NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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US 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 for Procedure Reviews

Wednesday, November 3, 2021

The Work Group convened via teleconference at

11:00 a.m. EDT, Josie Beach, Chair, presiding.
2 

Members Present: 

Josie Beach, Chair

Loretta Valerio, Member

Paul Ziemer, Member

Also Present: 

Rashaun Roberts, Designated Federal Official

Dave Allen, DCAS

Bob Anigstein, SC&A

Bob Barton, SC&A

Kathy Behling, SC&A

Elizabeth Brackett, ORAU Team

Ron Buchanan, SC&A

Grady Calhoun, DCAS

Rose Gogliotti, SC&A

Darin Hekkala, ORAU Team

Alek Kranbuhl, DCAS

Lori Marion-moss, DCAS

Robert Mcgolerick, HHS

Wade Morris, ORAU Team

Steve Ostrow, SC&A

Mutty Sharfi, ORAU Team

Scott Siebert, ORAU Team

Tim Taulbee, DCAS
3 

Contents

US 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 for 

Procedure Reviews Wednesday, November 3, 2021 1

Welcome, Roll Call and Introductions 4

SC&A Presentations 8

Preparation for December 2021 Full ABRWH 

Meeting 112

Preparation for December 2021 Full ABRWH 

Meeting 116
4

Proceedings

(11:00 a.m.)

Welcome, Roll Call and Introductions

Dr. Roberts: Well, I have 11:00 a.m. Eastern, so I 

think we need to go ahead and get started. So good 

morning everyone. Welcome to the Advisory Board 

on Radiation and Worker Health. This is a meeting 

of the Subcommittee on Worker Health. This is a 

meeting of the Subcommittee on Procedures 

Review. 

I'm Rashaun Roberts, and I am the Designated 

Federal Official for the Board. There is an agenda for 

today. You can find it on the NIOSH website under 

scheduled meetings for November 2021. Since the 

Subcommittee will be discussing a number of 

different documents today, we do need to address 

conflict of interest.

I don't think we're dealing with any documents 

today that relate to Subcommittee Members' conflict 

of interest, but if a conflict does happen to come up, 

Subcommittees and others do need to recuse 

themselves from the discussion where the conflict of 

interest applies.

So as we move through the roll call, Subcommittee 

and other Members and others please state where 

you have a conflict of interest, and we can start with 

you Josie.

Chair Beach: I'm here, and I have a conflict at 

Hanford.

Dr. Roberts: Okay. Valerio? Loretta, are you on? I'm 

not hearing anything. I think I see you.

Ms. Behling: Okay, this is Kathy Behling. I believe 

that they are using the audios through Skype as 

opposed to calling in on this line, because I can hear 

Paul and I can hear Loretta and Paul talking, but 

they don't hear us.
5

Dr. Roberts: Okay. Yeah, I can see Paul talking. 

Okay. Let me try to post the call-in information so 

they can call in. 

Chair Beach: I just talked to Loretta. She was on, 

but she -- she's going to call in on a phone.

Dr. Roberts: Okay, great. So we'll just give them a 

minute. 

Chair Beach: I think we get so used to using our 

computers through the Zoom that people --

Dr. Roberts: Yeah, well yeah. And Tim says that he 

can't hear, so they need to -- yeah. Maybe people 

just called in.

Member Valerio: Hello? Hi, this is Loretta, I'm on.

Dr. Roberts: Okay, great. I can hear someone 

talking. I posted it in Skype as well. Okay. So 

Loretta, in the meantime I put you down as in 

attendance, and then we just need to hear from 

Paul.

Chair Beach: And then I think Loretta didn't mention 

her conflict Rashaun.

Dr. Roberts: Okay. We'll get her to come back 

around to that.

(Pause.)

Dr. Roberts: Okay, it does sound like there's some 

music. Loretta, can you address your conflict?

Member Valerio: Looking over the documents, I 

don't believe I have any conflict for this meeting. 

Dr. Roberts: Yeah, no. I don't think so either, but if 

you could state your usual conflict, that would be 

great.

Member Valerio: All right. So Loretta Valerio, no 

conflict.
6

Dr. Roberts: But you're typically conflicted for the 

Nevada sites and others.

Member Valerio: Yeah. I don't think I have anyone 

at Nevada Test Site right now, but I'll go ahead and 

I'll conflict myself out of it. Sorry about that. 

Dr. Roberts: No, not at all. Paul, are you able to 

speak with us now?

Member Ziemer: This is Ziemer. I'm on the line here 

now.

Dr. Roberts: Okay great, and if you could cover 

your conflicts of interest, speak to that?

Member Ziemer: I'm conflicted on Oak Ridge. I 

think that's the only one. 

Dr. Roberts: Okay great. Thank you. All right. Let's 

move into roll call for others, and let's start with 

NIOSH DCAS ORAU.

[ROLL CALL]

Dr. Roberts: Thank you and welcome to all of you. I 

do need to go over a couple of additional items 

before I give the floor to Josie Beach, who's our 

Chair for this Subcommittee. I can hear some, 

already hear some static or something going on in 

the background. So if you would please mute your 

phones unless of course you're speaking. If you 

don't have a mute button, press *6 to mute and to 

take yourself off, press *6 again.

The agenda and the presentations and background 

documents that are relevant to today's meeting can 

be found on the NIOSH DCAS website if you'd like to 

follow along. All of these materials were sent to the 

Board Members or Subcommittee Members prior to 

this meeting. So with that, I'm going to go ahead 

and turn the floor over to Josie.

Chair Beach: Thank you Rashaun, good morning 

everyone. The agenda is posted on Skype. Hopefully 
7

everybody can see that, and as Rashaun pointed 

out this morning we have a very full agenda, a lot of 

items. We are scheduled to adjourn at 3:30, and if -

- I'm wondering. I would like to adjourn at 3:15, if 

that doesn't cause any problems for anybody. I 

have another meeting at my time 12:30. So if we 

could try to get it done about 15 minutes early.

The other question I have is normally when we're 

meeting we take a lunch break. I think we should be 

able to just go with a 15 minute break in between, 

our agenda for a comfort break. Is everybody okay 

with that? If there's any objections, just speak up. 

Hearing none I'm -- oh go ahead?

Member Valerio: I'm fine with that Josie. That 

works for me.

Chair Beach: Great, and Paul are you fine with that 

as well?

Member Ziemer: Yes. I'll be good with that, and I 

would have to leave no later than 3:30 myself. So 

3:15 is great for me.

Chair Beach: Okay, perfect. Hopefully we'll get 

through the full agenda. But the last, the one thing 

that isn't on here is there are some carryover items 

from the past couple of meetings that I want to just 

briefly go over those at the very end, to see how 

we're tracking those. But I'll leave that to the end 

and if we don't get to it, then I'll send the details 

around.

So I -- Kathy, are you presenting our first?

Ms. Behling: Yeah. I'm ready to -- if you don't mind, 

I was hoping to start with the second item on the 

agenda, which is the reply to NIOSH's response to 

SC&A's Observation 6 on DCAS-PER-057, which is 

the General Steel Industries. That's going to be a 

brief presentation from Bob Anigstein, and then he 

doesn't have to remain on the line if he chooses not 

to.
8

Chair Beach: Oh, and I was going to ask if there 

were any other changes. So is that the only one 

that you want to take out of sequence? I'm fine with 

the --

Ms. Behling: Yeah, the steel. That's the only one.

Chair Beach: Let's start there, then.

SC&A Presentations

Ms. Behling: Okay. So, Bob, go ahead.

Dr. Anigstein: Well, this Observation 6 arose during 

the SC&A review of PER-057.

(Simultaneous speaking.)

Chair Beach: Excuse me. Hello? 

Dr. Anigstein: Huh?

Chair Beach: Bob, is there a presentation to put up 

for that? 

Ms. Behling: There is not. Because this is very brief, 

there was no presentation included. We felt that this 

could be verbal, and so we did not make a 

presentation. Sorry about that.

Chair Beach: Okay. I think Rashaun was trying to 

chime in.

Dr. Roberts: Yes, and I'm still hearing -- I don't 

know if other people can hear some background 

noise. 

(Pause.)

Dr. Roberts: Okay.

Dr. Anigstein: Can I resume?

Dr. Roberts: Yes.

Chair Beach: Yes. Yes, please.
9

Dr. Anigstein: Okay. Like I said, PER-57 was a redo 

of the Site Profile for GSI, General Steel Industries, 

and one of the comments about it that we had, 

SC&A had on the observations was that we could 

not -- we could not match the numbers, the dose 

numbers for the intake, for inhaled intake, and we 

found out that the reason was that NIOSH was 

using an efficiency method, and that there were 

some workers.

If a worker had worked an entire year, January 

through December, our calculations matched the 

NIOSH calculations. We used a different technique, 

we used the DCAL, DCAL code written by Oak 

Ridge, and thus it was a totally independent check. 

We had very, very close results. 

However, if a worker had not worked a full year, 

either he left during the year or he was hired the 

latter part of the year, we did not match the doses 

for the first the first couple of doses afterwards, and 

the reason was that NIOSH was using a technique, 

an efficiency method, which was then coded into 

this Chronic Annual Dose Worksheet, the CADW, 

and by that tool they would simply say, well, let's 

just take the -- calculate the total intake over the 

course of the year, and divide it up among the 

number of days, the 365 days, and this would 

smooth out the intake for the whole year. 

But the fact is that because uranium has a long 

residence that really shows up in the lung cases, 

that uranium has a long residence time in the lung, 

an intake during the first six months -- I'll just 

arbitrarily say the first six months of the year -- will 

have a greater effect in later years than an intake 

during the second six months of that same year, 

because the uranium would simply have been in the 

lung longer.

So this was pointed out to NIOSH and at first there 

was -- at first there was a response that the CADW 

tool took that into consideration. But what it did was 

it simply relieved the dose reconstruction to a hand 
10

calculation, and it actually calculated the average 

intake, but it still had that problem.

So when this was -- it was actually resolved at the 

last Procedures Subcommittee meeting when Dave 

Allen was in attendance, and that they settled the 

thing. They said that if the POC was close to 50 

percent, that he said between 45 and 52 percent 

range, then it's possible that this change in the 

intake could make a difference in the outcome.

And consequently, in such a case, the dose 

reconstructors were asked to actually do the IMBA 

run for that individual case. And IMBA does take the 

actual exposure regimen and calculates the doses 

according to day by day when the intake was taken. 

So this is completely satisfactory and SC&A accepts 

that resolution and recommends that the 

Subcommittee closes the issue.

Chair Beach: Okay. And Bob, that was Observation 

6. And that's the last one for PER-057. Is that 

correct? 

Dr. Anigstein: That is correct. There was also a 

Finding 2. The reason it was duplicated was because 

there were -- the PER consisted of doing five cases -

- reviewing five cases. And so we -- I wrote that we 

listed the observations case by cases when going 

along. And so there was one case where there -- For 

one case was Observation 6. And the same issue 

came up in another cases -- in another case where 

it had a greater impact, so we called it Finding 2.

Chair Beach: Okay. 

Dr. Anigstein: And so there were both -- They're 

both resolved by this change in our procedure. 

Chair Beach: Okay. Thank you, Bob. Loretta or Paul, 

any comments or questions? 

Member Ziemer: This is Paul. I'd just point out that 

the Subcommittee Members do have a copy of Bob's 

memorandum on this. Even though it's not on the 
11

Skype right now, it was distributed with the other 

documents that the Subcommittee got. I'm not sure 

whether the website included it for today's materials 

or not. Rashaun, I'm not sure. But the 

Subcommittee Members do have Bob's memo on 

this.

Chair Beach: Correct. 

Member Ziemer: And I'm fine with this resolution.

Dr. Anigstein: This is Bob. It's not under the

meeting agenda on today's meeting, but it is on the 

website. I was able to retrieve it myself.

Member Ziemer: Oh, okay. So it is there for other 

participants in this meeting to look at if they want to 

see it in writing. And as I said, the Subcommittee 

Members had it in advance as well. 

Chair Beach: Correct. It was sent out August 17th, 

2021 or that's the day that the document -- You're 

correct. There's also a reference in the document. It 

was with the documents that Rashaun distributed to 

us for this meeting. 

Chair Beach: Yeah, and there's also a reference to 

the transcript where we discussed it on the February 

meeting. So I'm fine with closing this also. Loretta? 

Thanks for --

Member Valerio: I'm fine with closing this. I'm good 

with closing it. 

Chair Beach: Okay. Bob, I think -- and Kathy, are 

you keeping track of this for the BRS?

Ms. Behling: Yes, we are.

Chair Beach: Thank you. Okay, so we can consider 

this closed unless there's any other comments or 

questions. Okay, then let's move back to our first

agenda item -- the Site Profile for Grand Junction. 

Ms. Behling: Yes. And hopefully I am sharing my 
12

screen. And what I'm going to try to do is toggle 

this up. Hold on.

Ms. Gogliotti: And I'll confirm you are sharing your 

screen, Kathy.

Ms. Behling: Okay, thank you. And this is actually 

going to be presented by Ron Buchanan.

Dr. Buchanan: Can you hear me? I dialed back in. 

Can you hear me now? 

Chair Beach: Yes. We can hear you, Ron.

Dr. Buchanan: Okay, thank you. 

Ms. Behling: Okay. Are you seeing that? 

Dr. Buchanan: Yes.

Chair Beach: Yes. We are, Kathy.

Ms. Behling: Okay, Ron. You can proceed.

Dr. Buchanan: Okay. This is Ron Buchanan. I'll now 

be presenting today a SC&A review of TBD-0060 for 

the Grand Junction facility. Now the Grand Junction 

facility was located in Grand Junction, Colorado. The 

covered period is 1943 to 2006. The site was under 

contract to the AEC to support uranium processing, 

assaying, and milling remediation. There was some 

limited thorium exposures. 

Now in 1986, they started Grand Junction Remedial 

Action Project. And in 2006, the Grand Junction site 

was released. There was a Special Exposure Cohort 

from 1943 through 1985 due to the lack of internal 

dose reconstructability. Now before the TBD was 

issued -- now here's a dose reconstruction template 

for Grand Junction that was issued in 2015. And the 

TBD-0060 Revision 00 was issued in May of 2018. 

And the Subcommittee tasked SC&A with a review 

of this TBD in February of 2021. 

Now some other documents pertinent to this site 

was the PER-047 was issued in 2014. SC&A did a 
13

pretty extensive review of a lot of the data in 

response to that PER-047. And they issued a report 

in 2015. And NIOSH issued an addendum to the 

SEC in 2015 and SC&A reviewed that addendum in 

2016 and issued a report. 

Now NIOSH also issued PER-090 in 2019 to address 

the DR methods modified by issuing the TBD to 

replace the DR template for the facility. And SC&A 

has not -- They've been tasked to review PER-090. 

This tasking was only to review the recent TBD that 

was issued. 

Now of course the TBD-0060 has the standard six 

sections as we see in all TBDs. We will go through 

those in a little more detail. Okay, I know we 

reviewed each section. And in Section 2 is the site 

description. And it contained a reasonable amount 

of information about the facility and usual 

background for the dose reconstructor. Table 2-1 

summarized the buildings and our usage periods. 

And we had no findings or observations in this 

section. 

Now Section 3 was our occupational medical dose. 

Now at the Grand Junction facility, they switched off 

and on having the x-rays taken off site and on site. 

In the early years from '43 to '46, they had a 

preemployment manual and a post-employment xray exam used to be assigned. Now '47 through '61, 

it was taken off site, so no medical dose would be 

assigned. And then from '62 to '69, again we had 

the pre, the annual, and the post-employment x-ray 

to be assigned. In 1970 to present, it was taken off 

site, so no dose would be assigned for medical 

doses. 

And we found that these recommendations in the 

medical x-ray was consistent with other DOE sites 

and the records at the Grand Junction Facility. And 

we had no findings, but did have one observation. 

And that was a carryover observation in that the 

term "each year" needs to be clarified or replaced 

because the recommendation from 1943 to 1946 
14

contains the term "each year". And this could be 

misleading to the dose reconstructor because all 

exams wouldn't be assigned for each and every 

year. 

We also identified this in 2015 in our PER-047 

review as Observation 2, but it did not appear to be 

changed in the recent TBD. And so that really needs 

clarified so that a dose reconstructor wouldn't 

assign all of those three doses each year. 

Now Section 4, overhead, we did with onsite 

ambient and environmental dose. And it 

recommends that no on site ambient and 

environmental dose be assigned because it's 

accounted for in a co-exposure data assigned to 

unmonitored workers. And there was no indication 

that the ambient was extracted from the monitored 

dose. As I said, back in 2015, we went through the 

records -- or Dr. Hans Behling did. And so we also 

concur that there was no indication that the ambient 

dose was extracted. And we had no findings or 

observations in Section 4.

Okay, Section 5 had to do with internal dose. And 

we verified the prorated intake values for the 

categories listed in the tables. We verified the 

ingestion values according to TIB-9. And we concur 

with those sections and had no findings. We did 

have two observations. Okay, Observation 2 was 

apparent inconsistency in the DAC values. In the 

TBD in Section 5.3.4, NIOSH recommends a 

thorium-230 to derive their concentration. That 

value is 3 to the -12 microcuries for milliliter to 

derive the intake values for Table 5.6 for coexposures after 1990. And we did verify those 

numbers were entered correctly. 

However, we also noticed in an older memo --

2017, a memorandum indicated a DAC value of 7 

and a minus 12, about twice as high microcuries per 

mL was being used at the site. And so therefore 

there appears to be an inconsistency in DAV values 

used in the TBD and this memo that was issued in 
15

2017. We need a clarification of why there was a 

change or why this was done. 

Okay, Observation 3 was potential radon calibration 

chamber exposure. And so the TBD on Page 20 

states that any exposure from radon while working 

around radon calibration chamber was calculated as 

a working level month and should be provided in a 

worker's exposure file. And we had to question 

where some of the files examined of claimants that 

perhaps were working around the radon exposure 

chamber to see if there's actual working level 

months recorded in their file. Because in general, 

the site was bound by the 5.7 picocuries per liter 

found in Building 30B, which would apply to most of 

the most employees. But if a person was working 

with a radon calibration chamber, it's going to be 

higher in responding. Now it wasn't verified that 

there was some workers that had working level 

months recorded in their files. 

Okay, and the next section is 6, occupational 

external dose. Now according to the SEC 

unmonitored external dose cannot be reconstructed 

(audio interference) for 1960. Therefore this section 

applies to the period 1960 and forward. Now SC&A 

reviewed the references in the TBD for the (audio 

interference of detections and exchange frequency 

and found that they were correctly represented. 

And also the assignment of the energies, the 

different radiations were appropriate for uranium 

and the decay products. No issues there. And we 

analyzed the co-exposure methods for photons, 

betas, and neutrons presented in the TBD. So we'll 

cover each one of those in more detail of how the 

photon co-exposure dose. Again, we went through 

that data and found that they were applicable and 

how no issues there, just some thought notes. 

Now the beta dose in the TBD on Page 27 

recommends using a beta to photon ratio of 1.5 

derived from the REMS database. And we reviewed 

that REMS database in 2015 and concur with the 
16

beta to photon ratio of 1.5. And since that is the 

same value recommended in a TBD and we had no 

findings or concerns with the co-exposure beta dose 

or its application. 

Now for the neutron dose -- that was in Section 

6.5.3, SC&A checked the missed dose data used in 

Table 6.3 using the appropriate LODs and exchange 

frequency. We derived the same values as in 

Column 5 of that table. We had no findings 

concerning co-exposure neutron data, but did have 

two observations concerning the assignment of coexposure neutron doses.

Observation 5 was assigning a 95th percentile to 

only geologists. If you've ever been around a 

logging site, you know that probably the geologists 

aren't the ones that handle the source, it's the floor 

workers that get out and transport the neutron 

source to the logging tool, open it up, put it in, and 

then retrieve it -- restore it. And so we think that 

perhaps that workers that indicated they were tool 

workers worked on the drilling floor probably would 

be a higher exposure than the geologists. And so we 

would recommend that workers with any indication 

in their records showing working on the floor with a 

neutron source be given the 95th percentile also.

The Observation 5 is that we need some sort of 

substantiation for not assigning co-exposure 

neutron dose after 1985. TBD states on Page 28 

that after 1985 based on a review of the records, 

neutron dosimetry records are assumed to be 

complete. Therefore no unmonitored dose should be 

assigned after 1985. Now we looked through the 

information with TBD and the references there and 

we didn't really see anything that supported that. It 

might be true. There might be some indication that 

there would be no need to assign co-exposure dose 

after 1985 because everyone that handled neutron 

doses or had exposure to neutron doses was 

monitored. And we would recommend some sort of 

support for this assumption.
17

So in summary, we reviewed the TBD and compared 

it to the -- compared the present TBD to the 

previous templates and our previous reviews of 

those templates. We found the TBD to provide 

reasonable and technically-based recommendations, 

which was consistent with other DOE sites and 

previous templates used for the facility. 

We had no findings in this review, but had five 

observations that could benefit from some 

clarification or re-wording. And that's the text in the 

occupational medical section concerning each year. 

That value is used in radon calibration chamber 

potential exposure above the norm, assigning the 

95th neutron -- percentile neutron dose to some of 

the floor workers. And support of neutron 

recommendation after 1995, not assigning coexposure dose. Okay, any questions? 

Chair Beach: Any questions, Loretta or Paul or 

comments? 

Member Ziemer: Well, this is Paul. I have a couple 

questions. On Observation 1, which is the medical 

exam for the 1943 to '46 period, that period had 

pre-employment annual and post-employment xrays. And the issue had to do with the use of the 

term "each year". And it's not clear to me how that 

was misused. Certainly "annual dose" means each 

year, so was there -- were there some sentences 

that would lead one to believe that, that's not what 

was meant? Ron, could you clarify what was 

misleading about the use of "each year".

Dr. Buchanan: Well because if a person started 

working in '43 and terminated in '46, you wouldn't 

assign a pre-employment and a post-employment 

x-ray for each -- for '43, '44, '45, and '46. You'd 

only assign a pre-employment for '43 and 

termination x-rays of '46. You wouldn't assign all 

three every year that, that person worked there. 

Member Ziemer: So whatever the sentence was in 

the document, it implied that you would assign all 
18

three for each year. Is that what you're saying? 

Dr. Buchanan: Yes, for each year.

Member Ziemer: How should it be worded?

Dr. Buchanan: Well, it should be assigned as 

appropriate or something like that, rather than --

(Simultaneous speaking.)

Dr. Buchanan: Yeah, as appropriate, instead of 

assigning those three doses each year. 

Member Ziemer: Yeah. Would someone actually 

take it to mean that? You're saying there's some 

ambiguity. I'm okay on clarifying. I just wasn't sure 

what it actually said besides the words "each year." 

You're saying that it implies that you assign the pre 

and post, as well as the others each year. 

Dr. Buchanan: Right. And I can read it verbatim 

here. It says "pre-employment, annual, and postemployment, BHS, and AP pelvic x-ray exam for 

each year during the operation period before 1947."

Member Ziemer: I see, okay. Well I assume that 

NIOSH can figure out what to do to clarify that.

Okay. I'm fine with clarification. I just wasn't sure 

what it said that was wrong.

Chair Beach: And Paul, I also had a comment. 

Because this was also written up in the earlier 

document and it wasn't changed. Correct? 

Member Ziemer: Right. It came up off before. Yeah, 

I just didn't recall what exactly was going to be 

clarified. 

Chair Beach: Yeah. And you said you had a couple 

other questions. 

Member Ziemer: I had a question also on 

Observation 3, the radon chamber. I've used radon 

calibration chambers and in no case could a person 

enter one. They're big enough to put instruments in. 
19

So I wasn't clear. Is their radon chamber big 

enough a person could walk into it? 

Dr. Buchanan: That I couldn't -- I couldn't answer. I 

don't know the details. 

Member Ziemer: The biggest one I've seen is about 

the size of a 55-gallon drum, but maybe there are 

bigger ones that are as big as a room. But the 

implication on Observation 3 is that a person could 

go into the chamber. Was that your understanding 

of it, Ron? 

Dr. Buchanan: No, I debated that.

Member Ziemer: It talked about people who could 

enter the chamber. 

Dr. Buchanan: Well yeah, I guess that should say 

"work around a chamber". What our intent there 

was if -- Yeah.

Chair Beach: You do say "working around the radon 

calibration chamber." 

Member Ziemer: Well, the second bullet says 

"Workers who enter the chamber".

Dr. Buchanan: "Enter the chamber", right. And that 

should be "working around the chamber" because 

what our idea was whether you could enter it or 

couldn't enter it, you would be working -- taking the 

lid off or whatever you did, putting instruments in. 

Would that person be exposed to more than the 

others? And apparently they thought it might be 

because it says that the radon calibration chamber 

would be recorded as working level months. Our 

main question whether you get in it or just work 

around it or whatever is did they actually see any of 

that in any of the workers files? 

Member Ziemer: Yeah, okay. So your second bullet, 

you really mean workers who worked around the 

chamber versus --
20

Dr. Buchanan: Right. 

Member Ziemer: -- not necessarily entering. Okay, 

I've got you. Thank you. 

Chair Beach: Good catch, Paul. 

Member Ziemer: What's that? 

Chair Beach: I said that was a good catch. Yeah, 

just a wordsmith. Anything else, Paul? 

Member Ziemer: No. No. 

Chair Beach: Okay, thank you. Loretta, any 

questions? 

Member Valerio: The only question I had is what 

Paul just asked about the radon chamber because of 

the, you know, the verbiage that was in there. I 

thought the same thing, well are they going in or 

are they just working in close proximity? So that 

was my only question. 

But now that I look back, I do have one question 

regarding the occupational medical. And looking at 

the dates that the occupational medical was done 

off site, it appears that it was done off site more 

than on site. Is there a reason for that? 

Dr. Buchanan: I don't know. I would say that Grand 

Junction, you know, was a fairly small site 

compared to the other DOE sites. And I would just 

have to assume that they didn't have all the 

facilities there all the time. I can't answer that for 

sure, but that would be my impression that they 

didn't have all the medical staff there to do it on site 

all the time. But you know, perhaps (audio 

interference) can shed my light on that. I don't 

know for sure.

Chair Beach: Okay. And are we ready -- NIOSH, are 

you ready to go through any of these?

Dr. Taulbee: This is Tim Taulbee. Actually we are 
21

not at this point. As you know, Tom Tomes was the 

lead for the Grand Junction site for us and he retired 

at the end of August. Alek Kranbuhl is the new 

DCAS lead for this and he just got assigned this site 

a couple of weeks ago. So we're actually not in a 

position to go through all of these one by one. But 

we will follow up and get back to you all on them. 

I do want to say as far as the x-ray discussion that 

was just going on, I mean that's a simple 

clarification that we can do. And you know we've 

done -- had to do that at multiple sites. And this is 

more of an oversight that we missed it in this 

revision here. But the clear indication here is, you 

know, you do a pre-employment regardless of when 

they start, an annual one for each of the years 

afterwards, and then a post-employment. That's the 

intent and that's what we're doing in dose 

reconstruction. But we can simply clarify that 

language. That's not a problem at all. And the 

others, we will be following up with you all on.

Chair Beach: Okay. Thank you, Tim. I was pulling 

back to that very first one that Paul talked about, if 

you had any comments on that one. Where was it? 

Okay, we'll wait for you.

Member Ziemer: That was just the each year annual 

--

(Simultaneous speaking.)

Member Ziemer: -- that they would take care of 

that. That was Observation 1. 

Chair Beach: Yeah, I was just -- and, Tim, you 

probably can't comment on why they didn't change 

it because it was an observation in --

(Simultaneous speaking.)

Member Ziemer: It sounds like it might have been 

an oversight from what Tim said.

Chair Beach: Yeah. Okay. Any other comments 
22

before we move on to Clarksville and Medina site, 

PER-087?

Member Ziemer: Do we have to close observations 

or are these just going to -- these are going to 

remain in abeyance, I guess. Right? 

Chair Beach: Yeah, we're going to carry them 

forward until we hear -- until NIOSH --

Member Ziemer: Yeah.

Chair Beach: Yeah, and I don't know that we would 

-- we would just leave them open at this point since 

there's no --

Member Ziemer: Yeah. 

Chair Beach: Yeah. We did close 057, though.

Member Ziemer: Right. 

Chair Beach: But these other (audio interference) 

NIOSH is ready, we'll just leave them open. 

Member Ziemer: Thank you.

Chair Beach: Okay. Thanks, Paul. 

Member Valerio: Josie, it's Loretta. I have a 

question for you. 

Chair Beach: Okay.

Member Valerio: He did say that SC&A may have 

not been tasked to review our PER-090.

Chair Beach: Oh, thank you. 

Member Valerio: Is that something that, you know, 

should be assigned to SC&A?

Chair Beach: Good question. I had that written 

down in my notes too and just went right over the 

top of it. That is something that I thought we should 

look at also. Paul, what is your thoughts on 

assigning PER-090?
23

Member Ziemer: Well at some point, it certainly has 

to be tasked. I wasn't sure of the hierarchy of 

things. Do we put that in the -- kind of in the list for 

Rashaun to look at in terms of other tasking that 

may be coming. I don't have a feel for where that 

would be priority wise. 

Chair Beach: Yeah, I'm not sure either. So Kathy, 

could you make a note of that for tasking for the 

future and Rashaun also?

Ms. Behling: Actually Josie, in my final presentation 

on supplemental topics, it's newly issued documents 

and supplemental topics is my final discussion. I've 

included that as one of the slides that I was going to 

point out to the Subcommittee that has not been 

reviewed. So that's already on my list. And I was 

going to have that written down too. 

Chair Beach: Okay. We will discuss that later. 

Ms. Behling: Okay, great.

Chair Beach: Okay. And is Ron -- is he going to 

present Clarksville also? 

Ms. Behling: Yes. Ron's up for Clarksville. 

Chair Beach: Okay, I think we're ready. 

Ms. Behling: Ron, are you ready? 

Dr. Buchanan: Okay, I'm ready. Can you hear me 

okay?

Ms. Behling: Yes. We hear you now.

Dr. Buchanan: Okay. This is Ron Buchanan and 

today I'll be presenting SC&As review of PER-087 

for Clarksville and Medina Modification Center. The 

co-author on this was Joe Fitzgerald. 

The Clarksville Modification Center was located in 

Clarksville, Tennessee. The covered period is 1949 
24

to 1967. The Medina Modification Center was 

located near San Antonio, Texas. And covered the 

period 1958 to 1966. The two sites were under 

contract at AEC to support nuclear weapons and 

weapon components, maintenance, and storage. 

PER-087 was issued in January of 2019 for the two 

facilities. The earlier revisions to the TBD-39 

primarily resulted in a decrease or no change to the 

dose estimate. So there's no need to issue a PER087. However, PER-087 was issued in 2019 because 

Revision 3 of the TBD was issued in 2017 would 

increase some external dose assignments. 

Now the potential area of external dose increase, 

there was three: Lumbar spine exam dose to some 

organs increased because of the use of OTIB-0006. 

The dose to the lower torso organs could increase 

for some workers due to establishing scaling factors 

for workers who held weapon pits in their laps in a 

sitting position. So dosimetry on the chest wouldn't 

necessary give a correct reading. And so it was 

modified by scaling factors. And unmonitored 

external shallow dose increase for all years due to 

the incorporation of OTIB-0086 into the Pantex 

technical-based document. 

Now in this case as we'll find out a little later, the 

external exposure for Pantex was used as a coexposure for these two facilities. Now, the internal 

dose, there was no changes in Rev 3 of the TBD 

that resulted in increased internal dose. And so 

PER-087 didn't contain an internal dose modification 

or recommendations. 

Now a little history of these two facilities and dose 

reconstruction. Initial dose reconstructions were 

based on the complex-wide methods or other 

documents. The first TBD Revision 00 came out in 

(audio interference). And you can see Revision 001, 

002. And then 003 came out in 2017. So the 

important ones are Revision 00 and Revision 003, 

which resulted in increase in external dose. So we'll 

cover those. 
25

Now the cases to be evaluated under this PER-087 

was all of them because there was a variety of 

methods used in the past. So no population of 

claims were excluded from reevaluation because of 

this PER. All claims associated with the two facilities 

were considered. 

Now a little background on this. In March of 2021, 

the Advisory Board tasked SC&A to review PER-087, 

which came about because of the issuance of the 

TBD Revision 003. And to do that then, we had to 

also look at Revision 00, our findings from our 

review of that. So really a three level process going 

back to find out where it stood on our findings in 

Revision 00. And in evaluating Revision 003 to see if 

it addressed them. And then see if those changes 

were addressed in PER-087. And then evaluating 

PER-087. It's kind of a three tier report approach. 

And of course, a standard PER review has four 

subtasks as listed there. And we issued a Revision 1 

of our report on September 28th of 2021. And so 

we'll go into a little more detail on each of these 

subtasks next. 

Okay, Subtask 1 was to identify the circumstances 

that necessitate the PER-087. In SC&A evaluation, 

we found that NIOSH correctly identifies the 

changes in the Revision 3 and addressed them in 

PER-087. And had no observation of finding 

concerning Subtask 1. 

Subtask 2 was we were to assess the specific 

methods for corrective actions, including a review of 

the TBD Revision 3. And so our methodology was 

we evaluated the status of the findings from SC&A's 

review of the TBD Revision 00. And reviewed TBD 

Revision 03 that created PER-087. 

So we'll go back a little bit in time here and look at 

Revision 00. We were tasked to review that. And 

SC&A issued a report in 2012 and identified findings 

that could impact dose reconstruction. And we 

identified four findings -- excuse me -- seven 
26

findings concerning internal and external DR. 

Okay, there was four findings concerning internal 

dose. Finding 1, 2, 3, and 5. However, all of these 

dose findings are (audio interference) by the SEC 

for all Classes for both the (audio interference) the 

operating years due to the inability to reconstruct 

internal dose. So that just left us with the external 

findings. 

And so the external findings from our original 

review, in Revision 00, we had three of them. 

Finding 4 was neutron-to-photon ratio method that 

was cited. It was replaced with a correction factor 

for neutron film, coupled with a Monte Carlo NParticle -- MCNP-based estimate for missed dose 

below the 0.5 MeV energy ratio. In other words, 

when they abandoned the neutron-to-photon ratio 

and went to correction factor created to compensate 

for the below half MeV energy ratio that NTA 

neutron film suffered from back in early years. 

However, we still had some questions concerning 

that and an original review of Revision 00. 

Now Finding 6 concerned the use of surrogate 

Pantex external dose distribution for the two 

facilities because of the lack of dose records in 

earlier years, uncertainties, and operational 

information. Now Finding 7 was lack of dose records 

and source term characterization for the two 

facilities led to inadequate justification of surrogate 

data. 

So we'll go into those findings in a little detail here. 

These are original findings way back in 2012 or so 

and how they were resolved. We found that for 

Finding 4, concerning neutron dose, the N/P ratio 

has been replaced by the MCNP-based. However, in 

the following TBD revisions, the MCNP approach was 

not used and the correction factors were invoked. In 

other words, the different corrector factor for fading 

angular such as that all came out to an overall 

correction factor of 2.9. Now we evaluated these 

individual correction factors and resulting correction 
27

factor of 2.9 and satisfied this was claimant 

favorable and was a better approach than the 

previous MCNP approach. And we considered that 

Finding 4 has been resolved.

Now Finding 6 was the use of the surrogate Pantex 

external dose distribution for the centers. And 

NIOSH re-worked all the previous claims using PER087 and Revision 3 of the TBD -- I mean, excuse 

me -- In PER-087, they used Revision 3 of TBD and 

OTIB-0086. And therefore the change in external 

dose was accounted for. We had previously 

reviewed those OTIB-0086 and we are satisfied with 

this resolution and consider this issued Finding 6 

resolved.

Now Finding 7 however was -- Finding 6 was 

concern with using -- how it was applied. Now 

Finding 7 was more concerned with does this 

surrogate have a fit for these facilities? And our 

Finding 7 back in our original review did not find 

that it was addressed adequately. Now we reviewed 

Revision 3 of the TBD and did not find additional 

information that would address this. So we 

recommend that the original Finding 7 remain open 

as Finding 1 in our review of PER-087. In other 

words, support for the fact that the data for Pantex 

would apply to Clarksville and Medina in the earlier 

years especially when Pantex was more gearing up. 

And the other one -- Well, especially Clarksville was 

in operation. So that's why we recommend that 

Finding 7 remain open as Finding 1 for this review.

Okay, now the issue of the TBD Revision 3 that 

resulted in PER-087 -- we covered these briefly and 

we'll go into our evaluation of the three technical 

issues was the surrogate organ use for lumbar 

spine, the pits in the lap adjustment -- adjustment 

factor, and a shallow dose assignment. So we'll look 

at these individually now.

Okay, now the surrogate organ, we find that the 

surrogate organ changes in the TBD Revision 3 was 

correctly addressed in 087. In other words, they 
28

were compensated for and correctly addressed for 

dose reconstruction purposes. Now, the pits in the 

lap adjustment, while SC&A concurs with the 

derivation of the scaling factor of 0.125, the 

question is application of it, as stated on Page 27 of 

the TBD Revision 3, and I'll talk about this in 

Observation 1 in the next slide. 

Now, the shallow dose, SC&A concurs that 

application of OTIB-0086 Revision 1 should be used 

for shallow dose, per the Pantex external dose TBD 

pending, resolution of Finding 7. 

Okay, so, Observation 1 was the scaling factor 

needs clarification. The TBD on Page 27 instructs 

the dose reconstructor to multiply the 95th 

percentile of glovebox correction factor, which he 

derives the numbers in parentheses by 0.125. 

However, this would equal 0.44, which would lower 

the actual dose assignment. We think that it should 

read as the scaling factor we have listed there. It 

would appear that the wording in the first paragraph 

on Page 27 to Revision 3 should instruct the dose 

reconstructor to include the 7/8 factor. Add that in. 

That makes it come out to 1.32 as the actual 

multiplication factor. Hence, we think that's 

probably just an oversight that needs clarification. 

Okay, so, now Task 3, which we were to evaluate 

the PER's stated approach for identifying the 

number of DRs requiring reevaluation. In other 

words, how they were selected. And NIOSH surface 

(phonetic) resulted in a total of 172 claims for these 

two facilities. Fifty of them were reworked and 122 

were removed for various reasons such as 51 

previously had DRs greater than 50 percent. So no 

re-work was necessary. Forty-nine was included in a 

SEC, so no re-work was necessary. Eleven were 

duplicate claims identified in additional research. 

And then 11 were evaluated under PER for Pantex. 

So that left 50 claims to be recalculated using 

Revision 3 of the TBD in conjunction with PER-087. 

Now NIOSH did re-work all 50 claims and resulted in 
29

a new -- new PoCs below 45 percent. So our 

evaluation for Subtask 3 is SC&A determined that 

the selection process is per NIOSH, the previously 

completed DRs that required reevaluation under 

PER-087 were valid. We had no findings or 

observations associated with Subtask 3. 

Okay, Subtask 4 is to conduct an audit of a sample 

set of reevaluated DRs mandated by PER-087. And 

in this now -- of course, this is yet to be done -- we 

recommend that NIOSH select at least one DR to be 

reviewed for each of the centers during the covered 

periods. And each DR needs to include the 

requirements of assigning lumbar spine x-ray dose 

or a torso dose due to handling weapon pits in the 

lab and external shallow dose. 

And of course if all these exposures cannot be 

located in a single DR for each site, then additional 

DRs that do contain these elements would be 

needed. So currently we have no findings or 

observations concerning Task 4 because we have 

not yet been assigned the review cases.

So in summary, we have Finding 1 was the use of 

surrogate data in Clarksville, not adequately 

addressed in the TBD, which was originally Finding 4 

from our 2012 review of Revision 00. And 

Observation 1 was scaling factor needs some 

clarification in its wording in application.

Chair Beach: Okay. Thank you, Ron. That was a 

good review. The Subcommittee, we have Finding 4 

and 6 that SC&A recommends closure on those. 

That they feel those are resolved. Should we start 

there with questions or comments? 

Member Ziemer: This is Ziemer. I don't have any 

questions. I'm in agreement on closing 4 and 6. 

Chair Beach: Okay. I agree with that. And Loretta? 

Member Valerio: I agree with that as well, Josie.

Chair Beach: Okay, so we will take SC&As 
30

recommendation that Findings 4 and 6 are both 

resolved.

Member Ziemer: And then Finding 7 would remain 

open as a new Finding 1 for this PER. Is that my 

understanding? 

Chair Beach: Yes. 

Member Ziemer: As well as the Observation 1, 

mmm hmm. 

Chair Beach: Finding 7 as a new Finding 1 and then 

Observation 1, the scaling factor needs clarification. 

So, yes. NIOSH are you ready to comment on either 

of those? 

Dr. Taulbee: This is Tim. Yes, we can comment. 

First of all, want some clarification on Finding 1 

because this one actually caused us some confusion 

because of the Finding 6 that you all just closed, we 

read as the external dose methodology was correct. 

But what I'm hearing from Ron and this is where 

I'm seeking clarification is that the methodology is 

correct and we applied it correctly. But this finding -

- Finding 1 is that we didn't justify using that. Is 

that what you're saying? 

Dr. Buchanan: Yes. This goes back to 2012 review 

in that when you applied OTIB-0086 and 

everything, we agreed with the methodology and 

the application of it. But the justification for 

applying Pantex external dose to Clarksville when 

Clarksville was up and running before Pantex was 

up and running was the question. That is where 

we'd like to see further support for why it is 

believed that the doses would be bound -- that the 

Pantex dose could bound Clarksville dose, especially 

in the early years. 

Dr. Taulbee: Okay. So providing we do that, then 

the application that we've done has already been 

reviewed. 

Dr. Buchanan: Correct. Uh huh. 
31

Dr. Taulbee: Okay. 

Dr. Buchanan: Right.

Dr. Taulbee: All right. Thank you for that 

clarification and we can certainly -- well, we will 

provide a response from that and possibly update 

the TBD to include that, but we will provide a 

response. 

Observation 1, there is actually a typo in the units 

that's in the TBD in going through and reviewing 

this. And I believe this is what's causing some of the 

confusion. With regards to the, you know, "five 

hours per week" is what it should read, instead of 

"five hours per day". And so that does cause a little 

bit of confusion. And the scaling factor equation that 

you've got here at the bottom of your Slide 19 is 

the correct application. And that is what we are 

intending to be for the response in here. We believe 

we're applying that correctly right now, but we 

agree that we should clarify that in the TBD so there 

isn't any ambiguity from that standpoint and people 

wouldn't come up with a 0.44. But we believe this is 

being applied correctly right now. 

Chair Beach: Okay. So any other comments or 

questions on either of those? 

Member Ziemer: Yeah, this is Paul. I have one 

additional question just for clarification. So on the 

use of surrogate data, can you remind me whether 

or not when this was done originally, did NIOSH 

look at the surrogate data criteria and present 

those? Or SC&A, are you saying that they didn't 

actually go through the justification process? 

Dr. Buchanan: Okay. This is 2012 when Joe 

Fitzgerald actually did this finding, so I'll speak what 

I know of it. Is that yes, originally SC&A did not feel 

that Pantex -- the use of Pantex surrogate data for 

Clarksville was sufficiently supported in Revision 00. 

And then in Revision 03, we didn't see any further 

additional support for it. So this is the reason we 
32

brought it up again. 

Member Ziemer: Or Tim, do you know at this point 

whether -- is that the issue, the use of the 

surrogate data without doing the justification on the 

surrogate data criteria or do you know whether that 

was done? 

Dr. Taulbee: That is my understanding now that, 

that is what this new issue effectively is, is that we 

haven't documented that within the TBD, our use of 

the surrogate data. And so we can certainly do so.

Member Ziemer: Thank you.

Chair Beach: Great. That was my question as well 

against the surrogate data criteria. So thanks for 

raising that, Paul. Subtask 4, Kathy is that part -- I 

don't believe that's part of your tasking review. 

Ms. Behling: No, it's not. Yeah. I'm sorry. No, it's 

not because typically we resolve all of the issues --

the findings and observations before we move on to 

the Subtask 4. 

Chair Beach: Okay, that makes sense. So then 

anything else on PER-087? If not, I think we're 

ready to move on. 

Ms. Marion-Moss: Hey, Josie.

Chair Beach: Go ahead, Rashaun.

Ms. Marion-Moss: This is Lori. 

Chair Beach: Who is this? 

Ms. Marion-Moss: Lori. I have a question. 

Chair Beach: I'm sorry. Hi, Lori.

Ms. Marion-Moss: Hi. In terms of tracking the TBD 

findings, is the Subcommittee tracking the TBD 

findings? 

Chair Beach: I believe Kathy is keeping a note of 
33

those and I'm also keeping a note. Is that correct, 

Kathy? 

Ms. Behling: Yes, it is.

Chair Beach: Yeah, that's something I was going to 

try to discuss at the end of the meeting also is 

tracking and keeping tabs. Because without the BRS 

to go back and look through, this might get 

complicated. 

Ms. Marion-Moss: Well, I'm more so referring to the 

2012 findings that were issued. Was the 

Subcommittee tracking those findings or were they 

tracked by some other workgroup or another 

Subcommittee? 

Chair Beach: I don't believe there's a 

Clarksville/Medina workgroup, so I believe the 

Subcommittee would. Is that correct, Kathy? Do you 

know if the BRS is tracking that? 

Ms. Behling: I'm not sure about that. I know Joe 

Fitzgerald, like you said, worked on the original. And 

quite honestly, I'd have to look into that. 

Chair Beach: Thank you.

Ms. Behling: And I'll mark that down.

Chair Beach: Thanks, Lori. Yeah, that's something 

that we're going to have to address before we get 

too far in is tracking these. So I'll note that as well. 

Okay. And I think if we're ready, we can move on to 

PER-006, calculation of dose from intakes of special 

tritium compounds. Who's got that one? I haven't 

pulled it up yet. 

Dr. Ostrow: Hi. It's Steve Ostrow. This is me as 

soon as Kathy gets up the slides.

Ms. Behling: Yeah, I'm looking for them.

Dr. Ostrow: Kathy, if you go back to the NIOSH 

homepage we were just on and go a little bit to the 
34

right of that on your screen, that's where the --

Okay. So you see NIOSH homepage on the left. 

Okay, just move your cursor a little bit to the right 

and that's where the OTIB -- down, down, down a 

little more. Okay, stop. All right --

Ms. Behling: Okay. 

Dr. Ostrow: -- now go up a little -- go up a little, 

now to the right. Just go to the right --

Ms. Behling: Okay.

Dr. Ostrow: -- to the presentation focused review 

for ORAUT-OTIB. Down, down one. Down one.

Ms. Behling: Okay. Sorry about that. 

Dr. Ostrow: Okay. 

Chair Beach: No problem. 

Dr. Ostrow: That's it.

Ms. Behling: There it is. I kept looking for "memo" 

for some memo, so sorry. Okay. 

Dr. Ostrow: All right, that's it. All right, so this is 

me, Steve Ostrow. And before we go to the next 

slide, OTIB-0066 full name is the calculation of dose 

from intake to special tritium compounds. So just 

before the preface, what do they mean by "special"? 

In this case, it refers to tritium compounds in a 

metal matrix rather than tritiated water. It's also 

called stable metal tritides, SMT. So that's what 

they're referring to when they say "special".

Okay, next slide please. All right, so what's the 

purpose of the review? This was a focused review, 

which means we didn't start reviewing the entire 

procedure of the OTIB again. It's just to see if the 

latest revision -- if Revision 1 of the OTIB addressed 

the SC&A comments. And you can see relevant 

documents below where we have that on that slide. 

The original OTIB came out in 2007. That was Rev 
35

7. SC&A made comments on it. SC&A made 

comments on it in 2008. That was a while ago,

ORAU. NIOSH revised it recently -- well, about a 

year ago in 2020. And SC&A reviewed it. Did the 

focus review in April of 2021. So this slide 

presentation is basically a quick look at what our 

focused review was in April 28, 2001. 

Next slide, please. How did we review it? We looked 

at a few things. We compared the original revision 

(audio interference) and Rev 1 to see where the Rev 

1 (audio interference) Rev 00. We also looked while 

we were at it at BRS because there's a number of 

entries over the years on the OTIB. And then we 

also took a look at the procedures Subcommittee 

discussions. There were some discussions pertaining 

to the OTIB over the years. So we looked at three 

things.

Next slide please. All right, so what are the issues 

looking at? A little bit of background, this is taken 

from the OTIB Section 2, the purpose. And it 

explains that stable metal tritides are tritium 

compounds that cannot be detected by urine 

bioassay as easily as easily as tritium oxide. 

Because the particles in a stable metal tritide, the 

tritium is in a metal matrix and it's strongly retained 

in the lungs. So what happens is that over time, the 

particle of the stable metal tritide slowly dissolves in 

the lungs and the tritium defuses out. And 

eventually it's converted to heavy water, which 

subsequently can be treated like the standard 

biokinetic model for the HTO. 

So what happens is that this material is more 

strongly retained in the lungs. You get much smaller 

dose fractions of the intake excreted in the urine 

over time. Therefore, relatively small amounts of 

tritium in the urine sample can indicate a large 

intake of a special metal tritide. But it's not a good 

indication of that unless you make some 

adjustments.

Next slide please. And the OTIB purpose of it is to 
36

give guidance to the dose reconstructor of how to 

use urine bioassay data in a case where you have 

tritium in a metal matrix. 

Okay, next slide. Okay, our original 2008 evaluation 

has four findings. After discussions at the March 

24th, 2009 procedures meeting, the Findings 1 and 

3 were placed in the Abeyance and 2 and 4 were 

closed. So we're only left with Findings 1 and 3. And 

that's what Revision 1 of the OTIB addresses. And 

that's what our review of the revision addresses. 

Next slide. All right, this is a lot of words on this 

slide. I apologize. The Finding 1 of our 2008 review 

basically dealt with the recommended method. The 

OTIB refers to ORAU-OTIB-0011, which is tritium 

calculated in this dose estimate back in 2004 

document. And we found that this methodology 

can't estimate the dose coefficient, which convert 

the concentration of picocuries to millirems. And we 

found that on the various references that we gave 

that the other references, which are mainly the 

ICRP ones give a factor of 1.4 times higher than the 

ones apply to methodology given in ORAUT-OTIB0011. That was our first finding that basically the 

method given underestimates the dose.

Next slide please. Okay, how is it resolved? Well 

first, the BRS, NIOSH recognized and they agreed 

with our findings. And the OTIB itself, Revision 1 

gives recommendations at the end of the OTIB. And 

they said because the ORAU-OTIB-0011 method 

underestimates those from organically bound tritium 

intake by about 30 percent, it could not be used for 

assessment. And said you have to use IMBA when 

it's based on urine bioassay in IMBA or Web CAD, 

the dose assessment. So they agree with us in this.

Okay, next slide. Finding 3, which is the second 

finding that was in abeyance -- and this one, we felt 

that the guidance was a little bit inadequate in 

giving background information. That the method of 

choice if they have available, they should use the 

actual personnel monitoring -- particulate air 
37

monitoring if it's available rather than a urinalysis 

method.

Okay, next slide. We looked again at the BRS and 

NIOSH agreed with us again and committed to 

putting some words -- additional words into the 

OTIB to reflect that. They agreed.

Next slide. Okay, so the resolution, the Section 2.0, 

the purpose section of the OTIB -- revised OTIB 

expanded a lot that section. And NIOSH added a 

paragraph to discuss and gives more guidance to 

the dose reconstructor. And the slides here and 

earlier on the seventh slide had given some more 

background information on that. So finally, we 

looked at the two findings and how NIOSH dealt 

with it.

Go to the next slide please. And we concluded -- we 

did a focused review and we concluded that Findings 

1 and 3 have been adequately addressed and 

resolved. NIOSH followed our recommendation. 

They clarified several points and so forth. So we 

recommend that the Subcommittee close Findings 1 

and 3. So that's it. Do you have any questions? 

Chair Beach: Okay, thanks. Subcommittee 

Members, Paul or Loretta, do you have any 

questions? 

Member Ziemer: I have no questions. I'm pleased 

that they were able to resolve this. And thank you, 

Steve, for the presentation. I'm comfortable in 

closing both of these. 

Chair Beach: Okay. And Loretta, anything? 

Member Valerio: No, I'm good with closing them as 

well, Josie. Thank you. 

Chair Beach: Okay. So I'm also okay with closing. 

So this will finish the closeout for Findings 1 and 3 

in OTIB-0066 Rev 1. And Kathy, I'm assuming 

you're going to make note of that.
38

Ms. Behling: Yes, we will make note of that.

(Simultaneous speaking.)

Ms. Behling: No, we do not have any access to BRS 

and don't think that's coming in any near future. 

Chair Beach: When I was looking through Steve's 

presentation, I thought oh, they've got access, but 

no. Okay. 

Dr. Ostrow: No. Fortunately I did this before NIOSH 

decided to redo their computer system. 

Chair Beach: Gotcha, okay. So we'll close those. 

How is everybody doing on -- Are we ready for a 

comfort break or can you go for another -- I think 

the next two are fairly brief -- Subtask 4 is --

Member Ziemer: I'm okay, Josie. 

Chair Beach: You're okay for a little bit. And Loretta 

as well? 

Member Valerio: I'm okay. I'm fine. 

Chair Beach: Okay, so we'll wait for PER-006 

Subtask 4 to be put up on the screen. And I didn't 

ask NIOSH, any comments or are you okay with all 

of that? 

Dr. Taulbee: I believe we're okay with all of that. 

Thank you. 

Chair Beach: Tim, thanks. 

Ms. Behling: Okay. Then if we're ready, I'll address 

the PER-065, Subtask 4. And this is actually under 

our case review for the Anaconda Technical Basis 

Document TBD. And PER-065 was issued in 

November of 2015 for as I said revisions to the 

Anaconda Site Profile, which is actually addressed 

under Appendix G of Battelle-TBD-6000. And the 

revision increased external dose to all job categories 

for all years of operation due to incorporating 

changes to the Battelle-TBD-6000. SC&As review of 
39

PER-065 was issued on June 15th, 2017 and that 

review included an evaluation of the Anaconda Site 

Profile. And there were no findings from that review. 

For SC&As Subtask 4 review, we reviewed cases 

obviously impacted by the PER. And for this PER, 

the Board selected one case that met the criteria 

where external dose was assigned for operators and 

laborers and the employment was during the 

operational years between 1956 and 1958. SC&A 

issued our subtask for review on August 25th, 2021. 

And if you have access to that right now, I would 

encourage you to refer to it because during this 

presentation, I obviously have to be concerned 

about Privacy Act issues. And I can only provide 

limited case-specific data. So if you have that 

available, it may help you as we're going through 

this presentation.

Okay, NIOSH reworked the cases using the most 

current DR tools. They recalculated all the annual 

doses and they reran IREP. And the revised DR for 

this case was not sent to DOL because the 

compensation decision did not change. Although 

SC&As case reviews are typically limited to 

reevaluating only the pathways addressed in the 

PER, in addition to the external dose, which was 

addressed by this PER, SC&A also looked at the 

internal dose. And the internal dose was included in 

this evaluation because we determined that the 

Board would be interested in having an 

understanding as to why there was such a 

significant reduction in that internal dose. So we did 

briefly look at that.

Okay, a little background for this case. EE worked at 

Anaconda for approximately three decades and 

worked throughout the site. The worker was not 

monitored and was diagnosed with a qualifying 

cancer several years after termination of 

employment. 

Sorry. This slide shows percent changes between 

the re-work dose reconstruction and the original 
40

dose reconstruction. If you refer to Table 2-1 on 

Page 7 of our full Subtask 4 report, you can see the 

original and re-worked doses. But this table shows 

that there were reduction in all categories except for 

the medical dose. And as I mentioned, nearly 100 

percent reduction in the internal dose. 

Okay, the original dose reconstruction was actually 

performed prior to the issuance of TBD-6000, 

Appendix G. And it used Scherpelz 2006. And this 

reference was actually used ultimately as a basis for 

the TBD-6000, Appendix G. During the dose 

reconstruction, very claimant-favorable assumptions 

were made. And it was assumed that the EE was 

exposed at 1 foot from the rectangular uranium slab 

for three days in 1956 and 30 days in 1959. And 

that was considered a 10-hour work day at 2.08 

milligram per hour. The bladder was assumed as a 

surrogate organ for the photon dose and a DCF of 

1.523 then was applied. And this resulted in an 

assigned external dose of greater than 1 rem.

The re-worked external dose, NIOSH used guidance 

in Appendix G, Rev 1 of TBD-6000. And the external 

doses were calculated using annual photon doses 

for years 1956 through 1959 from Table G2 of the 

revised document. And due to revisions in OTIB0005 during the time of this re-work, it was OTIB0005, Rev 5 that was used, the liver was assumed 

as a surrogate organ. And then a photon DCF of 

1.064 was applied. This resulted in the assignment 

of an external dose of approximately 50 millirem. 

Now I will point out just for clarification that PER065 was issued to an increase in external dose. And 

that's true because if we go to the original Appendix 

G, there is a G3 and the dose is significantly 

increased in Rev 1. However, this dose 

reconstruction was done prior to the issuance of 

TBD-6000 and used conservative assumptions, 

which resulted for this case, a decrease in the 

external dose. 

Okay, the medical dose in the original dose 
41

reconstruction was based on assuming an annual xray for each year of employment. The urinary 

bladder was the surrogate organ and the dose data 

from Table 6-5 of OTIB-0006, Rev 3 was used. And 

this resulted in the assignment of about 100 

millirem for occupational medical dose. 

In the re-work case, they also assumed an annual 

x-ray for each year of employment. However, due 

to changes in OTIB-0005, the gallbladder was 

assumed as a surrogate organ. And using the same 

dose data from OTIB-0006, it resulted in the 

assignment of greater than 300 millirem for 

occupational medical dose in the re-worked case. 

Okay for internal dose, uranium intakes were 

assigned for extrusion and rolling in 1956 and '59 

using operator data from Table 7.8 of Scherpelz 

2006. And I'll just make mention that, that 

reference, the air sampling data was based on a 

summary of AWE metal-working sites. That's how 

they derived the data that went into this Table 7.8. 

For claimant favorability, a 30-day intake for each 

process was used for each year in 1956 and 1959. 

And intakes of recycled uranium from plutonium239 and neptunium-237 were scaled according to 

the uranium intakes. Type M solubility was the most 

claimant favorable and that was used in both 

inhalation and ingestion intakes were applied as 

inhalation, which is another claimant-favorable 

assumption. And this resulted in the assignment of 

0.250 rem.

Now for the re-work, uranium intakes were assigned 

based on inhalation and ingestion intakes from 

Appendix G Rev 1, Table G1. And Appendix G --

Yeah, Appendix G used for finding their air dose, 

they looked at the sampling data was based on the 

highest air monitoring data in the workplace from 

two surveys that were taken by the Health and 

Safety Laboratory in 1956 and 1959. And that 

resulted in 39 DPM per cubic meters. The doses 

were calculated for each year of uranium 
42

operations, 1956 through 1959. And again, Type M 

solubility was found to be claimant-favorable. And 

this resulted in the assignment of 1 millirem. 

So SC&As conclusion on the re-worked external 

dose, appropriate dose assignments were made 

based on the Appendix G information. The surrogate 

organ was based on the current revision of the 

OTIB-0005 and doses were correctly entered into 

IREP. 

For occupational medical dose, we also found that 

the appropriate doses were assigned based on 

OTIB-0006. Surrogate organ selection was correct 

based on OTIB-0005 and the doses were again 

entered into IREP correctly. 

For internal dose, we found that the appropriate 

intake values as specified in Appendix G were used. 

The input data was entered into IMBA correctly and 

the assumptions were claimant-favorable. So as a 

result of our review of this one impacted case, we 

had no findings. Any questions? 

Chair Beach: Thank you. Kathy, back on Slide 9, 

you mentioned the Appendix G for TBD-6000 was 

published a year after the original DR. Would that 

have made any difference? 

Ms. Behling: Yes. Yes. The doses would have been a 

lot less if when this dose reconstruction was 

originally done, if they had used Rev 00 of Appendix 

G, the doses would have been a lot less than what 

was used in this. This is a very claimant-favorable 

DR.

Chair Beach: Thank you. Paul or Loretta, any 

questions or comments? 

Member Ziemer: I don't -- This is Paul. I don't have 

a specific question on the re-work per se, but I'm 

trying to recall how and why the Procedures 

Subcommittee is looking at individual PER cases.
43

Chair Beach: This is the Subtask 4. That's how we 

close out these other procedures. Correct? 

Ms. Behling: Yes. The PER process -- the protocol 

that SC&A has established for the PER is under --

we reviewed the PER initially. And then we select an 

appropriate number of cases that meet the criteria 

that prompted the PER. And we look at a few of 

those cases to ensure that they were re-worked as 

specified in the PER and as corrected by whatever 

documents needs to be corrected. 

Member Ziemer: Yeah, yeah. That's the part I 

understand. But I'm not clear, are we actually 

tracking these in the -- in the tracking system -- the 

individual cases? 

Ms. Behling: We do.

Member Ziemer: Okay. 

Ms. Behling: We do put a section in there that the 

Subtask 4 has been reviewed and whether there's 

any findings associated with that, yes. 

Member Ziemer: Yeah, okay. In other words if in 

fact even though we approved the PER, if in fact 

they weren't carrying out correctly, that would be 

noted. 

Ms. Behling: Correct, yes. 

Member Ziemer: I got you. 

Ms. Behling: In fact, earlier today Bob Anigstein 

talked about Observation 6 from PER-057. And that 

was, I think associated with a Subtask 4 review. 

Member Ziemer: Oh, okay. I got you. 

Ms. Behling: Yeah.

Member Ziemer: I just didn't remember how we 

were including these in the system. 

Ms. Behling: Yeah. No, good question. Yes, good 
44

question. I was making note -- When we had access 

to the BRS, I was making note that there would be 

Subtask 4 findings. That's how I entered them into 

the system. 

Chair Beach: Right. 

Member Ziemer: Yeah. In cases where they are at a 

location where we have a workgroup, they would be 

reviewing these. Is that --

Ms. Behling: That's correct. PERs would be under a 

specific workgroup if that workgroup is still active.

Member Ziemer: Yeah, yeah. Because it didn't seem 

to me -- Well, let's see. General Steel, they're still 

an active work -- Well, I guess it's not active. We've 

closed out General Steel, so is that why it would 

have come to this -- to our Subcommittee? 

Ms. Behling: I believe so. In fact, later when I --

(Simultaneous speaking.)

Member Ziemer: So for example, Savannah River --

if there was Savannah River PER case, we wouldn't 

be reviewing it. Right? 

Ms. Behling: No. No, we wouldn't.

Member Ziemer: Okay. 

Ms. Behling: No, that would be under --

Chair Beach: Wait, wait. We would still review in 

Subtask 4 in our Subcommittee. We would still go 

through that. And if there was any findings, it would 

be transferred over. Is that correct, to an active 

workgroup? 

Member Ziemer: On the PER itself versus the 

individual cases. 

Chair Beach: Right. 

Member Ziemer: Yeah, I was trying to remember 
45

why we were looking at individual cases here as 

opposed to the PER itself. And I think it's because 

there's not a workgroup to look at it. Is that the 

case? 

Chair Beach: I think it's part of our charter to go 

through once we conclude that there's no findings 

or all the findings have been cleared and the 

observations that Subtask 4, we conduct an audit 

basically. And I think that's part of our charter, not 

the workgroups. Isn't that correct? And then the 

next one would be Subtask 5 where we would 

prepare a report with our conclusions, which that's 

like the question I had next. 

Member Ziemer: Okay. Well, I guess I'm -- I don't 

recall us doing this many PER individual cases in 

this Subcommittee. That's what I was trying to --

Chair Beach: Yeah, I think it just closes out our 

(audio interference) of the review. Correct, Kathy? 

Ms. Behling: That's correct, yes.

Chair Beach: So and then on that train of thought, 

I've never seen us go farther with a Subtask 5. 

Have we done any of those in the past? 

Ms. Behling: Actually Wanda and I used to talk 

about this a lot and we wanted to -- in that 

protocol, we actually are saying that are Subtask 5 

is writing up the results of our Subtask 4 reviews --

our case reviews. So this is actually consider, I 

guess technically, our Subtask 5 is to write up what 

we find from the review of the recommendations 

under Subtask 4.

Chair Beach: Yeah, because I was thinking about 

that prior to this meeting. 

Ms. Behling: Yeah. 

Chair Beach: I was thinking the exact same thing, 

that it kind of --
46

(Simultaneous speaking.)

Ms. Behling: Yeah. Wanda and I had talked about 

eliminating that Subtask 5 and then we just 

modified the wording a little bit to say that SC&A 

will follow through and present to the Subcommittee 

our findings from the review of these re-work cases.

Chair Beach: Okay, which is what we're doing now 

also. 

Ms. Behling: Correct. 

Chair Beach: Okay. Okay Paul, anything else? Are 

you okay, clear? 

Member Ziemer: No, I just wanted to be sure. So 

you're basically saying that all of the individual reworks that are selected for review by SC&A, we 

would be reviewing and not the workgroups 

themselves.

Ms. Behling: Correct. 

Member Ziemer: Okay. 

Chair Beach: Well and just like we have just finished 

Clarksville/Medina, there's still one finding, one 

observation. Once those are clear, then we would 

task SC&A to do Subtask 4, which if you remember 

back on those slides, they would find one case or a 

couple of cases to meet those requirements. 

Member Ziemer: Right. But there's no workgroup 

for that.

Chair Beach: No. 

Member Ziemer: There's no workgroup for that.

Chair Beach: Well even if there was, I believe we 

would still follow through with that in our 

Subcommittee. And if there was any issues with 

Subtask 4, then -- I don't know if we've ever had 

this to pass it onto a workgroup, have we, Kathy in 

the past? 
47

Ms. Behling: I'm not sure. 

Member Ziemer: Well, there's been PERs on a lot of 

different sites. I just don't recall this Subcommittee 

reviewing all those. I thought if there were 

workgroups, they -- not the PER itself, but the 

individual (audio interference) that were selected. 

But you're saying we do all the individual cases. I 

just don't remember us doing them all.

Chair Beach: Yeah. Yeah, we do. 

Member Ziemer: Okay.

Chair Beach: We just don't get to that point very 

often. 

Member Ziemer: Maybe that's the issue. Okay.

Chair Beach: Okay. So Anaconda, if there's no other 

questions or comments, we can consider that 

closed. Correct? 

Member Valerio: Josie, this is -- Josie, it's Loretta. I 

have a question.

Chair Beach: Okay. 

Member Valerio: And I have to restart my computer 

during part of this presentation, so I apologize for 

that. But on Slide 3, it shows an employment during 

the period from 1956 to 1958. And then if you go to 

Slide 8, the second bullet states that, you know, 

this assumed -- the employee was exposed to one 

foot from the rectangular uranium (audio 

interference) for three days in 1956 and 30 days in 

1959. So can someone explain the difference in the 

years to me? 

Ms. Behling: Okay, let me -- I have to go back and 

look at that. Maybe that was a typo on Slide 3. 

Perhaps that was supposed to say 1956 to 1959, 

yes. Let me look at that when we take a break and 

can I get back to you on that? I apologize. 
48

Member Valerio: Yes. Yes. 

Chair Beach: And if you look in the original 

document, Kathy -- Let me see what page I'm on. It 

says 59 also. 

Ms. Behling: Okay, all right. 

(Simultaneous speaking.)

Chair Beach: It maybe should have been 56 to 59.

Ms. Behling: Yes, correct. That was a just a typo 

then, yes.

Member Valerio: Okay. 

Chair Beach: But then let me go back to the 

beginning because I think in the beginning under 

the -- on Page 6 -- Let me go real -- On Page 6, it 

also says 56 to 58. So yeah, good catch on that, 

Loretta. 

(Simultaneous speaking.)

Member Valerio: -- I thought it said 1959 as well. 

Chair Beach: Yeah, it does. So Page 6 says 58 and 

then Page 9. So we'll have to figure out what the 

years actually were if it -- I'll look into that. 

Member Valerio: Okay. 

Chair Beach: Good question. Thanks, Loretta. Okay, 

are we ready for a break or do we want to move on 

to 0063, Subtask 4?

Member Valerio: I'd say we move on. 

Member Ziemer: I'm okay to continue. Mmm hmm. 

Chair Beach: Okay. Well then, let's move on. And 

Kathy, we'll leave that note for you to maybe report 

back this time or next. 

Ms. Behling: Okay, very good. I'll try to look into 

that when we have a break.
49

Chair Beach: Okay. 

Ms. Behling: Okay, let's move on then to -- This 

again is a Subtask 4 case review. And the site is the 

Aluminum Company of America, Alcoa in 

Pennsylvania. This PER was initially issued in June of 

2015 due to revisions of Appendix R to TBD-6000, 

which is the Alcoa Pennsylvania TBD. The revisions 

increased inhalation ingestion in external doses 

during the operational period. And if eliminated job 

categories and now evaluated everyone as if they 

were an operator. And SC&A issued a review of 

PER-063 on July 17th, 2017 and there were no 

findings. 

Okay and again in accordance with our Subtask 4 

protocols, SC&A reviewed a case or two based on 

certain criteria and in this particular -- for PER-063, 

there was one case that met all of the criteria that 

we requested. And that was -- and those criteria 

included PoC between 45 and 50 percent, the 

assignment of external dose during both the 

operational and residual periods, and internal dose 

between the operational and residual period. We 

issued our Subtask 4 report on September 2nd, 

2021. And once again, I would encourage you to 

refer to that for document details as we go through 

this presentation. 

Okay, as always NIOSH re-worked the cases using 

the applicable tools and most current documents. 

They recalculated all the annual doses and because 

this was a best estimate case, IREP was run 30 

times at 10,000 iterations per run. The revised 

report was not sent to DOE because the 

compensation decision did not change. And SC&As 

review is typically limited -- obviously limited to the 

pathways addressed. And in this particular case, 

since internal and external increased, SC&A 

compared the original and re-worked case for all 

exposure pathways. 

Okay, a background on this case. The EE again 

worked for more than three decades and worked 
50

throughout the site. EE was not monitored and was 

diagnosed with a qualifying cancer several years 

after termination of employment. Again, here's our 

table that shows percent changes between the reworked and the original doses. And if you go to 

Page 7 of our report, Table 2-1 actually lists the 

original and re-worked doses. And as you can see, 

there was a significant increase in the external 

dose. And it was just due to changes in the TBD. 

Okay, the original external dose, NIOSH used the 

whole-body dose rates from Table R-3 of Appendix 

R Rev 00 for both operational and residual periods. 

That's back when the job categories were used. In 

this case, it was Plant Floor High, which is the 

highest dose assigned to the Plant Floor High. The 

bladder was assumed as a surrogate organ for the

photon dose. And so a DCF of 1.244 was applied 

and this resulted in the assignment of 

approximately 0.5 rem, 500 millirem. 

For the re-worked external dose, whole-body dose 

rates were taken from Table R-2 of Rev 1 of 

Appendix R. For the operational and residual 

periods, the same surrogate organ was used. And 

this resulted in the assignment of external dose of 

approximately 9 rem. And this is a significant 

increase in the external dose. And it resulted from 

changes in the TBD that increased dose rates for 

the operational years. 

Okay, for occupational medical doses, the original 

DR assumed pre-employment annual termination xrays for the operational year. A urine bladder was 

assumed for the surrogate organ and dose data was 

taken from Table 6-5 of OTIB-006 Rev 3. And this 

resulted in the assignment of -- this should be less 

than 100 millirem for the occupational medical dose.

For the re-worked medical dose, it was assumed --

an annual x-ray was assumed for each year of 

employment. The uranium bladder was assumed for 

the surrogate organ. Dose data was taken from 

Table A-7 of a revised OTIB-006. And the 
51

occupational medical dose remained the same using 

these data and assumptions. 

Okay, internal dose. The original DR, the internal 

dose was derived using uranium intakes from 

inhalation and ingestion calculated based on Tables 

R-1 and R-2 of Appendix R. And that should be Rev 

00 for the original. The job category again was Plant 

Floor High and NIOSH compared types M and S 

solubility. And it was determined type M was the 

most claimant favorable or more claimant favorable. 

And this resulted in the assignment of 

approximately 300 millirem for internal dose. 

In the re-worked case, the uranium dose was 

assigned based on Table R-1 of Appendix R, Rev 1. 

Dose was calculated for each operational and 

residual year. And again, types M and S solubility 

were compared. And it was determined type M was 

more claimant favorable. This resulted in the 

assignment of dose that was nearly identical to the 

original calculated dose. 

So SC&As conclusion on the re-worked case, the 

appropriate dose assignments based on Appendix R 

of Rev 1 were used except -- and here again, I 

apologize. This should be for 1960. NIOSH slightly 

overestimated the dose. What happened, they 

assigned the 1959 dose of 15 millirems to 1960 

where actually the 1960 dose should have been 12 

millirems. So a minor -- you know, a slight 

overestimate. Appropriate surrogate organs were 

used base on OTIB-0005 and all doses were entered 

into IREP appropriately.

For occupational medical dose, again appropriate 

doses were assigned based on OTIB-0006. 

Surrogate organs were correctly based on OTIB0005 and all doses were entered into IREP correctly. 

The conclusion for the internal dose, appropriate 

intake values were used as specified in Appendix R, 

Rev 1. And again, except for one year -- and in this 

case NIOSH slightly underestimated the dose. They 
52

used the inhalation intake of 0.25 picocuries per day 

for both inhalation and ingestion. They should have 

actually -- the ingestion intake should have been 

2.71 picocuries per day. So that resulted in a slight 

-- slightly lower dose. The input data was entered 

into IMBA correctly and the assumptions were 

claimant favorable. And SC&A had no findings with 

our review of this particular re-work under PER-063. 

Any questions? 

Chair Beach: So that last slightly lower dose, would 

that be considered a -- it's not a finding. I realize 

that -- an observation? But we're not tracking these 

as findings or observations, it looks like.

Ms. Behling: Well, we do. I guess we did not identify 

this as such. The external, there was one year 

where the dose was overestimated for one year. It 

is an incorrect value that was used, but we did not 

identify it as an observation or a finding. But we do, 

do that in these -- in these reviewed case. And if 

you feel that, that should be addressed or should be 

identified as an observation or finding, we can 

certainly do that. 

Chair Beach: I guess I'm more curious as to why 

you didn't address it as a -- Was it just because it 

was such a slight incorrect? I mean it was an 

incorrect calculation used. 

Ms. Behling: I guess. And I guess the response from 

NIOSH would have been yes, we did -- it was 

inappropriate. But everything sort of evened out --

(Simultaneous speaking.)

Chair Beach: Right, I understand that. 

Ms. Behling: Not that, that -- Not that, that should 

alleviate or preclude us from making it an 

observation or a finding. And like I said, perhaps we 

can still do that if you would like to modify this.

Chair Beach: Was it just an oversight? Do you know 

why that was missed? And I think --
53

(Simultaneous speaking.)

Ms. Behling: Yeah. I think it was simply an 

oversight. They're looking at a table. And for the 

external dose, they assigned -- rather than 

assigning the dose that was listed in that table for 

1960, they just inadvertently took the dose from 

1959. Same type of thing for the inhalation 

ingestion. They're in two columns next to one 

another. And they just took the inhalation and put 

that in for both inhalation and ingestion, rather than 

pulling it from the other column. 

Chair Beach: Easy to do. Any comments, Loretta or 

Paul? 

Member Valerio: I don't have any, Josie. 

Member Ziemer: No. It appears that it's not an error 

in the methodology per se. It's an error in just 

looking at the wrong column. If those columns had 

been substantially different, it probably could 

change the outcome of the case. 

Ms. Behling: Correct. 

Member Ziemer: I think it's well to note that they 

selected the wrong column. Was this originally --

this case was between 45 and 55 or something like 

that? 

Ms. Behling: 45 and 50.

Member Ziemer: Was it 45 and 50? In any event, 

was this originally compensated or uncompensated 

case? 

Ms. Behling: It was an uncompensated -- it was an 

uncompensated case. 

Member Ziemer: Yeah. And had they been in the 

correct columns on this choice --

Ms. Behling: It would not have made a difference. 

(Simultaneous speaking.)
54

Ms. Behling: No.

Member Ziemer: Yeah. 

Ms. Behling: No, we looked at that. Yeah because 

this was -- This case -- the PoC was very, very close 

to 50.

Member Ziemer: Okay. And if they had been in the 

correct column, it wouldn't have changed that. I 

guess my question is it's not an issue of them using 

the wrong procedures or not going through the 

process correctly. It's somebody selecting the wrong 

column in the right procedure. 

Ms. Behling: Correct. That's correct. 

Member Ziemer: And had it been substantial

numerical differences that could have changed the 

outcome, then you'd certainly have to go back and -

-

Ms. Behling: Yeah. Oh, we certainly would have 

made that a finding. Yes, we would have certainly 

made that a finding.

Member Ziemer: So Josie, what I think what you're 

getting at is, is it not a finding simply because it 

didn't change things? Or should it be a finding 

anyway just so that it's noted --

(Simultaneous speaking.)

Member Ziemer: Or should it be an observation? 

Chair Beach: Yeah, I guess that's -- I don't think I'd 

write it to the level of a finding, maybe an 

observation. But yeah, I can see how that would 

happen with the two different columns. 

Member Ziemer: And even if it's an observation, it's 

not something that has to be --

Chair Beach: Yeah.

Member Ziemer: In other words, they could say 
55

yeah, we'll correct that in our records, but it doesn't 

change the outcome. 

Chair Beach: No. And there was two on this. One 

was over, one was under. Yeah, I think it's noted. 

So I don't know if you need to officially write it 

down. I guess I could ask NIOSH what's your 

thoughts on it? 

Dr. Taulbee: This is Tim. In looking at the 

underestimate and the overestimate that SC&A was 

reporting there on Page 9 of their document, I 

mean, there's are very small resulting doses or 

changes. And SC&A indicated that, you know, this 

doesn't change anything with the PoC. I believe 

their words here are resulting in a slight 

overestimated of 4E to the minus-six rem. So I 

mean this is microrem type of range. 

Chair Beach: Yeah, understood. 

Member Ziemer: Yeah. 

Chair Beach: And it's human error, so I'm fine with 

just leaving it as written. I mean we've --

Member Ziemer: Yeah. 

Chair Beach: -- it doesn't change anything either 

way. 

Member Ziemer: I think that's the way to go, yeah. 

Chair Beach: Yeah. Okay, I'm fine with that. 

Loretta, you okay? 

Member Valerio: Yeah, I'm okay. I'm fine. 

Chair Beach: Okay. So this one is also closed. And 

now I will ask again, are we ready for a 15-minute 

comfort break before we move on to the -- I think 

we have two more and then the newly issued 

documents. Unless you guys are okay to keep 

moving -- going forward. 

Member Ziemer: Well for me, it's your call, Josie. 
56

What kind of comfort break do you need? 

Chair Beach: Well, it's just not me. There's other 

people in offices. So SC&A, would you -- is this an 

appropriate time? Would you guys like a break and 

NIOSH? 

Ms. Behling: This is Kathy. I wouldn't mind having a 

break, if that's okay with you. It doesn't even have 

to be 15 minutes if you don't want it to be that long, 

but I could use just a few minute break. 

Chair Beach: Well, and I know you wanted to look 

at the --

Ms. Behling: Correct, yeah. 

Chair Beach: Let's go 15 minutes. Rashaun, are you 

okay with that? 

Dr. Roberts: Yes, that should be fine. So that would 

have us coming back at around 1:20 or so. 

Chair Beach: 1:20 or 1:25, yeah. I think.

Dr. Roberts: Let's do 1:25 we'll reconvene. 

Chair Beach: Okay, that sounds great. 

(Whereupon, the above-entitled matter went off the 

record at 1:07 p.m. and resumed at 1:25 p.m.)

Dr. Buchanan: Okay. So I guess we can get started. 

I will be presenting SC&A's evaluations of OTIB0088, which is concerned with external dose 

reconstruction. Kathy, do you want to do the next 

slide?

Chair Beach: Is Kathy back on? So, Ron, is Kathy, is 

she the one that's got the slides up for you?

Dr. Buchanan: Yes, she's been presenting the 

slides.

Chair Beach: Okay. I bet she got tied up looking for 

that year.
57

Dr. Buchanan: Right.

Ms. Behling: Okay, this is Kathy Behling. I just 

joined. I'm sorry if I'm a little late here.

Chair Beach: Okay, you're fine. We figured you 

were looking at Europe.

Ms. Behling: I started looking at all kinds of things 

here and different thoughts came to mind that I 

may want to discuss.

Chair Beach: Okay. So Ron's ready for you to move 

the slide presentation forward one slide.

Ms. Behling: Okay, can I make a comment and ask 

a question before we move on on things that were 

just previously discussed? Is that okay with you, 

Josie?

Chair Beach: Yes.

Ms. Behling: All right. Yes, in answer to Loretta's 

question, first of all, for Anaconda, the operational 

years are '56-'59.

And so our selection criteria would have wanted 

someone who worked within that employment 

period, would be '56-'59, not '58. 

So '59 is the correct year. Okay. So there would be 

--

Member Valerio: Thank you.

Ms. Behling: Okay. All right. And I don't want to 

digress too much here. So Paul asked a question 

that did get me to start thinking about where are 

the PERs typically reviewed?

And I went back through the Savannah River Site 

and I know that the Savannah River Work Group is 

very active and they look at all of the OTIBs and the 

reports that are out that are very specific to 

Savannah River.
58

But as I was going down through that list, I didn't 

see, and maybe there hasn't been recent PERs for 

them to have looked at, but I just want to be sure 

that these Work Groups are getting notified of these 

PERs and they are being done in those Work 

Groups, and if not I think that maybe that maybe 

this group Subcommittee should handle all the 

PERs.

I'm a little confused by that to be honest. I know 

Ted used to always say that they belonged to the 

Work Group, but I wonder if that's really happening, 

because I'm not involved with a lot of the Work 

Group work.

Member Ziemer: Kathy, this is Paul. I went back, 

also looked in earlier files of this Subcommittee and 

I find that we have actually looked at a lot of PERs 

from different places, including General Steel when 

the Work Group was still active.

We looked at the individual PER cases in this 

Subcommittee. So I just hadn't remembered it, but 

looking back, I looked back at quite a few previous 

meetings and I found that we had looked at a lot of 

PERs in the past. 

But it's been a couple years since we did it and I 

had forgotten, but we have done quite a few in the 

past.

Ms. Behling: Right.

Member Ziemer: So I'm guessing -- I'm guessing 

they all do come to us.

Ms. Behling: Okay, and perhaps this is a question 

for Rashaun. Should, because when, I'm usually the 

person that sits down and suggests to the 

Subcommittee what we should, what hasn't been 

reviewed and what could, what they should consider 

or what they want to consider for us to review.

Should all of the PERs, would you recommend that 

we look at those through the Subcommittee, 
59

through the procedures Subcommittee, or should I 

research it a little bit and see if there's an active 

Work Group that is handling that? I'm still --

Chair Beach: Well, Kathy, this is Josie. So the 

reason we're looking at the PERs is to make sure 

that the PERs are working and functioning the way 

they're supposed to be.

So it's not so much the individual cases, but just 

going back, and that's what the procedures group 

does is make sure those procedures work.

Ms. Behling: Okay.

Chair Beach: So that's what we're doing, is making 

sure that we didn't miss anything. Is that correct?

I mean, that's what I've always thought a path 

forward was, kind of a close out review.

Ms. Behling: Right, but I'm talking also about all 

PERs, no matter what sites they're affiliated with, 

should they be reviewed under this Subcommittee?

Member Ziemer: I think you can pick them all up. 

This is Paul. I think you can pick them all up.

If you look at the -- at the agendas for all of the 

past Subcommittee meetings, you'll see what PERs 

we have reviewed, and it's quite a few.

Ms. Behling: Yes. I don't think --

Mr. Allen: Can I say something? This is Dave Allen.

Ms. Behling: Yes.

Mr. Allen: From my memory in the past years, yes, 

this committee has reviewed I think 100 percent of 

the PERs and did the past four with those, too.

Whenever there is an actual technical issue with the 

CBD then normally we would make the 

recommendation that we transfer the finding to an 

active Work Group, and that's normally what is 
60

done.

Ms. Behling: Okay.

Mr. Allen: Assuming there's an active Work Group.

Ms. Behling: Okay. Okay, very good. I just didn't 

want to miss anything or not alert the 

Subcommittee of a new PER that is out there, 

thinking that it's going to be handled under some 

Work Group.

So, okay, that was more of a clarification for me, so 

I'm sorry to digress like that, but, okay, thank you.

Chair Beach: No, and no problem with that, Kathy, 

at all. It's good to make sure we'll on the right 

page.

Ms. Behling: Okay. All right. So I will let Ron take 

over.

Chair Beach: Okay, thanks, then.

Dr. Buchanan: Okay. I'll start again. I'll present the 

SC&A's evaluation OTIB-0088, external dose 

reconstruction. And we can have the next slide, 

Kathy.

Okay, OTIB-0088 revision one was just issued in 

2019. Revision zero had been issued in 2018, so it's 

a fairly recent document.

The Advisory Board passed SC&A to review revision 

one in March 2021. We did that review and issued a 

report in September 2021.

Now, revision two was issued after we were tasked 

with this, and that was in June 2021, and SC&A has 

not yet been tasked to review revision two. Next 

slide.

Okay, the purpose of OTIB-0088 is to provide 

external dose reconstruction guidance using IG-001 

and approved technical information bulletins and 

Site Profiles and the Oak Ridge procedures that 
61

have been developed and approved.

Now, this is for exposure for the photons, neutrons, 

electrons, ambient dose, and x-rays.

Now, the general approach to have an outline of 

OTIB-0088 was that they cover some information, 

an external dose symmetry records, occupational 

medical x-ray doses, incident reports, types of 

external radiation exposures, conversion of external 

dose, organ dose, and uncertainties.

Now, the OTIB contains three attachments. A is 

assigning missed dose, B is onsite ambient dose, 

and C is the DOE adoption of the ICRP Publication 

60 neutron weighting factors by each of the major 

sites.

Now, we reviewed the approach using OTIB-0088 

and we found that it was reasonable and useful and 

had no findings or observations in determining how 

the subject would approach in OTIB-0088.

Now, we reviewed the methods used in OTIB-0088, 

and we concur with NIOSH's methods, equations, 

and recommendations in the OTIB.

However, we did have several observations in that 

SC&A previously reviewed OTIB-0088 in 2019 for 

revision zero that was issued in 2018.

It had an observation screening for lack of 

information in OTIB-0088 for region zero zero. If it 

was used to facilitate cancellation of Procedure 60.

And in OTIB-0088, it states that it is being used to 

facilitate cancellation of Procedure 60, which is 

occupational onsite ambient dose reconstruction for 

DOE sites released in 2006.

Now, Observation 1 was to request a path forward 

for this issue. And it was discussed during the 

Subcommittee procedure review meeting in 

February of 2019, and the Subcommittee closed 

SC&A's Observation 1, with the understanding that 
62

NIOSH would consider SC&A's recommendations 

further and issue an email with a path forward.

And SC&A is not aware that NIOSH has issued an 

email concerning our concern over the cancelation 

of Procedure 60. 

And let me give you a little more information on 

that. Procedure 60 is the summary of ambient dose 

for all the major DOE sites.

And on page 14, it gives a good summary table of 

what sites and when to include ambient dose in the 

dose assignment and when not to.

OTIB-0088 is to replace Procedure 60 or help it 

phase out, but this information should be included 

or something similar to it.

So we are not aware of how this issue, NIOSH 

should address this issue as of today.

Okay, we evaluated documentation in OTIB-0088 

and found that the previous calculational error in 

Attachment C had been corrected in revision one, so 

we set aside that, and however did note several 

areas that would benefit from further clarification or 

explanation, which is listed as four observations, as 

discussed in the following slides.

Observation two is clarification of covered x-ray 

exams. The first paragraph on page 8 states that 

only doses that were received before diagnosis of 

the primary cancer included in the dose 

reconstruction, and if a worker received medical xray exams for occupational, medical, or health 

screening as a condition of employment at a 

covered site, reconstruction includes these doses, 

which we're all fairly well aware of.

Now, we're fairly well aware of the following fact, 

but it would be helpful, especially maybe to new 

dose reconstructors or the public, if you were to 

include the statement that clarified the fact that the 

x-rays that were performed for diagnostic or 
63

therapeutic reasons are excluded.

In other words, anything along those lines would 

not be included in the dose reconstruction.

Observation three concerns unmonitored worker's 

potential dose. On Page 10 of the OTIB, it states in 

general, it is expected that reconstruction dose to 

unmonitored workers, those that didn't have any 

records, would be less than doses to monitored 

workers.

This statement didn't appear to be substantiated, 

because it does not consider the fact that some 

unmonitored workers also include workers whose 

records who have been lost, destroyed, or are 

ineligible.

Now, in other words, just because there is no record 

of it doesn't necessarily mean that they weren't 

monitored.

And in addition, some Classes of workers had the 

radiation exposure controlled by their employer, 

such as subcontractors who don't necessarily follow 

the same procedures as the prime contractor in 

monitoring and record keeping.

On to the next one, Kathy.

Chair Beach: She's there.

Dr. Buchanan: Yes, okay. Okay, now, the 

Observation 4 is use of monitor badge records.

Okay, page 13 of OTIB states however for cases 

when the monitor badges were issued for particular 

monitoring period, only one zero measurement 

should be assigned per monitoring period.

In general, that applies to most facilities, that the 

worker worked in the same facility and they were 

issued several badges or something during the 

same period.
64

However, there are instances where workers may 

have worked at several facilities at the same site, 

and each facility issued their own badge for that 

period, and so they would issue different badges, 

and so that should be accumulated.

And such a place as Idaho National Lab did this at 

their different facilities on the same site.

In that case, all the badges' results should be 

analyzed and appropriate zero measurements 

assigned, because they were individual time periods 

at different facilities. 

Okay, and Observation 5 is clarification of NCRP to 

the ICRP correction factor. 

I'll give a little background on this. These sites use 

the NCRP neutron weighting factors originally back 

to about the year 2010.

At that time, the ICRP correct weighting factors 

were incorporated into many of the DOE sites.

And so when you do dose reconstruction, if you 

have neutron badges period recorded prior to 2010, 

you apply the ICRP to NCRP correction factor, which 

is usually around 1.9 and that is correct up until the 

site started applying the ICRP correction factor 

themselves, which started in about 2010.

Now, Appendix C of OTIB-0088 lists the major DOE 

sites and when they switched to the ICRP 60 

neutron weight factor.

And that's very useful. However, it would be useful 

also if there was a note in that saying that the dose 

reconstructor is not verified, that the correction 

factor of NCRP to ICRP, once the ICRP correction 

factor has been adopted by the DOE sites.

Checked a few of the Site Profiles, and some of 

them instruct the dose reconstructor on that issue, 

and but not always the Site Profiles instruct the 

dose reconstructor did not apply the correction 
65

factor after implementation date.

And so that would be helpful in ensuring consistency 

in dose reconstruction, in correct dose 

reconstruction.

So in summary, we had no findings. We had five 

observations that have to be addressed. And we're 

up for questions.

Chair Beach: Okay, and I think this is one also that 

NIOSH said they wouldn't be ready to comment on, 

but I do have a question.

Would it be appropriate to task SC&A to do a 

focused review on Rev. 2 that came out in June and 

verify that these observations are still an issue 

before we move on to getting answers from NIOSH? 

What do you think, Paul and Loretta?

Member Ziemer: Well, I would ask if this may be, 

Kathy, is this already on your list also? I mean, it 

would be appropriate.

Ms. Behling: No, Paul, it's not, because, again, I 

thought that these observations should be resolved 

before we got issued, but I agree with Josie that 

maybe it's appropriate to do a focus review. I'm not 

sure, but I do not have that on my list.

Member Ziemer: Oh, okay. Thank you.

Dr. Taulbee: This is Tim, if I may interject here. In 

going through the individual observations, the only 

one that's really been kind of incorporated in 

revision two is the Observation 5, but possibly not 

fully to the extent that Ron just mentioned about 

the exclusion, because that's really more in the Site 

Profiles type of scenario.

But I would like to go through some of these if I 

can.

Chair Beach: Of course.
66

Dr. Taulbee: Okay. With regards to Observation 1, if 

you could go back to that, thank you, we have not 

issued an email. Actually, that dropped off my radar 

in order to do so.

But we are cancelling. We have considered SC&A's 

recommendation, and our response is that PROC-60 

we will be cancelling. We are moving all of the 

information that is site-specific from PROC-60 into 

the individual Site Profiles.

And the generic type of information and the overall 

guidance is what we're moving into OTIB-0088. And 

we're doing this because we're consolidating 

documents here.

I understand and recognize SC&A's desire and their 

goal, or the efficiency of looking in one place to 

know which sites to assign on-site ambient dose 

and which ones don't.

But when we do dose reconstruction, the dose 

reconstructors are going to that Site Profile and 

that's what they're focusing on with that one.

They're not really looking at another guidance 

document from that standpoint. We're trying to 

consolidate it all into the Site Profiles because that's 

what the dose reconstructors are using as the 

primary source.

So this is why we're doing this. It's actually 

improving our consistency internally, and so it's 

much more efficient to do so.

Now, if you want me to write an email discussing 

this, I can certainly do so, but I'd really just like to 

go back to the original of closing this out. This is our 

reasoning for why we do it.

We did consider what SC&A was saying, that this is 

a handy user cable type of thing, but really, the 

information that dose reconstructors use is in the 

individual Site Profile.
67

Chair Beach: And do you know when that's going to 

be complete and you'll close out that document?

Dr. Taulbee: It's actually taking us much longer 

than what we thought, let me put it that way, 

because there are some sites that when we went to 

update their particular Site Profile for the onsite 

ambient doses, we realized that the cutoff dates 

were earlier, back into the 1990s type of timeframe, 

or late '80s, and there's a lot of new data over the 

past 20 plus years out in environmental reports.

And so updating those is what we've been currently 

doing. That's what's causing the delay in cancelling 

PROC-60 right now, is updating the few of the sites, 

the onsite ambient dose information.

So I don't really have a great date for you on when 

that's going to be accomplished.

Chair Beach: So is there a -- is there a Rev. 3 on 

the horizon for this also?

Dr. Taulbee: Well --

Chair Beach: Are those changes being incorporated?

Dr. Taulbee: Well, we've incorporated all of the 

generic type of information that we're going to 

move into OTIB-0088 already.

So actually, the problem with cancelling PROC-60 is 

the updating of the individual Site Profiles.

We won't cancel it and can't cancel it until we get all 

of those Site Profiles updated with the information 

that's currently in PROC-60.

Chair Beach: Okay. That makes sense. I was just 

curious if we needed to think about Rev. 3 or not. 

So, okay. So no date. 

And I'm okay with this being an answer to the email 

in Observation 1. Other Subcommittee Members?

Member Ziemer: This is Paul. You're saying you're 
68

comfortable not having an official email distributed 

and have this information that we have today would 

suffice for now?

Chair Beach: Yes, and --

Member Ziemer: That's what you're saying?

Chair Beach: Yes, that's what I'm saying that this, 

we can cancel. I think that was two meetings ago.

SC&A, I don't know what your thought is on that. 

Do you want something more formal, which that 

email would have been, or are you comfortable with 

Tim's explanation?

Dr. Buchanan: This is Ron Buchanan. And I'm okay 

with it. Kathy's head of the procedure part, so I'll let 

her make a final decision.

Ms. Behling: Yes, I'm okay with that also. And we 

will note this into the BRS when we have access for 

that.

Chair Beach: Right. Okay. All right, so that officially, 

then, if everybody's in agreement, closes 

Observation 1 with Kathy updating the BRS with 

what Tim told us today.

Member Ziemer: Yes.

Chair Beach: And that will be emailed. Okay. 

Loretta, you okay with that?

Member Valerio: I'm fine with that, Josie.

Chair Beach: Okay. Tim, did you have some other 

things you wanted to cover?

Dr. Taulbee: Yes. Observation two, and this is one 

where we can modify the language in the sections 

but frankly I really don't think it's necessary.

I understand clarifying that we don't include the xrays from diagnostic or therapeutic reasons, but 

that's been the case since the beginning of this 
69

whole program.

So specifically putting it in here, yes, we can do 

that, but I just don't see the real need for that -- for 

that exclusion. That's been the case for all of the 

sites for, well, since the beginning.

So I guess I, if the worker or the Subcommittee 

here feels that we should definitely include it in 

there, we can do that in a Rev. 3. What are your 

thoughts on that?

Member Ziemer: This is Paul. I agree with that. I 

never thought it was an issue that was in dose 

reconstructors. I thought it was, it's always been 

pretty clear, but medical, diagnostic and therapeutic 

exams are not to be included. And, in fact, we go so 

far as to say that, and diagnostic and therapeutic 

exams would almost never occur on site, would 

they?

And we already don't include reaching required 

occupational screening that's done outside.

Mr. Siebert: And this is Scott Siebert from the ORAU 

team. I just want to back up, Tim, yes, it's been 

done that way, and it is also documented in OTIB0006, dose reconstruction from occupational, 

medical x-ray procedures. That is specified and 

called out specifically in OTIB-0006 as well.

Chair Beach: Okay. And I guess I was going to ask 

that question, too, is I hadn't seen it where it called 

out therapeutic.

Ron, are you okay with that explanation?

Dr. Buchanan: Yes, I'm okay with it.

Chair Beach: You think that covers it, then?

Dr. Buchanan: As far as I'm concerned. Like, I say, 

Kathy has final say for SC&A.

Ms. Behling: Yes, that's fine. I agree.
70

Chair Beach: Okay. Then we can close one and now 

two. Loretta, any comments?

Member Valerio: No, I agree with that. I'm good 

with that.

Chair Beach: Okay. Thank you. Tim, any others?

Dr. Taulbee: Yes. Observation three, and this one, it 

kind of falls into the same, a similar scenario as the 

previous one. But on Page 10, it's stated here on 

the slide, it says, in general, it is expected that dose 

reconstruction. And either we're talking in 

generalities here. We're not being specific to 

basically what in general means.

We recognize that there are going to be exceptions 

and oddities to the rule or to the -- to the general 

statement here. And we kind of feel like SC&A's 

gone on and specifically talked about, there are 

some unmonitored workers that have lost or 

destroyed records or they're ineligible. We recognize 

that. But all we're doing is talking about in general 

here.

Now, we can go through and add additional 

language and go through basically what Ron's got 

here on the slide for Rev. 3 if that's what the worker 

wants. We can certainly do so.

But the statement here that is being brought up is 

we're just talking in generalities, and in generalities, 

people who are unmonitored are generally, their 

exposure is less, they have less dose than the 

monitored workers. 

I guess the question to the Subcommittee is do you 

want us to incorporate more information here with 

regards to this in a -- in a Rev. 3 of this OTIB?

Member Ziemer: Well, talk about the practicality. A 

general statement doesn't give any guidance on 

what they're supposed to do in making a decision as 

to the dose reconstruction.
71

I didn't go back and look at Page 10, but whether 

it's saying, sort of following that?

Dr. Taulbee: Give me just a second to pull that up.

Chair Beach: Yes, when you pull it, and my question 

was going to be, does it change anything if you 

reword that.

Is it going to add to that or is it going to change the 

way the dose reconstructor looks at it?

Dr. Taulbee: I don't think it's going to change 

anything at all. Okay, let's see. Oh, shoot, I've got 

the wrong version up. We're on Page 2. I'm sorry.

Chair Beach: Okay.

Dr. Taulbee: I'm going to have to get back to you I 

guess on that point as to what the rest of the 

paragraphs are saying, that point. But we have two 

we have modified.

Chair Beach: Okay. We'll leave that one open for 

now. And did you have, did you want to go on with 

four or --

Dr. Taulbee: Well, four is one that I just want to 

mention that we would -- go ahead, Paul, sorry.

Member Ziemer: No, I was going to say, I don't 

want to leave it open in the sense that we are 

expecting the wording to be changed.

I do want to, I'm, this issue is hanging by itself and 

it doesn't have any particular application unless we 

know the context of it, because in general, we know 

that what is done, what records are missing, versus 

cases where the person is not monitored because 

they're working in office or waiting for operational 

stuff.

So I don't think the dose reconstructors depend on 

this statement for determining how to proceed.

Chair Beach: No, I agree with that. But I was going 
72

to ask Ron if he had any comments on that?

Dr. Buchanan: Well, mainly, this was noted because 

there are several paragraphs in that section 2.1.1.2, 

says workers were not monitored and it gives about 

five paragraphs there. And this is the end of the 

third paragraph. I just felt that, it's kind of blames 

the idea of I didn't really see that it was necessary.

The statement itself could be left out and the 

second would be practical for the dose 

reconstructor. I just felt that it kind of maybe make 

a dose reconstructor think, well, he wasn't 

monitored, he probably wasn't exposed much, and 

that isn't necessarily the case. 

And the rest of the paragraphs kind of bore that 

out. And so I thought the statement itself really 

didn't lend anything and it might bias the dose 

reconstructor. That was my point.

Chair Beach: That was on Page 10, right?

Dr. Buchanan: Page 10, the first paragraph, last 

sentence.

Member Ziemer: First or third? 

Chair Beach: The first, often --

Member Ziemer: Is it the first or the third 

paragraph?

Dr. Buchanan: It's the first paragraph on Page 10. 

It's the last sentence.

Chair Beach: So, in general, yes.

Member Ziemer: So, Ron, you're saying just leave it 

out if you want, right? It doesn't add anything.

Dr. Buchanan: Right. That's what, and it could 

introduce a bias and that's the reason I pointed it 

out. It's no big deal.

It probably wouldn't change any of the dose 
73

reconstruction, other than it might make the dose 

reconstructor, well, it's probably less than 

monitored workers. And it might be true, but not in 

all cases, and so I just thought that this statement 

didn't need to be there.

Chair Beach: Yes, so if you left it with the workers 

with no significant exposure potential, external 

radiation dose reconstruction is based on ambient 

dose. See Attachment B, and then period, strike 

that.

Member Ziemer: Right. Right.

Chair Beach: I don't see a problem with that. Tim?

Member Ziemer: But even if it's there, is it going to 

change what it does?

Dr. Taulbee: Yes, I mean, we can do that. We can 

strike that sentence but then, I mean, we're revving 

the document due to that, so --

Chair Beach: Yes, I got you.

Member Ziemer: And it's probably not important 

enough to do a revision for. Like, if you --

Dr. Taulbee: Again, I don't -- I don't see that it 

would change how the dose reconstructor would 

actually go through the process.

You're saying it might bias them, but it still has to, 

it's not going to change its procedure is it?

Chair Beach: No.

Mr. Barton: Well, this is Bob, if I could just make a 

quick comment here. I think a lot of the intents 

beyond these observations, and I think we say that, 

is that, is that it's to improve the clarity of the 

document.

I agree that from pure practicality standpoint, we 

know how the dose reconstructions are performed.
74

I guess part of our thought was that just for fully 

documenting the program and maybe even from an 

outside viewpoint for members of the public who 

might be interested in this document, things like 

this may not accurately reflect what's actually done 

in dose reconstruction. And that's why there are 

observations and are findings. They were just 

suggestions for improvement. So --

Chair Beach: Good point.

Mr. Barton: Just take that comment for what it's 

worth.

Member Ziemer: Well, the other side is the fact that 

it is a fact, or it is an in general statement. It is a 

statement that says reconstructed doses to 

unmonitored workers will be less. It says in general. 

That's very different than saying that it's always the 

case, but, I mean --

Chair Beach: I could go either way here. Leave it or 

take it out.

Member Ziemer: I'm saying I don't want to revise a 

whole document to remove that one sentence.

Chair Beach: No, no, I agree with that. And 

typically, those get put on the side and when a 

document is reviewed, they may incorporate that, 

but that wouldn't be the reason to redo the 

document. So --

Member Ziemer: That's correct.

Member Valerio: Loretta, comments. Well, I don't 

think that it's imperative that it's changed right 

away, but if there's a revision, I think it needs to be 

clarified. I mean, it's --

Dr. Taulbee: This is not as --

Chair Beach: Go ahead and finish, Loretta.

Member Valerio: I just, I think that statement 
75

where it says the people who are not monitored, in 

general, and I agree, in general, but there are those 

situations where people were not monitored for 

whatever reason and still had exposures.

So it's, you know, I agree with you, Josie, it can go 

either way.

Chair Beach: Yes, and it could create a bias, which 

is what Bob pointed out. Tim, what were you going 

to say?

Dr. Taulbee: I was going to say that I can be in 

agreement with that. If we end up revving this 

document for another reason, then we'll strike that 

sentence.

Chair Beach: Okay.

Dr. Taulbee: It's not a problem from that 

standpoint.

Chair Beach: Okay.

Dr. Taulbee: If we don't have another reason to rev. 

that document, I'd prefer not to. Put it that way.

Chair Beach: Okay. So we can add that as, I think 

Lori tracks those, I believe, on your side. And then 

we would not, we would go ahead and close this 

with the understanding that if you rev. the 

document, you would just strike that statement. 

And I would be comfortable with that. Paul? 

Loretta?

Member Ziemer: I'm good with that, yes.

Chair Beach: Okay.

Member Valerio: I'm good with that, too, Josie. 

Chair Beach: Okay. And Kathy, would you just make 

a note of that? I guess that would be in our BRS of 

the explanation of why we closed these, right?

Ms. Behling: Yes. Yes.
76

Chair Beach: Okay. Tim, did you have something for 

four or was that your last?

Dr. Taulbee: This is my last one, Observation 4, but 

I actually don't have anything. In general, we're in 

agreement that all badges should be considered, 

although I need to do some follow up on this one, 

so we will be having to keep this one open and get 

back to you on.

We recognize there's unique scenarios at certain 

sites and what I'm looking at here now is we're 

going to follow up on this to ensure we're being 

consistent across all the sites in the complex, and 

we'll get back to the Subcommittee on this 

particular observation.

Chair Beach: Okay, thank you. And then five, the 

same? That's going to remain open?

Dr. Taulbee: Yes, and five is the one that we've 

actually updated in revision two, to where revision 

two of this OTIB is done.

We recognize what Ron talked about, is that not all 

the OTIBs have that language in there, but we are 

revising those OTIBs, and as we do, we add that 

language to it.

So it's a minor language adjustment. It's not really 

something that would go into OTIB-0088 here, but 

it's really more of the Site Profiles of after this 

particular date, you don't make that correction from 

NCRP to ICRP anymore.

Chair Beach: Okay. Thank you. Can we circle back 

to the focus review of Rev. 2? Subcommittee, are 

you in agreement to have Ron do a focus review of 

that new document?

Member Valerio: I am.

Member Ziemer: Yes, I am fine with doing that.

Chair Beach: Okay. So you can mark that as a 
77

tasked item, Kathy.

Ms. Behling: Okay.

Chair Beach: Okay, that brings us to --

Member Valerio: So, Josie?

Chair Beach: Yes? Go ahead, Loretta.

Member Valerio: Just to clarify, observations three, 

four, and five will remain open, correct?

Chair Beach: No, one, two, and three are closed. 

Three is noted as that will change if they rev. that 

document again.

Member Valerio: Okay. Okay.

Chair Beach: Four and five are still open. And then 

Ron will check the new rev. against those, also. And 

we'll carry that over --

Member Valerio: Okay, just wanted to make sure 

my notes were correct. All right, thank you.

Chair Beach: Mm-hmm, and I think we might have 

saved the toughest one for last. Well, not totally last 

today, but the last OTIB. So 45?

Ms. Behling: Oh, I'm sorry. Rose?

Ms. Gogliotti: That's okay. I will request control 

from you, Kathy.

Ms. Behling: Okay.

Chair Beach: Oh, Rose, we're going to hear from 

you finally.

Ms. Gogliotti: Yes.

Chair Beach: I knew you were waiting. Until I get 

them up, I'm not sure who's reporting on them, so 

mine's --

Ms. Behling: Okay, I'm going to give you control.
78

Ms. Gogliotti: Okay.

Dr. Roberts: Josie, did you say OTIB-0045?

Chair Beach: If I did, I meant 0049.

Ms. Gogliotti: 0049.

Chair Beach: Yes, it is 0049. Rev two.

Ms. Gogliotti: Getting it pulled up here.

Chair Beach: I think while Rose is getting that 

pulled up, Kathy and Rashaun and even Tim, not 

even Tim, but I think what I'm going to do, I was 

going to talk about some of the carryover items 

from the previous meetings that have kind of 

slipped through the cracks.

Instead of talking about it at the end of this 

meeting, I think this document and then the newly 

issued documents are probably going to take us to 

our end time.

I think I'll just go ahead and generate an email and 

send it out for things that we need to keep track of 

that we've said we would do and just so we can 

carry over with those moving forward. Would that 

be appropriate, Rashaun?

Dr. Roberts: Yes, if you could send that to me, that 

would be great.

Chair Beach: Yes, well, I'll send it to both Kathy and 

Tim, too, to add, make additions, and clarify 

anything that I might have missed. Because we've 

got stuff from the last two meetings, for sure, that 

we kind of haven't, we've dropped through this 

process. So --

Dr. Roberts: Okay.

Dr. Taulbee: Josie, if you could ensure that Lori is 

cc'd on that.

Chair Beach: Yes, I will also copy Lori on that. 
79

Absolutely. And I'll do that relatively quickly after 

today's meeting, just so we have something to 

move forward with.

Ms. Gogliotti: Okay, can everyone see my slide on 

the screen?

Chair Beach: No.

Ms. Gogliotti: Just one slide that you're seeing. No?

Chair Beach: I can't.

Ms. Behling: Maybe it's my fault. Should I do the 

stop presenting?

Ms. Gogliotti: Yes, hit stop presenting, Kathy. 

Maybe that's what I need.

Ms. Behling: Okay, I did.

Ms. Gogliotti: It was doing something strange, 

which I'm not used to seeing, so --

Ms. Behling: Okay, there we go. Do you have it 

now?

Ms. Gogliotti: Let's see.

Ms. Behling: I thought I gave you control but that 

didn't seem to work. 

Ms. Gogliotti: Okay, so, let's try this again. 

Chair Beach: There you go. It's up now.

Ms. Gogliotti: Okay. And you see just a single slide?

Chair Beach: Yes.

Ms. Gogliotti: Perfect. Okay, I'm presenting our 

review of OTIB-0049 revision two, which is 

estimating doses for plutonium strongly retained in 

the lung.

And while my name is on this, this is actually a 

collaborative effort. Joyce Lipsztein is the main 
80

author and also Ron Buchanan and Bob Barton 

helped with this, and Kathy added lots of input in 

terms of being a reviewer.

My mouse disappeared here. There we go. So we 

use OTIB-0049 quite a bit, and the previous revision 

was revision one PC-2. I'll just call it revision one for 

shorthand, and that was issued in November 2010.

And that was used for about a decade until revision 

two was issued in September of last year. And this 

is a complete rewrite of the document. And it really 

changed the way that plutonium, or type Super S 

plutonium, is being addressed. We were tasked to 

review revision two in February of this year, and we 

issued our review in October of this year.

So the purpose of OTIB-0049 is really to establish 

an updated biokinetic model for dose reconstructors 

to use to establish deposition, retention, and 

removal of highly insoluble plutonium using newer 

guidance documents than were used previously.

And when I say very insoluble plutonium, I'm 

talking about type Super S or SS plutonium.

And I know we talk about solubility types all the 

time. However, just a quick refresher of what a 

solubility type is and why it's important to a dose 

reconstruction.

Your solubility types are going to be the solubility of 

particulate matter deposited into the respiratory 

tract. 

And so more specifically, it has to do with lung 

clearance type rates of absorption into the blood. 

And when we talk about these, we typically talk 

about them in terms of solubility types F, M, and S. 

F would be standing for fast, M for moderate, and S 

for slow. So that has to do with the speed of which 

material is clearing the lungs into the blood.

But where does type Super S fall into all of this? 

Historical studies over the last four decades or so in 
81

both animals and some inadvertent human 

exposures have shown that in some cases, the rate 

of removal of plutonium from the lung is slower 

than what is predicted by type S. That means that 

the material is staying in the lungs longer and if it's 

there longer, it's giving a higher dose.

So using the typical type S model, you would be 

underpredicting the dose. And in this program, 

obviously, we are looking for a best estimate, or at 

least a bounding dose, which is why we have this 

type S or Super S, or SS model.

So NIOSH's new approach is combining guidance 

from ICRP 130, which is a fairly new document that 

was issued in 2015, I believe, with ICRP 67 and 

ICRP 30, which are older documents. And we've 

really come up with a hybrid model that introduces 

modified dissolution parameters that lower the 

predicted urinary excretion.

And they do this by creating three parameters: Fr, 

which is the fraction of inhaled materials absorbed 

by the blood relatively rapidly, and that value that 

they came up with is 0.001029; Sr, which is the 

rate at which material is absorbed, and that value is 

100.1; and the remaining fraction of material 

absorbed at a slower rate, which is Ss, and that's 1 

times 10 to the negative 6.

And that takes us to our first observation. And here 

NIOSH is using ICRP documents to come up with a 

model that they built. But there's actually been a 

new ICRP document that was issued in 2019 that 

was approved in 2018, ICRP 141, that has solubility 

information and biotitic models appropriate for type 

Super S plutonium.

So here we recommend that they should be using 

the latest guidance for modeling dose. And that is 

our Observation 1. And here, just to kind of 

compare the parameters that are in the current 

guidance document, Rev. 2 of OTIB-0049 and ICRP 

141, and you will see that there are fairly different 
82

values.

Okay, and Observation 2, this is more of just a 

typo, we believe. Section 4.1 of Rev. 2 of OTIB0049 lists incorrect Fr value.

In the document, it should be 0.001029 and 

erroneously, they flipped the 0 and the 2, so they 

used, they stated 0.001209. And we believe that's 

just a typo that should be corrected, especially 

because that's one of the main sections of the 

report.

Observation 3, OTIB-0049 Rev. 2 does not consider 

long-term binding of plutonium. In some cases, the 

dissolved materials appear to be attached to the 

lung, the lung structural components, and removed 

only by the absorption of blood.

To represent this type of time dependent uptake, 

it's assumed that the fraction SB of the dissolved 

material is retained in a bound state, from which it 

goes into the blood at a rate of sb. And ICRP 141 

recommends a value of 0.2 percent for the bound 

fractions, the sb a value of 0 for the sr, sb.

And Observation 4, Rev. 2 also doesn't use the 

updated systematic model that is included in ICRP 

141. I want to point out that 141, I think I forgot to 

mention earlier, was issued in 2019. It was 

approved in 2018.

So this was available at the time that this document 

was published. But it may have just been missed in 

the processing, based on the timing because this 

document is quite involved.

Observation 5 also has to do with ICRP 141. We just 

suggested that NIOSH should consider using the 

OIR Data Viewer, and that stands for Occupational 

Intakes of Radionuclides.

It's really a software package that accompanies 

ICRP 134, 137, and 141. And it's just something to 

consider using. But this is really a big change, and I 
83

think we were not expecting the level of change that 

we saw incorporated into this, and so I do want to 

take a moment to just address exactly what was 

changed.

In the original version NIOSH should not actually 

model type Ss doses. Instead, what they did is they 

applied a correction factor to the model type S to 

account for additional dose that would be expected 

to be retained from the Super S model.

So you might think of, when you think of OTIB0049, you probably think of the factor of four 

adjustment that gets used a lot in dose 

reconstruction or was used a lot. And that's just 

when a factor of four was multiplied by the doses 

for urinary secretion.

But the new model is completely different in that it 

is actually building on the model for type Super S. 

So there's no more adjustment factors. The 

parameters that they built are using ICRP guidance, 

not the 141 but earlier guidance, as well as 

historical intake information to develop these new 

intake parameters.

But we did note that there's really not a lot of 

guidance in the actual document that tell dose 

reconstructors how to use it. We were a little 

surprised. This is actually takes us to OTIB, our 

Observation 6, that there isn't a lot of guidance in 

the document to tell those reconstructors how to 

actually apply it.

And I know the Board has been focusing, especially 

lately, on making sure that guidance is 

unambiguous enough that things are processed 

consistently. 

And actually, while we were talking about this, we 

went back and forth. We had no idea how this was 

being implemented. We thought perhaps they were 

changing parameter in IMBA, but those numbers 
84

weren't working out right.

And come to find out, we asked the eval if there 

was maybe a tool that they were using that we 

hadn't been provided, and that was part of the 

reason for the delay of this report.

There was, in fact, a tool that we were unaware of, 

the IDOT user interface. Looks like this. IDOT 

stands for Internal Dosimetry Tool. Our 

understanding of it, and this hasn't been conveyed 

to us, but we believe that it's going to replace old 

IMBA and OTIB-0049 tool combination.

This picture that you see here is the opening main 

page when you pull it up. It looks very similar to 

what you would see if you pulled up IMBA.

You can see that there is ten places to input 

intakes, with a start and end date. You can use this 

for both acute and chronic models. 

You can change the units, you can change the 

radionuclide inputs. There's also a bio tab that is 

very similar to the bioassay calculation function in 

IMBA, where the user can input bioassay data from 

urine, fecal, lung, and whole body counts.

And then there's an annual dose tab, which is also 

very similar to annual dose tab in IMBA, and that 

allows the user to input cancer information, 

exposure start dates, and then there's also a 

committed dose tab, which is very similar to IMBA, 

also, where you press a single button and the page 

allows the user to calculate the committed dose to 

various orders and its committed effectiveness.

Okay. And in addition to this, NIOSH provided us 

with a little bit more documentation. There is a user 

guide for the tool.

There's RPRT-7, which is a technical document kind 

of supporting the tool, and there's an IDOT 

benchmarking tool for bioassay in doses.
85

At SC&A, we have confirmed that the tool is 

functioning, but we have not looked behind the 

curtain. Actually, the tool is locked, so we can't 

really look behind the curtain. We did request the 

password from David Allen and NIOSH told us that 

they didn't feel that it was within our purview of 

taxing.

So at this point in time, we've looked at them, but 

we haven't done an in-depth review of the software 

that's of the tool. So any of the calculations that the 

tool is using were really done in an independent 

benchmarking validation calculations.

If that's something bad that the Subcommittee 

wanted us to do, we could absolutely do that. It will 

be a lot of work. I'm not going to sugar coat it. It's 

a really complicated tool, and it would require a lot 

of work to really dig into. If that's something that 

you're interested in, we can certainly talk about 

that, but at this point in time, we have only looked 

at a cursory overview of the tool to see that it's 

doing what we think it should be doing, but we 

haven't gone further than that.

And just to kind of look at the tool or the use of this 

new revision in comparison to the old. We did a 

couple cursory runs here. This is not a direct 

comparison by any means. 

As I mentioned before, the old one was applying a 

correction factor and the new one is actually 

developing their own dose, but just a chronic intake 

of the same amount of Pu-239 and just to see the 

impacts that it had on dose overtime.

Now, normally, you use bioassay data, so this is not 

a great comparison, but just to get an idea, we see 

that in general, revision one had higher doses, 

except for the extrathoracic lymph nodes here. And 

these were just several runs that we did.

So looking more into that, we were interested in 

what impacts this would have on more of a typical 
86

case that we see in dose reconstruction.

So we ran two separate models, a case A, which is a 

short exposure period and a long latent period, and 

case B, which has a long exposure period and a 

short latent period.

Now, these are not real cases. We wanted to get a 

feel for using typical information that we see in a 

dose reconstruction, what would really the 

implications of that be?

So we compared organ doses derived from these 

two different methods. For the first method, we 

looked at a chronic intake of Pu-239, and we ran it 

on both the old and the new.

And here you see we have graphed the ratios of the 

two. And what's interesting were kind of what we 

expected, was that the majority of the organs have 

a ratio less than one, which means the new dose is 

less than the old dose.

But here, you do see that LN(ET), which is the 

extrathoracic lymph nodes, and ET2, which is the 

posterior nasal passage, do have higher doses than 

were previously assigned.

Similarly, with an acute dose of Pu-239, in case A 

which, remember, is a short exposure period and a 

long latency, you see a very similar effect.

The TBBAS and BBBAS, which stand for the tissue in 

the thoracic region through which the basal cells are 

distributed, and the same for the bronchial region, 

has a ratio much closer to one. But otherwise, we 

see a very similar trend here.

Switching to case B, which is a long exposure and a 

short latency period, here we have a chronic intake 

of Pu-239, and again, you see a very similar 

distribution, slightly higher ratios for some of these, 

but still very similar.

And then we have one more example for the chronic 
87

intake of americium, and that should be 241, sorry, 

but again, you see very similar trends.

So the takeaway from this was doses in the thoracic 

and extrathoracic regions can be greater using the 

new method compared to the old method.

And similarly, doses of the systematic organs are 

generally less using the new method compared to 

the old method.

So based on that, we believe that a PER is likely 

necessary. Based on our preliminary runs, it 

appears that in certain instances, the doses are 

going to increase, even though the original doses 

were believed to be bounding at the time. 

So we just believe that should be addressed at 

some point.

We did have one finding. When we were using the 

IDOT too, we found that it did not provide annual 

doses for one particular organ, the urinary bladder.

When you did a run for that, it came up with N/A for 

all of your annual doses. David Allen reached out to 

us about two weeks ago and said that they were 

aware of the problem, it had been fixed, and he 

provided us with a new tool where this had been 

corrected.

I don't know if that was the only problem that was 

corrected in that, and so someone will have to verify 

that for us.

And I did verify that as of last week, that tool was 

updated into the NIOSH edge computing platform.

So we'll just need to confirm that that was the only 

change that was made, and I assume there's some 

sort of documentation supports that change.

And then we also had one more comparison, and 

that was using the new OTIB-0049 guidance, or

parameters, and then also the ICRP 141 parameters 
88

with the HAN-1 case, which is a case of an incident 

human exposure.

We see that while the OTIB-0049 data does appear 

to fit better, that's kind of to be expected when you 

only use one case.

That's what you would expect. It somewhat 

indicates, could be an indication of overfitting 

because you're only using a single example and you 

don't have more data to introduce more variance 

into the population.

Sorry, my mouse is not clicking here. And our final 

observation, observation eight. And this is the ICRP 

141 parameters appear to be more climate 

favorable.

We did a lot of runs using the HAN-1 case as an 

example, and in general, the doses that we 

calculated using the 141 parameters or higher for all 

organs, so we believe that that should be something 

that should be explored in the future. And that's all 

I have.

Chair Beach: Thanks, Rose. I have a question back 

on Observation 6, the tool. Is that something that 

you, I know it's in depth and you don't have access 

to it.

It would be a big task, but is that something that is 

necessary to finish your review of this document?

Ms. Gogliotti: It's hard to say.

Chair Beach: Or make it more complete?

Ms. Gogliotti: It would -- it would definitely make 

the review more complete but it would be a lot of 

work.

I'm not going to sugar coat it. We certainly have the 

capabilities to look at this in more depth if we were 

given the passwords, but we really don't know what 

we would find.
89

If they did benchmarking, things should be as they

expect, as they say, but until we really look under 

the hood, we can't confirm that.

Chair Beach: Okay. I understand.

Ms. Gogliotti: We've never done that level of review 

previously on a tool, but this is also one of the most 

complicated tools we've ever seen.

Chair Beach: Thank you. And Paul, Loretta, any 

questions?

Member Ziemer: This is Paul. I assume that NIOSH 

only received this in the last few weeks, right? To 

look at?

Ms. Gogliotti: We published this on October 7, I 

believe.

Mr. Allen: Yes, Paul, this is -- this is Dave Allen. 

We're ready to discuss all these. I'd like an 

opportunity to discuss all these observations and 

findings. Just waiting for my opportunity here.

Member Ziemer: Yes, that's Josie's call. I just 

wasn't sure where we stood on this, and I don't 

think even if you're ready, we don't have anything 

written yet, do we? I don't --

Mr. Allen: No, there wasn't really enough time for 

our system to do a review cycle.

Member Ziemer: Right. Got you.

Chair Beach: Okay. And, yes, I was going to go, 

move to NIOSH, but I was checking to see if the 

Subcommittee had any other comments or 

questions, clarifications.

Member Ziemer: And I just, I kind of assume that 

on the -- on the issue of the tool itself, that maybe 

NIOSH would have some recommendation one way 

or the other on how the tool is evaluated, that 

would lead to whether or not it would be necessary 
90

or important for SC&A to go behind the curtain, 

quote unquote.

So that was, my question is mainly, where is NIOSH 

on this? So thanks, David.

Chair Beach: And Loretta, anything, any questions?

Member Valerio: No, I'm just waiting to see what 

NIOSH has to say.

Chair Beach: Okay. I guess we'll turn it over to 

David, then. Thank you.

Mr. Allen: Okay. Would you like me to just go 

through all the observations and findings one at a 

time or --

Chair Beach: Sure, and then if --

Mr. Allen: Okay, I think that's the way I'd like to do 

it.

Chair Beach: Okay.

Mr. Allen: Okay. Let's see. Starting with Observation 

1, looks like, Rose, you've got that on the screen. 

Thank you.

We do realize there is an ICRP 141 out with a new 

plutonium model. However, what's not realized is 

the amount of work that goes into actually trying to 

change over into a new model.

We started this effort with OTIB-0049 back in 2016. 

It took quite a while to, it wasn't as hard as far as 

developing this document and then developing a 

tool that would run this new model, but then we had 

to go back and change all these coworker internal 

models, or TBDs.

It seems like there are a few other. We had to 

document OTIB-0049, of course, but we also had to 

document a user guide and technical documentation 

for the tool.
91

We had to change all these coworker models. And 

there was any number of other things we had to go 

through to figure out how we're going to implement 

this.

So overall, it took us three, four years to do this, 

and then right before the end of that, they came out 

with a new model.

ICRP came out with it. We knew it was supposed to 

be coming, but they frequently say there's a draft 

and then they never publish it.

So they did actually publish this one and we have 

looked at this. And in the end, eventually, we would 

like to go through all the ICRP 130 family of models, 

which is for all the isotopes.

It's ICRP 130, 134, 137, and 141, and there's a lot 

of isotopes covered by that. They also cover some 

changes to specific effective energies based on new 

voxel phantom models, et cetera.

There's a whole -- a whole host cell change in the 

way ICRP is doing the internal monitoring there.

And, yes, we would like to update to that, but it's 

going to take years, going to take some time. And 

we wanted to get this model into place now and 

then work towards updating that.

And ideally, we would update that at the same time 

we update external cryotherapy 116, but I suspect 

116's going to come out first, going to be ready for 

that first, and then we'll just have to see where we 

stand and decide at that point whether we do this 

piece meal or wring it all out at one time.

But it is a Herculean effort, and I don't want to say 

that. To say that we've proofed this document 

recently, even though ICRP 141 is out that is 

actually true.

However, that document was drafted and ready to 

go for years while we were changing everything 
92

else.

I know that's kind of rambling, but that's where we 

stand right now, is that we know that exists.

We would like to go to that at some point, but it's 

going to take a long time for us to get there. But 

we're using this OTIB-0049 in the meantime.

And I think that answers that. Can we go on to 

observation --

Chair Beach: Okay, let me ask, do you have any 

comments or questions on this? And I'm assuming 

it's not ready to be --

Mr. Barton: Well, this is Bobby. Certainly --

Dr. Taulbee: I think that question was directed to 

us, David.

Mr. Allen: Okay.

Mr. Barton: Now, we agree that you'll eventually 

want to be using all the latest and greatest methods 

in science to do dose reconstruction.

We really can't comment on the resource allocation 

and where this would rank as far as importance to 

get it updated.

And we do sort of, we definitely understand that this 

was long in the making. We didn't know exactly how 

long, but we do, that comment about when ICRP 

141 came out versus when this report was officially 

accepted, we completely understand that just based 

on the timing of it, and we assume that it was at 

least a few years in development to be able to 

develop this tool.

So while we can't comment on the resources to 

update to it, that's really not our purview.

Chair Beach: Right.

Mr. Barton: We certainly agree that it's appropriate 
93

to eventually get there, however that fits in with 

other important aspects of the program.

Chair Beach: Right. Thanks, Bob. And, Paul, I think 

you had a comment.

Member Ziemer: Well, the only thing is that I guess 

we would anticipate that dose reconstruction is done 

under the ORAU 49 might eventually have to be 

redone years down the road under ICRP 41.

Chair Beach: Right.

Ms. Gogliotti: I'm sorry, this is Rose. I'm back. I lost 

audio there for a moment. I don't know what 

happened.

Chair Beach: Okay. Yes, you're not -- you're not 

showing anything on the screen. Are you able to put 

that back up?

Ms. Gogliotti: Yes, I'm working on it right now.

Chair Beach: Okay, thank you for, so I guess we 

can't really close these. And I'll let Dave just skim 

through.

Member Ziemer: Yes, I don't think we close them.

Chair Beach: Yes, and --

Mr. Allen: Well, I'm not sure what you're going to 

do with those, though. It's going to be years before 

we get this implemented. So it's just going to be 

hanging out there.

Chair Beach: Yes.

Mr. Allen: I mean, it's a recommendation for us to 

use the new models and that is our intent, but it's 

going to be a while

Chair Beach: Right. But it's a tracking for us also, I 

guess. Moving forward, if you want to just stop and 

see if SC&A needs clarification or comments? We 

can just move through these.
94

Mr. Allen: Okay, was that --

Member Ziemer: Yes, so actually, NIOSH needs to 

know whether, Dave, as I understand it, whether 

we're comfortable proceeding with the present 

model, right?

Mr. Allen: Not sure I understood that question, Paul

Member Ziemer: We have -- we have a 

recommendation from SC&A that ICRP 141 be used. 

But as a practical matter, you're saying, even if you 

say, yes, let's do that, we'd be several years off 

from implementing it, correct?

Mr. Allen: Correct.

Member Ziemer: Yes, so in the meantime, the issue 

is what do we do? And my question sort of would be 

SC&A, if they're not able to implement 141, it's the 

present use of 00-49 and the way they are 

presenting it. Is there anything wrong with it 

otherwise?

Mr. Allen: Other than the fact that it's not 141, is 

there anything inherently wrong with it as it stands?

Ms. Gogliotti: Our perspective was they did the best 

that they could with the data that they had available 

to them. I think we understood a lot went into 

developing this tool.

When you look at the benchmarking document, you 

completely understand why it took so long to build, 

but as your contractor, we did think it was 

important that we point it out that there is other 

guidance available.

Member Ziemer: Yes, and I'm sort of saying, 

maybe, Josie, you can help me on this, but in the 

meantime, does the Work Group, or not the Work 

Group, the Subcommittee need to say we are -- we 

are okay with proceeding in the meantime with 

0049 until the time when it's feasible to implement 

141, or something to that effect. 
95

Chair Beach: That makes sense, Paul, to make 

some kind of a note. And I suspect that might be 

the case on a lot of these.

Dr. Taulbee: This is Tim, if I can interject here. And 

just the sense that if SC&A has identified these as 

observations, with the one finding, I think it really 

speaks to that, in that I think they correctly and 

thankfully recognize that this is going to take us a 

long time in order to implement.

So this is kind of, in a sense, an interim tool until 

we get there with 141, and as Dave mentioned, the 

other ICRP documents 134, 137, that this tool is a 

better model than what we had before, and a better 

methodology.

And so we're moving towards a final model.

Chair Beach: Okay.

Mr. Barton: Yeah, Tim, this is Bob. I was going to 

say something very similar to that. I think we at 

SC&A certainly agree that this newer model, or 

interim model, as you referred to it earlier, it's very 

elegant compared to what was done previously, and 

we think it's certainly an improvement over the 

older factor four method. So I guess that's just our 

two cents on that.

Member Ziemer: I'm not sure how this would show 

up in the -- in the matrix. Would it be an abeyance 

type of thing?

Chair Beach: Yes, I would say it would probably 

need to be an abeyance. It's not really an open item 

at this point.

Ms. Gogliotti: I agree. It will still show up on your 

tracking.

Chair Beach: Yes.

Ms. Gogliotti: But maybe that's a good thing so it 

doesn't get lost.
96

Chair Beach: Yes, I think -- yes. Okay. So SC&A, is 

someone taking notes on this for entry into the BRS 

at some later date?

Ms. Behling: Yes. Kathy. Yes.

Chair Beach: Okay, thanks, Kathy.

Ms. Behling: Yes, and I definitely agree with putting 

it in abeyance. We have to continue to follow this.

Chair Beach: Okay. Dave, if you're ready, we can 

move on to two.

Mr. Allen: Okay, I'm ready. Rose, were you going to 

put that back on the screen or --

Ms. Gogliotti: You can't see my screen, no?

Chair Beach: No.

Ms. Behling: No.

Mr. Allen: Or me. I'm just not seeing it.

Ms. Gogliotti: Oh, I'm sorry. It's showing up on my 

screen. Let me try going out of this and going back 

in.

Mr. Allen: Well, I'm going to move on. While you're 

doing that, I'm going to move on. Observation two 

was simply that there was a transcription error 

where we had a 10, I can't remember the number 

now.

Member Ziemer: It was 1029 and 1209.

Mr. Allen: Yes, we transposed the two and the zero 

in one section of the document, and yes, we, that is 

what happened. We're sorry. And we'll have to 

revise that the next time we revise the document. 

I'm debating right now whether we need to revise 

for that, because as Rose pointed it out, it is an 

important number in there. But it's derived --

Ms. Gogliotti: And it's in the main section of the 
97

report.

Mr. Allen: Right, and in the Appendix where it's 

described is correct, and you can tell when you go 

look at the derivation as clearly 10.

But we'll have to eventually put that one in 

abeyance, I guess, basically say that, yes, we agree 

that it needs to be revised, and we'll see if we can 

do something to that quickly.

I'd like to get most of these others closed first 

before we do a document.

Member Ziemer: And the tool -- the tool that's used 

has the correct digits, is that correct?

Mr. Allen: That's correct. It's got default digits and 

then user can enter their own values, and the 

default digits are correct.

Member Ziemer: Yes, thank you.

Chair Beach: Okay, so that one's in abeyance. And 

then you're ready for three?

Mr. Allen: Yes.

Chair Beach: Okay.

Mr. Allen: Okay, number three was essentially 

mentioned that we did not consider long term 

binding for OTIB-0049. And my answer on that one 

is we did not feel like we had enough data to really 

say we could defend any value we came up with.

It's kind of like having five unknowns and three 

equations. We chose not to use the bindings. We 

didn't think there was enough information there.

Basically, the bottom line comes down to if I were 

to try to justify the values we came up with for 

binding, I don't think I could justify them. So along 

with almost all the other isotopes ICRP has come 

out with since, we left it all at zero, no binding.
98

In ICRP 141, they did use some binding for 

plutonium. That's one of the few isotopes they ever 

did it with, but it's 0.2 percent that is binding. It is 

not much, and actually solving those models with 

running numbers, it didn't make much of a 

difference.

And honestly, I wouldn't want to be one of the ones 

who justified that 0.2 that they used. But when it 

comes down to it, we've got three different 

parameters we could use.

We have the fast absorption, or the rapid absorption 

fraction, the rapid absorption rate, and the low 

absorption rate. And with the data we had, we could 

do whatever we wanted with those three 

parameters. There was no reason to use a bounding 

one. And I don't think SC&A has actually put 

anything in there saying that we should, they just 

pointed out that we did.

Chair Beach: Which one is typically used? The slow? 

Or do you know?

Mr. Allen: Both. You use the slow and the fast and 

then the F bar is a fraction of the material that 

absorbs rapidly, fast. So between the three of them, 

you essentially end up with two, everything you 

inhale is two groups. It's either absorbing very fast 

or it's absorbing very slow.

Chair Beach: Okay.

Mr. Allen: So anyway, I don't know how else to 

respond to this particular one. We considered it. We 

didn't write down anything in the document about it 

because we didn't write down anything about a lot 

of different things if we didn't use it.

Ms. Gogliotti: Is this something you'd consider using 

when you update in the future?

Mr. Allen: When we go to ICRP 141, they actually 

used it, so, yes, we will have to use it for that, for 

plutonium, but we will be updating for all of them 
99

and none of the other isotopes.

Well, maybe one or two, but most of the other 

isotopes do not use this. But we will for plutonium, 

since that's what ICRP is doing.

Chair Beach: Okay. So that would be an abeyance 

item also?

Mr. Allen: I wouldn't think, well, I, it's up to you 

guys.

Chair Beach: It falls into that category.

Mr. Allen: Well, I mean, regardless of what --

Member Ziemer: It would automatically be covered 

by 141, if they go to that. I think what David is 

saying is they're just observing that it's not used, 

that they haven't recommended the value be used.

Chair Beach: And so it wouldn't be used unless they 

went to, until they go to 141?

Member Ziemer: Well, it automatically gets you, 

right, David?

Mr. Allen: Yes, so it would be, I mean, it would be 

used when we go to 141, so it's really covered with 

observation number one.

Observation number three is really close, because it 

says we didn't consider using it. And that would be 

considering it for our interim model now.

Member Ziemer: No, you did consider using it and 

decided not to.

Mr. Allen: Right.

Chair Beach: Okay, so can we --

Member Ziemer: I think we can close it because, 

number one, it's going to get covered eventually 

anyway.
100

Chair Beach: Can we make note, can we close it and 

make note that it's covered in Observation 1 and --

Ms. Gogliotti: It will be included in the updated 

model?

Chair Beach: Yes, would everybody be okay with 

that?

Ms. Gogliotti: I think that's feasible.

Chair Beach: Okay. Loretta?

Member Valerio: Yes. Yes, I was just making a note.

Chair Beach: Okay.

Member Valerio: So it will be coming in Observation 

1, right?

Chair Beach: Correct, so it's, we're closing it for 

today.

Member Valerio: Okay.

Chair Beach: On to four.

Member Ziemer: Okay.

Chair Beach: Thank you, Paul, for your interjections 

there.

Mr. Allen: Okay. Number four essentially says we 

did not use the updated 141 model, which we have 

already discussed several times, and I think I'd like 

to see that one closed because it's covered under 

Observation 1.

Chair Beach: Okay, same thing. I would agree with 

that. Any other comments, Paul or --

Member Ziemer: No, I'm fine.

Member Valerio: I'm fine.

Chair Beach: All right, so same thing as one. So 

four is closed. Okay. Thank you. 
101

Mr. Allen: Okay, Observation 5 is talking about the 

OIR, which is the occupational intakes of 

radionuclides.

It is a little computer program put out by ICRP with 

these new models. It's not just for plutonium. It's 

for a variety of isotopes. 

And SC&A's recommendation is that we use that, or 

asked why we didn't use that. My response to that 

one is that this tool that they have, it does not 

provide annual doses, is probably the primary 

drawback to this. 

It makes it worthless to our program. But it also 

does not provide dose for chronic intake.

It does not provide bioassay for chronic intake. It 

does not provide organ doses for all the organs that 

we use in our program.

It does not calculate intakes from bioassays. It does 

not provide doses for multiple intakes. It does not 

provide bioassays for multiple intakes. Other than 

that, it ain't bad.

So, essentially, it's not usable by our program, is 

what it comes down to. Okay, do you want to move 

on to six?

Chair Beach: Sorry.

Member Ziemer: Well, it sounds like we should close 

it. SC&A, any comeback on that?

Ms. Gogliotti: I think this had to do with more of a 

reference document. I do not have intimate 

knowledge of using this data viewer, so I don't feel 

that I could comment on that with much 

intelligence. I believe this is Joyce's planning, and 

she's not on the line.

Member Ziemer: We asked them to consider it, and 

Dave said they've considered it and it won't do. 

Can't use it. Sounds like we should --
102

Mr. Allen: Not only can you not use it in the future, 

but we can't use it with the hybrid model we've got 

now anyway, because it doesn't use that. It uses a 

different biokinetic model.

Ms. Gogliotti: That is true.

Chair Beach: Okay. I'm okay with closing it.

Member Valerio: I'm good with closing it.

Chair Beach: Okay. Five is closed.

Mr. Allen: Okay, Observation 6. Observation six is 

an OTIB-0049 lacks information about the 

application.

That's not really the place for OTIB-0049. OTIB0049 was to develop the model for a particular 

solubility class, and that's what it did much like, 

well, essentially with other documents, TBDs and 

OTIB-0060, we have documentation on how to use 

various solubility types.

By and far, you're using the most favorable or 

credible solubility type for that claim.

Type Super S is just one more solubility type. And it 

is mentioned as type Super S in OTIB-0060.

Essentially, you would also use that one, and if it's 

the most favorable you would apply. So I don't think 

OTIB-0049 is the proper place to put all the 

guidance that they're essentially talking about in 

there.

Ms. Gogliotti: Well, I know the previous version of 

OTIB-0049 definitely gave those reconstructors 

input on how to apply the adjustment factor and so 

--

Mr. Allen: OTIB-0049 previously had a very 

complicated model, or a very complicated system, 

where it described how to use that system to come 

up with a number, whereas the new version of 
103

OTIB-0049 now, we have a tool that just spits out 

the number. 

We have a model that if you solve it, whether you 

use a tool or some other means, gives you a 

number.

Not a lot of guidance necessary for that. The 

guidance comes in sitting bioassay and what you do 

with the different solubility classes, and that's in 

other documents.

Ms. Gogliotti: I'm not sure I fully agree with that, 

but if NIOSH believes that their dose reconstructors 

have enough information to use this tool efficiently, 

the same way --

Mr. Allen: Well, we can make it easy. What kind of -

- what kind of guidance would you expect to see?

Ms. Gogliotti: I'm used to seeing, this is a tool that's 

available for this, to use this user's guide or 

something that directs, because from this, from 

your document, I did not get to the tool. And if I'm 

not getting there, I question who else is not getting 

there.

Mr. Allen: Well, there's not a lot of documentation 

on TBDs, et cetera, where you're going to see where 

we tell people to use IMBA.

(Simultaneous speaking.)

Mr. Allen: It comes up in reports and maybe some 

OTIBs, not a lot of TBDs. For the most part, the 

TBDs tell somebody you have three or two or 

however many credible solubility types, and barring 

anything else, you use the most favorable.

Ms. Behling: This is Kathy Behling. However, 

shouldn't you at least identify the tool in this new 

OTIB-0049? Identify that the tool is this? Because 

there's no mention of it at this point.

Mr. Allen: It would be probably an improvement to 
104

say that there is a tool to span this model, yes. 

I don't know if I would call that guidance, but, yes, 

it would probably be a good addition to the -- to the 

document.

Mr. Barton: Yes, this is Bob. I don't think this is, I 

mean, these are observations. I don't think this is a 

really huge deal, but if you're going back in to 

revise that typo in the value in the main body of the 

report, why not just add in a sentence indicating 

that there is a tool available, and here's the user 

guide for it and this is what implements this 

method. Seems like a pretty simple fix.

Ms. Brackett: This is Liz Brackett from the ORAU 

Team. I would propose that this actually belongs in 

OTIB-0060, not OTIB-0049.

That's where DRs are directed to use IMBA and I am 

in the process of revising OTIB-0060 right now, so I 

think it would be appropriate to add it there, to 

make a statement that IMBA is used for these 

particular types and then you would use IDOT for 

Super S plutonium.

Mr. Allen: Are you sure it's not already in there, Liz?

Ms. Brackett: Yes, I just did a search because I 

thought it might be, but I don't see, I did not get a 

hit on IDOT when I did a quick -- a quick search. So 

it just, because the last time --

Mr. Allen: Well, in the reports, the DCAS-RPT-005, 

which is the IDOT technical manual.

Ms. Brackett: The last time this was updated was 

2018, so I --

Mr. Allen: Oh, I'm sorry. Report five is type J.

Ms. Gogliotti: Yes, the --

Chair Beach: All right. So back to Observation 6, 

would that satisfy SC&A's observation here if it was 
105

updated in, is it OTIB-0060?

Ms. Brackett: Yes.

Chair Beach: Okay.

Ms. Gogliotti: Personally, I would like to see it in 

both places, but that's up to the Subcommittee.

Ms. Behling: Yes, that was going to be my comment 

also, that I think it should be in both places. This is 

Kathy.

Chair Beach: I don't see why it would be a problem 

to have it in both places other than you'd have to 

update 0049, which sounds like it's going to happen 

anyway at some point. Other Subcommittee 

Members?

Member Ziemer: If it helps get the dose 

reconstructors to the right tool, then why not put it 

in? It's not a -- it's not a big detail.

You're not -- you're not giving guidance on how to 

use it. You're just saying, look, here's where the 

tool is, I guess, right?

Chair Beach: Right.

Mr. Allen: Yes, I don't disagree with that Paul or 

Josie. We can -- we can get that put in there and 

probably point to the user guide, the tool.

Member Ziemer: Yes. Yes. All right. I think that, if I 

remember, that was the initial concern of SC&A, 

making sure there's some map to say where the 

tool is or what tool to use.

Chair Beach: Agreed. So that one is in abeyance 

also.

Mr. Allen: I mean, I've always been a little antsy 

about locking ourselves into something, and right 

now, with the way our computer systems are going, 

I'm kind of really antsy about locking ourselves into 

something that somebody else might come off.
106

Member Ziemer: Yes.

Mr. Allen: We can put it in there and just shut down 

and pull it back out if we get this turned off.

Member Ziemer: I didn't follow tat.

Chair Beach: I was going to say, you have some 

issues that we don't know about. Yes.

Mr. Allen: The whole thing about the Board Review 

System, NOCTS, all that getting shut down, it's not 

just NOCTS.

It's not just SRDB and it's not just the BRS, it's 

every computer thing we have now is under scrutiny 

and --

Chair Beach: Yes.

Mr. Allen: I haven't seen a lot of logic to it, so I 

can't guarantee what's going to fly and what's not.

Chair Beach: Yes, well, we'll have to continue as we 

have until we get further notice on how things are 

changing. So, I mean, we all agree that it should 

probably be in both places, so let's leave it at that 

and move on to seven, if everybody agrees.

Member Ziemer: Yes.

Mr. Allen: Okay. Moving on to number seven, 

essentially, it's just a statement that PER may be 

required.

Mostly, it was SC&A looked at some hypothetical 

cases at the old OTIB-0049 and what the new 

model in OTIB-0049 would give us, and the new 

model is lower for most organs, but some lung 

organs, some respiratory tract organs it is not.

My response to that one is, as I said with 

Observation 1, we intend to go to the newer ICRP 

models in the future, and again, that's not a small 

change and evaluating that change in a PER is not a 

small deal, either.
107

What I had planned all along, when we started 

working towards going to write 5115 for external is 

we were offered the ICRP 130 stage for internal, 

and at that point, we will have to change OTIB-005 

because the target organs in both of those are a 

little different than what the target organs are now. 

And this will end up being the PER from hell is what 

it amounts to.

Chair Beach: Ah, got you.

Mr. Allen: So I don't really want to do an interim 

one right now, and when I look at the models, I can 

-- I can, I've got enough I can put together the 

OTIB, I'm sorry, the ICRP 141 plutonium model.

And I can see even though our new model has the 

lung doses, some of the lung doses being a little 

higher, ICRP 141 does not.

It will be lower when we implement that. So there's 

really no need to do a PER on this at this point.

And the proof in the pudding will be when we do the 

mother of all PERs when we go to these new ICRPs 

in the future.

Chair Beach: Okay. Thanks, Dave. How's the best 

way to handle this one, then? Closed with a note? 

Included in one? Or what do you think?

Mr. Allen: I personally think we can close it saying it 

will be covered after we get the new models, which 

is discussed in observation number one.

Chair Beach: Okay. I would agree with that. Paul? 

Loretta?

Member Ziemer: Yes, an observation that a 

Program Evaluation Report may be required, you 

could say that about a lot of things. 

If it's required, we do it. If it isn't, we don't. So I 

don't -- I don't see any action that you'd take on 

this particularly one way or the other. So I would 
108

close it.

Ms. Gogliotti: My concern, if I could just --

Chair Beach: Yes, please, I was going to ask you to 

comment, Rose.

Ms. Gogliotti: Yes, I understand that it's a big 

undertaking, but if there's a case that is close that 

would benefit from the case being revised to the 

new model, I think asking it to wait another five 

years or ten years or whenever this gets 

implemented is really asking a lot of the claimant.

Mr. Allen: But, no, that's not true, Rose, because, 

like I said, I can solve that plutonium 141 model, 

and the numbers are lower. They are not higher, 

like they are now.

Ms. Gogliotti: Okay, so it will reduce every organ?

Mr. Allen: Well, it will reduce, yes, from the original 

OTIB-0049, yes.

Ms. Gogliotti: Do you have documentation of that?

Mr. Allen: No, I have my own little spreadsheets 

where I can solve the ICRP 141 models and I can --

I can say it's going to be lower.

I don't usually put the other documentation saying 

that I'm not doing a PER or I'm waiting on a PER or 

anything like that.

Ms. Gogliotti: I think we would have to run some 

internal numbers to confirm that, then.

Mr. Allen: Okay, we've got to solve the 141.

Actually, you can do some of that with the OIR tool. 

Actually, you probably can't because the ones you 

saw, like ET2 and LN(ET) are not in that tool. You'd 

have to find somebody that would solve the tool for 

you, the models for you.

Dr. Taulbee: Again, this is Tim. The point here is 
109

that we're going to end up doing a Program 

Evaluation Report when you switch and go to the 

new ICRP models for the 130 series, 141, as well as 

ICRP 116.

So I don't see any reason to keep this open. I 

understand your concern associated with either this 

newer method here, but we're in the process of 

implementing and we felt this was a better model at 

this time.

And we will go back and review them all when we 

get there.

Ms. Gogliotti: If it impacts dose or if it impacts PLC.

Chair Beach: Do you have a way to run some 

numbers, Rose, to make yourself comfortable or --

Ms. Gogliotti: I think we're going to have to talk 

internally about that.

Chair Beach: Okay.

Ms. Gogliotti: Is there a way we can leave this in 

progress?

Chair Beach: Committee, would you, is that okay if 

we leave it in progress for now?

Member Valerio: Josie, this is Loretta. I think it 

needs to stay in progress right now.

Chair Beach: Okay, with the action for SC&A. Paul, 

are you okay with that?

Member Ziemer: Well, a Program Evaluation Report 

is required whenever as IS changes the way they do 

dose reconstruction. So I don't understand the point 

of the observation.

Chair Beach: I think the point is that Rose is 

concerned that it's years down the road, and so she

wants to be comfortable with the dose 

reconstruction values. Is that correct, Rose?
110

Ms. Gogliotti: I want to be comfortable that there 

are no instances where you would expect the doses 

to be higher with this, even with the new model, 

with the current model or with the future model, 

because that, if the claimant is close and that could 

push them over the edge, it's not fair to ask them to 

wait for another decade.

Member Ziemer: I don't think you can do a PER 

unless you've changed the methodology.

Ms. Gogliotti: It would be the current methodology 

that changed. 

Member Ziemer: Well, yes, but if the current 

methodology is changed, then they have to do a 

PER if it changes the doses.

Ms. Gogliotti: They're indicating that they will be 

delaying that until more changes are implemented.

Member Ziemer: Wait, what?

Mr. Allen: Yes, that's --

Ms. Gogliotti: That's what they say in the PER. I 

don't think that's in question.

Mr. Allen: We're essentially delaying the idea that 

we're going to do a PER until after we implement 

the new ICRP models.

There's additional changes coming, and I already 

know those additional changes are going to make 

the doses lower than what the original OTIB-0049 

was.

Member Ziemer: Okay, but I'm, what I'm asking is, 

under the legal process by which you do PERs, do 

you do PERs before you make the changes and 

promulgate the changes?

Mr. Allen: No, she's telling me to do a PER for 

revision two of OTIB-0049.

Member Ziemer: Well, yes, right.
111

Mr. Allen: If we were to do that, and if we move the 

mouse to show there's a few cases that would go 

up, so they would get a higher dose, my point was I 

didn't intend to do that because that could be a big 

PER.

There's a lot of people educated out there. And my 

point was, we weren't planning on doing that until 

after we finished all the changes we know are 

coming, which includes the ICRP 132.

And once that's done, I am confident that the doses 

will be lower again, so the Rev. 2 OTIB-0049 PER 

would have been a waste, essentially.

Ms. Gogliotti: Except if you're a person that 

benefitted from it.

Mr. Allen: Benefitted because they fell into the gap 

where it was higher for a short period of time.

Ms. Gogliotti: Yes.

Mr. Allen: Or for a period of time. If we did a case --

if we did a case that got paid with the PER now, it 

did not get paid with Rev. 1 but does get paid with 

Rev. 2, it will not get paid in five or six years from 

now, so you don't need to do a PER now just so a 

handful of cases get paid now that won't be getting 

paid later.

Ms. Gogliotti: But you don't take away their 

payment. I don't know. But that's something for the 

Subcommittee to decide. But I'm just pointing out --

Mr. Allen: That's a resource thing because that took 

us two years to get through a PER for the last time 

we did the Super S. It was really a resource issue, 

so I'm not even sure if that's an issue for the 

Subcommittee.

Chair Beach: Right. So I guess my understanding 

was that SC&A wanted to look at some numbers, 

cases, not necessarily ask NIOSH to do the PER at 

this point so that, is that correct Rose? 
112

You just wanted to be comfortable with what Dave 

was saying. You wanted to look at those numbers?

Ms. Gogliotti: I want to look at the numbers and I 

want to talk internally with the team to confirm 

we're all in the same place.

Chair Beach: All right. Not necessarily, we're not 

tasking NIOSH to do anything at this point.

And I am okay with just holding off for SC&A to 

have an internal discussion. Others? Paul and 

Loretta, are you okay with that, just keeping this in 

progress?

Preparation for December 2021 Full ABRWH Meeting

Member Valerio: I am. My question is, if we, and I 

imagine we would have to suggest this at the next 

meeting of this committee?

Chair Beach: Correct.

Member Valerio: So that should be hopefully within 

the next few months.

Chair Beach: Yes. Paul, you okay with that? Did we 

lose you, Paul? Can you hear me, anyone?

Ms. Gogliotti: I can hear you.

Chair Beach: Okay. Maybe the same thing happened 

to him. I think we'll just leave it in progress and 

then move on to, I think finding one is next.

Mr. Allen: Observation eight.

Chair Beach: You want to go to that next? Okay. 

That's okay.

Mr. Allen: Oh, I'm sorry. Yes, it doesn't matter 

which order we go in.

Chair Beach: No, go ahead and do eight, that's fine.

Member Ziemer: This is Paul. My phone -- my 
113

phone died while I was talking so I had to go get 

tech and I can't hear.

Chair Beach: We moved to observation eight. We 

decided to go ahead and leave the other one in 

progress.

Member Ziemer: I'm fine -- I'm fine with that.

Chair Beach: Okay. Thank you. All right. Go ahead, 

Dave.

Mr. Allen: Okay. As far as observation eight, SC&A 

did an analysis but it's not a scientifically valid 

analysis.

What they did was took the ICRP 141 absorption 

parameters and put them into IDOT to compare, but 

IDOT is using a different biokinetic model.

So the amount of -- amount of plutonium you're

going to get in urine is going to depend not only on 

the lung model but also on the biokinetic model.

So that's really comparing apples and oranges. It 

doesn't make any more sense than taking, say, the 

uranium absorption parameters and putting those 

into your plutonium model.

It's no more valid than that. But I think eight should 

just be closed as a -- as a mistake.

Chair Beach: Okay. Rose? Comments?

Ms. Gogliotti: I'm not sure it's the same thing as 

plugging in uranium into the model.

Mr. Allen: It's exactly the same thing. You're 

plugging in parameters for one model and putting 

them in a different model. It's exactly the same 

thing.

Ms. Gogliotti: Well, in any event, because we are 

moving, in the future you'll be moving to the 141, 

this is kind of a moot point.
114

Chair Beach: Okay. Same, closed with included in 

Observation 1. Is that agreeable to everybody? Or 

closed with no comments?

Member Ziemer: Well, yes, I would close it. I'm not 

sure. I guess those comments are, you asked where 

they should be included in the explanation, thought, 

right? It's not -- it's not just that we're going to 

141.

Chair Beach: Yes, correct.

Member Ziemer: You're saying NIOSH had an 

agreement to comment to start with, right?

Mr. Allen: Right, I'm good with that. The analysis.

And it came across completely the opposite of what 

you came up with if you do something right. It's an 

invalid analysis

Chair Beach: Because the two don't compare is 

what you're saying.

Mr. Allen: Right. It's a different model. You can't 

plug in parameters from one model into a separate 

model and expect any kind of worthwhile analysis.

Chair Beach: Yes. So we're doing things that 

normally we have NIOSH's written comments and 

we go through them and so when we go to put 

these in the BRS, it's not going to be as complete.

Member Ziemer: And what we don't have here is 

we're not sure that SC&A now says, yes, we agree 

that that's the case.

Chair Beach: Yes.

Mr. Barton: This is Bob. I see Dave's point here. 

Frankly, the way this discussion has gone and with 

the plan to update the entire model, I'm fine with 

withdrawing that observation entirely.

Member Ziemer: Yes, I think I'd be more 

comfortable if SC&A agreed to that and not close it 
115

like we did with the others.

Because, on the others, now I should read, but it 

would eventually switch to the ICRP model. 

This is -- this is not an issue that the problem is 

going to be covered by the new model. This is --

this is a little different. So if it's withdrawn, I'd be 

more comfortable.

Chair Beach: Okay. I agree with that. Loretta, are 

you okay with the withdrawal?

Member Valerio: I agree with that. Yes, I agree with 

that.

Chair Beach: Okay. All right. So moving on to 

finding one, slide 24.

Ms. Gogliotti: Yes. I know that you wanted to end 

by now, so --

Chair Beach: I know. That's okay.

Ms. Gogliotti: Okay. Sorry.

Chair Beach: I messaged my husband I would be a 

little bit late, but Kathy, you should be thinking if 

we can do that last item via email or --

Ms. Behling: Yes, I just wanted to make one 

comment before we end. But that's --

Chair Beach: I'll give time to do that.

Ms. Behling: Okay.

Chair Beach: We've got a few, a couple minutes. Go 

ahead, Dave.

Mr. Allen: Okay, finding one is pretty simple. There 

was a glitch in the program that presented the 

urinary bladder doses from showing up on the 

annual dose.

In the -- in the version that I sent SC&A, and that 
116

has been fixed and they got a new version and I 

think they indicated that it now works.

Ms. Gogliotti: Yes. And we did confirm that it is the 

new version as of last week was updated into the 

new NIOSH edge computing platform.

Is that the only change that was made between 

versions?

Mr. Allen: Yes. Yes, there was -- there was actually, 

I take it back, there was a couple of format changes 

made earlier that we did not distribute because they 

were insignificant, and I was waiting for several 

more changes before, didn't want to distribute a 

new version every week or so. 

And so when you guys asked for it, I went ahead 

and gave you the newest thing I had by mistake, 

and somehow I managed to get a glitch.

And so when I had to unglitch it, once I put it out to 

you, I made a newer version pretty after you guys 

put it out to our guys. What you're looking at right 

now is the current version.

Chair Beach: Okay. So the wording just needs to be 

put into the BRS that the new version is out and 

SC&A agrees with that and we can close this 

finding, correct?

Ms. Gogliotti: Yes.

Chair Beach: Okay. Subcommittee agree?

Member Ziemer: Yes.

Chair Beach: Okay.

Member Valerio: Yes.

Preparation for December 2021 Full ABRWH Meeting

Member Valerio: I am. My question is, if we, and I 

imagine we would have to suggest this at the next 

meeting of this committee?
117

Chair Beach: Correct.

Member Valerio: So that should be hopefully within 

the next few months.

Chair Beach: Yes. Paul, you okay with that? Did we 

lose you, Paul? Can you hear me, anyone?

Ms. Gogliotti: I can hear you.

Chair Beach: Okay. Maybe the same thing happened 

to him. I think we'll just leave it in progress and 

then move on to, I think finding one is next.

Mr. Allen: Observation eight.

Chair Beach: You want to go to that next? Okay. 

That's okay.

Mr. Allen: Oh, I'm sorry. Yes, it doesn't matter 

which order we go in.

Chair Beach: No, go ahead and do eight, that's fine.

Member Ziemer: This is Paul. My phone -- my 

phone died while I was talking so I had to go get 

tech and I can't hear.

Chair Beach: We moved to observation eight. We 

decided to go ahead and leave the other one in 

progress.

Member Ziemer: I'm fine -- I'm fine with that.

Chair Beach: Okay. Thank you. All right. Go ahead, 

Dave.

Mr. Allen: Okay. As far as observation eight, SC&A 

did an analysis but it's not a scientifically valid 

analysis.

What they did was took the ICRP 141 absorption 

parameters and put them into IDOT to compare, but 

IDOT is using a different biokinetic model.

So the amount of -- amount of plutonium you're 
118

going to get in urine is going to depend not only on 

the lung model but also on the biokinetic model.

So that's really comparing apples and oranges. It 

doesn't make any more sense than taking, say, the 

uranium absorption parameters and putting those 

into your plutonium model.

It's no more valid than that. But I think eight should 

just be closed as a -- as a mistake.

Chair Beach: Okay. Rose? Comments?

Ms. Gogliotti: I'm not sure it's the same thing as 

plugging in uranium into the model.

Mr. Allen: It's exactly the same thing. You're 

plugging in parameters for one model and putting 

them in a different model. It's exactly the same 

thing.

Ms. Gogliotti: Well, in any event, because we are 

moving, in the future you'll be moving to the 141, 

this is kind of a moot point.

Chair Beach: Okay. Same, closed with included in 

Observation 1. Is that agreeable to everybody? Or 

closed with no comments?

Member Ziemer: Well, yes, I would close it. I'm not 

sure. I guess those comments are, you asked where 

they should be included in the explanation, thought, 

right? It's not -- it's not just that we're going to 

141.

Chair Beach: Yes, correct.

Member Ziemer: You're saying NIOSH had an 

agreement to comment to start with, right?

Mr. Allen: Right, I'm good with that. The analysis. 

And it came across completely the opposite of what 

you came up with if you do something right. It's an 

invalid analysis

Chair Beach: Because the two don't compare is 
119

what you're saying.

Mr. Allen: Right. It's a different model. You can't 

plug in parameters from one model into a separate 

model and expect any kind of worthwhile analysis.

Chair Beach: Yes. So we're doing things that 

normally we have NIOSH's written comments and 

we go through them and so when we go to put 

these in the BRS, it's not going to be as complete.

Member Ziemer: And what we don't have here is 

we're not sure that SC&A now says, yes, we agree 

that that's the case.

Chair Beach: Yes.

Mr. Barton: This is Bob. I see Dave's point here. 

Frankly, the way this discussion has gone and with 

the plan to update the entire model, I'm fine with 

withdrawing that observation entirely.

Member Ziemer: Yes, I think I'd be more 

comfortable if SC&A agreed to that and not close it 

like we did with the others.

Because, on the others, now I should read, but it 

would eventually switch to the ICRP model. 

This is -- this is not an issue that the problem is 

going to be covered by the new model. This is --

this is a little different. So if it's withdrawn, I'd be 

more comfortable.

Chair Beach: Okay. I agree with that. Loretta, are 

you okay with the withdrawal?

Member Valerio: I agree with that. Yes, I agree with 

that.

Chair Beach: Okay. All right. So moving on to 

finding one, slide 24.

Ms. Gogliotti: Yes. I know that you wanted to end 

by now, so --
120

Chair Beach: I know. That's okay.

Ms. Gogliotti: Okay. Sorry.

Chair Beach: I messaged my husband I would be a 

little bit late, but Kathy, you should be thinking if 

we can do that last item via email or --

Ms. Behling: Yes, I just wanted to make one 

comment before we end. But that's --

Chair Beach: I'll give time to do that.

Ms. Behling: Okay.

Chair Beach: We've got a few, a couple minutes. Go 

ahead, Dave.

Mr. Allen: Okay, finding one is pretty simple. There 

was a glitch in the program that presented the 

urinary bladder doses from showing up on the 

annual dose.

In the -- in the version that I sent SC&A, and that 

has been fixed and they got a new version and I 

think they indicated that it now works.

Ms. Gogliotti: Yes. And we did confirm that it is the 

new version as of last week was updated into the 

new NIOSH edge computing platform.

Is that the only change that was made between 

versions?

Mr. Allen: Yes. Yes, there was -- there was actually, 

I take it back, there was a couple of format changes 

made earlier that we did not distribute because they 

were insignificant, and I was waiting for several 

more changes before, didn't want to distribute a 

new version every week or so. 

And so when you guys asked for it, I went ahead 

and gave you the newest thing I had by mistake, 

and somehow I managed to get a glitch.

And so when I had to unglitch it, once I put it out to 
121

you, I made a newer version pretty after you guys 

put it out to our guys. What you're looking at right 

now is the current version.

Chair Beach: Okay. So the wording just needs to be 

put into the BRS that the new version is out and 

SC&A agrees with that and we can close this 

finding, correct?

Ms. Gogliotti: Yes.

Chair Beach: Okay. Subcommittee agree?

Member Ziemer: Yes.

Chair Beach: Okay.

Member Valerio: Yes.

Chair Beach: This should be interesting going back 

to the BRS to make sure we have all these 

comments when that's available.

Okay, Kathy, I'm going to go ahead and send it over 

to you. I know we aren't going to have time to do 

the newly issued documents, but you had a 

comment?

Ms. Behling: No, I just had a few questions. At the 

last full Board meeting teleconference, I asked that 

I provide you with a list of the documents that I 

would like to present to the full Board that have 

already been approved by the Subcommittee, and I 

included six documents on there.

Two of them were the ones that I previously 

included in examples when we talked about this 

matrix approach. The other ones were the email 

that I just gave you, the first four on that handout.

Lori and I have talked and she pointed out to me 

that this OTIB-0014 is very much embedded and 

incorporates a lot of things from OTIB-0052.
122

And OTIB-0052 and PER 14 and OTIB-0020 is just 

very complex. It's going to have to be a completely 

different discussion. And OTIB-0014 falls into that 

discussion also.

So I want to take that off the list. That's the only 

question.

Chair Beach: Okay, withdraw 14? Did you want to 

add anything or just go with the five?

Ms. Behling: I was thinking that I would just go with 

the five, unless you want me to add something.

Chair Beach: I think I'm okay with the five. The 

PROC-0022 was not on your list, the newly revised 

list. I looked. Was there a reason?

Ms. Behling: Yes. No, I don't know why I did that. 

Just because I had included that on, when we talked 

previously so I don't think I included that here. But 

might need to update that list just so we have a 

good turning point.

Chair Beach: Subcommittee Members, anybody 

have any problems with that? Or do you want to 

add any?

Member Ziemer: I would go with that. 0014 is off 

and 0022 is on?

Chair Beach: Okay, so we're doing OTIB-0033?

Member Ziemer: Same as on the new list. Just 

same as on the new list.

Chair Beach: Okay.

Member Ziemer: There will be six items.

Chair Beach: It's going to be five now, because it's 

going to be PROC-0022, which I discussed as an 

example during the matrix, and PER-081 along with 

OTIB-0025, OTIB-0032, and OTIB-0033.

Member Ziemer: Okay. I'm good.
123

Chair Beach: Okay, for tasking, so far we've tasked 

one item, the newly -- the newly issued documents 

that we've not tasked. Can we just do that over 

email, Rashaun? I know we've done that in the past.

Dr. Roberts: Yes, that's perfectly fine.

Chair Beach: Okay. So I will send out an email in 

the next few days and then we'll also maybe send 

out an email with that newly issued document 

talking about the tasking of those items.

Is there anything else for the good of the 

Subcommittee? I don't think -- I don't think -- go 

ahead.

Dr. Roberts: So I think we've tentatively scheduled 

the next meeting, but we could handle that via

email, too, if you prefer.

Chair Beach: Yes, I think let's do that. Let's get a 

good handle on what's carryover and different 

things and then -- and then do that via email. It 

probably won't be until the first of next year 

anyway.

Dr. Roberts: Right. I was thinking it would be early 

February, but we can -- we can go back and forth 

about that.

Chair Beach: We can do that relatively soon. Thank 

you for all the hard work. It's been a long meeting. 

Any last comments before we adjourn?

Member Ziemer: No. Thanks, Josie. Thanks, 

Rashaun and all the staff.

Chair Beach: All right. Thanks, everybody. We'll talk 

soon via email.

(Whereupon, the above-entitled matter was 

concluded at 3:27 p.m.)