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UNITED STATES OF AMERICA

DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH

+ + + + +

ADVISORY BOARD ON RADIATION AND

WORKER HEALTH

+ + + + +

TBD 6000 WORK GROUP

+ + + + +

WEDNESDAY

MARCH 28, 2012

+ + + + +

The Work Group convened in the 

Brussels Room of the Cincinnati Airport 

Marriott Hotel, 2395 Progress Drive, Hebron, 

Kentucky, at 8:30 a.m., Paul L. Ziemer, 

Chairman, presiding.

PRESENT:

PAUL L. ZIEMER, Chairman

JOSIE BEACH, Member

WANDA MUNN, Member
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ALSO PRESENT:

TED KATZ, Designated Federal Official

DAVE ALLEN, DCAS

ROBERT ANIGSTEIN, SC&A

JOHN DUTKO*

DAN CHUROVICH*

JENNY LIN, HHS

JOHN MAURO, SC&A

DAN McKEEL*

JAMES NETON, DCAS

JOHN RAMSPOTT*

*Present via telephone
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CONTENTS

Call to Order.......................... 4

Introductory Remarks and Review

of Agenda

Paul Ziemer...................... 4

Update of NIOSH White Paper on 

Doses from Betatron Operations at GSI

Dave Allen, NIOSH................ 8

SC&A Update on Review of NIOSH

White Paper on Doses from Betatron 

Operations at GSI

Robert Anigstein................. 58

Petitioner's Comments on NIOSH White

Paper Update

Paul Ziemer...................... 87

Dan McKeel....................... 174

Review of all Open Issues on SC&A

Findings Matrix for the GSI SEC

Petition Evaluation Report............. 221

Work Group Recommendation to ABRWH on

SEC Petition for GSI................... 275

Adjourn................................ 286
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1 P-R-O-C-E-E-D-I-N-G-S

2 (8:30 a.m.)

3 MR. KATZ: All right. Good 

4 morning everybody in the room and on the line. 

5 This is the Advisory Board on Radiation 

6 Worker Health TBD-6000 Work Group. We're just 

7 getting ready to go. We'll begin with roll 

8 call. We are speaking about a site. So 

9 please speak to conflict of interest. And 

10 we'll do roll call beginning with Board 

11 Members.

12 (Roll call.)

13 MR. KATZ: All right. We have an 

14 agenda for the meeting. It is posted on the 

15 NIOSH website and I believe there is some new 

16 materials on the NIOSH website, too, to go 

17 along with this meeting.

18 And it is your agenda, Paul.

19 CHAIRMAN ZIEMER: Okay, thank you. 

20 We will officially call the meeting to order.

21 I want to take just a moment to 

22 give us an overview of the agenda today and 
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1 then we will proceed from there.

2 First of all we have an update 

3 from NIOSH. Dave Allen has provided -- I'm 

4 going to call it an update -- from his 

5 previous White Paper on the betatron operation 

6 model and that was distributed since our last 

7 meeting and I believe the petitioners also 

8 have a copy of that. And we will take a look 

9 at that.

10 And then we have a document from 

11 SC&A, which is kind of a summary document. It 

12 is dated March 25th and it is called Review of 

13 Addendum to Dose Estimates for Betatron

14 Operations White Paper. And that was 

15 distributed to everyone. I believe the 

16 petitioners also received that.

17 And then we have several documents 

18 from the petitioners and I do intend for us to 

19 look at those in some detail as well this 

20 morning.

21 We have, I'm looking for the dates 

22 on these, but we have actually several 
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1 documents from Dan McKeel and the first of 

2 these, and Dan you may have to help me here, I 

3 have one which was the original critique of 

4 the January White Paper and I want to use that 

5 as well. And then we have the March 11th 

6 document, which was previously distributed.

7 And we have some material from 

8 March 27th, which was emailed and included 

9 with that actually on March 23rd we have a 

10 document called McKeel Response to Allen 

11 Addendum 3, Part I, Items 1 and 2. And then 

12 we have Part II comments. And then I believe, 

13 Dan you put those all together into one 

14 document that you re-circulated but I believe 

15 those are the two most recent ones.

16 MR. ALLEN: That's correct.

17 CHAIRMAN ZIEMER: So we will have 

18 a chance to look at all of those as well.

19 And then we have also distributed 

20 by SC&A the latest updated matrix that has 

21 been distributed and the matrix, I'm looking 

22 for the date on that. It was within the past 
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1 week. Everybody should have gotten that. 

2 March 22nd. And we want to go through the 

3 matrix in some detail as well and look at 

4 those individual items.

5 So we have a good amount of work 

6 before us today to get through all of these 

7 items. My intent was that by the end of our 

8 session we might be able to be in a position 

9 to make a recommendation on the SEC petition 

10 and we will have to see where we are at that 

11 point because there are some new materials and 

12 some new issues that have been raised. So we 

13 will have to see how that develops.

14 So let's proceed first with the 

15 update on the White Paper from Dave Allen. 

16 And Dr. McKeel, let me certainly invite you if 

17 you have comments or questions, as we proceed 

18 you can raise those just as if you were here 

19 at the table. I know you weren't able to 

20 travel today but please don't hesitate to 

21 raise questions as we proceed.

22 Okay, Dave, give us an overview of 
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1 the update and modifications that you have 

2 made.

3 MR. ALLEN: Okay. The addendum 

4 that I put together was based on our last 

5 meeting two weeks ago where some of the 

6 information that came out and I was asked to 

7 recalculate a few things.

8 The beginning of the paper 

9 mentions the two issues that were the primary 

10 reason for recalculating some of the dose and 

11 that was that the lead was not in that double12 leaf door prior to 1968, during the covered 

13 period.

14 And the second was the badges were 

15 not stored in the control room but stored in a 

16 badge rack that had been mentioned is in two 

17 different locations. And I will address that 

18 here shortly.

19 I put the map in there. One of 

20 the two maps we had of the location of the 

21 badge rack. And I recalculated the shot 

22 scenarios based on where the badge rack is in 
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1 this addendum as well as no lead in the door 

2 and simply redid the calculations that we did 

3 in the original White Paper.

4 And I also mentioned a handful of 

5 other issues that had been raised that didn't 

6 require recalculation of dose and why they 

7 didn't.

8 And about halfway through there is 

9 small header that says "Adjusted Values" and 

10 that is the recalculated doses that I have put 

11 together.

12 And then also towards the end Dr. 

13 McKeel wanted, I would say requested or 

14 suggested or whatever, that I put together an 

15 example or some calculations associated with 

16 what I was saying about the residual 

17 radioactivity of the betatron machine itself. 

18 Not much here that would be actually 

19 favorable to include that. So the last part 

20 of this was I just put together an example 

21 calculation, starting with an assumption that 

22 assumed you had five millirem each week from 
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1 this residual activity. What would that mean 

2 for the dose estimate? That is not the 

3 estimate we intend to use. That is a what-if 

4 example at the end of this.

5 And that is an overview. Would 

6 you like more detail?

7 CHAIRMAN ZIEMER: Well perhaps we 

8 could ask some questions and clarify some 

9 issues.

10 Number one, there were two 

11 locations identified for the badge racks. So 

12 would you look at two different sets of 

13 calculations or do those two locations affect 

14 the outcome at all?

15 MR. ALLEN: The one I used is the 

16 one that is in the figure in the addendum. 

17 The two locations were that location and then 

18 one in the office. If you look at the figure 

19 I put in, it is somewhat close to where that 

20 black area is, a little bit more to the left 

21 of that.

22 My thought was that most of the 
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1 radiation that is in the control room I 

2 already knew. I am going to assume that the 

3 rest of that area that most of the dose rate 

4 is caused from what is coming through that 

5 thinner wall in the tunnel there, the 

6 scattered radiation, not the direct radiation 

7 coming through the ten-foot chilled wall but 

8 the thinner, 16-inch wall.

9 The location I chose is further 

10 away from that wall. And in this case, that 

11 gives you a more favorable estimate. Also 

12 with the presentation that Dr. McKeel put out, 

13 it said that that location was changed to the 

14 hallway in 1964 and the bulk of the film badge 

15 data we have come after that.

16 So in reality we have a little bit 

17 before that. We don't know when in '64 or I 

18 don't know when in '64 it was changed. But 

19 the whole concept should work in both 

20 locations because we have some data prior to 

21 that movement, since we have starting in 

22 January of '64 and we have some data after 
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1 that movement.

2 So you could do this type of 

3 calculations in both locations but this one 

4 should have been more favorable.

5 CHAIRMAN ZIEMER: So the idea here 

6 is that to use this location that results in a 

7 higher value in the control room, if you back 

8 calculate.

9 MR. ALLEN: It results in a higher 

10 dose estimate for the layout.

11 CHAIRMAN ZIEMER: Oh, for the 

12 layout people, which is the one that is going 

13 to haul them away, drive it.

14 MR. ALLEN: Yes, because we are 

15 basing it on ten millirem at the badge rack. 

16 And the location I chose is a lower dose rate 

17 at the badge rack than the other location.

18 CHAIRMAN ZIEMER: Okay, any 

19 questions on that part of it?

20 Then --

21 DR. McKEEL: Dr. Ziemer?

22 CHAIRMAN ZIEMER: Yes?
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1 DR. McKEEL: This is Dan McKeel.

2 CHAIRMAN ZIEMER: Sure, Dan.

3 DR. McKEEL: I would just like to 

4 make a clarification. What I actually said 

5 was that the indication I had from the workers 

6 was that that second position was changed 

7 sometime between 1964 and 1966. I don't 

8 really know when. I'm not sure they do 

9 either. So I am just indicating that sometime 

10 during the film badge period, when we had 

11 badges, that location was changed. And it 

12 certainly seemed to me and to the workers that 

13 that second location was farther away from the 

14 control room. So in effect, the badges 

15 sitting there would get a lower dose compared 

16 to what they were given in a more forward 

17 position.

18 MR. ALLEN: Right. I might be 

19 wrong which way you said. The location I 

20 chose gets a lower dose rate --

21 CHAIRMAN ZIEMER: Because of the 

22 walls plus distance or the walls and the 
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1 distance both.

2 MR. ALLEN: Right, because the 

3 bulk of the radiation in that vicinity is 

4 coming through that thin wall. It is 

5 scattered radiation coming through that 16-

6 inch block wall. This is quite a bit further 

7 away than the other one. The other one is 

8 actually fairly close to that 16-inch wall.

9 MEMBER BEACH: So you are using 

10 the one that is closer, not the one that is 

11 further away.

12 MR. ALLEN: It is further away 

13 from the 16-inch wall and I think a little 

14 closer to the ten-foot wall.

15 CHAIRMAN ZIEMER: Well I think he 

16 is saying he is using the one that results in 

17 the --

18 MEMBER BEACH: Highest dose.

19 CHAIRMAN ZIEMER: -- highest dose 

20 to the layout workers.

21 MEMBER BEACH: Right.

22 CHAIRMAN ZIEMER: If you used the 
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1 other one when you do the calculations, you 

2 get lower dose to the workers.

3 MEMBER BEACH: That's what I 

4 thought I heard.

5 DR. MAURO: Excuse me, Paul.

6 CHAIRMAN ZIEMER: Yes?

7 DR. MAURO: Would you mind, I've 

8 been following this very closely. I have read 

9 transcripts and all the material. And SC&A 

10 has been putting out a lot of paper.

11 CHAIRMAN ZIEMER: Right.

12 DR. MAURO: And I find, one of the 

13 things I often do is I try to step back and 

14 say okay what do I see. And I would like to 

15 express very briefly SC&A's position on this. 

16 Well, SC&A's scientific position.

17 When all is said and done, all of 

18 the material that has been distributed and 

19 discussed I see as divided into two major 

20 categories. The original radiography work 

21 with the fish pole, the radium work, and the 

22 betatron work. It is SC&A's position that --
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1 I'm going to make one qualifier -- that there 

2 are no SEC issues associated with any of the 

3 calculations dealing with the betatron. The 

4 only question that Dr. McKeel raised that 

5 really wasn't explored at the last meeting 

6 that one could consider a possible SEC issue 

7 is whether the betatron is a good tool, a 

8 reliable tool that you could trust as a way to 

9 reconstruct doses with sufficient accuracy, 

10 given the fact that there are certain aspects 

11 of the code that are still being so-called 

12 beta tested.

13 But as far as we are concerned, 

14 given that you accept the models as being 

15 sufficiently accurate and reliable, SC&A's 

16 position, there are no SEC issues associated 

17 with any of the calculations, including 

18 everything that we are talking about right 

19 here. However, SC&A's position is there are

20 SEC issues associated with the radiographic 

21 work that was done between 1952 or '53 and I 

22 say right up to 1962 when the health physics 
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1 program took hold with the AEC license.

2 So in order to just sort of -- I 

3 know that the last transcript, I know one of 

4 the statements that we made was that we were 

5 trying to focus in on the SEC issues. That 

6 really was the first priority. And I know 

7 that we have been spending a lot of time on 

8 matters like this which at least from SC&A's 

9 perspective, use it as you see fit, are not 

10 SEC issues. And I just wanted to put that on 

11 the table early so you understand where SC&A 

12 is coming from.

13 CHAIRMAN ZIEMER: Thanks John for 

14 that comment. One of the reasons we are 

15 spending a fair amount of time on some of 

16 these issues is because there are questions 

17 that the petitioners have raised that we need 

18 to answer on their behalf so they understand 

19 why you, SC&A, and NIOSH believe that dose can 

20 be reconstructed for the betatrons as well as 

21 other things that were used during at least 

22 this time period here.
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1 One of the other questions with 

2 the neutrons and the differences, I guess 

3 again that had to do with assumptions made in 

4 the modeling between SC&A and NIOSH but maybe 

5 you could clarify because if we do dose 

6 reconstruction you end up with a particular 

7 model. And then the petitioners have raised 

8 the question about why the doses appear to 

9 have decreased on some of these such as the 

10 neutrons. Maybe you could clarify that.

11 MR. ALLEN: Yes, the way the White 

12 Paper was put together was to explore 15 

13 different shot scenarios and then try to find 

14 the combination of scenarios that would meet 

15 the other criteria we have in ten millirem 

16 badges, in this case at the badge rack, and 

17 the utilization factor that we had in there 

18 for how often it was actually on versus 

19 setting up shots.

20 And with the photon dose for the 

21 betatron operators, that scenario didn't 

22 matter. For layout guide, it did. However, 
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1 for the neutron dose, it was then based on the 

2 timing of those shot scenarios.

3 So I think in both White Papers, I 

4 mentioned how many hours each particular 

5 scenario the Excel Solver came up with and 

6 then the neutron dose rate times those hours 

7 were essentially what I gave to the betatron 

8 operators. When we changed the assumptions 

9 like taking out lead door and moving the badge 

10 rack, it changed dose scenarios and how many 

11 hours and that changed the neutron dose. 

12 That's essentially where we are at 

13 those two. It is not a huge dose and fairly 

14 small compared to the photon dose.

15 CHAIRMAN ZIEMER: Right. Any 

16 questions, Board Members?

17 DR. McKEEL: Dr. Ziemer, this is 

18 Dan McKeel.

19 CHAIRMAN ZIEMER: Yes, Dan?

20 DR. McKEEL: I have a comment and 

21 it is a comment to what Dave Allen just said 

22 and what Dr. Mauro just said.
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1 My concern about the betatron, I 

2 don't think it has been adequately presented. 

3 I'm going to try to present it today and with 

4 a little bit more clarity. But just so 

5 everybody is sure the way I feel about it, I 

6 believe that what we have for both betatrons 

7 is basically MCNPX modeling without any real 

8 data to validate that model. And as I 

9 expressed on 3/15, in my view a model, a 

10 computer model, I don't care how sophisticated 

11 the code may be, it can't be validated without 

12 real data to validate it.

13 And I expressed then and still 

14 feel today that an agreement between models 

15 and real data, at least in the academic world, 

16 is on the order of ten to 20 percent, not 200 

17 percent.

18 And I also pointed out on 3/15 I 

19 really would like it to be addressed today 

20 specifically and not vaguely is that the SC&A 

21 and the NIOSH models which Dr. Mauro did 

22 complement one another and he had no problem 
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1 with believing that the betatron dosage can be 

2 calculated accurately. They don't agree with 

3 each other between 2008 and 2012 and they 

4 don't agree with each other that either of 

5 those time periods are a factor of only 

6 twofold. They differ from each other by a 

7 factor of three to fivefold at the last 

8 meeting. And I pointed that out in my slide 

9 and that slide has been left with all of you. 

10 So I will bring that up later on.

11 For the neutrons, the situation, 

12 as far as I am concerned is much worse. There 

13 is no real actual neutron data. The film 

14 badges did not measure neutrons. So there is 

15 no data of that type. There is no survey data 

16 for either betatron building while the 

17 betatrons were in operation. And we know that 

18 the betatron beam consisted about 15 percent 

19 give or take a little bit which the exact 

20 fraction really has never been determined by 

21 anyone here. But 15 percent is the number 

22 that I have seen represented.
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1 So the betatron beam had a neutron 

2 component to it and the most direct way to 

3 measure that as everybody in the room knows, 

4 is with Bonner sphere. And as far as I know, 

5 not only is there no data like that at GSI, 

6 but nobody has obtained any data like that 

7 from another betatron site and there are lots 

8 of Allis-Chalmers betatrons.

9 So I think you are saying a model 

10 is validated basically by itself done by two 

11 different organizations but not using 

12 independent models. You know, it is Dave 

13 Allen said several times at the March 15th 

14 meeting that he used input files that SC&A 

15 first developed for the betatron. And while I 

16 understand the practical expediency of that, 

17 that still doesn't constitute an independent 

18 model.

19 So I just wanted to put that on 

20 the record. I don't believe there is any real 

21 betatron data to go by except for, we'll talk 

22 about that I hope, the film badges themselves, 
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1 which is very limited. I'll let it go at 

2 that. Okay?

3 CHAIRMAN ZIEMER: Okay, thank you. 

4 I don't know if either NIOSH or SC&A wants to 

5 respond to those comments. Bob?

6 DR. ANIGSTEIN: Yes, I have 

7 several responses to Dr. McKeel's comment.

8 First of all in terms of 

9 validation, the MCNP code has been around for 

10 decades I think, at least since the 1960s. It 

11 has been validated innumerable times by 

12 innumerable studies. All the aspects of the 

13 code has been validated with the ones that I 

14 have heard of or very closely corresponded 

15 within two percent.

16 As far as this particular model is 

17 concerned, because it was then -- because part 

18 of our model was adopted by NIOSH, it puts us 

19 in an unusual position because we had an 

20 internal discussion about this by SC&A. Then 

21 they asked to review its own model, 

22 essentially. So we went to an outside expert, 
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1 somebody who had worked for SC&A in the past 

2 but had not ever done original calculations 

3 for the NIOSH program, the OCAS program. He 

4 had just done QA.

5 And he is Michael Mallard who is a 

6 MCNP, Ph.D., CHP, has a been number of years 

7 with Los Alamos, which is where the MCNP code 

8 was first developed and still continues to be 

9 under development.

10 He independently reviewed all the 

11 assumptions, the input files, and he found 

12 perfect agreement. Correction. He found a 

13 transcription error of three thousandths of an 

14 inch in one of the contours of the aluminum 

15 columns in one spot on the periphery and the 

16 machine tolerances were five thousandths of an 

17 inch. So I consider that to be adequate 

18 conformity.

19 In terms of the neutron component, 

20 what Dr. McKeel I believe is referring to are 

21 medical betatrons. Now it is the same tube 

22 inside but the construction is very different. 
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1 In medical facilities, space is limited. And 

2 the primary concern is shielding against 

3 photons. So the most effective photon shield 

4 within reasonable cost is lead. So the 

5 medical facilities use a lot of lead 

6 shielding, which is very effective against 

7 photons per inch or per linear inch of the 

8 shield, but not very effective against 

9 neutrons.

10 Whereas, at industrial facilities 

11 such as GSI, they have a lot of space 

12 available. They resort to more cheaper 

13 material such as sand and concrete. So there 

14 is first of all much more distance involved. 

15 They don't come within the -- I forget what 

16 the betatron shooting room is but it is on the 

17 order of 50 to 100 feet. Yes, I do remember 

18 it now. The numbers come back to me. Outer 

19 dimensions are 97 feet in one direction, 112 

20 feet in another direction. And also the sand 

21 and concrete, lower atomic number materials 

22 are actually more effective against neutrons.
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1 So the neutron-to-photon ratio is 

2 very different for this industrial facility 

3 than it would be for a medical facility. But 

4 the measurements are not made right up close 

5 to the betatron. They are made in occupied 

6 areas where people have access while the 

7 betatron is on. So that would account for the 

8 difference in the neutron/photon ratio.

9 As far as the neutron generation, 

10 that is done entirely within the MCNP model, 

11 where the electron beam strikes at the target. 

12 We have very accurate drawings of the 

13 configuration of the target. The actual 

14 design drawings, we reproduced them pretty 

15 correctly in the MCNP input file. And what 

16 happens is the electron beam hits the target. 

17 Its primary purpose is to generate 

18 bremsstrahlung photons. And at the same time, 

19 because of the electronuclear interaction a 25 

20 MeV electron hits a neutron, hits a nucleus, 

21 where binding energies are on the order of ten 

22 MeV, it liberates some neutrons.
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1 And again, the latest version of 

2 the code uses the latest physics. I mean, 

3 basically as I recall, I'm not quoting, the 

4 regulation under which we are operating is the 

5 82 point, federal guidance under which we are 

6 operating says we should use the latest 

7 science. Meaning, we should use this year's 

8 science, not science ten years from now which 

9 may very well advance but the current science. 

10 And the current science is what is in the 

11 latest release of the MCNPx code, where the 

12 team, MCNPx development team, continuously 

13 researches the literature and they construct 

14 the cross-section and the data files, go 

15 through every model, there are two components 

16 at least. There is the algorithms, how do you 

17 -- what are the physical laws governing a 

18 certain interaction, in this case the high19 energy electron hitting the target and then 

20 what numerical data do you use, do you input 

21 into that model.

22 So the algorithm I don't think 
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1 changes much but the numbers that you use, the 

2 data gets updated periodically as new research 

3 in physics gets published and evaluated and 

4 accepted and they use the ENBSF, I believe it 

5 is, the evaluated nuclear data file that is 

6 maintained -- it is maintained at Brookhaven 

7 National Laboratory but is essentially an 

8 international collaboration to allow people 

9 such as the MCNPx developers, among others, to 

10 access the latest data. They don't have to 

11 search the literature themselves. This is 

12 already done by people, it is a full-time job, 

13 who research the literature, evaluate it, when 

14 they see there are findings, new publications 

15 which meet the test of being acceptable, they 

16 are incorporated into this file.

17 So I think we are using the very 

18 latest and the very best science available to 

19 do this.

20 CHAIRMAN ZIEMER: Thank you, Bob.

21 DR. McKEEL: Dr. Ziemer?

22 CHAIRMAN ZIEMER: Yes?
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1 DR. McKEEL: I must respond. 

2 Because what I am saying is being misconstrued 

3 and so let me put it another way.

4 In my opinion and I believe this 

5 is the way it is, MCNPx or ATILLA, which NIOSH 

6 first used to do their models, that is a tool. 

7 It is a piece of computer software that does 

8 many things but falls under the broad general 

9 paradigm of transport code.

10 Now that tool, just like you would 

11 use an electron microscope in my work or a 

12 light microscope or a phase microscope, or a 

13 differential interference microscope, they are 

14 tools. And you apply those tools to a 

15 particular model. And in this case, there 

16 were many models with various source terms 

17 that OCAS-IG-003 mandates must be all models 

18 accurately, with sufficient accuracy to comply 

19 with the mandate of the EEOICPA Act as 

20 amended.

21 Now, then you apply the tool MCNPx 

22 to a problem. And the problem is to model the 
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1 betatron output doses for photons and neutrons 

2 which should simplify things. That problem --

3 that the use of MCNPx the tool has to be 

4 validated for that problem.

5 I agree that the code itself, the 

6 lines of code, the subroutines, et cetera,

7 that they have been validated for other 

8 problems I am sure many times. I have seen 

9 many, many articles. But the point I am 

10 trying to make is, and I have sent these to 

11 the Work Group and the full Board and made 

12 comments about them. There are many papers in 

13 the literature where MCNPx, the tool, the 

14 software tool is applied to a given problem 

15 and then the investigator writes up a paper 

16 and presents it to a peer-reviewed article or 

17 journal to be published. And as part of that 

18 submission, the peer-reviewed journals insist 

19 that you have not only the model results with 

20 the tool MCNPx but a real-world validation 

21 that the values generated are accurate.

22 And for instance I sent you one 
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1 where MCNPx was used to model neutrons. Well 

2 the neutron real data is measured with Bonner 

3 spheres. And I am saying we do not have any 

4 kind of data like that for the betatrons.

5 So you know, we can go around and 

6 around with this argument. I personally think 

7 that the -- and to be honest with you, I 

8 really want this to go before the entire 

9 Board. The Board has previously ruled that 

10 the radon model, for example, that was first 

11 generated by SC&A, based on sound premises, 

12 was not valid. And the full Board agreed with 

13 that. The Work Group got deadlocked on it. 

14 The full Board voted the radon model was not 

15 valid.

16 So there is another example that 

17 yes, the methodology was well-explained and so 

18 forth and actually NIOSH and SC&A both agreed 

19 that it was a good model but the Board 

20 rejected it. I am asking the Board to do the 

21 same thing now based on the same kind of 

22 reasoning. That there is no measured real 
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1 data against which to validate this particular 

2 use of the MCNPx software tool.

3 And I think I will let it go at 

4 that.

5 CHAIRMAN ZIEMER: Okay, let me add 

6 a comment here that typically one does not use 

7 the system that you are trying to model to 

8 validate the modeling approach. That would be 

9 a circular argument. 

10 The MCNP model has been 

11 independently validated against other systems. 

12 It would be like if I want to calibrate a 

13 balance, I don't use the weights that have 

14 been weighed on that balance to calibrate the 

15 balance. I have to have those weights 

16 independently calibrated. And that is, I 

17 think the argument you are making. It sounds 

18 --

19 DR. McKEEL: No. No, that is not 

20 the argument I am making. I understand that. 

21 I agree with you.

22 CHAIRMAN ZIEMER: Well the only 
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1 reason for using the model is because you 

2 don't have the data. We don't have Bonner 

3 sphere data for this.

4 DR. McKEEL: That's exactly right.

5 CHAIRMAN ZIEMER: And that is why 

6 you use the model, that is the MCNP code to 

7 generate the information because the physics 

8 of it are very well known. We have the 

9 information about the beam. We know the 

10 energies. So we have the known basic data 

11 from the operation. Then the code, which has 

12 been validated independently then generates 

13 the information about the photon and neutron 

14 output.

15 DR. McKEEL: Well let me ask you a 

16 question then.

17 CHAIRMAN ZIEMER: If I already 

18 have Bonner sphere measurements for these 

19 beams, I wouldn't need to use that code. 

20 That's the only point I'm making.

21 DR. McKEEL: All right. Well, let 

22 me ask you a direct question.
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1 CHAIRMAN ZIEMER: Yes.

2 DR. McKEEL: Are you aware of any 

3 paper in the literature published ever that 

4 has used MCNPx to model an Allis-Chalmers 24 

5 to 25 MeV betatron?

6 CHAIRMAN ZIEMER: I'm not 

7 personally but I haven't looked for one.

8 DR. McKEEL: Has anybody ever seen 

9 such a paper?

10 DR. ANIGSTEIN: I'm not aware of 

11 it. Probably one reason would be that there 

12 are only in the United States two operating. 

13 The last I heard, there were two operating 

14 Allis-Chalmers 25 MeV betatrons. This is a 

15 tool that is now obsolete. It has been 

16 replaced by a much newer --

17 DR. McKEEL: Dr. Anigstein, these 

18 machines have been out in the marketplace and 

19 used for 40 years. And there are betatrons --

20 no. The betatron model itself is not at all 

21 obsolete. There are betatrons being sold 

22 today generally in the six to ten MeV range 
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1 that are portable and are used widely for NDT 

2 work. So there is plenty of opportunity to 

3 have such papers appear in the literature. 

4 I'm just not aware that I have ever seen one. 

5 And I am calling on everybody this 

6 morning. If you have seen one, please tell me 

7 what it is. Put it on the record.

8 I'm saying there is no -- there is 

9 a principle in science that things are not 

10 accepted unless they are replicated. And I am 

11 saying that this is a first issue.

12 And going back to Paul's analogy 

13 about the weight, yes he used a weight that is 

14 calibrated by the National Bureau of Standards 

15 but what you actually do when you put 

16 something on that scale is you are using it to 

17 calibrate the scale. So if you put a ten-gram 

18 weight on there and the balance shows it 

19 weighs 20 grams, then that balance is not 

20 validated. And that is what I am trying to 

21 tell you, that there is no National Bureau of 

22 Standards gold standard. There is a code 
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1 which has been validated but it has not been 

2 validated for measuring betatrons and its 

3 output. And I would also just like to put on 

4 the record right now that the model that is 

5 used by both SC&A and NIOSH is very 

6 simplistic. The betatron have a lot of other 

7 components to its radiation emissions.

8 For example, there has never been 

9 any modeling of the leakage from the beam from 

10 the machine itself. Not from the cone but 

11 through the column itself.

12 In the earliest days when I worked 

13 with an electron microscope, which is really 

14 an electron particle accelerator that sends 

15 the beam down and bounces off a target that 

16 you visualize to examine usually biologic

17 tissues or very thinly cut materials. And 

18 those machines from the beginning had inherent 

19 leakage. They were much lower voltage, you 

20 know, 50, 100 keV but there was leakage 

21 through the columns. None of that has been 

22 quantified in this entire exercise over these 
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1 four years. And it is very naive not to do 

2 that.

3 So you know, this model is a 

4 simple model of how a betatron would operate. 

5 And it is not productive to carry this 

6 forward anymore other than to say I don't 

7 believe that you have real-world data to 

8 validate this model.

9 I'll just let it go at that.

10 CHAIRMAN ZIEMER: Okay, thank you. 

11 John has a comment, John Mauro.

12 DR. MAURO: I just want to point 

13 out that I understand what Dr. McKeel is 

14 saying. And quite frankly, recently I have 

15 been engaged in a similar type of situation 

16 where a company was designing an accelerator 

17 for medical purposes and they were putting in 

18 place the tech specs, the design. All the 

19 physics was done, all the shielding was laid 

20 out. The whole program was put in place. And 

21 all the modeling was done to predict the 

22 fields with and without the patient, that sort 
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1 of thing.

2 And one of the tech specs, just as 

3 far as operations go, is that once a year 

4 their license to operate this requires a team 

5 to come in with the machine on and take 

6 measurements at various locations outside the 

7 envelope, the shielded envelope, to see in 

8 fact if there is any leakage or is any 

9 surprises.

10 So I would say to take the side of 

11 Dr. McKeel to a certain degree, yes. One of 

12 the things for defense in depth you do at 

13 least in the medical community today is to 

14 confirm that the machine is in fact performing 

15 as designed and as originally tested when it 

16 was installed and then annually come in.

17 Now, a thought that came to mind 

18 is that we did not talk about, the degree to 

19 which these types of annual tests might have 

20 been performed. It sounds like perhaps they 

21 weren't. I don't know. It is not so much --

22 You know, is the machine performing the way it 
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1 was originally designed and spec'ed for? I 

2 guess we haven't had that conversation and it 

3 is a legitimate question. It is something 

4 that is done today. To the degree to which it 

5 wasn't done, how serious a challenge is that 

6 to our ability to reconstruct doses is 

7 certainly a legitimate question. So I think 

8 that out of this conversation comes that 

9 legitimate question.

10 DR. McKEEL: Dr. Mauro, I 

11 appreciate that support. And I would just 

12 like to point out that a long time ago John 

13 Ramspott and I pointed out to you all that ‘ 

14 identifying information redacted’, the paid 

15 consultant that NIOSH CDC used to get 

16 information about the residual radiation from 

17 the betatron once -- I mean his first job was 

18 with Allis-Chalmers. And ‘ identifying 

19 information redacted’, who John and I 

20 interviewed personally face-to-face in 

21 Wisconsin who since John has talked to a 

22 number of times, told us that in the early 
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1 days every single Allis-Chalmers betatron 

2 installation was, upon installation by Allis3 Chalmers, or Picker, or whoever was doing the 

4 installation, there are only a few people that 

5 could do those installations, that they made a 

6 formal survey of the betatron facility.

7 And of course as soon as I heard 

8 that, I said oh, that is fantastic. I said, 

9 so ‘ identifying information redacted’ do you 

10 have any of those? And ‘ identifying 

11 information redacted’ had said at the 

12 beginning that he bought the access the West 

13 Allis/Allis-Chalmers betatron group when it 

14 went out business and stopped selling and 

15 making betatrons. ‘ identifying information 

16 redacted’ said well he had them for a little 

17 while and then because of space limitations 

18 for his filing, he destroyed them. He threw 

19 them all away.

20 Now that is ‘ identifying 

21 information redacted’. That is one person. 

22 That is the copies he had. But what I am 
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1 saying is there were dozens and dozens of 

2 Allis-Chalmers betatrons scattered around the 

3 country, including in hospitals in St. Louis 

4 and other places.

5 And so as far as I am aware, that 

6 information was out there. At least the maker 

7 of the betatrons thought it was important not 

8 to survey the building at the outset. We 

9 don't have that data. We don't have that data 

10 for any betatron facility, even though there 

11 are many.

12 And the other thing I want to say 

13 is that I was not talking about medical 

14 betatrons. Some of the papers have to do with 

15 medical betatrons back in the days of the 

16 industrial betatron used at GSI and similar 

17 facilities.

18 You know, I ran across recently a 

19 paper that John had showed me before on 

20 decommissioning accelerators and among the 

21 five examples there they gave a 22 MeV linac 

22 that had been decommissioned. And in the 
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1 table that accompanied that, they listed four 

2 betatrons in that dose range and a little bit 

3 higher that had been junked at Los Alamos.

4 So Los Alamos is a covered site. 

5 It has SECs. There has been extensive 

6 information about it. I'm sure that that 

7 would be a terrific source to go and look for 

8 betatron facility measurements, real-world 

9 measurements. You know, if they didn't do it, 

10 then there is something very, very wrong.

11 We rely on the Los Alamos betatron 

12 manual for comments about safety, the safety 

13 program at GSI. So I think the data is out 

14 there. I think Dr. Mauro is right. I think 

15 in the early 1950s, the manufacturer realized 

16 that these machines had to be -- the radiation 

17 flux field had to be measured and quantified. 

18 And I think it is a terrible shame that those 

19 data have not been preserved and have not been 

20 found. They must exist.

21 So yes, the fact that there are 

22 not very many betatrons, the betatron we saw 
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1 in 2006 at West Allis crashed to the ground. 

2 And so they now have a 6 MeV linac in there 

3 now.

4 But the other point about the 

5 industrial betatron that we need to talk about 

6 as far as leakage, they were not as well 

7 shielded either as our modern or then medical 

8 betatron. So you know, that would mean, I 

9 think, that the leakage from the columns in 

10 the machine itself was probably greater than 

11 the medical ones and there was even more need. 

12 But as you all well know from dozens of 

13 sites, you know, safety precautions gave way 

14 to financial expediency and concerns about 

15 liabilities that management had at many of 

16 these sites. And there was a rush. There was 

17 a national urgency to get the job done.

18 So all of those things figure into 

19 the equation but I'm just arguing we do not 

20 have all of the data that was available on 

21 betatrons, that probably still is available on 

22 betatrons, to characterize the radiation field 
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1 that it gives off in any other than a very 

2 simplistic way.

3 So, I'll let it go at that.

4 CHAIRMAN ZIEMER: Okay, thanks.

5 MR. RAMSPOTT: Dr. Ziemer?

6 CHAIRMAN ZIEMER: Yes John, go 

7 ahead.

8 MR. RAMSPOTT: Yes, if I could 

9 make a brief comment.

10 CHAIRMAN ZIEMER: Yes.

11 MR. RAMSPOTT: We have done a lot 

12 of homework on the betatrons and when you 

13 start looking at MCNPx and betatrons, the most 

14 common names you see is Dan McKeel and John 

15 Ramspott, at Los Alamos. There was not much 

16 investigation of what a betatron would do. 

17 And I totally respect some of these codes. 

18 They are very reputable, honorable. You 

19 didn't look at a betatron. That is the 

20 problem.

21 And then the second half of this 

22 actually lends to what Dr. Mauro was just 
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1 talking about he is doing an extensive study 

2 and the big problem you have that I think is 

3 an SEC issue at GSI, betatron. You're right. 

4 You say you know the energy and you know the 

5 spectrum. You don't know what they examined 

6 with it, though. That is the problem. There 

7 is no shot records. You don't know if they 

8 were looking at a piece of uranium or if they 

9 were looking at a massive casting.

10 And at the meeting in St. Louis 

11 about four years ago, I clarified and I had 

12 members of the Board actually confirm for me 

13 that there are three sources of neutrons when 

14 a betatron fires off. The target, I heard the 

15 target discussed. Dr. Anigstein talked about 

16 the target and that was one. But the casting 

17 itself without neutrons, 15 percent of the 

18 beam is neutrons. And everybody keeps talking 

19 about the target. That is one little piece of 

20 the pie. 

21 But the main thing I think that 

22 causes you problems that you don't have enough 
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1 information for sufficient accuracy of any 

2 doses is what did they use the betatron on? 

3 How much did they use the betatron versus the 

4 sources? Those are big issues. We are not 

5 just talking about a hardware issue. We are 

6 talking about the actual material that was x7 rayed. And then what happens?

8 You don't see much in any 

9 literature of the what happens. That is just 

10 the quick comment I would like to make. Thank 

11 you.

12 CHAIRMAN ZIEMER: Okay, thanks. 

13 And Bob has a comment.

14 DR. ANIGSTEIN: Yes, I have got a 

15 number of comments I have been accumulating 

16 while the discussion was going on.

17 Going back earlier to Dr. McKeel, 

18 the use of models in physics. If every 

19 calculation had to be validated, then there 

20 would be no point in having calculations. 

21 There will be no point in doing theoretical 

22 physics. As a nuclear physicist, the purpose 
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1 of experiments in physics are always to 

2 confirm or question an existing theory. Not 

3 the other way around. The theory is not there 

4 to supplement the experiment. The experiment 

5 is there to supplement the theory. Otherwise, 

6 all theoretical physicists should retire and 

7 only technicians should be working in physics 

8 and competent technicians making measurements 

9 and recording the data. That is not the way 

10 science works. Science is built on theory and 

11 the observations and the experiments are there 

12 to validate the theory.

13 If every single prediction had to 

14 be validated, if we had to predict -- well I 

15 can go on with some trivial examples, which I 

16 won't bother.

17 Secondly, this business about the 

18 neutron. There was a mistake in conception of 

19 what fraction of the beam is neutrons. The 

20 beam is not neutrons. The beam is the 

21 bremsstrahlung radiation, which means a high 

22 energy electron hits a target and it is 
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1 suddenly stopped. And bremsstrahlung is 

2 German for braking radiation; braking B-R-A 

3 like the brakes on a car. And with that high 

4 energy, it is predominantly going forward. So 

5 you have an intense beam going to the front 

6 but not entirely. It spreads out to the right 

7 of the -- you could draw a whole spectrum over 

8 the angles. As you get further away and 

9 further away from forward direction, it drops 

10 off.

11 Now the neutrons are generated by 

12 entirely different mechanisms. They are 

13 generated by an activated, briefly activated 

14 nucleus of the platinum atoms. And it is 

15 essentially isotropic, meaning it goes on all 

16 directions. So depending in what orientation 

17 you are to the betatron, you will get a 

18 different neutron-to-photon ratio. Then in 

19 terms of leakage, leakage when it applies to 

20 let's say an x-ray tube, which is how in the 

21 heavily shielded housing and is supposed to 

22 only be going in a forward direction but in 
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1 reality internally, x-rays go in all 

2 directions. And how well the head is shielded 

3 in terms of the leakage, if there is a crack 

4 in the lead or the lead is made in more than 

5 one piece, and they are not properly drawing 

6 together, you will have leakage.

7 This concept does not apply to the 

8 betatron. The betatron is actually extremely 

9 simple. Dr. McKeel said simplistic. It is 

10 not simplistic. It is simple. It is a very 

11 simple matter of a high energy electron, I 

12 mean how you get the electrons to get into the 

13 beam, how you get them into the electron, how 

14 you get them to go into the storage ring and 

15 stay, that is very complicated physics. But 

16 that does not generate any appreciable 

17 external radiation. The external radiation is 

18 generated when it hits the target and it goes 

19 forward.

20 And yes, we did not include all of 

21 the components but we don't need them. And if 

22 we put in other components, there would simply 
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1 be additional shielding. By leaving it out, 

2 it becomes, we maximize the exposure. We make 

3 it more claimant-favorable, if you will, by 

4 increasing the exposure rate and a dose rate 

5 in various external locations.

6 Then furthermore, as far as Los 

7 Alamos, my colleague Richard Olsher who worked 

8 on these MCNP calculations, he was actually my 

9 instructor -- I took a course at Los Alamos 

10 ten years ago, almost 11 years ago on the MCNP 

11 code -- actually and this is documented, it is

12 in my report, he actually was at that point 

13 responsible. He was the health physicist 

14 responsible for radiation safety and that 

15 included the betatron. And he asked to make a 

16 measurement inside the betatron room and he 

17 was told, well policy is you shouldn't go in 

18 for five minutes -- he said for a couple of 

19 minutes. He went in five minutes later to 

20 check the betatron. He could not measure any 

21 radiation in that room five minutes after the 

22 betatron was shut off.
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1 So this calls into question Mr. ‘ 

2 identifying information redacted’'s 

3 observation that it took 15 minutes for it to 

4 die down. And it was an Allis-Chalmers 

5 betatron, maybe slightly lower voltage at that 

6 time. Originally their standard model was 22 

7 MeV and then they gradually improved the 

8 circuitry by putting a capacitor back or 

9 something and they were able to get it up to 

10 25. It was basically the same tube.

11 So that again contradicts. We 

12 have one -- I mean if you want to talk about 

13 scientific validity, you have one recollection 

14 from Mr. ‘ identifying information redacted’

15 many, many years later. He had no notebooks. 

16 He had no data to prove it. It was not 

17 confirmed. This was something he recollected. 

18 We take it for what it is worth. We don't 

19 dispute it but the fact is if there was that 

20 kind of radiation, the workers' film badges 

21 would have shown it.

22 CHAIRMAN ZIEMER: Well, stick to 
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1 the issue of the model.

2 DR. ANIGSTEIN: Okay. But I think 

3 this is as, in my opinion, this is about as 

4 robust a model as you will find. And the fact 

5 that it has not been specifically validated 

6 for an Allis-Chalmers betatron, the opinion of 

7 experts such as my colleagues with the MCNP 

8 specialist does not invalidate it.

9 CHAIRMAN ZIEMER: What you are 

10 saying about the neutrons in terms of the way 

11 you modeled it, if you had put samples in the 

12 beam, as John Ramspott suggested, what would 

13 that do to the --

14 DR. ANIGSTEIN: Oh. The neutron 

15 emission included the emission of neutrons 

16 from the target because that is one of the 

17 capabilities of the code, which has now been 

18 finally finalized, you would say, word I don't 

19 like to use. I mean, the code is now in the 

20 public domain.

21 Earlier in 2008 we are using an 

22 early version of the code that was still under 
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1 development.

2 Oh yes, and the differences Dr. 

3 McKeel pointed out between 2008 and 2012. 

4 First of all, we changed -- we had a new 

5 drawing. We found a drawing of the new 

6 betatron building in this 1968 application for 

7 the cobalt-60 -- the 80-curie cobalt-60 source 

8 and so these were much more detailed. They 

9 were done on the spot by the people doing the 

10 radiation safety surveys. They had 

11 dimensions. They were hand-drawn. They were 

12 not, I wouldn't call it engineering drawings. 

13 They were not exactly to scale but the 

14 dimensions were listed. The material of the 

15 walls was carefully described.

16 And so we changed it from what we 

17 had originally were the FUSRAP reports where 

18 they had no interest in those kind of things. 

19 And it was simply a scale drawing. They gave 

20 no dimension. They say well you put a scale 

21 there and I had to go on the computer and 

22 calculate well this distance is so many pixels 
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1 on my graphics program and that corresponds to 

2 so many feet in doing a translation. So it is 

3 not surprising that the dimensions would have 

4 changed somewhat. There was a wall that

5 wasn't there earlier. I'm just saying earlier 

6 in terms of our time, later in terms of when 

7 the drawing was produced. They probably, they 

8 most likely had knocked down a wall.

9 CHAIRMAN ZIEMER: Well bottom line 

10 on the targets. So let's --

11 DR. ANIGSTEIN: So on the targets, 

12 yes we picked the HY-80 steel, which we were 

13 told by the metallurgist that was part of the 

14 group of workers who we interviewed back in 

15 2007 and the gentleman is recently deceased, 

16 who had a very clear knowledge. He even lent 

17 me some datasheets on this HY-80 steel. They 

18 had HY-80. They had something called HY-100, 

19 which turned out to be mostly the physical 

20 characteristics were a little different. The 

21 chemical composition was almost identical. He 

22 also said that they used I think it was a 
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1 high-manganese steel, if I remember correctly, 

2 which we also modeled back in 2008 and didn't 

3 find very much difference. It is not highly 

4 sensitive to the details of what particular 

5 alloy. Yes, there are differences. And what 

6 at least SC&A has done with the model that 

7 SC&A is proposing for the layout man, is a 

8 maximizing model. And this is, in our 

9 opinion, the highest plausible dose that a 

10 person working in that location could get over 

11 a period of a year. Not any particular hour 

12 or any particular minute. But if you take it 

13 over a period of a year, they are not always 

14 going to use a casting that would give you the 

15 absolute highest possible emission and in the 

16 worst possible location and the worker being 

17 in the worst possible location. That is just 

18 not plausible.

19 What we have is an upper bound 

20 which in all honesty it is probably a way over 

21 statement. I don't think anyone would have 

22 been in that position all year long with a 
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1 casting in that position. But this is an 

2 upper bound which is highly unlikely. We are 

3 not working at 100 percent certainty. The 

4 criteria, like in the IREP code is the 99th 

5 percentile and NIOSH has often used like the 

6 95th percentile individual to be sufficient 

7 bounding. At that level, it is confident that 

8 this would not have been exceeded. Once in a 

9 million, maybe, but on the order of one in a 

10 100 or five in a hundred, highly unlikely that 

11 the dose that we calculate would have been 

12 exceeded.

13 CHAIRMAN ZIEMER: Okay. Any other 

14 comments on that issue? We have Dr. McKeel's 

15 concerns. We understand what SC&A has done. 

16 The only other issue on this, I 

17 guess, is the differences in the numbers that 

18 SC&A generated versus NIOSH. And in both 

19 cases, as I understand it you are using that 

20 as examples. But is there an agreed-upon --

21 If you were to use this in dose 

22 reconstruction, is there an agreed-upon 
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1 distribution such as NIOSH developed with your 

2 what was it called, that optimizing code --

3 MR. ALLEN: The Solver.

4 CHAIRMAN ZIEMER: -- the Solver; 

5 the Solver approach. And SC&A look at that 

6 approach. And does that make sense to you 

7 guys?

8 If one were to accept the modeling 

9 approach, is that Solver --

10 MR. ALLEN: I think that is where 

11 the disagreement is right now, if I am not 

12 mistaken.

13 I don't know if SC&A has a problem 

14 with the Solver or not but to put words in 

15 Bob's mouth here, you can correct me if I am 

16 wrong, what he has written is he takes some 

17 issue with the scenarios that I put together 

18 and the -- well I think you mentioned the 

19 location of the badge rack, too.

20 DR. NETON: It was the modeling of 

21 the badge rack.

22 DR. ANIGSTEIN: I have -- I mean I 
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1 am ready whenever we are ready --

2 CHAIRMAN ZIEMER: Let me see. Let 

3 me see if there is any other question on --

4 DR. NETON: I think as a basic 

5 approach, can we reconcile the exposures using 

6 the available film badge data, using Dave's 

7 model versus the SC&A model --

8 CHAIRMAN ZIEMER: Right.

9 DR. NETON: -- which doesn't take 

10 that into account at all and just comes up 

11 with a worst-case shot scenario to the layout 

12 man regardless of what the badge readings have 

13 produced. That is the difference.

14 So there is no doubt SC&A's model 

15 has the higher values.

16 CHAIRMAN ZIEMER: So your model, 

17 you didn't normalize to the value.

18 DR. ANIGSTEIN: Let me -- can I --

19 CHAIRMAN ZIEMER: Yes, go ahead.

20 DR. ANIGSTEIN: It would be easier 

21 if I could make my presentation. That will 

22 answer the question.
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1 DR. MAURO: You realize that we 

2 are talking about an issue that goes toward 

3 what is the best way to do that that is 

4 plausible and claimant-favorable.

5 CHAIRMAN ZIEMER: Right.

6 DR. MAURO: We are not 

7 challenging. This is not an SEC issue. This 

8 is purely --

9 CHAIRMAN ZIEMER: Yes, I 

10 understand that.

11 DR. MAURO: I mean, it is very 

12 important because it is so easy to find 

13 yourself going down a pathway. We spent a lot 

14 of time --

15 CHAIRMAN ZIEMER: Well it becomes 

16 an SEC issue if in fact one concludes that you 

17 can't bound. So you have to talk about can 

18 you bound the dose.

19 DR. MAURO: Yes. Okay, I guess I 

20 leaped forward. I thought that someplace in 

21 this discussion is scientific agreement on 

22 what is the best way to bound a dose. But it 
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1 is there. It is just a matter of the 

2 judgments being made.

3 CHAIRMAN ZIEMER: Right. But I 

4 think both of you have said you believe you 

5 can bound the dose. You just have to convince 

6 the Work Group that you can bound the dose. 

7 And I think we are also listening to the 

8 petitioner, who is challenging whether or not 

9 this approach bounds the dose.

10 So I want to get all the parts on 

11 the table.

12 DR. McKEEL: Dr. Ziemer, this is 

13 Dan McKeel.

14 CHAIRMAN ZIEMER: Yes?

15 DR. McKEEL: A very short thing. 

16 I want to put on the record the concluding 

17 paragraph to Dr. Anigstein's four-page review 

18 of Dave Allen's work. And you know, this is 

19 really not the same that I am going to read to 

20 you as what he has said in this room today.

21 It says, "In summary, we conclude 

22 that the analyses presented by Allen (2012a 
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1 and 2012b) represent a major advance over the 

2 betatron studies described by Allen and Glover 

3 in 2007. However, we believe that further 

4 revisions are required in order for the 

5 results to be scientifically correct and 

6 claimant-favorable." And we are not hearing 

7 that this morning. We are hearing that NIOSH 

8 and SC&A agree and that doesn't square with 

9 what is written down on this piece of paper.

10 CHAIRMAN ZIEMER: No, I don't 

11 think that is what they said. Both of them 

12 said that they agree that it can be bounded 

13 but where they disagree is on exactly what you 

14 just read and I think Bob is going to go 

15 through that now for us.

16 DR. McKEEL: Okay.

17 CHAIRMAN ZIEMER: It has to do 

18 with the issue of what constitutes a claimant19 favorable bounding, if this approach is used.

20 Bob.

21 DR. ANIGSTEIN: Okay, thank you.

22 CHAIRMAN ZIEMER: And just for 
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1 those on the phone, Bob has some slides that 

2 he is presenting here which I think summarize 

3 what is in the paper, I believe.

4 DR. ANIGSTEIN: Correct. 

5 Summarize and amplify. 

6 CHAIRMAN ZIEMER: I suppose after 

7 Jenny Lin looks at these, we can probably make 

8 these slides available also to the folks on 

9 the phone. We can email them at some point.

10 MR. KATZ: If you send them to me 

11 I'll distribute them to everyone, including 

12 Dr. McKeel and John Ramspott.

13 DR. ANIGSTEIN: Well first of all, 

14 I want to -- this is reproducing from my 

15 previous report and Dave has included that in 

16 his report where --

17 CHAIRMAN ZIEMER: This is, for 

18 those on the phone, we are looking at the 

19 diagram that also appears on page two of Dave 

20 Allen's report. It is the diagram of the new 

21 betatron building showing the film badge rack 

22 location.
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1 DR. ANIGSTEIN: Right. So this is 

2 basic information I got from one of the 

3 betatron operators I spoke to. And so this is 

4 where, this is the basis of -- I'm really 

5 presenting Dave Allen's work. This is the 

6 basis of Dave Allen's work.

7 However, here is the model from 

8 the MCNP file that Dave Allen kindly shared 

9 with me and the critique I have here is, here 

10 is the building. Here are interior walls 

11 according to, again, recent information passed 

12 on by Dr. McKeel from one of the workers. 

13 There is all kinds of equipment here, which I 

14 would expect. Even I would assume that 

15 without being told specifically. And Dave's 

16 model, if he'll forgive me for saying this, is 

17 empty space.

18 There is a wall here which utilize 

19 the wall, the density of the concrete from the 

20 2008 SC&A report where we have no knowledge as 

21 to what this wall is made of and, therefore, 

22 assume the most, what in that aspect, was the 
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1 most claimant-favorable. We are taking the 

2 betatron being here. We are saying workers, 

3 the betatron operators are spending their time 

4 in the control room here. So the less 

5 shielding there is, the higher their doses 

6 would be. That was before we had the film --

7 before we knew there was a film badge there. 

8 We were just modeling. Everything was being 

9 calculated on the basis of a model.

10 So I simply went to the current 

11 commercial literature, the internet naturally, 

12 and found a building block that was 16 inches 

13 wide or long. We were told the wall is 16 

14 inches and that was mostly hollow. And I 

15 found the one with the lowest average bulk 

16 density. You take all the blocks, put them 

17 together, how many pounds per cubic foot do 

18 you have. Very light material. Density was 

19 like 0.92, which is lighter than the density, 

20 was less than the density of water.

21 Since then we learned from the 

22 material in the AEC application that these 
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1 walls were mortar-filled, were heavy. As a 

2 matter of fact, in some independent modeling 

3 of the cobalt-60 source, I started off with 

4 some very lightweight material, the same 

5 lightweight material here knowing any better, 

6 and I got rather high dose rates outside, 

7 which were completely inconsistent with the 

8 survey results. So I said no, this wasn't 

9 light. They used heavy-duty concrete. They 

10 used the concrete such as was recommended by 

11 Allis Chalmers because they were interested in 

12 radiation and they assumed they knew what they 

13 were doing.

14 So here, according to Dave Allen's 

15 approach, using Dave Allen's approach, the 

16 less shielding there is, the less dose is a 

17 sign because the more dose is a sign to this 

18 control badge which he assumes is located here 

19 at the badge rack.

20 In my opinion, SC&A's opinion, 

21 speaking for SC&A now, this report is just not 

22 valid. We just don't know enough about where 
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1 the control badges were stored. We don't know 

2 anything about it or enough information about 

3 the intervening equipment here so that the 

4 calculations for any individual shot scenario, 

5 the calculation of the exposure rate at the 

6 badge rack is not claimant-favorable. 

7 So we propose that this approach 

8 not be used when I had a problem with the 

9 Excel Solver. I made a comment in my previous 

10 report which I would like to retract. I 

11 really didn't understand how it was being used 

12 at that time. There is nothing wrong in 

13 theory with that approach. But in this 

14 application, I think it would make more sense 

15 to simply say we have -- pick a scenario. It 

16 is a little arbitrary but then the 15 

17 scenarios, the NIOSH scenarios are also 

18 arbitrary.

19 Pick a scenario we know happened. 

20 We were told specifically that this 

21 particular casting, there it is, photographic 

22 evidence it is in the betatron room. This 
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1 one, by the way, this particular one is not on 

2 the railroad tracks. It is often in a far 

3 corner of the room, as it should be. My guess 

4 is that the control room is probably off in 

5 this direction and this is shooting away from 

6 the control room in the described manner. But 

7 again, the same betatron operator that 

8 furnished much of the information did say at 

9 the meeting that there were four such axles 

10 and at least one of them was shot on the 

11 railroad track. So it was an occasional 

12 scenario. He also said that he thought of 

13 maybe 15 percent of the shots were in that 

14 location.

15 So again, we are taking by saying 

16 we are using that to say all of them were 

17 there. It is a bounding and it is less, it is 

18 more robust. It is less of these things well 

19 is it, you know, where is the exact location 

20 of the film badge rack. What is the exact --

21 how much dose was received by the control 

22 badges? I think that this is a more plausible 
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1 bounding.

2 Then I want go on to what Dr. 

3 McKeel didn't mention but passed on at the 

4 last minute correspondence we got just before 

5 and he said this is pointing out that this is 

6 the aerial view of the locations and this is 

7 the main part of the betatron building. Here 

8 are the offices and also the rail tunnel going 

9 into the building is here. Then there is 

10 another roofed connection from the betatron --

11 this is the betatron building proper and here 

12 is this little structure which passes right 

13 into the Number 10 Finishing Building, and the 

14 railcars pass through here into the betatron 

15 room.

16 And this is my model of that 

17 shooting scenario that I just described. So 

18 this is the betatron itself. If we blew it 

19 way up, you would see the detail, however in 

20 this scale you don't. This is the casting, 

21 these two lines because it is, you know, you 

22 are going to have a horizontal cylinder and 
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1 you are taking a cut through it so you only 

2 see the two sides. 

3 And we put the layout man in 

4 different locations. He is not going to be 

5 right on the railroad track because then he 

6 will be blocking all further traffic into the 

7 room. So he is going to be one side of the 

8 other. Put him ten feet to allow room for the 

9 casting on either side of the railroad track. 

10 It turned out that this location on this side 

11 was the much higher, almost a factor of two 

12 higher than the other location. So the center 

13 location will probably be somewhere in14 between. 

15 The reason this is maximizing if 

16 you can draw, I wish I could draw on this but 

17 I can't, the line of sight. This is the 

18 actual betatron target. This layout man, if 

19 he could look in, could actually see the 

20 betatron tube. Of course, it is encased in a 

21 big housing, everything else. But in this 

22 simplified model, the radiation goes in all 
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1 directions. Now very strongly peaked in a 

2 forward direction but there is still some. 

3 But he is actually getting direct radiation 

4 from the betatron, not even from the casting 

5 because he can probably, he may or may not be 

6 within line of sight of the casting, probably 

7 not. But this is as bad as it can get and 

8 still be realistic.

9 Now the point that was raised was 

10 they found another worker who said well, 

11 sometimes they were in a hurry to mark up the 

12 casting. So they would take this casting 

13 which is still sitting on the railcar. The 

14 reason they left it on the railcar again is to 

15 save time rather than use a crane to move it 

16 in and out. And they moved the casting out to 

17 here. This is where this legendary ribbon 

18 door is. It is not showing on my diagram 

19 because it is such a, on this scale, it is 

20 really in there but it is one-sixteenth of an 

21 inch thick so it just doesn't show up on this 

22 scale.
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1 So say they were just past it. 

2 Well they wouldn't be leaning against that, 

3 press their bodies against the door to be 

4 working on a casting which would be out here 

5 somewhere. They would be somewhere near that 

6 ribbon door. It will be nearer than this 

7 position, which is inside the 10 Building. It 

8 could be about here. Here is a scale in 

9 centimeters. So this distance is just about 

10 1200 centimeters, 12 meters, which is roughly 

11 speaking about 40 feet. So he is about 40 

12 feet outside this ribbon door. So they could 

13 be maybe ten feet outside the ribbon door. 

14 The casting is located near there.

15 Yes, however, there was a catch to 

16 this. They cannot be working on a casting 

17 that is on this railroad track and 

18 simultaneously have a casting on the railroad 

19 track inside the betatron building. The 

20 reason for working on this casting in this 

21 location would be so they could quickly move 

22 it into the betatron building. Well they 
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1 can't move it into the betatron building if 

2 there is already a railcar there with a 

3 casting.

4 So even though while this layout 

5 man is working, say, in this location, layout 

6 crew, there would be more than one man doing 

7 this at a time, and the betatron operator said 

8 well let's not waste time waiting for them; 

9 let's do something else. They would be doing 

10 a radiography on a casting somewhere in the 

11 normal region of the building here.

12 And here they would be shielded by 

13 -- the direct line of sight would be have to 

14 pass through these ten-foot thick walls and 

15 the radiation here from that source would be 

16 far smaller than the radiation in this 

17 location. So regardless of this new 

18 information, this is still the limiting 

19 bounding scenario. And that is about it.

20 Oh, and I want to answer something 

21 else that was raised in an earlier 

22 communication which goes back to the radium 
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1 use way back prior to 19 -- well prior to mid2 '62, they started using cobalt somewhere 

3 around May 1962. So from 1962 going 

4 backwards, the criticism was, this is taken 

5 from my report back in September, I believe, 

6 or October I think, and at that time I 

7 described the analysis of the radiography room 

8 using the radium-226 source, as was described

9 to me by the one worker who actually did that 

10 and is still around. And very easily I found 

11 him to have a good memory. I talked to him 

12 several times, and he was very consistent in 

13 what he told me. And he said that building 

14 was there. And as a matter of fact they found 

15 -- John Ramspott found evidence there as early 

16 as 1957. My assumption was that it had been 

17 there all along. That it probably was there 

18 earlier.

19 And this drawing which was made, 

20 as it turns out by, I looked at the name on 

21 the bottom, I didn't bother reproducing the 

22 entire drawing because that wasn't my purpose, 
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1 the drawing was made by a physicist from the 

2 Nuclear Consulting Corporation. He worked for 

3 -- Dr. Konneker was the President and this 

4 other man worked under him. And so he went

5 there and made the survey and as a good 

6 surveyor does, he made a drawing of that room 

7 based probably on drawings he got from the 

8 plant.

9 And at that time, and this was 

10 confirmed by the radiographer that I talked 

11 to, they improved their safety and they put in 

12 these steel plates. Apparently they found, 

13 either based just on the calculation or maybe 

14 based on actual measurement, that they were 

15 needed to protect the radiographers who will 

16 be spending their time in this room and also 

17 people outside this door, which was just a 

18 thin, presumably unshielded thin steel door. 

19 The purpose there for in order to prevent 

20 access.

21 In my model, there are no steel 

22 plates. They would have shown up. The model 
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1 is simply -- I simply used this drawing. 

2 There were a number of drawings in various 

3 parts of this FOIA -- this SEC -- AEC 

4 literature, AEC correspondence and this seemed 

5 to be the best one. In other words, it had 

6 the correct scale. Others didn't have the 

7 correct scale. They were distorted. So I 

8 used this one. I said this seemed to be the 

9 most reliable one. And I simply reproduced 

10 the concrete part, not the steel.

11 Now in terms of there was no 

12 information, nothing to indicate that concrete 

13 was added. The indication was that they added 

14 the steel plate which was a quick-fix 

15 solution. In the model of the exposure model 

16 to the radium-226, we had the worker, most of 

17 his exposure would simply be, it doesn't 

18 matter where he was, he would be carrying the 

19 source at the end of this fish pole that could 

20 be as near as four feet to his body. So I --

21 he gave me a range of four feet to six feet. 

22 I just said let's call it four feet, make it 
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1 most claimant-favorable. Let's make it 15 

2 seconds. He said 12 to 15 seconds, let's make 

3 it 15 seconds. Fifteen seconds to put the 

4 source in, 15 seconds to remove it, ten times 

5 a day. And when the exposure was going on, he 

6 spent his time in this office, which again had 

7 this concrete block shielding. Even as far as 

8 the material of the concrete it said sand9 filled. He said well I don't know what 

10 fraction is sand, what fraction is concrete so 

11 I am assuming it is all sand. Because that is 

12 again the lower density, the most radiation13 permeable and, therefore, the most claimant14 favorable.

15 MEMBER BEACH: Bob, do you know 

16 when the steel plates went in, what year?

17 DR. ANIGSTEIN: Oh yes, exactly. 

18 We know they went in like June or July 1962.

19 MEMBER BEACH: `62.

20 DR. ANIGSTEIN: After they 

21 discontinued the radium and starting using --

22 so in the radium era, the steel plates were 
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1 not there. And the external location was 

2 again not outside these relatively thick 

3 walls. It will be if you have line of sight, 

4 use a thin steel door, a sixteenth of an inch 

5 steel, which is essentially transparent to 

6 radium radiation. And I put somebody right 

7 here. I have got them leaning against the 

8 door. I forget how far but nearby. Let's 

9 just say for no good reason somebody decided 

10 to spend his time outside that door. And he 

11 will be getting direct radiation from the 

12 radium with only the door intervening. So it 

13 doesn't matter how thick the walls are. They 

14 were not a factor. They would have 

15 insignificant amount -- you had low-level 

16 radiation scattered from the walls but that is 

17 secondary. That is in the fraction of a 

18 percent range.

19 So the model was not based -- was 

20 based on this drawing but not the detail of 

21 this drawing and the statement that I used the 

22 steel plates in my model is simply incorrect. 
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1 And the fact that I left out the name of the 

2 man I thought was irrelevant is off here down 

3 on this edge of the drawing because I only 

4 wanted to illustrate how this model 

5 corresponded to this drawing.

6 CHAIRMAN ZIEMER: That is for 

7 clarification then.

8 DR. ANIGSTEIN: Right.

9 CHAIRMAN ZIEMER: That is not a 

10 part of this paper but just clarification --

11 DR. ANIGSTEIN: No, no. This was 

12 added on when I saw it.

13 CHAIRMAN ZIEMER: -- on the issue 

14 that was raised using that shielding.

15 DR. ANIGSTEIN: This part was --

16 CHAIRMAN ZIEMER: Right.

17 DR. ANIGSTEIN: No, this was done, 

18 my report was submitted on last Sunday. We 

19 only got Dave's report Friday morning. We 

20 turned this around over the weekend and then I 

21 subsequent to that I added these additional 

22 ones to respond to Dr. McKeel's -- comments.
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1 CHAIRMAN ZIEMER: Okay so as I 

2 understand it, on the betatron operations, you 

3 haven't normalized anything to the control 

4 room but rather have used just the basic 

5 output.

6 DR. ANIGSTEIN: Yes. We used the 

7 output of the betatron. We used the shooting 

8 schedule which simply being told again from 

9 the one betatron operator who furnished the 

10 most input, the single most prolific source of 

11 information ten percent were the long shots. 

12 It took an hour at a six-foot target distance. 

13 Ninety percent of them were the short shots. 

14 That is 90 percent of the shots. If you 

15 looked at the duration of course the long 

16 shots took longer so they comprised a higher 

17 percentage of time of the betatron. And if 

18 you simply say they always work at peak 

19 efficiency, which is probably again, just 

20 people in organizations just don't work that 

21 way, but assuming that the betatron is 

22 utilized 100 percent of the time, it was shut 
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1 off just long enough to go in, set up the next 

2 shot, run back into the control room, start it 

3 up. So it was always on the maximum amount of 

4 time. We calculated roughly 41 percent duty 

5 cycle, which again I am sure in the real-world 

6 I mean there is no downtime for maintenance. 

7 There is no goofing off, shall we say. There 

8 is nothing else. You know, running around the 

9 clock 168 hours a week, 41 percent of that 

10 time. Again these were all maximizing 

11 assumptions.

12 And with that, let me go back to 

13 what I skipped over. Here is how it ends up. 

14 So now we are much closer for the layout man, 

15 which is all that matters because he is the 

16 limiting individual. So now the DCAS is about 

17 half, slightly less than half of our exposure 

18 rate. So we are not that far apart.

19 The neutron dose is different 

20 because of the different orientation. On the 

21 one hand, they actually have a higher, for one 

22 of the scenarios, a much higher, instantaneous 
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1 dose because it's -- they assume that one of 

2 the scenarios I assume only that it's going 

3 horizontally perpendicular to the casting and 

4 parallel to the floor. They have assumed also 

5 a shot which is 45 degrees so it is aimed like 

6 halfway out towards that door, in more towards 

7 the door, and also aimed 45 degrees up. So 

8 you would get a lot of sky shine. I'm not 100 

9 percent sure why that gives -- I mean, I 

10 haven't worked it out but it certainly, the 

11 instantaneous dose rate is even higher.

12 So I just took what I thought was 

13 a reasonably maximum. But then with his, it 

14 is only a fraction of the time. Because it is 

15 so high, it is only a fraction of the time. 

16 So the neutron flux doesn't change that much 

17 with the direction. The photon flux does. So 

18 by reducing the frequency of this occurrence, 

19 I would assume why he would get a lower 

20 neutron dose. But since after all for any 

21 particular dose reconstruction, you know, it 

22 is not like let's say beta dose which is a 
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1 separate quantity because it delivers dose to 

2 the skin, so if you are looking at skin 

3 cancer, you are really looking at the beta 

4 dose where the photon dose is a very small 

5 contribution. Here for any particular dose -

6 - organ, the neutron dose and the photon dose, 

7 they are different conversion factors but they 

8 are basically added, they are additive.

9 So the photon dose is still by far 

10 predominant over the neutron dose and the fact 

11 that we were off by a factor of three on the 

12 neutron dose, I think I understand why, and I 

13 don't think it really makes any difference. 

14 Even in our calculation we had 4.483 so it is 

15 like what -- this comes out to about five 

16 percent. Because of this particular 

17 orientation, it comes out to five percent of 

18 the --

19 CHAIRMAN ZIEMER: Okay. So in a 

20 sense you have bounded the NIOSH thing by 

21 using a single shot.

22 DR. ANIGSTEIN: Yes.
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1 CHAIRMAN ZIEMER: And, Dave, on 

2 yours now, did you -- help me remember. Did 

3 you still use all 15 scenarios or just --

4 MR. ALLEN: Yes. I mean, with 

5 Solver it ends up picking essentially two or 

6 so.

7 CHAIRMAN ZIEMER: It only picked 

8 two or three though.

9 DR. NETON: The two highest.

10 CHAIRMAN ZIEMER: Right.

11 MR. ALLEN: I think it picked a 

12 high and a low to get the total number of 

13 hours. And then it was asked to maximize the 

14 Number 10 Building dose.

15 CHAIRMAN ZIEMER: So you have this 

16 configuration part of the time but not 100 

17 percent of the time. And then you would 

18 normalize I think to the --

19 MR. ALLEN: Well as Bob said, it 

20 is not the exact configuration. It is a 

21 railroad track that I have part of the time 

22 but it is, as you said, it's 45 degrees over 
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1 and 45 degrees up, and Bob's straight on and 

2 level.

3 CHAIRMAN ZIEMER: Right. So those 

4 assumptions are a little different. And then 

5 you normalize to the control room value based 

6 on the film badge value.

7 MR. ALLEN: In the White Paper and 

8 in the addendum normalized to that other film 

9 badge rack.

10 CHAIRMAN ZIEMER: To the location, 

11 right. So the numbers are different based on 

12 how you are approaching bounding.

13 DR. MAURO: And I would say if you 

14 had a third person come in to look at this, 

15 they may come up with something else. These 

16 are judgment calls.

17 CHAIRMAN ZIEMER: Yes, I 

18 understand.

19 DR. MAURO: And so I mean, I keep 

20 coming back and in my mind the single most 

21 important question we have in front of us is 

22 we have two separate scientists looking at a 
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1 scenario, a circumstance, doing their best to 

2 place a plausible upper bound, which there is 

3 judgment based on factual information that 

4 has been collected over the last few years.

5 Then we have claimants and 

6 petitioners. And the real question I see is 

7 there anything by way of factual information 

8 that characterizes what transpired 

9 historically that leads us to a place where 

10 perhaps we have not captured that bound? That 

11 is, is there a scenario that was raised by Dr. 

12 McKeel where wait a minute, wait a minute, 

13 there was something else going on or you had 

14 the drawing wrong or you had the timing wrong?

15 In other words, when I look at 

16 this I keep asking myself the question have we 

17 exhausted our understanding as best we could, 

18 all of the different positions, thicknesses, 

19 operating scenarios in a way that we all agree 

20 that we have placed a plausible upper bound? 

21 And when I read Dr. McKeel's material, I read 

22 the transcript, I keep looking for information
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1 that says is there anything here that is new 

2 that says it wasn't the way we thought it was. 

3 And I have to say I am having trouble finding 

4 it, something that defeats Bob's in a way that 

5 would have a substantive effect on the 

6 outcome.

7 CHAIRMAN ZIEMER: Right.

8 DR. MAURO: And I think that is 

9 where we really are.

10 CHAIRMAN ZIEMER: Okay what I want 

11 to do, we are going to take a break for 15 

12 minutes and then I want to come back and I 

13 want to step through a number of the points 

14 that Dr. McKeel raised and ask you guys to 

15 respond to them. I want to be very specific 

16 on items that he has raised. And I have 

17 written down my questions on each of them and 

18 see how we can respond. So that will help 

19 clarify some of that.

20 So let's take a 15-minute break 

21 and then come back. So it is now ten after, 

22 so we come back at 25 after.
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1 MEMBER MUNN: Good. And when we 

2 get back, I would like to make two general 

3 comments that don't bear specifically on the 

4 science involved but more on just the general 

5 observations about what we seem to be involved 

6 with here.

7 MR. KATZ: Okay. Okay, I am 

8 putting the phone on mute for you all on the 

9 phone, but the line is not cut. You can keep 

10 your phones on the line if you want.

11 (Whereupon, the foregoing matter 

12 went off the record at 10:07 a.m. 

13 and went back on the record at 

14 10:26 a.m.)

15 MR. KATZ: Okay, we are back 

16 online. Dan, are you with us?

17 DR. McKEEL: Yes, I am.

18 MR. KATZ: Okay, great.

19 CHAIRMAN ZIEMER: Okay, I want to 

20 take a few minutes and go through the document 

21 that Dr. McKeel generated called General 

22 Comments on GSI Dose Reconstruction. I think 
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1 this was the original critique to the White 

2 Paper. I just wanted to make sure that we had 

3 covered the points that were raised there and 

4 then we will look at the other ones that were 

5 distributed this week.

6 So this is called Critique of the 

7 NIOSH January 2/12 White Paper Dose Estimates 

8 for Betatron Operations. And each of the 

9 items on here is numbered. Item number one, 

10 general comments and then there are some sub 

11 things on there. And I have some questions on 

12 these, and others may wish to add to it. But 

13 my first question is, and I will maybe ask 

14 Dave Allen to clarify for the record, and that 

15 is the statement there is zero urine bioassay 

16 monitoring data for GSI workers in the covered 

17 period. And do you want to comment on that? 

18 We don't have that page.

19 MR. ALLEN: I was going to say, 

20 yes, true. 

21 CHAIRMAN ZIEMER: Right. But I 

22 think the question that is being raised is why 
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1 is bioassay not a concern at this facility? 

2 Can you address that?

3 MR. ALLEN: I don't think there 

4 has been a lot of disagreement that the 

5 potential for internal dose is pretty small at 

6 this facility. They handled the uranium but 

7 they didn't mechanically abrade it or forming 

8 or machining or fixing of it of any kind. So 

9 there is some loose contamination from uranium 

10 that could transfer or get into the air. 

11 And we kind of put that in the 

12 Appendix with the bounding method based on 

13 facilities that handle a lot of uranium.

14 CHAIRMAN ZIEMER: Appendix BB --

15 or not Appendix BB.

16 MR. ALLEN: Yes, Appendix BB. We 

17 covered it based on surrogate data from other 

18 uranium facilities, based on TBD-6000.

19 CHAIRMAN ZIEMER: And I don't know 

20 if SC&A, I think agrees with that. Right?

21 DR. MAURO: To what degree did you 

22 look at internal dose from either the uranium 
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1 that is airborne from the ingot that may be 

2 brought around and/or from the scavenging of 

3 the activated material and steel that might 

4 have been activated? I know you have modeled 

5 both those.

6 DR. ANIGSTEIN: Okay, the uranium 

7 was taken from TBD-6000, which you reviewed. 

8 So we didn't have any -- we accepted that as 

9 being a reasonable model.

10 And the activated steel I did 

11 model the internal dose. Maximum internal 

12 dose given maximum permissible dust 

13 concentrations in the air, ingestion, and 

14 under the worst conditions to a worker that is 

15 doing, spending his whole time at the grinders 

16 and chippers, who is one of those people 

17 preparing the castings shortly after they were 

18 irradiated with the betatron. And we end up 

19 with an annual dose a fraction of a millirem. 

20 So it is just not -- very short-lived 

21 nuclides in that. 

22 There was an interesting tradeoff 
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1 here. If the nuclides are very short-lived, 

2 they build up quickly. You don't need very 

3 much betatron exposure to come to equilibrium. 

4 But by the same token, they have negligible 

5 biological effect because you take them in and 

6 they decay. And if they are long-lived, they 

7 don't build up if they have a half-live on the 

8 order of a year, it will take years of 

9 irradiation of the same piece of steel for 

10 them to build up to equilibrium.

11 CHAIRMAN ZIEMER: Okay, I just 

12 wanted to have that in the record.

13 The other one under Part 1, I'm 

14 just going to comment. It is Section E and, 

15 Dr. McKeel, I just wanted to mention to you 

16 that these are concerns about attribution. 

17 And the Work Group is not going to get into 

18 that. I think that is between the petitioner 

19 and NIOSH in terms of attribution of 

20 information. So my comment is that the Work 

21 Group is not going to deal with that.

22 Under E3 on page 2, there is a 
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1 comment at about the middle of the paragraph 

2 that says to our knowledge NIOSH and DCAS have 

3 made no effort to secure possible copies of 

4 surveys. He's talking about Allis-Chalmers's 

5 survey. And I think this is the issue that 

6 Dr. McKeel mentioned earlier, ‘ identifying 

7 information redacted’ ‘ identifying 

8 information redacted’'s comment that they 

9 always surveyed the facilities after they 

10 installed. And just for my benefit, has 

11 anyone actually tried to get Allis-Chalmers's 

12 records? SC&A?

13 DR. ANIGSTEIN: No. About these 

14 surveys, Allis-Chalmers presumably installed 

15 the old betatron. The old betatron, the 

16 building was constructed by or under contract 

17 to the US Army Corps of Engineers. Allis18 Chalmers installed the betatron and it would 

19 have been their normal practice they would 

20 have conducted a radiation survey.

21 But as we know, both the Allis22 Chalmers records and of course the GSI records 
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1 have long, long, long disappeared.

2 CHAIRMAN ZIEMER: Well that is 

3 what I was asking. Has anybody gone to Allis4 Chalmers for those records?

5 DR. ANIGSTEIN: Have we? No. 

6 Well Allis-Chalmers does not exist. And the 

7 only descendent, Allis-Chalmers went out of 

8 business, went out of the betatron business. 

9 They formed or sold their service business to 

10 another company I don't remember the name now, 

11 so for a number of years they were no longer 

12 in the business of installing or building new 

13 betatrons. However, they would service them 

14 and they would, I think, continue buying tubes 

15 from Machlett was one of the tube 

16 manufacturers and they would replace the tubes 

17 as they burned out.

18 However, that business dissolved, 

19 and it was passed on to ‘ identifying 

20 information redacted’ ‘ identifying 

21 information redacted’. I think he had a 

22 partner at one time. And ‘ identifying 
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1 information redacted’ ‘ identifying 

2 information redacted’ said he only kept the 

3 records that would be useful, you know, he 

4 probably was working out of his home. He 

5 wasn't going to take up a lot of space so he 

6 destroyed -- everything was destroyed except 

7 the records that he thought might be useful 

8 for him to continue servicing existing 

9 customers with the installation.

10 Now that was the second 

11 installation when they were more concerned 

12 with the new betatron was not even done by 

13 Allis-Chalmers. The GSI when they shut down 

14 the Eddystone facility which had the betatron, 

15 they simply moved the betatron from Eddystone, 

16 Pennsylvania, outside of Philadelphia, to 

17 Granite City. They themselves, or their 

18 contractors, built the building and installed 

19 the betatron. And ‘ identifying information 

20 redacted’ ‘ identifying information redacted’

21 told me that he never, ever visited the new 

22 betatron. So there was presumably they did 
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1 not do a radiation survey. And since the 

2 betatron, they might have because by this time 

3 the state of Illinois got into the radiation 

4 control business. By 1963 the Department of 

5 Public Health within the State of Illinois was 

6 involved with radiation. The Atomic Energy 

7 Commission -- well, I'm not sure about the 

8 Atomic Energy Commission because I think that 

9 once there is a license, perhaps, Paul, you 

10 are much better on the knowledge of that, do 

11 they look at all radiation sources, including 

12 electronic machine, electrical machines or do 

13 they still look only at radioactive material? 

14 In other words, would they have been 

15 concerned about -- would the AEC have been 

16 concerned with the betatron exposure?

17 CHAIRMAN ZIEMER: No.

18 DR. ANIGSTEIN: Even though they 

19 had a license for cobalt sources?

20 CHAIRMAN ZIEMER: Well that all 

21 depends. Under an AEC license, if a worker is 

22 exposed to both, they do exercise control over 
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1 non-licensed material. For example --

2 DR. ANIGSTEIN: Including 

3 electrical equipment.

4 CHAIRMAN ZIEMER: Yes, they would 

5 have included that. If they determined that 

6 there was not a clear delineation. In other 

7 words, the worker's dose limits would not be 

8 just limited to the AEC material.

9 DR. ANIGSTEIN: Oh, sure. Yes, 

10 but if all the workers handling the AEC 

11 material, meaning the small cobalt-60 sources 

12 were monitored with film badges and the ones 

13 doing the betatrons were also monitored, so if 

14 some of the betatron operators were also 

15 isotope workers or in some cases they tended 

16 to be assisting the isotope workers, they 

17 themselves were not the licensee, then the 

18 whole population of workers that could 

19 possibly be exposed to radiation would have 

20 been monitored. And that is all that would 

21 matter. Right? They had the weekly film 

22 badge data.
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1 DR. MAURO: I could speak --

2 CHAIRMAN ZIEMER: I'm not sure 

3 about that.

4 DR. MAURO: Yes, I can speak about 

5 what is going on in the last ten years because 

6 I am doing a lot of work right now with the 

7 NRC on this very subject.

8 The TLDs, records that are being 

9 maintained, the NRC when it collects that data 

10 keeps a database, even though it would say 

11 hospital, has an NRC license and is registered 

12 as a state licensee also because workers are 

13 always being exposed. Very often some workers 

14 are exposed to both licensed NRC or agreement 

15 state sources and also electronic devices.

16 I just want to tease out from the 

17 TLD readouts what fraction of the dose is 

18 missing. That's a done deal.

19 CHAIRMAN ZIEMER: No, I think the 

20 issue would be do they regulate --

21 DR. MAURO: No.

22 CHAIRMAN ZIEMER: -- on the other 
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1 stuff. The answer is no.

2 DR. MAURO: I'll tell you right 

3 now, I am very close to the State of New 

4 Jersey. I work with the Commission on 

5 Radiation Programs in the state. Very 

6 aggressive program on electronic devices, x7 ray machines, accelerators, and they have a 

8 very comprehensive set of regulations 

9 requiring annual surveys of accelerators that 

10 are used for therapeutic purposes.

11 CHAIRMAN ZIEMER: Yes.

12 DR. MAURO: NRC has no role 

13 whatsoever there. It is solely controlled by 

14 the state. 

15 Now the question is well placed in 

16 that at that time to what degree --

17 MR. KATZ: Hold on a second. 

18 Someone has kicked the phone and there is no 

19 connection.

20 (Off the record comments.)

21 MR. KATZ: Folks on the phone, we 

22 just -- hello? We have someone's fax machine 
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1 on there. Hello? Dan McKeel, are you still 

2 on?

3 MR. RAMSPOTT: Hey, Ted. I just 

4 redialed in. Everybody went dead.

5 MR. KATZ: Okay. Yes, the phone 

6 got disconnected here about a minute ago. So 

7 we stopped. 

8 MR. RAMSPOTT: We were just 

9 starting to hear Dr. Mauro.

10 MR. KATZ: Okay.

11 DR. MAURO: I'll briefly 

12 reiterate. At a facility that has both Atomic 

13 Energy Act license material under the NRC 

14 and/or an agreement state and also has 

15 electronic devices that are regulated by the 

16 state agencies, the folks that are wearing 

17 this -- TLDs, those TLDs are recorded and do 

18 not make a distinction between how much is due 

19 to what.

20 CHAIRMAN ZIEMER: Sure.

21 DR. MAURO: And the state, 

22 agreement state is held accountable for making 
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1 sure that those workers meet their five rem 

2 per year limit. So there is no way to tease 

3 those two out.

4 The second point regarding 

5 surveys, the state authority that issues its 

6 permit or license to the use of x-ray machines 

7 or any other electronic devices has full and 

8 sole responsibility over the -- and has a 

9 very, at least currently, comprehensive set of 

10 state regulations holding the permittee or 

11 licensee accountable for meeting all of these 

12 requirements, but that is in force by the 

13 state, not by the Nuclear Regulatory 

14 Commission.

15 To bring it back to this 

16 circumstance as I understand, the second 

17 betatron came in place at a time when I 

18 believe there was some degree of state 

19 regulatory oversight. And one would expect, 

20 although I can't say for certain, that if 

21 there is any way it is today, they would take 

22 on that responsibility very seriously.
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1 DR. ANIGSTEIN: And as we were 

2 talking, I recall now that in the application 

3 to the AEC for the 80-curie source in 1968, 

4 they did mention the betatron and they did 

5 mention that it was regulated by the state of 

6 Illinois and that they fulfilled, that they 

7 were good boys and they fulfilled all the 

8 state requirements and they passed the test.

9 And as a matter of fact, there was 

10 one case on record but that corresponded. The 

11 file is not complete, despite the fact that it 

12 is over a thousand pages, many of which are 

13 redundant and repetitive. But there was one 

14 time that there is actually a letter from the 

15 state of Illinois saying thank you very much 

16 for allowing us, you know, cooperating with 

17 us, and they mentioned a name, a state 

18 official who met an AEC official and they 

19 conducted a survey, they jointly conducted it.

20 So there was state oversight, and 

21 there may very well have been irradiations. 

22 You know, if they were able to make radiation 
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1 survey for the cobalt source, they might very 

2 well have done a radiation survey for the 

3 betatron.

4 Now the betatron is a little more 

5 complicated to conduct a survey because, 

6 unlike a radioactive source which has 

7 essentially a uniform rate of radiation 

8 emission, the betatron acts in bursts. And 

9 the instrument would have to be an instrument 

10 that would average out over a period of time. 

11 That period of time would be maybe a few 

12 seconds. But if you had something -- like a 

13 Geiger counter would not be a good instrument. 

14 It is not a good instrument anyway for a 

15 radiation survey but would not be a good 

16 instrument for this. But a ionization chamber 

17 certainly would be. That is just --

18 CHAIRMAN ZIEMER: Well --

19 DR. ANIGSTEIN: The fact is that 

20 we wouldn't even -- did we ask, did we try to 

21 find those records? We did not because we 

22 wouldn't have even known where to begin to 
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1 look. I mean, there is no records -- it is 

2 like trying to find a lake in the dessert. It 

3 is not there.

4 CHAIRMAN ZIEMER: Well I just 

5 wanted to clarify that for my own information.

6 DR. McKEEL: Dr. Ziemer, may I 

7 make a comment?

8 CHAIRMAN ZIEMER: Dr. McKeel, a 

9 comment on that?

10 DR. McKEEL: Yes. Well the 

11 obvious place to start, it seems to me, is 

12 with the Illinois Department of Health. And 

13 so I did that and sent an open records request 

14 to them for all the records that they might 

15 have of the GSI -- that would cover the GSI 

16 betatron operational period. And what I got 

17 back from them is about two pages, one of 

18 which had really nothing on it except the 

19 mention of the word betatron.

20 So I felt like, yes, there 

21 probably were records with the State of 

22 Illinois, but I certainly didn't get them with 
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1 that open records request, but I did try.

2 DR. ANIGSTEIN: Can I comment on 

3 that?

4 CHAIRMAN ZIEMER: Yes.

5 DR. ANIGSTEIN: We made a very 

6 extensive effort with the State of Illinois. 

7 One of our associates, Joseph Zlotnicki, who 

8 lives in Illinois in the Chicago area, and the 

9 formerly an official and scientist working 

10 with Landauer, so he was very familiar with 

11 the State of Illinois. And he made a request. 

12 He actually knew individual people there. I 

13 independently made a request for anything 

14 about General Steel Industries, General Steel 

15 Castings, the answer was I have a letter and 

16 not with me, simply saying we have searched 

17 our records, we have nothing.

18 CHAIRMAN ZIEMER: Okay, thank you. 

19 I want to move on then. The item 2A and B on 

20 Dr. McKeel's sheet are items we discussed last 

21 time, the use of the 80-curie source to 

22 establish information about the shielding and 
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1 the dimensions of the rooms, we discussed that 

2 in some detail. We also talked about the 

3 photon-to-neutron ratio issues, and the only 

4 question I wanted to ask under that main --

5 under item C, it really is a question of the 

6 ingots and dingots, those shots in addition to 

7 the uranium slices. The question that is 

8 being raised here is does that affect the 

9 output of the model. In essence that is the 

10 question.

11 If you are shooting at the -- and 

12 I think on the ingots or dingots, those are 

13 the angular shots, I believe, Dave, were they 

14 not?

15 MR. ALLEN: I think they were. 

16 The operators described that they had to shoot 

17 some shots with the uranium, I think it said 

18 obliquely was the term which, you know, 

19 angular. And that makes sense with a top crop 

20 trying to put --

21 CHAIRMAN ZIEMER: Well my general 

22 question is, is that taken into consideration 
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1 in the model?

2 DR. ANIGSTEIN: Yes. The actual 

3 original characterization of the uranium, we 

4 originally characterized the uranium as a 

5 dingot. And the dingot actually, the purer, 

6 first I thought it was something like some 

7 mixture of uranium. The dingot is actually 

8 purer uranium than the specifications for the 

9 -- obviously the desire is to have pure 

10 uranium but -- and there were specifications 

11 on the dingot, there was a whole report on 

12 dingots which actually John Ramspott had 

13 furnished to us back in about 2007. And the 

14 chemical, the elemental composition of the 

15 uranium we used in the model was that of the 

16 dingot. And we believe that this were where 

17 the uranium slices were made from.

18 And also I want to comment on the 

19 -- angular shots. In the earlier information, 

20 I know there have been many repeat interviews, 

21 many comments, in my discussion with the 

22 workers, you are in Collinsville and knew 
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1 about the betatron sites. And I said, is this 

2 what you recall, something like up to 18 

3 inches in diameter, about four-inch thickness 

4 slice? And they agreed, yes, that sounds 

5 right. That sounds like what we would always 

6 get.

7 Later, in one interview of a 

8 worker that I conducted on the telephone, he 

9 reported, he worked on the day shift, he 

10 reported coming in on a Monday morning and 

11 talking to the workers that were just going 

12 off the shift, the weekend night shift. And 

13 they discussed doing the corner shots. And he 

14 even drew me a diagram on a letter that I sent 

15 him, or I drew the diagram and he confirmed 

16 it, saying that they would shoot just the four 

17 corners. They would take mind you a round 

18 shape so he could turn it everywhere but they 

19 just took four corners. 

20 And the only purpose of such a 

21 shot would be to establish how would the 

22 defective material at either end to crop it. 
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1 They did not take shots all around, and it 

2 didn't sound like a very frequent thing. He 

3 just said, oh yes, that happened. There was 

4 one occurrence that was reported.

5 So shooting the slices we know 

6 from the Mallinckrodt records was a common 

7 practice.

8 CHAIRMAN ZIEMER: Okay.

9 MR. ALLEN: I was going to say in 

10 any case essentially the model used was to 

11 have a thick enough slice of uranium that 

12 absorbed a great deal of the betatron beam and 

13 was large enough in area to get the high 

14 intensity part of the beam. And that is what 

15 we used in our original appendix and then in 

16 what we had done more recently was the 

17 realization that those top crops the 

18 discussion was that if they did 100 percent 

19 they had a lot of overlap. So essentially we 

20 had to hit at the same spots four times, 

21 which can make a bit of a difference. So that 

22 is where we are at in the White Paper right 
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1 now. And that should account for, 

2 conservatively account for virtually anything 

3 --

4 DR. ANIGSTEIN: Also, there were 

5 two different analyses for two different 

6 purposes. One of them was to get the 

7 scattered radiation -- maximum --

8 CHAIRMAN ZIEMER: Right. 

9 DR. ANIGSTEIN: The other analysis 

10 -- and that was also to get what we called the 

11 prompt gammas. I shouldn't have said 

12 scattered radiation. Cancel that. The prompt 

13 gammas and prompt neutrons.

14 What happens just after you shut 

15 off the betatron beam, five seconds later 

16 which, of course, is a very optimistic time, 

17 five seconds later somebody comes into the 

18 room to set up the next shot. And what 

19 radiation are they being exposed to?

20 So these were the delayed 

21 neutrons, the delayed gammas, and so the 

22 bigger the slice is, the more there is because 
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1 of MCNP reports the total amount.

2 Then there was a second 

3 consideration of skin dose. What are the 

4 short-lived beta emitters? And there we took 

5 a very thin slice. We took a small circle, 

6 very thin, so as to maximize the 

7 concentration. And this would be the most you 

8 would get per gram of uranium. And so we did 

9 that analysis.

10 That is not to be a robust 

11 analysis because we looked at it again in 2012 

12 using -- and turned out to be actually 

13 slightly less than what we had gotten in 2008. 

14 So we figure we will stick with the 2008 

15 results. Number one is they are not that 

16 different. Second of all, it turned out that 

17 the short-lived isotopes make a very small 

18 contribution to the skin dose. In other 

19 words, the unirradiated uranium accounts for 

20 by far the bulk of the skin dose.

21 CHAIRMAN ZIEMER: Okay, thank you.

22 DR. McKEEL: Dr. Ziemer, may I 
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1 make a comment?

2 CHAIRMAN ZIEMER: You bet.

3 DR. McKEEL: I guess my comment 

4 is, although I appreciate Dr. Anigstein's 

5 comment about this, you know, to me what is 

6 the SEC issue and the Appendix BB issue, and I 

7 don't want to revisit our conversation of last 

8 meeting, but you know he is telling about how 

9 SC&A modeled all of this when really for the 

10 SEC issue, the issue is can NIOSH do the 

11 modeling, and all these various modelings that 

12 were done were done by SC&A. So it seems to 

13 me we are getting -- I mean, that is 

14 interesting. And I understand from Ted and 

15 everybody that the job of SC&A is to do 

16 evaluations, but you know, they are actually 

17 doing -- my question was directed at the SEC 

18 issue. And the SEC issue is did David Allen 

19 and DCAS do all of that modeling, which I 

20 assume if SC&A did it, then they must have 

21 thought it was necessary and useful to do 

22 that. My question is did NIOSH do it?
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1 And so I would be very much

2 interested in all of these things to hear what 

3 NIOSH did. I think that is what the Work 

4 Group has got to decide on. Can NIOSH do this 

5 calculation, and can they bound the dose with 

6 sufficient accuracy for SEC purposes?

7 And honestly, whether SC&A can do

8 it is interesting, but it is not directly 

9 relevant.

10 CHAIRMAN ZIEMER: Well I guess the 

11 point here is that one of the things SC&A 

12 would do would be to determine whether or not 

13 NIOSH had omitted something significant in 

14 their bounding. And I think in answering that 

15 question they have checked this particular 

16 parameter and have decided that was not a 

17 significant issue and, therefore, did not need 

18 to be specifically included.

19 Wanda has a comment.

20 MEMBER MUNN: Is this not material 

21 we are going to cover as we go through the 

22 matrix?
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1 CHAIRMAN ZIEMER: We may. I'm 

2 just trying to --

3 MEMBER MUNN: It is my --

4 CHAIRMAN ZIEMER: I'm trying to 

5 deal with the petitioner's questions. I think 

6 that was one of the questions.

7 MEMBER MUNN: Right. Right but I 

8 think it is dealt with in the matrix response.

9 DR. ANIGSTEIN: Okay, my comment 

10 just occurred to me. I think there is a 

11 confusion here. Under the -- my 

12 understanding, and please, Dave or Jim or Ted, 

13 correct me, under the statute NIOSH does dose 

14 reconstructions. That is the ultimate. That 

15 is the ultimate thing that they do. NIOSH or 

16 its contractors, ORAU and its associated ORAU 

17 team do the dose reconstructions.

18 What we are dealing with here is 

19 what directions are going to be given to the 

20 dose reconstructor. If you get a case from 

21 GSI or you redo a case from GSI, these are the 

22 assumptions you are directed to use. These 
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1 are the doses we are directed to assign and so 

2 forth.

3 Whether these assumptions are 

4 developed independently, say by Dave Allen, or 

5 whether they are developed jointly where SC&A 

6 has input and NIOSH looks at the input and 

7 says yes, we agree with this. We don't 

8 disagree with that. We adopt this part of it. 

9 And there was some consensus reached. The 

10 main thing is that there be a set of

11 instructions, at the bottom line there be a 

12 set of instructions that NIOSH has determined 

13 and SC&A agrees with as the contractor to the 

14 Board and basically that the Board agrees 

15 with, the Work Group agrees with. And after 

16 that, the dose, the individual 300 odd and one 

17 time I heard health physicists doing the 

18 individual dose reconstructions are the ones 

19 who are given that job.

20 And can they do that? Yes, if 

21 given the right instruction of course they can 

22 do that. They do it day in and day out.
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1 So whether -- who did the original 

2 model and who did -- that is not the issue. 

3 The issue is can, in the end, NIOSH do the 

4 dose reconstructions. And it seemed pretty 

5 obvious that once given the right dose 

6 assignments for the right periods, the answer 

7 is that they can.

8 CHAIRMAN ZIEMER: Okay, I don't 

9 want to spend a lot of time on debating that 

10 philosophical issue. 

11 A couple other items under this 

12 main thing. The petitioners, another concern 

13 toward the end of that page, NIOSH has failed 

14 to calculate exposures to many unbadged 

15 workers who handled uranium during transport 

16 loading and unloading and so on. 

17 My understanding is that NIOSH's 

18 intent here would be to assign these doses 

19 that arise out of the model to all the 

20 unbadged workers. Is that not correct?

21 MR. ALLEN: Yes, the betatron, the 

22 White Paper, the last paragraph or two 
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1 mentioned two estimates in the White Paper 

2 where the radiographers, the betatron 

3 operators, and the layout man the 

4 reconstructor be instructed to assign the most 

5 favorable.

6 CHAIRMAN ZIEMER: No, as I 

7 understand it, you could, in principle take 

8 individual jobs such as loading and unloading 

9 and try to fraction out what people did. But 

10 the worst case, bounding case if they spent 

11 all their time, basically, doing the layout 

12 stuff that maximizes the assigned dose. Is 

13 that not --

14 MR. ALLEN: Yes, that was the 

15 intent was that there was probably multiple, 

16 more than one maximizing or more than one 

17 working scenario that we reported in the White 

18 Paper came down to those two.

19 CHAIRMAN ZIEMER: That's right.

20 MR. ALLEN: And the reason it says 

21 the most favorable is even though the photons, 

22 you know, in the White Paper the photon dose 
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1 for the layout man is the one that we would be 

2 maximizing for everybody but that is not true. 

3 The beta dose.

4 CHAIRMAN ZIEMER: Right.

5 MR. ALLEN: So probably for a skin 

6 cancer, the most favorable would end up being 

7 the radiographer dose, and the dose 

8 reconstructor is instructed to try both.

9 CHAIRMAN ZIEMER: But what you are 

10 saying is that these other jobs, such as 

11 transporting and loading, would not --

12 MR. ALLEN: Be encompassed in --

13 CHAIRMAN ZIEMER: -- have higher 

14 doses than you have already bounded by the 

15 layout men. I just wanted to make sure that 

16 was the understanding.

17 And then could you also speak to 

18 the issue of what is the concern -- the 

19 concern is raised that you have identified the 

20 wrong peak years where the uranium amounts 

21 were the greatest. How does that impact on 

22 your bottom line? 
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1 The statement is that peak uranium 

2 volume for the betatron you stated was in '64 

3 to '66 where the purchase orders indicate that 

4 it was '62 and declined or '64 and '66. My 

5 question is what is the role of that 

6 information in terms of the model? 

7 MR. ALLEN: Well there is a little 

8 bit of misconception there or reading it 

9 wrong. And it was the peak operations of the 

10 betatron '64 to '66, which was -- or '63 to 

11 '66 I think is what we were told --

12 CHAIRMAN ZIEMER: What you are 

13 modeling, not the uranium shipments per se.

14 MR. ALLEN: Right. And there is a 

15 table in there with the uranium work that was 

16 done. And that is true, that wasn't '63 to 

17 '66. It was mostly steel work. But the 

18 argument in the White Paper used before is '63 

19 to '66 was what we were told routinely and 

20 this seems to work with some of the ancillary 

21 facts was the peak operations of the betatron. 

22 We used that in the White Paper to say that 
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1 the betatron operations that we model for the 

2 new betatron would be bounding on the old 

3 betatron, since it was lower intensity and 

4 pre-new betatron it would have been a lighter 

5 workload from what we are told.

6 CHAIRMAN ZIEMER: Okay.

7 DR. MAURO: Paul, in the interest 

8 of keeping the record as complete as we can, 

9 when you were talking about the beta dose, 

10 this is a question I raised, and I guess I 

11 don't recollect the answer.

12 I know that all of us modeled the 

13 slice and on the outside of the slice is this 

14 crust and the outside crust is where this 

15 Puzier thing might or might not occur on some 

16 occasions.

17 What I am not sure is when doing 

18 the beta dose, to what extent was 

19 consideration given that on occasion a full 

20 dingot or ingot was in fact brought in for the 

21 reasons we discussed earlier. Perhaps not to 

22 go through the whole thing but look at the 
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1 edges.

2 In a circumstance like that, what 

3 you now have is a much larger surface area 

4 with crust, which means that the potential for 

5 beta exposure from the Puzier effect might 

6 increase. And that is an area where I guess I 

7 never got a good sense of the degree to which 

8 the beta dose that is being reconstructed here 

9 has taken that into consideration.

10 CHAIRMAN ZIEMER: I thought we had 

11 put the Puzier effect thing to bed --

12 DR. MAURO: We may have, and I 

13 apologize if we have.

14 CHAIRMAN ZIEMER: -- and in fact 

15 had agreed to modify TBD-6000 to include the 

16 discussion of that.

17 DR. MAURO: Okay.

18 CHAIRMAN ZIEMER: That issue has 

19 in fact been discussed.

20 DR. ANIGSTEIN: But for GSI, I 

21 would not go back and redo it. We did assume 

22 with the slice 50 percent of the skin dose 
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1 that would either with handling the face of it 

2 where you would not have the Puzier effect or 

3 you were handling the edge and we are just 

4 50/50.

5 So if it was entirely -- yes, it 

6 could elevate. I mean, it could be a higher 

7 percentage of the time handling the crust. So 

8 conceptually it would -- the maximum it could 

9 do is double. It would actually less than 

10 double it. There would be some increase. And 

11 that these were doable. I mean, all we had to 

12 do was switch the ratio and increase, you 

13 know, this was significant amount of handling 

14 the whole ingots. But, again, the information 

15 was that mostly it was the slices.

16 MR. RAMSPOTT: Dr. Ziemer, this is 

17 John Ramspott, if I could make a comment.

18 CHAIRMAN ZIEMER: Sure, John.

19 MR. RAMSPOTT: Actually, I 

20 disagree with Dr. Anigstein's analysis, his 

21 last sentence.

22 CHAIRMAN ZIEMER: Okay.
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1 MR. RAMSPOTT: We have absolutely 

2 no information, none, zero, no inventory of 

3 what went to GSI. We have some hour 

4 notations, and they didn't start until '58, so 

5 there is five years that is totally missing. 

6 And most of the workers that we have all 

7 worked with and interviewed started at GSI in 

8 about 1963 or '64. And the individuals that 

9 actually mentioned slices or dingots or 

10 ingots, those people I know started in '64.

11 So talk about what happened at GSI 

12 pre-'64 is purely speculation. And I 

13 definitely agree with Dr. Mauro. You have 

14 five times the mass with an ingot and 

15 information I have actually forwarded to the 

16 Board, SC&A, and NIOSH from Mallinckrodt. The 

17 main intention of what went to GSI was dingots 

18 and ingots. And if we all review the DOE, 

19 DOL, FUSRAP cleanup reports, they really 

20 mention ingots and dingots and the DOE 

21 actually revised theirs to show that. That is 

22 just fact.
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1 So to try and go to slices, there 

2 is another piece to that. It is the handling 

3 of anything, whether it is a slice or an ingot 

4 or a dingot. You shoot it four times. There 

5 is four handlings. There is four chainings. 

6 There is four movings. Even a slice of a 

7 3300-pound something, if it is cut in one8 fifth isn't like picking up a piece of paper. 

9 They actually had to chain it and move it. 

10 So there is a lot more activity there than I 

11 think is being given credit.

12 Thanks for your time.

13 CHAIRMAN ZIEMER: Okay, thank you.

14 Now --

15 DR. ANIGSTEIN: Can I just briefly 

16 respond to that?

17 CHAIRMAN ZIEMER: Oh, comment on 

18 that? Yes.

19 DR. ANIGSTEIN: The exposure we 

20 were just discussing a minute ago, John, 

21 before your comment, was we took the number of 

22 hours from the purchase orders from 
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1 Mallinckrodt, allowed them so many hours of 

2 uranium. So part of that time, they were 

3 handling the uranium. We assigned the skin 

4 doses very, very claimant favorable, as if 

5 half the time they actually had their hands on 

6 the uranium. Bare hands, mind you. No 

7 gloves. Just bare hands. This is about as 

8 bad as you can get.

9 The chain men would have been near 

10 the uranium. I doubt that they would have 

11 spent more time with -- any individual chain 

12 man would have spent more time with the 

13 uranium than the betatron operators. If there 

14 is evidence to the contrary, we certainly 

15 would look at that, but it would seem to me 

16 that hooking up the chain and putting it on 

17 the rail car would involve less personal 

18 contact than the betatron operator in the room 

19 positioning the film, guiding where it comes 

20 in and so forth.

21 But the only difference will be 

22 the skin dose. The skin dose needs to be 
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1 increased. It can be easily, you know, reason 

2 to believe that that can be easily 

3 accommodated.

4 DR. MAURO: I think this is 

5 important. I mean we just hit on an area with 

6 a little softness because of the Puzier effect 

7 and the fact that maybe there were these full 

8 dingots being handled on occasion. Right now, 

9 the models do not explicitly address that.

10 You know, I think it is important 

11 it is clear that this, you know, I think the 

12 reason we are going through this list, is are 

13 there places where there might be some 

14 softness in the model that we did not 

15 explicitly address, I think it is important 

16 that we tabulate them and then decide what 

17 needs to be done to deal with those. And I 

18 think this is one.

19 I think this is one where 

20 something needs to be done to improve the way 

21 in which the doses are being calculated or at 

22 least evaluate it to see if it's going to 
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1 change very much. I understand you made a lot 

2 of conservative assumptions in the way you 

3 handled the slice. That may very well cover 

4 the problem, but what I am hearing is that 

5 there is still a little bit of uncertainty 

6 here on whether or not it is possible the 

7 current method may underestimate the skin 

8 dose.

9 CHAIRMAN ZIEMER: Thank you. 

10 Other comments on that, Dave?

11 MR. ALLEN: No.

12 CHAIRMAN ZIEMER: But I think what 

13 Bob is referring to is that percentage 

14 distribution. That is part of it.

15 DR. MAURO: Yes.

16 CHAIRMAN ZIEMER: I think John 

17 Ramspott was questioning whether or not we had 

18 confidence in actually what forms were being 

19 handled prior to -- what is the earliest we 

20 have the records on the orders?

21 MR. ALLEN: The purchase orders 

22 1958.
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1 DR. ANIGSTEIN: Yes.

2 MR. RAMSPOTT: Dr. Ziemer?

3 CHAIRMAN ZIEMER: Yes.

4 MR. RAMSPOTT: You are partially 

5 correct. My concern is the quantity and what 

6 the actual material was. It is both.

7 CHAIRMAN ZIEMER: Yes, thank you.

8 DR. McKEEL: And, Dr. Ziemer, my 

9 comment, this is Dan McKeel, would be you 

10 don't have that information for any time 

11 period. You have purchase orders, but it 

12 doesn't say explicitly whether they were 

13 betatron slices, ingots, or dingots, whether 

14 they were pure ingots, whether they were 

15 ingots that were alloyed, which we know were 

16 produced at Weldon Spring and Mallinckrodt, et 

17 cetera. You really do not know the details of 

18 the source term at GSI, and you don't know it 

19 at all up until the time that we have zero 

20 purchase orders.

21 CHAIRMAN ZIEMER: Thank you. I'm 

22 making a note of that.
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1 Let me go on here to another item, 

2 and that is the question that is raised by the 

3 petitioners of using basically the modeling of 

4 the new betatron to cover the old betatron 

5 activities. Issue 4 on Dr. McKeel's list. 

6 So from NIOSH's point of view, how 

7 do you look at that?

8 MR. ALLEN: The argument I made 

9 was in the White Paper, a paragraph towards 

10 the end.

11 CHAIRMAN ZIEMER: Right.

12 MR. ALLEN: And essentially what 

13 it came down to was the workers on more than 

14 one occasion mentioned that the intensity of 

15 the old betatron was less than the new 

16 betatron. They mentioned that shots take 

17 longer there. They even gave us numbers the 

18 best that they could recall at one point. And 

19 then we also had information from more than 

20 one worker, as I mentioned earlier, that the 

21 workload in 1963 jumped up and essentially was 

22 responding I believe to the shutdown on the 
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1 Eddystone plant. And I think some of the 

2 other ones had corresponded to the sinking of 

3 the Thresher and they had to do a lot more QA 

4 on some of the materials they were making.

5 Between the two, the higher 

6 intensity of the new betatron and the more 

7 workload in that time frame I thought that the 

8 model of the exposures at the new betatron 

9 would be bounding on the previous years and 

10 that those years also for the old betatron.

11 CHAIRMAN ZIEMER: And I assumed 

12 that was the case but just for the record, I 

13 wanted to get that out.

14 DR. ANIGSTEIN: I have a comment, 

15 too, a further comment further on what David 

16 just said.

17 This maximally exposed individual, 

18 this layout man who was working in the 10 

19 Building right outside the entrance to the new 

20 betatron wouldn't have been there. The old 

21 betatron was way out in the weeds, about 400 

22 yards away and there was no, I was told, you 
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1 know, there may have been people going back 

2 and forth, but there was no one who was 

3 stationed eight hours a day outside the door 

4 of the old betatron. So that exposure 

5 scenario just didn't exist. And the fact that 

6 again it had a lower energy, it had a lower 

7 output so the new betatron is limiting.

8 You don't have to consider a 

9 weaker source if you have a stronger source 

10 and assign that exposure to everyone.

11 CHAIRMAN ZIEMER: Okay, thank you.

12 MR. RAMSPOTT: Dr. Ziemer?

13 DR. McKEEL: May I?

14 CHAIRMAN ZIEMER: John, go ahead. 

15 John Ramspott.

16 MR. RAMSPOTT: First off, the old 

17 betatron wasn't 400 yards away. It was 300 

18 feet.

19 CHAIRMAN ZIEMER: Right.

20 MR. RAMSPOTT: That is a 

21 significant difference.

22 DR. ANIGSTEIN: Correct.
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1 MR. RAMSPOTT: And we have worker 

2 testimony, people definitely were right 

3 outside the betatron door; yard workers and 

4 when I say yard I mean railroad yard, 

5 laborers, people who had to load and unload 

6 those cars, pick up castings. All of the 

7 material we showed in a photograph something 

8 called a flask or a framework for castings sat 

9 out there. So they were definitely right in 

10 the area. That is just for the record.

11 CHAIRMAN ZIEMER: Okay, thank you.

12 DR. McKEEL: Dr. Ziemer, this is 

13 Dan McKeel.

14 CHAIRMAN ZIEMER: Yes, Dr. McKeel?

15 DR. McKEEL: Really my real point 

16 is about the differences between the old 

17 betatron facility and the new betatron once 

18 again are being skipped over. 

19 My concern is that let's just take 

20 the buildings themselves. They are not 

21 comparable. Their siting is not comparable. 

22 The new betatron building was built ten years 
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1 after the old betatron building by a different 

2 contractor. There is no complete list of 

3 engineering drawings or engineering materials 

4 that went into those buildings. They weren't 

5 the same physical dimensions and the walls, 

6 the metal part of the walls didn't go up to 

7 the same height. So there were many 

8 differences between the building structures 

9 themselves, and nobody is able to define those 

10 with any degree of clarity. That is number 

11 one.

12 Number two, the machines. You 

13 know, I think for SEC purposes you certainly 

14 can argue that a high dose might be bounding 

15 for a lower dose. But the point that I have 

16 tried to make since commenting on Appendix BB 

17 that has been totally ignored is that under 

18 OCAS-IG-003, I believe what you have to do 

19 first is you have to calculate, and I am not 

20 talking about you, I am talking about NIOSH, 

21 needed to calculate the doses from the various 

22 sources and show that the doses from, for 
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1 example, the old betatron machine were lower 

2 than the doses from the new betatron machine.

3 Now that could be modified by a 

4 number of factors. For example, let's say --

5 and I agree, ‘ identifying information 

6 redacted’ ‘ identifying information redacted’

7 had detailed records from being at GSI. And 

8 although he said he had never been in the new 

9 betatron building, we have records that show 

10 he was installing doughnut tubes in the GSI 

11 machines as late as 1973. And he did have a 

12 notebook and he produced those figures for us 

13 when we were up in West Allis. And I believe 

14 he put those in his report to NIOSH under his 

15 contract.

16 So let's say that I think that is 

17 true. The old betatron's doughnut tube put 

18 out less R per minute than the new betatron 

19 building, the new betatron machine, that is 

20 true. However, suppose the materials 

21 shielding the control room were different. 

22 And let's say that it admitted more x- rays, 
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1 than did -- x-ray photons and neutrons, than 

2 did the material shielding the new betatron 

3 control room. You haven't shown that one way 

4 or the other.

5 And so that is a level -- Dr. 

6 Anigstein made a comment earlier today that 

7 the models were not 100 percent. Well I would 

8 suggest that in the absence of a formal 

9 uncertainty analysis, you can't say whether 

10 the models were within five percent, ten 

11 percent, 100 percent or 1000 percent of the 

12 real situations that existed in those rooms.

13 And so I think when you couple 

14 that with the fact that in October 2010 I 

15 tried to point out that DCAS came out with a 

16 schedule that Dr. Ziemer distributed of what 

17 work products they were going to produce under 

18 the path forward for GSI. And one of them was 

19 a new exposure model for the old betatron 

20 facility. And that model was not produced.

21 So I think that becomes an SEC 

22 issue, and I think the SEC issue is it just is 
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1 not enough to say oh yes, we can do that. 

2 They have had 18 months since that time when 

3 the schedule was announced to produce a new 

4 old betatron model, and they haven't done 

5 that. And so that will apply to many of the 

6 other issues that I brought about sources at 

7 GSI. I think they are all SEC issues. I 

8 don't think -- anyway we will go on to that. 

9 I am supposed to have a time to make my 

10 statements. So while we are on this subject, 

11 I just wanted to make that comment. I don't 

12 think the buildings or the machines have been 

13 proven to be comparable. I definitely don't 

14 think it has been shown, except for the output 

15 tube of the betatron doughnut tubes, if there 

16 was a difference in the output of the 

17 machines, and there certainly has not been 

18 shown a difference in the exposure or to put 

19 it another way, what you are suggesting is 

20 that the exposures were the same or lower in 

21 the old betatron building and, therefore, 

22 bounded by the new betatron exposures. I just 
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1 don't think that has been proved.

2 Thank you.

3 CHAIRMAN ZIEMER: Thanks, Dan.

4 MR. RAMSPOTT: Dr. Ziemer, John 

5 Ramspott. If I could make one more quick 

6 comment on this.

7 CHAIRMAN ZIEMER: You bet.

8 MR. RAMSPOTT: I guess the SEC 

9 issue that I see or one of them, there is no 

10 badge information for the old betatron. The 

11 badges started essentially in 1964, if I 

12 understand correctly.

13 Now there might be, and there is 

14 one individual who was a part-time worker that 

15 had an early badge. We don't know if his 

16 badge readings are from isotope work which he 

17 did part-time. He was a chem lab guy. He 

18 worked ten percent or 13 percent I think to be 

19 exact as a radiographer on the weekend. We 

20 don't know if he worked Saturday and Sunday, 

21 but we have one person. And in those early 

22 days, they were actually the highest 
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1 employment years at GSI. That has been 

2 documented. That is Wikipedia, annual 

3 reports, whatever. The early years were the 

4 highest employment at GSI. So to say that was 

5 more of a slack time, actually it wasn't. 

6 They were making more tank turrets and hulls 

7 than they ever were the big steam chest.

8 But no badges essentially for 

9 those ten years prior to the new betatron? 

10 That is a pretty serious issue if the badges 

11 are what is being used to do some bounding. 

12 Thank you.

13 CHAIRMAN ZIEMER: Thank you, John.

14 DR. McKEEL: And, Dr. Ziemer, I 

15 guess I have to comment something that I left 

16 out of that to be complete about why it is 

17 important to have an explicit model for the 

18 old betatron building that's as good as 

19 possible is that the whole reason that GSI is 

20 even being considered as an AWE site was 

21 because they had an AEC contract to do NDT 

22 work on Mallinckrodt AEC uranium.
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1 And the first ten years of that 

2 contract was carried out at the old betatron 

3 building. There was no new betatron building 

4 until 1963.

5 So to not model the old betatron 

6 building 1953 to '63 is a serious omission. 

7 And in my opinion it is enough, after all the 

8 time that has passed by, to recommend that 

9 SEC-105 be approved.

10 CHAIRMAN ZIEMER: Okay, thanks.

11 DR. ANIGSTEIN: I have two 

12 comments.

13 CHAIRMAN ZIEMER: You want to 

14 comment here, Bob?

15 DR. ANIGSTEIN: Yes. First of 

16 all, in 2008 report SC&A did explicitly model 

17 the old betatron building. We found the doses 

18 in the control room to be lower. We modeled a 

19 couple of the locations. And the one 

20 difference besides the fact that the building, 

21 and we say we know nothing about the building, 

22 no, we have, first of all the building was 
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1 built under the direction of Allis-Chalmers so 

2 we have their typical, the Allis-Chalmers 

3 betatron manual specifies an example of a 

4 building structure. And that building 

5 structure in that manual seems to be very 

6 close to the building structure in the FUSRAP 

7 reports that did investigate the old betatron 

8 building. And most likely, that building had 

9 not been modified because my understanding is 

10 that it has essentially been not ever used 

11 after the shutdown of GSI.

12 Secondly, the major source of 

13 exposure which is modeled now by NIOSH and by 

14 SC&A, the layout man from the new betatron 

15 building was, because of this practice that 

16 was introduced in I believe 1965 when a new 

17 supervisor or manager took over and instructed 

18 the workers you flip the head so that we can 

19 override the limit switches and radiograph 

20 castings right on the railroad track.

21 The previous supervisor who was 

22 present at the meeting in Collinsville who is 
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1 now deceased agreed with the workers. No, he 

2 never would have. They said he wouldn't have 

3 allowed that practice. And he agreed. No, 

4 that practice was never allowed in those days. 

5 And he was in charge then.

6 So the practice that would have 

7 been allowed is one I showed here on the 

8 diagram on the last meeting was the betatron 

9 would normally point away from the control 

10 room. It could go as much as a 110 degrees in 

11 either direction so it could point towards the 

12 walls perpendicular. It could not point at 

13 the control room wall directly, and it 

14 definitely could not point towards the door 

15 leading to the railroad track. That is why 

16 Allis-Chalmers that obviously was safety 

17 conscious -- they specified ten-foot. I don't 

18 know how much more safety conscious you can be 

19 than to specify ten-foot thick walls -- didn't 

20 bother. I asked my last conversation with ‘ 

21 identifying information redacted’ ‘ 

22 identifying information redacted’, did you 
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1 specify any metal shielding. He said no, just 

2 a light aluminum, they used aluminum, just to 

3 keep people out. Because he said we relied on 

4 the shape of the limit switches and the L5 shaped geometry of the room to make sure that 

6 there was no significant amount of radiation 

7 escaping out of that building through that 

8 door.

9 So by every measure, the new 

10 betatron is limiting. You don't need a -- you 

11 don't have to analyze it. You have to 

12 consider radiation, but you don't have to do a 

13 detailed calculation of every single possible. 

14 You know to get silly, suppose somebody in 

15 those days were wearing a watch with a radium 

16 dial. Do you consider that radiation? I 

17 mean, it is on-site radiation.

18 DR. McKEEL: No, that is a not a 

19 covered source.

20 DR. ANIGSTEIN: It is not a 

21 covered source. The betatron, of course it 

22 would be -- well, okay. It will be a source 
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1 of radiation. The point is -- okay, I am 

2 giving a silly example.

3 You only have to consider sources 

4 if there is a possibility that they could 

5 exceed the limits that you get from other 

6 sources. If you can prove that it cannot be 

7 greater, then you don't have to do a detailed 

8 calculation. It is just a waste of effort.

9 DR. McKEEL: This is Dan McKeel 

10 again. I really don't think that OCAS-IG-003 

11 has language in there that supports what you 

12 just said at all.

13 DR. NETON: This is Jim Neton. I 

14 can read you exactly what it says in IG-003, 

15 section 3.1. It says, "For exposures that 

16 were incurred during the designated DOE 

17 contract period, all occupationally-derived 

18 source radiation exposures at covered 

19 facilities must be included in dose 

20 reconstruction." It doesn't have any specific 

21 description as to how that exposure analysis 

22 is performed.
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1 And I agree with Bob. If you can 

2 come up with a limiting case and include that 

3 exposure in there and say it is limiting, then 

4 that fulfills the criteria of IG-003.

5 DR. McKEEL: Well, I am still 

6 saying -- this is Dan McKeel again. With all 

7 due respect to both of you gentlemen, you just 

8 read me the language of Section 3.1 of OCAS9 IG-003 and it did not say. You all are 

10 putting words in that document's mouth.

11 DR. NETON: No, I think this 

12 document --

13 DR. McKEEL: I mean, that is your 

14 interpretation. That may be NIOSH's derived 

15 policy now but it is not what that document 

16 says.

17 DR. NETON: Well, I was the author 

18 of IG-003 and I pretty much know what I said.

19 DR. McKEEL: Well then, it is like 

20 laws. Today, people are at the Supreme Court 

21 arguing because of a law that is being written 

22 that is going to affect all of us in America. 
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1 And what they are arguing about is how 

2 explicit is the language. And that law is 

3 going to be tossed out.

4 DR. NETON: Well, let's go back to 

5 the law. The law says that dose 

6 reconstructions must be done. And it says if 

7 we can reconstruct them with sufficient 

8 accuracy -- it becomes an SEC if you can't 

9 reconstruct them with sufficient accuracy.

10 And the intent of IG-003 was 

11 merely to state that all exposures had to be 

12 considered above and beyond any DOE-derived 

13 exposures.

14 DR. McKEEL: I agree. I think it 

15 is a great document.

16 DR. NETON: It was not speaking to 

17 the degree of sufficient accuracy of a dose 

18 reconstruction. That is a very separate 

19 issue.

20 DR. McKEEL: I understand that.

21 DR. NETON: And what we need to 

22 debate is if using another betatron to bound 
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1 exposures at the old betatron, is that 

2 sufficiently accurate. That is really the 

3 question.

4 DR. McKEEL: I say no. And you 

5 all obviously say yes.

6 DR. NETON: Well, that's in issue 

7 here. But I don't think that it hinges upon 

8 an interpretation of IG-003 at all.

9 DR. McKEEL: Okay.

10 CHAIRMAN ZIEMER: Okay, let's move 

11 on. Under Issue 5, I mainly have a question 

12 and this is for you, Dan. You indicate that 

13 there is evidence that the GSI film badge 

14 retraction letters signatures by individuals 

15 with the highest film badge readings were 

16 forged by GSI supervisors. And I am not 

17 certain -- is there evidence that that has 

18 occurred? I mean, what evidence --

19 DR. McKEEL: Is that exactly what 

20 I said, Dr. Ziemer?

21 CHAIRMAN ZIEMER: I'm reading from 

22 it. It says: "There is evidence that the 
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1 retraction letter signatures were forged."

2 DR. McKEEL: Well, let me tell you 

3 -- yes, sir. I understand.

4 Well, let me tell you what the 

5 evidence is. The evidence is: first, the 

6 background is that although we asked and 

7 although we think it is highly necessary, if 

8 you remember, you acted as an arbiter to 

9 verify and ascertain whose signatures they 

10 were on the letter, the retraction letters to 

11 Landauer. However, we never actually saw the 

12 names. We know all the people involved, but 

13 we can't be sure whose names were on those 

14 letters. But we are very certain of who one 

15 of the two people with the highest film badge 

16 data was, and that individual has been 

17 interviewed by a worker who is on the phone 

18 this morning. And that particular worker said 

19 he never was told that he had a high film 

20 badge reading.

21 And so the scenario that Dr. 

22 Anigstein developed with his colleague, Dr. 
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1 Zlotnicki, who was a former Landauer employer 

2 and now is an SC&A employee was that the 

3 worker apparently agreed with his supervisor 

4 and the supervisor wrote a letter on his 

5 behalf to Landauer retracting the film badge 

6 readings as being -- I'm not sure what word 

7 was used, because I really haven't seen a 

8 wording of those letters -- but retracted the 

9 information. And my point is, if the man 

10 asked the worker whose badge had the higher 

11 reading didn't even know about that reading, 

12 how could he possibly have had a conversation 

13 with his supervisor that admitted that it was 

14 bogus and not a real value and that it should 

15 be retracted?

16 The other reason that I have my 

17 serious doubts about the whole matter is that 

18 I talked to Landauer a full 13 months before 

19 NIOSH got their more complete data set from 

20 Landauer on the GSI film badge program 2084.

21 And when I talked to those folks, 

22 I talked to two individuals several times, 
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1 wrote them, corresponded with them, sent them 

2 worker releases and so forth. And they never 

3 mentioned any retraction notices being 

4 present.

5 So you know, it is not that I 

6 doubt Dr. Anigstein at all. I'm sure he saw 

7 that. But all I can say is that information 

8 when I alone had talked to them, well before 

9 SC&A had gotten involved in anything, well 

10 before NIOSH had gotten their data, a year 

11 before, nobody mentioned anything about the 

12 high film badge readings being retracted. And 

13 in fact, and I have all this correspondence, 

14 one of the ladies at Landauer who was 

15 extremely helpful pointed out for me, flagged 

16 for me, if you will, the highest film badge 

17 reading of all and said, you know, I just 

18 wanted to bring this to your attention because 

19 it looks like this person received this badge 

20 reading in a single quarter.

21 Now it turns out that that highest 

22 film badge reading was outside the covered 
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1 period. You know, people can argue that, 

2 well, maybe that is irrelevant but it wasn't 

3 irrelevant because NIOSH and SC&A and the 

4 Board, this Work Group made a big deal out of 

5 it.

6 And so, I guess that is what I 

7 would say. This lady never mentioned that 

8 that film badge reading had been retracted. 

9 And I can't imagine that she was unaware that 

10 that had happened. If these letters that are 

11 supposedly transpired, all transpired, I 

12 assume, back in the time period when the film 

13 badges program was ongoing, that is, prior to 

14 1973, then those letters should have been in 

15 the Landauer files for what, you know, I 

16 contacted them 30 years later. So all of 

17 those records should have been in their file. 

18 And she would have, I'm sure, mentioned to me 

19 that, oh, by the way, those very high readings 

20 have been retracted, so you should disregard 

21 them. She didn't say that.

22 So you know, I can't, in all of my 
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1 dealings with this Work Group, I have tried to 

2 report what various workers tell me. 

3 Sometimes they corroborate each other, 

4 sometimes they don't. I can't really judge. 

5 I'm not making judgment on who is telling the 

6 truth and who is not because, you know, 

7 everybody, I am certain, is trying to do their 

8 best at recollecting what happened decades ago 

9 and that is very, very hard to do for any of 

10 us.

11 CHAIRMAN ZIEMER: Okay, I thought 

12 --

13 DR. McKEEL: So that's it.

14 CHAIRMAN ZIEMER: I understand 

15 because we have had that discussion before. I 

16 thought maybe there was some new direct 

17 evidence that you had of forgery that I wasn't 

18 aware of.

19 MR. RAMSPOTT: Dr. Ziemer?

20 CHAIRMAN ZIEMER: Yes?

21 DR. McKEEL: Well, actually, the 

22 reason I keep bringing it up, Dr. Ziemer, is 
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1 because until today, until today that basic 

2 information has not been acknowledged. No, 

3 you are right. We have had this discussion 

4 before. I have to keep on making the point 

5 because they don't seem to be recognized and I 

6 want them to be recognized.

7 CHAIRMAN ZIEMER: Okay, thank you. 

8 Bob has a comment and then we will get to 

9 you, John.

10 MR. RAMSPOTT: Okay, sir. Thank 

11 you.

12 DR. ANIGSTEIN: Can I comment?

13 CHAIRMAN ZIEMER: Yes, go ahead.

14 DR. ANIGSTEIN: Can I go first?

15 CHAIRMAN ZIEMER: Yes.

16 DR. ANIGSTEIN: All right. Dr. 

17 McKeel obtained, because he had to pay for 

18 this information and Landauer charges for its 

19 time, he obtained year-end summaries. A 

20 single report at the end of each year that 

21 summarizes the entire dose records for that 

22 year of workers who are still employed at that 
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1 time. If somebody quits in the middle of the 

2 year, it doesn't show up on the year-end 

3 summary or in October.

4 The year-end -- so he was given, 

5 this lady looks at the year-end summaries and 

6 gave him that information. Both NIOSH and 

7 myself, we went through every single record 

8 for the two and a half years of the covered 

9 period and then I went through the quarterly 

10 records and many of the individual records for 

11 the later years that were not covered and were 

12 not part of this, but nevertheless we looked 

13 at them.

14 Therefore, she correctly said at 

15 the end of the year, and this happened very 

16 late in the year, I think in November, it was 

17 reported in December, yes, there was this very 

18 high exposure.

19 It was not retracted until the 

20 following year, but it took time for the 

21 correspondence to take place and it took time 

22 to get that letter out back to Landauer and it 
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1 took time for them to make that correction. 

2 If I remember correctly, the correction was 

3 made the following February that the dose was 

4 subtracted. And there was a notation, DS. 

5 And we went to Mr. Zlotnicki, went back to his 

6 contact at Landauer. He is on very close 

7 terms with the current vice president of 

8 Landauer, who is in his own right eminent. He 

9 was formerly with Pacific Northwest 

10 Laboratory, has publications, a respected 

11 health physicist and scientist. And they dug 

12 up and went into those files and dug up those 

13 letters. 

14 The lady that Dr. McKeel talked to 

15 would not have had that, would have had no 

16 reason to go into that. She did not examine. 

17 He did not pay what NIOSH paid. I have no 

18 idea what the order number, they gave him a 

19 purchase order to dig out every single record 

20 for a period starting with January '64, which 

21 implicitly covered the previous six weeks 

22 because it said here the total starting with 
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1 middle of November '63 through the end of the 

2 program in '73.

3 They purchased those ten years' 

4 worth of records, thousands of records and we 

5 went through them. And we found the DS and I 

6 said, "What does "DS" mean?" I asked Joe 

7 Zlotnicki, "What does DS mean?" He found out 

8 it means dose subtracted and he found that 

9 correspondence. And the correspondence was 

10 released. The names were taken out but the 

11 wording of the letters, everything else was 

12 released, my understanding, to the 

13 petitioners. I was specifically asked to give 

14 the redacted version and Ted Katz passed them 

15 on. So number one is the fact that the lady 

16 that Dan McKeel spoke with did not know that 

17 on the basis of the year-end records does not 

18 mean it wasn't there. And we have that. We 

19 got it from Landauer. So any implication that 

20 this is not valid information is simply wrong.

21 And second of all, those incidents 

22 happened well after the covered period. It 
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1 happened in '69 and there were other sources. 

2 The 80-curie source, the cobalt-60 source was 

3 in use at that time and there may very well 

4 have been potential for exposure or potential 

5 for accidental exposure of the film badges.

6 So the fact that one of the film 

7 badges had been something like 26 rem, if I 

8 recall correctly, even one of the workers who 

9 have been recently, currently in touch with 

10 the Board, participated in the meeting, said 

11 oh yes, he knew. He knew that this -- I 

12 interviewed him and it is in the record. He 

13 said this man got very upset. He said, "I 

14 lost my film badge and I guess you are going 

15 to have to fire me because I left my film 

16 badge near a radioactive source." There were 

17 different details. 

18 So it was admitted that no, a 

19 human being did not get that dose of 26 rem. 

20 And when she said it was in one quarter, to be 

21 more specific it was in one week on a single 

22 weekly film badge. And the same person who 
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1 had that exposure had no significant exposures 

2 or no exposures all the rest of his time. It 

3 was an accident to the film badge.

4 MEMBER MUNN: In any case, none of 

5 it has any bearing on the period that we are 

6 concerned with.

7 DR. ANIGSTEIN: It was completely 

8 outside.

9 MEMBER MUNN: There is no bearing.

10 DR. McKEEL: No, but what it does 

11 -- this is Dan McKeel again. What it does 

12 have a bearing on is, I just sent the Board a 

13 snippet from one of the two workers who sent 

14 me their complete film badge records that they 

15 got as part of the NIOSH dose reconstruction 

16 program, and I sent all Members of the Board 

17 and NIOSH and SC&A, everybody in the room and 

18 on the phone a copy of two records that were 

19 shown from 4/25/66 and 5/29/66, within the 

20 covered period, where a reading that was not 

21 on the April report shows up in May, at the 

22 end of May as 300 millirems. Now that is not 
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1 a gigantic, high reading, but it is one where 

2 a new reading appears on the badges.

3 So yes, I am aware of the 

4 phenomenon you are talking about. You will 

5 also see in my extracted record that I have in 

6 that report that there is one reading on that 

7 list of 2,470 millirems cumulative dose.

8 So you know, there were other 

9 higher doses. The particular gentleman that I 

10 am talking about is not the one with the 

11 highest 30 rem dose but the other one. And 

12 that gentleman, no matter what you all have 

13 said, I understand everything that Bob has 

14 said. I believe it. I have no problem with 

15 it. But I am telling you that one gentlemen 

16 whose dose was apparently retracted said he 

17 was never told about that high dose.

18 So all it means is that his 

19 supervisor -- it is doubtful whether his 

20 supervisor ever talked to him about it. Now, 

21 if the supervisor just wrote it on his own, 

22 retracted the dose without telling the worker, 
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1 well, that is another matter.

2 MR. DUTKO: Dr. Ziemer?

3 CHAIRMAN ZIEMER: Yes.

4 MR. DUTKO: John Dutko. Comment, 

5 please.

6 CHAIRMAN ZIEMER: Yes.

7 MR. DUTKO: I was the person that 

8 interviewed this individual, talked to him by 

9 phone. He told me that he was never at all 

10 informed of any high exposure. And that after 

11 he had left their employment, they continually 

12 tried to get him to take a physical exam. He 

13 never could understand why.

14 After that conversation with him, 

15 sir, he would not answer the phone. He would 

16 not answer an email. The only thing I have 

17 got to say about the situation, you can take 

18 it to the bank that we weren't dealing with 

19 any Girl Scout troop.

20 CHAIRMAN ZIEMER: Okay. A couple 

21 other items.

22 MR. RAMSPOTT: Dr. Ziemer?
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1 CHAIRMAN ZIEMER: Yes, John.

2 MR. RAMSPOTT: I had a comment, if 

3 I may.

4 CHAIRMAN ZIEMER: Yes.

5 MR. RAMSPOTT: It had to deal with 

6 this past conversation before Mr. Dutko. And 

7 Dr. Anigstein just confirmed for me that I 

8 wasn't dreaming this up.

9 There was a conversation between a 

10 supervisor who has frequently called in and 

11 added information, ‘ identifying information 

12 redacted’, which you all know. He was 

13 actually interviewed, I thought by yourself, 

14 Paul, Dan McKeel, and now I know Bob 

15 Anigstein. I wasn't on the interview, but Mr. 

16 Dutko and myself had met with this gentleman 

17 prior to this interview and if I am not 

18 mistaken, and you guys can help me and it 

19 sounds like Bob has already started to, he 

20 recanted a story about an exposure.

21 It was in 6 Building. The film 

22 was misplaced, lost, the badge was lost. He 
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1 panicked, he went home, he came back the next 

2 day, cleaned out his locker, figured he was 

3 fired. And the supervisor just mentioned he 

4 went in to his boss, told him what happened, 

5 and then I believe some sort of letter was 

6 concocted to cover that issue.

7 And you guys talked to . So I 

8 think you probably -- hopefully this refreshes 

9 some memories on that conversation. So 

10 somebody did something. You know, forged is a 

11 nasty word, but somebody did something, 

12 apparently, and feel free to re-interview that 

13 supervisor. I think he would have no problem 

14 telling you. He told it to you once. Did I 

15 miss that or -- I wasn't there on the 

16 interview. You guys did it on your own.

17 Does anybody have a comment on 

18 that?

19 CHAIRMAN ZIEMER: Well, I don't 

20 know that we need to pursue that here today. 

21 I think we got the information we needed.

22 MR. RAMSPOTT: Well, it was just 
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1 in answer to your question about --

2 CHAIRMAN ZIEMER: Yes, I was just 

3 trying to clarify.

4 MR. RAMSPOTT: -- some things that 

5 were jockeyed around.

6 CHAIRMAN ZIEMER: Yes.

7 MR. RAMSPOTT: Hope it helps.

8 CHAIRMAN ZIEMER: A couple other 

9 items. Under Issue 6, the issue of whether 

10 guards and electricians and so on could have 

11 had higher doses than layout workers. I think 

12 that we have pretty well established that the 

13 layout worker's contacts had to exceed 

14 virtually any other job there. I don't know 

15 if anyone has any questions on that. 

16 But under issue 6, a couple other 

17 things I just wanted to comment on. Dr. 

18 McKeel, you raised a concern that NIOSH has 

19 not done a breakdown of gender in the dose 

20 reconstructions. And let me just tell you 

21 that typically gender is not an issue in dose 

22 reconstructions. NIOSH uses the National 
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1 Cancer Institute risk values, which pretty 

2 much are gender-neutral with an exception or 

3 two. Breast cancer sometimes is an issue, and 

4 that is taken into consideration but the 

5 assignment of dose as it is in the models 

6 certainly is gender-free and there is no 

7 either SECs or dose reconstructions that look 

8 at gender specifically, except for the case 

9 where if a woman gets breast cancer. Then, I 

10 am trying to remember, Dr. Neton, is there a 

11 different risk value used for the women for 

12 breast cancer?

13 DR. NETON: Actually, male and 

14 women's breast cancer have the same graph, but 

15 it is based on the women's.

16 CHAIRMAN ZIEMER: It is based on 

17 the women's, right.

18 MR. ALLEN: The background rate is 

19 drastically different.

20 DR. NETON: Yes, actually.

21 CHAIRMAN ZIEMER: Right. And that 

22 shows up in the calculation as far as the risk 
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1 calculation is concerned.

2 DR. NETON: Correct.

3 CHAIRMAN ZIEMER: So that if a 

4 woman gets breast cancer, that actually shows 

5 up in the determination.

6 DR. NETON: Correct.

7 CHAIRMAN ZIEMER: So I just wanted 

8 to mention that for the record, that there is 

9 not a need for a breakdown of gender in terms 

10 of the front-end of the dose reconstruction 

11 process. 

12 DR. McKEEL: The reason I think --

13 Dr. Ziemer, this is Dan McKeel again. I think 

14 the reason I put that in there is I wanted to 

15 call your attention to a new epidemiologic 

16 study that had shown a difference between 

17 cancers in women and men. And it was just to 

18 point out a general finding.

19 I understand about IREP being 

20 gender-neutral and so forth. The other issue 

21 that comes up that is a gender issue and I 

22 believe it is an SEC issue has to do with the 
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1 film badge records from General Steel, which 

2 are on a very small subset of people, none of 

3 whom are women.

4 So not only is that badge data not 

5 representative as far as jobs or years, it is 

6 also not representative as far as gender. 

7 There are no women represented. So that was a 

8 very small point.

9 CHAIRMAN ZIEMER: Yes, I just 

10 wanted to clarify that. Okay.

11 MR. CHUROVICH: Dr. Ziemer? 

12 CHAIRMAN ZIEMER: Yes.

13 MR. CHUROVICH: My name is Dan 

14 Churovich and I would like to have one comment 

15 about the safety issues at the Commonwealth. 

16 From 1951 to 1961 I worked there and I can 

17 tell you the safety issues and state 

18 oversight, and any other kind of oversight are 

19 almost nonexistent, except for taking care of 

20 your eyes wearing your safety glasses. 

21 Harry Truman, his comment was that 

22 if you -- he made a statement once and said at 
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1 the end that a certain statement somebody else 

2 had made was horse manure. And you are 

3 talking about the safety at the Commonwealth 

4 and oversight, that is basically what you are 

5 talking about because it did not happen.

6 CHAIRMAN ZIEMER: Okay, thank you. 

7 Let's see. Other items on Dr. 

8 McKeel's document here we have already 

9 discussed. It has been agreed that the double 

10 leaf or the lead shields weren't there during 

11 this period.

12 DR. McKEEL: Dr. Ziemer?

13 CHAIRMAN ZIEMER: Yes.

14 DR. McKEEL: No. Both SC&A and 

15 NIOSH and now you have missed my main point. 

16 My main point was I understand that the lead 

17 is not being used in the model. That is good. 

18 But Dave Allen's model and what he says in his 

19 latest report, Addendum 3, is that he still is 

20 using a double leaf door in his model. And we 

21 have shown you that that double leaf door was 

22 not the door that was present in 1966.
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1 Now what I think what is the 

2 practical matter of that, you know, does it 

3 matter. I think it does, because as everybody 

4 has said this morning, you know, what we are 

5 talking about is sky shine, radiation going 

6 down the tunnel. And possibly -- let's just 

7 talk about the new betatron building -- and 

8 possibly affecting layout men doing layout 

9 work in the tunnel or in Building 10. If that 

10 radiation has to pass through two doors, let's 

11 call them double leaf and ribbon steel, it 

12 does matter what that material is.

13 Now I understand that it may or 

14 may not retard photons and/or neutrons but it 

15 does, the door, the material of which the door 

16 is composed does affect the MCNPX model 

17 quantitatively speaking. And it matters which 

18 door you have in the model. And I am saying 

19 that the door that should be in the model is 

20 the ribbon steel door. And I believe Dr. 

21 Anigstein mentioned this morning and that he 

22 has said before that in his earlier model of 
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1 the old betatron building in 2008, you know, 

2 he has referred to that door as one-sixteenth 

3 inch steel.

4 Now that may be true. You can't 

5 tell from the pictures exactly what material 

6 the double leaf door was but, you know, it had 

7 a discrete thickness. It was made of a 

8 discrete type of metal, which we don't know 

9 what it was. We call it steel and we call it 

10 metal but we don't really know what either one 

11 of those doors, what kind of steel it was, or 

12 what kind of metal the double leaf door was. 

13 So I guess that is my point.

14 You know, if we want the model to 

15 be as precise as possible, then we should use 

16 the correct type of door material and it was a 

17 ribbon steel roll-up door. 

18 CHAIRMAN ZIEMER: Okay. We'll so 

19 note that. I suspect that is fairly easy for 

20 NIOSH to take a look at that and see if that 

21 makes any difference. It may make a slight 

22 difference.
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1 MR. ALLEN: Yes, we got a steel 

2 door there now. And all I did was remove the 

3 lead from what I had before. I don't recall 

4 the thickness of it. It is less than an inch 

5 but it might be a little too thick right now.

6 CHAIRMAN ZIEMER: Okay, we will 

7 take a look at that. Okay, thank you.

8 I think the other items on this 

9 document we have already discussed. We are 

10 going to take a lunch break here in a minute.

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

12 a question --

13 CHAIRMAN ZIEMER: Yes.

14 DR. McKEEL: -- that I am unclear 

15 about?

16 You know, I think I appreciate 

17 your going through the issues that concern you 

18 about what I wrote. But there is an issue on 

19 here about petitioner's comments on NIOSH 

20 White Paper update, Dan McKeel, number five. 

21 Am I going to get to talk about those things?

22 CHAIRMAN ZIEMER: Yes.
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1 DR. McKEEL: Okay, good.

2 CHAIRMAN ZIEMER: Number five on 

3 which document, the one I was just looking at?

4 DR. McKEEL: No, I'm talking about 

5 the fifth item on the agenda.

6 CHAIRMAN ZIEMER: Oh, yes. Oh, 

7 yes, yes, right.

8 DR. McKEEL: Okay.

9 CHAIRMAN ZIEMER: Your comments.

10 DR. McKEEL: Can we do that after 

11 lunch?

12 CHAIRMAN ZIEMER: We can do that 

13 after lunch.

14 Wanda had some comments she wanted 

15 to make earlier and let's do that before we 

16 leave. Wanda? Or do you want to wait?

17 MEMBER MUNN: They were only very 

18 general comments and really don't have any 

19 bearing on our technical discussion here. It 

20 was just I think as the discussion goes on, it 

21 is more and more clear to anyone who is 

22 listening to it that different people infer 
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1 different positions on what any fact that is 

2 put before them seems to say. And we hear 

3 that continually around this table. I'm not 

4 sure how we can get past that. It seems to 

5 occur everywhere, but it seems to be very bad 

6 here.

7 We have people with different 

8 backgrounds who infer something from the same 

9 set of information that we have, and it is 

10 disturbing that we don't have a way to get 

11 past that. It is just an observation on the 

12 human condition, I suppose. I do wish that we 

13 had some mechanism other than what we are 

14 doing here to try to get around that. But I 

15 throw that out simply because if anyone has 

16 any thought on how we might move forward more 

17 succinctly on the differences that people have 

18 and implications that they see in the same 

19 information that we have, it would be 

20 extremely helpful to all concerned. 

21 I have no words of wisdom in that 

22 regard, but I guess we have to slog through 
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1 it. That's just -- I only comment.

2 CHAIRMAN ZIEMER: Well, I'm not 

3 sure that the goal is to get everybody to 

4 agree on things.

5 MEMBER MUNN: No, it isn't.

6 CHAIRMAN ZIEMER: The goal is to 

7 get everybody's issues on the table. Insofar 

8 as there are facts that we can agree on, that 

9 is good. The implications of those facts and 

10 anything derived from them, it goes from data 

11 to perhaps models to some other level of 

12 characterization, we will have to make our 

13 individual judgment about that. The 

14 petitioners I mean certainly have a different 

15 view than -- or may not, than NIOSH. SC&A may 

16 or may not agree with NIOSH. There will be 

17 points of, perhaps, disagreement. 

18 Ultimately, I think it will fall 

19 on the Work Group Members to take this 

20 information and make a judgment on whether or 

21 not we are prepared to recommend an SEC for 

22 all or part of the time periods in question.
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1 MEMBER MUNN: I agree. My concern 

2 is the fact that we seem to be working toward 

3 different goals. And sometimes it is helpful 

4 to reinforce the idea that the goal, I believe 

5 I am stating this correctly, of the Board and 

6 certainly the goal of this Work Group is to 

7 identify the best possible science in 

8 relationship to ability to do dose 

9 reconstruction for this specific site.

10 CHAIRMAN ZIEMER: Right.

11 MEMBER MUNN: And if that is the 

12 same goal that we are all working toward, then 

13 it is helpful to restate it once in a while.

14 DR. MAURO: To add to that very 

15 quickly. What I am doing is there is a lot of 

16 material to go through. What I am doing is I 

17 am writing down the essence of which items 

18 that Dr. McKeel brought up that I believe need 

19 to be answered that have not yet been 

20 answered. And I have two. And quite frankly 

21 I was surprised by the second one, namely the 

22 thickness of the ribbon door. It is my 
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1 understanding that whichever assumption you 

2 use regarding -- once you get rid of the lead, 

3 you are not going to change anything. Now I 

4 was hoping --

5 CHAIRMAN ZIEMER: Well, we don't 

6 know for sure. But it is easily checked.

7 DR. MAURO: Yes, there's a 

8 difference -- the difference between --

9 DR. ANIGSTEIN: The lead or the --

10 DR. MAURO: No, no not the lead. 

11 Take the lead out.

12 CHAIRMAN ZIEMER: The lead is out 

13 anyway.

14 DR. MAURO: Dr. McKeel had 

15 mentioned that once the lead is out, we still 

16 have a question about whether the ribbon is a 

17 double ribbon or a single ribbon, which 

18 changes the thickness.

19 DR. ANIGSTEIN: The thickness --

20 again, we had a disagreement. It was an 

21 inadvertent aspect of his model where you put 

22 in a thick steel. And the thin steel, it is 
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1 not going to be anything less than a sixteenth 

2 of an inch. This is a typical stiff sheet 

3 metal and we use a typical alloy. Steel is 

4 basically iron with a little bit of carbon 

5 added, some trace elements, some trace amounts 

6 of other metals, unless you are looking for 

7 stainless steel or some special purpose steel, 

8 but ordinary steel. We took a typical alloy 

9 and changing the alloy composition, you know, 

10 on the level of significance that we are 

11 operating, is it going to change it in the 

12 fifth decimal place? Probably.

13 DR. MAURO: That is what I wanted 

14 to get on the record. We didn't get that on 

15 the record.

16 You see, right now I have, as we 

17 left it up to this moment, this was item 

18 number two. I don't think it deserves to be 

19 an item number two for the reasons Bob just 

20 said.

21 MEMBER BEACH: Well, and just for 

22 me, I am looking for, once all the 
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1 recommendations come out, all the questions, 

2 then I am looking to NIOSH to see what they 

3 are going to do with all that information. So 

4 we still don't know that at this point 

5 completely.

6 CHAIRMAN ZIEMER: Okay, let's 

7 break for lunch. Try to get back by 1:00. We 

8 are a little bit after 12:00 but let's get 

9 back here by 1:00, and we will hear from Dr. 

10 McKeel and then we want to go through the 

11 matrix.

12 (Whereupon, the above-entitled matter 

13 went off the record at 12:05 p.m. and resumed 

14 at 1:05 p.m.)

15

16

17

18

19

20

21
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1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N

2 (1:05 p.m.)

3 MR. KATZ: Okay, we are back. 

4 This is the Advisory Board of Radiation Worker 

5 Health, TBD-6000 Work Group. Let me just 

6 check on the line. Dan and John, are you with 

7 us again?

8 DR. McKEEL: Yes, this is Dan 

9 McKeel. I'm here.

10 MR. RAMSPOTT: John Ramspott. I'm 

11 here.

12 MR. KATZ: Super. And Mr. Dutko, 

13 too?

14 MR. DUTKO: Yes, sir.

15 MR. KATZ: Great.

16 CHAIRMAN ZIEMER: Okay, let's 

17 begin now with comments from Dr. McKeel. And 

18 Dan, we do have the materials that you 

19 distributed this past week and if you need to 

20 refer to those, that is fine but I will let 

21 you proceed as you wish.

22 DR. McKEEL: Okay. Thank you very 
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1 much for giving me the opportunity. I am 

2 going to try to keep my remarks very focused 

3 in the spirit of what Wanda Munn was asking 

4 for this morning.

5 My time today is pretty limited 

6 and the Work Group has a lot more to get 

7 through. So I am going to try to focus on the 

8 two Allen/NIOSH Path Forward White Papers, but 

9 also I want to raise SEC-105 issues, so 

10 everybody can have time to discuss the SEC 

11 matrix.

12 And hopefully, at the end of this 

13 I hope Dr. Mauro has added to his list of 

14 issues that need to be resolved for the SEC.

15 First I have a comment regarding 

16 David Allen's addendum number three. We went 

17 over this briefly this morning. I agree with 

18 SC&A that the new betatron model is still not 

19 correct. A) is: the modeled new betatron 

20 tunnel door was not double leaf, even though 

21 it was minus lead shielding. It was a thinner 

22 driven-steel roll-up door, the exact physical 
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1 characteristics of which, including the 

2 thickness and the type of steel are not known. 

3 There was no lead shield.

4 I think not incorporating this 

5 into the model already indicates that my 

6 presentation on 3/15 was ignored on this 

7 point.

8 Point B is that David Allen did 

9 not model the badge position number two for 

10 GSI. And the new betatron film badge rack 

11 when it was moved farther away from the 

12 betatron source during 1964-1966.

13 The Landauer GSI film badge 

14 program number 2084 data has been analyzed 

15 thoroughly and accurately, nor has it been 

16 presented in entirety to the TBD-6000 Work 

17 Group or the petitioner. 

18 McKeel's most recent White Paper 

19 to the Board on 3/27/12 showed evidence of an 

20 exposure of 300 millirem that newly appeared 

21 on a worker record between April 25th and May 

22 29th, `66 of the covered period. McKeel 
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1 interprets this as a previously unreported 

2 overexposure incident that was apparent from a 

3 detailed temporal analysis of film badge 

4 records that NIOSH has possessed for several 

5 years.

6 The replicated records showed 33 

7 records on one page. There were 21 instances 

8 of cumulative photon dose marked M and 12 

9 instances of photon doses ranging between 10 

10 and 2,470 millirem, 2,470 millirem with 

11 several 20 millirem and a 40 millirem dose. 

12 No sheets had any beta or neutron doses 

13 recording.

14 Point D under one, McKeel 

15 introduced a new real-world new betatron 

16 layout worker shooting scenario attested to by 

17 former GSI betatron employees and contained in 

18 one of his four recent communications to this 

19 Work Group following the 3/15 Work Group 

20 meeting.

21 What he showed was that layout men 

22 worked on castings that required a quick 
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1 turnaround, referred to as hot, rushed or 

2 urgent nondestructive testing jobs in the rail 

3 tunnel just outside of the thin roll-up steel 

4 door while shooting was ongoing.

5 Two workers who are known to the 

6 Work Group and SC&A offered this new affidavit 

7 information. Dr. Anigstein mentioned that he 

8 didn't think that scenario would add to the 

9 dose because it wouldn't be possible to have 

10 gotten another casting into the beta room to 

11 be worked on while the layout men were doing 

12 their job outside. And I think that is just 

13 wrong.

14 I think it would be easy to 

15 imagine a scenario where a smaller casting had 

16 already been brought into the betatron 

17 shooting room and then suddenly men found or 

18 discovered a defect and maybe they fixed it 

19 and then it had to be turned around quickly 

20 and they did that just outside the tunnel 

21 area.

22 In any case, the SEC issue 
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1 regarding GSI film badges is the pedigree of 

2 these data. It is limited to males. It is 

3 limited to one job Class, which is betatron 

4 employees that itself is heterogeneous and 

5 includes clerks and photography technicians. 

6 And badge data is available for only three 

7 years, 1964 to `66, out of a 13-year covered 

8 period. There are no measurements of beta 

9 dose or neutrons available on only 89 

10 individuals out of a work force of 3,000 to 

11 4,000 persons.

12 There is no reasonable scientific 

13 basis to construe these very limited badge 

14 data as being representative of the entire 

15 work force. Nor should they be extrapolated 

16 to cover all workers during the entire 13-year 

17 covered period of 1953 to 1966, as NIOSH 

18 suggests.

19 These were very limited film badge 

20 data and they are not even bounding for 

21 betatron employees who only wore them part22 time. Badges were not worn, for example, by 
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1 betatron employees doing layouts in the new 

2 betatron tunnel on urgent, hot or rushed 

3 casting jobs. Those unbadged layout employees 

4 would be expected to have the highest 

5 exposures of any employees. And I say this. 

6 Of course, that has to be proven by the model.

7 These doses have not yet been 

8 modeled by NIOSH or SC&A during the Path 

9 Forward time period from October 2010 until 

10 today.

11 Main point two. Petitioner 

12 challenges the validation of a 25 MeV new 

13 betatron source using a post-1968 GSI cobalt14 60 source which was 54, not 80, curies, that 

15 had a beam geometry that was very different. 

16 The Co-60 sources does not model neutrons that 

17 were a significant portion of the betatron 

18 output. And GSI workforce measured data from 

19 1971, which is outside the covered period.

20 Item three, the petitioner objects 

21 to NIOSH and SC&A passing off betatron 

22 residual radiation that was measured as quote, 
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1 "magnetic interference,", unquote. This is 

2 their unproven construct but it was measured 

3 by a paid CDC NIOSH consultant. In fact, 

4 because setup workers were exposed to the 

5 distance of one to two feet rather than six 

6 feet from the betatron nose cone while the 

7 machine power was turned off, the inverse 

8 square law indicates a dose of 60 millirems 

9 rather than five millirems should be assigned. 

10 NIOSH has ignored more recent testimony 

11 replicated in my post-3/15 White Papers that 

12 ‘ identifying information redacted’ ‘ 

13 identifying information redacted’ was re14 interviewed and said that the had measured 

15 residual radiation emanating from the doughnut 

16 tube of the betatron within seconds after 

17 removing it from an Allis-Chalmers betatron 

18 that was similar to the one used at GSI.

19 Point number four. SC&A in 2008 

20 modeled an 80-curie source at GSI. Dr.

21 Anigstein recently pointed out correctly that 

22 the Allen Co-60 model assumed the source was 
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1 80-curies, when in actuality it was only 54-

2 curies in 1971. This source was not factored 

3 into the 2008 model of the same GSI source 

4 term.

5 The Path Forward documents have 

6 stated that GSI obtained the 80-curie source 

7 after 1966, a point that at least six GSI 

8 workers still dispute. They testify the large 

9 source was present during the 1964 to `66 time 

10 period. Petitioner believes that NIOSH, in 

11 the spirit of being claimant-favorable, should 

12 model the Co-60 80-curie source to comply with 

13 OCAS-IG-003 guidance. This is an SEC issue 

14 because the NIOSH Path Forward White Papers 

15 have not modeled this very important source.

16 Point number five. No direct 

17 measured monitoring data exists for either 

18 operating betatron for any portion of the 

19 covered 1953-1966 time period. This includes 

20 air monitoring or neutron flux, plausible 

21 coworker data or surrogate data. There are no 

22 valid computer models for this because there 
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1 is no real data to validate the model. MCNPX 

2 alone is not sufficient.

3 Point number six. No new old4 betatron model was introduced by NIOSH and Mr. 

5 Allen in either recent White Paper for the 

6 Path Forward GSI Initiative. This is despite 

7 the fact that SC&A modeled the facility back 

8 in two thousand -- well, a while back. The 

9 old betatron facility was built ten years 

10 earlier than the new betatron building by a 

11 different contractor using different 

12 materials.

13 The new betatron building was a 

14 short distance away from a heavily populated 

15 work area in Building 10. The old betatron 

16 was located in a field 300 feet away from the 

17 new betatron facility with heavy outside 

18 traffic around it.

19 The old betatron building had 

20 different physical characteristics that are 

21 not completely defined. Engineering drawings 

22 do not exist for either betatron facility. 
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1 Only sketches that are not to scale and are 

2 not accompanied by any certified list of 

3 construction materials. The Allis-Chalmers 

4 manual may apply or it may not apply.

5 E. All of the Mallinckrodt AEC6 contracted uranium NDT work between 1953 and 

7 1963, including the peak production year of 

8 1962 was done in an old betatron facility. 

9 The new betatron facility was not built until 

10 1963. This is also an SEC issue. Betatron 

11 Path Forward progress to date after 18 months, 

12 NIOSH has not been able to develop and 

13 validate an updated old betatron exposure 

14 model using the production code of MCNPX 

15 together with the real-world measured data.

16 Point seven, NIOSH has not modeled 

17 the two GSI radium-226 sources correctly. The 

18 sources were used inside the 6 Building 

19 radiography facility pre-1962, as well as in 

20 other GSI buildings, as testified to by 

21 workers.

22 Petitioners have shown at the 3/15 
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1 Work Group meeting that the radiograph room in 

2 building 6 facility existed as indicated on a 

3 January 29, 1957 GSI plan engineering drawing. 

4 This is also an SEC issue. 

5 Point number eight. The GSI-owned 

6 iridium-192 NDT source was not modeled at all 

7 in the Path Forward White Papers. In the 3/15 

8 meeting, petitioners reviewed five pieces of 

9 evidence that such a source was used to 

10 inspect pipe wells in Buildings 9 and 10 and 

11 rail transit cart trucks in the Building 6 

12 radiography facility.

13 We don't know the way it was used. 

14 We don't know the nominal when new size, 

15 although one worker testifies it was 20-

16 curies. Nothing is known exactly when it was 

17 used. The best estimate from testimony is the 

18 late 1950s and possibly into the early 1960s 

19 before St. Louis Testing Company entered the 

20 picture with their own iridium-192 and cobalt21 60 sources.

22 The half-life of radioactive 
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1 iridium-192 is 73.83 days. Therefore, knowing 

2 the exact curies when the source was brand new 

3 and the time passed since use are both 

4 critical for accurate modeling of this source. 

5 None of these factors are known for the GSI6 owned iridium-192 source, or for the St. Louis 

7 Testing Ir-192 source for that matter.

8 To my knowledge, the St. Louis 

9 Testing Company iridium-192 and cobalt-60 AEC 

10 source license was never obtained and 

11 examined by either NIOSH or by SC&A.

12 Point number nine, next to the 

13 last point. NIOSH has not modeled the two GSI 

14 portable 250 kVp x-ray machines correctly. No 

15 doses have been assigned to these sources by 

16 Dave Allen in his August 2011 Path Forward 

17 White Paper on portable GSI sources.

18 NIOSH knows practically nothing of 

19 where the units were used, what they were used 

20 for, what were the NDT inspection targets, how 

21 frequently they were used and by what workers. 

22 What were the exposure conditions, dose rate, 
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1 time, et cetera? These units were not 

2 equipped with safety interlock. OCAS-IG-003 

3 mandates doses from these sources must be 

4 determined. This is an SEC issue because 

5 NIOSH has not demonstrated it can model these 

6 two sources with sufficient accuracy.

7 Final point ten. The petitioners 

8 challenge the NIOSH dose model for the two 

9 small nominally 500 millicurie Co-60 sources 

10 used in the 6 Building radiography building at 

11 GSI. These data are based on Nuclear 

12 Consultants Corporation's measured data from 

13 1962, during and before the date which was 

14 July and June 1962 that D. Carr indicated was 

15 when added steel plate and concrete shielding 

16 was added to the Building 6 radiography 

17 facility. And the drawing that I showed on 

18 3/15 did show that new concrete wall material 

19 was added to that facility on those dates. 

20 One set of NCC measurements, 

21 according to NRC FOIA 2010-0012 documents was 

22 obtained in January of 1962 before the 
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1 shielding was added and the other set were 

2 made during the period the extra shielding was 

3 being installed.

4 On 3/15 the petitioner offered an 

5 analysis of the geometry of the Building 6 

6 overhead crane and catwalk which suggests it 

7 might have blocked some of the Co-60 source 

8 radiation from below.

9 The accuracy of the NCC Building 6 

10 radiography facility measured data was not 

11 checked using MCNPX code, which seems to the 

12 petitioner to be an obvious thing to do for 

13 two reasons. A) the NCC data accuracy could 

14 be established on a firmer scientific basis; 

15 and B)the NCC-measured data could serve to 

16 validate the MCNPX model. This too is an SEC 

17 issue. NIOSH cannot assign doses from the 

18 small 0.5-curie Co-60 sources because complete 

19 information is not known how these sources 

20 were used and because workers testify that 

21 some of the enumerated safety procedures, the 

22 GSI 1962 AEC license application had stated to 
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1 be in place were not followed according to 

2 worker testimony.

3 So that ends my remarks and I will 

4 try to keep my input into the matrix issues 

5 minimal because I think I have covered those, 

6 hopefully, in these remarks. 

7 Thank you very much.

8 CHAIRMAN ZIEMER: Okay, thank you. 

9 Let me see if there is questions or comments 

10 on any of these items. Okay, Bob?

11 DR. ANIGSTEIN: Okay, going down 

12 the list, about the castings being 

13 radiographed on the railroad and it was a 

14 layout man working near the ribbon door. As I 

15 said, you cannot have another casting -- not 

16 talking about the side of the casting. Two 

17 railcars cannot pass each other when they are 

18 on a single track. Therefore, there would 

19 have been no point in having a casting on the 

20 railcar inside the shooting room and another 

21 railcar blocking the exit because the whole 

22 point of it was to make this whole thing 
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1 quick. And this would have made it take much 

2 more longer.

3 DR. McKEEL: Bob? Dr. Anigstein, 

4 please let me explain. I understand what you 

5 are saying but here is the scenario that I 

6 think happened. 

7 They brought casting number one on 

8 a transfer car into the new betatron building. 

9 The crane picked it up and set it on the place 

10 where it would be imaged by the betatron. 

11 That car was then removed from the building.

12 Then a new transfer car was rolled 

13 up to the door on a urgent rush basis and 

14 things were imaged that way. And then that 

15 casting was laid out. The casting was brought 

16 into the betatron room. The other casting in 

17 this scenario would have to accommodate the 

18 shooting room in addition to the rush 

19 castings. But it was a big room and that 

20 could easily be done.

21 So I am suggesting that they 

22 brought the new casting in, they imaged it, 
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1 they took it out on the railroad transfer car 

2 and then at a more leisurely pace, they then 

3 went ahead and imaged casting number one and 

4 took it out on a railroad car. And that would 

5 be how you got to do that.

6 DR. ANIGSTEIN: Dr. McKeel, I 

7 understand that. And all I am saying is that 

8 the casting that is already in the betatron 

9 building would not have been on the railroad 

10 track. It would have been shot elsewhere in 

11 the room, where the exposure in the railcar 

12 would have been much less.

13 MR. DUTKO: Dr. Ziemer?

14 DR. McKEEL: Dr. Anigstein, I'm 

15 sorry. I really have to interrupt you here 

16 because I want to finish my line of talking 

17 here, please.

18 I understand what you are saying 

19 but once again, you can't presuppose modeling 

20 results without actually doing the work. And 

21 what I am saying is that specific situation 

22 has not been modeled. We do not know the 
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1 results of it, and you can't just state a 

2 priori I know what the results will be. You 

3 have to do the modeling.

4 Okay, that's it.

5 CHAIRMAN ZIEMER: Somebody else 

6 had a comment there?

7 MR. DUTKO: Yes, sir.

8 CHAIRMAN ZIEMER: Yes, go ahead.

9 MR. KATZ: Mr. Dutko, go ahead.

10 DR. McKEEL: Terry, go ahead.

11 CHAIRMAN ZIEMER: I wonder is he 

12 pushed the mute button or something.

13 DR. McKEEL: He might have a 

14 problem with his phone.

15 CHAIRMAN ZIEMER: Well, we will go 

16 ahead here and then if he comes back.

17 DR. ANIGSTEIN: I would like to go 

18 down the list.

19 CHAIRMAN ZIEMER: Go ahead, Bob.

20 DR. ANIGSTEIN: The second comment 

21 was that those doses of 2,470 millirem, 300 

22 millirem, this is the first we have heard of 
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1 them. In the SC&A report, my report dated 

2 November 8, 2008 explicitly listed all of the 

3 doses during the covered period that were in 

4 excess of M, meaning minimal. There were 

5 about 27 such doses. Most of them were just 

6 ten millirem and there was 40, a 300, a 2470. 

7 This was reported to NIOSH and to the Board.

8 If I remember correctly, at that 

9 time, OGC would not allow those numbers to be 

10 left in the redacted, PA-cleared copy. So it 

11 may very well be that the petitioner, the

12 others never saw those numbers in that report.

13 MR. DUTKO: Dr. Ziemer?

14 DR. McKEEL: Well, wait. Terry, I 

15 have got to finish this. Dr. Anigstein is 

16 asking me questions --

17 MR. DUTKO: I'm sorry, sir.

18 DR. McKEEL: -- and I need to 

19 answer this.

20 MR. DUTKO: I had something 

21 important to say.

22 DR. McKEEL: All right.
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1 CHAIRMAN ZIEMER: Hang on. Just 

2 hang on. Go ahead, Bob.

3 DR. ANIGSTEIN: All right.

4 DR. McKEEL: Well, I would say he 

5 said you have never seen that before but this 

6 is a report that a worker obtained by asking 

7 for his case file and specifically his NIOSH 

8 dose reports.

9 DR. ANIGSTEIN: And those numbers, 

10 Dr. McKeel, those numbers are in the data that 

11 we have and they are in my report from 

12 November 8, 2008. Our job is to report to 

13 NIOSH and to the Board, NIOSH makes the -- The 

14 rest of the Agency makes a decision of what to 

15 release to the petitioners.

16 DR. McKEEL: I just want to remind 

17 everybody that in the sample that I saw --

18 DR. ANIGSTEIN: I have that 

19 report.

20 DR. McKEEL: Well, I know you do.

21 DR. ANIGSTEIN: I have that report 

22 and I have reported it to the Board.
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1 DR. McKEEL: I am trying to show 

2 you that in the -- and I showed you the actual 

3 report in my report. You know, there is a 

4 value on that page of 2,470 millirem --

5 DR. ANIGSTEIN: And that data was 

6 reported to the Board back in November 2008. 

7 This is not new information.

8 DR. McKEEL: Well, I'm sorry then, 

9 if I am going over old information. I'm 

10 trying to summarize four years of information 

11 that we have given to this Work Group and 

12 still we have not gotten a vote on a 

13 recommendation for the SEC. So I think it is 

14 perfectly okay to do that.

15 You know, I pointed out the 

16 temporal relationship. I don't want to go 

17 into a long thing about it and I really don't 

18 think I am being cross-examined here. That is 

19 not what is going on here. What is going on 

20 here is that that data, what my comment was, 

21 that data was never completely reported to me. 

22 I personally think that OGC made an error in 
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1 that. You know, I think they can redact names 

2 but I don't think they should redact doses. 

3 That is absolutely ridiculous.

4 And I do point out that this has 

5 been a recurring theme in my interaction with 

6 the NIOSH and the Board. The Privacy Act 

7 doesn't cover dead people. And a lot of the 

8 doses that we were talking about were deceased 

9 people.

10 So anyway, I apologize if I 

11 belabored old data that everybody knew about. 

12 But when I keep on hearing that the vast 

13 majority of these numbers were M, then all I 

14 can say is from a simple spot check, I wanted 

15 to put some perspective on that observation 

16 and I believe I did.

17 CHAIRMAN ZIEMER: Dan, we 

18 appreciate that. And actually I wasn't aware 

19 that these numbers got redacted. If they 

20 were, I am not personally sure why they would 

21 have redacted numbers.

22 DR. McKEEL: They did.
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1 DR. ANIGSTEIN: They were 

2 redacted.

3 DR. McKEEL: I thought it was 

4 improper at the time and I still do.

5 MS. LIN: I'm not quite sure, I 

6 think I haven't seen a copy of --

7 DR. ANIGSTEIN: It was long before 

8 Jenny was on the team.

9 CHAIRMAN ZIEMER: Our current 

10 counsel here wasn't aware of that. But we 

11 will anyway, just so you are aware, we had 

12 seen the numbers.

13 MR. KATZ: I don't know 

14 specifically, but it is very possible, you 

15 don't just redact names, you redact any

16 information that would be identifying. And in 

17 some cases where numbers are unusual and in 

18 effect would be identifying in and of 

19 themselves, you would have redacted them too. 

20 It is anything that is identifying, not just 

21 names. So that is possibly what happened. I 

22 couldn't tell you.
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1 CHAIRMAN ZIEMER: They might have 

2 redacted whole lines, you mean?

3 MR. KATZ: So they would have 

4 redacted any information that would lead 

5 someone to be able to identify an individual, 

6 not just a name is what I am saying.

7 So if you have, for example, only 

8 a few data points and so there are only three 

9 workers that were ever involved in a certain 

10 operation or what have you, you would have 

11 redacted all the information you needed to 

12 protect the privacy of those individuals.

13 CHAIRMAN ZIEMER: And of course an 

14 M is also considered a number here. So I'm 

15 not sure --

16 DR. MAURO: No, I know exactly 

17 where it was --

18 CHAIRMAN ZIEMER: Well, okay.

19 DR. MAURO: I was there.

20 CHAIRMAN ZIEMER: It apparently 

21 happened. Our apologies. I wasn't aware that 

22 that had happened.
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1 (Simultaneous speaking.)

2 MR. KATZ: Okay, so that's what --

3 MEMBER BEACH: And then John had a 

4 comment.

5 MR. ALLEN: Can I make one comment?

6 CHAIRMAN ZIEMER: Okay. Yes, Dave 

7 Allen.

8 MR. ALLEN: From what Dr. McKeel 

9 put in here, the numbers he is pointing to, I 

10 just wanted to point out that the column of 

11 numbers of that he is pointing to is the 

12 permanent column.

13 CHAIRMAN ZIEMER: The accumulated 

14 dose?

15 MR. ALLEN: Right, this is their 

16 essentially lifetime dose for the period of 

17 time that Landauer had the dosimetry data. 

18 The number to the right of that is the number 

19 of the badge reading, the badge number.

20 CHAIRMAN ZIEMER: The badge, what 

21 that represents.

22 MR. ALLEN: Like 125 for a number 
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1 of them, et cetera.

2 CHAIRMAN ZIEMER: Okay.

3 MR. ALLEN: The numbers all the 

4 way to the left, the column of Ms all the way 

5 to the left are the weekly badge readings for 

6 that particular week.

7 CHAIRMAN ZIEMER: Yes.

8 MR. ALLEN: And the three columns 

9 that end with those numbers he is pointing to 

10 are calendar quarter, calendar year, and 

11 permanent.

12 CHAIRMAN ZIEMER: Right.

13 DR. McKEEL: And what I am trying 

14 -- this is Dan McKeel again. What I was 

15 trying to show is the 300 millirem dose. I 

16 understand that is a cumulative dose and I 

17 said that in my little report, but that 

18 occurred over a month's period of time. So it 

19 was a dose that suddenly appeared on the 

20 record. That is the only point I was trying 

21 to make and I think I showed one report from 

22 April 25, `66 and another snippet of a report 
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1 from a month later and the 300 millirem was 

2 not on the first one but was on the second 

3 one. So I think that is the correct 

4 interpretation of that, that it newly 

5 appeared.

6 CHAIRMAN ZIEMER: Okay.

7 MR. ALLEN: That is actually not 

8 the correct interpretation but it would be 

9 hard for a redacted copy to get the right 

10 interpretation. And that is actually a 

11 different person. When people who were not 

12 there or did not turn in a badge, then they 

13 were not on the weekly report.

14 DR. McKEEL: Well, then that is a 

15 great example. I'm glad we have put this on 

16 the record because it is one more example of 

17 why overly severe redaction can not only 

18 impair information flow but it can actually 

19 cause -- and I have said it all along, there 

20 is a gray area between protecting privacy and 

21 censorship. And I think that is a great 

22 example. If that is the truth, then it is 
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1 misleading to redact those numbers.

2 MR. KATZ: Well, it may be hard to 

3 interpret, Dan, but it is certainly not any 

4 intent of the Agency to censor anything other 

5 than to protect privacy.

6 DR. McKEEL: Well, the Privacy Act 

7 -- Ted, let's not go into that.

8 MR. KATZ: Fine. That's fine. 

9 But I am just telling you because I know how 

10 things work and there is no one censoring 

11 anything.

12 DR. McKEEL: I do, too.

13 CHAIRMAN ZIEMER: Bob, you have a 

14 comment?

15 DR. ANIGSTEIN: One comment. To 

16 clarify those doses right now apparently we 

17 are talking about them, the 2,470 was a single 

18 one-week incident.

19 CHAIRMAN ZIEMER: Yes, well, we 

20 have discussed that one over and over again.

21 DR. ANIGSTEIN: Okay.

22 CHAIRMAN ZIEMER: Don't go through 
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1 it again.

2 DR. ANIGSTEIN: Okay.

3 CHAIRMAN ZIEMER: Okay.

4 MEMBER BEACH: I think John had 

5 something, John on the phone.

6 CHAIRMAN ZIEMER: John on the

7 phone had a comment.

8 MR. DUTKO: Yes, one quick 

9 comment, Dr. Ziemer. Can you hear me now?

10 CHAIRMAN ZIEMER: Yes.

11 MR. KATZ: Yes.

12 MR. DUTKO: I would like to inform 

13 Dr. Anigstein that there is no law that two 

14 castings can't be present in the shooting room 

15 at one time. We did that many, many times. A 

16 transfer car is a lot shorter than a low-boy. 

17 Like you saw the Marion axle loader. The 

18 Marion axle weighed 96 tons in over four 

19 axles. That, of course, couldn't happen.

20 But many times, we had two 

21 transfer cars back-to-back at the base of the 

22 DL and you could unload castings, either/or. 
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1 Thank you, sir. 

2 CHAIRMAN ZIEMER: Okay, thanks. 

3 That is helpful. Okay, Bob did you have any 

4 additional comments?

5 DR. McKEEL: I would like to --

6 this is Dan McKeel. Having heard that answer, 

7 what it means is that it underscores what I 

8 wrote, that that scenario needs to be modeled. 

9 And it can't be passed off and swept under 

10 the rug because it is impossible to occur. 

11 Not only is it possible to occur, but Mr. 

12 Dutko has just testified that it did occur 

13 frequently.

14 CHAIRMAN ZIEMER: Okay.

15 DR. McKEEL: Okay?

16 DR. ANIGSTEIN: I want to ask 

17 Terry. I don't know if it was clear. I 

18 didn't say that you couldn't have a second 

19 casting in that room. I was going to say that 

20 you wouldn't have a second casting on the rail 

21 car on the tracks being radiographed at the 

22 same time there was another car just outside 
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1 the door. Because the only reason that my 

2 understanding from you is that you would 

3 radiograph the casting on the car on the track 

4 would be to save the time. But since you 

5 couldn't get one out and the other one in on 

6 the same track at the same time --

7 MR. DUTKO: Comment, Doctor --

8 DR. ANIGSTEIN: -- you would have 

9 removed it. You would have unloaded it with a 

10 crane and put it elsewhere in the room. I 

11 don't disagree with that. I'm just saying 

12 that it wouldn't be shot on the railroad track 

13 while there was a second rail car just outside 

14 the door.

15 MR. DUTKO: Dr. Anigstein, we did 

16 not shoot everything on the railroad tracks.

17 DR. ANIGSTEIN: No, but I was only 

18 looking at this limiting scenario. Because 

19 once it was off the railroad track, the 

20 betatron was no longer pointing towards the 

21 ribbon -- in the direction of the ribbon door. 

22 And I am simply saying that my analysis of 
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1 the layout man was --

2 MR. DUTKO: But it is not normal 

3 casting work, Dr. Anigstein.

4 DR. ANIGSTEIN: Pardon?

5 MR. DUTKO: A 96-ton casting is 

6 not normal.

7 DR. ANIGSTEIN: I know. And then 

8 I took that as the limiting case.

9 MR. DUTKO: It was an exceedingly 

10 long casting that would limit another transfer 

11 car or low-boy of course behind it. But in 

12 all other cases, 99 percent of the time we 

13 could put two transfer cars back-to-back close 

14 by the shooting cell where they could be 

15 unloaded by cranes.

16 Many times, sir, many times we 

17 have two large turbine hulls in the shooting 

18 area. Many times.

19 DR. ANIGSTEIN: Sure. I'm not 

20 disagreeing with that. I am simply saying you 

21 would unload it with a crane. That was my 

22 whole point.
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1 CHAIRMAN ZIEMER: Okay, other 

2 questions here? Okay, then are we ready to 

3 move -- oh, another comment?

4 DR. ANIGSTEIN: Yes, I am going 

5 down the list of Dr. McKeel's --

6 CHAIRMAN ZIEMER: Oh, okay. Finish 

7 up your list.

8 DR. ANIGSTEIN: So okay, the 

9 question is: the point that Dr. McKeel raised 

10 about the 80-curie source. Yes, I have seen 

11 some people saying that it was there. Several 

12 other workers who gave us extensive 

13 information on other things said it was not 

14 there. It was not there during that period.

15 So we have it on record, recorded 

16 interviews that they said, no, I knew nothing 

17 about such a source. If that source had been 

18 there, I would have known about it. I don't 

19 believe it was ever there.

20 So we have to make a judgment. 

21 And the fact that it would have been difficult 

22 for the Commonwealth facility to have obtained 
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1 an 80-curie source without an AEC license, and 

2 we could not trace where it came from. We 

3 even went to the extent of saying, well, maybe 

4 they got it from another GSI facility and it 

5 was like a transfer in between facilities, 

6 wasn't legal but maybe they just did it. 

7 There was no other GSI facility that had such 

8 a source.

9 So we just believe on the weight 

10 of the evidence that it was highly unlikely.

11 DR. McKEEL: Well, Dr. Anigstein, 

12 this is Dan McKeel.

13 DR. ANIGSTEIN: Well, let me 

14 finish.

15 DR. McKEEL: Why did you model it 

16 in 2008, if you didn't think it was a valid 

17 source?

18 DR. ANIGSTEIN: Excuse me?

19 MEMBER BEACH: He wanted to know 

20 why you modeled it.

21 DR. ANIGSTEIN: Back in 2008, we 

22 didn't know that. We hadn't gotten the AEC 
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1 records. We got the 80-curie records --

2 (Simultaneous speaking.)

3 DR. McKEEL: That means you should 

4 have accepted the worker's testimony.

5 DR. ANIGSTEIN: The information 

6 was always contradictory. Some people said 

7 yes. Some people said -- we heard in my 

8 interview with the workers back in 2007, I 

9 heard there was an 80-curie source, so I put 

10 it into the model. I later learned that the 

11 80-curie source came after the covered period. 

12 And several workers said it was not there 

13 earlier. Some said it was. We just made that 

14 judgment.

15 CHAIRMAN ZIEMER: Well, we have 

16 had these discussions before. We know there 

17 is conflicting testimony on that source. 

18 There is also some conflicting testimony on 

19 presence of the iridium source. So we have 

20 both on the record.

21 DR. ANIGSTEIN: Okay, I can go 

22 down the list. The radium-226, the small 
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1 radium-226 sources, the analysis that was 

2 performed, certainly the analysis that SC&A 

3 performed is a bounding analysis. It already, 

4 whether occasionally or frequently the sources 

5 were taken out of the shooting room, the one 

6 radiographer said it happened very rarely. As 

7 long as NIOSH has now adopted a policy and 

8 they will assign the maximum dose for any 

9 given period to all workers, it is irrelevant. 

10 Because the same person that said they shot 

11 outside the shooting room also said they set 

12 up a two mR per hour boundary so the workers 

13 would not be exposed to -- they were actually 

14 exposed to a higher dose rate from that 

15 radiographic room in 206 -- in Building 6 if 

16 they happened to be right outside the door.

17 And both Dave Allen and I 

18 independently analyzed okay, let's say nobody 

19 is watching the store and sometimes the worker 

20 is going to cross that boundary. We analyzed. 

21 We calculated the doses. They are small. 

22 They are very small additional doses. You 
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1 know, no worker -- it is highly unlikely the 

2 worker will deliberately go and say here is a 

3 nice place. I'm going to sit on top of the 

4 source and have my lunch. That is ludicrous.

5 DR. McKEEL: Actually, there is 

6 testimony that in fact people walked through 

7 there all the time when the source was in 

8 there.

9 DR. ANIGSTEIN: Well, the same 

10 person would not have been next to, staying 

11 for eight hours next to that source. They 

12 might have been walking past it, and we 

13 accounted for that. And it is a very small 

14 additional dose, and it is far less than the 

15 limiting dose to the radiographer.

16 DR. McKEEL: Well, once again, I 

17 have just got to put on the record --

18 DR. ANIGSTEIN: You may not 

19 believe our analysis, but they are on record. 

20 They have been reported by NIOSH. They are 

21 reported by SC&A.

22 DR. McKEEL: I don't think the SEC 
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1 issue is whether SC&A can calculate that dose. 

2 And that is not -- the thrust of my comment 

3 was that NIOSH hadn't modeled it correctly.

4 DR. ANIGSTEIN: Yes, they have.

5 DR. McKEEL: Oh, okay.

6 DR. ANIGSTEIN: And the point is 

7 it is limited. It is limited by the dose to 

8 the radiographer. And then the next item, the 

9 iridium-192 source, it would have been, again, 

10 as I recall, would have been even more 

11 difficult for GSI to have obtained an illegal 

12 iridium-192 source. There would have been no 

13 point to it because it is only good for a few 

14 months, then it has to be sent back to a 

15 facility that has a nuclear reactor and they 

16 will take the iridium metal and will re17 irradiate it to refresh to boost up its 

18 activity so it can be used again.

19 And all of this was going on 

20 illegally, hidden from the AEC, you are having 

21 a criminal enterprise --

22 DR. McKEEL: Dr. Anigstein, if I
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1 hadn't h’ve gotten those 1,016 pages of NRC 

2 2010-0012, you wouldn't have even known about 

3 a lot of the sources that were there. You 

4 wouldn't have even known about the radium-226 

5 sources.

6 DR. ANIGSTEIN: As it happened --

7 DR. McKEEL: I showed you, I sent 

8 the Work Group an excerpt from the 1968 

9 renewal application from GSI that said this 

10 site was licensed for iridium and cobalt. And 

11 the reaction was, oh, well, that was past the 

12 covered period. But actually if you think 

13 about the words, it didn't say when it was 

14 licensed. It just said it is licensed for.

15 DR. ANIGSTEIN: It is licensed as 

16 of the moment.

17 DR. McKEEL: I am saying that plus 

18 I gave you four new worker affidavits.

19 DR. ANIGSTEIN: Right.

20 DR. McKEEL: So, again, if you 

21 ignore that and disbelieve that and your 

22 argument about the half-life and not being 
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1 practical, I just point out to you that you 

2 all easily accept that St. Louis Testing had 

3 an iridium-192 source.

4 DR. ANIGSTEIN: Why not?

5 DR. McKEEL: You haven't gotten 

6 their license. You haven't looked at that.

7 So maybe if you tried harder, you 

8 would get the GSI iridium-192 source license.

9 DR. ANIGSTEIN: Okay.

10 DR. McKEEL: I can't do 

11 everything.

12 DR. ANIGSTEIN: Dr. McKeel, number 

13 one, just for the record and I haven't said 

14 this before, I did go to the NRC and made --

15 and requested information on GSI.

16 DR. McKEEL: I understand that, 

17 but you didn't get the records.

18 DR. ANIGSTEIN: Just a moment. 

19 Let me finish, please. They told me that they 

20 have already fielded such a request from you. 

21 They gave me your name and said they had 

22 already searched all their records and they 
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1 found nothing.

2 Consequently, I didn't bother. I 

3 said why waste going through the paperwork if 

4 they have already told me they already made 

5 that search. Now the reason they found 

6 nothing is that it had the incorrect name. 

7 Your original request to them was under 

8 General Steel Castings. They searched that 

9 name. They got nothing.

10 When I asked them about General 

11 Steel Castings or General Steel Industries, 

12 they said they already searched for it, and I 

13 did not pursue it only for that reason.

14 Now I find out you went back and 

15 used the correct name, which I think you 

16 deserve credit for, but it is not that we 

17 didn't think of it. We were thrown off the 

18 trail by your original request under the wrong 

19 name.

20 CHAIRMAN ZIEMER: Well be that as 

21 it may, let's proceed here. Any other 

22 comments, Bob, on any of the other issues?
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1 DR. ANIGSTEIN: Yes. Well anyway 

2 and as far as the iridium-192 going on, we 

3 have a continued -- in the records which you 

4 finally obtained, there was a continuous 

5 sequence of license amendments. The original 

6 license, amendment one, amendment two, 

7 amendment three. There are no missing 

8 numbers. And the first one that mentions the 

9 cobalt-80 -- the 80-curie cobalt-60 source and 

10 mentions iridium is the amendment that was 

11 issued in 1968. The previous, the one number 

12 just before it does not mention that and 

13 mentions only cobalt-60 not to exceed one 

14 curie.

15 My personal opinion is what they 

16 obtained was a camera, which means a big lead 

17 shield with mechanism for the sources to be 

18 removed -- to stick out and be retracted. And 

19 that camera was actually designed both for 

20 cobalt-60 and for iridium-192. I forget the 

21 name of the company now that made it. It had 

22 two channels, and there was one for each 
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1 source. So having a camera that could hold 

2 both, they apparently decided that they might 

3 as well, in case they want to in the future 

4 have it, they are licensed for it. But that 

5 was only in 1968.

6 DR. McKEEL: Well I would suggest 

7 that that one license that's after the cobalt8 60 license, that could have been one license. 

9 But for instance, when I was involved with 

10 the Dow SEC, they had numerous licenses.

11 DR. ANIGSTEIN: That's not true.

12 DR. McKEEL: And so they could 

13 have easily had a different license that is 

14 not recoverable by DOE, not recoverable by 

15 NRC, which many of their records are not. So 

16 once again, we have made this point in many 

17 other scenarios to the Board that the absence 

18 of a particular record does not mean the 

19 record never existed.

20 It doesn't mean it did exist but 

21 against that and using that reasoning you also 

22 have to deny the testimony of a number of 
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1 people, not just the gentleman that Dr. Ziemer 

2 interviewed and later retracted and said he 

3 meant cobalt instead of iridium, but we have 

4 other people who made affidavits about there 

5 being a GSI iridium source on different 

6 occasions over a long period of time from the 

7 1950s forward. And I am saying that to be 

8 claimant favorable, if you really believe that 

9 that is what the job is, then the claimant 

10 favorable thing to do would be to calculate 

11 those doses and show that you can do that.

12 And, again, I view that as the job 

13 of NIOSH. So my statement still stands. I 

14 don't think they have done that, and I think 

15 they need to do that.

16 CHAIRMAN ZIEMER: Okay, Bob, any 

17 other points?

18 DR. ANIGSTEIN: I think I will 

19 stop.

20 CHAIRMAN ZIEMER: Okay.

21 MR. RAMSPOTT: Dr. Ziemer?

22 CHAIRMAN ZIEMER: Yes.
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1 MR. RAMSPOTT: John Ramspott. If 

2 I may, on the one topic Bob mentioned, the 

3 radium source.

4 CHAIRMAN ZIEMER: Yes.

5 MR. RAMSPOTT: Just to set the 

6 record straight or publicly spell it out a 

7 little bit, the gentleman that said the radium 

8 was seldomly used outside the building was a 

9 part-time radiographer who worked primarily on 

10 weekends. And the gentleman who everybody 

11 acknowledged he actually was that gentleman's 

12 supervisor, ‘ identifying information 

13 redacted’, told us on record at the last Work 

14 Group meeting, I believe, that they used 

15 radium any time they needed to. They used any 

16 of the sources, the small sources, anywhere in 

17 the plant, they could do it. 

18 He is also the gentleman who said 

19 yes, I set up a perimeter. Then the guy who 

20 was teaching me the ropes, we both left. We 

21 went and did our other jobs. So setting up a 

22 perimeter is only as good as if you are there 
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1 watching it.

2 And then the other item that he 

3 confirmed was the radium source was actually 

4 stolen or taken out of 10 Building. He 

5 actually had to go report it to upper 

6 management and that is when the big search 

7 started for the missing radium plumb-bob. It 

8 was radium that was used in the plumb-bob.

9 So to say the sources are pretty 

10 much used in the 6 Building radiograph room, 

11 that is far-fetched and totally wrong.

12 CHAIRMAN ZIEMER: Okay, thanks 

13 John.

14 MR. RAMSPOTT: Thank you.

15 CHAIRMAN ZIEMER: Okay, I would 

16 like to move to the matrix, if you would pull 

17 that out.

18 There are ten items in the matrix, 

19 one of which we had previously closed. We 

20 have a summary that SC&A added on page five 

21 where they talked about the importance of the 

22 issues and highlighted Issue 1 and 6. They 
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1 also indicated that they recommended closing 

2 Issues 4 and 5, although in your narration you 

3 also made a similar recommendation for 2 and 

4 3. So those are in there. And 2, 3, 7 

5 through 9 are identified as being of medium, 

6 what's the term, importance, whatever that 

7 means. It is kind of an arbitrary term.

8 I think we will just go through 

9 them in order, even though you have 1 and 6 as 

10 highest importance. I think that is easier 

11 just to go through them in order and see what 

12 questions we have and what issues are still 

13 opened up.

14 Issue 1 had to do with monitoring 

15 data or more particularly what was identified 

16 as lack of monitoring data for the early 

17 years, which would be '53 to '63, maybe late 

18 '62. The cutoff may not be quite so clear. 

19 But in that time range. And during that 

20 period, you have the betatrons in use and you 

21 have the radium radiographic sources being 

22 used.
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1 DR. McKEEL: And you have the 

2 iridium.

3 CHAIRMAN ZIEMER: And the 

4 petitioner also indicates they believe that 

5 iridium was used at least in part of that 

6 period.

7 Now as I understand SC&A -- I am 

8 going toward the end of the matrix here, SC&A 

9 say that they believe it is possible to 

10 reconstruct doses during the early years using 

11 the bounding calculations. In this case, they 

12 would use the bounding calculations for radium 

13 for all the workers and then you would use, I 

14 guess, the betatron values for the betatron 

15 workers.

16 MR. ALLEN: It was actually just 

17 every scenario. We picked the highest 

18 essentially is what is going to be.

19 CHAIRMAN ZIEMER: Every scenario 

20 of the --

21 MR. ALLEN: If the radiography was 

22 going to give you more than betatron or layout 
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1 worker --

2 CHAIRMAN ZIEMER: Right. In other 

3 words, if the person for a particular organ --

4 MR. ALLEN: It would be for a 

5 particular case.

6 CHAIRMAN ZIEMER: -- or for a 

7 particular case, if they got more from the 

8 dose assigned by the radium model, you would 

9 assign that even if they were a betatron 

10 worker.

11 MR. ALLEN: Yes, because I don't 

12 think it was ever --

13 CHAIRMAN ZIEMER: It wouldn't be 

14 distinguishing between them.

15 MR. ALLEN: I don't think you can 

16 -- it would be pretty tough in probably any 

17 time frame to distinguish a betatron operator 

18 from source radiographer. I mean they did 

19 some of that interchangeably. Some 

20 concentrated on betatron, but they did get a 

21 little bit of source and most you just flat 

22 wouldn't know.
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1 CHAIRMAN ZIEMER: Okay.

2 DR. MAURO: A little qualifier 

3 here, and Bob certainly --

4 CHAIRMAN ZIEMER: Well there also 

5 is, part of your recommendation is that the 

6 '53 through '56 period you say it is not clear 

7 that bounding exposures can be assigned during 

8 that time period. And I certainly want to ask 

9 how do you see the first three years of that 

10 as being different from the next five or six?

11 DR. ANIGSTEIN: Okay, the main 

12 reason being that we have next to no 

13 information during the first four years. 

14 However, starting with '56 we have the one 

15 gentleman whom we interviewed, who gave a very 

16 good account. He did the radium radiography. 

17 He gave a very clear description of how it 

18 was done. And he turned over his accumulated 

19 exposure records.

20 We started by looking at it and 

21 carefully he recalled coming, he said he had 

22 come to work at GSI. He was laid off. He 
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1 went into the Army. He came back in '56 and 

2 went back to work for GSI. All right, the 

3 earlier years he had not done any radiography. 

4 Later he did.

5 But his record starts with -- it 

6 was produced in 1962 when the Nuclear 

7 Consulting Company came onboard and they 

8 applied for the AEC license. So I guess a 

9 part of the process they produced this record 

10 and they looked at -- they just said records. 

11 So they must have had earlier records which 

12 they examined and they had 18 quarters. So if 

13 you back calculate, this was done early in '62 

14 so it was not a full quarter again. So 18 

15 quarters would be four and a half years. So 

16 this would put us into the middle of 1957. So 

17 therefore it was most likely that this person 

18 started, he had other duties at GSI, started 

19 doing radiography in 1957. So that just seems 

20 like a good break point.

21 And by using his exposure record 

22 and taking into account the fact that he 
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1 worked most weekends one or two days. He said 

2 he worked as much as he could. He didn't say 

3 he worked every single Saturday and Sunday all 

4 year, but he worked most weekends and often 

5 more than one shift during the weekend.

6 So if you can take his record and 

7 then prorate it to a full-time worker, you 

8 come with something about, my memory of the 

9 record, something up to 20 rem a year could 

10 have been. So that is one piece of evidence.

11 The second piece of evidence is 

12 the statement made during a site visit made to 

13 the AEC inspector that they have maintained 

14 records ever since they had this film badge 

15 program going back. We know -- we have good 

16 evidence it was there in 1953 because we have 

17 a photograph taken in 1953 of a betatron 

18 operator, and it very clearly appears that he 

19 is wearing a film badge on his belt. 

20 And they said that during that 

21 period the then applicable -- they were very 

22 careful to qualify that each year they kept 
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1 track of what the AEC rules were, even though 

2 it didn't apply to them and they made sure 

3 that they stayed within the limits for that 

4 year. So at one point it was 15 rem and then 

5 later on it was essentially 12 rem because it 

6 could be 3 rem a quarter. So they said they 

7 always stayed within that. And they said they 

8 were never exceeded, which led to the 

9 possibility that they might have reached 

10 somewhere near that limit and on average for 

11 25 percent. So I take that as a second piece 

12 of evidence saying during these years it was 

13 probably 12 rem would be a good upper limit. 

14 And that is within the range of the 

15 extrapolated readings from this one person who 

16 worked on the weekends. So that was the 

17 second piece of evidence.

18 And the third piece of evidence is 

19 the model which I showed earlier my diagram of 

20 that room where I modeled here is the man --

21 well the source is inside a deep well inside a 

22 lead shield so -- a little external radiation. 
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1 He lifts it out, holds it four feet away from 

2 his body, brings it in, puts it down next to 

3 him, puts it back. In-between shots he is in 

4 that concrete room but without any steel 

5 shield and that comes out to about 12 rem a 

6 year.

7 So when you get that much 

8 coincidence, you say you know, that looks like 

9 a pretty robust model.

10 And prior to the record to the 

11 verbal testimony of this gentleman and prior 

12 to this record, we really don't have any 

13 information. We still say, yes, they probably

14 didn't exceed the limits, but that is only one 

15 leg of a three-legged stool and now we have 

16 all three legs.

17 And you can say, well, can you 

18 trust their testimony. They would not have 

19 likely lied to the AEC inspector when he could 

20 simply say is that what you are telling me? 

21 Let me see those records. So it seems 

22 unlikely that they would have. They 
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1 volunteered that information. They weren't 

2 required to give it because the radium use was 

3 not under AEC control.

4 All in all it seemed like a very 

5 believable story that from mid-'57 to 

6 somewhere, you know, we can talk about the 

7 exact number but something on the order of 12 

8 rem from mid-'57 to mid-'62, it would be a 

9 five-year period, would probably be bounding. 

10 Starting with May '62, you have the cobalt-60 

11 sources, which were much more tightly 

12 controlled that were using these lead shielded 

13 cameras, the exposures were much lower. And 

14 as a matter of fact, this gentleman's film 

15 badge records for as soon as the cobalt-60 

16 sources dropped dramatically from a rem a year 

17 to a millirem a year.

18 And then if we just say in rough 

19 numbers let's consider, even though they 

20 started using the cobalt in '62, let's assign 

21 the annual dose for all of '62 the same as for 

22 the previous years. And then in '63 already 
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1 you have the betatron. True, it is toward the 

2 end of the year but if we just say this time, 

3 we don't know exactly when, let's assign it 

4 for the full year. And we have again, by this 

5 model that I showed you a little earlier, 9.2 

6 rem -- 9.2 R per year.

7 So all of those periods are 

8 covered and with very claimant-favorable 

9 exposure estimates. And so that would seem to 

10 be a good break point.

11 CHAIRMAN ZIEMER: I will add one 

12 comment. I went back and looked at Dr. 

13 Konneker's letter which is part of the -- I 

14 think January '63 was the date on it. It was 

15 part of the application for the AEC license.

16 DR. ANIGSTEIN: Well he followed 

17 it up with a survey.

18 CHAIRMAN ZIEMER: Yes, but --

19 DR. ANIGSTEIN: But the license --

20 they got the sources in May, I believe in May 

21 of '62.

22 CHAIRMAN ZIEMER: But there is a 
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1 statement in his letter that says and he is 

2 talking about the training courses and the 

3 film badges. He says the training course has 

4 been used successfully for 15 years and the 

5 published dose limits were followed. The 

6 published dose limits --

7 DR. ANIGSTEIN: Yes, that is what 

8 I said.

9 CHAIRMAN ZIEMER: -- these are 

10 NCRP or --

11 DR. ANIGSTEIN: They meant AEC, I 

12 believe.

13 CHAIRMAN ZIEMER: Well it could 

14 have been AEC also.

15 DR. ANIGSTEIN: In another place 

16 they --

17 CHAIRMAN ZIEMER: If you go back 

18 15 years, yes it could be either one. It says 

19 the published dose limits were followed. And 

20 it also said no one has exceeded these limits.

21 Now if he goes back 15 years from 

22 1963 --
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1 DR. ANIGSTEIN: I see.

2 CHAIRMAN ZIEMER: -- you are 

3 actually back to '48 --

4 DR. ANIGSTEIN: Right.

5 CHAIRMAN ZIEMER: -- which is 

6 prior to this date.

7 But all I am saying is that 

8 Konneker suggests that whatever that program 

9 was was being followed earlier. 

10 DR. ANIGSTEIN: Oh, okay.

11 CHAIRMAN ZIEMER: That is all I am 

12 saying.

13 But there is not any -- you have 

14 some sort of independent evidence. Two 

15 things. You have that person's film badge 

16 records --

17 DR. ANIGSTEIN: Yes.

18 CHAIRMAN ZIEMER: -- and we do 

19 have the photograph of '53 showing or '56 --

20 DR. ANIGSTEIN: 1953.

21 CHAIRMAN ZIEMER: Yes, '53.

22 DR. ANIGSTEIN: And also I have, 
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1 you are going by Konneker's letter which I 

2 must have -- I probably -- I'm sure I saw it 

3 but I was going by a part of the AEC 

4 application where they had made this statement 

5 to the AEC, where the person in charge of the 

6 program, a GSI official, made that statement 

7 to AEC that they've always followed -- that 

8 they followed the AEC rules. They followed 

9 the AEC limits.

10 CHAIRMAN ZIEMER: Right. This 

11 letter was in connection with a survey that 

12 Konneker did.

13 DR. ANIGSTEIN: Yes. It is not 

14 contradictory.

15 CHAIRMAN ZIEMER: Right.

16 DR. ANIGSTEIN: As a matter of 

17 fact, I think it reinforces it.

18 DR. McKEEL: Dr. Ziemer, this is 

19 Dan McKeel.

20 CHAIRMAN ZIEMER: Yes?

21 DR. McKEEL: Let's see, my comment 

22 would be as follows. I really find it 
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1 astounding that we are basing an argument that 

2 you can bound doses based on letters and a 

3 photograph. I'm sorry, I just have to put 

4 this on the record.

5 The Board has given SECs to many 

6 sites that have far more hard film badge data 

7 with neutrons and everything. This is really 

8 ridiculous.

9 I'm sorry. I understand words and 

10 what they are meaning, and I hate to use a 

11 term like that, and I am using this in terms 

12 of scientific proof and good science. This is 

13 terrible. 

14 You are saying that one man's film 

15 badge records. You can't even substantiate 

16 the program. You don't have any other 

17 reports. It happens to be this one fellow 

18 volunteered this material to us and we gave it 

19 to you. That's fine.

20 But to base an entire seven years 

21 on that and then to say that to base it also 

22 on Dr. Konneker's letter, if Dr. Konneker was 
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1 accurate, then where is all that data? You 

2 know, did it just go away? Did it vanish in 

3 thin air? There is no evidence of that film 

4 badge data. And to say that a letter that a 

5 self-serving company is providing with their 

6 license application is absolutely ridiculous.

7 Now I know, as a matter of fact, 

8 from interacting with the Hematite site in the 

9 early days, back in the early '50s and so 

10 forth, that they were required from day one to 

11 hold on to their film badge records. Yes, the 

12 AEC may have gotten a copy, but that site had 

13 to hold on to their own film badge records. 

14 And what is totally missing, what is totally 

15 absent is any evidence that that data actually 

16 existed at GSI.

17 So when Dr. Konneker says they 

18 have been having a program like that for 15 

19 years, I'm sorry. We had an opportunity to 

20 interview him. We had a deal set up. Dr. 

21 Anigstein was going to call him; Dave Allen 

22 was going to interview him; and I was going to 
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1 listen in. That interview was aborted. Dr. 

2 Anigstein had a talk with Dr. Konneker, but 

3 not Dave Allen, and I wasn't even allowed to 

4 participate other than to listen. And I 

5 didn't even get that opportunity.

6 But if I had talked to him, I 

7 would have asked him questions like that. You 

8 know? I mean, I don't think that stands up at 

9 all.

10 And I will just point out another 

11 thing. We have direct testimony from ‘ 

12 identifying information redacted’ is one and 

13 other workers who absolutely contradict that 

14 idea that there were annual AEC training 

15 courses. There was not. There was a lecture 

16 that Dr. Konneker gave at Washington 

17 University that ‘ identifying information 

18 redacted’ said he attended with three other 

19 supervisors. The other three supervisors 

20 flunked the written test, and he passed.

21 But the point is that that is the 

22 only evidence we have on the record of any 
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1 worker ever taking a written test.

2 Now yes, does the license 

3 application say that that was done all the 

4 time? Yes, it does. Is there any proof that 

5 it ever happened? And there were men who 

6 lived back in that era. No, there is not. ‘ 

7 identifying information redacted’ was the only 

8 one. He said there were three people there.

9 So I think that to accept that 

10 kind of data, I hope this Work Group won't do 

11 it, and I am going to argue until the last 

12 vote is cast that the full Board does not 

13 accept that kind of evidence.

14 I think the fact is you have no 

15 hard evidence from 1953 up through 1962 that 

16 would stand up in court. And an n of one to 

17 base seven years of denying an SEC on is just 

18 not acceptable scientific reasoning, and I 

19 hope you won't do it.

20 I guess that's all I want to say.

21 CHAIRMAN ZIEMER: Okay.

22 MR. RAMSPOTT: Dr. Ziemer?
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1 CHAIRMAN ZIEMER: Yes.

2 MR. RAMSPOTT: I would like to add 

3 something to that, if I could.

4 The worker, again I don't want to 

5 beat a dead horse, but you have got one 

6 worker's badge records. He is a part-time 

7 worker, part-time radiographer. And what do 

8 you do when he is part-time? They do look at 

9 these badges weekly. If he is not there and 

10 then all of a sudden he goes there on 

11 Saturday, his weekly badge report is going to 

12 look pretty good, even if he got a dose, a 

13 heavy dose because it would be divided by 

14 seven days instead of one. I mean, that is 

15 almost fictitious.

16 You know, and now I am actually 

17 looking at a magazine here in front of me, and 

18 I know I have provided it to SC&A, NIOSH, I 

19 think yourself. I can email it to you in about 

20 a minute. It is dated 1964. And the one 

21 source that you are referencing as a 

22 radiographer, it states in here these 
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1 Commonwealthers have just completed the first 

2 isotope training course. This is 1964 March. 

3 Here is Mr. Powers. Here is Mr. Leroy Dell. 

4 Here is all these guys in here. A whole crew. 

5 1964. This guy that wrote a letter and said 

6 they went back to 1948 is on drugs. He's way 

7 off. I'm going to email this to you here in 

8 about a second. I will send it to Ted. It is 

9 1964.

10 CHAIRMAN ZIEMER: I think we have 

11 seen that actually. The only point I was 

12 making, I think Bob was making, was not that 

13 we would base an SEC or not an SEC on these 

14 pieces of data. The question is whether or 

15 not there was any kind of monitoring going on 

16 during those early years.

17 MR. RAMSPOTT: It said the 

18 Commonwealthers pictured here were the first 

19 to successfully -- the first to successfully 

20 complete a 32-hour course in radiation health 

21 physics. This is 1964, and this is the first 

22 class. And it names all these guys we are 
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1 talking about. It names the guy with the 

2 massive dose that starts with a P. James 

3 Powers is in here. I mean, these guys weren't 

4 trained, not until `64. This is a magazine. 

5 I heard this, I can't even believe it. This 

6 is ludicrous.

7 See what GSI does? They say there 

8 was a building 1,000 feet away and they forget 

9 the one that is 40 feet away. They would do 

10 anything to get a license. I'm more upset 

11 because no one came out and looked. They 

12 wouldn't have put that new betatron where it 

13 was if somebody had come out there and looked. 

14 There is a reason the United States government 

15 and the Army put one out in a field.

16 CHAIRMAN ZIEMER: Okay, we hear 

17 you, John.

18 MR. RAMSPOTT: All right. Thank 

19 you.

20 CHAIRMAN ZIEMER: Any comment, 

21 Bob?

22 DR. ANIGSTEIN: Yes. First of 
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1 all, there was a letter or a report from Dr. 

2 Konneker that he had both instructed and 

3 tested, and there were eight workers who 

4 qualified on the very first AEC license -- or 

5 the second one. The first one didn't identify 

6 who the workers were.

7 And the supervisor was not one of 

8 them. He came later. And he said he tested 

9 them. There was nothing about he gave a 

10 course at St. Louis University -- at 

11 Washington University. I believe that 

12 gentleman in his memory is mistaken. The 

13 courses would have been given at -- he came to 

14 GSI. This is where he was hired as a 

15 consultant, and this is what he did. And he 

16 tested them, and he said there were eight that 

17 qualified.

18 The one going back 15 years they 

19 said in the various AEC applications that they 

20 had informal training; meaning you can take 

21 that whatever, on-the-job training, some 

22 discussions. They did not say they had a 
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1 formal program with testing.

2 Konneker put in the first formal 

3 program with testing. So if that magazine was 

4 '64, perhaps they were referring to something 

5 that happened slightly earlier. I'm sure I 

6 can pick out the dates. I haven't got them in 

7 front of me at my fingertips right now. I 

8 don't want to hold up the meeting for that. 

9 But there is nothing there that is 

10 contradictory. They had first informal 

11 training. He went over the records and said 

12 this was not, or he was told that there was 

13 nothing earlier. And then as far as the 

14 interview with Dr. Konneker, he basically said 

15 each and every question I really don't 

16 remember. He had no, I asked him do you have 

17 records, no. He didn't even remember where he 

18 got his film badges. 

19 You get somebody 50 years later, a 

20 gentleman 90 years old sounded very, very 

21 feeble. He could barely get his words out. I 

22 did not think it was -- as a matter of fact, 
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1 Dr. Ziemer instructed me to contact him first 

2 to see if he had anything useful to say and 

3 then maybe we would set up a formal interview 

4 with NIOSH and Dr. McKeel participating. And 

5 there just didn't seem to be any point in 

6 bothering him. Nothing more he could tell us. 

7 He said at the end, I'm sorry I couldn't 

8 really help you.

9 CHAIRMAN ZIEMER: We can't beat 

10 that horse to death. You have the information 

11 that is in the document. You have heard the 

12 discussion. You have heard the points from 

13 the petitioners. You have heard the 

14 discussion here.

15 Let me ask the Work Group Members, 

16 what would you like to do on the Issue 1? 

17 Currently it is open. SC&A's recommendation 

18 is to accept the bounding for the second half 

19 of that period but not the first half I think 

20 is basically what I would interpret your 

21 recommendation to be.

22 DR. ANIGSTEIN: Yes, following '57 
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1 on.

2 MEMBER BEACH: Well from my point 

3 of view, Paul, I don't agree with the 

4 recommendation that the second half, '57 to 

5 '62 is boundable. I think the evidence is too 

6 flimsy from my personal opinion, and I think 

7 that we should recommend that the SEC be 

8 passed for '53 through '62 on that issue for 

9 number 1.

10 CHAIRMAN ZIEMER: Through '62?

11 MEMBER BEACH: Yes. That is my 

12 personal opinion.

13 CHAIRMAN ZIEMER: Okay. And 

14 Wanda, what are your thoughts on that?

15 MEMBER MUNN: I have a tendency to 

16 believe we have adequate information to be 

17 able to bound, although we do not have the 

18 kind of records we would like to have for the 

19 early years. That is frequently the case.

20 We do, however, I believe have 

21 enough information about sources for those 

22 early years to be able to make a logical 
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1 bounding estimate.

2 I would like to hear what NIOSH 

3 feels with response to the SC&A 

4 recommendation. We haven't had an opportunity 

5 to really probe that.

6 MR. ALLEN: As far as my opinion 

7 on this, I actually think Bob laid it out 

8 fairly decent as to what the information is, 

9 and we have put our best estimate forward for 

10 those early years. And I am not going to 

11 pretend that it's iron clad 100 percent 

12 accurate, and I am also not going to pretend 

13 to know what is sufficiently accurate. That 

14 is unfortunately your job, Wanda.

15 MEMBER MUNN: Yes, I recognize 

16 that. But my job relies on the information 

17 that we have in front of us with respect to 

18 source terms. And it seems to me that we have 

19 done a -- does NIOSH not feel comfortable with 

20 the source terms that we have. We are fairly 

21 sure that we have covered those bases well. 

22 Correct?
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1 MR. ALLEN: I believe we have got 

2 the source terms. I also, I still believe in 

3 our estimate as a reasonable estimate. Bob's 

4 opinion seems to be that we have information 

5 about practices, et cetera, back to '57-ish. 

6 My opinion was those practices didn't come out 

7 of thin air in '57. You know, they are based 

8 on what was going on prior to that. They 

9 didn't reinvent the wheel in '57. There is 

10 nothing that happened in '57 that we can find 

11 that really changed anything. So, yes, I am 

12 back extrapolating those practices to '53. 

13 That is where my opinion is.

14 And like I said, I know that is 

15 not bullet-proof. It is not 100 percent. Bob 

16 wanted something more significant.

17 DR. ANIGSTEIN: The only point I 

18 would make about that is the second-hand 

19 account of the missing radium source, which is 

20 there was some question to the validity 

21 because it was always, I heard this from 

22 someone. Everybody who said that gave an 
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1 account that they heard it from someone else. 

2 But the best account was again 

3 from the same person whose badge records we 

4 have who said it happened when he was away in 

5 the Army and when he came back there was a 

6 lock on the door.

7 So, you might look at that as a 

8 watershed moment that they improved their 

9 security and not so much that the radiography 

10 practices were different but that perhaps the 

11 controls were a little more lax. 

12 There is question in my mind 

13 whether that incident actually happened at 

14 GSI. We know it happened here earlier at 

15 Eddystone. Eddystone was the same company and 

16 it is not inconceivable that the word simply 

17 went to the Granite City facility saying you 

18 better watch your radium sources because here 

19 we had a case and the word got around. And 

20 then second, third-hand next generation of 

21 workers heard about it and thought that it 

22 happened there. I'm just saying it is a 
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1 possibility.

2 MEMBER MUNN: Yes, I doubt that we 

3 have the information that can assure us of 

4 that one way or the other, although I do 

5 understand how stories of that type take a 

6 life of their own and spread from one site to 

7 the other, but I would not go so far as to say 

8 that is a probability here.

9 Even though we assume that that 

10 may indeed have occurred, I --

11 DR. ANIGSTEIN: In which case, 

12 there would be a reason for that being an SEC 

13 period because the controls were more lax than 

14 later.

15 CHAIRMAN ZIEMER: In either case, 

16 even if you had no information about either 

17 the lock or the one person whose records you 

18 have or the Konneker letter about the training 

19 and so on, the bounding is not dependent on 

20 any of those.

21 MEMBER MUNN: No, it isn't.

22 CHAIRMAN ZIEMER: My question to 
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1 SC&A and to NIOSH, I know NIOSH's answer, I 

2 guess you were only thinking of that in terms 

3 of whether or not the controls were inherently 

4 tighter and you would feel a little more 

5 comfortable about bounding under conditions 

6 where they were perhaps more controlled.

7 The bounding methodology would be 

8 no different in the first three years in the 

9 next six years if you went with bounding. 

10 Isn't that correct?

11 MR. ALLEN: That's correct.

12 CHAIRMAN ZIEMER: You are not 

13 dependent at all on any of those records that 

14 Bob has got --

15 DR. ANIGSTEIN: Exactly.

16 CHAIRMAN ZIEMER: -- or any of 

17 those letters, anybody's training program, any 

18 locks or lack thereof. Your bounding 

19 methodology is the assumptions about -- well 

20 assumptions, the idea that the radium when it 

21 was used outside the room was roped off. That 

22 is sort of inherent in the control issue.
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1 MEMBER BEACH: That's an 

2 assumption also.

3 CHAIRMAN ZIEMER: Yes, it is. It 

4 is.

5 MEMBER BEACH: So what I heard 

6 though was the back-extrapolation that you 

7 would take data from '62 and back-extrapolate 

8 to the 1953 time period or that 11-year 

9 period.

10 MR. ALLEN: No, it is the portable 

11 sources, I'm trying to recall, I don't think 

12 it was really -- not sure I'm going to be able 

13 to remember this --

14 MEMBER BEACH: I just wanted to 

15 make sure I heard what I thought I did.

16 MR. ALLEN: It wasn't based on --

17 The data that we used was the scenarios the 

18 workers gave us as far as practices, et 

19 cetera, roping it off, that people walked 

20 through the barriers.

21 MEMBER BEACH: Right.

22 MR. ALLEN: The number data, the 
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1 values that we used that came after that was I 

2 think the only one we really used was the NRC 

3 document thing and it was 500-millicurie 

4 sources, which I don't think anybody has 

5 actually disagreed with that or anything.

6 And Bob you can correct me if my 

7 memory is wrong but from that and the fishing 

8 pole techniques, etcetera, it was all the 

9 worker information that we got on their 

10 practices and what we based our exposure 

11 estimate on.

12 Like I said, I don't know of 

13 anything that really changed in '57. We 

14 didn't use really film badge data or anything, 

15 if that is what you were saying from pre-'62 

16 or anything. We just used the practices and 

17 the source terms.

18 MEMBER BEACH: I just heard back19 extrapolate. So I wanted to make sure I 

20 understood what you were saying earlier.

21 MR. ALLEN: I think what I meant 

22 was back extrapolate the work practices.
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1 MEMBER BEACH: Well that's fine. 

2 I got that.

3 CHAIRMAN ZIEMER: John?

4 DR. MAURO: There is one thing I

5 did want to say. I like the place that SC&A 

6 is in and NIOSH is in. I think that we have 

7 exhausted the fact-finding. What I mean by 

8 that is to try to bring to the table the 

9 history of this, including Dr. McKeel and all 

10 of the GSI folks what we did is collect facts 

11 and do calculations, explore the probe and try 

12 to place into a big basket everything we know. 

13 And I think you have it.

14 I don't think there is much more 

15 that your contractor or that NIOSH can tell 

16 you in order to collect more information that

17 will help you make your judgments. 

18 Unfortunately, I think that, and I agree with 

19 everything I am hearing around the table, 

20 certainly there is some softness before 1962. 

21 And the way we see it, it is really soft in 

22 my opinion from '53 to '57 or '56; not so soft 
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1 from '57 to '62 and things get pretty good at 

2 '62.

3 And I mentioned this at one of our 

4 earlier meetings and I still feel that way. 

5 The difficult part is what you have in front 

6 you right now. This is the facts. This is 

7 what we have got. Now it becomes a judgment 

8 and it is almost a personal judgment. I don't 

9 know if there is anything more that we can do 

10 to gather any more information, do any more 

11 calculations, do any more surveys. Maybe but 

12 I have got to say I don't see it.

13 Now it is really a tough call. 

14 And in my opinion, Bob and I struggled with 

15 this, you know, can you go all the way back to 

16 '53 given the information? I walk away saying 

17 no. And the reason I say no was ‘ 

18 identifying information redacted’'s testimony 

19 about his concern about lack of controls, the 

20 lost source that might or might not have 

21 occurred. And that is why I had this elbow in 

22 1956 and '57 because things seemed to be soft, 
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1 very soft at that time.

2 But I can see someone saying, 

3 Wanda, yes, no we can go back, you know, for 

4 the reasons we all talked about. And I could 

5 also see someone saying from '57 to '62 that 

6 is not good enough for me.

7 So I could see. I'm trying to 

8 look at it through your eyes but I don't think 

9 there is very much more we can do. Sort of 

10 the card is now, as far as I am concerned, in 

11 your hands. There might be a couple of things 

12 you may want us to follow up on but I think we 

13 are almost there in terms of fact-finding.

14 MEMBER MUNN: To answer your 

15 question specifically, given the information 

16 that we have, given the understanding we have 

17 of the sources, and we are fairly certain of 

18 those, and given the understanding of the 

19 practices that were intact in '57 and 

20 afterwards, the bounding process is a 

21 perfectly legitimate one and certainly spreads 

22 enough umbrella to be sufficiently accurate, 
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1 in my view.

2 CHAIRMAN ZIEMER: For '53 to '62?

3 MEMBER MUNN: Yes.

4 CHAIRMAN ZIEMER: Because right 

5 now we are talking about --

6 MEMBER BEACH: Well SC&A has said 

7 they don't think '53 to '56 is doable --

8 CHAIRMAN ZIEMER: Right.

9 MEMBER BEACH: -- but '57 to '62 

10 is.

11 DR. ANIGSTEIN: Can we make a 

12 change? Can we amend?

13 DR. MAURO: Well we can do 

14 whatever you want.

15 DR. ANIGSTEIN: I would say that 

16 it is a little less firm, there is less 

17 evidence but I agree with Dave Allen that 

18 there is no reason to believe there was a 

19 change of practices. And it is basically this 

20 is something we wouldn't argue, neither John 

21 or I would argue very hard with the Board. I 

22 mean, it is not our place to argue but even 
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1 so, it is not impossible. It is not 

2 necessarily inappropriate to assign doses from 

3 the '53 to '56 time period, I agree, based on 

4 the same information. The information is a 

5 little more firm in the later period but there 

6 is no reason to really believe that it should 

7 have been different in the earlier period.

8 And even if say one person one 

9 time did take that radium source, I don't 

10 think that over a couple of days he would have 

11 gotten in excess of say 12 rem. And that 

12 would have been his only exposure because he 

13 certainly was not a radiographer, regularly 

14 exposed. So that was a single incident.

15 CHAIRMAN ZIEMER: Well actually if 

16 you have an incident where a worker with a 

17 claim says I took that source --

18 DR. MAURO: We could deal with it. 

19 (Simultaneous speaking.)

20 MR. ALLEN: We actually did it at 

21 GSI but I was trying to leave it open for --

22 CHAIRMAN ZIEMER: The bounding is 
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1 not necessarily intended to cover incidents 

2 that either are known or can be identified by 

3 a worker.

4 DR. MAURO: Yes, I understand what 

5 you are saying but I saw that as a breakdown 

6 in controls.

7 CHAIRMAN ZIEMER: It is. And the 

8 wandering through the workspace is also. And 

9 the question was if that is sort of a regular 

10 practice and not just a one-time thing and 

11 some worker says you know I remember once 

12 walking through that, and so add that to my 

13 dose. But in a sense, we are adding it to 

14 everybody's dose. We are assuming all the 

15 workers wander through the radium sources.

16 MR. ALLEN: It is assumed that the 

17 boundaries aren't respected.

18 CHAIRMAN ZIEMER: This bounding 

19 that is being proposed is based on loose work 

20 practices.

21 DR. MAURO: Yes, that's true.

22 CHAIRMAN ZIEMER: And that is one 
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1 of the reasons that I personally am supportive 

2 of the bounding. I think the full Board has 

3 to weigh in on this.

4 You know, I am like you, John. I 

5 think reasonable people can disagree on this 

6 because we are working in an area where there 

7 is not a whole lot of confirmatory data. But 

8 unlike some other facilities, we do have good 

9 source term data. We know that there are the 

10 radium sources and we know there was the 

11 betatron. And by the way, if there was an 

12 iridium source actually being used, that would 

13 be easy to bound that in because it is going 

14 to behave. I mean, you would assume the same 

15 loose work practices and you would, my guess 

16 is if you did that, you wouldn't -- if you are 

17 working with the radium, you are not working 

18 with it, and vice-versa. So I am not even 

19 sure. It would be an interesting thing to 

20 look at. But in any event, I think you could 

21 bound it also that way.

22 Now we don't necessarily have to 
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1 close this right now but we sort of have to 

2 know where we are on each of these.

3 I mean, I think -- I'm not sure 

4 what closing means on the matrix. Does it 

5 mean we all agree?

6 MR. ALLEN: Well I kind of 

7 mentioned that the last time a couple weeks 

8 ago. I think there are some where we have 

9 reached, as John is saying, all the 

10 information we have got and all the analysis 

11 we are going to be able to do are out there. 

12 And reasonable people can disagree. Whether 

13 you call that closed or not, I think the fact14 finding might be closed.

15 CHAIRMAN ZIEMER: Well it sounds 

16 like SC&A is cautiously agreeing that you can 

17 bound or are you?

18 MR. ALLEN: Reasonable people 

19 disagree.

20 DR. ANIGSTEIN: I think the 

21 wording here is not simply to put '53 to '62. 

22 It does not -- we would not disagree with the 
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1 bounding approach even for that period.

2 CHAIRMAN ZIEMER: Well okay, let 

3 me ask the Board Members. Do you wish to 

4 close this item or pursue it any further? I 

5 mean we can close it and not necessarily agree 

6 on the final recommendation on this.

7 MEMBER MUNN: I don't know what 

8 else one could do.

9 MEMBER BEACH: Well if there is no 

10 other work to be done, I don't think we need 

11 to leave it open.

12 DR. ANIGSTEIN: Right.

13 CHAIRMAN ZIEMER: Then we'll agree 

14 to close it.

15 The next one, item two, incomplete 

16 monitoring of workers. Of course some of 

17 these are very related one to the other. I 

18 mean, we have discussed the fact that we have 

19 some film badge data that is useful for 

20 certain things but we are largely relying on 

21 the modeling for bounding. So the title line 

22 here SC&A says we believe that using 
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1 reasonable bounding claimant-favorable 

2 assumptions and the latest calculational 

3 tools, that it is possible to reconstruct 

4 doses over the period January '64 to '66. And 

5 this needs to be addressed by NIOSH in 

6 revision of Appendix BB.

7 Again, let me ask the Work Group 

8 Members what you believe.

9 MEMBER BEACH: I personally 

10 believe these should stay open until we see 

11 that that has been done. That is my personal 

12 thought.

13 MR. ALLEN: Can I make a silly 

14 suggestion on that?

15 CHAIRMAN ZIEMER: Yes.

16 MR. ALLEN: Would it be 

17 appropriate to transfer that to the Appendix 

18 Matrix or is that --

19 MEMBER BEACH: Oh, to the other --

20 MR. ALLEN: Yes.

21 DR. NETON: Dave makes a good 

22 point that if it is not considered an SEC 
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1 issue, it becomes a Site Profile issue and 

2 then this is a matrix for the SEC evaluation. 

3 And the Working Group feels that the issue 

4 has been addressed as far as SEC is concerned.

5 DR. ANIGSTEIN: Yes, that was 

6 already done with issue 10.

7 CHAIRMAN ZIEMER: Right.

8 DR. ANIGSTEIN: Which will be 

9 transferred. It wasn't resolved. It was 

10 addressed.

11 MEMBER MUNN: Recommend it be 

12 transferred.

13 MEMBER BEACH: That's fine.

14 CHAIRMAN ZIEMER: Okay, we will 

15 agree we are going to transfer this to 

16 Appendix BB.

17 Now in essence, that takes it off 

18 the SEC table at the moment. Now that doesn't 

19 mean that later it couldn't -- that doesn't 

20 preclude an SEC in the later years, depending 

21 on how this comes out. But for the time being 

22 it removes that later year.
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1 Lack of documentation, high2 importance one. It was of high importance.

3 MEMBER MUNN: Another transfer 

4 issue.

5 CHAIRMAN ZIEMER: This is similar. 

6 This has to do with the bounding in the post7 radium era. SC&A agrees with NIOSH that 

8 bounding can be done and recommend moving this 

9 to Appendix BB and closing.

10 MEMBER MUNN: Agree.

11 MEMBER BEACH: I agree.

12 CHAIRMAN ZIEMER: Okay. Close 

13 this or move this to Appendix BB.

14 Issue 4 is the film badge 

15 dosimetry dependence on photon energies and 

16 exposure geometry. This had to do in part 

17 with the AP exposure press back and so on. 

18 There was a commitment from NIOSH that they 

19 would revise their assumptions and repeat the 

20 analysis but I think we had come to an 

21 agreement on this. Did we not?

22 DR. MAURO: You said this might be 
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1 in abeyance until I'm done?

2 DR. ANIGSTEIN: We have the 

3 recommendation, my recommendation was that it 

4 be closed.

5 DR. MAURO: That it be closed. 

6 Oh, okay.

7 DR. ANIGSTEIN: Right.

8 DR. MAURO: All right. I told you 

9 we are delayed until the Site Profile is 

10 revised. I was thinking in Procedures 

11 Subcommittee space. 

12 DR. ANIGSTEIN: No, the conclusion 

13 sentence is, "Whichever set of assumptions is 

14 used, it is clear that the betatron operator 

15 would not receive the bounding exposure and, 

16 therefore, it can be closed."

17 DR. MAURO: Oh, okay. Sorry.

18 DR. ANIGSTEIN: The layout workers 

19 --

20 CHAIRMAN ZIEMER: The layout 

21 workers would have the higher values.

22 DR. MAURO: It preempts this. I'm 
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1 sorry.

2 CHAIRMAN ZIEMER: Close?

3 MEMBER MUNN: Close.

4 MEMBER BEACH: Close. 

5 CHAIRMAN ZIEMER: Close.

6 Issue 5, lack of validation of 

7 models of radiation exposure of betatron 

8 operators. This had to do with the use of 

9 MCNPX and some of the things we went through 

10 there. And then the modeling and use of the 

11 normalization with the film badges, versus 

12 just the modeling in part. 

13 Bob says the discrepancy has now 

14 been resolved but numerically we are not 

15 seeing that quite yet because there is a 

16 couple things still out there. One of them --

17 well, I guess we are going to get some 

18 confirmation on the steel door issue. But the 

19 other one --

20 DR. MAURO: The control badge --

21 are you still --

22 MR. ALLEN: Well I might be wrong. 
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1 I was taking this one to be the kind of 

2 calibration for the validation they did in the 

3 beginning of that White Paper. That is based 

4 on the 1971 survey and the 80-curie cobalt 

5 source.

6 CHAIRMAN ZIEMER: Right.

7 MR. ALLEN: The lead shielding, et 

8 cetera, the best we can tell were in place at 

9 that point. So I think what you are talking 

10 about is the shot scenarios put together for 

11 the betatron itself, which come under the 

12 other ones that we already discussed, I think.

13 CHAIRMAN ZIEMER: Oh, yes. Okay, 

14 yes. This was just the calibration. I think 

15 we have agreement on this one. Don't we?

16 DR. ANIGSTEIN: I'm sorry, on 

17 which?

18 CHAIRMAN ZIEMER: This is number 

19 five.

20 DR. ANIGSTEIN: Yes, we think that 

21 we resolved -- there was a big discrepancy 

22 between the film badges and the model. And we 
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1 resolved it. We understand now why that was 

2 the case. So we don't think there is any more 

3 issue.

4 DR. MAURO: Well help me out a 

5 little bit. There are a couple of matters 

6 here and I might just be disoriented.

7 CHAIRMAN ZIEMER: This doesn't 

8 have to do with the actual assigning of doses 

9 to people. This has to do with, I think, with 

10 the use of the 80-curie source, calibration.

11 DR. ANIGSTEIN: No.

12 CHAIRMAN ZIEMER: No?

13 DR. ANIGSTEIN: I mean, let me 

14 give you a quick overview of this. Remember 

15 this goes back to 2008 in time for starters. 

16 October 2009 the matrix was done. So we have 

17 come a long way since then with our 

18 understanding.

19 At that time, there seemed to be 

20 discrepancies. Now we understand reasons for 

21 the discrepancy. We don't expect that the 

22 limit that the film badges would actually 
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1 represent the limiting doses that we calculate 

2 in the model because the model predicts the 

3 worst doses in the worst locations in the 

4 worst time. So the fact that there was a 

5 difference we now have a degree of comfort and 

6 we understand why there is a difference and 

7 why the model has already been modified.

8 One of the issues is that the main 

9 source of exposure actually was that residual 

10 radiation from the betatron and we have now 

11 pretty much have a better understanding of 

12 what it is, what it isn't. And so we just 

13 don't think there's an issue.

14 CHAIRMAN ZIEMER: Okay, close? 

15 Close.

16 Issue 6, underestimate of external 

17 exposure of unmonitored workers.

18 MEMBER MUNN: Transfer to BB.

19 CHAIRMAN ZIEMER: Well, this is 

20 the actual bounding part. Right?

21 DR. ANIGSTEIN: Yes.

22 CHAIRMAN ZIEMER: And it is the 
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1 issue bounding in later years. And both SC&A 

2 and NIOSH are agreeing that they can bound in 

3 later years. We do still have some 

4 differences. And so I think we want to see 

5 what those look like.

6 I mean, we can transfer this to --

7 MR. ALLEN: Well that is why I 

8 suggested transferring because then it 

9 wouldn't be closed but it would be in the TBD.

10 CHAIRMAN ZIEMER: They would still 

11 have to show that they -- and if you didn't, 

12 this would reopen it for an SEC in the later 

13 years.

14 DR. ANIGSTEIN: Yes.

15 DR. McKEEL: Dr. Ziemer, this is 

16 Dan McKeel.

17 CHAIRMAN ZIEMER: Yes?

18 DR. McKEEL: I didn't hear you on 

19 Issue 5. Did you close that or what was the 

20 disposition?

21 CHAIRMAN ZIEMER: Issue 5, we 

22 closed that.
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1 DR. McKEEL: Okay, thank you.

2 CHAIRMAN ZIEMER: Issue 6 would 

3 transfer, we all agreed to transfer to 

4 Appendix BB.

5 MEMBER MUNN: But Bob has 

6 something to say.

7 CHAIRMAN ZIEMER: Yes, Bob?

8 DR. ANIGSTEIN: We have a burning 

9 question.

10 CHAIRMAN ZIEMER: Yes. 

11 DR. ANIGSTEIN: It is 2:45. Do 

12 you think we are going to adjourn at 3:00?

13 CHAIRMAN ZIEMER: Yes.

14 DR. ANIGSTEIN: Okay.

15 CHAIRMAN ZIEMER: Issue 7, dose 

16 reconstruction is not based on best available 

17 science.

18 MEMBER BEACH: In progress.

19 MEMBER MUNN: Or Appendix BB.

20 CHAIRMAN ZIEMER: Let's see. Well 

21 this was one where there was an actual error 

22 in a table or something. You were using the 
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1 wrong value for uranium surface dose rates or 

2 something. So it was scientifically an error. 

3 And they have agreed to correct it and the 

4 correction will be in the new -- it is 

5 strictly an error, an actual error.

6 MR. ALLEN: Math error.

7 CHAIRMAN ZIEMER: Isn't that 

8 right?

9 DR. NETON: Well, it all had to do 

10 with a new MCNPX.

11 CHAIRMAN ZIEMER: But now it has 

12 gone beyond that?

13 DR. NETON: Kind of morphed into 

14 this -- which version of MCNP to use.

15 CHAIRMAN ZIEMER: Okay, but 

16 originally it was just an error that you were 

17 going to correct.

18 DR. ANIGSTEIN: Now we found new 

19 --

20 DR. NETON: But it is still the 

21 similar issue which is using the best 

22 available model in time.
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1 DR. ANIGSTEIN: I noticed that 

2 Dave's latest calculation was using version 

3 27E.

4 MEMBER BEACH: Which had some 

5 errors, too, didn't it?

6 DR. ANIGSTEIN: Not really. The 

7 latest one is 27. Oh, this is.

8 No, there is no problem.

9 CHAIRMAN ZIEMER: Okay, we are 

10 going to transfer this one, also now, I 

11 believe, to Appendix BB.

12 MEMBER MUNN: I guess I should 

13 raise a process question here. We notice we 

14 have indicated that it is in progress, which 

15 is what we have done in the past when we 

16 transfer things from one to the other. In 

17 other venues, that is what we have done in the 

18 past. What are we doing to do here?

19 CHAIRMAN ZIEMER: It is in 

20 progress.

21 DR. NETON: It will be closed in 

22 the SEC matrix. So it would transfer as in 
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1 progress in BB.

2 CHAIRMAN ZIEMER: Right.

3 MEMBER MUNN: That is what we have 

4 done in previous cases.

5 DR. NETON: That makes sense.

6 MEMBER MUNN: So we keep it alive 

7 until it is done completely.

8 CHAIRMAN ZIEMER: Issue 8 had to 

9 do with the model again, incomplete model use 

10 for exposure assessment. A lot of these are 

11 interrelated, I guess.

12 The latest one getting down to the 

13 assumptions and how that affected neutron 

14 dose. And I think both of you again have 

15 agreed that you can model this and you are 

16 kind of fine-tuning that model. Right?

17 MR. ALLEN: Yes.

18 CHAIRMAN ZIEMER: So this one 

19 should also transfer.

20 MEMBER MUNN: Transfer to the 

21 Appendix.

22 CHAIRMAN ZIEMER: I believe the 
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1 underestimate of the beta dose is going to be 

2 the same.

3 MEMBER MUNN: Yes.

4 CHAIRMAN ZIEMER: Transfer.

5 MEMBER BEACH: On this one you 

6 questioned the use of 26E but you just said

7 they used version 27E.

8 DR. ANIGSTEIN: No, only for the 

9 latest. Not for the betas.

10 MEMBER BEACH: Okay. With the 

11 others, okay.

12 DR. ANIGSTEIN: We haven't 

13 mentioned the beta. It is just a matter of 

14 rerunning it.

15 CHAIRMAN ZIEMER: And number 10 we 

16 have already done.

17 DR. ANIGSTEIN: Right.

18 CHAIRMAN ZIEMER: Now, I want to 

19 go back and on Issue 1, I think we are at a 

20 point where we can probably go forward to the 

21 Board on the early years. The Work Group, I 

22 mean, we have a 2-1 split but that's alright. 
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1 What we would do would be to tell the Board 

2 that -- all of this other modeling is later 

3 year stuff. The rest of these items that we 

4 transferred. But the early year section is 

5 what it is. I don't think -- we have agreed 

6 there is nothing more we can really do on that 

7 and we can present that to the Board.

8 And I will work on a summary and I 

9 will ask the Board -- you all know I try not 

10 to bias these things. I try to be fair to 

11 these minority reports.

12 MEMBER BEACH: I will get my say 

13 is what you are saying.

14 CHAIRMAN ZIEMER: My report is a 

15 minority report. The other two are women, 

16 see.

17 (Laughter.)

18 CHAIRMAN ZIEMER: In any event, I 

19 will try to summarize where we are on this at 

20 the full Board meeting. And then we will --

21 MR. KATZ: And then you will make 

22 a recommendation.
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1 CHAIRMAN ZIEMER: -- make a 

2 recommendation.

3 Dan, are you still there?

4 DR. McKEEL: Yes, sir.

5 CHAIRMAN ZIEMER: I will want you 

6 to be prepared also to make a case for the 

7 early years, focus on that for the SEC. 

8 Okay?

9 DR. McKEEL: Of course.

10 CHAIRMAN ZIEMER: I'm not trying 

11 to talk you into it, Dan. We are going to I 

12 think focus on the early years. They have a 

13 process question.

14 DR. NETON: Yes, I just saw the 

15 Working Group transfer all of the SEC issues 

16 over to the Appendix BB Site Profile Issues. 

17 CHAIRMAN ZIEMER: All except one.

18 DR. NETON: So I am a little bit 

19 confused, except for number one. 

20 And since they have been 

21 transferred, I am wondering why -- does the 

22 SEC Work Group continue to remain open to 
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1 study them? Then I question why you 

2 transferred them over the Appendix BB Work 

3 Group because --

4 DR. ANIGSTEIN: It is the same 

5 Work Group.

6 DR. NETON: Well there is a 

7 fundamental difference here, though. If it is 

8 a Work Group that is reviewing Site Profile 

9 issues, that sort of implies that the 

10 determination has been made that these are not 

11 SEC issues.

12 MEMBER BEACH: That is still in 

13 question also.

14 DR. NETON: Well I don't know why 

15 it is. I mean, if we all agree that they are 

16 Site Profile issues and they are tractable 

17 problems, to use SC&A's language, why would we 

18 leave these open? Otherwise you are going to 

19 go to the Board and say we made a 

20 recommendation for this first early period or 

21 we are going to make a recommendation and then 

22 these just stay open forever. We will just 
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1 have to go back and rehash them as SEC issues 

2 all over again.

3 At some point, the SEC Work Group 

4 has to come to determination whether these are 

5 tractable issues and are not SEC issues. To 

6 leave them open indefinitely, it is going to 

7 be very painful.

8 You can do what you want I suppose 

9 but in other Work Group situations, it is 

10 normally you sort of triage them. Are these 

11 SEC issues or Site Profile issues and then you 

12 decide to make a recommendation on the SEC 

13 unless you feel it is expeditious just now to 

14 move this first one forward and continue to 

15 study these, in which case I think they need 

16 to come back from the Work Group and stay on 

17 the SEC Matrix as open.

18 CHAIRMAN ZIEMER: Well we could do 

19 that with them. I think that the transferring 

20 that we did was based on an agreement that 

21 they were tractable.

22 DR. NETON: Right, which implies 
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1 that they are Site Profile issues.

2 CHAIRMAN ZIEMER: Right.

3 DR. MAURO: In our position, 

4 SC&A's position, all betatron issues are 

5 tractable and it is just a matter of bringing 

6 out details. Everything else with regard to 

7 the radium, iridium, cobalt, we feel that the 

8 only place where there is some subjective 

9 judgment is that there is only '53 to '62, a 

10 big time period.

11 SC&A's position is we believe that 

12 they could be bounded and are tractable from 

13 '57 or '56-'57 to '62. We feel that they may 

14 not be tractable for various reasons. And 

15 this is all we can give you from '53 to '57.

16 So the way we see it is the only 

17 real SEC issues are can you reconstruct the 

18 doses with sufficient accuracy from '53 to 

19 '57. That is SC&A's position.

20 Now, but that may not very well be 

21 our position.

22 MEMBER BEACH: Well that may not 
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1 be the thought of the Board either.

2 DR. MAURO: That is not your 

3 position. Exactly. Right.

4 MEMBER BEACH: But unless you 

5 bring it to the Board and explain that -- we 

6 can fill it all in. And I'm not so sure I 

7 totally agree with that either.

8 MR. ALLEN: I guess my question 

9 was you keep talking the early years. Are you 

10 not going to make a recommendation on the 

11 later years, then for this Board meeting?

12 MEMBER BEACH: At some point you 

13 have to make a recommendation. The Board has 

14 to --

15 DR. NETON: But we have 

16 transferred them all to Site Profile issues. 

17 That is why I am confused.

18 MR. ALLEN: That's what I thought 

19 your question was.

20 DR. MAURO: And you are right.

21 MR. ALLEN: It seemed like there 

22 was almost some agreement.
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1 CHAIRMAN ZIEMER: Well haven't we 

2 done that on other SECs where we have left 

3 open the study?

4 MR. KATZ: Well if you make the 

5 judgment that they are tractable and they are 

6 TBD issues, you have made the judgment with 

7 respect to the petition as to where they stand 

8 and you can make that recommendation to the 

9 full Board.

10 CHAIRMAN ZIEMER: For the whole 

11 thing.

12 MR. KATZ: Yes, for the whole 

13 thing. That doesn't mean that you don't 

14 follow up on the TBD issues as a Work Group. 

15 And the Board of course will do what it will 

16 do going forward on all of this. But you 

17 might as well, if you have made the decision, 

18 you all did just go through this process of 

19 saying this is a tractable TBD issue. This is 

20 a tractable TBD.

21 But in effect you made a decision 

22 as a Work Group, you might as well recommend 
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1 on the whole kit and caboodle to the Board and 

2 then of course the Work Group can follow 

3 through with TBD and the Board of course can 

4 say go dig more on this or that if they want 

5 to. But you might as well put the full plate 

6 in front of them.

7 MEMBER BEACH: I agree with that.

8 DR. McKEEL: Dr. Ziemer, may I 

9 make a final comment?

10 CHAIRMAN ZIEMER: Yes, you sure 

11 can.

12 DR. McKEEL: Okay, well the final 

13 comment of the co-petitioner is that I could 

14 not be more disappointed by this decision nor 

15 could I disagree more with the shunting of 

16 many of these issues over as Appendix BB 

17 issues, which I do not believe they are 

18 exclusively.

19 The second thing I have got a 

20 comment on that I am extremely disappointed 

21 about is during the four-year course of the 

22 deliberations of this Work Group we have lost 
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1 two members. Mark Griffon, as I understand 

2 it, resigned on his own volition. And Dr. 

3 Poston has missed the last four meetings and 

4 isn't even mentioned during roll call as 

5 trying to attend the meetings.

6 So essentially what I feel is that 

7 I have spent a large major fraction of my life 

8 providing information and interacting with 

9 this Work Group and trying to be an honest 

10 broker between the Work Group and the workers 

11 and site experts. And I really feel that the 

12 two members who voted against an early SEC 

13 have let us down. 

14 I also want to say that I think it 

15 needs to be said for the record that SC&A was 

16 not definite about their recommendations. 

17 They made a sort of piece of advice to the 

18 Work Group that well, the 1953 to '57 data was 

19 soft. And you know, but they would not 

20 disagree with bounding the doses for that 

21 period. Well that is essentially just 

22 avoiding a recommendation altogether and I 
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1 don't think that is their job.

2 I also want to say that despite 

3 all of the protests to the contrary, I believe 

4 that when this complete record is looked over, 

5 and I certainly hope it will be, that many 

6 people will find that SC&A did much of the 

7 work that NIOSH was supposed to be responsible 

8 for and that NIOSH was allowed an inordinate 

9 amount of time to rework their models over, 

10 and over, and over and in particular this last 

11 period of time of 18 months with the Path 

12 Forward.

13 And now essentially all of the SEC 

14 issues magically have now been declared 

15 Appendix BB issues. So not only will I 

16 address the Board about the way I feel about 

17 it, but I am going to be vigorous in my 

18 defense. This was a very bad decision on the 

19 part of the Work Group. I respect your right. 

20 That is your right to do exactly as you see 

21 but I think it is a cloudy decision. And 

22 frankly, I welcome taking it to the full Board 
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1 and making my case to them.

2 CHAIRMAN ZIEMER: And that's fine, 

3 Dan. And I certainly will expect you to make 

4 a vigorous defense and I will do the same for 

5 the Work Group. And that's fine. We will 

6 each try to make our case.

7 But we will let the larger Board 

8 look at the issues and then hopefully they 

9 will come to a conclusion or they may ask us 

10 to do additional work. We will throw it in 

11 their lap at that point.

12 But thank you again for your input 

13 and John and Mr. Dutko and others. We are 

14 going to adjourn at this time and then plan to 

15 see you at the full Board meeting. Thank you.

16 (Whereupon, the above-entitled 

17 matter went off the record at 3:00 p.m.)

18

19

20

21

22
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4