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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

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

137th Meeting

Wednesday, December 9, 2020

The meeting convened via teleconference at 1:15 

p.m. Eastern Standard Time, via Videoconference,

Rashaun Roberts, Designated Federal Official,

presiding.
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 

2 

Present: 

Rashaun Roberts, Designated Federal Official

Henry Anderson, Member

Josie Beach, Member

Bradley P. Clawson, Member

R. William Field, Member

David Kotelchuck, Member

James E. Lockey, Member

David B. Richardson, Member

Genevieve S. Roessler, Member

Phillip Schofield, Member

Loretta R. Valerio, Member

Paul L. Ziemer, Member

Registered and/or Public Comment Participants:

Adams, Nancy, NIOSH Contractor

Barrie, Terrie, ANWAG

Barton, Bob, SC&A

Buchanan, Ron, SC&A

Burgos, Zaida, NIOSH

Calhoun, Grady, DCAS

Cardarelli, John, DCAS

Fester, Joshua, On behalf of Petitioner

Fitzgerald, Joe, SC&A

Gogliotti, Rose, SC&A

Lewis, Greg, DOE

Naylor, Jenny, HHS OGC

Nelson, Charles, DCAS

Rutherford, Lavon, DCAS

Sisko, Jeannie

Taulbee, Tim, DCAS
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 

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 137th Meeting 

Wednesday, December 9, 2020 1

Welcome 4

Dr. Rashaun Roberts, DFO 4

SEC Petition Status Update 6

Mr. LaVon Rutherford, NIOSH 6

Board Work Session 66

Public Comment 114

Warren Johnson 114
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed 

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cautioned that this transcript is for information only and is subject to change. 

4 

Proceedings

(1:15 p.m.) 

Welcome

Dr. Rashaun Roberts, DFO

Dr. Roberts: So good afternoon and welcome, 

everyone. I'm Rashaun Roberts. I'm the Designated 

Federal Official for the Advisory Board on Radiation 

and Worker Health. 

Welcome -- okay. It sounds like someone's not on 

mute. I'm hearing some pages turn. If everyone 

could just please make sure that we're muted. 

Okay. No. I can still hear background noise. If 

everyone could please check their phones and make 

sure that we're muted so I can move forward.

Okay. So welcome to the second and final half of 

Board meeting 137. Like yesterday we need to over 

a few preliminaries. If you are just on the telephone 

line, all of the materials for today, the meeting 

agenda, presentations and other documents, are all 

posted on the NIOSH website for this program 

under Schedule of Meetings for December 2020. 

You can go there and read all the materials, and 

you can follow along with the presentations. 

Materials were provided to the Board Members and 

to other staff prior to this meeting.

If you look at the agenda on the website, at the top 

there is a Skype link which will enable you to watch 

the presentation through Skype. I want to advise 

you however that you'll be only able to speak to the 

group and to hear the presentations through the 

telephone line, so you should not hook into Skype 

audio.

In order to keep everything running smoothly and 
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 

5 

everyone speaking can be clearly understood 

without interruption, I ask each of you to please 

mute your phone, of course unless you're speaking. 

If you don't have a mute button, press *6 to mute. 

To take yourself off, press *6 again. And because 

we will be unable to see each other for the meeting, 

please identify yourself before your comments or 

questions. 

Let's address conflict of interest for this Board 

meeting session. As you may see from the agenda, 

the main focus of the discussion today is largely the 

Savannah River Site. None of the Board meetings --

members for the record are conflicted for this site, 

so none of them will need to be directed to 

disconnect from the meeting today.

So with that important piece of business squared 

away, let's go ahead and move into roll call now, 

and I will start with the Board Members in 

alphabetical order.

(Roll call.)

Dr. Roberts: Okay. Very good. So thank you and 

welcome everyone. Let's prepare to move further 

into the agenda. Again if you would just kind of on a 

regular basis check your phone and mute it. Again, 

if you don't have the mute button, use *6 to mute, 

*6 to un-mute.

So we're now ready for the SEC petition status 

update and overview of the SEC qualifications 

process presented by Mr. LaVon Rutherford.

LaVon, over to you. 
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6 

SEC Petition Status Update

Mr. LaVon Rutherford, NIOSH 

Mr. Rutherford: Okay. Thank you, Dr. Roberts. Can 

everybody hear me okay?

Member Beach: Yes. 

Mr. Rutherford: Okay. Good. All right. As Dr. 

Roberts mentioned, I'm going to do the SEC update, 

and I'm also going to do a presentation on the 

qualification process. I'll stop after the update and 

give a few moments for any questions during that, 

and then we'll proceed.

Okay. We do this update at every Advisory Board 

meeting, give the Advisory Board an indication of 

petitions and qualifications under evaluation 

currently with the Advisory Board and potential 

83.14s. It helps them prepare for future Work 

Group meetings and future Board meetings as well.

To date we've had 258 petitions. We have two 

petitions that are in the qualification process at this 

time. We have one evaluation of a new petition 

that's in progress, and we have 11 reports with the 

Advisory Board. 

The two petitions we have in Qualification 1 is the 

Rocky Flats petition. I think I spoke about this 

petition previously. We had previously determined 

that it did not qualify, and an administrative review 

was requested. That administrative review panel 

came back with a recommendation to provide 

additional information. We have provided that 

additional information. The slide says we did it in 

November. However, actually we did not do that 

until December. I believe she received it on 

December 3rd.
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reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

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7 

Another petition is the Pantex Plant is in 

qualification. We are just about to finalize that 

qualification determination. We expect to have that 

completed in the next week or so. That's for a 

period of January 1992 through December of 2000. 

Those of you will remember that we have an SEC 

class that goes up right up against that.

Petitions under evaluation. We have a Pinellas Plant 

petition for 1957 through 1990. This petition did 

qualify. A lot of you will remember that we have had 

a number of petitions for Pinellas Plant. However, 

we have not had the information provided to qualify 

the petitions. We also went through a detailed Site 

Profile Review with Pinellas. And this most recent --

I obviously have something pushing my slides 

forward -- but this most recent petition identified an 

issue that we are dealing with at Los Alamos and 

the Savannah River Site that ultimately qualified 

that petition and moved it forward. So that is 

something that we will definitely have in our 

evaluation.

Lawrence Livermore National Lab. This is an 

addendum that addresses the remaining years in 

the existing petition. Most of you will remember that 

this expected completion date has moved out a 

number of times. We have been trying to get on the 

site to complete a data capture to address one issue 

that we've been working on, however, due to the 

pandemic we've been unable to get on the site. So 

at this time we have a completion date of March of 

2021, but it may shift as well.

All right. Since it jumped right to Y-12, I'll go ahead 

and discuss that. This again is a petition that we 

have years remaining of 1987 to 1994. We did have 

a Y-12 update yesterday, and we are working this 

issue -- or the addendum. The one thing I wanted 

to point out when I prepared my presentation, I 
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8 

don't know where I came up with that February 

date at that time, but the -- based on responding to 

the petitioner's presentation at the last Work Group 

meeting and completing our interviews, that 

completion date is out till mid-next year. 

Okay. So petitions under Advisory Board review. We 

have the Hanford petition. Most of the SEC issues 

are closed out. We are working on starting the work 

on the co-exposure model. That will be the last 

major issue to address with that petition. I believe 

that happens sometime in -- later this month or 

January, if I remember correctly. 

Savannah River Site. That will follow after my 

presentation today. 

Los Alamos National Lab. Ms. Beach spoke to that 

yesterday, and we are working a couple of papers to 

provide to the Advisory Board Work Group. And I 

owe her a schedule update, which will -- I should 

have tomorrow.

Sandia National Lab. We just received SC&A's -- we 

had received a copy of this, but it was not 

releasable. We got SC&A's review of the NIOSH 

addendum, and we are working on responding to 

that.

INL. We got an update yesterday.

Argonne National Lab - West. Again, we're working 

to resolve issues raised by SC&A and the Work 

Group.

Area IV Santa Susana. We got an update yesterday.

Metals and Controls. As Ms. Beach indicated 

yesterday, we're working on providing some 

additional information to the Work Group and hope 

to have that in the next few weeks.
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9 

De Soto Avenue Facility. Again, this update occurred 

yesterday, so I'm not going to add much.

And then Reduction Pilot Plant. The Reduction Pilot 

Plant evaluation report was presented to the Board. 

The Board sent that to SC&A to review, and so we 

are waiting for SC&A's review on that.

So these are the time periods that we have 

openings in existing SEC petitions, Hanford, 

Savannah River Site, Los Alamos, Sandia, INL, 

Lawrence Livermore, Argonne National Lab - West, 

Area IV, Santa Susana, Metals and Controls, De 

Soto, and Reduction Pilot Plant. 

Potential 83.14s. We have the West Valley 

Demonstration Project. A lot of people remember 

that we actually added a class for that, however, we 

had data from a 1966 to '68 period that we were 

still evaluating. We are still in that evaluation 

process. We have a large number of documents that 

we'd received from a data capture, so we have not 

completed our determination on that. 

And that's it for the SEC update. Do I have 

questions from that?

Member Clawson: Yeah, LaVon, this is Brad. Go 

back to your Savannah River on that date. You've 

got 19 -- 

Mr. Rutherford: I've got 1973 --

(Simultaneous speaking.)

Member Clawson: Yes, I thought that it was '72.

Mr. Rutherford: I think it's probably the -- I will 

have to check that. 

Tim, can you weigh in on that? Am I wrong?
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10 

Dr. Taulbee: Yes. No. No, Brad is correct. It should 

be October of 1972.

Mr. Rutherford: Okay. Well, there you go. Good

catch, Brad. I will get that corrected and --

(Simultaneous speaking.)

Member Clawson: Well, I just -- it just kind of threw 

me off there for a minute there. I just -- it's just 

there, you know? That's -- I understand what's 

going on. Thanks.

Mr. Rutherford: Mm-hmm. Any other questions?

All right. If there's no other questions, I'll go into 

the SEC qualification process. 

All right. I'm going to talk about the SEC 

qualification process, and then I will talk about 

process improvements that have been made either 

through by petitioner input, Advisory Board Work 

Group recommendations, and also from admin panel 

reviews and findings and recommendations. Then 

I'll finish it up with some things that we're adding 

based on recent petitioner concerns and some 

admin review discussions.

A brief overview of the SEC petitioning process from 

the beginning to adding a class. 

The petition, you have petition submission that 

starts the process. When a petition is submitted, it 

will go through the qualification process. If the 

petition qualifies for evaluation, we will evaluate 

that petition. Then we submit that Evaluation Report 

to the Advisory Board. The Advisory Board will then 

review that Evaluation Report and provide a 

recommendation, and that recommendation along 

with the NIOSH Director's proposed decision is sent 

to the Secretary.
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11 

Now if we're recommending a class, the Secretary 

will go through the HHS designation to -- and then if 

we're designating a class, that recommendation 

from the Secretary then goes to Congress. 

However, if the determination that dose 

reconstruction is feasible and we're denying the 

class, it stops at the HHS Secretary.

Just for people listening on the phone that want to 

file a petition, we have information on filing a 

petition. Forms can be found on our website, and 

you can also contact our SEC petition counselor. 

There's his number and email address, Josh 

Kinman. 

Forms are optional. And I think some people don't 

know this, but -- forms are optional, but the forms 

do provide guidance as to what type of information 

will be used by NIOSH to qualify a petition. Believe 

it or not, we have had petitions -- we had a petition 

on a piece of paper that -- for Y-12 that was 

steamfitters, pipefitters, and plumbers cannot be 

reconstructed, and ultimately we qualified that 

petition and moved it forward.

Form A should be used -- somebody has -- needs to 

mute their phone there. I hear papers rolling.

Okay. 

Dr. Roberts: I can still hear the typing. Please mute.

Mr. Rutherford: Yeah. Okay. Sounds like we're good 

now.

So the forms are optional and provide guidance as 

to what type of information will be used to -- by 

NIOSH to qualify a petition. A Form A should be 

used if NIOSH has notified the claimant/petitioner 

that a dose reconstruction cannot be completed. 

Form A is associated with the 83.14 process. And 
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12 

when we notify a claimant or -- that a dose 

reconstruction cannot be completed, we provide 

that Form A for them to sign and send back to us.

Form B should be used if a petitioner believes a 

class should be added and are requesting NIOSH 

evaluate a class for addition to the SEC under the 

83.13 process. That's pretty much what we call a 

standard SEC petition.

Qualification process. Once a petition is submitted, 

it is reviewed to determine whether it meets the 

minimum requirements established in the SEC rule. 

In order to qualify for evaluation, the petition must 

include identifying and contact information for the 

petitioner and a proposed class definition. 

The class definition should specify a single DOE or 

AWE facility, locations at the facility that are 

included, job titles and/or job duties of the class 

members, and periods of employment relevant to 

the petition. We can always work with the petitioner 

on getting a proper class identified.

The key item that a petition needs to have is a 

description of the basis for believing records and 

information available are inadequate to estimate the 

radiation doses based on one of the following: a 

lack of monitoring; destruction, falsification, or loss 

of records; expert report; scientific or technical 

report; and exposure incident involving a high level 

of radiation dose. Any one of those five would 

qualify a petition to move forward. Documentation 

or statements in the form of an affidavit must be 

provided to support one, two, and five. I want to 

talk a little bit about each one of these. 

A lack of monitoring. If a petitioner provides an 

affidavit that says to the best of my knowledge 

there is no thorium monitoring data at X facility 
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13 

during this period, if we go in and we look and we 

say, you know what, there is no thorium monitoring 

data during that period, we'll qualify that petition 

and move it forward. However, if we have this 

affidavit and we go in and we find that we have 

monitoring data, then that affidavit is not supported 

by the evidence, and we will not qualify the petition. 

So an affidavit in and of itself is not necessarily 

going to qualify a petition to move forward. If the 

evidence supports what that affidavit says, then 

we'll move it forward. But if it's not supported, then 

it will not qualify. That goes for destruction, 

falsification, or loss of records as well as the 

exposure incident if an affidavit is used to support 

that.

An expert report is a report from a health physicist 

or other individual with expertise in dose 

reconstruction. This report specifies the basis for 

believing that documented limitations might prevent 

the completion of dose reconstructions. And we 

have had a number of petitions that have qualified 

on the expert report. They've used SC&A site profile 

review as those will identify issues that would 

support moving a petition forward.

Scientific or technical reports are published -- are 

issued by government agencies that identify 

dosimetry and related information that are 

unavailable.

Okay. And as I mentioned, exposure incident.

We work closely with the petitioner during the 

qualification process to develop relevant information 

explaining deficiencies in the petition and to aid in 

submitting any needed materials. You know, I want 

to talk a little bit more about this.

When we have -- the petition comes in, we review 
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14 

the petition, we review the basis provided by the 

petitioner, and we set up a consultation call to get 

clarifications and we identify issues we need 

clarified, things we need clarified, and we also 

identify deficiencies. For example, if a basis -- a 

good basis is not provided.

We also during that discussion we help work with 

the petitioner to identify which bases we feel they're 

-- what they've identified it would be -- would fit 

under. But I also want to point out that for every 

basis that is provided to us, we look at any one of 

these five things, these five bases to see if it 

supports. We don't say okay, if a petitioner says I'm 

going (f)(1), I'm going to do lack of monitoring, and 

we say okay, well, we're going to look at 

everything, we're going to go through destruction, 

falsification of records, expert report, and to see if it 

really would qualify under one of those. So I want it 

to be pointed out that we don't just go by what the 

petitioner says. We look at all of the different bases 

to try to qualify that.

Okay. I want to talk a little bit about some of -- to 

date we have 258 petitions that we've received. As I 

mentioned earlier, 103 have not qualified. Below are 

the reasons, the main reasons they did not qualify.

Again, you can see that the biggest reason that a 

petition does not qualify is because we have not got 

a qualifying basis that's supported by the evidence. 

You see we've had petitions that have been 

voluntarily withdrawn by the petitioner, and almost 

every one of those, in fact I believe every one of 

those, was early on after the rule was promulgated, 

and they were waiting on their dose reconstruction. 

And once they got their dose reconstruction they 

withdrew the petition.

Covers an already existing SEC class. We've had a 
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15 

number of individuals that have petitioned because 

they have a non-presumptive cancer that ultimately 

will not be compensated under the SEC, but they'll 

petition basically to add that cancer, which you 

cannot do. 

We've also had petitions for sites that are not 

covered under the program. And we had five 

petitions that were actually received prior to the 

rule being promulgated. And then the other nine 

reasons are just various reasons. I didn't want to 

list them all, but you can see the main number is 67 

from lack of qualifying basis. And that's about 25 

percent of the total number of petitions received, a 

little bit more than 25 percent.

If a petition qualifies for evaluation, as you know 

NIOSH reviews the petition as submitted and 

evaluates it according to the SEC rule. We send 

notices to the petitioner, the Advisory Board, and 

congressional staff. We don't always send it to 

congressional staff now. We did early on when the 

congressional staff were very active. We still send it 

to New Mexico staffers because they're very active. 

And, again, if we do have congressional staff with 

any inquiries or anything like that or if it's 

recommended that we send, do send those as well. 

We also -- notices are published in the Federal 

Register and published on the NIOSH website.

Okay. If a petition is not qualified for evaluation, the 

proposed decision not to qualify becomes the final 

decision in 31 calendar days. The petitioner can 

provide new information when it's in this 30-day 

period for consideration or a petitioner can request 

an administrative review of the proposed findings. A 

written review request to the NIOSH Director must 

be submitted within 30 calendar days -- boy, this is 

making it challenging -- of the notification that the 
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16 

petition did not qualify. A petitioner can also file a 

new petition for the same class thereafter with new 

information.

We have had petitions that have gone through the 

complete evaluation process, completed their 

evaluation for a given time period. We've 

recommended a class for a certain time period, 

denied a class for another time period, and then got 

new petitions because there's been new information 

that was not previously evaluated, and that new 

information moved the petition forward, qualified it 

and moved it forward.

So the NIOSH administrative review. The NIOSH 

Director appoints -- it says three HHS personnel --

three NIOSH personnel for the -- this is the 

qualification administrative review. The NIOSH 

Director appoints these three personnel who are not 

involved in developing the proposed finding. They 

have never been employed at a DOE site in question 

or by DOE Headquarters, and have never been 

employed at DCAS.

The Administrative Review Panel reviews the 

administrative record and the petitioner's request 

and has 30 work days to complete its review. The 

NIOSH Director then communicates its final decision 

to the petitioner.

NIOSH has found one of the hardest things to 

communicate to petitioners is why their petition 

does not qualify. And that's for many reasons, but 

one -- explaining a technical reason in terms that 

anyone -- that everyone can understand is not 

always easy. If they've identified an incident that --

or an accident that they feel does have the potential 

for high-radiation exposure however we've reviewed 

additional information and determine that there is 

no high-radiation exposure or that the accident may 
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17 

have occurred but it was monitored, then all of 

those things we have to communicate to the 

petitioner, and it can be very difficult. The difficulty 

in communicating these findings have been 

recognized in communications with petitioners, 

Advisory Board Work Group, and administrative 

review panels.

Early on in the process we identified that we've got 

to have some interactions with these petitioners, 

and so we established an SEC petition counselor. 

You may remember Laurie Ishak Breyer was the 

first one, and then Josh Kinman, who's doing that 

now, to communicate with the petitioners. 

We also -- NIOSH added an ombudsman to support 

petitioners and claimants involved in the dose 

reconstruction and the SEC process and early on 

based on communications from -- we increased 

communications between petitioner, SEC petition 

counselor, and NIOSH lead HP during the 

qualification process. 

Also in process improvements the Advisory Board 

established a Work Group to review petitions that 

did not qualify. That was chaired by Dr. Lockey and 

included Dr. Melius, Dr. Roessler, Brad Clawson, and 

Wanda Munn. The charge of this Work Group was to 

review disqualified Special Exposure Cohort 

petitions and the process followed by NIOSH and 

the rationale for petition disqualification. 

They completed their task on May 2nd of 2007, and 

their conclusion was that the final rule as reflected 

in the legislation was followed and NIOSH review of 

the petition was claimant-friendly. The Work Group 

provided several recommendations regarding 

making the process of submitting a Special 

Exposure Cohort petition more user-friendly. The 

key part of the recommendation focused on the 
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18 

communication with the petitioner.

Administrative review findings and 

recommendations that supported process 

improvements. The admin review panels reviewed 

27 petitions as requested. The panel has agreed 

with NIOSH's proposed decision not to qualify on 23 

of the 27. The four where they did not agree and 

recommended qualifying the petition were due to a 

lack of clear communication to the petitioner 

explaining the reason for the disqualification. 

Based on the admin review panel findings and 

recommendations we have tried to provide more 

information or proposed finding letters to make it 

easier for the petitioner to understand our decision 

not to qualify a petition. And I'll talk about that a 

little bit more.

Okay. Changes we're making based on recent 

petitioner concerns and admin review panel 

findings. I went back after -- this was brought up at 

the last Board meeting. I reviewed the -- some of 

the, you know, our initial communications. I also 

looked back at the Work Group findings that came 

out of Dr. Lockey's Work Group. And then I also --

we just kind of coincidentally had some discussions 

from the admin review panel that provided some 

communications discussions. And it's pretty clear 

that the biggest problem, as I mentioned earlier, 

was communicating our findings in an 

understanding way to the petitioners.

So what we've done is we've added non-technical 

reviewers to review the proposed finding notification 

to the petitioner, meaning that I wanted people that 

were non-HPs to look at this and say okay, can you 

make -- can you understand what we're saying 

here, because after the last Board public comment 

session previously it was clear that we were having 
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19 

issues with that still. And then we provided 

additional opportunities -- in the future we're going 

to provide additional opportunities to petitioner to 

receive verbal explanation on the proposed findings.

I think one of the things that we've kind of got away 

from that we're going to get back to is more 

interaction with our health physicist, SEC petition 

counselor, and the petitioner, more verbal 

interaction to help alleviate this issue. And as I'd 

mentioned previously, we're including a more robust 

explanation on the proposed finding and the 

notification letter to the petitioner.

And that's all I've got. Questions?

Member Clawson: Hey, LaVon, you were -- 

Mr. Rutherford: Yes.

Member Clawson: -- and I understand this is a 

difficult thing. This is Brad Clawson again. 

Mr. Rutherford: Yeah.

Member Clawson: When you say lack of data, I got 

a question for you. So you've got an SEC petition 

that ranges for 25 years, and they say that you 

have insufficient data -- who's typing? 

Anyway --

Mr. Rutherford: I know I dealt with that the whole 

time.

(Simultaneous speaking.)

Member Clawson: Anyway, somebody's got to mute 

something there.

Anyway, my question is is lack of data, because let's 

just take for instance, and I'm just going to throw 
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20 

one out there, americium. Okay. They say that they 

were not monitored for americium, and you go into 

that, and this covers 25 years, and you only have 

three years' worth of data. How do you -- 

Mr. Rutherford: Well, that was -- 

(Simultaneous speaking.)

Mr. Rutherford: Yes, and that's -- no, I mean, that -

- to me that's a good one because if I look at it --

first of all, if I got a petition, they're petitioning for a 

25-year period, and they say americium is my --

that I had a lack of exposure for americium, and I 

got three years of data, okay, then -- again this is -

- remember, Brad, this is qualification. This is not 

the evaluation. I mean, almost --

Member Clawson: Right, right.

Mr. Rutherford: -- automatically I would suspect 

that I -- if I determined that they were truly dealing 

with americium for 25 years, and I only have three 

years' worth of data, that petition will move forward 

most likely to -- into evaluation because I have a 

lack of monitoring data for 22 of those 25 years. 

But, again, I mean, that --

Member Clawson: Okay. I -- 

Mr. Rutherford: Go ahead.

Member Clawson: Well, I was just -- I was trying to 

understand that because we see this so many times 

in these petitions that come in and stuff. We've got 

a large period of time, and it's speckled, that we 

sometimes --

Mr. Rutherford: Yeah.

Member Clawson: -- have a --
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21 

(Simultaneous speaking.)

Mr. Rutherford: Remember though -- yeah, Brad, 

remember though when you're seeing them, those 

are petitions that have qualified and have moved 

forward for evaluation. And so that example you 

gave me was a perfect reason to move it forward 

for evaluation and get it in front of the Board.

Member Clawson: Okay. That's what I was 

wondering. 

The other thing, too, is, LaVon, if you remember 

right, Dr. Lockey and I's Work Group on that, that 

was to get kind of a backlog of SECs that have not 

qualified that were sitting out there and people had 

questions of. I don't think that we've looked at any 

of these later on, and we've brought this up before 

this. Do we need to take and go through and review 

these again or what? And if -- because I haven't 

looked at anything --

Mr. Rutherford: Well, I -- 

(Simultaneous speaking.)

Mr. Rutherford: Yes. I will tell you that if you look at 

the numbers of petitions that have not qualified 

prior to that Work Group meeting -- prior to that 

Work Group, it was roughly 25 percent of the 

petitions with a -- that -- as I mentioned earlier, 25 

percent, roughly 25 percent of petitions that did not 

provide a good supporting basis didn't qualify. That 

number didn't change before you guys looked at it 

and after you guys looked at it. 

So I think the biggest difference that you'll see now 

is the amount of documentation and detail that goes 

through in the review, but I just wanted to point 

that out.
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22 

Member Clawson: Well, and I understand that, and 

I'm not saying anything wrong about it, but I've 

heard it brought up several times in meetings where 

the people have said -- and we have a Work Group 

that looks at the ones that do not qualify, and we 

haven't looked at anything since that original time. 

That Work Group went through all of those that did 

not qualify, and then we hadn't met again. I'm just 

wondering if once every two or three years like that 

just to -- if we ought to be looking at those.

Member Lockey: Brad? I mean, LaVon? LaVon, Jim 

Lockey.

Mr. Rutherford: Yes.

Member Lockey: Can I ask who's on the NIOSH 

administrative review panel? Who are those people? 

I don't need their names. 

Mr. Rutherford: Well --

Member Lockey: I mean, what's the background?

Mr. Rutherford: Well, they are scientists and such. 

They're technical background people.

Member Lockey: Health physics background people? 

Mr. Rutherford: You know, I did not review their 

qualifications because I'm not allowed to be part of 

that process, but I believe that -- I just know that 

they're technical people. I don't know that detail.

Member Lockey: But they are technical? They're not 

laypeople?

Mr. Rutherford: Correct. Yes, they are technical 

people. And Jenny can correct me if I'm wrong, but 

Jenny is -- they are briefed on the process, they're 

briefed on the qualification process, they're briefed 
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23 

on what's expected and so on. 

And, Jenny, if you want to add anything to that?

Ms. Naylor: Sure. Happy to. So the SEC regulation 

specified that the Director of NIOSH could appoint 

three HHS personnel. And so that's not limited to 

just NIOSH personnel. It can include any scientist 

that has health physics or radiation or occupational 

health and safety background under the entire HHS 

universe. And in the past the HHS panel reviewers 

have been fairly high-ranking scientists within this 

research agency.

Member Kotelchuck: It's Dave Kotelchuck. But it is 

entirely within the purview of the Secretary to 

decide who is qualified. And I --

Ms. Naylor: No --

(Simultaneous speaking.)

Member Kotelchuck: -- suppose we could inform our 

superiors that -- in the administration that, oh, well, 

I wish you would do this or that, but that person 

has the authority and -- but it's good to hear that 

they're well-qualified people. I'm not surprised.

Member Lockey: One of -- Jim Lockey. One of the 

things I was thinking as to Brad's comment was that 

maybe at some point if it's possible, LaVon, to have 

one of those three people just run through their 

process with us on the Board so we feel comfortable 

with what's happening. Is that something that's 

doable or not?

Mr. Rutherford: I'm going to defer to Jenny.

Ms. Naylor: Sure. The administrative review process 

really is trying to create a secondary review to 

make sure that there's accountability over this 
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24 

qualification process. And so we have done our part 

in building a firewall between the NIOSH review of 

the qualifications, the Advisory Board's deliberation 

process, and also the administrative review process. 

And there are actually two administrative processes 

that are specified in the SEC regulation. One is at 

the junctions of the qualification stage, and the

other one is when the Secretary has final decisions 

about SEC petitions.

So I could send your request, and I assume it would 

be a request from the Board to have one of those 

scientists to come and speak about their process, 

but I'm trying to get a sense of what the Board --

what does the Board hope to come out of this? I 

think -- hearing you say the comfort level was one 

of them, but I'm trying to also -- is it something 

that I can do for you, basically? 

Member Lockey: Well -- Jim Lockey. What I was 

thinking was that if Brad, say, is -- wants the -- our 

committee to meet every two or three years to 

review the process, then we have two sets of people 

doing that. And that -- I'd rather just know what's 

being done currently. And if it appears that it makes 

me very comfortable, I'm fine with that. I'd like to 

drop it --

Ms. Naylor: Okay.

Member Lockey: -- and move ahead through those -

- that's what I'm thinking.

Ms. Naylor: Sure.

Member Clawson: Well, and, Jenny, this -- 

(Simultaneous speaking.)

Member Clawson: Jenny, this is Brad. The other 

thing that I would like to do as a Board Member is 
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25 

I'd like to better understand -- because what LaVon 

is doing -- I have the utmost respect for LaVon and 

everything else. I'm not questioning anything about 

that, but it -- so that as a Board Member I 

understand why these are not getting qualified a 

little bit better, because some of them are very 

complex and it -- we've dealt with several of these 

over the years that when we really got to the root of 

it like that, was quite complex and we -- it helped 

me be a better Board Member by understanding of 

why it did not qualify and things in the future that 

we need to be able to look for. 

Ms. Naylor: Okay. So there are a couple of issues 

here. One is that I'm happy to relay -- assuming 

this is the Board's request, to have one of those 

scientists who has served on the panel to come in 

and talk to the Board about their deliberation 

process. And just keep in mind that these don't 

always have the same panel members. There is a 

group of scientists who take this on as an additional 

duty, and it all depends on their availability. So this 

is point number one.

And number two, Brad, again I just want to make 

the point that the complex issues that you're seeing 

are those petitions that have already been qualified. 

And there's reason why that NIOSH are qualifying 

these petitions, because they're complex. And so --

and these are petitions that do not qualify for 

evaluation, what we're talking about today. So just 

want to keep those apart, right?

(Simultaneous speaking.)

Member Clawson: I understand that 100 percent, 

Jenny, and that isn't what I said. I said the ones 

that do not qualify. I have been through this review 

before. And I understand what Jim wants because 

he wants -- I just feel, as a Board Member and as 
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26 

an individual on this Work Group, I just -- I think it 

would be good for us as this Work Group to get 

together every once in a while and just run through 

some of those real quick with LaVon and get to the 

fine detail of it of why -- where it didn't qualify and 

everything else.

When we went through all of those cases and stuff, 

we went through them in like about a day-and-ahalf because a lot of it was just really up front and it 

was simple, but some of them got very complex. 

That's all I'm looking for. I'm not looking to talk 

with the Board beyond this or anything else like 

that, but I can understand why Lockey would want 

to. 

I just want to -- I'm just throwing out to Lockey and 

to LaVon that maybe once a year or something like 

that we could just run over the ones that didn't 

qualify and why they didn't qualify just so that the 

petitioners are seeing that the Board is reviewing 

this and is looking into why they didn't qualify and 

be able to give maybe some suggestions or to be 

able to help them qualify better. That's all I'm 

wanting.

Ms. Naylor: Okay. You want --

(Simultaneous speaking.)

Dr. Roberts: Hey, Jenny, this is -- if I could cut --

I'm sorry. If I can cut in at this point, I think what 

we're going to need to do is if we want to continue 

to discuss this, to come back if we have time at the 

end. I believe that we need to move into the 

Savannah River Site SEC Petition 103 agenda item.

Member Beach: Yes, can I just ask --

Dr. Roberts: So -- 
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27 

Member Beach: Rashaun, this is Josie. Can I just 

ask a really quick question?

Dr. Roberts: I'm just trying to be mindful of the 

petitioners who are on the phone. If it's very quick, 

go ahead, but I'm --

Member Beach: It is -- 

Dr. Roberts: -- going to need to cut in if it isn't.

Member Beach: And it's something I don't need an 

answer to now, but if Jenny could tell us if there is a 

charter document or statement that this group --

the scientists follow, that may be something we can 

review, or the Work Group can reestablish and 

review rather than having someone come and talk 

to the Board.

So anyway, we can pick this back up. Thank you.

Dr. Roberts: Okay. Thank you, Josie.

So as I mentioned, we are at the next agenda item. 

It's the Savannah River Site SEC Petition 103. And 

you will note that pretty much the remainder of 

today's session is devoted to that particular agenda 

item with a small break built in at roughly 3:15 

p.m., resuming the session at 3:30 p.m.

The agenda allows for presentations from the SRS 

Work Group, NIOSH, SC&A, and Petitioners will be 

welcome to present as well.

Mr. Brad Clawson is the chair of the SRS Work 

Group, and I will now hand it over to him to open it 

up.

Brad?

Member Clawson: Okay. Thank you. Now let me ask 

you a question. Is everybody else's screen black, 
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28 

because mine is?

Member Roessler: I can see your --

Member Clawson: I have -- you can see my slides?

Member Roessler: I can see them.

Member Ziemer: This is Paul. I can see your slides, 

Brad.

(Simultaneous speaking.)

Member Clawson: Okay. Because my computer just 

went dead. So I'm going to read it.

Bob, could I get you to do the slides for me?

Mr. Barton: Yeah, no problem, Brad.

Member Clawson: Okay. We'll start out with the first 

slide. Advisory Board on Radiation and Worker 

Health, Savannah River (SRS) Work Group 

recommendation for SEC Class consideration. Those 

on the SRS Work Group are James Lockey, Dave 

Richardson, and Phil Schofield, and myself, Brad 

Clawson, as the Work Group Chair.

Next. SRS site. SRS began operations in 1952, 

devoted to material production for nuclear weapons 

program. SRS processes included nuclear fuel 

fabrication, reactor operations, radiochemical 

processing, uranium recycling, plutonium and 

tritium production, neutron source production, and 

waste management.

Facilities. Thirty-plus, included production reactors, 

F and H processing canyons, Solid Waste Disposal 

Facility, F/H Area Tank Farms, Plutonium Form 

Facility and Plutonium Experimental Facility, 

receiving Basin for Offsite Fuel Facility, Uranium 

Target Fabrication Facility, Fuel Fabrication Facility, 
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29 

scrap recovery facility, and 773-A analytic 

laboratory.

Key radionuclides at Savannah River: plutonium, 

americium, uranium, neptunium, thorium, tritium, 

fission products.

RPRT-0092 analysis period was from 1972 through 

1998. Two operating contractors were there: 

DuPont from 1972 to 1989 and Westinghouse, 1989 

to 1998.

Next. SEC history for SRS. Petition 00101, qualified 

March 2008. NIOSH Evaluation Report, November 

14th, 2008; January 1st, 1950, through December 

31st, 2007. Addendum 1, May 4th, 2010; January 

1st, 1953, through December 31st, 1965. 

Addendum 2, January 1953 through December 31st, 

1972. 

The Advisory Board, on December 29th, 2011, 

recommended SEC Class for January 1st, 1953 

through September 30th, 1972, for all employees at 

SRS, due to lack of sufficient information necessary 

to complete individual dose reconstructions with 

sufficient accuracies for internal radionuclides 

exposure due to thorium in some areas of the 

facility during the time period in question.

Addendum 3, November 20th, 2012; October 1st, 

1972, through December 31st, 2007. Under review 

by the Work Group with focus on current reviews on 

subcontractors and job-specific bioassay data 

completeness and representativeness for 1972 to 

1998. 

Next. Subcontractors at SRS. Supplemented inhouse construction trades workers performing same 

work: electrical, carpentry, labors, sheet metal 

workers, welders, and so on. Relatively few in the 

1970s, but grew rapidly in the 1980s to the early 
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30 

'90s, as SRS mission expanded to include major 

waste management, environmental upgrades, D&D, 

and the reactor restart operations. Usually 

temporary and intermittent hires, subcontractor 

construction trade workers. Moved throughout SRS 

facilities. May have been assigned higher exposure 

radiological jobs, based on interviews with former 

workers, which were often performed under work 

permits.

Next slide. SEC Issue: subcontractor bioassay data 

completeness. In 2014, SC&A reported to the 

Advisory Board that the SRS subcontractor records 

had not been verified and validated, V&V, for 

completeness. NIOSH considered options for 

substantiating bioassay data completeness, 

including use of CPWR and NOCTS data.

In 2017, NIOSH performed a subcontractor 

construction trade worker bioassay data 

completeness review, based on job plans for 

Building 773-A for 1981 through 1986. This is RPRT0083. The Advisory Board tasked SC&A to perform 

similar sitewide reviews for 1972 through 1998. 

SC&A found completeness, based on indicators of 

subcontractor job-specific bioassays in the range of 

66 to 84 percent, depending on assumptions made. 

NIOSH determined a higher rate. More notable were 

contractor self-surveys showing only 21 percent 

completeness for job-specific bioassays in 1997, 

leading to DOE enforcement action at that time.

Work Group evaluation. NIOSH expanded scope of 

SRS subcontractor construction trade workers 

review with additional permit records from the 

Atlanta Federal Records Center. Evaluation issued in 

June 2019 as RPRT-0092, concluding that, for 1972 

to 1998, a large percentage of the subcontractor 

construction trades were monitored for potential 

intakes while working under a job plan, safe work 
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31 

permit, or a radiological work permit.

SC&A noted that a large percentage, 89 percent, is 

over all years, all permits, one radionuclide, but 

found conclusions based on a faulty premise and 

assumptions regarding what, when, and how 

bioassays matched.

In the context of permit-related, job-specific 

bioassays for at least 1972 through 1990, SC&A 

found: inability to link job-specific bioassays to 

permits; uncertain target radionuclides; lack of 

reliable sitewide facility characterization; only one 

SRS facility, 773-A, surveyed, with none from 1975 

to 1979; low completeness rates found for 

americium in 1981 through 1987 (e.g., 20 percent 

actually monitored; 33 percent total could be 

considered represented in a co-exposure model). 

The RPRT-0092 survey results for americium are

only for 1973 and 1981 through 1987.

Work Group discussion in the meetings of December 

6th, 2019, and November 17th, 2020. Did RPRT0092 accomplish its objective of demonstrating that 

the monitored subcontractor construction worker 

trades and unmonitored subcontractor construction 

worker trades worked side by side in the same 

radiological environment at the same time? Can 

completeness of job-specific bioassays for 

subcontractor construction trade workers be 

demonstrated? Not for at least 1972 to 1990.

Does the limited scope of review for 1972 through 

1990 (just 773-A) impair a sitewide conclusion 

regarding subcontractor construction trade worker 

job-specific bioassay completeness for those years? 

Yes.

Does limited subcontractor construction trade 

worker bioassay data for americium (only for 1973 
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32 

and 1981 through 1987), with 20 percent monitored 

and 33 percent represented in co-exposure model, 

satisfy IG-006 criteria? No, it does not.

Are there alternative methods of demonstrating 

completeness available? Or applying a co-exposure 

model for unmonitored subcontractor construction 

trade workers based on routine, incident, or NOCTS 

data? None that satisfy IG-006 co-exposure 

guidelines concerning representation.

Work Group conclusion. For 1972 through 1990, 

RPRT-0092 falls short of demonstrating 

subcontractor construction trade worker job-specific 

bioassay data completeness due to the lack of 

permit records to support evaluation and inability to 

relate bioassays to specific permits in the DuPont 

era.

For 1991 through 1998, subcontractor construction 

trade worker job-specific bioassay data 

completeness may be established, but with some 

qualifications that remain to be addressed regarding 

effectiveness of RWP bioassay compliance.

Alternative methods, including relying on routine 

monitoring and NOCTS data, are not sufficient to 

establish completeness and representativeness of 

subcontractor construction trade worker data, as 

required by IG-006 co-exposure model guidelines.

Work Group recommendation to the Board: that the 

Advisory Board consider an SEC Class for 

subcontractor employees at SRS from October 1st, 

1972, to December 31st, 1990.

Basis includes: 

Unmonitored subcontractor construction trade 

workers who should have been monitored under 

work permits and job plans for job-specific 
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33 

bioassays, but were not. 

Potential for elevated exposures over various site 

locations at intermittent times; subcontractor 

construction trade workers were often transient, 

performed high-exposure potential jobs under job 

plans and permits, and did not consistently provide 

termination bioassays.

Severely constrained scope of data: only 773-A 

facility. Limited data analysis demonstrates real 

issues for americium-241 across all years. Uncertain 

completeness for other radionuclides (plutonium 

and fission products): subcontractor construction 

trade worker job-specific bioassay evaluation in 

RPRT-0092 performed only for 773-A, none for 

1975 through 1979.

This is the recommendation that has come from the 

SRS Work Group to the Board that we wanted you 

to take under consideration. We still have NIOSH's 

and SC&A's presentation, but if there are any 

questions at this time, we're more than willing to 

listen to them.

Member Field: Thanks for the presentation. This is 

Bill Field. I was just wondering, was the Work 

Group's recommendation unanimous?

Member Clawson: Yes.

Member Field: For the record. Okay. Thanks.

Member Clawson: Anything else?

Dr. Roberts: Also, sorry, Brad, but I can still hear 

someone typing. If people could take a moment to 

mute phones, that would be very helpful.

Member Beach: Rashaun, I wonder if someone 

needs to mute their computer, as well; they think 
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34 

their phone's muted and maybe they have their 

volume on on the computer. This has been going on 

the whole meeting.

Dr. Roberts: Yes. So, take care to mute your 

computer as well.

Member Clawson: Rashaun, without any questions, 

I think that I would move on to SC&A's report. And 

I'll try to get my computer back working at this 

time. I apologize for this. It's just my luck.

Dr. Roberts: Okay. All right. So, yeah, let's go 

ahead. I believe, Joe, you're presenting on behalf of 

SC&A?

Mr. Fitzgerald: Yes, I certainly can. I wasn't sure 

what the order would be, so I will switch this to 

being next. And I would assume NIOSH will close 

out, then.

Dr. Roberts: Yes. My understanding was that NIOSH 

was coming next, but it sounds like Brad --

Mr. Fitzgerald: Well, that was my understanding, 

too, so that's why I'm a little confused.

Dr. Roberts: Okay. Well, maybe we should just go 

with the order of the agenda. Is NIOSH ready? Tim, 

are you ready to present?

Dr. Taulbee: I certainly can. I was ready to go 

either next or last. It didn't matter to me.

Dr. Roberts: Okay. Why don't you go ahead?

Dr. Taulbee: All right. Give me just a second here to 

pull up the presentation.

(Pause.)

Member Clawson: I'm sorry; I went to unmute my 
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35 

phone and hung up the phone. If NIOSH is going 

next, I'm sorry, Tim, go ahead. I didn't know what 

was going on with that.

Dr. Taulbee: Okay. I was open, like I said, to going 

either next or last. It didn't matter to me.

Member Clawson: That's fine. Go ahead and go 

next, Tim. That's fine. This whole computer thing 

kind of got me a little bit frazzled.

Dr. Taulbee: I understand. I certainly understand.

Okay. Well, thank you, Mr. Clawson. Our 

presentation is going to be on dose reconstruction 

feasibility for subcontractor construction trades 

workers at the Savannah River Site. I'm going to be 

giving the presentation. John Cardarelli is coming up 

to speed and will be taking over for Savannah River 

Site from me.

But, really, I wanted to thank the ORAU Team for all 

of the work they've been doing, and, specifically, 

Mike Mahathy, Nancy Chalmers, Roger Halsey, Matt 

Arno, Liz Brackett, and Don Morris. They've been 

working on this subcontractor construction trades 

worker monitoring issue now for about three years, 

and I'm going to be trying to summarize their work 

in less than an hour here. So, bear with me, and I 

hope I do their work justice here.

As an overview here, I'm going to start with some 

background, go over the Savannah River coexposure model, the Co-exposure Implementation 

Guide as it applies to completeness, briefly, very 

briefly, on radiological monitoring at SRS. And I'm 

going to focus the presentation on the three 

subcontractor evaluations that we've conducted. 

Okay. The first one is RPRT-92, and the second one 

is RPRT-94, which looks at just the NOCTS data. 

And then the final one is the plutonium bioassay 
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36 

logbooks, and wrap up with a summary and 

conclusion.

So, let's start with the SRS co-exposure models, 

okay? NIOSH develops co-exposure models because 

we recognize that some workers were not 

monitored that, in retrospect, perhaps should have 

been monitored. For a co-exposure model to be 

valid, a bounding or representative sample of the 

workers is needed. If all the exposed workers were 

monitored 100 percent for every radionuclide, there 

wouldn't be a need for a co-exposure model. This is 

why we have it. We know or we believe that there 

should have been more people monitored than 

were. So we're really looking for a bounding and 

representative sample here.

The internal dose models in the Savannah River coexposure model -- this is ORAU-OTIB-81 -- form the 

basis of why we believe dose reconstruction is 

feasible for unmonitored workers at the Savannah 

River Site. The internal dose co-exposure models 

were stratified a priori by operations workers, nonconstruction trades workers, and construction 

trades workers. This resulted in two separate coexposure models for each radionuclide. And the 

radionuclides that we developed models for were 

americium, tritium, plutonium, uranium, fission 

products, cobalt-60, cesium-137, neptunium, and 

thorium.

The construction trades workers strata was set up --

it combines two groups of construction trades 

workers. One of them is the DuPont construction 

trades workers, and these are select Role 2 

workers. Role 2 workers means they were assigned 

to operations, but they were construction trades 

crafts; electronics and instrumentation technicians, 

these were electricians; building maintenance, these 

would be more like millwrights. And then there 
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37 

would be other carpentry and so forth assigned. But 

these workers were assigned organizationally to 

operations and they did a lot of the kind of lowerlevel maintenance and so forth within the facilities.

All other construction trades workers, Role 4, 5, and 

6. So it was the combination of these that we put 

into our initial strata. 

Okay. The definition that we used in these 

evaluations is by payroll ID, not by employer, from 

this 1972 to 1989 time period. In this time period, 

the subcontractors in Role 4, 5, and 6 include the 

electricians. The subcontract was Miller-Dunn. The 

pipefitters were under a subcontract to B.F. Shaw. 

The insulators were under a contract to North 

Brothers.

Other groups, such as the boilermakers, were hired 

directly out of union halls by DuPont, okay, so there 

wasn't a set subcontract for them. But they would 

be hired by DuPont. They would work for a few 

months, maybe a year or two, and then be 

terminated, and then we would see them coming 

back after a period of another few years, or so 

forth. We treated those as subcontractors because 

they were added as Roles 4, 5, and 6. Okay. So, it's 

not by employer; it's more by payroll.

Dr. Roberts: Okay. Sorry, Tim. We clearly have 

someone off mute again. Zaida or Nancy, is there 

any way to --

Ms. Burgos: Yes, I'm going to call the information 

to cut it off.

Dr. Roberts: Okay. Thank you. Sorry, Tim.

Dr. Taulbee: No, that's all right.

Member Lockey: Rashaun, this is Jim. For some 
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38 

reason I got the presentation last time, but I'm not 

seeing it on my screen this time. So, I tried to reenter three times. It hasn't helped.

Dr. Roberts: Are you able to just bring it up --

Member Ziemer: This is Paul. I'm seeing it just fine. 

I'm seeing it just fine.

Member Beach: Yeah, this is Josie. I have it also.

Member Clawson: It's just you, Jim.

Dr. Roberts: Do you think you can pull it up, Jim, 

and follow along, you know, opening it up as an 

independent file?

Dr. Taulbee: Dr. Lockey, if you can do that, I will 

tell you when I'm advancing slides so that you could 

better keep up, if you can open it independently. Is 

that possible?

Dr. Roberts: Jim, are you there?

Member Lockey: Yes, I'm here. I'll find it. Go ahead.

Dr. Roberts: Okay.

Dr. Taulbee: Okay. I'm on the "Co-exposure 

Implementation Guide" title slide. And I believe this 

is slide 8 of 71. Okay? All right.

Member Lockey: Thank you.

Dr. Taulbee: Slide 9. So, the issue, as Mr. Clawson 

had pointed out, is the completeness of the 

subcontractor data for co-exposure. And this is a 

slide I presented during the December 2017 

Advisory Board meeting, where SC&A concluded 

that bioassay data for subcontractors, for 

construction trades workers subcontractors 

specifically, and CTWs generally, is demonstrably 
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39 

incomplete from 1989 to 1998, and likely before 

that time period, and does not satisfy the criteria 

set forth in the NIOSH Draft Criteria for the 

Evaluation and Use of Coworker Datasets. And I 

added emphasis here. Okay?

Now, we respectfully disagreed at that time, and we 

still do. We believe that 90 to 87 percent direct 

monitoring of subcontractors is not demonstrably 

incomplete. The NOCTS data indicated the 

subcontractors were monitored and indicated 91 

percent of the subcontractors who were claimants 

between '91 and '97 have some form of internal 

monitoring. What we've done over the past three 

years is we've expanded this evaluation beyond the 

1989 to 1998. We've added an RWP evaluation. And 

so we've expanded this.

Okay. Next slide, slide 10. So, the issue here is 

completeness. And since that time, last year, in fact 

-- or earlier this year was when it officially became 

approved -- is the Co-exposure Implementation 

Guide. And Section 2.2 covers data completeness.

And this is what it says: "Once the measurement 

techniques have been found to be technically 

acceptable, the amount of available monitoring data 

must be evaluated to determine if there are 

sufficient measurements to ensure that the data are 

either bounding or representative of the exposure 

potential for each job exposure category at the 

facility. This analysis should look not only at the 

amount of data that is available, but also consider 

any temporal trends in the data availability."

Next slide, slide 11. It goes on to say, "If the 

number of potentially exposed workers in each 

category is unknown, a useful starting point is to 

look at the distribution of samples among the 

various categories of workers represented in the 
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40 

claimant population at that site. Table 1 provides an 

example of this for the categories of workers who 

were monitored for plutonium at the Nevada Test 

Site."

And so I've reproduced here Table 1 -- this is slide 

12 -- out of the Co-exposure Implementation Guide. 

And what you see here is that they indicated that 

there was 290 plutonium samples over the time 

period of 1963 through 1992. 206 of them were 

from the rad safety group; very few from the 

laborers, the welders, the wiremen, the miners. 

Security had a significant fraction of 74, but they 

were only in the latter time period.

What I hope you'll see after my presentation today 

is that Savannah River looks nothing like this, okay, 

that we've got data that demonstrates that all of the 

different job categories are covered, and then we've 

got data that is indicating the workers were 

monitored in the other time periods.

And my slide just advanced on me automatically. 

Okay. All right.

So, now, before I move on into those three 

evaluations, I want to briefly touch on the 

radiological monitoring at SRS, because this is 

critical, okay? SRS used a defense-in-depth 

approach to radiation monitoring with the intention 

to prevent non-tritium intakes. They had a zero 

intake policy. They had engineered controls. These 

will be glove boxes, fume hoods, and cabinets, 

which is a much larger glove box, effectively. Those 

were the engineered controls. They had procedural 

controls of how much material you could work in 

fume hoods versus glove boxes. And when they 

broke into those particular engineered controls to do 

maintenance or to do something, they wore 

personal protective equipment. Okay?
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41 

There was surveillance to verify that these 

engineering, procedural, and personal protective 

equipment controls were effective. There was air 

monitoring. There was facility contamination 

surveys. There was personal contamination surveys. 

And there was routine and job-specific bioassays. 

Okay?

Moving on to slide 15. There's no practical 

difference between routine and job-specific 

bioassay. Both were used to verify the effectiveness 

of the procedural and engineering controls. Okay? 

When one of these bioassays came up positive, that 

was a trigger for a special bioassay; for-cause, 

effectively. And so that was when they would do 

follow-up. They would do more characterization to 

find out what the workers were exposed to. 

These bioassays were requested from workers who 

had a reasonable potential for intakes, but who SRS 

was pretty confident that the intakes did not have 

intakes in excess of 2 percent of the annual limit.

Westinghouse -- and this is in the 1990s -- further 

stated the workers themselves were the last line of 

defense in the workplace indicator program, which 

was the reason why a confirmatory program for 

workers was conducted.

Now, routine versus job-specific bioassay. Most 

workers, 95 percent, were on routine bioassay. This 

includes both subcontractors and operations 

workers. SC&A postulated that subcontractors were 

primarily on job-specific bioassay. And this is a 

quote from the November 2017 Work Group 

meeting: the question of how "complete is complete 

enough for coworker development can only be 

answered in the context of coworker guidelines and 

stratification assumptions that have been validated 

-- they guide what datasets can be legitimately 
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42 

applied. However, 79 percent incompleteness 

strains credulity."

SC&A is implying here that only 21 percent of the 

subcontractors were monitored. We will show in this 

presentation that the subcontractor monitoring was 

much greater than 21 percent.

Where did that 21 percent come from? And I 

showed this slide previously, in December 2017, at 

the Advisory Board meeting. And I'll walk through 

the limited assessment here, the 3200 bioassay 

requirements that were evaluated where they found 

the 33 percent compliance with job-specific 

bioassay.

And so the red numbers is what I'm going to go 

through here. The worker signs in on an RWP 

requiring bioassay. The worker participates in a 

routine bioassay sampling program for the 

radionuclide specified on the RWP. Ninety-five 

percent of them -- 

Dr. Roberts: Sorry.

Dr. Taulbee: Go ahead.

Dr. Roberts: Okay. I was hearing something in the 

background. I don't know if you could hear it, but it 

was disruptive. It sounds like someone muted. 

Thank you.

Dr. Taulbee: Okay. So, 95 percent of the workers 

participated in the routine sampling. Five percent 

participated in the job-specific bioassay. And you 

see here, no, they did not participate in routine. It 

was required on the RWP. And so it goes over here 

to the job-specific bioassay. Sample was required.

When you follow down through to the red, 67 

percent noncompliance here resulted in 107 
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43 

samples out of 3,092 samples. Okay? So, from a coexposure modeling standpoint, we don't feel that 

these job-specific bioassays are that critical to the 

overall co-exposure model.

Now, SC&A pointed out that's a limited assessment. 

The full assessment found that that compliance rate 

dropped to 21 percent, and that's where I got the 

numbers here in blue. Okay? This is the 33 percent 

there in the center. I don't know if you can see my 

pointer or not. But that's where the 21 percent 

comes from.

We know from that evaluation, that full assessment, 

that a total of 256 samples were not received under 

the job-specific bioassay. When you back through 

the calculations, going backwards, that results in 

that there would be 324 job-specific bioassays. And 

that would be 324 out of 6,481 total bioassays. So, 

again, the job-specific is a very small component of 

this program at this time, and most of the workers 

are under the routine monitoring program.

Savannah River did a hundred percent follow-up 

with those 265. In other words, they didn't get 

those samples initially, they went back and 

requested samples from all 256, and no worker had 

any intake during that time period. Okay.

So, are subcontractor construction trades workers 

bounded or sufficiently represented in the coexposure model? SC&A is saying, no, they are not. 

The basis for saying subcontractors are not bounded 

or sufficiently represented is not clear to us at 

NIOSH. Okay? I can kind of see it, maybe, with just 

looking at RPRT-92, but there's more information 

out there and more that we have developed, more 

information that we feel is important here.

We feel that the subcontractors are bounded and 
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44

sufficiently represented based on the analysis of the 

work permits and bioassays, the quantity of 

monitoring data available in NOCTS, and a review of 

the plutonium bioassay logbooks.

Okay. Now I'm going on to, this will be slide 20. And 

I'm going to start talking about those three 

evaluations. And this one is RPRT-92, the Evaluation 

of Bioassay Data for Subcontractor Construction 

Trades Workers at SRS. The goal of this report was 

to determine the percentage of subcontractor 

construction trades workers monitored by year --

that temporal effect that I showed you earlier in the 

Implementation Guide -- to determine whether 

unmonitored subcontractor construction trades 

workers were represented by a monitored 

subcontractor in the same radiological environment 

at the same time, and determine whether the 

subcontractor CTWs were monitored for the 

radionuclides of concern, given the radiological 

environment on the RWP.

So, to do this, we developed an RWP sampling plan. 

We randomly selected subcontractor radiation 

workers from various areas at the Savannah River 

Site so that an evaluation of monitored and 

unmonitored workers could be conducted. The first 

step was to define the sampling frame. We focused 

on actinide exposures: plutonium, uranium, 

americium, and neptunium. We excluded standing 

radiation work permits. These are more routine 

work, and subcontractors likely would not be a large 

number of the workers identified on those standing 

radiation work permits. They are identified 

sometimes, but, usually, it's the non-standing 

radiation work permits.

We specifically excluded Reactor Areas C, K, L, P, 

and R from our sampling. Okay? And the reason 

that we did this was primarily due to low-dose 
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45 

tritium. Previous discussions with the Work Group 

and the Board where we looked at subcontractors 

versus the subcontractor CTWs, versus DuPont 

CTWs, we found that, since 1973, 95 percent of the 

subcontractor tritium doses have been less than the 

95th percentile -- sorry -- have been less than 100 

millirem, with a downward trend. Since 1980, the 

DuPont CTWs' 95th percentile tritium dose has been

less than 100 millirem, again, with a downward 

trend.

Our conclusion was tritium monitoring for 

subcontractors is not a dose reconstruction issue. 

And this is primarily because below 100 millirem, in 

modern times, that's the threshold for even 

requiring monitoring. Okay? So, it's a combination 

of all internal and external, of course, but the 

tritium, it takes a lot of tritium intake in order to 

receive a significant dose. So we never even looked 

at tritium, which is part of why, when we got the 

initial draft SEC Class proposal a week ago from 

Tuesday, when all internal radionuclides were 

included, we were quite surprised, because tritium 

has not even been really discussed or evaluated 

within the Work Group. Okay?

Now, for RPRT-92, one of our assumptions was that 

respirator use is a reasonable conservative 

surrogate for the need for internal monitoring. 

However, we recognize that not all respirator use 

requires bioassay. We had to come up with some 

way from these RWPs to try and figure out; did this 

person need internal monitoring, yes or no? And so 

we said, if they used a respirator or that was 

indicated on the RWP, then, yes, we would look for 

internal monitoring.

Please keep in mind that in health physics some use 

of respirator protection is precautionary, okay, in 

case something happens or if contamination is 
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46 

unexpectedly encountered. All right? If there's no 

contamination, then there's no potential for an 

intake and bioassay is not necessary. The RWP 

evaluation that was conducted did not consider this 

effect. We simply looked at, respirator, do they 

have bioassay.

And here's an example of respirator use that I 

presented in August 2017 where bioassay is not 

needed. And I'll read this particular radiation 

survey: "Survey for construction pipefitters to 

complete job started yesterday. Off-gas exhaust line 

was bagged up and cut into two sections. No 

problems were encountered during job. 

Construction and occupational health physics wore 

two pair of white coveralls, cloth and plastic shoe 

covers, cloth hoods, rubber gloves, and full-face 

respirator for the job. No transferrable 

contamination was detected during the job. 

Impactor air sample taken during the job calculated 

less than .2 times 10 to the minus-12 microcuries 

per cc. Job was completed at this point."

So there's no transferable contamination, and the 

air concentration was less than .2 times 10 to the 

minus-12 microcuries per cc. Bioassay really would 

not be required here. But, in our evaluation, if we've 

got four construction pipefitters working on this job, 

we went and looked, do they have bioassay? If two 

of them did and two of them did not, then that 

would be 50 percent. Okay?

Now, if you go through the radiation surveys, you're 

going to find more of these type of evaluations 

where that air sample is not less than 10 percent. In 

fact, it could be 2 to 3 DAC. And so there are times 

when airborne contamination was expected and was 

found and there was transferrable contamination. 

Okay? So, you're going to find both of them in 

there. When we did our evaluation, it was simply 
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47 

from that RWP, if they wore a respirator, yes or no, 

did they have a bioassay?

Okay. So, now I'm going to briefly go through the 

Westinghouse era of 1990 to 1998. And this is 

where we looked at the plutonium. I'm just going to 

show the plutonium monitoring here by year for this 

particular time period. And how do you read this 

table that I'm showing here? And I'm going to go 

through the very top line of the year 1991.

And I'm sorry; I've not been keeping up here, Dr. 

Lockey. It's slide 27.

For 1991, we looked at 17 RWPs. And from those 17 

RWPs, there were 82 construction trades workers 

that will be wearing respirators. We went through 

and looked at bioassay monitoring, and we found 78 

of the 82 had plutonium bioassay. So that's 95 

percent with bioassay. There were four workers that 

did not have bioassay. Okay? Three of them we 

matched directly onto an RWP with one of these 

monitored workers. So the effective monitored 

between subcontractors with monitoring and those 

we could directly match was 99 percent in this 

particular case. You can see the range here. It's 

from 83 percent to 100 percent. Okay? So, this is 

from plutonium by year, 1991 through 1998. 

We also looked at area in this time period, 1990 

through 1998. We looked at A, F, H, E, and Z Areas. 

Okay? F and H are the two primary plutonium 

areas. That's where plutonium was separated. 

These are the canyon buildings and the B lines. And 

also you've got the PUFF facilities, as well as PEF 

facilities that Mr. Clawson had mentioned in his 

presentation. So, they're actually in F area here. 

Okay? Scrap recovery is in H area. Okay? So, these 

are the main areas, and what we see is consistent 

monitoring across each of the areas from the 
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48 

workers' standpoint. The subcontractors were 

monitored.

We also looked by craft. And here's where, if you 

think of that chart that I showed earlier with the 

Nevada Test Site workers where whole crafts were 

missing, we don't see that here. We see reasonable 

monitoring across all of the crafts that were 

evaluated on this RWPs. And here you can see there 

would be 12 RWPs that identified boilermakers: 27 

boilermakers. Twenty-four of the 27 were 

monitored. Okay?

And so we looked at not just plutonium, but multiple 

radionuclides: plutonium, strontium, uranium, 

americium, neptunium. And we see the percent with 

bioassay. This is where that total 88 percent comes 

from. When you add all of these up, subcontractors 

monitored for the bioassay required, you get 88 

percent. We could match 114 to these. So we've got 

like 95 percent here in this time period.

Now let's look at the late DuPont era, 1980 to 1989. 

And this is where we began to run into some 

difficulties, because only job plans and special work 

permits for A Area were available for our evaluation. 

Job plans were the primary source of the 

information. Job plans from other areas we believe 

might have been destroyed, based upon interviews 

with workers and discussion of records personnel.

But it's important to note that job plans are not 

considered a permanent record. Okay? So, to use or 

to base all conclusions upon the availability of job 

plans is really not reasonable because we are not 

going to find these type of plans, necessarily, at all 

the facilities across the complex, because they 

weren't necessarily permanent records to be 

retained. The bioassay, the whole-body counting, 

the dosimetry, those are permanent records that we 
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49 

use for dose reconstruction.

The other point here is that special work permits 

were being phased out after 1972, which is part of 

why we don't have them. They switched to using a 

checklist type of methodology before they reinstituted the radiation work permits in the 1990s.

During this time period, instead of doing a random 

sampling, we did a census. And that means that we 

evaluated all job plans that had subcontractor 

CTWs. And now, you know, SC&A has indicated we 

only had one area in this particular evaluation. We 

evaluated 5,000 job plan pages. That's what we 

reviewed.

Dr. Roberts: Okay. I'm hearing a lot of background 

noise. If we can mute phones and computers, if 

you're on Skype.

Sorry, Tim.

Dr. Taulbee: Okay. So, of the 5,000 job plan pages, 

1,200 involved construction trades workers. A 

thousand of those were DuPont construction trades 

workers, the Role 2 workers. These would be those 

electricians under the E&I, electronics and 

instrumentation, technician; the building 

maintenance mechanics; the millwrights, so forth. 

Those were the DuPont construction trades workers.

But we did find 163 pages that involved 

subcontractor CTWs. So, approximately three 

percent of the total off-normal work was conducted 

by subcontractor CTWs. However, 14 percent of the 

construction work was conducted by these 

subcontractor construction trades workers. In total, 

there were 591 subcontractor construction trades 

worker monitoring evaluations that we conducted in 

the 1980 to 1989 time period. Okay? This identified 

219 unique subcontractors on 145 job plans.
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50 

Now, from 1990 to 1998, when we did the random 

sampling, we sampled 146 radiation work permits 

and identified 429 unique subcontractors. Okay? So, 

this is less subcontractors, roughly about the same 

number of RWPs, but only for one area. But we did 

the same evaluation. We looked at radionuclides by 

year and by craft. But, again, this was one area, 

and we did not have any data from 1989.

Okay. So, here it is the plutonium monitoring data 

by year. And what you'll see here is that there's 

about a 10 percent drop in the total monitoring of

subcontractors with bioassay. Before, this was 88 

percent, and now it's down to about 80 percent. 

Okay? But the effective monitoring stayed relatively 

stable. We were pairing more of these unmonitored 

subcontractors with the monitored subcontractors 

on a per-year basis.

We looked across crafts again. And again, we're 

seeing all of the crafts being represented here 

within the monitoring. And we looked at 

radionuclides: plutonium, strontium, americium. The 

results for plutonium and strontium-90 are slightly 

lower, about 10 percent less than the 1990-to-1998 

time period. The percent monitored results for 

americium are lower at 34 percent.

What it's important to look at here: the 

subcontractors matched to a coworker with 

bioassay. Okay? It's much higher from a percentage 

standpoint, making the effective monitored there 

around 76 percent. So, while we only have 34 

percent with monitoring, we are able to match 63 of 

these workers who were not monitored to these 52. 

These would be on the same radiation work permit.

Okay. Now, one of the things that has not been 

greatly discussed, but I really want to point it out to 

the Board here, is that the subcontractor evaluation 
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51 

in this time period, from 1985 to 1989 -- or I'm 

sorry, 1980 to 1989 was for one area. However, we 

have additional incident report data from F and H 

Areas. These would be the two primary plutonium 

separation areas.

Is this data limited? Yes, but it does represent the 

upper bound of the exposure potential. Because 

here is the situation, if you think of that defense-indepth approach, where something went wrong, 

okay, where something happened with those 

controls, either a PPE control or an engineer control 

or a procedural control. Something went wrong and 

there was some incident that occurred.

And so our question was, is there evidence the 

subcontractors were monitored following an incident 

and upset type of condition? Because if we don't see 

subcontractors in this group, we've got a problem 

with the co-exposure model, because that means 

the people had a potential for an intake where they 

got contamination on them, where there was an 

incident recorded, and if they don't have bioassay, 

that means the high-end data is missing from the 

co-exposure model. And that is a very serious 

situation. Okay?

So, we looked at these. This is data that we don't 

feel should be discarded so easily. And what we 

found is that a higher percentage of the incident 

monitoring data in the subcontractors were 

monitored. Of these incidents, there were 44 

plutonium bioassay required, and 41 of the 44 

showed plutonium monitoring data, or 93 percent. 

So there was good follow-up of these subcontractors 

that were involved in these incidents, these workers 

with a high exposure potential, because something 

went wrong and an incident happened. Okay?

The numbers are slightly less for strontium and 
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52 

fission products, but, again, these are low numbers 

here -- or a low sample size. Let me put it that way. 

Okay?

So, based upon this, there's clear indications for not 

just one area, but three areas of sufficient 

monitoring of subcontractors, CTWs, during the 

1985 to 1989 time period, for plutonium and 

strontium mixed fission products. The combined 

evaluation shows no significant difference by year, 

craft, or area. Again, we're only looking at A, F, and 

H Areas. But the F and H Areas, we know those are 

the upper bound here of that potential exposure. 

So, remember, in co-exposure modeling, it's 

representative or bounding. Okay? There's less 

monitoring in the modern era, but, still, a majority 

of the workers are monitored for plutonium and 

strontium. But there is a lower percentage for 

americium, 34 percent, but we are matching more 

of the unmonitored to those workers. So it's not 

that those workers were not monitored. And with 

the americium, the combination of the two 

represents 77 percent of the population.

Now let's talk about the last era, the mid-DuPont 

era. Again, only job plans and SWPs from A Area 

were available. Instead of sampling, we did a 

census. There's no data that we could find from 

1975 to 1979 to conduct the evaluation. There were 

some job plans available from 1975 to 1979, but 

none indicated subcontractor construction trades 

work. Evaluation was limited to 1972 to 1974, three 

years in this era.

Again, there was approximately three percent of all 

the work, off-normal work, involved subcontractors, 

and approximately 14 percent of the construction 

trades work was conducted by subcontractors. And 

here you can see that the numbers are dramatically 

decreased when compared to the 1980s and 1990s. 
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53 

We're only at 136 subcontractor evaluations could 

be conducted, 31 unique subcontractors on 59 job 

plans. And what you can see is they use the same 

subcontractors on multiple job plans here. The same 

evaluation method as the previous two intervals. 

They didn't do it quite by year and craft, but, again, 

this was limited.

1972 to 1974, what we see is a marked decrease in 

plutonium by year. In 1972, there's a reasonable 

percentage, a majority, of 77 percent. In 1973, a 

rather low percentage of 28 percent. And in 1974, 

there was only four job plans, involving seven 

workers -- that we could evaluate.

Okay. Next slide. This will be slide 45. 1972 to 

1974, the plutonium monitoring by craft. Again, we 

don't see any crafts that are really being excluded 

here. We were limited on the job plans. There's only 

a few crafts, I guess five here, that were identified 

on those job plans.

And what we see in the totals, looking at plutonium, 

strontium, and americium, the results for plutonium 

and strontium are both lower than in the 1980s and 

'90s. However, the percentage is really dominated 

by 1972, so I'm not sure you can draw a big 

conclusion based upon this. There was only one 

data point for americium.

Again, this evaluation was limited and dominated by 

the 1972 data. There was a marked decrease in 

plutonium monitoring in '73 and '74. Less than a 

majority of the subcontractor construction trades 

workers were monitored for plutonium in those two 

years. Strontium monitoring was better, and there's 

only one data point for americium.

So, a summary of the RPRT-92 from our standpoint 

is that, 1990 to 1998, the evaluation across time, 
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54 

area, and craft indicated subcontractor construction 

trades workers were monitored 88 percent of the 

time. And we believe this 88 percent would be 

sufficiently representative for use in a co-exposure 

model for the 12 percent that would not be 

monitored, roughly.

1980 to 1989, evaluation across time and craft in 

one area indicated that subcontractor construction 

trades were monitored 74 percent of the time. And 

we believe that this 74 percent would be sufficiently 

representative for the 26 percent that would not be 

monitored, primarily because the evaluation of the 

incident data in two other areas indicated that the 

subcontractors with the highest exposure potential 

are represented in the co-exposure model. That 

would effectively bias the model slightly high.

1972 to '79, there's limited data to the first three 

years for one area. It indicates CTWs are 

represented, and we're not seeing that they're being 

excluded, but they are certainly depressed from the 

other two areas.

Now let's look at RPRT-94. The SRS and SEC Issues 

Work Group discussions since 2017 have focused on 

the RWP job plan -- that's RPRT-92 -- and the coexposure models, with a major emphasis on the coexposure models, to try and obtain Advisory Board 

approval of that Implementation Guide 6.

Simultaneously, we have done another analysis, and 

this is the NOCTS data analysis in ORAU RPRT-94. 

This has not been discussed at the SRS or SEC 

Issues Work Group meetings. When the proposal for 

a Class came forward to the Advisory Board, we 

requested that Work Group Members consider this 

report before recommending a Class be added to 

the SEC. And I'd like to reemphasize that. I would 

encourage all the Board Members to please review 
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55 

and read RPRT-94.

In this report, NIOSH evaluated subcontractor 

monitoring using only NOCTS data. And this would 

be as of August of 2018. When we cut off the 

analysis, there were 6,097 total SRS claimants; 886 

were subcontractor construction trades workers.

Off to the right is the distribution of the pie chart of 

the subcontractor construction trades workers. It's 

26 percent electricians, 22 percent were pipefitters, 

9 percent were laborers, 7 percent were carpenters, 

6 percent were ironworkers. We're seeing all the 

construction trades represented here, is my point.

The NIOSH evaluation, we evaluated external 

monitoring and internal monitoring. Internal 

monitoring was broken into tritium bioassay, nontritium bioassay, which is primarily the actinides, 

and whole-body count. This would be fission 

products.

I want to focus on the externally monitored 

subcontractor construction trades workers 

discussion within this report. And the reason I want

to do that is the difference between new 

construction and the renovation, remodeling, and 

D&D, because the renovation, remodeling, and D&D 

activities is where the high risk of exposure is. New 

construction, there really isn't much -- depending 

upon where it is, there really isn't much potential 

for an internal exposure. And so those workers 

doing new construction in a clean area weren't 

externally monitored.

But to do the renovation, remodeling, and D&D 

within a facility, those workers were externally 

monitored. So the numbers I'm going to be 

presenting to you here are the externally monitored. 

But we recognize not all externally monitored work 
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56 

required internal monitoring. If you think of the 

RPRT-92 evaluation, I gave the example of 

respirators, did it require internal monitoring? Most 

of them likely did, but not necessarily all of them.

We had the same situation here. Not all externallymonitored work requires internal monitoring. One of 

the facilities Mr. Clawson mentioned was the 

Receiving Basin for Offsite Fuel. There you would be 

required to be externally monitored, but there really 

isn't a potential for internally monitoring, as the 

source term is spent nuclear fuel that is the spent 

fuel pool that is under water. And so the potential 

for exposure is primarily external radiation.

When we did our analysis, though, we only looked 

at, externally monitored, do they have internal 

monitoring, period, nothing further. One of the 

benefits of this analysis is it's not limited to a 

specific area. It covers all areas and all facilities. It 

also represents the data used in dose 

reconstruction. Okay? This is the actual claimant 

data. This is what we get to do dose reconstruction.

So, we used a simplistic internal analysis. Why did 

we do that? Well, radionuclide-specific internal 

monitoring depends on where the workers 

conducted their work. SRS is a very large site. 

Subcontractors in reactor areas likely didn't need 

plutonium monitoring, but may have needed tritium 

monitoring or fission products, depending on where 

they were working. If they were working on the top 

of the reactors, it's primarily tritium monitoring that 

they needed. If they were working with the heat 

exchangers or some of the resin beds, it might be 

fission products in addition to tritium. 

Subcontractors in plutonium areas likely didn't need 

tritium monitoring. Subcontractors at tritium areas 

likely didn't need plutonium or fission product 

monitoring.
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57 

The fundamental question, again, is, are 

subcontractors sufficiently represented or bounded 

in co-exposure models? And we feel you can do this 

evaluation without necessarily going to RWPs, okay?

Now, let me back up here. The radionuclide-specific, 

the RWPs and job plans help this because that gives 

you the location of where the worker is, and so then 

you can make more of these determinations. But 

can you look at whether workers are sufficiently 

represented or bounded in co-exposure models 

without this? And we believe you can.

This is an example of Attachment B from RPRT-94. 

And I'm just going to go through the top line here, 

and then go through a vertical column of 1984 so 

that you can understand the next slide. But I really 

encourage, again, please, to the Board Members, to 

review RPRT-94 in its entirety.

So, the top one is an electrician who started in 

1980. So, 1979, there's no data because he didn't 

work there in that time period. 1980, there is nontritium bioassay. That's what that "N" stands for. 

1981, he has external monitoring and tritium 

bioassay. That's the "E" and the "T". 1982, he has 

non-tritium bioassay. 1983, he did not work onsite. 

Actually, this could be a "she". I'm sorry, I'm using 

pronouns wrong here. 1984, they did work onsite, 

but they had no external or internal monitoring. 

1985, '86, and '87, they did not work on the site. 

1988, there's external monitoring with a whole body 

count.

So, in the next slide, I'm going to be showing 

percentages of workers with non-tritium urine 

bioassay and/or whole body count. Okay? We're 

basically, just excluding the tritium internal 

monitoring here. 
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58 

If you look at 1984, what we're caveating this is the 

need for external monitoring. So, if you go down the 

vertical column here 1984, you'll see two red 

blocks, for the second and third electrician there, 

where we've just got an "E". That means they were 

externally monitored. The "nei" for the other 

workers are they worked onsite where they're not 

externally monitored or internally monitored. 

There's an ironworker that did not work onsite that 

year. The two laborers at the end are externally 

monitored and monitored in urine bioassay, both of 

them.

When we go through and calculate these 

percentages, if it was just these nine people -- and 

it's not; there's 886 total workers; it varies by year 

as to how many workers we've got in a year -- this 

would indicate a monitored percentage of 50 

percent. Four workers with external monitoring, two 

have internal monitoring and two do not. So, it's 

just that simple of an analysis.

So, here's the NOCTS claimant data. And I want to 

focus on the green bars here, because that's the 

NOCTS data over this whole time period from 1972 

through 1997 -- 1998 -- I guess '97 for this dataset. 

Okay.

Now, what you see, I'm going to start from the far 

right of this particular graph in the 1990s. And what 

you see here is that, of the claimants that we have, 

roughly -- well, 1991, over 90 percent of the 

claimants had some internal monitoring. A higher 

percentage in 1992. It drops back down to around, 

let's see, like 75 percent -- or I'm sorry, the 

internal, it drops down to around 75 percent in like

the 1997 time period. Okay?

Now, you go into the mid period, mid-DuPont -- or 

not mid-DuPont, late DuPont era of 1980-to-1989 
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59 

timeframe, and you'll see that the subcontractor 

population in NOCTS is greater than 50 percent, but 

they're between 50-60. It does go up to around 75 

percent in the late 1980s. But you see it's fairly 

consistent. And when Westinghouse took over you 

do see an increase in the subcontractor monitoring. 

Okay?

In the 1970s, it starts out above 50 percent -- these 

are, again, the green bars -- but then drops down to 

where, between '73 and '79, only around 10 

percent, 5 to 10 percent, of the subcontractor 

claimants in NOCTS have internal monitoring data. 

Okay.

So, now, if you compare that to the RWP plutonium 

analysis, which I've plotted here in the blue solid 

lines, you see that these are quite similar. Okay? 

Now, between 1989 and 1990, we had no RWP data 

to do an evaluation. That's why that's blank. In 

1991 forward, that's all areas that we were able to 

do that sampling with. It's a very nice, robust 

analysis.

From the 1980 to 1989 time period, we only had the 

data from one area, A Area. Okay? The green bars 

are representing all areas. The A Area data is there 

in the blue. And the same goes for the 1970s. The 

blue is just one area; the green is all areas. Okay.

So, a summary of the RPRT-94. It's very similar to 

the RPRT-92. 1990 to 1998, a high percentage of 

subcontractors, greater than 75 percent for all 

years, are in NOCTS, were monitored. And, again, 

we feel they would be sufficiently representative of 

the co-exposure model.

1980, a moderate percentage, greater than 50 

percent of the subcontractors in NOCTS were 

monitored. And, again, we feel this would be a 
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60 

sufficient representation of the co-exposure model.

1972 to 1979, initially, a moderate percentage of 

subcontractors were monitored for internal 

exposure. However, there's a marked decrease in 

the late 1970s, followed by a surge of monitoring 

starting in 1980. Again, a similar pattern was 

observed in the limited RWP evaluation of just 

looking at one area in the 1980s, but all areas in the 

1990s. Okay. So we've got two different datasets 

showing us the same thing.

The final group of data that we looked at was the 

plutonium bioassay logbooks. NIOSH reviewed the 

available SRS plutonium bioassay logbooks in order 

to determine a more complete picture of bioassay 

monitoring practices for subcontractors. We found 

11,316 plutonium bioassay samples from 

subcontractor construction trades workers between 

1972 and 1990. This is distributed amongst 7,028 

individual subcontractors.

Samples were submitted from at least 23 different 

areas at the site. Again, the main plutonium areas 

are F and H area, and A Area was the research and 

development. So, how are these samples distributed 

amongst the site? This graph shows that. The two 

main bars there that you see are F and H area. 

Where plutonium was separated is where 

subcontractors were monitored onsite. They 

comprised the vast majority of the plutonium 

bioassay.

The third largest bar there is Central Shops. There's 

no plutonium in Central Shops. However, Central 

Shops is where subcontractors and construction 

trades workers in general were dispatched to other 

areas, such as F and H, to go and conduct their 

work.
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61 

Okay. This is where that routine monitoring comes 

into play. There are workers out of Central Shops 

who are subcontractors, but were routinely 

monitored, sent to other areas.

The C area here is the fourth highest. This is a C, 

reactor area. However, many people onsite 

considered C area and Central Shops to be the 

same area. It wasn't really distinguished very 

clearly. And so, a lot of those C area samples I 

believe should be Central Shops. So, that Central 

Shops is likely a little greater. C area would be more 

commensurate with the L and K reactor areas over 

here in total number and size.

Now the limited evaluation that we did showing the 

workers worked side-by-side one another was just 

in A Area, which represents a moderately small 

number of the plutonium bioassays there on the 

site. Okay? But you can see the bulk of the samples 

were coming from other areas. All right?

So, when we looked at this same data over time, 

that temporal evaluation that the Implementation 

Guide tells us we should be doing, we see the same 

decrease in plutonium monitoring from 1972 

through the 1970s, followed by a significant 

increase in plutonium monitoring in the 1980s. 

Okay?

So now, we believe that subcontractors were 

sufficiently monitored in areas outside of 773-A 

between 1972 and 1990, and we feel these other 

graphs, the evaluation demonstrates this. We saw a 

similar pattern of internal monitoring between the 

RWP analysis, the NOCTS data analysis, and now, 

the plutonium bioassay logbook analysis. And that 

pattern is a decrease in plutonium monitoring in the 

1970s, followed by a surge 10 times the plutonium 

monitoring from the 1978-to-1980 timeframe. It 
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62 

jumped from 56 samples total to 500.

So, summary and conclusion. There's three sources 

and evaluation of the subcontractor bioassay data 

that have been done: the RWP job plan analysis, 

which is kind of the Cadillac of the evaluations; the 

RPRT-92 analysis, but there's also the NOCTS 

claimant data. This is RPRT-94, and this is a pretty 

important component here that I feel is being 

overlooked and would encourage you all to please 

read that report. And the plutonium bioassay 

logbooks is the third one. All three evaluations are 

showing similar results, at least for plutonium here.

So, we use a weight-of-evidence approach. In 1990 

to 1997, we feel there's robust monitoring of 

subcontractor construction trades workers. The RWP 

analysis evaluated the temporal effects for multiple 

areas in the crafts. And the NOCTS data showed a 

high percentage, greater than 75 percent, of 

subcontractors were monitored.

And 1980 to 1989 shows acceptable monitoring of 

subcontractor construction trades. The job plan, 

yes, is limited to A Area, but we were able to look at 

the time periods. We were able to look at crafts. We 

didn't see any gaps or see any issues associated 

with that.

We also know that the co-exposure model would be 

bounded based upon the incident data from F and H 

area. These are those off-set conditions, and did 

they do follow-up bioassay? Yes, they did.

The NOCTS data and the plutonium bioassay 

analysis show a moderate percentage of more than 

50 percent of the subcontractors being monitored. 

In this time period, there's over 10,000 bioassays of 

subcontractors, or approximately 10,000 

subcontractor construction trades worker plutonium 
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63 

bioassays in this time period. So, to say that they're 

not representative in the co-exposure model just 

concerns us to come to that conclusion.

1972 to 1979 is a limited evaluation, and it's a 

monitoring of subcontractors. The RWP analysis was 

very limited. The NOCTS data is showing that 

there's limited monitoring. The plutonium analysis is 

showing limited monitoring. There's only 1200 

bioassays in that time period, plutonium bioassay, 

but it's 1200 plutonium bioassays amongst 

subcontractor construction trades workers. So, 

these are not your routine DuPont workers. These 

are people hired in under the transients. Okay?

Our evaluation method we feel is conservative. 

Okay? Did all subcontractor construction trades jobs 

requiring respirators need bioassay? Did all 

subcontractors monitored for external need 

bioassay? Subcontractor work in this timeframe 

constituted approximately 14 percent of the total 

construction work. The majority of the construction 

work was done by DuPont CTWs. This is why we feel 

the DuPont CTW workers are likely bounding for the 

subcontractor construction trades.

Now we looked at a sub stratification, and this was 

presented to the Work Group a couple of weeks 

ago. And in the graph off to the right you'll see the 

bar charts of the DuPont CTW plutonium urine 

graphs in the subcontractor CTWs. It's important to 

point out here that over 95 percent of the plutonium 

bioassay data is below the reportable level of .1 

dpm. If you think back to that radiological 

monitoring of the defense-in-depth approach, the 

whole purpose of the routine and the job-specific 

bioassay was confirmatory. Okay? That was the 

rule, was nobody gets an intake. Ninety-five percent 

of the bioassay here is non-reportable, non-indepth.
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64 

The bioassay data from the DuPont CTWs appear to 

be slightly greater than the subcontractors, but

really not significant here. When co-exposure 

models are developed based upon this data, the Pu 

intakes for the two populations are quite similar. 

And we presented this particular slide as well. And 

in both cases, both intake regimes are in intervals. 

In the 1970s and the 1980s, the DuPont CTW 50th 

percentile was greater than the subcontractor 

CTWs. However, the 95th percentile was greater in 

the earlier time period for the DuPont CTWs than it 

was in the latter years that that the subcontractors 

were hired. 

But, as Dr. Ziemer pointed out during the Work 

Group meeting, 279 dpm per day is nearly 300; 325 

dpm per day is nearly 300. And so, within internal 

dose monitoring, those numbers are quite similar, 

which is why we feel that the DuPont CTWs are 

likely bounding.

But, based upon the NOCTS data analysis, there are 

six years where the percentage of internal 

monitoring via non-tritium and whole body county is 

less than 50 percent. All the other years, it is 

greater than 50 percent.

To bias a co-exposure model, the exposures to the 

unmonitored subcontractor construction trades 

would have to be significantly higher than the 

monitored subcontractor construction trades. Again, 

we're not talking about now comparing DuPont's 

versus subcontractor construction trades. I am just 

comparing subcontractors to subcontractors here --

okay -- to where, if we were to develop a 

subcontractor construction trades worker coexposure model. Okay? In order for that not to be 

valid, those unmonitored would have to be much 

greater.
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65 

Considering the radiation protection program at 

Savannah River, the zero intake policy, the defensein-depth approach to radiological protection, 

coupled with the health physics coverage of the 

construction jobs, we just don't believe that that's 

plausible, when for most years the monitored 

subcontractors outnumber the number of 

unmonitored subcontractors.

I mean, if you think back to even the americium 

example where 34 percent were monitored, we 

were able to match a very large fraction to workers 

who were on the same RWP as those monitored 

workers. Okay? So, it's not like they're just hiring 

other people, sending them into extreme 

radiological environments and not monitoring. 

Okay? We've got a lot of monitoring data amongst 

subcontractors here.

In this review, we feel we've demonstrated that 

unmonitored workers worked alongside the 

monitored workers in the same radiological 

environment, especially in the 1980-to-1998 time 

period. The bioassay data within individual records 

can be used for dose reconstruction for most 

subcontractor construction trades workers. Most of 

these workers don't even need a co-exposure 

model. We have got their own monitoring data. We 

can do the dose reconstruction based upon it.

These internal monitoring records can also be used 

to develop co-exposure models and subsequently 

used for dose reconstruction to either supplement 

gaps in individual monitoring or to estimate doses 

to unmonitored workers. We do not see any 

evidence where subcontractor construction trades 

workers were not monitored to a degree that would 

bias the co-exposure models.

And again, you've got to look at the entire weight of 
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66 

evidence here. Based upon that weight of evidence 

of these three evaluations, we believe the coexposure models are bounding and representative 

of exposures that would be received by an 

unmonitored subcontractor construction trades 

worker at Savannah River. Therefore, we conclude 

that dose reconstruction is feasible.

With that, I'll be happy to answer any questions. 

Thank you.

Dr. Roberts: Okay. Thank you, Tim.

Actually, can we go ahead and take a break, and 

then, come back to the session with questions at 

3:30? Would anyone object to that?

Member Clawson: That would be great.

Dr. Roberts: Okay. Okay, great. So, hearing no 

objections, let's meet back at 3:30. Thank you.

(Whereupon, the above-entitled matter went off the 

record at 3:19 p.m. and resumed at 3:30 p.m.)

Board Work Session

Dr. Roberts: Okay. So, by my clock, I have 3:30.

I just wanted to remind everybody once again just 

to be mindful of whether or not your phone or 

computer is on mute. As you are hearing, 

complicated information is being presented and 

there are differences between NIOSH and the Work 

Group. So, it's really important that everybody be 

able to hear everything that's being presented and 

discussed. And so, if you could, again, just be very 

mindful of keeping yourself on mute if you are not 

speaking, it would be much appreciated.

And I have a couple of other notes for you. So, I did 
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67 

get a note from Andy that he will have to leave the 

call at about 3:50, but will be back by about 4:30 

p.m. 

Also, I should say that, because I have some 

previous commitments, we do need to wrap up this 

meeting by 5:30 p.m. Eastern.

So, with that, let me go ahead and open the session 

first with a roll call again.

So is Anderson here?

(No audible response.)

Okay. Beach?

Member Beach: I'm here.

Dr. Roberts: Clawson?

Member Clawson: Here.

Dr. Roberts: Field?

Member Field: Here.

Dr. Roberts: Kotelchuck?

Member Kotelchuck: Here.

Dr. Roberts: Lockey?

Member Lockey: Here.

Dr. Roberts: Richardson? Richardson?

(No audible response.)

Roessler?

Member Roessler: Here.

Dr. Roberts: Schofield?
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68 

Member Schofield: Here.

Dr. Roberts: Valerio?

Member Valerio: I'm here.

Dr. Roberts: Ziemer?

Member Ziemer: Here.

Dr. Roberts: Okay. Has Anderson joined us yet?

(No audible response.)

Okay. How about Richardson?

(No audible response.)

Okay. Well, even though that's the case, I think we 

can go ahead and proceed with the session.

So, NIOSH or DCAS just finished their presentation 

on SRS, and we are open for questions.

And, Tim, are you back on the line? I guess I should 

ask that first.

Dr. Taulbee: Yes, I am. I'm here.

Dr. Roberts: Okay, great.

So, any comments or questions from the Board?

Member Clawson: Well, this is Brad. I've got an 

awful lot of questions, but I think that we need to 

let SC&A finish this up, especially with our time 

restraints, and then, we're just going to have to 

take questions at the end of this.

Dr. Roberts: Okay.

Member Lockey: This is Jim Lockey. I've got a 

couple of questions I'd like to ask, I think. I actually 
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69 

would prefer to ask questions after each, if that's 

okay.

Member Clawson: Whatever, Jim. But if you want to 

open it up, I'll start asking, too.

Member Lockey: Okay. So, do you want me to go 

first, Brad?

Member Clawson: Go ahead.

Member Lockey: Or do you want to go?

Member Clawson: Go ahead.

Member Lockey: So, our Work Group, as Brad 

shared, has been struggling with this Savannah 

River for a number of years. It's a very complex 

issue and very involved, and it has implications 

going forward for other areas we're looking at. So, I 

think that it's important that we understand what 

the playing field here is.

I've gone through this data extensively a number of 

different times, and every time I go through it, 

sometimes I get more confused; sometimes I get 

more enlightened.

But, while I've got Tim on the line here, I'd like to 

ask him some questions. And one is, one of your 

slides talked about defense-in-depth and I went 

through that and it seemed like a reasonable 

approach in regard to how DuPont was planning to 

handle their program. The question is, was it done 

that way and is it reliable?

So, one of the things they talk about, or you talked 

about, was equal to or less than 2 percent ALI, 

correct? Or am I missing that?

Dr. Taulbee: Yes. This would be the Annual Dose 
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70 

Limit.

Member Lockey: Right. So, their goal was to have 

less than 2 percent, is that right?

Dr. Taulbee: Yes, their goal was to not have any 

intake in excess of 2 percent of the Annual Limit of 

5 rem, which would be 100 millirem.

Member Lockey: Okay. And you might have told us 

in the past, or maybe this data is available -- and 

I'm sorry, I'm getting a phone call. I'm afraid, if I 

press a button, I'll press the wrong button here.

But, anyway, if you look at the data, the bioassay 

data, how does that fall out? I mean, how many 

were greater than 2 percent?

Dr. Taulbee: Okay. I'm trying to figure out how to 

answer this.

Member Lockey: Oh, I understand --

Dr. Taulbee: I mean, the majority of the bioassay 

are non-detects. Okay?

Member Lockey: Right.

Dr. Taulbee: So, if you look at all of those that are 

positive, then you can calculate a dose and actually 

do an assessment here. Now I don't have what the 

total number of bioassays for all the time period is 

for Savannah River. We could come up with that. 

We can certainly tally and come up with that.

We do have a listing of those that had intakes at the 

site as a whole and what those doses are. If that 

would help, I can certainly show you that data.

Member Lockey: Tim, I'm trying to figure out -- in 

paper, they had a good program. I want to know, in 

fact, if it was a good program. And this Savannah 
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71 

River has a lot of bioassay data, a lot, right?

Dr. Taulbee: Yes.

Member Lockey: And there's various statistical 

packages I could apply to that bioassay data and 

tell you how rigorous this is and how representative 

it is. But one of the first things I would look at, if 

their goal was to have people less than 2 percent 

ALI, then did they achieve that goal? And the 

second thing I would look at is, okay, the ones that 

had a greater than 2 percent, how many were 

above 100 percent of the ALI?

Dr. Taulbee: Okay. Now that's something I could --

Member Lockey: Am I missing something or not 

with that?

Dr. Taulbee: No. No, that's something that I could 

possibly show you here. Give me just a second 

here. I believe I can pull that up.

Member Clawson: Jim, this is Brad. Jim, this is 

Brad. You need to speak up a little bit.

Dr. Roberts: Yes.

Member Clawson: We're having a hard time hearing 

you. Okay?

Dr. Roberts: Yes.

Member Lockey: I'm sorry. Is this better? Is it me 

you're having a hard time or Tim?

Member Clawson: It's Tim.

Member Lockey: Yes, I'm having a hard time. He's 

breaking up.

Dr. Taulbee: Okay. Let me switch to a headset here. 
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72 

Hold on just a second.

Okay. Is this better?

Member Lockey: It's better.

Dr. Taulbee: Hello?

Dr. Roberts: Yes.

Dr. Taulbee: Okay. Okay. All right.

And so, one of the things that I could try and show 

you here is a graphic. You asked what percentage; 

did they achieve that particular goal? And they 

didn't really kind of compare along that line. Okay? 

But what I can show you is those that had intakes, 

and particularly something like plutonium, those 

workers that had a plutonium intake and how that 

dose is distributed here.

So, give me just a second here to get this graphic 

up and I will show that to you.

Member Lockey: The question is, will I be able to 

see it?

Dr. Taulbee: I'm hoping. Oh, so you're not seeing 

my slides right now?

Member Lockey: Well, I'm going to try to do it 

again. I tried to do it now four times to get back in. 

I get into the waiting room where I'm put with 

everybody, but I don't get the -- I got the 

projections this morning, but not now. I don't know

why. So, I'm with everybody else. I see, you know, 

Zaida and Nancy, but I don't see any of your 

presentations. I don't know why.

Dr. Taulbee: Oh, great. Okay. Okay. Well, then, I 

can describe it to you, or at least I hope I can.
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73 

All right. I've got it ready, I think. Let's see here. 

Okay.

And can everybody see this particular slide right 

now?

There's 868 plutonium intakes at SRS over all time. 

Okay? Or at least up to 2005.

Do people see this particular graph?

Member Lockey: I got it. I see it.

Member Ziemer: Yes, I see it. Ziemer.

Dr. Taulbee: Okay. All right.

So, the less than 2 percent would be less than 100 

millirem, effectively, there. Okay, so .1 rem. And 

this is committed effective dose equivalent. Okay? 

So, it's not exactly what we consider annual, but 

bear with me here that it's CEDE.

So, between 100 millirem and, then, 5 rem, 5 rem 

would be your Annual Limit. Okay? So, if you go up 

here and you draw a straight line across, you can 

see that it looks like the majority of the doses are 

between -- of the people that would have positive 

bioassay, which is a small fraction, of those people 

that would have positive bioassay, the majority of 

the doses are between the 2 percent and the Annual 

Limit.

While I was doing that, I did look up -- there are 

868 here plutonium intakes shown, and 86 of that 

868 are greater than 5 rem CEDE. So, 10 percent 

would be greater than what that Annual Limit would 

be.

Mr. Rutherford: Tim, I think I've got something that 

might be able to help Dr. Lockey, too. It is you've 
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74 

said that the majority of the number of bioassay 

samples were non-detects.

Dr. Taulbee: Right.

Mr. Rutherford: So, you've indicated that there's 

868 plutonium intakes that were positive from the 

very earliest days when they started monitoring up 

through 2007. How many non-detects do we have 

in comparison to that 868 positives?

Dr. Taulbee: Tens of thousands. I mean, we know 

from the 1980s that just subcontractors, there's 

10,000 bioassay. So, you know, of just the 

subcontractors, not the routine operations type of 

folks. So, there are thousands and thousands of 

samples here from plutonium. We can come up with 

a total. If you wanted to get those percentages, we 

can certainly do that.

Member Lockey: As a physician that does clinical 

population studies, if you showed me a figure that 1 

percent is above 100 percent, or .5 percent, the 

number is very, very low, that reinforces to me to a 

certain extent that that defense-in-depth program 

that they had in place would be a relatively vigorous 

program.

Dr. Taulbee: Okay.

Member Lockey: But that data is very important just 

to look at the basic question, is there a 

demonstrated health risk in this population based 

on the available data? After I went through this for 

the umpteenth time, I came back to that question: 

is there a demonstrated health risk based on this 

huge database that you have available?

Dr. Taulbee: Okay. I mean, we can certainly pull 

that together. I mean, that is data that we can do 

and show the total number of samples in a given 
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75 

year and the percentage that are positive here, and 

what those consequences are, what those doses 

are. We can do that.

My impression is -- or not just my impression -- our 

analysis so far has shown the vast majority are nondetects. Especially when you look at the coexposure models that we've got in OTIB-81, those 

are showing what the percentage of non-detect is, 

and it's really high. Okay.

Member Lockey: Okay. And I'm going to follow up 

with one question, and then, I'll give it to Brad, 

because I know he'll have questions.

The second question I have, then, is about the 

incident data. And I need to ask one basic question 

about incident data before I go into what I'm 

looking for. In regards to the incident data, last time 

we met as a subcommittee, I asked about the 

incident data and how it was used. And apparently, 

it's not being used in the dose reconstruction 

because of chelation issues. Is that correct?

Dr. Taulbee: It depends upon on the level of the 

incident. Because if it was a severe incident, then 

they would be chelated and, yes, we would exclude 

them. However, if it was not a severe incident and 

they didn't do chelation, we absolutely would 

continue to include them.

And looking at some of the upper end of the coexposure model data, clearly, there were some that 

were incidents that are included in that, in that 

particular co-exposure model. So, it's a mix.

Member Lockey: So, the incident data that you 

would not include -- and say I had an incident and I 

needed to be chelated. Okay? The chelation is based 

on what? On what data that somebody gets 

chelated or not?
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76 

Dr. Taulbee: It was a decision that was made by the 

physician and the health physicist at the time as to 

whether somebody would be chelated.

Member Lockey: Is it made just on the 

environmental exposure data or is it made on a 

preliminary bioassay sample?

Dr. Taulbee: It could be on both. If the intake was 

severely high, the air samples were severely high, 

they may not wait and go ahead and start chelation. 

In other cases, they would wait until they got a first 

bioassay before they would do chelation. So, it's a 

mix. There was no set criteria from the chelation. It 

was up to the medical, the physician at the site and 

in conjunction -- I mean that physician is who made 

the decision whether to chelate or not, but he did it 

in conjunction with the health physics department 

to make that decision.

Member Lockey: Okay. The reason I'm trying to go 

down this pathway is I'm trying to say, okay, how 

rigorous is this database? How representative is 

your database, your exposure database? And does it 

encompass the subcontractors or does it not?

And one of the ways I would approach that would 

be I'm going to look at the incidence data for prime 

contractors and for subcontractors, and I'm going to 

look at the initial bioassay data that's available after 

the incident, and to see if there's any difference, to 

determine whether, did, indeed, the subcontractors 

-- were they put in job tasks that were potentially 

more hazardous because the prime subcontractors, 

for whatever reason, did not get involved with those 

activities?

Dr. Taulbee: Okay. Where we have examples -- go 

ahead. I'm sorry.

Member Lockey: I'm looking for a reason in the data 
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77 

to say that your database is not representative of 

the subcontractors, not because there's missing 

data, because you have a lot of data. But is there 

anything out there that we can use to say, yes, 

here's an example where subcontractors had very 

much higher pre-chelation urine bioassay data in 

comparison to the prime contractors?

Dr. Taulbee: Okay. I think we can go back and look 

at those incidents in F and H area, that there would 

be sufficient data for us to look at that. I'm recalling 

John Cardarelli did a presentation showing an 

incident and the follow-up associated with that had 

subcontractors, a mixture of operations folks and 

subcontractors in that particular incident. And so, 

now what you're looking at is kind of a compilation 

of that data.

Member Lockey: I'm looking at subcontractors must 

have had incidents that occurred that required a 

needed bioassay and possible chelation. And I'm 

sure prime contractors had the same type of 

phenomena that occurred to that. Is there any 

difference in the urine bioassay results after the 

incidents in these two groups? Or are they similar?

Dr. Taulbee: I believe they are similar, but that's 

something that we can look at and do that type of 

comparison.

But keep in mind that these incidents and these 

intakes are fairly rare. So, it really would somewhat 

depend upon the severity of the actual individual 

incident as to which way that's going to be driven. 

But I understand what you're talking about here, 

and we can certainly look at, I believe, in particular, 

the F and H area incidents that I talked about there, 

and show you or get you some of that data. I 

believe that is possible.
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78 

Mr. Cardarelli: Tim, this is John. This is John 

Cardarelli.

Dr. Taulbee: Yes?

Mr. Cardarelli: I was wondering if we could take one 

minute here, and Liz Brackett does a ton of our 

analyses for us on this internal. She might have 

some good insight for us. Would it be okay if she 

were to give a one-minute summary?

Dr. Taulbee: Sure.

Member Clawson: One minute? We've already been 

here an hour and --

Dr. Taulbee: Liz, can you give --

Member Clawson: You know, no, I want everybody 

to remember something of why we're here on this. 

It's because we've got something brought up before 

the Board right now: has RPRT-0092 completed 

what it was supposed to do? And the Work Group 

has already said no. And we're proceeding on.

This is an entire data dump. I want you guys to 

remember about Fernald. We had thousands and 

thousands and hundreds of thousands of urinalysis 

and stuff like that. But did it do what we needed it 

to do to do a dose for a coworker model? It did not.

Now this one of the reasons why I wanted a limited 

presentation and stuff, is because we start to lose 

focus of what the real issue is here. Now we've been 

dealing with just this section of it for three years --

three years -- and it hasn't been done.

I can start right now and start going on for about an 

hour and a half of what Tim has been saying, not 

that it's wrong, but there's a little discrepancy in 

some of the things. I've always said this. Savannah 
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79 

River is different. We keep talking about 

construction trades workers and sub construction 

trades workers.

Tim says that we can separate them out by their 

badges and by their ID. Well, I want you to know a 

few years ago they tried that and everything else. 

We came back. They couldn't do that.

All the work that was done at Savannah River, they 

had their operations people, and then, DuPont and 

everybody else had their construction work trades 

that did their work. Then, we had subcontractor 

construction trades workers who could bounce back 

and forth without any problems, which we've 

already talked to, that were brought for high-rad 

jobs. They were burned out and went back on the 

road and went from there.

I want to everybody to remember why we are here. 

I think, right now, I've got a lot more questions that 

I want to be able to go into, but I think that we 

need to be able to give SC&A their opportunity, and 

then, let's discuss this path forward.

Dr. Roberts: Okay. All right. Let me just ask, 

though, Brad, before we pivot to SC&A, and just ask 

if anyone else on the Board had any questions for 

Tim, and then, we can move on to the SC&A 

presentation.

(No audible response.)

Okay. Well, hearing none, at this time, Joe, did you 

want to get things going?

Mr. Fitzgerald: Yes. Okay. And I realize half the 

Board probably has seen a lot of these slides in the 

Work Group. We had a joint Work Group meeting 

two weeks ago. So, I will go through some of these 

quicker than others.
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80 

First off, I'm going to try to simplify what the issues 

are, basically, what Brad just said. You know, 

there's a lot of data that could be thrown out there. 

Savannah River is a huge site, a lot of years, 

thousands of bioassay data points. And once you 

get weighed into the routine, the incidents, the 

NOCTS, you can do endless sorts. And certainly Tim 

has done a good job, and we've seen quite a few of 

them today. But I'm going to focus exactly, very 

clearly, on what the issue has been.

Next slide, please.

This has a three-year history, and I think you're 

familiar with a lot of this. The '92 review that came 

out in 2019, to which we commented, this was 

based on a request by this Board back in 2017 to 

expand the review from what it was, which was a 

specific review on 773-A for, I think it was five or 

six years in the early '80s, to one that would 

encompass the entire site.

The concern there was that any answer on 

completeness would be proscribed by the limited 

facility coverage and the years involved. So, that's 

why the expanded review was done.

There's somebody talking on there, not on mute.

Dr. Roberts: Somebody's talking.

Mr. Fitzgerald: Okay. Next one, please.

I'm on "Background: Job-Specific Bioassays".

Okay. I want to really focus the Board on what this 

specific issue is. Okay? You know, there's just a lot 

of dust being kicked up about a lot of different 

forms of bioassay, whether it's routine, special 

incident, you name it, NOCTS. But what we're 

focused on is a particular type of bioassay, job-
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81

specific bioassays. And I wanted to take a few 

minutes to really define what we're talking about 

because that is the currency that we're dealing with.

And it gets very confusing when NIOSH starts 

talking about the sorts that they're doing and some 

of the quotes they're making about something other 

than job-specific bioassays. That's the context of 

our concern. That was the context that was raised 

originally.

Okay. So, job-specific bioassays are performed for 

workers when warranted by job internal exposure 

potential. Okay, these are the bioassays typically 

required when you have an RWP, a radiological work 

permit, or in the DuPont era it was a job plan, or 

SWP, when you had a situation that was atypical. It 

wasn't a typical radiological work situation or a 

situation where you had a radionuclide involved that 

wasn't one that the worker was on routine bioassay 

for. So, one would order up a special bioassay to 

cover that particular situation.

Okay. Again, DuPont implemented job plans. RWPs 

were on the books as a procedural requirement for 

DuPont. DuPont did not implement them. Okay? 

And that was something that was cited by the Tiger 

Team in 1990. There was to be an accountable RWP 

system where one would, in fact, have required jobspecific bioassays that would follow on a particular 

job that had RWPs, but RWPs were not 

implemented, and they weren't implemented until 

the early '90s, when Westinghouse had assumed 

operational control of this site.

So, essentially, you had a system where you had 

job plans and SWPs, but you didn't have any 

accountability necessarily to perform the jobspecific bioassays in response to those permits. And 

this was a large part of the problem with RPRT-92 
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82 

that we'll get into, is that the objectives of RPRT-92 

embodied an expectation that you could survey job 

plans and RWPs and be able to link the job-specific 

bioassays for the purposes of looking at the 

completeness. To what extent could you establish a 

job-specific bioassay that followed on to a job plan 

or RWP that specified certain nuclides that needed 

to be monitored? Okay?

And that all came from a finding that Westinghouse 

itself made in 1997. What happened was, in late '95 

-- I think it was November-December of 1995 -- the 

field office, DOE field office, made a finding on the 

job-specific bioassay program that workers were not 

leaving their bioassays, and it was a significant 

issue. And Westinghouse responded by doing a 

series of self-assessments, one of which, the one 

that's often cited, was a 100 percent survey of the 

second quarter of 1997.

Lo and behold, they found that only 21 percent of 

the workers were actually turning in their jobspecific bioassays. And I think Tim quickly adds 

that, oh, well, they went back and they did a reanalysis and were able to find the workers, and the 

surveys turned out to be negative.

The real question, though, is, given the significance 

of that incompleteness -- you know, this program 

has historically talked about incompletenesses of 10 

and 20 percent, and those were deemed significant 

enough to follow up on and try to reconcile what the 

implications were.

Here is an incompleteness of almost 80 percent of 

all the bioassays in this particular work category. 

And why does it matter that almost 80 percent were 

found missing? Well, one, the percentage is almost 

unprecedented in EEOICPA, to have 80 percent of 

any monitoring measurements missing.
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83 

The second thing is these are job-specific bioassays. 

Okay. They're non-routine for non-typical rad work, 

for unique setups, one-off jobs where you would 

have to have a job plan or RWP, and you would 

want to have a bioassay at the end of work. Okay? 

So, this is significant.

I mean, I think we all are familiar with RWPs and 

the importance that RWPs have in this system. Well, 

at Savannah River RWPs did not exist in that 

traditional sense until the 1992-to-93 timeframe, 

when Westinghouse upgraded the system and put 

them back in place.

Okay. So, the question that was posed originally 

that was the inaugurating factor for RPRT-92 and 

the entire assessment over the last three years 

was: how complete are job-specific bioassays for 

the preceding years? Okay. We know, 1997, we 

lacked 79 percent of those bioassays. Job-specific 

permits indicated job-specific bioassays. What's the 

situation? What's the incompleteness? What is the 

gap for the years preceding 1997? That was the 

very simple question.

I mean, this is not a complicated issue. It's a very 

simple completeness question that we faced at 

every site and that we do a V&V for at most sites at 

the very beginning of the review. Savannah River 

we did not do that. There was no V&V for 

subcontractor data completeness, and this was 

something that was picked up at midcourse.

So, the question is, how complete are the preceding 

years at Savannah River? And what complicates it is 

the subcontractors, who figure in many, but not all, 

of the job-specific bioassays, are ones that 

increasingly toward the late '80s into the '90s were 

temporary and more transient; were brought in by 

the hundreds. And they moved around the entire 
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84 

site.

A lot of them, if you are a carpenter or you are a 

laborer, you may do one work under one job plan or 

an RWP at one facility, like 773-A, and the next day 

you may have to go over to the tank farm and do 

some construction-type work over there, and you 

would constantly move around and you would be 

constantly under different job plans and perhaps 

different radionuclide source terms.

So, it was certainly important that one would want 

to capture those bioassays. And unfortunately, 

because the workers were often transient, the only 

other way one would possibly capture a positive 

bioassay would be a termination bioassay. 

Unfortunately for Savannah River, the termination 

bioassay program wasn't effective and wasn't 

upgraded until 1997-98, when, in fact, there was a 

follow-up activity, due to the self-assessment at 

that time, to, in fact, make the termination bioassay 

program an accountable one, where you couldn't 

have a subcontractor come in and, then, go out 

without leaving a bioassay.

And that follows for a lot of your radionuclide source 

terms, like Pu and americium where, yes, okay, 

they might have been on a pre-scheduled required 

bioassay, but if they were on the site for a few days 

and left, and didn't leave a termination bioassay, 

well, they had no bioassay. That information is 

lacking.

And the implication of not having this information is 

you can do all of the distribution sorts you want, 

you can do all the percentage rate assessments --

and we saw a lot of them today -- but if that 

information isn't there, you don't know what you 

don't know. It's missing. That information is not 

part of the database that you're sorting.
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85 

And so, whatever outcomes you get may possibly 

validate the completeness and representativeness of 

the routine program. It may show they have a nice 

incident analysis program, but it's not going to 

illuminate whether, in fact, the job-specific 

bioassays are appropriately represented and 

whether that influences the distribution of doses in 

a co-exposure model. That is not possible if you're 

missing as much as 80 percent of that data.

So, that is the issue on job-specific bioassays.

Next one, please.

I want to talk about subcontractors. Okay. Not all 

subcontractors -- because I think there's a lot of 

discussion about, you know, how much data do we 

have on subcontractors. Well, we have a heck of a 

lot of data. You know, Savannah River is a huge 

site. There's a lot of monitoring, and as far as 

routine and incident data, we have considerable 

data on subcontractors. Not arguing that at all.

The question, though, is, how much job-specific 

bioassay data do we have for subcontractors and 

how complete is it? That's the essential question. 

And again, I've already said this to some extent, but 

I want to emphasize that we're talking about a 

category of workers, these subcontractors, that 

were temporary, intermittent in a lot of cases, 

short-term, yes, and some actually stayed onsite 

longer, but certainly that was the nature of the 

work.

That work changed over time. There were more 

resident subs in the early '80s than there were 

toward the late '80s. DuPont had in-house 

construction and hired their CTWs and subs directly 

from the union halls. Westinghouse had a 

construction contractor, Bechtel, which did the same 
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86 

thing.

And I include a bullet in this slide from '94. You 

know, we certainly looked at '94, and I don't have 

any issues with the kinds of analyses and sorts that 

are in there. I think this illuminates the fact that 

you had a change in situation as far as the 

monitoring that might have went on for subs, based 

on the claimant database. And that's the third 

bullet. I won't go through that. I think Tim has done 

quite a bit on that.

The question of sub stratification, I'm not going to 

dwell on that, but I think we have gone through this 

a number of times with NIOSH. And I went ahead 

and used this quote, since I think NIOSH has 

liberally used our quotes, because I think this one 

illustrates the concern that we have, that, you 

know, as far as subs being different than CTWs, I 

think there is evidence, at the 95th percentile, that 

there is some differences as far as the exposures 

that have been seen during the '70s and '80s. We 

have seen the graphs and we have also interviewed 

workers that have suggested that, yes -- and this is 

not unusual at DOE sites -- subs did fulfill a role 

where what we would call the "dirty work," the dirty 

radiological work was often given to transient 

workers that came onsite and would do the work. 

And that was sometimes how things were handled. 

That was just based on interviews, but we did get 

that input. And I think, in this quote, that input was 

acknowledged.

But, in the final analysis, before getting into a big 

debate on that question, we question if the jobspecific bioassay data itself is missing. And we have 

not -- and I don't think NIOSH has -- established 

exactly what the circumstance is pre-1997. Okay. 

After all this work, I don't think we have a firm 

answer on the completeness level of job-specific 
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87 

bioassays SRS-wide for subcontractors.

Okay. Next slide, please.

Okay. As far as 92, we could spend, and the Work 

Group did spend, days on the different findings. But 

let me just take the overall conclusion, which is that 

92, as far as its conclusion that "a large percentage 

of subcontractors were monitored for potential 

intakes while working under a job plan, SWP or 

RWP."

We would say, yes, but that large percentage, which 

was quoted as 89 percent -- and I think Tim also 

said that -- encompasses all subcontractor 

bioassays -- remember what I was saying as far as 

distinguishing job-specific versus all -- all 

subcontractor assays over the entire '72-to-90 

period. So, that's kind of washing over all of the 

periods of time, even periods where you did not 

have much data. It sort of washes it all together 

without ascertaining to what extent a permit 

indicated job-specific bioassays actually were 

performed.

And this was the specific charge. Okay? I'm going to 

go back to that. That was the specific charge of this 

Board, was to come back with a measure of the 

completeness of job-specific bioassays for that time 

period for the entire site. Okay?

And the result of RPRT-92 very clearly is that, for 

1972 to 1990, we still have only one facility, the 

same facility we had back in 2016 or 2017, which is 

773-A, and even that is for incomplete years. We're 

missing the late '70s.

Now what I heard in Tim's presentation was that 

now we can add F and H. Well, we're going to get to 

that in Finding 5, but F and H is basically an area 

that was added because of incident data. We have a 
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88 

problem with that because, in terms of the 

completeness, it was very clear that Savannah River 

had a fundamental issue in terms of compliance 

with job-specific bioassay performance.

Bioassays were not being turned in. It was a loose 

system, a lot of management issues, a lot of fix-its 

in 1998 to get that corrected. But, very clearly, 

there wasn't an accountable system that was 

compelling workers to, in fact, submit their 

bioassays and a system that was going to process 

those.

The incident bioassay program is tied to special 

bioassays, by and large, and the special bioassay 

program at Savannah River, like the routine 

program, is -- unlike the job-specific bioassay 

program -- is a very sound program that has what 

one would expect in any modern site, which is a 

very accountable system that has a number of 

management checks. And if one were charged with 

a special bioassay following an incident, I would not 

be surprised if you had close to 100 percent 

completeness because you're looking at a very 

rigorous, compliance-based system when you're 

dealing with special bioassays.

And that's why, on Finding 4 of our report, we 

objected to NIOSH complementing its completeness 

percentages by citing these special bioassays as 

showing all these very high percentage rate 

completions. Of course. Of course, you're going to 

get high completion rates. These were rigorously 

enforced, unlike job-specific bioassays. So, let me 

just throw that out, that I believe we have one area 

upon which one could base any completeness 

finding on RPRT-92, and that remains just the one 

area.

Okay. It's not feasible to identify radionuclide-
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89 

specific exposure potentials. And it comes down to 

job plans rarely specified radionuclides. Workers did 

not sign in and out of SRS areas. The only place 

where that was happening was 773-A, and that did 

not change until 1989.

Facility radiological characterization is inadequate. 

The source term information that would wind on job 

plans and RWPs was faulty. This was a finding by 

the Tiger Team in 1990, that SRS-wide facility 

characterization that was the basis for your type 

and frequency of bioassays was not working, was 

inadequate, and was out of conformance with DOE 

orders. There was only one facility that was, in fact, 

deemed as in conformance, and that was the Naval 

Fuel Facility.

So, anyway, I think that gives you a flavor without 

getting into the five-hour version of what we found 

in RPRT-92. But, certainly, RPRT-92 did not 

accomplish the objectives that were laid out in its 

sampling plan in 2017 and did not, in fact, validate 

the completeness of job-specific bioassays in the 

preceding years.

Next slide, please.

I'm not going to dwell on this, but I just want you to 

know -- you heard weight of evidence -- well, we 

took the same approach back when we started 

reviewing this a year or so ago, and we wanted to 

look at the NIOSH evaluation in 92 from all angles:

From the sampling premise, the assumptions that 

were used, because the assumptions are allimportant to what you end up getting. By virtue of 

what nuclides you include -- will you just go with 

one nuclide, which NIOSH tended to do, or you took 

all the nuclides that should have been on the job 

plan or RWP and tracked the percentage that did 
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90 

have that, that would give you another answer. So, 

we looked at the assumptions from the get-go.

Sampling execution: the question of looking for 

randomly-selected radiological workers, so that you 

could evaluate the monitored and unmonitored 

workers who would be working side by side, the 

coworker issue, we thought was an essential aspect 

of this. This is cited in the Implementation Guide. 

NIOSH agreed that it was something that needed to 

be ascertained. So, we looked at that in terms of 

whether they achieved that objective, showing 

whether you could demonstrate workers working 

side by side, one monitored versus unmonitored.

And beyond that, we focused on the two operational 

periods. Now we hear defense-in-depth quite a bit 

relative to Savannah River. I'm here to tell you that 

defense-in-depth varied considerably in terms of 

results. I think Jim Lockey mentioned, yes, that 

sounds good, but what are the results?

Well, I can tell you the results of defense-in-depth 

in the DuPont era was such that, when 

Westinghouse took control of the site, they were 

forced -- and, of course, the Tiger Team had 

something to do with it, too -- but they were forced 

to come up with a radiological improvement 

program that literally put a technical basis and a 

5(q)(i) procedural basis to the rad-monitoring 

program in place, because there had not been one.

And it was basically founded on DPSOL procedures, 

very general procedures for which there was very 

little accountability, and which had hardly any basis 

in national and DOE standards, national consensus 

standards and DOE orders. It was pretty much an 

in-house-based program, insular, expert-based 

program in the DuPont era.
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91 

So, when we talk about the difference between the 

operational periods, you have a very distinct 

difference in the management of rad-monitoring in 

the DuPont era versus following the upgrade that 

Westinghouse made in the early '90s. And in the 

Work Group, we went through a series of 

comparisons, whether it's RWPs, no RWPs, whether 

you monitored with respiratory protection or you did 

not, and whether you actually did do a 

comprehensive source term analysis facility by 

facility. Night and day between DuPont and 

Westinghouse.

And finally, the central thesis -- and no matter what 

words are put in our mouths -- the central thesis of 

our review is, can bioassays be linked to 

corresponding work permits, so that monitored 

subcontractors can be compared with unmonitored 

subcontractors and data completeness established? 

That is it. Okay. That is the question that we 

weighed RPRT-92 against.

Next slide, please.

Okay. We're going to get into the findings, and 

again, I'm going to go through these relatively fast.

But the first one is there was a premise behind the 

RPRT-92 survey, the one that was planned and 

executed a few years ago. And I don't have any 

fault with the design because this was designed 

against the Implementation Guide. In terms of 

completeness, one wanted to measure whether 

there was a sufficiency of measurements. That's 

actually in the Guide.

And the way it was approached is, since job-specific 

bioassays are linked to your RWPs and job plans, 

the question is, could you survey those plans, those 

permits, and establish the percentage of job-specific 
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92 

bioassays that could be linked to those plans or 

those permits? And if one is talking only 21 percent 

in 1997, would you see a higher proportion, or not, 

in the preceding years? So, that was a fundamental 

premise of the RWP and job plan surveying that was 

a fundamental part of RPRT-92. 

Unfortunately -- and again, this is in retrospect --

only job plans were found in the DuPont era for one 

facility, 773-A. And that was a fundamental problem 

because, then, whatever assumptions you made, 

you would have to look at respirator use and make 

assumptions regarding whether or not the bioassays 

that you could find for a particular worker was, in 

fact, appropriate for that particular permit, job plan, 

whatever. And this is where you get into, I think, 

some problems.

And we'll talk about the question of the assumptions 

that guided it, but the finding here is that the 

assumed linkage that I think was assumed in 92 

that you would find job-specific bioassays that 

would follow on from a specific identifiable job plan 

did not exist. There just wasn't any linkage. You 

could not show that.

Those linkages did not exist at Savannah River until 

Westinghouse stood up the RWP programs in the 

early '90s, where you actually had an accountable 

system where you did, in fact, have trackable 

bioassays tied to an RWP.

Next one, please.

Okay. Finding 2 I mentioned before. And one of the 

other fundamental assumptions in RPRT-92 is the 

fact that you could assign a particular source term 

to a job plan based on a hierarchy of considerations, 

one of which was the DPSOL procedures, another of 

which was the facility type and frequencies.
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93 

And finally, there was a 1999 report that provided a 

modern, system-based characterization of 

Savannah River source terms that NIOSH would 

back-extrapolate or back-apply to those facilities to 

come up with those values.

My problem -- and I think the SC&A's issue -- is 

that it is very clear that back-applying 1999 

characterization information to assign source terms 

was a reach, but more so in 1999, or 1990, DOE 

itself in the Tiger Team assessment singled out the 

facility characterization in support of bioassay type 

and frequency as being flawed and deficient at 

Savannah River. And the corrective action was, in 

fact, to come up with a comprehensive system that 

would, in fact, assign appropriate source terms to 

these facilities.

Before this time, in the DuPont era, it was 

essentially expert-based. Basically, you had facility 

managers very familiar with the operations -- and 

these were longstanding operations -- who would 

basically assign whatever the radiological source 

term would be to these job plans, whatever.

And, of course, the issue is that, as work changed 

and as special tasks, one-off tasks became more 

common, that system just wasn't going to work 

because there was no facility manager that could 

keep up-to-date and keep those source terms 

accurate.

Next one, please.

Okay. Finding 3 we've talked about. I'm not going 

to dwell any more on this, but, very clearly, 

Savannah River has -- it's a large site -- many 

operations, many activities, many facilities. And that 

was the genesis of the Board's concern in 2017 of 

having an expanded survey done, so that whatever 
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94 

answer came back on completeness, it would be a 

comprehensive answer, not just one that would be 

singled to one facility, 773-A. And in the end, the 

only job-specific bioassay sampling -- I'll be very 

careful with that -- job-specific bioassay sampling 

that could be done was done for the same facility, 

773-A.

Okay. Next one, please.

I've already touched on this. I object to NIOSH 

including F and H areas, in addition to A Area, as 

being a measure of completeness. F and H area was 

added because of the incident information, incident 

bioassays that were a product of special bioassays 

that were collected. The special bioassay program is 

a much different management process than jobspecific bioassays. It's apples and oranges. Okay?

Finding 5, we've had this as a long-running concern 

at Savannah River, records destruction. I think, 

certainly, we and NIOSH agree that it figured in 

perhaps the lack of RWPs and job plans that were 

found. But, at the same time, I think in the end we 

agree that, empirically, there's so far no evidence 

that there's records missing, although I will be quick 

to say that, you know, as far as the worker 

interviews about destruction of subcontractor 

records, again, several of the examples included 

timecards and monitoring records. So, that does 

give one pause. But, at this point, in terms of the 

NOCTS information and claimant information, 

there's no evidence that dosimetry records are 

missing. So, certainly, we want to make that 

acknowledgment.

Okay. I want to keep this moving. Bob, I think 6 is 

yours.

Mr. Barton: Yes. Thanks, Joe.
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95 

I'm going to quickly go through SC&A's findings 

related to reevaluation of those DuPont era jobspecific bioassays. And there are about five findings 

related to that and, also, a finding that sort of deals 

with the year 1990, which we sort of refer to as one 

of the transition years.

So here, what we're talking about is americium. And 

again, it's only for one section of A Area, the F wing, 

and for a very limited time period, '81 to '87.

And we found that only 20 percent of those worker 

job-specific and bioassay combinations, that only 20 

percent of the workers were actually monitored for 

americium. Now that's lower than NIOSH's estimate 

that Tim showed in their presentation. NIOSH 

estimated it at 34 percent.

And the difference is that it appears NIOSH 

incorrectly included chest count data that was 

actually greater than two years past the end of the 

job date, job plan date. Now, obviously, two years 

later, I don't think the internal monitoring result is 

actually related to the job plan. But, more 

importantly, NIOSH's own internal dose 

reconstruction procedures dictate that periods 

longer than two years for chest count data should 

be considered unmonitored. So, that data should 

not have been included as potentially a match for a 

monitored worker. So, if you take those remaining 

numbers, 20 percent, not 34 percent.

Finding 7 is also related to americium, and this 

really talks about the concept of "effectively 

monitored," which Tim mentioned in his 

presentation regarding RPRT-92. And SC&A defined 

it a little bit differently. SC&A defined "effectively 

monitored" as the combination of those workers on 

a job plan who were directly monitored or the 

unmonitored workers who were on a job plan with a 
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96 

directly-monitored worker who was actually being 

fed in the co-exposure model.

If you're an unmonitored worker and you're on a job 

plan with someone who was monitored, but those 

records are not going to be used in a co-exposure

model, are you really represented in any 

subsequent co-exposure model?

And so, we found that 33 percent can be considered 

effectively monitored. Again, that's 33 percent of 

the workers surveyed in RPRT-92 were either 

directly monitored or on a job plan with a worker 

who was monitored and feeds into the co-exposure 

model. This is lower than NIOSH's number, which 

was estimated at 42 percent.

And again, that's due to what we feel is incorrect 

inclusion of chest count data greater than two years 

and, also, how we define what an effectively 

monitored worker is. So, those two combined lower 

it from 42 percent to 33 percent.

Moving on, this one is just real quick. It's about 

fission products. We wanted to note that the 

percentages we came up with were around 70 to 73 

percent, based on which period you're looking at, 

and again, '72 to '74 and '80 -- and that should be 

'80 to '88, because there weren't actually data 

available to really evaluate for '89.

And the only thing I wanted to point out here is that 

all of these results were based on in vivo counting. 

And that's fine; you can use in vivo to directly 

monitor. However, the co-exposure models are 

based on urinalysis data. And so, none of these 70 

to 74 percent would feed into any increase really in 

the effectively monitored population.

Moving back to Finding 9 -- and this is really just a 

combination of two of the previous findings about 
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97 

americium -- and that's directly-monitored workers 

were around 20 percent, and then, we could add on 

another 13 percent of -- they were on a job plan 

with the directly-monitored worker who feeds into 

the co-exposure model. So, you can combine both 

of those and you get an effectively monitored 

population of 33 percent, if you add those two 

numbers together.

Again, I had mentioned there's a finding about 

1990. And this is just the fact that Westinghouse 

took over during 1989, I believe. So, this would be 

considered the Westinghouse era. However, the 

data for 1990 are still just as lacking. There was 

only one radiation work permit, I believe, and there 

was no associated monitoring.

Okay. Moving along to Finding 11 -- and just trying 

to keep this thing moving -- this finding is really 

borne out of the summary conclusions in NIOSH's 

RPRT-92 that analyze the percentages of 

subcontractor trade workers that were monitored 

for at least one radionuclide required on the job 

plan, not all of them, but just at least one. And they 

tabulated that.

We don't feel that's really an appropriate metric. For 

example, does it really matter if a worker on a job 

plan was monitored for fission products, but was not 

directly or effectively monitored for the other 

required radionuclides? The more appropriate metric 

is whether the workers are directly monitored for all 

the relevant radionuclides, or really perhaps more 

importantly, effectively monitored for all of the 

relevant radionuclides.

I mean, we do a comparison here between our 

ranges of percentages for appropriately being 

monitored or covered by the co-exposure model. 

And as you can see, they're different. Especially 
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98 

directly monitored, we came up with 47 to 77 

percent, based on the time period. And this actually 

includes the Westinghouse era, which you'll see in a 

second. And we have the comparisons here with 

what NIOSH reported in RPRT-92.

And the last slide here is a pretty informative table. 

Again, this is SC&A's calculation. I think the third 

column there, "Effectively monitored for all 

radionuclides," so, again, that would mean the 

worker was on a job plan and they either had direct 

monitoring records, they were monitored 

themselves, or someone else on that job plan was 

monitored who's getting fed into a co-exposure 

model.

As you can see, '72 to '74, that number is about 55 

percent effectively monitored. No data for '75 to 

'79. And 66 percent for '80 to -- and again, that 

should be '88, because the RWP in '89 didn't have 

any associated monitoring with it.

I think that's it for the findings associated with rereview of the data and RPRT-92.

So, I'll turn it back over to you, Joe.

Mr. Fitzgerald: Okay. Thank you, Bob.

I'm not going to go through the clarifications on the 

quotes because there's so many quotes to catch up 

to. But, you know, I'd put at least two of these in 

context.

And I think the key thing here is that, yes, DuPont 

handled subs pretty similar to how they handled inhouse workers, but that is to the detriment of the 

subs because they, frankly, suffer from a lack of a 

termination bioassay program because they were so 

mobile. And they had an inadequate facility 

characterization program and an absence of an 
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99 

RWP. So, if you're a sub, and you're doing that kind 

of work and relied on job-specific bioassays, yes, 

you were at a disadvantage to the regular 

workforce, even though DuPont handled both 

groups the same.

So, I think I'm going to leave it at that, but when 

these quotes are thrown out, just remember context 

is critical and you need to have overall context to 

understand what's being said.

Next one, please.

Okay. Knowing we're racing the clock, not unusual, 

I'll go to the conclusions, 1972 to 1990. 

And I want to go through these conclusions, and 

then, since we just received NIOSH's slides right 

before the meeting, we weren't aware of the new 

proposal. So, I wanted to also provide our brief 

comment on that, since we were unable to see that 

and be able to react to it in our slides. So, I'm going 

to provide a comment on that.

But the conclusions for '72 to '90, and this is, 

essentially, the DuPont era with one additional year, 

is that we conclude that:

NIOSH has been unable to demonstrate the 

completeness of subcontractor job-specific bioassay 

data and did not accomplish the objectives defined 

in its sampling plan for RPRT-92. Okay.

And as Bob just pointed out, in terms of americium, 

in particular, radionuclide-specific, we found that 

there was limited associated monitoring to conclude 

that the co-exposure models would be 

representative of workers on the job-specific 

bioassay program. And while higher data 

completeness is ascribed to other radionuclides of 

concern, like plutonium and fission products, that 
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100 

analysis relies on job plan and SWP data from only 

one facility again, 773-A. And we see no way you 

can extrapolate that to the other 30-plus facilities at 

Savannah River.

And I think the bottom line is it remains unknown to 

what extent, after three years, to what extent past 

job-specific bioassays are incomplete, but it is 

known that the gap in 1997, 79 percent incomplete, 

was significant. And the weight of evidence provided 

by SC&A's review, in our view, invalidates the 

inclusion of at least that pre-1991 subcontractor 

data as being demonstrated sufficiently complete 

and representative for use in the SRS co-exposure 

model.

And this gets to the issue that, as the 

Implementation Guide provides, the completeness 

of the data comes first. One has to validate the 

completeness before you start talking about 

workarounds, looking at other ways that one can 

manipulate data, looking at distributions, looking at 

incident files, NOCTS. One has to look at 

completeness first. Otherwise, you're not dealing 

with all the cards in the deck. In this case, we don't 

think that completeness question was settled by 92.

Okay. For '91-98, our conclusion there is that, yes, 

you have many more RWPs for more than just 773-

A. That provides an avenue, but not necessarily a 

conclusionary one, for establishing the 

completeness of those job-specific bioassays in that 

period. This is the period right before the 1997 

finding that precipitated this whole survey.

And the reason we hedge our bets on this latter 

period, even though there is more RWP data, is that 

Westinghouse, when it did its self-assessment 

during the 1997-98 enforcement moratorium -- and 

there was a DOE-wide enforcement moratorium on 
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101 

bioassay programs because they found the same 

issue at a number of sites -- Mound, Los Alamos,

Brookhaven I think, and Savannah River, to name 

at least four -- where bioassays were not being 

collected at a high percentage rate.

And rather than citing and fining all these sites, they 

decided to give everybody a 90-day moratorium to 

self-assess. Well, Savannah River self-assessed and 

identified a number of longstanding management 

system deficiencies in how job-specific bioassays 

were being administered at the site and came up 

with a corrective action program. We have a copy of 

that. But these were pretty fundamental fixes in 

procedures, in management accountability, and the 

system that was used.

So, our concern is, if it was that fundamental and 

you had this many bioassays that went missing in 

'97, how could one be so sure that the 

completeness in '96, '95, and '94 was any better, 

and particularly given the milestone of a DOE 

finding in 1990 that they weren't collecting and 

holding the workers accountable for bioassays?

So, this latter period is one that is troublesome to 

us, although, again, we acknowledge that there are 

more permits to look at and perhaps more data. 

And it's certainly later in the timeframe. And it's a 

management system that was more modernized 

under Westinghouse.

So, it gives you more confidence that, if, in fact, you 

would establish something, it would be established 

in that time period. But, again, the asterisk is that 

Westinghouse was the one that was cited, and the 

management findings are that these were 

longstanding, fundamental flaws in the way those 

programs were being managed.
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102 

Okay. Finally, I want to, again, not take up too 

much more time. I hope my voice survives.

But I want to provide some comments regarding 

Tim's latest approach to determining completeness 

now that it has crystalized into a formal proposal. 

And I want to read these into the record, again, 

because we just didn't have a chance to provide any 

slides on it.

Okay. In terms of the proposal, I guess, simply put, 

we would say we believe it won't suffice to resolve 

the issues that we've been talking about.

And if RPRT-92 was NIOSH's Plan A for 

demonstrating data completeness for subcontractor 

job-specific bioassays, we believe, as we just 

concluded, it cannot be accomplished with the 

information available.

And NIOSH is now proposing to the Board a new 

Plan A plus B, with B being NOCTS logbook data, 

and I think a number of other things -- I didn't 

catch all of it -- much of which, we would add, was 

available three years ago at the beginning of this 

effort.

We looked at RPRT-94, and Tim's early proposal 

was discussed at the December 2019 Work Group 

meeting. RPRT-94, while informative, does not alter 

our findings and conclusions relative to RPRT-92 

and the completeness of subcontractor job-specific 

bioassay data at Savannah River.

As Brad noted earlier, NOCTS data was an early 

option looked at by NIOSH for this completeness 

review some years ago, and it was not pursued. We 

and the Board agreed at that time that the review 

and sampling, in addition, for RPRT-92 was the right 

course of action, given the co-exposure guidelines.
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103 

While the co-exposure guidelines do suggest NOCTS 

data as a, quote, "useful starting point" to look at a 

distribution of samples, and NIOSH did, I'll say, a 

sound job with that analysis for RPRT-94, it is not 

enough for ascertaining job-specific bioassay 

completeness for Savannah River.

As NIOSH's co-exposure guidance emphasizes, data 

completeness needs to be, quote, "determined," 

unquote, from sufficient measurements and, quote, 

"established," unquote, from monitored workers 

with comparable activities and relationships to the 

radiation environment. We do not see this as 

feasible with NOCTS.

As Tim pointed out last year in our December 2019 

Work Group meeting, there is a potential detriment 

to a NOCTS-based approach, such as what's being 

envisioned in RPRT-94. And what he had to say is 

we can't directly compare coworkers; therefore, the 

data completeness must be inferred.

While he justified using NOCTS for its simplicity, 

timeliness, and resource efficiency, we find such a 

tradeoff of concern. Data completeness and 

representativeness should not be inferred or judged 

from NOCTS for expediency's sake.

And as a Board Member noted during that 

discussion back on December 5th of 2019, care also 

needs to be taken, as NOCTS is not necessarily 

representative of a site's actual workforce.

Under NIOSH's latest proposal, the A plus B option -

- this is RPRT-92 plus RPRT-94, plus logbooks, plus 

whatever -- we still have not determined whether 

there are sufficient job-specific bioassay 

measurements for subs, and we certainly cannot 

compare coworkers with similar exposure potential, 

which in the final analysis will not answer the 
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104 

specific questions posed by the Board back in 2017, 

the first of which was, if almost 80 percent of your 

job-specific bioassays, not routine, not NOCTS, not 

logbooks, not incident, but job-specific bioassays, 

were missed at Savannah River in 1997, how can 

NIOSH account for their completeness in the years 

before it?

The second question is, how can NIOSH provide 

assurance that a co-exposure model for construction 

trade workers is representative of subcontractors on 

job-specific bioassays when such a potentially wide 

gap of permit-required bioassay measurements 

exist?

Okay. Finally, SC&A continues to view RPRT-92 as 

the completeness analysis whose objectives best 

track the tenets of IG-006 Guide, despite the 

ultimate lack of documentation and programmatic 

issues that precluded an adequate result for at least 

'72 to '90. So, it wasn't for want of a sampling plan 

that was consistent with the Guide that was the 

problem. It was just the lack of records and some of 

the management issues in the early time period that 

precluded the outcome that was desired.

So, again, though, I don't see how this expansion 

into all these other so-called weight-of-evidence 

avenues is going to do anything but diffuse what is 

a very basic question that needs to be answered, 

and was not answered by the survey over the last 

two or three years that was designed to do so.

So, anyway, I think that's all we have, and 

certainly, we'll take any questions.

Member Clawson: Thank you, Joe. I appreciate that.

So, why don't we open it up to the Board for any 

questions?
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105 

I want you to realize one thing, though. As the 

Savannah River Work Group, we looked at this very, 

very carefully. And if you notice the dates that I'm 

bringing up, '72 to '90, the reason is that, in my 

eyes, it's cut and dry; there's no issues.

Now, from '91 on, there's questions of that they will 

be able to perform this. We frameworked this for 

this reason, because if we're not, we're looking at a 

very, very, very big timeframe and there's a lot of 

things that fall into it. And this is why we cut it 

down to 1990. This is when Westinghouse took 

over. Actually, I call it the DuPont era.

I want you to think about this because this has been 

three years, and I'm not saying that there's time 

restraints or anything else like that, but at some 

time we have to be able to deal with this. And this is 

why I looked at it in this framework of '72 to 1990, 

because, to me, there is no question, no ifs, ands, 

or buts, it did not meet what the requirements 

were. That's my personal opinion. You guys all have 

yours.

So, I open it up to the rest of the Board for any 

questions that they have at this time.

Member Ziemer: Brad, I have a question. Oh, go 

ahead.

Dr. Roberts: Go ahead, Paul.

Member Ziemer: This is Paul.

I think my question will go to Tim Taulbee. And it's 

my understanding -- I want to ask something about 

the incident reports -- my understanding is that 

both SC&A and NIOSH agreed that the incident data 

would not be used if there were a coworker or a coexposure model, is that correct?
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106 

Dr. Taulbee: That's not entirely correct, no, sir.

Member Ziemer: Well, let me ask my basic question 

first, and then, we can follow up, if necessary.

But let us say that a worker was working in any of 

the facilities without a work permit or a job-specific 

permit, and an incident occurred. Would that 

individual -- let's say a subcontractor -- if an 

incident occurred, would they not be followed up, 

regardless of whether there was a job-specific 

permit or not? Or do we know the answer to that?

Dr. Taulbee: That is correct, Dr. Ziemer, they would 

be followed up. Whether they would appear in the 

co-exposure model depends upon the severity. If 

the severity of the incident was enough that they 

would do chelations, they wouldn't appear in the coexposure model. If it wasn't a severe incident, then 

those positive bioassays would appear in the coexposure model, but they would be followed up.

Member Ziemer: Okay. I was trying to get a feel for 

whether or not that the incident data, which, 

presumably, would be the highest bioassay data, 

would cover, or not cover, workers, whether or not 

there was a job-specific bioassay requirement.

Mr. Fitzgerald: Paul, can I respond a little bit on 

that?

Member Ziemer: Yes, Joe, I'd appreciate either of 

you, the two of you.

Mr. Fitzgerald: Yes, my concern is, before you get to 

that question, we don't know what radionuclides, 

what exposures, were tied or linked to these jobspecific bioassays that are missing because we don't 

know the degree to which we have them. But if they 

are, in fact -- and this is the reason I put the 

definition of job-specific bioassays up -- if they were 
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107 

used when you were dealing with non-routine 

radionuclides and atypical rad work, which is kind of 

the definition of an RWP anyway, then if it's 

missing, you literally don't know. I mean, you don't 

know what nuclides may have figured in those 

exposures. You don't even know if there were 

exposures and to what degree they might have 

been high or not. The fact that the data is missing 

hamstrings you from even drawing conclusions.

That's the problem with the data completeness 

issue. One has to ascertain the completeness first 

before you can go further and decide what the data 

tells you. And I find -- you know, I'm not saying 

that the analyses that NIOSH has done is not 

comprehensive, certainly not attentive to all the 

different avenues one can come up with analyses --

I'm just saying that the very first question that we 

always ask at the very beginning of a Site Profile 

and an SEC, which is the V&V, "Do we have all the 

data that we need?", wasn't asked for 

subcontractors and wasn't certainly ascertained for 

job-specific bioassays.

So, we are now going sort of after the fact and 

going backwards trying to figure out, is there any 

way we can see if we do have enough of that data 

that we can do a co-exposure model, and we 

haven't lost whatever information was in those 

bioassays.

Member Ziemer: Yes, I understand. I understand 

that point. I was trying to get at the idea of whether 

or not an incident, regardless of where or what it 

involved, an incident being reported would require a 

follow-up, and it sounds like it would.

Mr. Fitzgerald: Yes, it would. It would. Because the 

special bioassay program I think would be --
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108 

Member Ziemer: Right.

Mr. Fitzgerald: -- was a pretty sound program at 

Savannah River.

Member Ziemer: Right. Yes. Okay. Now my other, if 

I could just follow up with one other comment at 

this point? And I might preface this by saying that I 

really appreciate the analysis that both of the 

groups have done, NIOSH and SC&A. I think they've 

given us a great deal to think about and evaluate.

Well, let me also say that I appreciate the lack of 

both the rigor and procedures that are reflected in 

those early years. I'm certainly one that uses the 

Tiger Team as a turning point for many of the 

facilities. But we find that lack of vigor in a lot of 

different places.

But, in any event, my question is, did the lack of 

job-specific bioassays -- or are job-specific 

bioassays needed to develop a co-exposure model? 

I know that NIOSH was not able to demonstrate 

that they had these over the full site. They had it for 

one facility, because they just aren't there.

But my question is, does that preclude developing a 

co-exposure model from the data that is available? I 

must say that I found NIOSH's presentation on this 

pretty compelling.

Dr. Taulbee: If I may answer first? And then, you 

could go, Joe.

Yes, we believe that the job-specific bioassays are 

not a critical component for developing the coexposure models, primarily due to their just sheer 

number in volume. Most of the subcontractors at 

the Savannah River Site were on a routine bioassay 

monitoring program. So, if they didn't leave this 

job-specific bioassay, six months or a year later, 
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109 

they would leave a routine bioassay. And so, for 

estimating their dose, it's not critical because we 

have a bioassay measurement of that worker who 

worked in that environment.

And so, for the development of the co-exposure 

models, when we look across larger periods of time, 

we calculate the TWOPOS values on a per-year 

basis. We don't believe that these job-specific 

bioassays are that critical.

The numbers that I showed on my one graph, those 

are directly out of those assessments. And so, when 

you're looking at 256 missing bioassays, which 

would come back to just 324 job-specific bioassays 

total -- that's that only 21 percent compliance --

that's out of 6,000 bioassays for that particular site 

at that time. So, when you consider the 300 versus 

the 6,000, now, granted, a lot of the 6,000 are 

operations workers, but a significant fraction of 

them are subcontractors. And looking at plutonium 

bioassay logbooks, in the 1980s, you're looking at 

10,000 plutonium bioassays in that time period. So, 

the number of job-specific is very small compared 

to the routine. So, we don't believe that those 

missing bioassays are actually going to impact those 

co-exposure models that we've developed.

And now, I'll leave it to Joe.

Mr. Fitzgerald: Okay. We put up the slide on jobspecific bioassays with the express purpose of 

showing that this is a category of bioassays that you 

can't just sweep under and assume would be 

subsumed by your routines without establishing 

whether or not you can characterize what you have.

And this all started with the notion, and certainly, 

DOE felt strongly enough about it, and I find NIOSH 

using the same arguments that Westinghouse used 
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110 

in the enforcement conference with DOE: "We have 

lots of routine data. We have a very sound defensein-depth program, and these job-specific bioassays 

don't matter that much. We do them just to verify. 

So, you know, what's the big deal?"

Well, I think DOE's response is very clear. The big 

deal is that these, in fact, identify exposures that 

may result from atypical work situations. They may 

result from unusual nuclide mixes. Nuclides, they're 

not routine nuclides. That was the whole definition 

of why you would do a job-specific bioassay.

The job-specific bioassays are linked to radiological 

work permits, job plans. Okay? So, this is not your 

normal, routine work. These are ones that require a 

work permit that establishes a certain approach to 

the work, requires protective equipment, and 

attention to certain hazards.

So, there's this whole notion that, "It just doesn't 

matter. What is the big deal? We can subsume this 

into a larger database," which I find to be very 

similar to how this is approached by Westinghouse.

So, the problem when you have subcontractors in 

that mix as well is that, contrary to what Tim was 

saying, you can't assume you're going to catch 

them on the pre-scheduled bioassay. They could be 

in and out without a termination bioassay and they 

don't have any bioassay record, end-of-job record. 

You know, you're just lacking that.

So, I'll just leave it at that, but -- hello?

Dr. Roberts: Hello. Yes, someone needs to go on 

mute, please.

Mr. Fitzgerald: Hello?

Dr. Roberts: Okay.
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111 

Mr. Fitzgerald: Yes, just to round that off, I mean, 

just think of the worker category or the bioassay 

category that one could be writing off as something 

that is subsumed by your routine data, and what 

you're talking about is the very specific non-typical, 

non-routine exposures, potential exposures that 

figure in RWPs, job plans, and job-specific 

bioassays. This is not sort of an extraneous outlier 

as far as a category of either exposures or 

bioassays. I think it is a rather significant 

component of the radiological monitoring program.

And again, to be missing 80 percent of those, and to 

have a DOE-wide moratorium covering some 20 or 

30 sites with a major fine, citation and fine, on 

Savannah River, I think all of that speaks to the 

importance of the program.

So, again, we wouldn't be here today after three 

years if that importance wasn't recognized from the 

beginning by this Board when this survey was 

inaugurated in 2017. So, if we're asking the 

question, "What's the big deal?", well, the big deal 

in 2017 was this gap, potential gap, was seen as a 

significant gap in terms of co-exposure modeling. 

And I don't see any change from then to now.

And we had lots of data. We had lots of routine data 

back in 2017, and that wasn't sufficient to not 

address this issue. So, I guess I'm concerned that 

we're retreating from, I think, a stance that was 

taken three years ago on this, and I don't see any 

basis other than the fact that there's a lot of data, 

which was certainly the condition three years ago.

Dr. Taulbee: I would really like to follow up on that 

very last comment there. I think a lot has happened 

in the last three years. This is the evaluation that 

we did in the 1990s. That was the discussion at that 

time period of the multiple areas and "Can you 
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112 

prove that construction trades workers worked, 

unmonitored subcontractors worked on the same 

RWPs as workers who were monitored?" Those were 

all questions that were not answered back in 2017.

So, I do want to emphasize that we have learned a 

lot more since then. We've been able to 

demonstrate that those unmonitored workers 

worked on the same RWPs as monitored workers, 

and RPRT-92 does that.

We were able to demonstrate that in multiple areas 

across multiple years in the 1991-through-1997 

time period. Now, in the 1980 time period, we were 

only able to demonstrate it, though, within one 

area. Okay? But we saw the same thing. We saw 

workers, unmonitored workers, on the same RWPs 

or job plans as the monitored workers. So, that 

answered a very big question there of the 

unmonitored workers, were they actually 

represented by monitored workers? And I think 

that's an important point here.

Mr. Fitzgerald: It was information that was 

developed, but we looked specifically at the bottomline question. That's why I emphasized that in the 

conclusions that we just provided.

Can one establish the completeness of job-specific 

bioassays preceding 1997? And I think we are very 

clear that there was a lot learned and there was a 

lot of pairing that was possible in the '90s, and that 

did not, in fact, happen in the '70s and '80s.

And that's the basis for our saying that it was a 

good-faith effort, a lot was learned, there was a lot 

of effort put into it, but the availability of the 

records and the management shortfalls that you 

mentioned, that, you know, it just wasn't possible to 

link some of this back in the DuPont era, kind of 
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113 

brings us to this point of saying, as far as 

completeness on this particular matter, one can't 

demonstrate it by virtue of 92. And that was 

certainly the thesis that was being examined for the 

two-year or three-year period.

And so, that brings us back to, what do we do with 

that? And that's our conclusion: that really we're 

back to the point where we've learned something. 

We have established where the data is available. 

But, for the DuPont era, for those reasons, one 

cannot establish the completeness of job-specific 

bioassay data sufficient to provide a 

representativeness in the co-exposure model.

And, yes, I know you disagree, but, as far as the 

objectives of 92 in terms of delivering those 

answers, for '72 to '90, those answers were not 

delivered for SRS as a whole. And I think that's kind 

of where we've arrived at this point in time.

Member Beach: This is Josie. Can I jump in with and 

have a process question here of the Work Group?

Dr. Roberts: Sure.

People need to be on mute. If everyone could mute 

except for Josie, please, at this point, that would be 

great.

And, Josie, after your question, just in the interest 

of time, I'd like to give the Petitioners a chance to 

step in and present as well. So, we'll go with your 

question and get an answer to it.

Member Beach: Okay. So, mine is a process 

question. Has the Work Group made a formal 

motion or a recommendation, and has it been 

seconded? Is that something you're planning on 

doing, Brad?
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114 

Member Clawson: Okay. All right. Yes, we've 

already done that in the Work Group. We're bringing 

it to the Advisory Board now to be able to put that 

forth.

Member Beach: Okay. So, the motion, we are 

talking about the motion that's been formalized at 

this point, is that correct? I didn't know if you 

needed to bring it before the Board, and then, with 

the discussion.

Member Clawson: Yes. Yes, we do. We need to 

bring it before the Board, but we were trying to get 

through this. And Rashaun leaves at 5:30. I want us 

all to remember that we have brought this to the 

Board for this vote. So, yes, we do have to bring 

this before it.

Member Beach: Okay. Thank you. Thank you so 

much.

Dr. Roberts: So, I do want to give, if there is any 

public member or Petitioner still with us, please, we 

welcome you to make your presentation or 

comments at this time.

Public Comment

Warren Johnson

Mr. Johnson: Thank you.

This is Warren Johnson, an attorney for the 

Petitioner.

And as I understand it, I've got about -- there's 19 

minutes left in this meeting, and I certainly hope 

you're going to have the opportunity to vote. So, I'll 

keep this very short.

Quite frankly, this petition was filed November of 
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115 

2007. And that was based on the fact that NIOSH 

has, every time they've proposed a way to meet 

their charge, which is to bind a dose, to 

demonstrate it's feasible to bind a dose with 

sufficient accuracy, then there have been 

deficiencies that SC&A has demonstrated that shows 

that's not the way to do it, and they have to revise 

the approach. And that has gone on for -- at this 

point, we're now 13 years down the road.

Three years ago, there was, essentially, the same --

well, what's happened at every meeting, which is, 

okay, this is not the appropriate path forward. This 

does not demonstrate with sufficient accuracy. 

Therefore, here's the path we're going to propose. 

That's been NIOSH's position every time.

Three years ago, it was, okay, this is the way we'll 

do it. This RPRT-92 will save this. It will prove the 

completeness, and therefore, there will be no SEC 

granted, and we'll continue on with dose 

reconstructions.

RPRT-92 failed. And I, unfortunately, don't have the 

transcript from the November meeting with the 

Work Group, but that was admitted to by both, I 

believe it was Mr. Cardarelli as well as Mr. Taulbee, 

that critical data is missing. That's what they said.

But now, we just changed the subject yet again. We 

don't really need 92, even though that was their 

proposal; that was the way that this would be 

demonstrated. It didn't happen.

I say this every opportunity I get, but you cannot 

ignore time. People are dying. The very people that 

this program was intended to benefit, they're dying 

and they're not getting the care they need.

And it's all because, no matter what, NIOSH is 

never going to let this go. They will find a way to 
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116 

compound guesses on top of estimates, manipulate 

the data, and get to a result.

What I keep hearing about is this defense-in-depth 

program. And that's why routine bioassays weren't 

really that important; they were just to show the 

program was working. Well, that's a policy.

I've looked through thousands of pages of these 

records for my clients. And there used to be an old 

policy that was on the letterhead of DuPont that 

said, "Don't say it; write it." Well, we're missing all 

the records which would confirm that they followed 

the policy.

And I know there's a debate over whether those 

records were lost, misfiled, or shredded. There's a 

lot of evidence indicating, well, certainly, a lot of 

statements from employees that were witnesses to 

the shredding of documents. Now we assume that 

the documents that were shredded must not have 

been important, I think is what NIOSH said the last 

time. Again, that's not claimant-favorable.

And now, we're here today, three years later, 92 

wasn't really important; we're going to do it yet 

another way. Time is a component of feasibility. So 

is money. Hundreds of millions of dollars is being 

paid to ORAU to do these programs, this 

reconstructions, and to turn around and find yet 

another technical bulletin and yet another proposed 

way to go. Meanwhile, the very people who were 

supposed to be served are suffering. It's not right.

Where we are today -- despite in November when 

they said critical data is missing, and therefore, 92 

is flawed -- now I'm hearing, well, it's not really a 

critical component.

Member Beach: Excuse me for a second.
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117 

Mr. Johnson: Yes, ma'am.

Member Beach: And this is Josie.

And I am not trying to be rude at all, but if we're 

going to bring this to a vote, we need to do it soon. 

So, just letting you know that.

Mr. Johnson: Yes, ma'am. Okay.

In addition, the last couple of things I do want to 

comment on. Excluding the severe incidents, 

meaning the people who had a high enough uptake 

to need to be chelated -- so, we take them out of 

the equation -- and then, excluding the job-specific 

bioassays, obviously, that eliminates many of the 

higher exposures and falsely lowers the coworker 

model.

Going back to the point about the 868 plutonium 

intakes ever, that's based only on the workers who 

had a special bioassay and were assigned a dose. If 

somebody popped up on a routine above the 

technical limit, that didn't go into that statistic.

Again, there's just too many guesses, too many 

estimates, assumptions. And as such, the only 

plausible or the only path forward is to recognize 

that there is no way to demonstrate, to bind a dose 

with sufficient accuracy, and it's certainly not 

feasible. If we don't move forward this way, it's 

going to be many more years before the next 

proposal comes out. And again, the claimants are 

suffering from this.

And so, I certainly feel that it's more than 

appropriate to go ahead and grant this and I 

certainly hope you do so.

But thank you for your time, and I'll stop. Thank 

you.
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118 

Member Lockey: Hey, Joe, this is Jim Lockey. Are 

you there, Joe?

Mr. Fitzgerald: I'm here.

Member Lockey: I just have a few questions to ask 

you.

Are you aware, is there any data (telephonic 

interference) by us in the database --

Mr. Fitzgerald: I'm sorry, say it again?

Member Lockey: Is there any current data that 

you're aware of in the current exposure bioassay 

database that indicates that the subcontractors 

were not encompassed by that database? I know all 

the limitations of the job-specific, and I agree with 

those limitations. I'm just wondering, when you look 

at the current database, is there any objective data 

that says, yes, this data indicates they did not 

encompass some of the subcontractors?

Mr. Fitzgerald: Just the finding in 1997 that, clearly, 

all that data was missing. That's the only real 

indication that --

Member Lockey: There's missing data, but none of 

the data exists to differentiate the subcontractors 

from the contractors?

Mr. Fitzgerald: Yes, again, there's no easy way to 

know that. And that was the purpose of 92, was to 

do the match-ups, so that one could look at that 

particular --

Member Lockey: No, I know the --

Mr. Fitzgerald: I'm just saying that I haven't seen 

anything else that sheds light on that. The question 

that we posed was a very simple one: can we 
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119 

assume there was completeness in that data going 

back? And so far, we have not been able to see 

that. That's the only question that was asked in 92.

Member Lockey: That segues me into the second 

question. At least in some of the studies that I got 

involved with, we have an extensive exposuremonitoring database and bioassay database. And 

where we have extensive and we have data 

missing, we approach it to supply very statistical 

models to that to really determine as to the quality 

of the data and does the data really -- is it really 

representative of what we think the data 

demonstrates, such as resampling and sampling 

techniques or bootstrapping techniques? Did your 

group apply that to this database?

Mr. Fitzgerald: There's no way to treat this data 

because there's no notion of whether it was 

collected regularly. There's no linkage between the 

data and the permits that may have required it. It is 

all loosey-goosey.

So, in terms of actually doing an analysis, it's not 

clear what data you have to analyze. The routine 

program, the incident program, that was all 

managed very clearly in a very stable manner. The 

job-specific bioassay program, whether it's RWP or 

job plans, was not. So, you have a much different 

situation and one that doesn't lend itself to those 

kinds of analyses.

You have to make some wide assumptions about

what that data might be, and it's very speculative to 

compare what you have on the routine side to what 

that data might actually be. '97 is the only year we 

actually have some good idea. We don't have an 

idea going further back than that.

So, you have to make assumptions. And the 
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120 

question is, does the Implementation Guide give 

you that leeway to make that jump? We think it 

does not, that one does need to establish 

completeness before you do anything else. And we 

haven't seen that.

Member Lockey: I wasn't looking at data in 

relationship to specific job tasks. I was just looking 

at the bioassay data in relationship to prime 

contractors and subcontractors, specific 

radionuclides, locations, and year.

And, you know, bootstrapping really does assign a 

measure of accuracy. It looks at bias. It looks at 

variances. It looks at confidence intervals. It looks 

at predictive areas. And it can really tell you by 

resampling/sampling how rigorous that bell-shaped 

curve is and whether it's representative.

I don't know if you're familiar with that technique, 

but it's routinely used in this type of sampling 

databases, large databases, and there is a concern 

whether they truly are representative of the 

population that's being surveyed.

I'm just looking, Joe, for some objective evidence. 

And I agree with you that the job-specific bioassay 

data as we defined it three years ago is lacking, but 

it would be nice to know that the database was 

looked at and see if there is any objective 

determination that we have (telephonic 

interference) fact it did make an impact.

Member Clawson: This is Brad.

I want to remind everybody, you know, while we 

could go on for years -- and like we said numerous 

times, this isn't a science project -- this is a 

compensation program. I brought this before the

Board to have a vote.
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121 

And I'm going to throw that out right now, that the 

Advisory Board consider an SEC Class for 

subcontractor employees at SRS from October 1st, 

1972 to December 31, 1990. And that's what the 

issue is and that's what I've put out in that. And 

that's what we voted on in the Work Group, and 

that's what I'm bringing forth before the Board now.

Do I have a second for that?

Member Beach: This is Josie. You have a second.

Member Clawson: Then, we need to vote on it.

Dr. Roberts: Should we have discussion? 

Member Clawson: I think we have to have 

discussion, don't we?

Dr. Roberts: Yes. Yes.

Member Clawson: Let's have a discussion on it.

Ms. Naylor: Hi. This is Jenny with OGC.

Can you express out the motion a bit more, so that 

it's a bit more clearly formed, rather than just a 

concept at this point? So, for example, what is the 

insensibility? And also, if you can just describe what 

the contractor population --

Member Clawson: Sure, Jenny. If you look at the 

back page, look at the back page of my slide, and it 

gives you all of that. You've got everything. The 

basis included:

Unmonitored subcontractor construction trade 

worker who should have been monitored under 

work permits and job plans for job-specific 

bioassays, but were not.

Potential for elevated exposures at various site 
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122 

locations at intermittent times. Subcontractors were 

often transient, performed high-exposure potential 

jobs under job plans and permits, and it did not 

provide termination bioassays.

Ms. Naylor: And, Brad, do you get the sense from 

DOL that this is a Class Definition that could be 

administered?

Member Clawson: We're not getting into the Class 

Definition right yet because we've got to vote on 

this first. You're kind of putting the cart before the 

horse. Once we get the vote on this, we can take 

and submit it the way we need to for DOL to be able 

to perform what they need to be able to do.

Dr. Roberts: Brad, this is Rashaun.

Member Clawson: Yes?

Dr. Roberts: We are going to need to get more 

specificity around the definition of the Class. And 

we're at 5:26. I understand your sense of urgency 

to get this through, but I'm afraid that the Board 

Members haven't had adequate time to continue to 

discuss this. So, I don't know the wisdom about 

continuing --

Member Clawson: It's been almost every year we 

have gone through this --

Dr. Roberts: Right.

Member Clawson: -- the last three years.

Dr. Roberts: I understand. But I am concerned that 

the --

Member Beach: Can we vote to table the motion?

Dr. Roberts: Yes. Yes.
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123 

Member Beach: I mean, I don't know that we have 

any other option at this point, is that correct?

Dr. Roberts: Yes. Yes, I think that is a potential --

Member Ziemer: Are you (telephonic interference) 

to a certain time, Josie, a week from now or 

something like that, or what?

Member Beach: Well, we would need to reconvene 

the Board meeting in order to continue the 

discussion, and we don't have time now. So, what 

else would -- I mean, there's a motion on the table, 

correct? So, you would have to table --

Member Ziemer: There is a motion on the table. If 

you moved to table it, a tabling motion takes 

precedence and is not debatable. So, if somebody 

seconds the tabling motion, we have to vote 

immediately on tabling.

Member Beach: Okay. Is there any other thing you 

suggest at this point, since we're running out of 

time, Paul?

Member Ziemer: No, I was asking whether your 

tabling motion was going to include a time to pull it 

from the table.

Member Kotelchuck: Well, tabling -- I mean, we 

would normally discuss this at our next meeting. I 

understood that it was brought up for consideration. 

If we had time, I'd vote on it now, but we don't 

have to do a resolution. It will come up at our next 

meeting automatically.

Member Beach: And this is Josie again.

I would say, at our January meeting, it would be 

tabled until that point, where we could pick up 

discussion. 
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124 

Dr. Roberts: At what January meeting are you 

referring? What are you referring --

Member Beach: To the next Board meeting.

Dr. Roberts: The next? Okay. So, the next one is in 

February --

Member Beach: Oh, I'm sorry.

Dr. Roberts: -- as a teleconference.

Member Beach: Okay.

Dr. Roberts: Okay.

Member Beach: Unless we convene a special 

meeting, and that's up to you. Otherwise, we'll have 

to table it until the 13th, or whenever. When's our 

call? I'm sorry, February --

Dr. Roberts: I don't have the schedule.

Member Beach: February 24th is our next Board 

call, unless we convene a special one.

Member Kotelchuck: We have to have people -- it 

has to be a public meeting. It can't be a telephone 

conference call. People from the public have to be 

able to be there.

I just didn't realize that we had to push the time to 

get it voted on by the end of the day. I thought we 

were considering it, and I assumed it will come up. 

The actual next meeting is April.

Member Ziemer: This is Ziemer.

The February meeting is a public meeting.

Dr. Roberts: That is a public meeting.

Member Kotelchuck: Okay.
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125 

Dr. Roberts: Yes.

Member Kotelchuck: Good. All right. Fine.

Dr. Roberts: That's a public meeting.

Member Beach: So, then, the motion is to table 

until the next February public meeting. I believe 

that was the 24th, correct? So, it needs a second.

Member Anderson: I'll second it. It's Andy.

Dr. Roberts: Okay. Okay. And now, we need to vote 

--

Member Clawson: Sure.

Dr. Roberts: -- on tabling.

Okay. So, Anderson?

Member Anderson: Yes.

Dr. Roberts: Beach?

Member Beach: Yes.

Dr. Roberts: Clawson?

Member Clawson: No.

Dr. Roberts: Field?

Member Field: Yes.

Dr. Roberts: Kotelchuck?

Member Kotelchuck: Yes.

Dr. Roberts: Lockey?

Member Lockey: Yes.

Dr. Roberts: Richardson? Richardson?
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126 

(No audible response.)

Roessler?

Member Roessler: Yes.

Dr. Roberts: Schofield?

Member Schofield: Yes.

Dr. Roberts: Valerio?

Member Valerio: Yes.

Dr. Roberts: Ziemer?

Member Ziemer: Yes.

Dr. Roberts: Okay. And is Richardson able to 

register a vote?

(No audible response.)

Okay. Well, it sounds like, regardless, the majority 

has agreed to, has voted to table this until our 

February 24th meeting.

Member Lockey: And what are we going to do 

between now and then?

Member Clawson: You guys are going to read an 

awful lot.

(Laughter.)

And the thing is, I want you guys to think about this 

because we've been at this. And I want to take 

some of my colleagues because I'm going to get 

into this. There is no time pressures. Time isn't in it. 

But you know what? We can chase this rabbit 

around and around and around. At some point, we 

have to take the decision.
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127 

Ms. Naylor: Brad, this is Jenny with OGC.

And my recommendation is for the Work Group to 

develop a letter to the Secretary that is fully formed 

with the scientific bases, explaining why a certain 

dose cannot be reconstructed; and also, a 

justification, the rationale in support of --

Member Clawson: Jenny, why would we do that 

when we haven't even voted yet?

Ms. Naylor: Well, that's for the Board to consider 

what is the full rationale and, also, the Class 

Definition. And during this period of time, the DFO 

can also work with DOL to make sure that that Class 

Definition is something that they can administer.

So, you can help streamline the entire process, 

come the February Board meeting.

Member Lockey: This is Jim Lockey.

I agree with Brad. I think the Board has to vote on 

it, and then, a little time can be taken to define the 

Class. But I agree with Brad; I want to get, we want 

to get this done. There may be a few other 

questions, but we don't want to spend more than a 

couple of months on this. And so --

Member Clawson: We've already made a strawman 

poll. If they need more justification than that, you 

know -- we based that on Hanford. We based it on 

everything else. We put a lot of work into it. But 

that was just a strawman. It was just so that we 

could look at what we were looking at.

Jenny, I think we're really putting the cart before 

the horse. But you know what? We'll do what we 

need to be able to do and go from there.

Member Beach: Well, it seems to me, if I recall past 

SEC votes, we vote, and then, the next day we pass 
This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been 

reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 

128 

around a definition. I'm kind of wondering why 

we're having to establish all this stuff pre-vote.

Ms. Naylor: This is Jenny with OGC again.

The reason why you actually have a letter the next 

day to be able to vote on is because we worked on 

it in advance of the meeting in anticipation. And so, 

there is actually quite a bit of background work. And 

because you currently don't have a Chair, that's 

why I was asking Brad, who was the champion of 

this SEC Class, to do some work prior to the 

meeting itself as a preparation.

Member Beach: Okay. That makes sense.

Member Clawson: And we can work on that, Jenny, 

but, also, too, if you remember, the other reason 

why that letter was able to be sent around, too, is 

because there was kind of a consensus between the 

Board and NIOSH on which way we were going with 

it. And it's been kind of made apparent to me that 

we don't have that. So, that's kind of an interesting 

twist to have into it, too. We'll work on that, Jenny.

Member Ziemer: Keep in mind we can't forward it to 

the Secretary until we have that letter, anyway. So, 

even if we voted favorably today, we couldn't do 

anything until we had the letter next time.

Dr. Roberts: Right.

Member Ziemer: So, we're going to end up at the 

February meeting either way.

Dr. Roberts: Right. Right.

Okay. Well, my apologies, but I do need to go 

ahead and adjourn this meeting.

It seems like there needs to be some more work on 
This transcript of the Advisory Board on Radiation and Worker Health, Board Meeting, has been 

reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed 

and certified by the Chair of the Advisory Board for accuracy at this time. The reader should be 

cautioned that this transcript is for information only and is subject to change. 

129 

the SEC Class Definition and putting together the 

draft letter in the interim. And then, we will bring 

this on the agenda again in February.

Member Beach: I'll second that.

Dr. Roberts: Okay.

Member Kotelchuck: Okay.

Dr. Roberts: Great. Well, thank you very much, and 

thank you for your engagement through this twoday meeting.

Happy holidays to you, if I don't speak with you.

(Whereupon, the above-entitled matter went off the 

record at 5:35 p.m.)