no finding pertaining to the issue of how 

17 PER-0042 came to be.

18 With regard to Subtask 2, which we 

19 are required to assess NIOSH's specific method 

20 for corrective action, we have to look at this 

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167

1 particular PER slightly differently in light of 

2 the fact that we were party to all of the issues 

3 that led up to the revision of 0.3 of the TBD.

4 However, we did not necessarily 

5 review TBD, the revision of TBD as Rev 3 and that 

6 is really the source for this PER. And what we 

7 intend to do here in this PER, for those who have 

8 read the review of the PER-0042, is that we went 

9 through the Revision Number 3 as if it were a 

10 new TBD because all subsequent revised dose 

11 estimates were based on that.

12 So I will just briefly go through 

13 each of the time periods and issues that we 

14 addressed. The first time period was the 

15 internal exposures for the period of November 

16 1, '47 through December 31st, '53, and that is 

17 the operating time period during which it was 

18 assumed that the bioassay data for all workers 

19 involved in, exposed to uranium, radium and 

20 radon exposures were insufficient to really do 

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168

1 dose reconstruction.

2 However, and this is important 

3 because it will come back later on in a 

4 different format, but the statements are in the 

5 TBD. In spite of the, and I'll read it. And 

6 I'm not sure, for those who may be following the 

7 review of PER-0042 online, I'm on Page 12 of the 

8 writeup, the statements are as follows.

9 In spite of the paucity of bioassay 

10 data and the establishment of three SEC 

11 Classes, the TBD acknowledged that uranium 

12 bioassays are available for a limited number of 

13 workers for the period of '47 through 1950, and 

14 if uranium bioassay are available for a worker 

15 they should be used to reconstruct an 

16 individual dose. And the same thing applies to 

17 radium and to radon exposures.

18 And the point that I want to make 

19 here is that this period is covered under the 

20 SEC, and yet because of the fact that there are 

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169

1 a limited amount of bioassay data involving 

2 uranium, radium and radon exposures, the TBD 

3 specifically states that a partial dose 

4 reconstruction may be available and may be done 

5 for workers for whom these data are available.

6 And this is not an issue here. I 

7 just wanted to make that statement because 

8 later on I'm going to come back to another area 

9 that involves the residual period that may be 

10 relevant to the issues that I've just raised 

11 here.

12 So in context with the Subtask 2, 

13 again SC&A found no inconsistencies and no 

14 areas for partial internal dose estimates for 

15 the time period '47 through '53.

16 For the external exposures to Linde 

17 Ceramic period for the duration of '42 to '53, 

18 film badges were used to monitor some workers 

19 for beta dose during select time periods when 

20 the African ore was produced. And 

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170

1 for, I guess as a summary, for the external dose 

2 reconstruction, NIOSH simplified and 

3 consolidated a large volume of information that 

4 was introduced in Table 4-1 through 4-23 into 

5 a single table that is 4-24, for all years going 

6 from '42 to '53 by regrouping various job 

7 workers into high, medium and low exposure 

8 groups. And as a convenience to the reader, I 

9 have included Table 4-24 as Table 5 in my 

10 summary for those who may want to take a look 

11 at that.

12 So in essence, for the external 

13 exposure data, the various data that were 

14 introduced as Table 4-1 through 4-23 were 

15 consolidated and simplified into a single table 

16 that was identified as 4-25, and in my writeup 

17 was reproduced as Table 5. So I may make 

18 reference to that in a few minutes. 

19 Okay, I do have in addition to two 

20 findings there was a single observation, and 

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171

1 what I wanted to do is to bring that to the 

2 attention of NIOSH for simply correcting the 

3 text that appears in the TBD.

4 And that involves, and I'll go to, 

5 to simplify it, to Page 17 of my writeup where 

6 there is a discrepancy between information that 

7 was expressed in Table 4-6 which erroneously 

8 cites the value of 26 rem per year to the hands 

9 and forearms for the loader. That's a worker 

10 category.

11 In fact, the correct value, 74 rem 

12 per year, is given in the fourth bullet on Page 

13 45, so it's strictly an observation and a 

14 correction.

15 A second correction under 

16 Observation 1 is that the third bullet on Page 

17 45 of the TBD incorrectly cites 221 rems per 

18 year to the hands and forearms to the Step 2 

19 process operator, and the correct value is 158 

20 rem per year as shown in Table 4-6.

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172

1 The benefit or the good part is that 

2 these values were actually not incorporated in 

3 the final table, which I assume is really the 

4 source for the dose reconstructor to extract 

5 year by year dose to the various groups of 

6 people who are identified as such. So this 

7 observation is strictly a correction of two 

8 errors that are identified in the text of the 

9 TBD.

10 So let me go on now. We just 

11 finished, as I said, there no findings for the 

12 operating period with the exception of the 

13 observations that I just cited and are 

14 described on Page 17 of my writeup.

15 The next time period is the exposure 

16 estimates from the residual contamination 

17 after 1953. And here's where I will come back 

18 to the issue of a partial dose reconstruction 

19 that was ultimately identified as the first 

20 finding that I'll come to in a moment.

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173

1 But I do want to read a following 

2 item that I think is important to understand in 

3 behalf of that first finding. In Section 6 of 

4 the Linde Ceramics TBD it starts out with the 

5 following statement.

6 This section develops parameters 

7 for reconstruction of doses due to internal and 

8 external exposure at the ceramics plant 

9 starting January 1, 1954, which is the 

10 beginning of the residual period.

11 NIOSH has determined with 

12 concurrence from the secretary of DHHS that 

13 internal doses at the Linde Ceramic Plant 

14 cannot be reconstructed with sufficient 

15 accuracy from the beginning of 1954 to the end 

16 of 1969.

17 If monitoring data are available 

18 for workers who are included in the SEC dose, 

19 including the SEC Class dose is to be 

20 reconstructed as appropriate based on such 

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174

1 data. However, such dose reconstructions are 

2 still considered partial dose reconstruction 

3 because NIOSH has determined that internal 

4 exposures during the SEC Class period 1954 

5 through '69 cannot be bounded.

6 And it's important to take that into 

7 consideration with what I previously stated 

8 that during the operation period, as I 

9 mentioned earlier, internal dose 

10 reconstruction for uranium and product as well 

11 as radon could be added even though those years 

12 of the operating period were also covered by the 

13 SEC.

14 And here again by and large they 

15 said beginning from 1954 to the end of 1969, if 

16 data are available a partial dose 

17 reconstruction may be added. So having said 

18 that I will go and discuss what was done in terms 

19 of estimates of internal exposures. 

20 When I looked at the data, NIOSH elected 

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175

1 to avoid estimating internal exposures for the 

2 period, for the 16-year period of 1954 to 1969, 

3 and did something that sort of puzzled me.

4 In terms of uranium, NIOSH employed 

5 the following information assumptions for 

6 dividing inhalation intakes for the residual 

7 period that no longer starts in 1954, but 

8 actually was decided to represent only the 

9 years from 1970 to 2009, and this is what they 

10 did.

11 They by and large said that because 

12 of the SEC, I assume because of the SEC period 

13 that extends through 1969, the residual period 

14 between '54 and '69 is skipped.

15 And so what they did, they said you 

16 will not get any internal exposure but we're 

17 going to do the following. We're going to take 

18 a maximum air concentration of 161 dpm per cubic 

19 meter that was observed in 1950. This is four 

20 years before the beginning of the residual 

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176

1 period.

2 And then in 1976, a survey of 

3 Building 30 showed air concentrations of 0.0422 

4 dpm per cubic meter. And so they used in 1950 

5 data point that actually precedes the residual 

6 contamination period that starts in 1954 and 

7 transported the 1950 data points and assigned 

8 it to 1970. And that to me makes no sense.

9 And then by extrapolation used the 

10 data to cover the period from 1970 to the 

11 balance of the period of, that goes all the way 

12 to, I guess, 2009.

13 And I have no way of accepting or 

14 understanding this in light of the fact that why 

15 would you take a 1950 data point and without 

16 modifying that data point assign that same data 

17 point to 1970 and then use the extrapolation of 

18 that data point to a 1970 data point for all 

19 years and assume that this is how you're going 

20 to assign internal exposure?

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177

1 And the same thing was done with 

2 radon, where again because there were no radon 

3 surveyed for the years '54 to '69, NIOSH 

4 employed the radon air concentration value of 

5 10 picocuries per liter and which corresponds 

6 to a radon exposure rate of 0.48 working level 

7 year that had been assumed for Linde workers for 

8 the years '47 through '53, and assigned that 

9 same value again to 1970.

10 And then using a 1981 data point 

11 again to determine what the source term 

12 depletion rate would be for those two data 

13 points and assigned these data for the entire 

14 residual period. And so I find that very 

15 puzzling.

16 And so in light of the fact that 

17 there was an encouragement to use any form of 

18 available data for partial dose reconstruction 

19 as was done during the operational period, if 

20 there were bioassay data for uranium and radon 

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178

1 exposure values that were considered 

2 incomplete but for a partial was used.

3 And for the residual period, even 

4 though we have data that predate, actually, in 

5 both instances the uranium and the radon 

6 exposure residual period by several years and 

7 then transport those two data points for 

8 uranium and radon to a time period that follows 

9 the SEC period that terminated in the end of 

10 1969 and start off with that.

11 And so to me that makes no sense at 

12 all and it violates by and large the 

13 recommendation that defines OTIB-70. So 

14 Finding Number 1 which appears on Page 18, I 

15 state that SC&A questions NIOSH's restrictive 

16 methodology to deriving internal exposures to 

17 ceramic plant workers from residual 

18 contamination.

19 The availability of data that 

20 satisfied criteria cited in OTIB-70 allow for 

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179

1 the assignment of internal exposures to uranium 

2 and to radon inclusive of years 1954 to 1970, 

3 in spite of the fact that this time period is 

4 part of the SEC period.

5 And so as far as I'm concerned, it 

6 doesn't seem to agree with the statements that 

7 appear in the TBD and it does not comply with 

8 the requirements of OTIB-70.

9 If NIOSH would like to comment, I 

10 guess it's a good time to try to get an 

11 understanding of why that was done.

12 CHAIR MUNN: Thank you, Hans. I 

13 don't know whether NIOSH is prepared to comment 

14 yet, not having had an opportunity to provide 

15 a response. But if you do have comments, let's 

16 hear them.

17 MR. HINNEFELD: Well, this is Stu. 

18 I would just offer that, you know, we got these 

19 reports, what, a week or so ago and we've not 

20 really distilled them very much.

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180

1 I don't know, Jim, if you had any 

2 reaction that you wanted to get into on this 

3 one?

4 DR. NETON: No, like I say, I agree 

5 with you. We just got them a week or so ago, 

6 and it's somewhat complicated because this is 

7 one of the few if only sites that I can remember 

8 that we added an SEC during the residual period. 

9 So I'll have to go back and look at that pretty 

10 carefully.

11 DR. H. BEHLING: Yes, I was trying 

12 to scan OTIB-70 and try to understand whether 

13 or not OTIB-70 would be exempted from the 

14 recommendations for defining exposures due to 

15 six independent protocols that they offer you 

16 and say that this will not apply during an SEC 

17 period.

18 But I didn't see anything like that, 

19 and in light of the language that was used 

20 throughout the TBD that says a partial dose 

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181

1 reconstruction may be done if the available 

2 data exists that allows you to do so, and I 

3 consider the data points that were obtained for 

4 the residual period that predate the actual 

5 start of the residual period of 1954 certainly 

6 would satisfy the criteria of OTIB-70.

7 DR. NETON: Well, again, it's 

8 complicated because that blanket statement 

9 that you read we include in all SECs, we say, 

10 and really it applies. I don't know if it's an 

11 individual monitoring data or not, but that's 

12 the intent, bioassay data not air sampling 

13 data. And so that's one issue there. 

14 But again it's complicated because you 

15 have an SEC period that covers, a residual 

16 contamination period that's in the middle 

17 between a covered period and an ending residual 

18 period.

19 So I'll have to go back and look. 

20 And I understand what you commented on about the 

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182

1 OTIB-70 and extrapolation through the SEC 

2 residual period. But again I'll have to go 

3 back and look at it a little more closely.

4 DR. H. BEHLING: Yes. If it turns 

5 out that the SEC period precludes the use of 

6 OTIB-70 that's okay. And if that's the case, 

7 then those two starting data points that 

8 predate the SEC period by several years for both 

9 the uranium and the radon issue should as a 

10 minimum then be reduced to, I mean we're talking 

11 about a 20-year time period. You can't 

12 transport uranium data that was taken in 1950 

13 and then say, oh that same value now applies to 

14 1970, and then decrease it in a rapid fashion 

15 that corresponds to a subsequent data point. 

16 That makes absolutely no sense.

17 DR. NETON: Yes, I hear what you're 

18 saying. We just need to look at it a little 

19 more closely.

20 CHAIR MUNN: All right, I'm 

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183

1 assuming that we do not have those findings as 

2 yet posted on the BRS, or am I incorrect in that?

3 MS. K. BEHLING: This is Kathy, and 

4 no, I did not get a chance to do that. I 

5 apologize.

6 CHAIR MUNN: All right.

7 MR. HINNEFELD: Wanda, that's 

8 related to what we did at the start of the 

9 meeting. We only assigned them, quote, in the 

10 system at the start of the meeting and so there 

11 was no way they could have entered them until 

12 --

13 CHAIR MUNN: That's why I was 

14 assuming that they weren't there, Stu, not 

15 being able to check it myself right now. But 

16 our first action item is to add those two 

17 findings to the BRS, and our next action then 

18 will be to anticipate a response from NIOSH for 

19 those two findings.

20 Any other comments with respect to 

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184

1 the Linde PER?

2 DR. BUCHANAN: Yes, this is Ron 

3 Buchanan at SC&A.

4 CHAIR MUNN: Yes, Ron.

5 DR. BUCHANAN: Hans worked on that 

6 part. I worked on part of it too, and so I 

7 worked on Subtask 3 and 4. And so do you want 

8 me to cover that section at this time?

9 CHAIR MUNN: I think that's 

10 appropriate, Ron, yes.

11 DR. H. BEHLING: Well, can I 

12 interrupt, Ron?

13 CHAIR MUNN: Oh, yes.

14 DR. H. BEHLING: I'm not finished 

15 quite yet. I was going to turn you over in 

16 about five minutes.

17 DR. BUCHANAN: Oh, okay.

18 CHAIR MUNN: My mistake, Hans. 

19 I'm sorry. I didn't mean --

20 DR. H. BEHLING: No, no, no.

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185

1 CHAIR MUNN: That's fine.

2 (Simultaneous speaking)

3 DR. H. BEHLING: I should have 

4 stated that up front that Subtask 4 and 5 will 

5 be covered by Ron.

6 CHAIR MUNN: Very good, yes, and go 

7 on from there. Are we done with your coverage 

8 of your portion of the report? I don't want to 

9 shortchange you, but if you have more to say 

10 please continue.

11 DR. H. BEHLING: Yes. The second, 

12 I told you there was an observation that I 

13 identified in the first finding, and I'm about 

14 to briefly discuss Finding Number 2 without 

15 going through a lot of things. But the Finding 

16 Number 2 centers around the utility tunnel 

17 exposures involving internal exposure to 

18 uranium and to, and in progeny as well as to 

19 radon exposures.

20 And let me just briefly, and for 

NEAL R. GROSS

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186

1 those who may be following me I'm on Page 19, 

2 and you can quickly, because when I talk about 

3 numbers it's very hard to somehow mentally get 

4 an understanding, and it would certainly help 

5 if you would actually look at the writings and 

6 the description of the issues that are being 

7 discussed.

8 So right now I'm on Page 19 and I'm 

9 discussing utility tunnel exposures. And for 

10 internal exposures to uranium and progeny, the 

11 assumption was that for modeling the annual 

12 exposure times were identified as 1,000 hours 

13 per year for trade workers and 100 hours per 

14 year for all others. And there were other 

15 assumptions which are not relevant to the 

16 discussion.

17 And those estimates were based on 

18 tunnels surveyed, beta measurements on 

19 surfaces during, in the tunnels. And for the 

20 radon exposures, NIOSH derived radon 

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187

1 concentrations and worker exposures for two 

2 independent source terms, and this is really 

3 the key here to Finding Number 2.

4 The two source terms were based on 

5 radium-226 surface contamination inside the 

6 tunnel. So you have activity, contamination 

7 activities that were on the inside of the 

8 tunnels that were used by trade workers for 

9 during work times as well as transit times for 

10 other people.

11 The second source term for radon was 

12 from radium-226 levels in the soils that 

13 surround the underground tunnels. So there 

14 are two independent source terms, interior 

15 contamination of the tunnels themselves, and 

16 contaminated soil that surround the tunnels 

17 that just like in a house that in itself is not 

18 contaminated but radon permeates from the 

19 surrounding soil of a basement, et cetera. So 

20 those are the issues.

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188

1 And quite frankly I can make it 

2 quickly an issue here that the 100 hours per 

3 year for trade workers and 100 hour per year for 

4 all others is a reasonable assumption. 

5 But here's what happened. In the case of 

6 the radon exposures from surface 

7 contamination, those were the actual exposure 

8 time periods used, 100 hours per year or 50 

9 percent of a full work year for trade workers 

10 and 100 hours per year, which is five percent, 

11 for all others, respectively.

12 When it comes to radon exposures due 

13 to contaminated soils, I'll read to you what the 

14 issues were here. It was assumed, and I'm 

15 quoting directly here.

16 It was assumed that trade workers 

17 and laborers worked in these tunnels doing 

18 maintenance work for eight hours per workday, 

19 and in parentheses, two months of the year, and 

20 for the other ten months a transit time of ten 

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189

1 minutes per workday using the tunnels to get 

2 between buildings. For all other workers, 

3 only the transit time of ten minutes per workday 

4 would be applied for year-around.

5 And they ended up resulting into 

6 estimates of working level months per year for 

7 trade workers and for others. And if you do a 

8 simple calculation that corresponds to the 

9 eight hours per workday for two months and the 

10 ten minutes transit time for the balance of the 

11 ten months, you only end up with 375 hours per 

12 year for the trades worker and 41.7 hours for 

13 all others.

14 And of course you cannot separate 

15 these two source terms. I mean if you're in the 

16 tunnel for source term number one, you're going 

17 to be exposed not just only to the radon that 

18 comes from the contamination that's inside the 

19 tunnel, you're also going to be exposed to radon 

20 that permeates the tunnel from contaminated 

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190

1 soil. So you cannot separate these two source 

2 terms in terms of exposure time.

3 So in essence, my Finding Number 2 

4 states the following, and I'm on Page 20. The 

5 assigned radon exposure rates in Table 6-11 and 

6 6-12 are correctly based on the identical 

7 occupancy of 50 percent and five percent which 

8 translates to 100 hours per year, and 100 hours 

9 per year for trade workers and all others, 

10 respectively, and not by the stated occupancy 

11 factors described in the text.

12 So once again you have a situation 

13 here where the actual numbers are correct, but 

14 the supporting time frames that support those 

15 numbers are incorrect in the text. 

16 Again I don't expect a response, but this 

17 is strictly a technical error that says the 

18 actual numbers that appear in Table 4-24 use the 

19 consistent time frames of 1,000 hours and 100 

20 hours, respectively, but the text is incorrect 

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191

1 in stating, state times for the second source 

2 term that simply do not apply to those hours.

3 At this point, if there's no comment 

4 from NIOSH I will turn this over to Ron Buchanan 

5 for just a quick discussion of Subtask 3 and 

6 Subtask 4.

7 MR. HINNEFELD: No, we don't have 

8 any comment. We can go on to Ron.

9 DR. BUCHANAN: Okay, thank you. 

10 This is Ron Buchanan, SC&A. And of course 

11 Subtask 3 has to do with the approach that NIOSH 

12 include the correct number of claims to 

13 reevaluate.

14 While in this case is unusual, I 

15 stated earlier in that there was so much change 

16 in the TBD that they reevaluated all the claims 

17 that had qualified.

18 Now it's kind of hard to go back and 

19 determine how many claims are actually on the 

20 drawing board in this. I think it's July of 

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192

1 2012 when the TBD was issued in the latest 

2 revision.

3 And so what I did is I went back and 

4 seen if what they said made sense or if there's 

5 any contradiction to that and what's available 

6 on the database at this time, and I found no 

7 contradiction.

8 And that my best estimate was that 

9 there was about 250 claims had been submitted 

10 and DRs performed in July of 2012 and that 134 

11 of these had PoCs better than 50 percent. And 

12 so we don't need to go back and revisit those. 

13 So that leaves 116 claims that needed to be 

14 evaluated.

15 Now 38 of these had SEC cancers only 

16 and so those would be paid and so you would not 

17 reevaluate those. Now some of them had SEC 

18 cancers plus non-SEC covered cancers, so we 

19 want to reevaluate those because they might be 

20 paid for medical benefits under the non-SEC 

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193

1 cancers.

2 So that left 78 claims, and I tried 

3 to kind of list of those there on Page 21 of our 

4 report in decreasing numbers. And so it left 

5 78 original dose reconstructions with PoCs less 

6 than 50 percent that need reevaluated.

7 They did reevaluations on all 78 

8 cases. Seventy four of those resulted in the 

9 PoC being less than 50 percent as the original 

10 DR indicated but with the new TBD 

11 recommendations, and four of them came out with 

12 PoCs greater than 50 percent.

13 And two of those four had SEC 

14 covered cancers and also non-SEC covered 

15 cancers, and so they would qualify for the 

16 medical benefits if necessary there. Two of 

17 them had no SEC cancers to them, and so one of 

18 them was greater than 50 percent so that would 

19 be available for compensation.

20 The other one was kind of an unusual 

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194

1 case in that originally the original DR was less 

2 than 50 percent, when they came back and did it 

3 with a revised TBD is was greater than 50 

4 percent and DOL sent down a letter saying that 

5 the employment period was incorrect and that 

6 they decreased the employment period so the PoC 

7 went below 50 percent on that.

8 And so that was our analysis of 

9 Subtask 3. We felt that NIOSH did what they 

10 needed to do. They reevaluated all the claims 

11 that had been done before July of 2012 and went 

12 down the right process, so we had no findings 

13 in that section. And we agreed other than the 

14 findings Hans said in the TBD revision.

15 As far as selecting the cases, we 

16 felt that that was correct. Any questions on 

17 that?

18 CHAIR MUNN: None here.

19 DR. BUCHANAN: Okay. And so that 

20 brings us to Subtask 4 on Page 23. And so, in 

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195

1 this section, we recommend that SC&A audit two 

2 of the cases that were below 50 percent to see 

3 that the TBD Revision 3 was correctly applied.

4 Now, this will mostly consist of a 

5 complete audit of the cases because there was 

6 so many changes that it was completely 

7 reworked. And so we won't just do a focused 

8 audit like we do in some PERs where we just look 

9 at internal plutonium or something. In this 

10 case we'll have to look at the whole set and 

11 determine that it was done just like we do 

12 during the audit process for other cases. 

13 And another option, we think we'd 

14 probably recommend two of those that the Board 

15 would work with NIOSH to assign to us to audit, 

16 and then perhaps audit that one case that was 

17 below 50 and then greater than 50 then less than 

18 50, to make sure that the final DR on that was 

19 actually less than 50 percent according to the 

20 new TBD, the Rev 3.

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196

1 And so that's our conclusion on this 

2 PER.

3 CHAIR MUNN: Thank you so much, 

4 Ron. Any comment from any source?

5 MR. HINNEFELD: This is Stu. I 

6 mean, there aren't different flavors there, 

7 right, like we'd need one from Column A and one 

8 from Column B in picking these two? It's just 

9 any two?

10 DR. BUCHANAN: Right. Since 

11 they'll undergo a complete audit, any two. And 

12 then, of course, the third one would be that 

13 particular case.

14 MR. HINNEFELD: Okay. There's a 

15 new app that shows cases that were reviewed 

16 under PERs. Do you guys just want to select 

17 them yourself? If you can look on our Staff 

18 Tools page.

19 DR. BUCHANAN: Yes.

20 MR. HINNEFELD: Let's see what I 

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197

1 can get here. If you look on our Staff Tools 

2 page, there should be something called -- let 

3 me look for it a minute. I saw it just the other 

4 day. Program Evaluation Reports. That makes 

5 sense.

6 DR. BUCHANAN: Yeah.

7 MR. HINNEFELD: One of the buttons, 

8 like Board Review System is a button.

9 DR. BUCHANAN: Okay.

10 CHAIR MUNN: Sounds like a logical 

11 thing.

12 DR. BUCHANAN: And it'll have the 

13 cases that were associated with that?

14 MR. HINNEFELD: Click on Program 

15 Evaluation Reports, you get a list that 

16 actually looks like the Board Review System, 

17 but it's a list of the PERs that have been done.

18 And if you find the one you're 

19 interested in and press the select button, it 

20 will display all the cases that were 

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198

1 reevaluated under that. And it includes the 

2 files of the reevaluation. There's a link to 

3 those files as well.

4 DR. BUCHANAN: Okay. With the 

5 Work Group's approval, I will address two 

6 cases, the 71 and the one case that had the 

7 different PoCs at different times.

8 MS. K. BEHLING: This is Kathy 

9 Behling. Should we proceed with that or do we 

10 wait until there's been some discussion on the 

11 two findings?

12 CHAIR MUNN: It appears to me that 

13 you're going to need to complete the 

14 reevaluation of the audits, and under any 

15 circumstance, how do the other Board Members 

16 perceive that? Any differently?

17 MEMBER BEACH: No, not here, Wanda.

18 MEMBER ZIEMER: That wouldn't 

19 affect what they do on this, would it?

20 CHAIR MUNN: I wouldn't think so. 

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199

1 You're still going to have two cases that 

2 require -- that should have audit. It seems to 

3 me that the two could occur in parallel.

4 DR. H. BEHLING: Yeah, there's a 

5 significant difference between what may have 

6 been done and the two findings really involve 

7 the residual periods that at this point 

8 eliminates any consideration for exposure for 

9 the years '54 through '69. And then that could 

10 impact at least a case that's very close to 

11 being compensated.

12 CHAIR MUNN: So you're suggesting 

13 that we wait until we've addressed the 

14 findings?

15 DR. H. BEHLING: Yeah. Because 

16 we're potentially biasing in our review of 

17 cases that do not consider potential exposures 

18 from residual contamination for years '54 

19 through 1959, if it turns out that NIOSH will 

20 concede that issue in saying we could do a 

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200

1 possible dose reconstruction during that 

2 period of the SEC period for some residual 

3 contamination.

4 MR. KATZ: This is Ted. Without 

5 speaking to that, because I wouldn't make any 

6 assumption about that, but it's going to make 

7 no difference auditing whether or not how the 

8 other two findings come out.

9 It's going to make no difference, 

10 because the purpose of the audit isn't to 

11 determine if the case would change, it's just 

12 to determine whether the procedures were 

13 applied correctly. And you're not going to be 

14 auditing a procedure that's in contention for 

15 that. So I think you can do the audit now. It 

16 will make no difference.

17 MS. K. BEHLING: This is Kathy. 

18 And, yes, that's correct. And if they were to 

19 make some change to the residual period, there 

20 will be another PER issued.

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201

1 MR. KATZ: Exactly.

2 MS. K. BEHLING: I would assume. 

3 So, yeah, okay. I just wanted to be sure that 

4 we could go on parallel paths here. That's 

5 fine.

6 CHAIR MUNN: We see no reason why 

7 not. So our actions will show two findings 

8 that need to be posted and will require a NIOSH 

9 response, and the audit of two cases will 

10 proceed.

11 DR. BUCHANAN: Just to clarify, do 

12 you want to do just two cases rather than the 

13 third one involving the one that went up and 

14 down on the PoC?

15 MR. KATZ: Ron, can you just 

16 explain for everybody, why does that make that 

17 -- why should that be audited?

18 DR. BUCHANAN: Well, it bothered me 

19 that it was less than 50 percent, greater than 

20 50 percent and then went back to less than 50 

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202

1 percent. And I just wanted to point it out. I 

2 mean, if the Work Group doesn't want that 

3 checked out that's fine. It was kind of an 

4 anomaly compared to the rest of them.

5 CHAIR MUNN: Well, it was. But by 

6 the same token, since the Department of Labor 

7 has reduced the amount of allowable work time, 

8 then it seems to me it's a fairly clear-cut 

9 rationale.

10 DR. BUCHANAN: Okay.

11 CHAIR MUNN: I personally don't see 

12 any compelling reason to pursue that further. 

13 Paul?

14 MEMBER ZIEMER: No, I agree.

15 CHAIR MUNN: Josie?

16 MEMBER BEACH: Well, I guess I'm 

17 kind of at a loss on that. I think that there's 

18 no reason why we shouldn't do a third audit if 

19 SC&A thinks that it's logical to do that.

20 MR. KATZ: Well, I mean, it's more 

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203

1 like, just because -- it's an odd circumstance 

2 but it's an explained circumstance. And I 

3 don't think you do audits by, you know, by 

4 glancing at what you've run across catches your 

5 eye. I mean, I don't think that's really good 

6 procedure.

7 MEMBER BEACH: Okay. Well, that's 

8 probably true.

9 CHAIR MUNN: Fine. I think we can 

10 do without the audit, Ron.

11 DR. BUCHANAN: Okay, fine. Two 

12 will be fine.

13 CHAIR MUNN: The two will be fine 

14 from our perspective.

15 All right, any further comments 

16 with respect to Linde? If not, then now let's 

17 move on to ICD-9, PER-0043.

18 DR. H. BEHLING: PER-0043. Yes, 

19 again I was the person who reviewed this. Just 

20 for background information, this particular 

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204

1 PER addressed the OTIB-5, which is the bulletin 

2 for internal dosimetry organ and external 

3 dosimetry organ IREP model selection of ICD-9 

4 codes.

5 And just as a review, the original 

6 version of OTIB-5 was issued back in 2003, and 

7 since that time there were a total of nine 

8 revisions. Of the nine revisions, however, 

9 only seven made significant changes to 

10 potential dose reconstruction.

11 And for those who are looking at 

12 their screen, I am on Page 7 as well as now I'm 

13 going to 8 and 9. And at the bottom of Page 7 

14 and 8, I identify what each of those revisions 

15 really did in terms of affecting dose 

16 reconstruction, and comments involving those 

17 changes to these revisions are on the bottom of 

18 Page 8.

19 And one of the things that I looked 

20 at was how were these changes made? And for 

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205

1 your benefit again here, I quoted a section of 

2 the TBD that identified how these changes came 

3 about. And again, if I'm on Page 9 here, I 

4 quote Section 2 from the PER.

5 And it identifies that the 

6 Department of Labor is really the key agency or 

7 group of individuals that identify what 

8 assigned ICD-9 codes apply in the dose 

9 reconstruction process, with exception of 

10 those instances where you have a medical 

11 review, which then obviously involves the 

12 contractor to the NIOSH people.

13 And on that assumption, SC&A 

14 concludes the following -- and I'm on the very 

15 bottom of Page 9 where I say the SC&A concludes 

16 that revisions to OTIB-5 were exclusively 

17 introduced by parties that are generally not 

18 within the scope of SC&A's review.

19 So we assume that these changes and 

20 additions to ICD-9 codes reflect updates and 

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206

1 revisions to the International Classification 

2 of Diseases and ORAU's improved understanding 

3 of corresponding internal and external target 

4 organ. Therefore, SC&A accepts these changes 

5 introduced to ORAUT-OTIB-5 and there are no 

6 findings.

7 Under Subtask 2, again I looked at 

8 all the revisions, and again they all basically 

9 complied with what was stated in the revisions 

10 and how they were introduced in the final 

11 tables. And so again, in behalf of Subtask 2, 

12 SC&A found no discrepancies and no findings. 

13 For Subtask 3, which 

14 evaluates the PER stated approach for 

15 identifying the number of DRs requiring 

16 reevaluation of dose, they were by and large --

17 I'm on Page 13. There are four particular 

18 criteria that have to be met and potentially are 

19 used to determine whether or not a claim will 

20 have to be reviewed. 

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207

1 And in the case of Subtask 3, again 

2 SC&A has no findings pertaining to the 

3 identification of claims that were impacted, 

4 and there were a total of 36 claims that are 

5 subject to dose reevaluation.

6 For Subtask 2, of the 34 DRs that are 

7 subject to audit, SC&A recommends selection of 

8 one claim from each of the following revisions 

9 of ICD-9 codes. And there I identified those 

10 revisions, and they are Revisions Number 2 in 

11 ICD-9 code number 50; Revision 3, ICD-9 code 

12 155.1; and from Revision 4, ICD-9 code 232, as 

13 well as 238.

14 So in this case, as I said, if we can 

15 select one of each of those revisions I think 

16 that would satisfy our need to evaluate 

17 PER-0043.

18 CHAIR MUNN: Any thoughts or 

19 comments? In this case, as the preceding one, 

20 there is no -- unlike the preceding one, we do 

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208

1 not have specific findings. I see nothing for 

2 NIOSH to respond to, except for the selection 

3 of claims for the audit. Is that the same view 

4 of the other Board Members?

5 MEMBER BEACH: Yes, Wanda. It is 

6 for me.

7 MEMBER ZIEMER: And for me.

8 CHAIR MUNN: Very good. Then all 

9 that remains for us is to identify how the 

10 choices will be made for the audit cases.

11 MR. MARSCHKE: Wanda?

12 CHAIR MUNN: Yes.

13 MR. MARSCHKE: This is Steve. Do 

14 you want us to enter a finding of no findings 

15 in the BRS for this one?

16 CHAIR MUNN: I believe that's 

17 appropriate and will keep us from being puzzled 

18 two years from now.

19 MR. MARSCHKE: Okay.

20 CHAIR MUNN: Thanks, Steve. I 

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209

1 will make a notation that a choice needs to be 

2 made with respect to auditing cases. 

3 And is there any concern with 

4 respect to the recommendation as far as numbers 

5 are concerned? I find that to be, personally, 

6 quite acceptable. If anyone has any concerns, 

7 please express them now, otherwise I'll take 

8 that as assent. 

9 Hearing none, we can proceed with 

10 selection of claims for audit. I'll ask that 

11 --

12 MR. HINNEFELD: This is Stu. In 

13 this case, since there are categories based on 

14 ICD-9 codes, we can probably query for these 

15 ICD-9 codes and provide the claim numbers that 

16 fall into these ICD-9 codes to SC&A, and so that 

17 they can then select from those numbers. 

18 Because if they were to go to the PER 

19 application, and in order to find the ICD-9 code 

20 they'd have to open each case to see what the 

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210

1 ICD-9 code was for that. So --

2 CHAIR MUNN: If you'll be good 

3 enough to do that, that would be helpful, Stu.

4 MR. HINNEFELD: And probably run a 

5 query and then just generate the list of here 

6 are the claims that have ICD-9 codes, the 150 

7 and so forth. So we can provide that. And 

8 since it's an ICD-9 code selection that should 

9 be pretty straightforward.

10 CHAIR MUNN: All right.

11 MR. HINNEFELD: And then once we 

12 have that available we'll just send it out to 

13 SC&A and to the Work Group.

14 CHAIR MUNN: Thank you.

15 MR. HINNEFELD: And then I would 

16 assume SC&A could select the cases from those. 

17 Is that correct?

18 CHAIR MUNN: I'm assuming that that 

19 will be the case. Hans? Ron? Is that all 

20 right with you?

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211

1 MS. K. BEHLING: This is Kathy. 

2 I'll probably be doing that, so, yes, it's fine. 

3 I can do that if you're in agreement.

4 CHAIR MUNN: Very good. No 

5 problem here. Any problem from anyone, speak 

6 now. 

7 Thank you, Stu. I'll make a 

8 notation to verify if we haven't had a status. 

9 Thanks much.

10 And we can move on to Aliquippa 

11 Forge, PER-0045.

12 DR. H. BEHLING: Okay, that's me 

13 again. You're going to get tired of hearing me 

14 talk.

15 CHAIR MUNN: No, that's quite all 

16 right. We'll just forge on.

17 DR. H. BEHLING: Well, 

18 unfortunately the worst one's for last, and 

19 this one is going to be very difficult to 

20 follow, really. And I'm hoping that we can 

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212

1 minimize the discussion to only do most 

2 critical issues here that involves the 

3 individual findings, because they're quite 

4 difficult at times to understand without having 

5 first read the document in its entirety and 

6 understand the various issues. Because they 

7 talk about different values, different times 

8 and numerical quantities that are difficult to 

9 assess without having a full understanding of 

10 what's involved. 

11 CHAIR MUNN: There's a lot of 

12 material here.

13 DR. H. BEHLING: Yes. The 

14 PER-0045 involves the Aliquippa Forge TBD 

15 revision. And the original TBD was issued back 

16 in 2004 and then was revised in 2012. And this 

17 TBD addresses the changes that occurred in the 

18 TBD revisions between those years.

19 For the sake of getting a few pieces 

20 of information, I provided my write-up on Page 

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213

1 8, specific issues and a timeline for those 

2 issues. And I want to briefly -- I won't go 

3 through all of these, but I want to point out 

4 the items identified as Number 2, 3, 13 and 14.

5 Number 2 identifies the time frame 

6 during which Aliquippa Forge was a production 

7 facility for the AEC, under contract, and that 

8 period extends from August 16th, '48 through 

9 February 28, 1950. The issues there was they 

10 were rolling operations of uranium.

11 In Item Number 3, it identifies the 

12 actual period of residual contamination, which 

13 starts March 1, 1950 through December 31st, 

14 1987, and again from January 1, 1989 through 

15 December 31st, 1992. So those time frames are 

16 very important in understanding the issues that 

17 I will be addressing with reference to 

18 particular findings.

19 Item Number 13, and again these are 

20 integrated now. In August 1983, the Aliquippa 

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214

1 Forge site was designated for remedial action 

2 under FUSRAP. In December '87, storage 

3 activities began in Building 3 and then 

4 remedial actions were taken from October to 

5 December 1988 to enable additional restricted 

6 use for Building 3. But those dates are very 

7 important, and again I don't expect people to 

8 remember them but it's something that at least 

9 NIOSH has to look at in more careful terms.

10 And finally, Item 14 identifies the 

11 final remedial activities that occurred from 

12 June '93 to September 1994.

13 So also the items that I did not 

14 discuss I briefly discussed under SC&A's 

15 comments that by and large states that the most 

16 basic health physics practices in facility 

17 engineering designs and controls were lacking 

18 during the operational period.

19 And correspondingly the air 

20 concentrations during rolling operations were 

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215

1 orders of magnitude above the AEC-recommended 

2 preferred level of 50 micrograms per cubic 

3 meter, or the more conventional metric of 70 dpm 

4 per cubic meter.

5 And the last bullet -- I'll skip the 

6 third bullet. The last bullet was under 

7 FUSRAP, these are the dates that need to be 

8 recalled. A radiological survey of the 

9 Aliquippa site was conducted in 1978, and there 

10 was an interim remedial action undertaken to 

11 decontaminate the facility in 1988.

12 And the final site remediation 

13 occurred between June of '93 and September '94, 

14 because those are dates that will come into play 

15 in dealing with the findings.

16 Then we go to the next page, and 

17 under Subtask 1, identify the circumstance that 

18 necessitated the need for DCAS PER-0045. And 

19 obviously it was these changes that occurred 

20 between Revision 1 and Revision 2.

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216

1 What's important to note, however, 

2 is that neither Revision 0 and Revision 1 of the 

3 Aliquippa Forge TBD had ever been previously 

4 reviewed by SC&A. So once again we're kind of 

5 starting out after the fact, or we're putting 

6 the cart before the horse in terms of this PER 

7 since we did not really review the TBDs.

8 The major changes we have to address 

9 under PER-0045 as a supporting document really 

10 involves the ORAUT-OTIB-70. And I will read 

11 from DCAS PER-0045. It states the following: 

12 Revision 1 of the Aliquippa Forge Technical 

13 Basis Document revised the dose estimates in a 

14 residual period starting 3/1/1950. This 

15 revision included both internal and external 

16 dose and was the result of both new data, and 

17 this I underline, a revision of OTIB-70.

18 Now, when I read that, it doesn't 

19 really matter and I only identified it as 

20 observation. The fact that OTIB-70 postdates 

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217

1 the original version of the TBD by several 

2 years, it is not something that is technically 

3 correct to assign that it was a revision of 

4 ORAUT-OTIB-70 that prompted the issue of a PER, 

5 it was the fact that when I looked at the data 

6 it shows that the original OTIB for Alquippa had 

7 made no reference to any OTIB because it didn't 

8 exist. And it was based on assumptions and 

9 methodologies which had very little in common 

10 with ORAUT-OTIB-70.

11 So it was not the revision that were 

12 introduced in Rev 1 of OTIB-70, but the very 

13 existence and substitution of guidance 

14 contained in Rev 1 of OTIB-70 for earlier 

15 estimates that identified, that prompted or 

16 that introduced these changes.

17 So, in essence, Observation 1 is 

18 that NIOSH should rephrase the role of OTIB-70 

19 in Section 2.0 of DCAS 45. Also, Observation 

20 2, review of records indicate that neither Rev 

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218

1 0 nor Rev 1 of the Aliquippa Forge TBD was ever 

2 reviewed or audited by SC&A.

3 Going to Subtask 2, Subtask 2 

4 requests that SC&A assess NIOSH's specific 

5 methods for corrective action. I want to 

6 briefly go and review the basic issues that are 

7 defined in ORAUT-OTIB-70.

8 And one of the things that in our 

9 review showed that we had several criticisms 

10 that involved the depletion of rates that was 

11 originally identified as one percent a day. 

12 And two, the resuspension of residual 

13 contamination of 1E minus 6 per meter.

14 In our review, we were able to get 

15 NIOSH to rescind its one percent per day 

16 depletion rate into a much lower value. But 

17 with regards to the residual contamination of 

18 1E minus 6 per meter, that remained unchanged

19 with the exception of the fact that a footnote 

20 was added. And I'm going to ask you to turn to 

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219

1 Page 14 of the write-up, where the footnote 

2 appears that was introduced, and perhaps in 

3 light of our concerns that maybe 1E minus 6 may 

4 not always be the appropriate resuspension 

5 value that should be used.

6 And I read to you in the footnote, 

7 it says, in cases where the contaminated area 

8 is still involved in active operation, a 

9 site-by-site analysis of the appropriateness 

10 of the 1 times minus 6 per meter suspension

11 should be done. And that issue also appears in 

12 Page 23 of this report later on.

13 The table itself identifies clearly 

14 a total of six potential options where a dose 

15 may be reconstructed based on the availability 

16 of air sampling data and surface contamination 

17 in combinations, and you see in the Table 1 that 

18 I provided, those different combinations and 

19 how they may be used.

20 So then we go to Page 16, which 

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220

1 involves estimates of residual external dose. 

2 I briefly explain how doses, external exposures 

3 would be constructed by NIOSH using residual 

4 radioactivity. And I quote from the document 

5 that says to reconstruct external exposure to 

6 residual radioactivity, the maximum reported 

7 exposure rate of 0.01 milli-R per hour was 

8 back-extrapolated using the source term 

9 depletion rate calculated from internal data.

10 And I put that in brackets, which 

11 were defined by 1.15 into the minus 4 per day 

12 or 0.042 per year, and assuming that workers 

13 were exposed to 2,000 hours per year. And in 

14 the load that I briefly identify with those 

15 numbers -- by the way there's a typo that needs 

16 to be corrected, but the actual value is that 

17 0.082 rem times 5.6 gives you a dose of 0.15 rem. 

18 That is the starting point.

19 Finding 1 is the failure to account 

20 for previous D&D effort. What this really 

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221

1 involves is that they took the year 1992 as a 

2 point to extrapolate between, and as I 

3 mentioned earlier, and this is why I spend a 

4 fair amount of time identifying that on Page 9 

5 of the report, I identified the fact that in 

6 1988 there was a remediation or decontamination 

7 effort that was substantially going to reduce 

8 the exposure. So that when you extrapolate 

9 from 1992 and ignore the remediation effort 

10 that took place in 1999, you're going to grossly 

11 underestimate dose exposures that occurred 

12 between 1988 and 1950.

13 So the Finding Number 1 is, in 

14 essence, an issue where we underestimate the 

15 exposures by ignoring the decontamination 

16 effort that took place several years before the 

17 final remediation in 1992.

18 Finding Number 2 addresses the 

19 issue of the 1.15 times 10 to the minus 4 per 

20 day. It's also a problem because it was based 

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222

1 on removable contamination. And when you talk 

2 about a dose rate, the dose rate does not 

3 differentiate between removable contamination 

4 and fixed contamination.

5 So when you by and large take 

6 removable contamination to establish a 

7 decrease in activity, you're making a mistake, 

8 because it should not be based on the removable 

9 contamination but on the collective 

10 contaminations since dose rates do not 

11 distinguish between removable and fixed.

12 And so the backward extrapolation 

13 by means of the NIOSH-devised source term is 

14 incorrect because it is based on a dose rate 

15 that does not necessarily reflect the removable 

16 contamination by itself. And I elaborate on 

17 that issue at the bottom of Page 17 and 18. So 

18 that's Finding Number 2.

19 Let's see here. It's very difficult 

20 to talk about things that we may not be in a 

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223

1 position to go through, but I did want to make 

2 an issue here about the estimates of residual 

3 internal exposures.

4 There's numerous findings 

5 associated with it and they come in stages. 

6 The first attempt was to, in essence, identify 

7 what NIOSH did and see if we can duplicate those 

8 numbers. And then the second level of review 

9 is to say, what's the protocol that NIOSH used, 

10 was it correct? So on Page 18, I start to at 

11 least identify the methodology that NIOSH used 

12 in assessing the estimates of residual internal 

13 exposure.

14 And so on Page 18 I have a verbatim 

15 transcript of the information that was used. 

16 And what they did was to actually identify 

17 activity levels, contamination levels, in the 

18 furnace area which was identified at 5.9 

19 microgram per cubic meter, which, based on the 

20 specific activity of 1.516 dpm per microgram, 

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224

1 translates to 8.94 dpm per cubic meter. And so 

2 that becomes your data point for 1950.

3 And, let's see, they then used that 

4 data point and said let this activity level, 

5 this is an air sampling data point, the 5.9 

6 micrograms per cubic meter or the 8.94 dpm per 

7 cubic meter, is an air sampling point, and that 

8 needs to be understood.

9 And so in the next paragraph, I 

10 underlined it, that to calculate -- and this 

11 comes from the document itself -- to calculate 

12 internal exposure from residual activity, the 

13 analysis assumed that all buildings had an air 

14 concentration of 8.9 dpm per cubic meter in 

15 1950.

16 And it says this operational air 

17 concentration was assumed to have occurred for 

18 one year with no cleanup, and an indoor 

19 deposition velocity of 0.00, the standard 

20 deposition velocity was applied to calculate 

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225

1 2.11 times 10 to the 5 dpm per square meter 

2 surface contamination level at the end of 

3 operations or start of the residual period. 

4 And then they applied the standard 

5 resuspension factor that's identified in 

6 OTIB-70 of 1 times 10 to the minus 6 per meter, 

7 and applied that to the surface contamination 

8 level that would result from the deposition for 

9 one year as formerly mentioned, and then they 

10 came up with an air concentration that would 

11 result from that resuspension.

12 And then they also used the 1992 

13 calculated air concentration of 0.35 dpm was 

14 based on applying the resuspension factor of 1 

15 minus 6 per meter and so forth and so forth. 

16 And we looked at this, and here on 

17 Table 3, which I included, on the basis of those 

18 numbers they came up with inhalation of 

19 picocuries per day for all the years between 

20 1950 and 1992.

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226

1 When I accepted this without 

2 reservation, the air data, I came up with the 

3 fact that, for 1950 and 1992, for those two 

4 years that I selected from Table 3, I came up 

5 with slightly different numbers.

6 And for the 1950 data, I'm on Page 

7 20, the cited value of 0.627 picocuries per day 

8 matches NIOSH's numbers, so this number was 

9 okay. For the 1992 number, I tried to match 

10 that and I ended up with a value that was 

11 slightly lower and does not match NIOSH's value 

12 of 0.112 picocuries per day.

13 So in trying to simply determine 

14 whether or not the NIOSH's approach I could 

15 match the numbers, I was able to match one but 

16 not the other. And the same thing, because the 

17 daily ingestion rates were based on air 

18 concentration values, I was not able to match 

19 those numbers either, and I'm on Page 21.

20 So Finding Number 3 says that I was 

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227

1 not able to match NIOSH's number exactly, 

2 without considering whether or not their 

3 protocol was correct. So that's Finding 

4 Number 3.

5 But a much more critical assessment 

6 I am going to discuss involves Section 4.2.3 on 

7 Page 21 of my write-up. And that involves two 

8 elements. The first element I will discuss 

9 states the following.

10 In Section 5 of the TBD it states the 

11 following: After the end of AEC rolling 

12 operations, a July 1949 survey was performed 

13 and the survey indicated that the maximum air 

14 dust concentration taken during normal 

15 operation in the furnace areas was 5.9 

16 micrograms per cubic meter, which translates to 

17 the 8.994 dpm per cubic meter that we identified 

18 above.

19 They also state, as I had already 

20 mentioned before, that all buildings were 

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228

1 assumed to have an air concentration of 8.94 dpm 

2 in 1950, and therefore they came up with the 

3 estimates that are defined in the previous 

4 table that I mentioned.

5 When I looked at the actual data 

6 from which this came -- and that's included in 

7 Attachment 1 of this report, which is on Page 

8 30 and 31, if you can go there, Page 30 and 31 

9 has Attachment 1. What you'll see on Page 31 

10 is the furnace area value of 5.9 -- I think I 

11 blocked it out and hopefully that's easily 

12 identifiable, middle page -- the furnace area 

13 had 5.9 micrograms per cubic meter, and so it 

14 corresponds to the number that was cited. 

15 However, right below, it says during 

16 floor sweeping of the mill area the samples 

17 showed 110 micrograms per cubic meter, this 

18 being the only sample in excess of the preferred 

19 level.

20 And so the first question that comes 

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229

1 to mind is why wasn't that sample used, because 

2 it is part of the area that was frequented. It 

3 was obtained by a floor sweeping activity, 

4 which is not outrageous, which is something you 

5 would expect in an operational setting.

6 And so the original value that was 

7 identified as the maximum, 5.9, is not correct, 

8 but 110 micrograms could have been used as a 

9 bounding value for air concentrations in 1950. 

10 So it turns out to be -- I guess it's Finding 

11 Number 5.

12 But the second, more important 

13 issue, and probably the single most important 

14 issue that I want to address here, is Finding 

15 Number 6 and how all this comes to light when 

16 you use the suspension factor as a way -- and 

17 what NIOSH did, they took an empirical air 

18 sample of 5.9 micrograms per cubic meter, which 

19 converts to 8.93 picocuries per meter, and then 

20 goes and reconfigures that internal air 

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230

1 concentration.

2 And this is -- I'm sorry, I should 

3 have said 8.94 dpm per cubic meters. That is 

4 an actual empirical air sample. And what they 

5 did, in essence, was to say, no, we're not going 

6 to accept an empirical air sample. And we will 

7 rather, then, convert it into another air 

8 sample by assuming that that air concentration 

9 will deposit on the floor for one whole year,

10 and then use a resuspension factor of E minus 

11 6 per meter and then come up with a revised, 

12 modeled air concentration that is 42-fold 

13 lower.

14 And this leaves me baffled in terms 

15 of how do you justify taking an air sample and 

16 then using a modeling approach that involves an 

17 assumed deposition velocity and assumed 

18 resuspension factor and then establish a new 

19 air concentration that is 42-fold lower than 

20 the empirical air concentration that you 

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231

1 started out with?

2 That, I think, is really the most 

3 serious issue that I have come across. And 

4 actually, on Pages 23 and 24, I actually 

5 identify the flaw in the use of the E minus 6 

6 resuspension factor. If you were to use the 

7 higher concentration that was identified in 

8 floor sweeping in the furnace area of 110 

9 micrograms per cubic meter, you would end up 

10 with a resuspension factor that's close to E 

11 minus 4.

12 And this is what we always talked 

13 about. When you have a facility where there 

14 are still residual activity, the resuspension 

15 factor of E minus 6 is probably a factor of up 

16 to two-fold too low and would support a factor 

17 of E minus 6, which I then actually came up with, 

18 and I describe that briefly on the top of Page 

19 24.

20 With regard to, let's see, the next 

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232

1 issue comes on in the middle of Page 24, 

2 comments pertaining to NIOSH's assessment of 

3 the source term depletion rate. Here they 

4 used, let's see, 1992 survey data that showed 

5 an air concentration of 0.035 dpm per cubic 

6 meter. And they also had the 350 dpm alpha per 

7 100 centimeters square that -- let's see, I'm 

8 trying to recall exactly what I've done here. 

9

10 Yeah, this issue once again goes to 

11 the issue of the removable contamination 

12 levels. And in Finding Number 7, NIOSH's 

13 choice of the 1992 survey measurement of 350 dpm 

14 per 100 centimeters square removable alpha 

15 contamination is compromised by the fact that 

16 it postdates the interim decontamination 

17 efforts of 1988 here.

18 And so one should not take a point 

19 in time that does not consider a previous 

20 decontamination level. Remember that in 1988 

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233

1 the decontamination was fairly significant. 

2 Not as stringent as it was in the subsequent 

3 time period between 1992 and '93, but it clearly 

4 was something that has to be taken into 

5 consideration. And you cannot take a point in 

6 time that does not address the interim 

7 decontamination that took place in 1988.

8 Okay. And I guess the final 

9 finding raises the issue, why wasn't OTIB used 

10 in the way I would have expected it to be used? 

11 And that is, if you have, assuming for a moment 

12 that we're not even going to address the highest 

13 contamination level that was considerably 

14 higher than the 5.9 micrograms per cubic meter, 

15 but instead use 110, assuming for a moment that 

16 NIOSH were to continue to insist that that is 

17 the more appropriate value, why couldn't you 

18 have used that, the measured air concentration 

19 of 8.94 dpm per cubic meter, at the end of the 

20 rolling period and the beginning of the 

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234

1 residual period, and then use the source term 

2 depletion factor, as defined in OTIB-70, of 

3 0.00067 per day and then calculate what the air 

4 concentration would have been for all years 

5 subsequent to the beginning of the residual 

6 period?

7 That, to me, again, is not 

8 consistent with the recommendations in 

9 OTIB-70. And that particular recommendation 

10 is the one that I would have preferred, but 

11 alternatively, among the six options that 

12 OTIB-70 permits for, you could have chosen the 

13 second and third tier option. In other words, 

14 that would have also provided a suitable means 

15 by accommodating the residual period.

16 So that is pretty much the end of the 

17 findings. And then considering the 

18 significance of the findings, especially the 

19 way the air concentrations were modeled, like 

20 I said, where you take an empirical air 

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235

1 concentration and then reconfigure it by using 

2 an assumption about deposition for a year, 

3 resuspension, and then coming up with a 

4 starting air concentration that is 42 fold 

5 lower than the empirical air concentration data 

6 that you start out with makes no sense. 

7 And given the significance of that error, 

8 I made a recommendation that it would be 

9 premature to assess any potential reworked DRs 

10 until this issue's addressed.

11 CHAIR MUNN: Thank you, Hans. And 

12 given the scope and depth of the findings that 

13 you've presented, I have a tendency to agree 

14 with you with respect to the audits.

15 Does anyone have any comments one 

16 way or the other with respect to the 

17 recommendation relative to postponing the 

18 audits? Paul?

19 MEMBER ZIEMER: You're asking 

20 about postponing the audits?

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236

1 CHAIR MUNN: Yes. The 

2 recommendation from the contractor is that the 

3 audits be postponed until after NIOSH has had 

4 an opportunity to review and respond to the 

5 findings.

6 MEMBER ZIEMER: Well, I don't 

7 object to that. Is this a case where it's going 

8 to make a big difference?

9 DR. H. BEHLING: The difference is, 

10 like I said, when you start out, even if you 

11 ignore the highest air concentration sample 

12 that defines the residual period that was 20 

13 times higher than the --

14 MEMBER ZIEMER: Yeah, yeah. We 

15 better have -- yeah, I understand what you're 

16 saying. We better have NIOSH respond first, 

17 probably, yeah.

18 DR. H. BEHLING: Yeah. But even if 

19 you ignored that difference of the 20-fold 

20 difference between the sample that they 

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237

1 selected as the highest but accept the fact that 

2 the 5.9 microgram per cubic meter is in fact the 

3 more credible value, what they did was they 

4 converted that value, which is an air sample 

5 value, and converted by modeling it with 

6 assumptions about a deposition velocity and 

7 resuspension that results in a starting air 

8 sample concentration that is 42-fold lower. I 

9 mean, how do you --

10 MEMBER ZIEMER: Well, like I said, 

11 I'd like to hear whether NIOSH has any immediate 

12 response. Is there something that was 

13 overlooked or is it something that's been 

14 misunderstood or any immediate reaction to the 

15 review?

16 MR. HINNEFELD: This is Stu. I 

17 don't have any. I don't know if Jim has looked 

18 at it more than I have or not.

19 DR. NETON: I think I can make a 

20 general observation. The conversion that 

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238

1 we've done here has been applied at a number of 

2 sites. This is not unique to Aliquippa Forge. 

3 That is, take the end of operational period air 

4 sample data and convert it and use it to 

5 estimate the surface contamination. Because, 

6 in reality, what you're trying to do is get an 

7 estimate of the amount of air concentration due 

8 to resuspension of surface material, not to use 

9 the air data that was conducted during the 

10 operational period, which is a combination of 

11 resuspension and some source term activity 

12 that's been ongoing.

13 So it makes no sense to use the 

14 operational air sample data to start with. And 

15 we've done this many times. You take the 

16 operational air sample data that is a source 

17 term generator and deposit it on the ground 

18 using those default parameters that Hans 

19 mentioned to come up with the surface 

20 contamination.

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239

1 MEMBER ZIEMER: Right. That was 

2 my impression, that that was not different from 

3 --

4 DR. NETON: It's been the practice 

5 for a number of years. There's nothing new 

6 here. Because you, really, if you start with 

7 the operational data, of course you're way 

8 overestimating what the resuspension is in the 

9 residual period because you have no -- you don't 

10 need to account for the source term that's 

11 generated in the air during that period.

12 As far as the floor sweeping sample 

13 goes, that's not a source term generator. 

14 That's just a resuspension generator. And 

15 I'll reverse judgment on the use of 10 to the 

16 minus 5th, 10 to the minus 6th. I think, you 

17 know, we need to talk about that later.

18 But as far as using a sweeping 

19 activity that is not really a source term 

20 generator to estimate the deposition back onto 

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240

1 the ground makes no sense at all. It's just 

2 technically not correct.

3 DR. H. BEHLING: But let me --

4 DR. NETON: -- some kind of an air 

5 sample that is representative of what was 

6 generated during the operations of the plant.

7 DR. H. BEHLING: Well, the value of 

8 5.9 was documented July 28th, 1949. That's 

9 when rolling operations ceased. And so I would 

10 consider that almost the best estimate for the 

11 beginning of the residual period. And to take 

12 an air sample that truly defines the beginning 

13 of the residual period and then convert it and 

14 come up with a 42-fold reduction --

15 DR. NETON: Well, that's where we 

16 need to go back and look and see, is that really 

17 representative of operations or is that 

18 representative of, what I would call, the end 

19 of operations, where there was nothing ongoing? 

20 I don't know. We'd have to take a look at that.

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241

1 But if it really was with operations 

2 ongoing, then it's totally valid, I think, what 

3 was done. If it's true what you just said, that 

4 there was no activity going on in the plant at 

5 all, then I would tend to agree with you. So 

6 I'm needing to look at it.

7 MR. BARTON: This is Bob Barton. 

8 Just to make a comment here. I hear what you're 

9 saying, Jim, about the application of a 

10 deposition velocity at other sites, but that's 

11 not always used.

12 I mean, we just wrapped up the 

13 Simonds discussions and they actually used 

14 operational general air sampling as the 

15 starting source term for the residual period. 

16 So it's not always the case.

17 DR. NETON: I understand that, Bob, 

18 but there's usually a reason behind that. 

19 There's the quality of the data, or we don't 

20 have -- it's determined to be general area data 

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242

1 to begin with, which would be indicative of 

2 resuspension, versus a sample that was taken in 

3 the middle of a process. So you've got to be 

4 careful what you compare.

5 MR. BARTON: I understand. And in 

6 this case it was general air during an actual 

7 rolling operation.

8 DR. NETON: Exactly. And general 

9 area air samples have been considered to be more 

10 representative of resuspension than a sample 

11 that was taken in a process, while a process was 

12 ongoing, you know, right at the process.

13 So we need to look at it a little 

14 closer, but there are reasons why one is used 

15 versus the other, and we've been behaving 

16 fairly consistently for a number of years in 

17 this area.

18 The only thing that really concerns 

19 me now is if this 5.4 sample was truly -- was 

20 operations-driven or whether it actually more 

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243

1 representative of a general area sample where 

2 nothing was going on. We'll take a look at it.

3 CHAIR MUNN: All right, very good. 

4 I have as our action items for next time to add 

5 eight findings to the BRS, and anticipated 

6 responses from NIOSH at our next meeting. Any 

7 other comments?

8 DR. H. BEHLING: I just want to make 

9 a comment. I understand what Jim Neton was 

10 saying regarding the modeling of an air 

11 concentration at some point in time, let it 

12 settle for a year and using resuspension, 

13 because that basically complies with one of the 

14 six methodologies that says you can start out 

15 with surface contamination and end up with an 

16 air concentration.

17 But in the case where you start out 

18 with an air concentration, I think you should 

19 stay with an air concentration either by using, 

20 under Table 1 that I identified on Page 14, 

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244

1 those are the various options. You can use an 

2 air sample during operational period and an air 

3 sampling during post operational period, or you 

4 can use an operational air sample and then apply 

5 the depletion factor of 0.00067.

6 And I can guarantee you, if you did 

7 that, even if you assume that the 5.9 microgram 

8 per cubic meter was an operational air sample, 

9 you would end up with a higher dose than you're 

10 getting with the model that was used here. And 

11 I would assume that the various options that are 

12 recommended in OTIB-70, and as I said, those are 

13 the options defined on Page 14 of my write-up, 

14 they're taken directly from OTIB-70, you have 

15 to use various options.

16 And I would imagine that they are 

17 given in order of priority. Highest priority 

18 meaning that you have air sampling data, which 

19 you do have. The lower tier options for 

20 reconstruction exposures would involve the 

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245

1 surface contamination during operational and 

2 post-operational period.

3 So there were multiple options here 

4 available for use and I'm not sure I go along 

5 with the methodology that was used by NIOSH.

6 DR. NETON: Just for your 

7 information, those are not listed in order of 

8 priority. That the operational air samplers 

9 are the best way to reconstruct inhalation in 

10 the residual period, that just doesn't make any 

11 sense. It's an option, but to take an 

12 operational air sample that is in the middle of 

13 a process of generating airborne activity and 

14 say that's representative of what's being 

15 resuspended from the ground during the residual 

16 period, it makes no sense.

17 I mean, if that's all you have, 

18 that's all you have. But if you've got 

19 something better, I think that you should use 

20 it. In fact, surface contamination 

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246

1 measurements in the post-operational period, 

2 which is the last choice, is probably the best 

3 thing to use.

4 DR. H. BEHLING: Well, as you read 

5 in my footnote on Page 14, I did acknowledge the 

6 following: SC&A notes that Method 1 was 

7 identified as the method of choice for bounding 

8 internal exposures from residual contamination 

9 in behalf of the Dow Chemical Company/Madison 

10 Site, and this is identified in NIOSH 2008.

11 DR. NETON: What, using 

12 operational air data was the method of choice?

13 DR. H. BEHLING: Yes.

14 DR. NETON: I'd have to look at 

15 that. I'll take a look at it, but that's 

16 certainly not what I would consider to be true.

17 CHAIR MUNN: We'll address it after 

18 NIOSH has had an opportunity to review 

19 in-depth.

20 DR. NETON: And it may be the method 

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247

1 of choice for that particular site given the 

2 data we had available. That may be true. But 

3 certainly if we had surface contamination data 

4 available that was taken during the residual 

5 period we would have used it. So I think you're 

6 misinterpreting what was said there.

7 CHAIR MUNN: We will address

8 PER-0045 at our next meeting, and thank you all 

9 for your comments.

10 Our next item on the agenda is the 

11 prioritized list of PER recommendations. And 

12 thank you, John Stiver, for providing that to 

13 us. Would you like to address that, please?

14 MS. K. BEHLING: This is Kathy 

15 Behling. John, if you'd like, I can take that.

16 CHAIR MUNN: All right. Thank you.

17 MS. K. BEHLING: Okay. Yes, we 

18 sent out a memo on the 25th of August, and just 

19 I updated the three tables that are provided. 

20 In Table 1, I just moved these three PERs that 

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248

1 we've discussed today into that table, and I've 

2 highlighted in blue those things that have 

3 changed since our last meeting.

4 And I guess what you're really most 

5 interested in is Table 2, which is actually a 

6 list of four new PERs that have been issued by 

7 NIOSH. And I do give you a summary description 

8 of those four PERs.

9 And I will point out that three of 

10 the four, the first thing you're going to read 

11 is that no TBD actually existed for these, and 

12 however there was a template that was used and 

13 that template has changed and that's what 

14 prompted the PER.

15 And I think maybe at first glance 

16 you might say, well, why do we need to look at 

17 these? But my feeling is that the fact that a 

18 template did exist, it hasn't been really a 

19 formalized document that SC&A has looked at, 

20 and we go back to this consistency issue. And 

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249

1 so in all of the cases of four new PERs, I did 

2 suggest that we may, as a minimum, want to do 

3 a pre-review for those new PERs.

4 And in some of the cases, there are 

5 50-some, almost 60 cases that were reevaluated. 

6 So that was my recommendation. In Table 2 

7 there are four new PERs and that you may want 

8 to have us at least do a pre-review.

9 And then, finally, Table 3 is -- I 

10 probably won't get too formal, we won't even 

11 need this. But I just indicated on there, 

12 there are a few of the very earlier PERs that 

13 were done that we never went back and 

14 reevaluated any claims. I don't know if that's 

15 something that's even necessary at this point. 

16 And I indicated on there that you have assigned 

17 us claims for the Hooker and that work is 

18 underway.

19 CHAIR MUNN: Thank you, Kathy.

20 MS. K. BEHLING: You're welcome.

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250

1 CHAIR MUNN: Does any Member of the 

2 Subcommittee have any questions for Kathy with 

3 respect to the list that you have in hand?

4 MEMBER ZIEMER: Well, we 

5 appreciate her analysis of these for us. Thank 

6 you, Kathy.

7 MS. K. BEHLING: You're welcome.

8 CHAIR MUNN: So the question now, 

9 what is your desire with respect to the four 

10 that have not been assigned and have been 

11 recommended? Does a pre-review seem to meet 

12 your personal feelings with regard to proper --

13 MEMBER ZIEMER: Well, how much 

14 difference is there in the workload, Kathy, for 

15 a pre-review versus a review?

16 MS. K. BEHLING: Well, actually, I 

17 was going to say I think, to some extent, we're 

18 adding a step that probably can be avoided. 

19 Because I do think that in each case, the only 

20 one that I actually would say is perhaps the 

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251

1 Bliss & Laughlin, just because when I look 

2 through these, TBD-6000 has been reviewed quite 

3 extensively by us. We've reviewed OTIB-4, and 

4 I know with OTIB-4 there were a lot of very 

5 conservative assumptions there. I have a hard 

6 time imagining that there would be a lot of 

7 increase in dose associated with that 

8 particular one.

9 But I would really almost 

10 recommend, rather than just a pre-review on at 

11 least 47, 52 and 54 to just go ahead and do a 

12 full review rather than adding the additional 

13 step.

14 As I said, these were done by 

15 templates which were never formalized or 

16 reviewed by SC&A, and I just think it might be 

17 a good idea to do a full review of those three 

18 as a minimum.

19 And I can dig a little bit closer and 

20 do a pre-review of the 50, PER-0050, because 

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252

1 that may be a little bit more extensive. But 

2 that would be my recommendation.

3 MR. KATZ: So, Kathy, let me ask you 

4 a question about the carborundum, because I had 

5 asked Stu just to give me his thoughts about how 

6 significant the changes are here in terms of how 

7 complex they are and how much likelihood there 

8 is of there being much here at the end of the 

9 day. Because we've done a lot of PER reviews 

10 at this point, and quite a number of them, 

11 really. I mean, they've been good in sort of 

12 finding concurrence that everything was done 

13 right, but in fact we didn't learn much was out 

14 of whack for the vast majority of PER reviews 

15 that you've done so far.

16 And carborundum, I mean, as I 

17 understand, I think, from Stu, I mean, the main 

18 thing here is the revision of depletion values 

19 in OTIB-70, which, you know, SC&A was heavily 

20 involved in, so there's not much new here.

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253

1 CHAIR MUNN: No.

2 MR. KATZ: So I was wondering 

3 whether there's, for example, really any value 

4 in going further on that one.

5 MS. K. BEHLING: Yeah, you're

6 right. As I look at this, as I said, with the 

7 Bliss & Laughlin that's true. This was more 

8 based on the OTIB-70. I was just looking at the 

9 number of claims that were affected by this. 

10 But you're probably correct. I guess probably 

11 a full review of 47 and 52 would be probably 

12 adequate.

13 MR. STIVER: This is John Stiver, 

14 if I can just jump in for a minute. I'd just 

15 kind of like to remind everybody that the reason 

16 we started doing these pre-reviews was to avoid 

17 kind of having to, you know, guess at the level 

18 of value in realtime during the meetings.

19 But you do a quick scoping review, 

20 I know Hans did the last -- correct me if I'm 

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254

1 wrong, but I don't think he spent more than 

2 about a day or two doing that. So, you know, 

3 let you take a quick look and you can just say 

4 right away that, you know, this is something, 

5 this is a no-never mind. The others might take 

6 a little bit more digging. So I wouldn't 

7 necessarily recommend abandoning the 

8 pre-review stuff with some of these things.

9 MR. KATZ: Yeah, except that, I 

10 mean, every PER doesn't need to be reviewed at 

11 all. I mean, there's still -- there doesn't 

12 have to be a sense that all PERs get reviewed. 

13 In fact, I mean, that doesn't make much sense 

14 given the experience so far to be reviewing 

15 every PER.

16 So, anyway, that's why I just raised 

17 the question about, similar to what Kathy said 

18 about 50, about 54. It's not looking like 

19 there's anything there of value.

20 CHAIR MUNN: Thank you, Ted, and 

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255

1 thank you, John. Any other thoughts? Any 

2 recommendations with respect to the four PERs 

3 we're looking at?

4 MEMBER BEACH: I think I agree with 

5 all the discussions so far. I think 47 and 52 

6 look like likely candidates, and 50 and 54 have 

7 been reviewed based on OTIB-6000 and 70, so I'm 

8 good with that.

9 CHAIR MUNN: I have a tendency to 

10 agree. Paul, how do you feel about it?

11 MEMBER ZIEMER: Yeah, I think it 

12 makes sense. Just certainly backing just the 

13 two of them.

14 CHAIR MUNN: Let's move forward 

15 with PER 47 and 52.

16 MEMBER ZIEMER: Yeah, yeah.

17 CHAIR MUNN: And recommend those to 

18 SC&A as appropriate subjects for --

19 MEMBER ZIEMER: Are we talking 

20 about pre-reviews or reviews?

NEAL R. GROSS

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256

1 CHAIR MUNN: We're talking about 

2 reviews, I believe.

3 MR. KATZ: Yeah, what I would

4 suggest is just assume it's a full review. If 

5 SC&A, John, if you guys get into it in one of 

6 those and there's not much there, then, you 

7 know, you can back off of it. But if there 

8 seems to be some pith there then carry on and 

9 just do a full review.

10 MR. STIVER: Okay, we'll go ahead 

11 and take those marching orders.

12 MEMBER BEACH: And then I have one 

13 question on 54. This is just in general. 

14 Because of the number of cases, did SC&A feel 

15 like we should do a pre-review on that or just 

16 eliminate them totally from review?

17 MS. K. BEHLING: Well, based on the 

18 fact that we have looked pretty extensively at 

19 OTIB-70, I guess, as indicated by Ted, perhaps 

20 we don't even need a pre-review.

NEAL R. GROSS

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257

1 Again, if you want us to do just a 

2 quick look at this, we can do that. And like 

3 Ted said, back off if we feel that there's no 

4 real need.

5 CHAIR MUNN: When I first looked at 

6 it, the OTIB-70 jumped out at me as being 

7 something we have vetted extensively, and for 

8 that reason, and primarily that reason, I would 

9 have a tendency to reject 54, personally.

10 MS. K. BEHLING: Okay. And I'm 

11 comfortable with that. I just wanted to throw 

12 it in.

13 MEMBER ZIEMER: Yeah, I would hold 

14 off on it and let this one --

15 (Simultaneous speaking.)

16 CHAIR MUNN: Yeah, 52 has been 

17 appropriately assigned and we can move on to 

18 Table 3 and your response to the question as to 

19 whether or not you feel that it's appropriate 

20 to be going back to these and addressing them 

NEAL R. GROSS

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258

1 further.

2 I don't see any really driving 

3 reason to do that, personally, but if other 

4 Board Members --

5 MEMBER BEACH: The only one that 

6 stands out to me is PER-0029 and that's just 

7 because of the number of claims that 

8 potentially affect.

9 CHAIR MUNN: Paul?

10 MEMBER ZIEMER: Yeah, I don't have 

11 any that jump out at me, but I'd go along with 

12 29 if Josie is concerned about it.

13 MEMBER BEACH: Well, I just noticed 

14 it was referred back to the Work Group, so they 

15 may make a decision on that themselves.

16 CHAIR MUNN: Yeah, it doesn't seem 

17 necessary for us to address this here, in my 

18 personal view. I don't want to throw a monkey 

19 wrench in that.

20 MEMBER BEACH: No, I'm fine with 

NEAL R. GROSS

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259

1 that.

2 CHAIR MUNN: All right. So I think 

3 we can dispense with concerns for that. And 

4 thank you. Anything else from anyone with 

5 respect to the PER recommendations? If not, 

6 then let's take a look at some of our details 

7 from carry-overs from previous meetings.

8 We have status reports that we 

9 haven't had in quite some time on what's going 

10 on with one report and four PERs as listed on

11 your agenda. Can we hear a status update on 

12 RPRT-53 and the four PERs?

13 MR. HINNEFELD: I think RPRT-53 

14 might be Jim.

15 DR. NETON: I'm sorry, I was 

16 distracted there for a second. RPRT-53. I 

17 think most people are aware, the Board is pretty 

18 aware of where we are. NIOSH is in the process 

19 of preparing an implementation guide in draft 

20 form right now that is accepting comments from 

NEAL R. GROSS

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260

1 the Board.

2 We had a fairly lengthy discussion 

3 about that document, about the draft version of 

4 that document, at the Idaho Working Group that 

5 was held prior to the Idaho Board Meeting and 

6 received a lot of good feedback. The 

7 transcripts have been issued and I'm combing 

8 through the transcripts trying to glean the 

9 suggestions that were made during that 

10 discussion, and there were a number of them.

11 We're working on that from that 

12 front, and that will address a number of the 

13 findings that were made on -- at least to put 

14 NIOSH's position on paper as to the number of 

15 findings that were made in RPRT-53.

16 Also I think that a lot of that has 

17 to do with the evaluation of a significant 

18 difference, how you evaluate significant 

19 difference between a strata of coworker models, 

20 and NIOSH has put out a paper on that. 

NEAL R. GROSS

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261

1 But we also, I think, have made some 

2 progress on the OPOS, the issue of OPOS. There 

3 seem to be some favorable reaction, at least 

4 from my opinion, from SC&A, on the use of a 

5 backwards time-weighted average calculation. 

6 I owe a response to SC&A on comments that was 

7 made on the use of calculations that we've done 

8 using IMBA in chronic versus -- multiple acute 

9 intakes versus a single chronic acute intake, 

10 and I will provide that shortly.

11 But I think there was -- I sense that 

12 there was reasonable agreement on that, so we 

13 may be moving towards some agreement on how OPOS 

14 is calculated. The key difference, the key 

15 thing in my mind right now is the evaluation of 

16 what do we consider a practical or a significant 

17 difference between two strata. That's about 

18 all I have to say.

19 CHAIR MUNN: Thank you, Jim. 

20 Shall we continue to carry this as a request for 

NEAL R. GROSS

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262

1 status report, or are we almost to the point 

2 where we can begin to address your response to 

3 the findings specifically?

4 DR. NETON: I would carry it right 

5 now just as a status.

6 CHAIR MUNN: All right. We'll 

7 continue to carry it the way we have been. 

8 Who is prepared to give us a status 

9 on the four PERs?

10 MR. HINNEFELD: This is Stu and 

11 I'll give it a try. Maybe somebody else can 

12 help me out. PER-0037 is Ames. And we also 

13 have an Ames Site Profile Review that we're 

14 working on responding to, so I presume that our 

15 research and response efforts for the Ames Site 

16 Profile Review will include the -- we'll just 

17 go ahead and throw the PER-0037 findings in 

18 there. I don't know to what extent they're 

19 similar, but we'll sort that out. 

20 I was trying to look around BRS on 

NEAL R. GROSS

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263

1 PER-0037. That particular one wasn't working. 

2 Everything else was working great and that one 

3 didn't seem to bring up any findings and didn't 

4 even seem to bring up a field that looked even 

5 remotely familiar, I mean a page that looked 

6 even remotely familiar. So did anyone try to 

7 put findings in the PER-0037 from --

8 MR. KATZ: Stu, there's no review 

9 yet.

10 MR. HINNEFELD: Oh, there is no 

11 review yet?

12 MR. KATZ: Right. The review's 

13 waiting for the Site Profile resolution.

14 MR. HINNEFELD: Thank you.

15 DR. NETON: That makes sense. I 

16 was going to say, because we didn't roll in any 

17 PER-0037.

18 MR. KATZ: That's right. No, I was 

19 about to interject. But SC&A we had to hold off 

20 on the PER review until the Site Profile goes 

NEAL R. GROSS

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264

1 through resolution with the Work Group, which 

2 is just awaiting for your responses.

3 MR. HINNEFELD: Okay, good. So 

4 then I'm not behind the eight ball on 37.

5 DR. NETON: I can report that, 

6 somewhat related, that we have addressed all 

7 the findings, I think there were 22 on Ames, and 

8 I've got them on my inbox for review now. So 

9 we should be able to put those out fairly 

10 shortly.

11 (Simultaneous speaking.)

12 MR. HINNEFELD: PER-0011 is K-25, I 

13 think, that is -- really the finding that is 

14 open relates to how are construction trades 

15 workers identified and how are they selected, 

16 treated. And in going through that issue we've 

17 determined that there was some confusion on 

18 which workers that construction trades workers 

19 adjustment should be applied to. And so we are 

20 in the process of doing that. In fact, I think 

NEAL R. GROSS

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265

1 we may have just reissued that construction 

2 trades worker OTIB, didn't we, Jim?

3 MS. K. BEHLING: OTIB-52 was 

4 updated.

5 MR. HINNEFELD: Yeah. So I think 

6 there might be some effort associated with 

7 trying to make sure, you know, look back at 

8 cases that maybe weren't treated 

9 appropriately. The confusion came in to 

10 whether the construction trade workers 

11 adjustment should apply only to subcontractor 

12 construction trade workers or should be applied 

13 to everybody with a construction trade worker 

14 job title, including what I would call in-house 

15 employees, the prime contractor employees.

16 So there was some confusion about 

17 that and it wasn't being used consistently, and 

18 so we've sorted that now that it should 

19 apparently apply to all construction trade 

20 workers regardless of their employer. And so 

NEAL R. GROSS

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266

1 there's going to have to be some sort of 

2 look-back associated with that change as well. 

3 Now, once that -- I think that 

4 action in some fashion may be able to finish out 

5 -- or we might be able to finish out this 

6 PER-0011 finding by referring to whatever 

7 action's coming out of the OTIB-52 revision and 

8 associated PER.

9 So we still need to sort that out. 

10 I'm not really ready to say definitely how we 

11 will say it, but I think we can probably close 

12 this finding based on that that OTIB-52 work.

13 I know that PER-0033 is a Reduction 

14 Pilot Plant and the only finding is no finding, 

15 so I don't know what we would have to do on that. 

16 Anybody got any ideas there, if I missed 

17 something there?

18 CHAIR MUNN: Certainly not I. 

19 Perhaps we need to take a close look at why we're 

20 even carrying that.

NEAL R. GROSS

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267

1 DR. BUCHANAN: Yeah, this is Ron 

2 Buchanan. We discussed that at the February 

3 13th, and I have a note that we had no findings 

4 on the two cases we audited and that it was 

5 closed at the meeting on 2/13-14.

6 CHAIR MUNN: Do we say that in the 

7 BRS, or is that our only --

8 MR. HINNEFELD: The BRS has no 

9 finding in it, so there were no findings.

10 CHAIR MUNN: If there were no 

11 findings then we don't need to continue 

12 carrying it, if we've said that in the BRS.

13 MR. HINNEFELD: Yeah, it's in 

14 there.

15 CHAIR MUNN: Good. All right, I 

16 think Steve's checking on that for us just to 

17 make sure. Thank you, Steve.

18 MS. K. BEHLING: This is Kathy 

19 Behling. I can speak to PER-0018.

20 CHAIR MUNN: Kathy, you're 

NEAL R. GROSS

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268

1 breaking up badly.

2 MR. HINNEFELD: Can't hear you. 

3 No, still can't hear you.

4 CHAIR MUNN: Something happened to 

5 your connection. You're really bad now.

6 MS. K. BEHLING: Okay. Hold on 

7 just a second.

8 MR. KATZ: It's a bad case of 

9 laryngitis.

10 MR. MARSCHKE: Wanda, am I looking 

11 for 18?

12 CHAIR MUNN: I'm sorry about that. 

13 No, PER-0033.

14 MR. MARSCHKE: 33.

15 CHAIR MUNN: There it is. No 

16 findings.

17 MR. MARSCHKE: Yeah, but it's open. 

18 We should make it as closed, shouldn't we?

19 CHAIR MUNN: Yeah, we should. I 

20 don't think you even need to have a comment. It 

NEAL R. GROSS

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269

1 just needs to be closed.

2 MR. KATZ: So what Kathy was saying 

3 is that she could address PER-0018.

4 MS. K. BEHLING: Yes, can you hear 

5 me?

6 MR. KATZ: No. You're still --

7 MS. K. BEHLING: Hold on one 

8 second. Hold on one second.

9 CHAIR MUNN: Now we're hearing you. 

10 We're hearing you, Kathy. Suddenly you're 

11 okay.

12 MS. K. BEHLING: Is that any 

13 better?

14 MR. KATZ: Yeah.

15 CHAIR MUNN: It is.

16 MS. K. BEHLING: I think my phone 

17 was telling on me here. PER-0018, we actually 

18 finished our subtask for review on PER-0018, 

19 and PER-0018 is the LANL Site Profile revision. 

20 And that was sent out on May 30th of this year. 

NEAL R. GROSS

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270

1 I can briefly go through that if you'd like. 

2 There were five cases that we reviewed and four 

3 findings. Do you still want to do that today?

4 CHAIR MUNN: I don't think we need 

5 to review the findings. Do you know whether we 

6 have them in the system?

7 MS. K. BEHLING: We do not. I have 

8 not gotten them into the system yet but I can 

9 certainly do that.

10 CHAIR MUNN: Okay. I think if we 

11 had that as our action item for next time then 

12 we will pull it out of our status review and 

13 bring it to the forefront.

14 MS. K. BEHLING: Okay.

15 CHAIR MUNN: Thanks, Kathy. I'd 

16 appreciate that.

17 MS. K. BEHLING: All right.

18 CHAIR MUNN: We'll look forward to 

19 that when you have an opportunity to do it.

20 MS. K. BEHLING: Okay, I will do 

NEAL R. GROSS

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271

1 that shortly after this meeting.

2 CHAIR MUNN: Thank you. No 

3 further questions here with regard to status on 

4 the outstanding items that we have listed. 

5 Does anyone have any question or do you have any 

6 additional items that need to be added to our 

7 status list?

8 If not, then we'll move on to the 

9 next item, which is simply to comment for those 

10 who have any concern about it and who might not 

11 have followed what transpired recently.

12 The PPG status will be going to the 

13 hands of that Work Group, which has now been 

14 established, and we will stop carrying this 

15 item as a concern for us until we hear back from 

16 the Work Group.

17 Our next meeting needs to be 

18 defined. My suggestion would be two months 

19 from today, a little bit before today. My 

20 suggestion would be Wednesday, October the 22nd 

NEAL R. GROSS

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272

1 or Thursday, October the 23rd.

2 MR. KATZ: Those are out of the 

3 question for me and probably Stu too.

4 CHAIR MUNN: Okay.

5 MEMBER BEACH: That's out of the 

6 question. Anything after the 20th for me won't 

7 work.

8 CHAIR MUNN: Then can we say either 

9 the 15th or the 16th?

10 MR. KATZ: I'm just wondering, it's 

11 awfully soon, considering that work needs to be 

12 done before it's a worthwhile meeting. I think 

13 we might as well then -- and I know that Josie's 

14 going to be off until, when do you get back, 

15 Josie?

16 MEMBER BEACH: November 20th.

17 CHAIR MUNN: That would put us into 

18 Thanksgiving. I would suggest not postponing 

19 it another month.

20 MR. KATZ: Well, I don't think we 

NEAL R. GROSS

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273

1 have much work to do if we give it six weeks or 

2 whatever. I mean, there will be hardly 

3 anything to address.

4 CHAIR MUNN: Well, Ted, I might 

5 take a little issue with that. We have all of 

6 the things that we looked at early this morning 

7 we'll take care of that next time, we know what 

8 we're doing, we just haven't done it yet.

9 MR. KATZ: But the next time, I 

10 mean, we'll take care of it means they have to 

11 do work to be ready. The next time, I mean, we 

12 haven't been meeting --

13 CHAIR MUNN: All right.

14 MR. KATZ: -- every two months --

15 CHAIR MUNN: When would we suggest?

16 MR. KATZ: So, well, I would 

17 suggest we do this later in November, then. 

18 Stu can see --

19 (Simultaneous speaking.)

20 MR. KATZ: -- and if there's plenty 

NEAL R. GROSS

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274

1 of work to have a meeting, that's fine. I'm not 

2 seeing where all that work is.

3 MR. HINNEFELD: Well, it's a little 

4 hard to judge how much will be accomplished. I 

5 think there are probably some things we can 

6 enter but I don't know how much. I mean, we 

7 always have the option for having a shorter 

8 meeting. Since we're not traveling, you know, 

9 there's no imperative to have a full-day 

10 meeting or a six-hour meeting.

11 We will accomplish what we -- you 

12 know, we will work to accomplish it, like we 

13 always do, to align, you know, fitting it in 

14 with the other work we do on the program. So 

15 we'll try to get -- but it's hard to judge today 

16 how much exactly we'll have in there.

17 CHAIR MUNN: Well, someone suggest 

18 a target date to me after the 20th, after the 

19 week of the 20th, if Josie is not --

20 MEMBER BEACH: Actually, Wanda, 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
This transcript of the Advisory Board on Radiation and Worker Health, Procedures Subcommittee, has 

been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information 

has been redacted as necessary. The transcript, however, has not been reviewed and certified by the 

Chair of the Procedures Subcommittee for accuracy at this time. The reader should be cautioned that this 

transcript is for information only and is subject to change.

275

1 this is --

2 CHAIR MUNN: -- to find out where 

3 she lives again.

4 MEMBER BEACH: Wanda, this is 

5 Josie. I'm actually available the 18th and 

6 19th of November, if that works.

7 CHAIR MUNN: I'm waiting for a 

8 suggestion from others.

9 MR. HINNEFELD: Well, not that it 

10 matters very much but those dates work for me.

11 DR. NETON: The 19th does not work 

12 for me.

13 MEMBER BEACH: How's the 18th?

14 DR. NETON: Yes, the 18th works.

15 CHAIR MUNN: 11:00 a.m. Eastern 

16 Time, October the 18th.

17 DR. NETON: Wait, in October or 

18 November?

19 CHAIR MUNN: November the 18th.

20 MR. KATZ: November the 18th is 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
This transcript of the Advisory Board on Radiation and Worker Health, Procedures Subcommittee, has 

been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information 

has been redacted as necessary. The transcript, however, has not been reviewed and certified by the 

Chair of the Procedures Subcommittee for accuracy at this time. The reader should be cautioned that this 

transcript is for information only and is subject to change.

276

1 good here. Paul, is that good for you? Do we 

2 still have Paul on the line?

3 MEMBER ZIEMER: Yes, I was on mute. 

4 Is that October 18th?

5 CHAIR MUNN: No, November 18th.

6 MEMBER ZIEMER: Or November 

7 rather. Hang on here. November 18th, yes, 

8 that's okay.

9 CHAIR MUNN: Anyone have any 

10 problem with November 18th?

11 MR. KATZ: I'll send a note to Dick. 

12 But we'll do that in any event because it seems 

13 like his availability -- when he's available, 

14 it can fall away pretty quickly.

15 MEMBER ZIEMER: Was that November 

16 18th?

17 CHAIR MUNN: November 18th. 

18 Tuesday, November 18th.

19 MEMBER ZIEMER: Yes, that's fine 

20 for me.

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
This transcript of the Advisory Board on Radiation and Worker Health, Procedures Subcommittee, has 

been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable information 

has been redacted as necessary. The transcript, however, has not been reviewed and certified by the 

Chair of the Procedures Subcommittee for accuracy at this time. The reader should be cautioned that this 

transcript is for information only and is subject to change.

277

1 CHAIR MUNN: Any other business to 

2 be addressed today? If not, thank you for your 

3 help, and we will see you, talk to you, 

4 hopefully we'll see you in Los Angeles, and if 

5 not, then we'll talk to you three months from 

6 now.

7 MR. KATZ: Thanks, everyone.

8 CHAIR MUNN: Thank you much.

9 MEMBER ZIEMER: Thanks, Wanda.

10 CHAIR MUNN: Bye-bye.

11 MEMBER ZIEMER: Bye-bye.

12 (Whereupon, the above-entitled 

13 matter went off the record at 4:13 p.m.)

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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