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UNITED STATES OF AMERICA 

 DEPARTMENT OF HEALTH AND HUMAN SERVICES 

 CENTERS FOR DISEASE CONTROL AND PREVENTION 

+ + + + + 

 NATIONAL INSTITUTE FOR OCCUPATIONAL 

SAFETY AND HEALTH 

 ADVISORY BOARD ON RADIATION AND 

 WORKER HEALTH 

+ + + + + 

WORK GROUP ON MOUND 

+ + + + + 

 MEETING 

+ + + + + 

WEDNESDAY, MAY 27, 2009 

+ + + + + 

 The Work Group convened at 

9:30 a.m., in the Zurich Room of the 

Cincinnati Airport Marriott Hotel, Josie M. 

Beach, Work Group Chair, presiding. 

MEMBERS PRESENT: 

JOSIE M. BEACH, Chair 

BRADLEY P. CLAWSON 

PHILLIP M. SCHOFIELD 

PAUL L. ZIEMER * 

MEMBERS ABSENT: 

ROBERT W. PRESLEY 
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ALSO PRESENT: 

NANCY ADAMS, NIOSH Contractor 

TERRY BARRIE*, ANWAG 

BOB BISTLINE, SC&A 

ELIZABETH BRACKETT*, ORAU Team 

RON BUCHANAN, SC&A 

MELTON CHEW, ORAU Team 

LARRY ELLIOTT, NIOSH 

JOE FITZGERALD, SC&A 

EMILY HOWELL, HHS 

KARIN JESSEN, ORAU Team 

MATT KAPLAN*, Senator Brown's Office 

THEODORE M. KATZ, Designated Federal Official 

TOM LaBONE*, ORAU Team 

GREG LEWIS, DOE 

JOYCE LIPSZTEIN*, SC&A 

JOHN MAURO*, SC&A 

JAMES NETON, NIOSH 

GENE POTTER, ORAU Team 

KATHY ROBERTSON-DeMERS, SC&A 

MUTTY SHARFI, ORAU Team 

DON STEWART, ORAU Team 

BRANT ULSH, NIOSH 

*present via teleconference 
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TABLE OF CONTENTS 

Welcome.............................. 4 

Adequacy of Internal Dose Records 

Issue No. 11 

 SC&A........................... 11 

Integrity/Completeness of Internal 

Dose Records Issue Nos. 12 and 13 

 SC&A........................... 92 

Adequacy and Completeness of 

External Dose Records Issue 

Nos. 18 and 19 

 SC&A........................... 172 

Stable Tritium Compounds Issue No. 6 

 SC&A........................... 192 

Price-Anderson Related Bioassay 

Issue No. 21 

 SC&A........................... 275 

Shallow Dose Issue No. 16 

 SC&A........................... 288 

Environmental Issue No. 20 

 SC&A........................... 297 

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

 9:33 a.m. 

 MR. KATZ: Well, good morning 

everyone in the room and on the line. This is 

Ted Katz. I am the Acting Designated Federal 

Official for the Advisory Board on Radiation 

Worker Health. And this is the Mound Working 

Group and we are convening. 

 And the first order of business is 

to run roll call. And we will start with 

Board Members in the room. And please, 

everybody, with roll call also indicate 

whether you have a conflict or not. And let 

me just note that one member, Bob Presley, is 

not going to be in attendance for most of this 

meeting, although he said he would try to call 

in. And Dr. Ziemer who is the alternate for 

this Working Group, I believe, is coming but 

he is on the road. He may be on by line. So, 

let's begin in the room with the Board 

Members. 

 CHAIR BEACH: Okay, I am Josie 
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Beach. I am the Working Group Chair and I 

have no conflicts. 

 MEMBER CLAWSON: Brad Clawson, 

Advisory Board Member. No conflict. 

 MEMBER SCHOFIELD: Philip 

Schofield, Advisory Board Member. No 

conflict. 

 MR. KATZ: And on the line, Paul, 

are you with us by phone? 

 (No audible response.) 

 Okay, so let's carry on with roll 

call in the room, NIOSH ORAU team. 

 DR. NETON: Jim Neton, OCAS. No 

conflict with Mound. 

 DR. ULSH: This is Brant Ulsh with 

OCAS and I have no conflict with Mound. 

 MR. SHARFI: Mutty Sharfi, ORAU 

team, unconflicted. 

 MR. STEWART: Don Stewart, ORAU 

team. I am not conflicted with Mound. 

 MR. CHEW: Mel Chew, ORAU team, I 

am not conflicted. 
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 MR. KATZ: And on the line, NIOSH 

ORAU team? 

 MS. BRACKETT: This is Elizabeth 

Brackett with the ORAU team and I do have a 

conflict with Mound. 

 MR. KATZ: That is Elizabeth 

Bracket. She says she has a conflict. 

 Anyone else NIOSH ORAU team? 

 MR. LaBONE: This is Tom LaBone and 

I have a conflict with Mound. 

 MR. KATZ: Tom LaBone, also 

conflicted. 

 Okay, in the room then, SC&A. 

 MR. FITZGERALD: Joe Fitzgerald. I 

don't have a conflict. 

 DR. BISTLINE: Bob Bistline. I 

don't have a conflict. 

 MR. BUCHANAN: Ron Buchanan. I do 

not have a conflict. 

 MS. ROBERTSON-DeMERS: Kathy 

Robertson-DeMers, conflicted. 

 MR. KATZ: Okay, then on the line 
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for SC&A? 

 DR. MAURO: John Mauro, SC&A. No 

conflict. 

 MR. KATZ: Welcome, John. 

 DR. LIPSZTEIN: Joyce Lipsztein, 

SC&A. No conflict. 

 MR. KATZ: Okay, then in the room -

- well, we don't -- oh. Federal officials or 

contract staff in the room. 

 MS. HOWELL: Emily Howell, HHS. No 

conflict. 

 MR. KATZ: And on the line, any 

federal officials, federal contract staff. 

 MS. ADAMS: Nancy Adams, NIOSH 

contractor. No conflict. 

 MR. KATZ: That's Nancy Adams. 

 Okay, and then members of the 

public in the room. 

 (No response.) 

 MR. KATZ: Okay and on the line, 

any members of the public who want to selfidentify or any staff for congressional 
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offices? 

 MS. BARRIE: This is Terrie Barrie 

with ANWAG. 

 MR. KATZ: Welcome, Terrie. 

 MS. BARRIE: Good morning. 

 MEMBER ZIEMER: Ted, it is Paul 

Ziemer. I'm on the line now. 

 MR. KATZ: Oh, glad to have you. 

Welcome, Paul. 

 MR. KAPLAN: This is Matt Kaplan 

from Senator Brown's office, listening in on 

the call. 

 MR. KATZ: Welcome, Matt. Senator 

Brown's office. 

 And, Paul, you didn't note a 

conflict. 

 MEMBER ZIEMER: No conflict. 

 MR. KATZ: Thank you. Okay, I 

think that does it for roll call. Then just 

let me just remind everyone who is on the 

line, if you are on the line, to please when 

you are not speaking, mute your phone. And if 
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you don't have a mute button, use *6. And 

please disconnect; don't use your hold button. 

 Just disconnect. And we just got someone's 

something. A TV show. 

 Someone on the line, I think you 

may have hit mute. Please don't do that again 

because -- or don't hit hold, sorry, because 

it disrupts the call. Thank you. It's all 

yours. 

 CHAIR BEACH: Okay, thank you, Ted. 

 First of all, I want to say good morning and 

welcome to the Mound's fourth Working Group 

meeting. And I would like to thank NIOSH ORAU 

Team, SC&A, and all the Work Group members for 

all of the work that has gone into preparing 

for this two-day meeting. 

 A couple of agenda item changes or 

additions, actually, that I need to make note 

of. Today, if you would add, I think most of 

you in the room have it, at the end of the day 

after Price-Anderson related bioassay, Issue 

21, we are also going to discuss, led by SC&A, 
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Shallow Dose, Issue Number 16, and 

Environmental Issue Number 20, also led by 

SC&A. 

 MR. FITZGERALD: Yes, that is 

already on there at the end. 

 CHAIR BEACH: On yours but the ones 

on line did not have those added. 

 MR. FITZGERALD: Oh, okay. 

 CHAIR BEACH: So that is for the 

folks on the phone. 

 And at this time, we are going to 

go ahead and start in with Bob Bistline, I 

believe you are leading. 

 MR. FITZGERALD: Well, let me give 

a little preface. 

 CHAIR BEACH: Okay, please do. 

 MR. FITZGERALD: This is Joe 

Fitzgerald and just a little history on this 

one. 

 You know, we look at the 

reliability of records, in terms of integrity, 

completeness and adequacy on all of the SEC 
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reviews as part of the Board's procedures. 

And of course, the reliability of records are 

fundamental to dose reconstruction and 

certainly key to the SEC review. 

 This one, we looked at adequacy and 

completeness. And they were really one white 

paper for a long time then we broke it up. So 

in essence, the first item, which is issue 11, 

which deals with adequacy is sort of the first 

part of the question of reliability of 

records. And the second part we have down as 

issues 12 and 13. So really this morning, we 

have reliability in two parts but they are 

really part of the overall same issue. 

 And as far as a little bit of 

background since we have been going back and 

forth on this issue for almost, well, a bit 

over a year in fact, the evaluation report 

claims that the available monitoring records, 

process descriptions and source-term data are 

sufficient to support dose reconstruction, 

sufficient accuracy, except for the '49 to '59 
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period, which was acknowledged as an SEC 

period. 

 We reviewed the ER and, in support 

of the Work Group, responded that we had a 

couple of issues with that statement, that 

conclusion. One was that the historic methods 

we felt were unclear, again, based on the 

evaluation report. And all of this goes back 

to the evaluation report and the site profile 

before that the historic methods were unclear 

in some cases. Not all cases, some cases. 

 Secondly, that the effectiveness of 

early bioassay methods, particularly the gross 

alpha technique, which we have discussed 

already in the past; we still had questions or 

felt that, based on what we have reviewed that 

it was still, in our mind, not clear how that 

is going to support dose reconstruction. 

 And with all of that in the white 

paper that we generated last year, we laid out 

again some examples, illustrative examples of 

what we were trying to convey on that. 
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 The NIOSH response, and again, this 

has been going back and forth, the NIOSH 

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position -- overall position and provided 

certainly, I thought, some different 

perspectives on the specific examples that we 

offered. That, you know, they are in fact, 

where we had problems or questions or 

concerns, I think the response was they can be 

managed in some cases, if the issues were ones 

that were faced routinely in dose 

reconstruction, there's ways to, in fact, 

address these issues and work around them. In 

other cases, I think the NIOSH response was a 

request for more clarity from SC&A. 

 And I think on that basis the Work 

Group, last year assigned SC&A the task of 

going back and elaborating in more detail 

where this concern stemmed from and providing 

some more-detailed basis. And this is the 

genesis of the white papers. There are two 

white papers, one for Issue 11 and one for 
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Issues 12 and 13. So, the first dealing with 

data adequacy which we are addressing right 

now and the other dealing with the 

completeness issue. 

 And I am going to let Bob get into 

the findings on that first white paper, which 

deals with data adequacy, but that is kind of 

the background on that. 

 DR. BISTLINE: Okay, I just don't 

want to go ahead and address these issues and 

then after I address the main issues -- and 

they are pretty well covered in the executive 

summary of this paper on adequacy. Then, we 

can have some response from NIOSH and some 

interaction on some of these. 

 But the first point coming up is 

the fact that many -- there was a wide variety 

of radionuclides, including alpha-, beta-, and 

gamma-emitters. And the primary radionuclides 

of concern by building and room have been 

outlined in the King Report, Mound Site 

Radionuclides by Location. 
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 And at times, Mound conducted 

operations where there were potentials for 

exposure to radionuclides outside the scope of 

Mound's bioassay capabilities and in some 

cases, bioassay techniques were available. 

However, the bioassay samples were not 

collected. 

 And examples for periods of time 

when Mound did not routinely analyze for other 

radionuclides -- and this the issue that we 

have tried to point out -- are demonstrated by 

gaps in the bioassay for radionuclides such as 

actinium, the americium-241, curium-244, 

protactinium-231, and uranium and thorium. 

 In response to these, the absence 

of radionuclide-specific data, the NIOSH 

proposes to use gross alpha and gross beta 

results. And since the radiochemistry was 

conducted on samples prior to gross alpha and 

beta counting, it is important to validate the 

ER's assumption that the chemical recovery is 

equivalent for all alpha emitters in the 
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generic gross alpha procedure. And we feel, 

SC&A feels, that it is important that NIOSH 

demonstrate the procedure for assigning 

internal dose to employees who were exposed to 

multiple alpha emitters during that time 

period when the gross alpha analysis was 

implemented at Mound because there were 

multiple alpha-emitters and it points out the 

fact that it is not clear how dose 

reconstruction for specific isotopes of alphaemitters is going to take place. 

 In addition, it should be 

demonstrated how internal exposures will be 

reconstructed for gamma- and beta-emitters, in 

the absence of the gross alpha and beta. 

 So, this, the issue of gross alpha 

is an issue that we have some real heartburn 

over. 

 DR. NETON: Bob, excuse me, what 

time period is that for the gross alpha? 

 DR. BISTLINE: The gross alpha, 

these were during the earlier part of the 
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analysis. 

 DR. NETON: I mean, '59 to -- I 

mean is it a short period of time we are 

talking about or is it a long period? 

 MS. ROBERTSON-DeMERS: The gross 

alpha years were from 1956 to, I believe, 

through 1980, when they started doing alpha 

spectroscopy. 

 DR. NETON: And I guess that is 

helpful. Thank you. 

 DR. BISTLINE: So that goes outside 

the bounds of the SEC period, time period. 

 Another issue that is the issue on 

polonium, it is SC&A's judgment that the 

uncertainties of polonium, urine excretion 

results, were not adequately resolved. The 

accuracy of measurements depends on the 

efficiency of the plating method, which is in 

turn a function of the activity excreted. And 

the time after the intake, the mode of intake, 

and there is differences. The metabolism that 

is sited as a response goes back to the baboon 
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studies. And in conclusion, polonium 

calculated using results from urinary 

excretion and correction factors suggested the 

ORAU's Technical Basis Document 16 probably do 

not present the doses really incurred by their 

workers from polonium exposures until 1964, 

Millard 2004. 

 The uncertainties on the plutonium 

excretion results were not really resolved. 

The dependency of the efficiency of the 

plating and so on and the metabolism are not 

sufficiently accurate to estimate the workers' 

body burdens and to calculate organ doses, 

based on the baboon metabolism and the 

differences between the metabolism between the 

baboons and humans. 

 The next issue that is sited in 

this white paper is the issue of thorium which 

is a pretty large issue. And it gets into the 

method for thorium monitoring. The preferred 

method for thorium monitoring is really, 

because of the problems with bioassay urine 
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sampling, is usually using a combination of 

personal air sampling, PAS, and fecal analysis 

and monitoring, which were not routinely 

implemented at Mound. 

 And solubility studies from samples 

collected in the R building indicate that the 

thorium-228, thorium-232, and a fraction of 

thorium-230 compounds behaved as a class YY 

form, a very insoluble form, making detection 

in urine more difficult. So, this would put 

more emphasis on the issue of doing fecal and 

air sampling, in order to get decent results. 

 So, dependency on urine bioassay 

for thorium is really questionable because of 

the solubility issue for some of the forms 

that were used at Mound. And regardless of 

whether thorium or gross alpha bioassay is 

utilized for dose reconstruction, NIOSH has 

not evaluated the effectiveness of 

radiochemical techniques, thorium-specific or 

gross alpha, to isolate thorium in urine. 

 An evaluation of the radiochemistry 
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is necessary to verify the thorium. It could 

be effectively measured by the techniques 

employed. 

 And the ER evaluation report does 

not clearly state how NIOSH determined the 

employees with the greatest potential for 

exposure were monitored. In other words, how 

are these workers that may have had potential 

exposure to thorium, including support 

workers, identified. And so we have some 

concern as far as identification of workers 

because NIOSH says that employees with 

greatest potential for internal uptake were 

monitored but the question is, how that is 

being determined and how support workers fit 

into that equation. 

 Similar to the difficulties in 

interpretation of radium-226, and actinium-227 

and thorium-228, there are similar issues 

associated with the data interpretation of 

thorium data prior to the implementation of 

the thorium procedures. And MJW does not 
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indicate in the pre-1989 reports that the 

data-interpretation issues diminished after 

February of 1959, the end of the SEC. In 

fact, the following comments were made related 

to that. And there are four different 

specific comments that are brought out in the 

paper here. 

 In many cases, there were results 

for an element such as radium or thorium but 

it was unclear which isotope was intended. 

And there was no information on the age, 

solubility or chemical form of the element. 

And certainly one of the most fundamental 

problems faced by the assessors assigned to 

the other radionuclides was to determine if 

there was even sufficient data upon which to 

estimate whether the individual would require 

a Phase II assessment. And in some cases, the 

sample is identified by a code number. No 

person is directly associated with it in the 

log book. And a second log book must be 

consulted for the cross-reference between the 
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person and code number. 

 We found that there is data that is 

located in various locations, and this will 

come up in the completeness report later, 

where one has to go to a number of different 

locations and databases in order to be able to 

trace this down and we are not sure that that 

is being done by the dose reconstruction of 

individuals, that they are capturing all of 

the data that is out there. And regardless of 

the availability of a thorium bioassay 

procedure, bioassay-specific for thorium at 

Mound is limited. 

 A total of 84 sample results were 

located by SC&A for thorium-232 for the period 

1960 to 1967 from the database of the 

excretion data of other radionuclides and the 

database of radium, actinium, thorium 

excretion data as well as log books and 

bioassay reports. There were no sample 

results during this time period for thorium230. In addition, five samples were located 
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for the 1970s and NIOSH should produce the 

thorium samples for the periods 1960 through 

'67, 1972, 1978, and 1979. In contrast, there 

were 238 thorium-232 bioassay results and 180 

thorium-230 bioassay results available for the 

SEC period, based on the MJW, other 

radionuclide files. 

 So in summary, the limited amount 

of data and the shortcomings associated with 

data interpretation remain for thorium beyond 

the established SEC period ending in February 

of 1959. 

 Although urinalysis data exists for 

thorium prior to 1970 procedures on how these 

samples were analyzed and interpreted are not 

available. The data infers that at least a 

portion of the thorium analysis was analyzed 

by the radium extraction and differential 

accounting method to measure the radium 

daughters of the thorium. And if this is the 

case, then it is noted by MJW. There are a 

lot of questionable assumptions to be made in 
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using an excreted daughter to estimate the 

intake of the parent. 

 Use of radium daughter analysis for 

thorium isotopes is suspect due to the 

questionable assumption that the daughters are 

in equilibrium with their parents. And the 

lack of bioassay procedure information can 

make the derivation of the minimum detectable 

activity or minimum detectable concentrations 

which form the basis of the NIOSH-proposed 

method of assigning missed dose difficult, at 

least. 

 SC&A recommends that the procedures 

implemented for thorium analysis be 

investigated further. NIOSH should 

demonstrate the feasibility of conducting 

thorium dose reconstruction prior to 1970, the 

earliest date when a specific procedure can be 

located for thorium analysis. Furthermore, 

NIOSH should demonstrate the supplemental data 

such as process information and air sampling 

data are available for all years and areas 
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where thorium was handled. 

 So, that kind of summarizes the 

issues with regard to thorium. As far as some 

other radionuclides, as a result of the 

inability to isolate radionuclides such as Pa231, actinium-227, and thorium-228 directly 

with early bioassay methods, radionuclide 

progeny, or daughters, were used as a 

surrogate for the parent. And where daughters 

are used to derive parent radionuclide 

activities, knowledge of the ratio of the 

daughters to parents in source terms must be 

known and the differential effects of 

biokinetics between the parent and the 

daughter radionuclides must be considered. 

 Because of the difference in 

solubilities and the metabolic differences in 

biokinetics, data can be obtained from process 

information. However, the age of the material 

is generally unknown in equilibrium between 

parent and daughter. It depends on the age of 

the material, and equilibrium may or may not 
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exist, which complicates trying to use a 

surrogate or a progeny as a means of 

calculating dose for those individuals. 

 Given the uncertainties of the 

early bioassay techniques for these isotopes, 

the limited amount of bioassay data available 

are for these radionuclides. The feasibility 

of performing dose reconstruction prior to 

development of such methods for parent 

radionuclide isolation is questionable, in our 

minds. 

 There is also an issue of, a 

question of the chronic or multiple intakes of 

the radionuclides that may confound the 

problems associated with determination of 

retention and excretion rates. And these 

issues introduce large uncertainties in the 

determination of intakes of the Pa-231 and 

actinium and thorium-228. 

 Going on to the next issue that is 

brought up in the paper is the issue of 

tritium and the question of tritium at Mound 
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did not exclusively handle tritiated water and 

gas but was involved in research and 

development activities for other tritium 

compounds. And it is a very well-known that 

there were a large number of tritium compounds 

handled at Mound. We have been able to trace 

down at least, well, I have got one table of 

35 different compounds and the number 

actually, it turns out, is probably more like 

about 50 compounds of tritium. Many of these 

are stable metal tritides and the ER did not 

provide a discussion on how tritide exposures 

will be identified and assessed, although this 

issue is partially addressed in the OTIB-0066 

calculation of dose for special tritide 

compounds that ORAU published in 2007, for 

which SC&A provided a detailed review in 2008. 

 Pre-1982 data is available only in 

terms of dose in the MESH database and the 

individual exposure files. 

 In the absence of these data, the 

-- oh, excuse me, I mentioned that. How is 
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can they identify the workers exposed and to 

which of the many different compounds that 

were present? These are questions which we 

have in mind and there is a session later on 

talking about the tritides where we will get 

into a little more discussion of this. 

 Another issue that is brought out 

is the bioassay collection and timely 

analysis, the failure to collect and analyze 

bioassay samples in a timely basis leads to 

questions about the validity of the sample 

results. There has been questionable 

implementation and coverage of the bioassay 

program at Mound and detailed characterization 

of areas and appropriate guidance assessing 

bioassay requirements are not effectively 

implemented until the site transition to D&D 

mission. So, this was not until much later in 

the years at Mound. 

 The absence of inadequate or 

infrequent participation in the bioassay 
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program can lead to an internal exposure which 

may not be bounded by assigning a chronic 

exposure based on the reporting level or 

bioassay samples were not collected within 

several effective half-lives of fast-clearing 

radionuclides. Because of the sampling that 

was done, there were times when, probably, the 

time between the samples actually ran for 

short-lived isotopes through several halflives. It would have been through several 

physical half-lives of those radioisotopes. 

And so there are some issues that we have with 

trying to do the dose calculation based on the 

fact of sampling frequency. 

 Although NIOSH has developed a coworker model for plutonium and polonium, the 

issue with absence of or inadequate monitoring 

extend primarily to other radionuclides. 

NIOSH should demonstrate the existing dose 

reconstruction models and bound situations 

outlined in the Price-Anderson reports, 

keeping in mind that the details of potential 
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exposure will not be readily available prior 

to consistent implementation of the radiation 

worker permitting process which didn't come in 

until 1989. 

 So, this kind of summarizes the 

issues that SC&A is concerned with in terms of 

the adequacy of data. 

 Joe, do you have -- 

 MR. FITZGERALD: No, the only thing 

I would say is that you know, the white paper, 

I think has been in NIOSH's hands for probably 

three or four weeks. So, it is not a long 

time for the details that were provided. But 

I think that is a pretty good outline of what 

we had originally raised last year in a little 

more detail, more examples and faces. 

 CHAIR BEACH: NIOSH, would you like 

to weigh in? 

 DR. ULSH: Oh, yes. Well, as Joe 

mentioned, the latest SC&A paper has been in 

our hands for about three weeks or so and we 

will be preparing a detailed response to it. 
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Obviously, that couldn't be done for this 

meeting. 

 But there are a number of issues 

that Bob raised and I am not sure that we can 

go into a detailed discussion of all of them. 

 But I know that there are a number of people 

on the ORAU team who want to jump in here and 

address some of the specific issues, including 

Don Stewart, Liz Brackett on the phone, and 

perhaps Mutty Sharfi, who is also in the room 

here. 

 Just for a few of them, in General 

the quotes that you cited from MJW, I think 

Liz, would you like to talk about those? 

 MS. BRACKETT: I guess there so 

many issues. Can we pick one? 

 (Laughter.) 

 MS. BRACKETT: Because I wasn't 

taking notes because I thought maybe we would 

go through and address one at a time. And so 

I am kind of overwhelmed. 

 DR. ULSH: Okay. Well how about, 
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let's talk about the radium/actinium/thorium 

method and the difficulties that MJW quoted or 

the quotes that Bob gave from MJW on that. 

 We agreed that there were issues 

with the radium/actinium/thorium method and 

that was the basis for the SEC period up to 

1959. We understand that, and that is already 

a given. It was surprising to me that you 

talked about a difficulty with actinium in 

years after that. We have also talked about 

that issue in the past. 

 Oh, and the other quote that you 

gave was that MJW did not say that that 

problem interpreting those results diminished 

after 1959. Well that is correct; we never 

said that they did. The issue with the 

radium/actinium/thorium program was that it 

was completed and D&Ded in 1959. So it is not 

that all of a sudden we can interpret the 

bioassay results, but rather the program to 

which those results related was finished and 

done. 
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 Now, we have talked about in the 

past that there was a small operation to 

extract some of the actinium that was done 

inside a hot cell. We talked about that. 

There was a spill inside the hot cell but it 

was completely contained. So it is not that 

we suddenly became confident in the bioassay 

method but rather that program was done and 

over. And it is not like actinium processing 

continued after that date. Certainly, they 

had an issue with actinium samples early in 

the D&D period but that was related to D&D of 

the facility. And I think we all know what we 

are talking about here, our corridor job. But 

it is not like they were doing actinium 

samples throughout Mound's history. We talked 

about that. 

 With regard to the thorium program, 

I think a little perspective is in order here. 

 Mound did have a large inventory of thorium 

material. It came onsite in I think late 1954 

and in early 1955. This was residues, 
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Brazilian monazite residues, oxidite residues, 

a bunch of different kinds of thorium 

residues. And Mound got this material in 

anticipation of operating a thorium refinery. 

 That program never got off the 

ground. They received the feed material. 

They even built the facility to handle it, the 

pilot plant to handle it, but that project was 

canceled in 1945 and never went into 

production. 

 So, since that happened, Mound was 

left with all of this inventory of thorium 

material. The only thing that we are aware of 

that Mound did with that material was re-drum 

it because it was contained in drums that 

corroded. The material in some cases was 

stored outside and drums were in very bad 

shape, so they re-drummed it. This involved 

only a handful of people, approximately 20. 

Don't hold me to that number but we know who 

they are. We have bioassay results for them. 

 Now, I know that some questions 
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have been raised about the adequacy of the 

thorium bioassay but I think we are missing 

one of the important pieces of information 

that that bioassay, that collection of 

bioassay results gives us and that is, who was 

involved. We have done worker interviews. 

They confirm the small number of people 

involved. They also confirm the sporadic 

nature of this work. It was done primarily in 

the months of the year when the weather was 

good: the summer. And some of the drums, it 

was re-drummed up to about three times. 

 This work was performed, by and 

large, outside. Respiratory protection was 

employed. So, we can talk about the thorium 

bioassay methods and results. But the bottom 

line is this involved a small number of 

people. Due to the issues, the continuing 

issues of having to re-drum this material, 

they eventually built Building 21, which was 

located near the site periphery, far removed 

from other buildings onsite, other facilities 
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onsite and the material was emptied into this 

building. 

 Now, keep in mind that this 

building is essentially kind of like a silo 

and it was unoccupied. People didn't go into 

this building on a routine basis, although 

sometimes they did to sample, to do air 

sample. So, it is not like this material was 

a source of exposure to other people onsite 

routinely. 

 So I just think we have to keep a 

little perspective when we are talking about 

thorium-232 and I know that there are some 

other issues that we will need to go into in 

our written response. 

 The same kind of perspective needs 

to be drawn with the protactinium-231 program. 

 Yes, they did have several, numerous drums of 

material to extract plutonium, I'm sorry, 

protactinium-231 but that program involved 

about five people. So it is not like it is 

everyone on site. And there are protactinium 
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bioassay results but it wasn't as if that 

protactinium was in isolation. At the 

beginning, it was in residues in very, very 

low concentrations. So, yes, we did use 

surrogate or Mound did use surrogate 

radionuclides. 

 Now, you mentioned that you have to 

know the age and material and several other 

factors of biokinetics. But the bottom line 

is if you are working with a drum of material 

that contains numerous radionuclides and you 

sample for the most prevalent radionuclide and 

you don't get a positive result, that 

indicates to you that an uptake didn't happen. 

 So that is, I think, the approach that Mound 

took. 

 And it is kind of difficult to see 

how they would have selectively got exposed to 

the trace element without being exposed to the 

major radionuclide in the matrix. 

 Now, you mentioned chronic versus 

acute and some uncertainties that that brings 
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in. This is a -- do you want to jump in now? 

 MR. STEWART: This is something 

that we evaluate on a case-by-case basis. We 

look at bioassay data and try to determine 

whether what we have got is chronic or acute. 

 When we don't know, which is often, we will 

simply assume the one that generates the 

highest dose. And that is the approach that 

we take to every single case. Very rarely 

will we say, aha, I have a result here. It is 

an acute intake. 

 And if you have enough data, you 

can isolate that. You can go back and say 

well, chronic intake results in a very large 

dose, which I can't use that much dose. It is 

too claimant-favorable but I have enough data 

to isolate this. I have got incident data. I 

have got repeat bioassays, follow-up 

bioassays, whatever I do, whatever I have got 

to generate an accurate dose. 

 But as I say, it is very seldom 

that we do that because as we all know here, 
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the vast majority of claims fall into the 

easily compensable or the easily noncompensable range. I don't have to generate 

an accurate dose estimate. I just have to be 

right. Is it greater than 50 percent or less 

than 50 percent. 

 So, if I have a guy that has got 

tons of plutonium intakes and lung cancer, I 

will assume a single acute intake on this one 

day, I will come up near the data point on the 

graph and drop down below it. I will have a 

number of data points above the line that I 

draw, the excretion curve. But that dose is 

sufficient, in and of itself to determine 

whether that case is compensable. So, I am 

done. I don't need to generate an accurate 

dose. I have established that it's obvious 

this guy's dose is going to result in 

compensability. 

 On the other side of it, I may have 

a number of data points that I could plot very 

accurately. But if everything I do is not 
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going to make this case compensable, I will 

simply pick the highest one, generate a line 

that sails over every data point, generates a 

very large dose, and yet is not compensable. 

So that again, is not an accurate dose 

estimate but it is sufficient to show whether 

it is compensable or not. 

 DR. ULSH: Well, this is not a 

Mound-specific issue. We use this strategy in 

every dose reconstruction we do. 

 MR. STEWART: Correct. 

 DR. ULSH: So, I don't know why 

this is being brought up as an SEC issue for 

Mound when this is an accepted methodology. 

 MR. FITZGERALD: Well, let me step 

back. Again, the ER, I think, didn't focus on 

the reliability or assay question other than 

making a statement that there was sufficient 

data, there was sufficient process information 

and, you know, made those statements. And 

certainly, the Work Group, if not the Board 

obviously has the responsibility of probing 
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the reliability. So what we are saying is 

that we, in the process of looking at this 

question of reliability, posed the questions 

of, you know, and this is particularly on the 

other nuclides, and clearly we looked at the 

mainstream and felt that you know, during the 

history of the operations, the mainstream 

nuclides, plutonium, what have you, did have 

in fact an established bioassay method and we 

found the documentation, we felt that it was 

certainly evidence of accuracy. 

 On the other nuclides, and granted, 

I think your point was, five workers here, ten 

workers here, these were relatively small 

operations. These were secondary operations 

made at the plant. We were less clear because 

ER didn't treat those subjects. Less clear 

what the strategy of dose reconstruction would 

be. 

 And again, this is the going 

through and looking at the balance of the 

plant in terms of the nuclides saying, it is 
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not treated specifically in the ER. We do 

have questions. We are concerned, in some 

cases, because it is not obvious to us what 

the reliability of the dosimetry is for each 

of these. And we posed these in a very short 

form, I think, last year, and tried to be a 

little more elaborate this time. 

 So, you know, this to me is just 

simply clarifying since the ER did not address 

these specifically but made a broader 

statement what the stance is, how dose 

reconstruction would be done. In some cases, 

I think you are saying that it would be 

addressed in the dose reconstruction 

procedures. In other cases, you have, I think 

you stated this before, Brant, that there is 

mitigating issues relative to the number of 

workers involved, as well as some of the 

techniques applied. That is what we want to 

clarify. We have to walk through this but I 

think these are the questions that came up. 

So that is the context of why these were 
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raised. You know, I don't think we are 

presuming that we found this huge gap that we 

are saying that the ER didn't go into these 

other specific other nuclides in the detail 

that would give us confidence that the 

reliability has been addressed. And that, I 

think is the responsibility of the Board to 

ask those questions. 

 DR. ULSH: Okay, I understand -- 

 DR. MAURO: John Mauro. I would 

like to add a comment. You know, I have 

reviewed these six white papers and I 

understand the response you provided, the 

fundamental concept of your strategy for 

bounding dose reconstructions. It is not 

intended, necessarily, to be an accurate but 

to make sure a good decision could be made 

regarding compensation. 

 But you know, when I reviewed these 

issues, the ones that were just summarized by 

Bob Bistline, it seems that there seems to be 

certain radionuclides that you are going to 
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have a difficult time placing a plausible 

upper bound on, for the reasons described. 

And it is not apparent to me that you do have 

a good method for placing a plausible upper 

bound, in light of the limitations that were 

identified by Bob. 

 Maybe we could talk a little bit 

about, as was mentioned earlier, we went over 

so much material, starting with the gross 

alpha work and then proceeding on through all 

these other isotopes. And unfortunately, I 

think we gave an overview of really all these 

internal dosimetry issues. And it would be a 

pretty good idea, I think, let's go; we have 

got two days and if you agree, let's go to the 

issues one-by-one, perhaps starting with the 

gross alpha analysis and how, with the gross 

alpha analysis and the uncertainties regarding 

the biokinetics, chemical form, and recovery 

of radiochemistry. When you do the bioassay 

for urine, how are you going to place a 

plausible upper bound when you don't know 
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which radionuclide chemical form and perhaps 

the, I guess, recovery efficiency is. You 

know, I would like to hear a little bit about 

-- that would be one example of one particular 

issue that if there is a way to place a 

plausible upper bound, given these 

circumstances, I would like to hear 

conceptually a little bit about how you are 

looking at it or would you rather wait until 

you have a chance to prepare your formal 

write-up? 

 CHAIR BEACH: John, this is Josie. 

 And while we do have two days, we do have a 

very full schedule. So we are going to give 

them an opportunity to respond to your 

question but I believe Kathy wanted to add 

something before we do that. 

 MS. ROBERTSON-DeMERS: Let me ask 

you a more basic question. You have got 

somebody who is exposed to multiple 

radionuclides at Mound. Can you walk me 

through what records you would get to do the 
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dose reconstruction and how you do it? 

 MR. STEWART: It is always 

difficult to do that in the abstract. What 

records do we look at? Right now, the 

technical basis document doesn't drive us to 

drill down to this level of detail, and that 

needs to be revised. So, right now, we don't 

have that process. 

 We will see records for Pu-238. And 

we typically accept them at face value at this 

point. Some of the older records will be 

listed as thorium, radium, actinium, in some 

cases, protactinium. We do have some 

procerium, some proamericium. But we will 

have those -- when those are present in the 

record, they are evaluated. 

 MS. ROBERTSON-DeMERS: Let me 

clarify here. 

 MR. STEWART: Could you speak up 

just a little bit, Kathy? I am sort of hard 

of hearing. 

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looking at just the individual employee folder 

for data or are you going out to the MESH 

database and collecting that data? Are you 

going to the MJW tables and collecting that 

data? 

 MR. STEWART: The very simple 

answer is we look at the employee data files 

because that is what we are given. That is 

the standard approach as far as dose 

reconstruction. 

 DR. ULSH: I would assume they give 

you a MESH. 

 MR. STEWART: Yes, MESH is part of 

that record, Kathy. 

 MS. ROBERTSON-DeMERS: You mean the 

printouts? 

 MR. STEWART: Say again, please? 

 MS. ROBERTSON-DeMERS: You mean 

there are printouts of the MESH data in the 

files. 

 MR. STEWART: That is correct. 

 MS. ROBERTSON-DeMERS: Okay and 
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then you find, for example, that somebody has 

been working at Mound from 1959 to 1994, for 

example, and they have been exposed to, 

potentially exposed to uranium, thorium, 

radium, actinium, fission products, plutonium. 

 How do you go about assigning the -- 

 MR. STEWART: Well the simple 

answer is, we don't find that. Other 

radionuclides are a problem at other sites as 

well. And what you have got is very small 

programs worked on by very few people. Most 

of the people walking around at Mound were 

exposed to polonium or Pu-238. And that is 

what is in their records. 

 DR. ULSH: But in terms of gross 

alpha, if we have knowledge that they might 

have been exposed to some of these other 

alpha-emitting radionuclides, those would be 

in the mix for dose reconstruction in terms of 

-- I mean, if there is a potential for them to 

be exposed to say, uranium, then we would 

consider that. 
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 But by and large, like Don said, 

these programs were extremely small. So, if 

you have a gross alpha result and followed by 

lots of plutonium-238 results, chances are, it 

is plutonium-238, if there is anything in the 

gross alpha. 

 MR. STEWART: Right. The dose reconstructor doesn't go into a dose 

reconstruction with a preconceived idea of the 

radionuclides he is going to or he is going to 

assign. They look at the data in the case. 

They look at what the claimant may have said 

about what the person was exposed to and then 

they go from there. 

 So, I mean, you could find that and 

I have found that in the past. I had a 

gentlemen who had a lot of polonium bioassay, 

routine polonium bioassay and in fact, his 

work was on polonium research. But he also 

had a couple of other samples thrown in there. 

 So, those were evaluated as well. 

 You typically don't get that. You 
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know, you have to remember that the cases we 

are looking at are a small fraction of Mound 

employees. And I don't know what the numbers 

are. Several hundred Mound claims. There 

must have been tens of thousands of Mound 

workers by this point. 

 So all the dose reconstructor is 

going to evaluate is the data for that 

specific case. 

 DR. ULSH: Well and another thing 

to consider is that not in every case, 

certainly, and not for every particular organ 

in the body but in most cases, plutonium-238 

is going to be the claimant-favorable choice. 

 MS. ROBERTSON-DeMERS: Well, I 

guess that is what I am asking. If you have 

got multiple, if you have found that somebody 

 has potentially been exposed to multiple 

alpha-emitters for example, how are you going 

to assign? 

 DR. ULSH: We are going to take the 

most claimant-favorable choice, just like we 
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do everywhere else. 

 MS. ROBERTSON-DeMERS: And you are 

going to take the most claimant-favorable 

radionuclide recording. 

 DR. ULSH: Of course. That is what 

we do everywhere. 

 MS. ROBERTSON-DeMERS: And assume 

that say a plutonium-238 value that is given 

is actually thorium, for example, if that is 

the most conservative. 

 DR. ULSH: If it is reasonable to 

assume, keep in mind, say for instance the 

thorium, the example that you used, we knew 

who was involved in the thorium program. We 

have thorium bioassay results. Now, you may 

not like what the thorium bioassay results 

tell you but it does tell you who was involved 

with the thorium program. So if we, let's 

say, we have someone, one of these, let's just 

pick a number, 20 people who are involved in 

the thorium program and their claim comes in 

for dose reconstruction and they have a gross 
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alpha result, of course we are going to 

consider thorium as one of those 

possibilities. And if it is the most 

claimant-favorable choice, say it is a bone 

cancer, of course, that would be in the mix. 

That would be one that we could consider. 

 MEMBER SCHOFIELD: Okay, what if we 

had someone that comes in from one of the 

crafts who is not part of the polonium 

project, he is not one of those 20, but he or 

she comes in there to do a particular job and 

gets exposed or even multiple times because 

they have the certain expertise or they are 

familiar with that system there. So, they 

come into that area but yet you are not going 

to show them in that database that they were 

one of the polonium workers. How are you 

going to address those type of people? 

 DR. ULSH: Wait a minute. Are we 

talking about -- 

 MEMBER SCHOFIELD: Okay, we are 

talking about, it doesn't matter, take any of 
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the -- whatever you want to pick. It doesn't 

matter. We are saying that you said there was 

like 20 people in that project, -- 

 DR. ULSH: Thorium. 

 MEMBER SCHOFIELD: -- thorium 

project. Okay. 

 Now, you have got these craft 

workers, maybe fire department, maybe guards, 

come in there for whatever reason, doing 

something and getting an exposure. But when 

you go back and look at that database, it is 

not going to show that they worked with 

thorium. And they may not even actually have 

any bioassay for thorium because people making 

decisions said, well, they don't really work 

in that area. But for whatever reason, they 

had to go in there and do a job or they were 

in there when something for whatever reason. 

 MR. STEWART: As far as the thorium 

re-drumming goes, those were craft people. 

 DR. ULSH: Yes, exactly. 

 MR. STEWART: They were riggers, 
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laborers. They were assay by job. You know, 

they were doing this thorium job so they are 

bioassay. And I think you will find that that 

is generally true with Mound. 

 MEMBER CLAWSON: Well, yes, but the 

point that he is trying to bring up, you guys 

have brought up a very good point that certain 

people only worked on actinium or any of these 

low radionuclides. You are saying 10, 15, 

maybe five or whatever. But you have got 

support personnel that come in there 

continuously to be able to redo calibration on 

instrumentation, do maintenance on their work, 

do ventilation upgrades or anything else like 

that. Those people aren't going to be 

monitored. Because as most of the sites, and 

we have all seen this, have said no, they are 

not into this 24 hours a day. They are just 

bits and pieces so they don't need to be 

monitored for that because that is costly. So 

just monitor these and we can go from there. 

 Because you have people going 
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through this stuff all the time. You have all 

your support organizations, endless ones, that 

are going to be going in there but they are 

not monitored. 

 MR. STEWART: Are you talking about 

this from a Mound-specific point of view or on 

a complex-wide basis? 

 MEMBER CLAWSON: It would be a 

complex-wide issue. You get into this quite 

often. But Mound is the exact same thing as 

the rest of these. We have seen at so many of 

these sites that the decision has been made, 

these ten people are the scientists that are 

going to work with this, so we will monitor 

them for this. 

 But then you have all your 

instrumentation people coming in, all your 

maintenance people, your electricians, 

changing out pumps. You have the broad 

spectrum of people going in there that are not 

monitored for that. 

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the individual situation here. For instance, 

with the thorium program, as Don said, these 

were the crafts people that were monitored. I 

mean, that was pretty much a -- it wasn't a 

research program it was -- 

 MR. STEWART: Crafts. 

 DR. ULSH: Right. The uranium 

activities, again, a small number of people. 

But to even get into the radiation controlled 

area, you had to be on a bioassay program. 

And by and large, the primary radionuclides of 

interest, like Don said, polonium in the early 

years and then it transitioned to plutonium238. If you went into those areas, you were 

on a bioassay program. 

 Now, I just thought of a caveat to 

that that in the later years, in the D&D 

years, of course, you have a DOE regulation 

where only if you had the potential for 100 

millirem per year. So there is a slight 

caveat there. 

 But by and large, I mean, Mound was 
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a very access controlled site. 

 MR. CHEW: Let me just jump in. 

After a few months away, I am just getting 

back into it. 

 Let's talk operational. And I 

think you know because you are in operation. 

I was an operation RHP. Let me tell you what 

is really going on. 

 At Mound, especially with the 

radioisotopes that we are talking about, 

plutonium isotopes and polonium isotopes they 

are handling glove boxes. There are many 

indicators. There are many indicators that 

tell you that an exposure potential could have 

occurred. Glove breakage, leakage, something 

you did wrong, bag out, okay you name it. So 

there is swipes and there is air samples. 

 Now, the people who are actually 

working on a day-to-day basis, less 

conservative on a routine basis. But if a 

relevant person came in and did something that 

potentially caused an exposure, indicators 
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would show up very quickly -- air sample, 

swipe. In these particular cases, what we did 

was, and you probably did, too, this is an 

incident because these are the people who are 

not normally working with the material who 

potentially get exposure. We have got to talk 

about exposure potential. 

 And so you could always give a 

hypothetical situation when a person walks in 

they walk into an exposure. And I would say 

from an operational standpoint, those people 

are, for lack of a better word, are generally 

picked up. When you see that, yes, there was 

a bunch of craft people that came in and they 

opened the pump and they did something wrong. 

 No operational people were around. That is 

not usually true. We usually don't do a job 

unless there are monitors around plus all the 

other indicators. 

 And so my comment to you is that if 

the people are crafts people coming and did 

something that is unusual, that is huge 
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created and not only for exposure potential 

but a real exposure for so many indicators 

that they would have followed up on bioassay. 

 And as you know, one of the things that you 

have asked us to do is go back to the road map 

and pull all the incidents. 

 So I am saying, you have got to 

think operational. I think you understand -- 

 MEMBER CLAWSON: I understand that. 

 And being in operations, took, you understand 

that we have in the earlier years, you had so 

many wonderful HPs or RAD techs or whatever 

watching us. They would come in, they would 

swipe the outside of it and say okay when you 

guys break this, I want to be able to take a 

look at it or whatever else. We are pulling 

out whole pumps or breaking lines or whatever 

else like that. A lot of times, there is not 

enough coverage to go around. 

 But the whole thing is, when they 

make the term you are on a bioassay program, 

you know, we will catch it if anything does 
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pop up. But a lot of times, they were looking 

for these other odd ones that came out. Where 

were they? When they went into the -- they 

checked for everything. Did they give the 

bioassay the whole gamut or -- 

 DR. ULSH: Well, I think the 

thorium example, it is kind of unfortunate in 

the way that we have focused on that one 

because it is not typical of what was going on 

at Mound because it did involve a lot of 

primarily crafts people. It wasn't an active 

research program, it was just re-drumming. 

 But some of these other exotics, I 

would call them, or the other radionuclides, 

they were very small in scale. They were very 

limited, a limited research program. And you 

didn't have craftspeople wandering through. 

 MEMBER CLAWSON: But you had them 

maintaining. That is what I am saying, these 

programs did, these guys didn't walk into a 

room and you never saw this stuff again until 

five years down the road. There was 
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maintenance that had to go on there. There 

had to be instrumentation that was calibrated. 

 There had to be all of this to be able to 

make this research work. This is what I am 

talking about because we see this so often so 

many times. 

 We have instrument techs that go in 

there that pop lines on things. They are 

supposed to be so clean, no big problem. They 

are not. 

 But then I realize what you are 

saying Mel, but you know as well as I do that 

what I am trying to say is that when we put a 

caveat on there that this is a very small 

operation and only five people worked on it, 

times that by about five. Because that is 

usually what ended up working onto it. 

 Because when there was also 

incidences, it brought in more people of hey, 

you know, what do we need to do to just be 

able to monitor this, to be able to keep this 

better off. This is the point that I am 
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trying to make. 

 MR. CHEW: Let's go back to your 

reference point where I know that you worked 

in the chem plant. And I think we can go back 

and look at how the chem plant was designed. 

Remember, it was a pilot plant that operated 

for infinite years here and it should have 

been shut down initially. I think that was 

the first pilot plant that really was a pilot 

plant. 

 And I think if I remember 

correctly, part of the problem was the chem 

plant was the instrumentation information was 

brought back lines from the process actually 

came into the control room. That is why you 

actually had release. 

 I had many tours of the chem plant 

and I wonder why they flunked. That is not 

true of Mound. Mound is dealing with high 

specific activity, alpha emitters, plutonium, 

polonium, those were the big ones, and we were 

handling glove boxes. It didn't have 
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instrumentation lines that were outside of the 

glove box, the material solution, fission 

products like you do. The chem plant actually 

has an excess. 

 So, it is a different type of 

operation. And like I say, go back to it. 

There is just so many other indicators that 

tell you that their exposure really did 

happen. Okay, exposure potential is obviously 

 when a person comes in and does a job, they 

assess the exposure potential. The exposure 

that really did happen is you follow them not 

only for contamination there, you know you can 

go back check their hands and feet, show the 

air sampler. The air samples are collected. 

You collect an air sample and say gee that 

day, there was a high air count because you 

see it a few days later. Who was in there? 

Well, gee, there was a craftsperson in there. 

 Let's go do a bioassay. And this happened. 

 MEMBER CLAWSON: And I realize that 

and I cannot speak for Mound on the air 
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samples. But you know what? We never really 

started pulling a lot of really good air 

samples into the late '80s and so forth. 

There weren't a lot of them pulled. 

 And I am just speaking from my 

side. I can't talk about Mound because I 

wasn't there but it seemed like we got a 

universal throughout all these telling like 

1985, '88 somewhere in there. That is when 

our radcon program really stepped up. We have 

got to look at that it really was in those 

days. 

 MR. CHEW: Yes, I don't know who is 

supposed to be speaking about the roadmap 

later on. Okay? I think it is the next day 

but I think I also brought a couple of things 

to show about the roadmap. I think the 

roadmap was good. As a matter of fact, I 

think was saying, no you gave them too much 

detail. I said okay, that is fine. 

 MEMBER CLAWSON: You can never have 

too much detail. 
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 MR. CHEW: Right. But I think if 

you really clearly look at the roadmaps, they 

are identified by room, by building, by period 

of time. The process was very important. 

Okay, we put a lot of process information. 

Sensitivity of the roadmap, obviously, and 

anytime that we know what radionuclides were 

present, they are listed, and then also the 

bioassay methodology. 

 So I think we need to think about 

that. You know, we presented you the 

potential exposure potential but to know 

understand what really exposures did occur and 

what follow-on. And then now when you have 

information on that real exposure, what does 

the dose reconstruction do with it? 

 And I think you know Brant and Don 

is just basically talking about that we took 

the most conservative radionuclides and used 

that as the basis. 

 MR. FITZGERALD: Well, I think we 

have -- just to reaffirm what Brad commented 
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on just a little earlier ago. You know, we 

have looked at the multi-purpose laboratories. 

 Now Mound certainly doesn't resemble Los 

Alamos or Livermore, but still, -- 

 MR. CHEW: Or a chem plant. 

 MR. FITZGERALD: -- or a chem 

plant, but in the pre-1980 era and examining 

laboratories like it, I mean, these issues are 

not new issues. You know, the notion of 

whether or not the technical feasibility was 

there to accurately measure mixed fission 

products, mixed fission activation products, 

a very big issue at some of the other 

laboratories. The same thing with thorium at 

Y-12. 

 You know, there just, to me, is a 

time frame where these, you know, the 

technology was on cusp and we did have 

exposures taking place. The question was 

whether in fact you had the bioassays being 

done and whether or not they were being done 

after these. 
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 I think we are talking about an 

early period where Mounds, like some of the 

other laboratories, were in fact on this 

cutting edge in terms of technology. The 

technology at Mound wasn't any better or 

worse, perhaps, than other laboratories. In 

fact, a lot worse based on Oak Ridge, in terms 

of the techniques. But nonetheless, I think 

the issues are very similar and we have asked 

the same questions and have had some concerns 

at other sites. 

 MR. CHEW: It sounds very similar 

to Rocky Flats. Bob, I think you and I met, I 

met you the first time when I was sent to 

Livermore to visit Bob Bistline, to find out 

what he does. 

 DR. NETON: I think we have been 

focusing a little too much on the bioassay 

program because that is a fact of the final 

safety measure and an entire radiological 

control program. 

 You know, we are talking almost 
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like we use people as human air samplers to 

see if the program is really working properly. 

 In fact, that is the last stop at that 

measure. We either look at the radiological 

control program, the controls Mel talks about 

such as glove boxes, are there continuous air 

monitors in place. You know, there is some 

sort of a general area air sampling program to 

supplement that, along with swipes. 

 And so you know, you have all those 

control measures available to you. And I 

haven't look at the Mound data but I assume 

there is data available to -- at least the 

program would be in place to document that. 

And the fact that a worker may have gone into 

an area and does not have a bioassay does not 

mean that it wasn't, his potential for 

exposure wasn't assessed at some point, using 

either air samplers, swipes, that sort of 

thing. 

 So you can't just assume because 

people weren't bioassay monitored that there 
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was this large unmonitored exposure going on. 

 You have got to look at the whole picture. 

 MR. CHEW: And also not assume that 

just because we list the radionuclide in that 

particular room, -- 

 DR. NETON: Well, right, I mean -- 

 MR. CHEW: -- doesn't mean it all 

jumped into the person's lung. It just 

doesn't happen. 

 DR. NETON: I mean, so you have to 

look at in perspective. 

 MS. ROBERTSON-DeMERS: And I think 

-- this is Kathy DeMers. I think you need to 

be aware of something that, you know, -- I 

think you need to be aware that there were 

some facilities at Mound that were used that, 

where they did use glove boxes but they were 

not designed for that function. And so they 

had numerous problems with incidents. 

 MR. KATZ: Excuse me. Excuse me, 

on the line, please. On the line there is a 

discussion going on and it is interfering with 
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the discussion in the room. Could you please 

 mute your phones? If you don't have a mute 

button, just use *6. That will work. Thanks 

a lot. And then when you want to come off 

mute, you just hit *6 again. Thanks. 

 MR. STEWART: I'm sorry, Kathy, 

could you go through that last bit again, 

please? 

 MS. ROBERTSON-DeMERS: Okay, there 

was a facility at Mound where they did handle 

things in glove boxes. But it was not 

designed for the handling that they were 

doing. So they were having numerous problems, 

incidents. This was SM building. 

 MR. STEWART: Say again. 

 MS. ROBERTSON-DeMERS: SM Building. 

 And so also keep that in mind. And we need 

to make -- 

 MR. STEWART: Is that covered in 

your paper? 

 DR. ULSH: I'll take that one, Don. 

 Yes. We are certainly aware of that, Kathy. 
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 One of the problems with SM building, and we 

have been talking to former workers and they 

all, to a man, emphasize that it was just a 

nasty place to work. The problem with SM 

building is that they handled plutonium-238 

but it was designed, essentially, to handle 

plutonium-239. And they didn't take into 

account the high specific activity of 

plutonium-238, the amount of heat that is 

generated, and they led exactly to the kind of 

problems that you just described; numerous 

leaks, numerous incidents. That is absolutely 

true. 

 That is why eventually they built 

PP Building to replace or to take over the 

activities of the SM Building. 

 Certainly while it was in place, 

though, there were numerous incidents like you 

described. Numerous incidents with plutonium238, primarily. I mean, I can't say that is 

the only thing that ever went into that 

building but far and away, that was the 
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mission of that building with plutonium-238 

handling. 

 And people who worked in SM 

Building would have been on plutonium 238 

bioassay. 

 MR. STEWART: And we see that in 

the records as well. You know, there is a 

noticeable drop in positives when you get out 

of the SM Building. 

 MS. ROBERTSON-DeMERS: That is not 

the only thing that was handled in SM 

building. 

 MR. STEWART: No, it certainly 

wasn't. 

 MEMBER SCHOFIELD: Let me give you 

some hands-on experience there. With 238, it 

is a real nasty player to clean up. It is 

very difficult. It is kind of like chasing 

mercury all over the place. I mean, that is 

effectively invisible mercury that you are 

playing with. 

 Well you go in. You have had an 
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exposure, whether it is broken line, a broken 

window, a torn glove. It doesn't matter the 

cause. Time is money. And you go in there 

and you try and get it cleaned up as quick as 

possible. 

 Now how often, and I could give you 

hundreds of examples where these guys go in 

there. Later on somebody goes in there. They 

get up underneath the glove box where there is 

some penetration and they get up on top where 

there is motors and electrical trays. 

 Well, they have got the front of 

the glove box down on the floor, all the very 

nice exposed stuff cleaned. But there is 

still loose contamination that can sit there 

for years. And they send this person in there 

and say well, you know, we just want you to 

insulate those lines for us, you know, we are 

having a little problem. 

 Fine, they go up there. They says 

we need new cable strung. You know, just use 

the existing tray. They get up there and they 
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get exposed. Nobody is expecting exposure up 

there. Nobody is going to do a bioassay. 

Maybe they just had one done because they are 

only on an annual bioassay. So, it is almost 

twelve months down the road before anybody 

knows they got exposed. And this is hands-on 

stuff I have seen time after time. 

 And I don't care what SOPs read. 

The bottom line is these people get exposed. 

A lot of times, it is not caught until quite a 

bit down the road, if it is ever caught. A 

lot of times, it is not even discovered until 

they start demolishing or cleaning up that 

building. My God, these electrical trays or 

where the bolts are holding the trays to the 

roof or the walls, there is loose 

contamination behind there. Well, you didn't 

really care about it. Your job was to get it 

cleaned up, get back in business again. 

 But a lot of these people, we have 

had it, and it is well documented that we have 

 numerous instances in Los Alamos, I can't 
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talk about Mound, where people have gone in 

there years later. And they go, hey, those 

guys were in there last week? Yes. Well, 

guess what? We don't know how many people 

have been exposed because when these guys 

starting monitoring themselves, they were all 

craft up. This is real world stuff. 

 This is not theoretical. This does happen 

where these people get into these situations. 

 What? 

 MR. STEWART: I have covered some 

of those jobs. 

 MEMBER SCHOFIELD: Yes. 

 DR. ULSH: So let me talk about the 

real world situation at Mound as related to me 

by people, the health business systems in 

charge of the building who was actually in the 

stuff by other former workers who actually 

worked in SM building. 

 Did exposures happen? Absolutely. 

 Did contamination incidents happen in SM? 

Absolutely. Did contamination incidents 
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happen where perhaps you might not have 

expected? Yes, for sure. Did people 

sometimes get sent into areas where they 

weren't expected to be contaminated but they 

got contaminated? Yes, absolutely. And those 

people were on bioassay programs. So the 

question is not did people get exposed. We 

all agree that they, in some instances, some 

people got exposed. The question is, can we 

do dose reconstruction on them? And the 

answer is yes. 

 Now maybe the bioassay wasn't done 

the following week. Maybe it wasn't done the 

following month but it was done. If you went 

into SM Building, you were on plutonium-238 

bioassay. And we have methods to estimate. I 

mean, let's say a person goes through and they 

have negative bioassays, six months later, 

they come up with a positive bioassay. We can 

do a dose reconstruction in that situation. 

Even if they got exposed the day after their 

last negative bioassay. We just don't have 
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situations where people got exposures to 

plutonium-238 and we can't do a dose 

reconstruction at Mound. We don't have it. 

 MR. STEWART: That situation 

doesn't arise. 

 MS. ROBERTSON-DeMERS: Can I ask a 

question? I am jumping ahead. 

 MR. STEWART: Can you speak up, 

please? 

 MS. ROBERTSON-DeMERS: I am jumping 

ahead here but what is the status of the 

roadmap? Is there a classified version? 

 CHAIR BEACH: Can we hold that, 

Kathy, for another -- In keeping with our 

schedule, which I am going to try really hard 

to do, this is Josie, what I would like to do 

is get last minute inputs. 

 I would like to request that NIOSH 

respond to SC&A's white paper in detail, 

answering the many questions. For example, on 

page 25 of the white paper, one of the 

questions requests that NIOSH demonstrate the 
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procedure for assigning internal dose to 

individuals who were exposed to multiple 

alpha-emitters during the time period when 

gross alpha analysis was implemented at Mound. 

 That is one question that you will find on 

page 25. The other one is to demonstrate how 

to reconstruct dose internal exposures from 

gamma and beta emitters in the absence of 

gross gamma and beta results. 

 Also on page 26 of the white paper, 

request NIOSH ORAU to retrieve the urinalysis 

log book data for potential evaluation of 

exposures to special tritium compounds. What 

I would like to see is that all of the 

questions, there is many of them buried within 

that white paper, that they are answered in a 

timely manner and I would like to throw out 

30 days to get that back into our hands, so 

that we can move forward with this issue for 

our next work group meeting. I am seeing how 

much time. 

 DR. ULSH: Okay, we are going to 
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need more time, I think. And you have to 

build into the schedule the time it is going 

to take not just for the normal reviews but we 

also have to have it reviewed by DOE for 

security plans. 

 CHAIR BEACH: Correct. 

 DR. ULSH: That has to be built 

into the schedule. 

 CHAIR BEACH: You are right. 

 DR. ULSH: So, would you give us 

60? 

 CHAIR BEACH: Sixty days? 

 DR. ULSH: Forty-five? What will 

you give us? 

 CHAIR BEACH: Well, -- 

 DR. ULSH: We will start on it 

tomorrow. 

 CHAIR BEACH: Okay. 

 DR. ULSH: Or no -- Friday. 

 CHAIR BEACH: I just -- we are 

going to have this come up many times in the 

next two days. So overall, I would like to 
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strive for something in the next couple of 

months to get papers out and back into DOE's 

hands and then back to the work group so that 

we can continue to move forward with the 

process. 

 So, if it takes 60 days, -- 

 DR. ULSH: Well, six weeks? I'm 

looking at Don. I'm putting him on the spot. 

 MR. STEWART: Well yes, we can talk 

about my deliverables for the next 60 days 

after that. 

 DR. ULSH: All right. Josie, how 

about -- we understand your desire to get this 

done quickly. We will put our heads together 

after the meeting and send an email -- 

 CHAIR BEACH: Okay. 

 DR. ULSH: -- to you and the other 

working group members proposing it. 

 CHAIR BEACH: And by the end of 

tomorrow, hopefully maybe we can have some 

idea. 

 DR. ULSH: Yes. 
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 CHAIR BEACH: Because we will have 

many of these in the next two days that we are 

going to be struggling for time periods on. 

So, maybe -- 

 DR. NETON: I think it is fair to 

allow us to talk offline. 

 CHAIR BEACH: Oh, I agree. I 

agree. No, that's all right. 

 DR. NETON: Because we are 

balancing a lot of different working groups. 

 CHAIR BEACH: And that is why I 

say, maybe at the close of tomorrow's work 

group, we will be able to kind of come into 

some kind of action items and time frames. I 

mean, that is completely viable to me. 

 So, is there any last comments? 

Paul, are you still on the line? Paul Ziemer? 

 MR. KATZ: Paul? Paul, are you 

still with us on the line? 

 MEMBER ZIEMER: Yes, I had to push 

*6 here to get back. Yes, I am still on the 

line. 
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 CHAIR BEACH: Did you have any 

comments on this? I am just trying to push it 

ahead so that we can take a break here. 

 MEMBER ZIEMER: No, I agree. They 

need to move ahead. I understand the need for 

the reviews and so on. So, I think their 45 

day target is good but it may take a little 

longer, based on the additional reviews 

needed. 

 CHAIR BEACH: Yes, and Paul, I 

wasn't just talking about the time. If there 

was any other additional comments you had just 

for this issue. 

 MEMBER ZIEMER: No, I don't have 

any additional comments. I think we have 

heard a lot of these issues before and a lot 

of the responses before. So, they keep 

reemerging. 

 CHAIR BEACH: Yes. 

 MEMBER ZIEMER: But I agree. A 

detailed response from NIOSH will be helpful 

so you can put some of these things to bed one 
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way or another. 

 CHAIR BEACH: Okay, thanks, Paul. 

 MR. STEWART: Yes, just one thing. 

 We have gone back and forth about this a 

number of times. And I just wanted to say 

that I am grateful to see that the issues are 

here. I may have spoken out of ignorance in 

the past as to what the issues really were. 

And this paper goes a long way to resolving 

that. So, I just wanted to thank you. 

 MR. FITZGERALD: Yes, I don't think 

it really changed so much as we just wanted to 

be more specific. 

 MR. STEWART: Yes, there is more 

detail. 

 MEMBER CLAWSON: I have got just 

one more question. And this is getting, and I 

realize bioassay is a last line of defense but 

in some of the worker interviewers and stuff 

like that, they made the comment that I heard 

that they may have not been on the bioassay 

program but people in their group were in the 
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bioassay and were covered. So, they were 

saying that you know, they were meeting the 

requirements of what they had in the bioassay 

program. 

 Have you seen, and this came from 

some Mound interviews, you know, that people 

that they were working with were on the 

bioassay. So technically they were covered 

that way. And this is where, you know, I know 

bioassay is the last line of defense and 

everything else like that but seeing some of 

this and a lot of the data to me is very 

difficult to sift through and so forth like 

that. 

 MR. CHEW: Usually in that 

situation, Brad, they are people who were not 

exposed to like an incident but was following 

 the routine just making sure that your 

program was complete. And then you certainly 

bioassay people with the highest potentials. 

Okay? And then the people who had the low 

potentials said yes, I was covered by that 
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particular group. Usually, there are no 

choices. 

 MEMBER CLAWSON: Because where I 

saw this mainly was in the maintenance 

departments, electricians, so forth and stuff 

like that. Because a lot of those rolled 

throughout the whole thing. So it was kind of 

like a spot sample to be -- 

 The other thing I found very 

interesting and we see this complex-wide, 

Mound is no exception, is that they built one 

building on top of another building that was 

designed for this but now became this. And we 

saw a lot of this in the ventilation systems 

and the instrumentation lines and so forth 

like that. And this is what was interesting 

to me about Mound. The T Building, all these 

other -- it was like they were stacked one on 

top of another and we got into some issues 

down the road with some cracks and so forth 

like that. 

 But this is what is somewhat of 
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interest to me is that they said that 

everything was so cut and dry but these 

buildings were being used for things and glove 

boxes, some of the earlier glove boxes were 

not designed to really be doing what they were 

supposed to be doing and this is some of the 

people that were hands on. Yes, we made do 

with what we had. 

 And that is where part of my issue 

comes into this. And sure they monitored 

things and everything else like that. I just 

wanted to say -- 

 MR. STEWART: Sure, the area will 

have been monitored and have access 

requirements to go in. It might have been an 

contamination area. It might have been a high 

contamination area. And the better the glove 

box was at maintaining the separation is going 

to determine a level of control where you can 

go in there. 

 And on the bioassay, certainly I 

have witnessed operations where I was not on 
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bioassay but the technicians that I was 

supervising were on bioassay. And though it 

didn't happen while I was there, everybody in 

the room came out and got a special because we 

had a lost containment. 

 So yes, okay, you know, Bob was an 

electrician. He wasn't in there. He was in 

there when this thing happened. Send them all 

downtown. And that is the way we did it. 

 MEMBER CLAWSON: And this is in the 

later years. I am looking a lot more towards 

earlier years up until the '80s. I know that, 

we understand our radcon program from '85 on 

has made leaps and bounds. Because really, to 

tell you the truth, we did not know a lot of 

the daughter products, a lot of the things, a 

lot of the potential that we were doing. I am 

saying this because we are all on a learning 

curve on this whole thing in the earlier 

years. 

 MR. CHEW: Also, instrumentation 

was developed to a higher degree of 
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sophistications so you can do that, too. And 

that doesn't necessarily mean that when you 

did the gross alpha on Pu-238 did not bound 

with the most contributing isotope. You know, 

we have to take a look at that. 

 MEMBER CLAWSON: Okay, thanks, 

Josie. 

 CHAIR BEACH: Anything else? 

 MR. STEWART: I had just one more 

question. As far as the thorium solubility 

types go, is this a Mound-specific issue or is 

this something that we need to look at on a 

complex-wide basis? 

 MR. CHEW: It was raised as a 

Mound-specific. 

 MS. ROBERTSON-DeMERS: Both. 

 DR. NETON: I'm not sure what the 

issue is here. I mean, thorium has different 

solubility classes like any other 

radionuclide. It is hard to detect in urine, 

which raises the missed dose quite a bit but 

it still is calculable. There is a number 
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that can be calculated if you have a urine 

sample and it has non-detectible thorium in 

the urine, albeit it is much larger than for 

plutonium or for uranium. 

 I am not sure what the issue is 

here. Is it that you come to implausibly high 

doses? Because the issues is if you come with 

a very high dose, it would probably compensate 

 most lung cancers but most systemic organs, 

even with that high missed dose, would not put 

a PC over 50 percent for most of the soft 

tissues, the bladder, the pancreas, the GI 

tract, kidneys. So, it is a usable technique 

for us. I am not sure what the issue is here. 

 MS. ROBERTSON-DeMERS: It gets back 

to issues that we dealt with at Y-12 and the 

thorium processing. And I wasn't involved in 

the later portion of that. And the 

inadequacies of bioassay versus air sampling -

- 

 DR. NETON: Well that is a 

different issue. But I mean, if we have 
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bioassay samples for thorium, I am of the 

opinion and the NIOSH is of the opinion if we 

can use them to reconstruct internal doses. 

 MS. ROBERTSON-DeMERS: You have 

them for some periods. 

 DR. NETON: That's agreed. Now, if 

there is something, if there is another issue 

regarding representativeness of the bioassay 

program, then we can talk about that because 

that is a Mound site-specific issue. 

 MS. ROBERTSON-DeMERS: And the 

other thing is you need to look at your 

decision levels and so on and so forth because 

there is some highly insoluble thorium. 

 DR. NETON: There is S-type 

thorium. I am not aware of super-S thorium. 

I mean, if you are saying there is, then I 

would like to see some evidence. 

 MS. ROBERTSON-DeMERS: Well that 

what the paper that was generated by James and 

Weaver says is that there was YY in the ICRP-3 

terminology thorium at Mound. 
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 DR. NETON: I would like to see 

that. I have not seen it. And if there is, 

we can certainly deal with it in some way or 

another, I am sure. 

 MR. LaBONE: Can I make a comment 

on that? This is Tom LaBone. 

 On this, the solubility of the 

thorium from the Weaver and James paper, if 

you go back and look at that, they basically 

followed the dissolution of that material out 

for 75 days. And I would propose to you that 

you can't estimate 30,000 day half-lives from 

a 75 day experiment. 

 And I think that data is good to 

give us an idea of the initially soluble 

portion but I don't think it is very valuable 

as far as estimating you know, super YY or 

something like that. 

 So that is just again, after 

looking at the original report, that was what 

I came away with. And I just wanted to add 

that in, since the topic came up. 
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 DR. NETON: Thanks, Tom. That was 

good. I had forgotten about that. 

 CHAIR BEACH: I think it is break 

time. How much time do we normally take, ten, 

fifteen? 

 MR. KATZ: Whatever you -- 

 CHAIR BEACH: How about if we 

reconvene at 11:15? 

 MR. KATZ: Okay, 11:15 for folks on 

the phone. I am not breaking the line, I am 

just putting you on mute. 

 (Whereupon, the above-entitled 

matter went off the record at 11:02 a.m. and 

resumed at 11:17 a.m.) 

 MR. KATZ: Okay, this is the Mound 

Working Group. We are coming back on line. 

We had a short break. And I think Joe is 

going to present next. 

 CHAIR BEACH: Well, actually we are 

going to move on to integrity completeness of 

internal dose records issues, 12 and 13. And 

Joe are you -- 
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 MR. FITZGERALD: Yes. Yes. 

 CHAIR BEACH: Joe, you are. Okay, 

I had Bob down. 

 MR. FITZGERALD: I am just going to 

say, just to tee it off, this is the 

continuation of our review on the reliability 

question. We did split this thing into two 

parts. This is the looking at integrity and 

completeness of the data. 

 And our response to the ER, and 

again, the ER laid out a picture of where 

there was certainly complete records or 

relatively complete records and sufficient 

process descriptions, source terms to enable 

dose reconstruction. And our concern was that 

here was a need for a validation between the 

electronic records and the source information. 

 Often times the paper records, whatever was 

the source information, be electronic just to 

demonstrate that in fact the electronic 

database is valid and one that can be relied 

on. And this is something we have done, I 
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think, with every SEC site. 

 That was a comment that we felt 

needed to be pursued. It wasn't specifically 

addressed in the ER. And we also cited in the 

white paper, or actually comments from last 

year as well, that we felt there were some 

short comings in terms of the completeness of 

the databases that would be relied upon. And 

 again, as with the other issue 11, we are 

looking for clarifications, primarily because 

I think there were, since it wasn't really 

addressed for focused on in the ER 

specifically, we felt this is the step that 

needed to be taken. We need to at least ask 

the questions to get answers on it. 

 I think the NIOSH response, I am 

being very brief on this, was to disagree with 

the concerns that we had expressed. And at 

the time, I think, the comment was we ought to 

go back and take a look at the MJW QA 

documentation of what we have done in the, I 

think it was the early '90s and that process. 
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 And also revisit the Meyer document we had 

reviewed but we certainly felt that okay, we 

can go back and take a look at that. 

 And at the time, the work group, 

this is going back I think to last summer, 

charged SC&A with doing a detailed review of 

both the MJW QA documentation, as well as the 

Meyer document, which we have. Now, that was 

a separate white paper, relatively recent, I 

think 15 or 16 pages. But this focused on the 

Meyer document and the MJW review. 

 And I think in general, you know, 

we found, you know, the Myer document does 

address I think a lot of the mainstream 

nuclides. We did find that it was incomplete 

in terms of addressing some of the so-called 

exotic or other nuclides. That was kind of 

the bottom line. There is more details in the 

white paper. 

 And relative to the MJW document, 

again, I think the QA process they followed is 

pretty thorough but we found some gaps that we 
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identified in that piece as well. So that is 

kind of how we addressed that particular task 

by the work group. And you have the white 

paper on that. 

 We also did a sampling of the 

bioassay, I guess the worker claims, the head 

bioassays. We picked 25 individuals. We 

picked a small sample. Again, we didn't want 

to get into a large-scale sampling but just 

enough that we could get a picture of how the 

various nuclides were addressed, in terms of 

potential exposures and what bioassays were 

available to be used in dose reconstructions. 

 We looked at 25 claims. 

 That is addressed in terms of 

general conclusions in the white paper. We 

have the specifics on the individual claims 

that we used and we are providing that 

separate because that has identified Privacy 

Act information, providing that separately to 

NIOSH so they can basically see the details on 

the 25 workers that we chose. 
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 And I think, without going into 

details, I will leave it to Bob to get into 

those details but we certainly did use that 

sample to highlight some questions that we 

have and some of them have already been raised 

about some professions about how one addresses 

the bioassay databases and how they would be 

used in dose reconstruction and whether or not 

it supplies a complete picture. 

 The other thing we did, we reviewed 

the July version of the roadmap. And I 

understand that since then instances have 

been added and it has been refined to a later 

edition. But I think a lot of it was in the 

July version that was useful. And we used 

that as well as the available bioassay 

databases to just look at completeness, pretty 

much in the same vein as Mel and his crew 

looked at, you know, whether you could map the 

nuclides and the locations and the timeframes 

with a bioassay technology. 

 We went further beyond the 
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technology to see whether or not the data, in 

fact, whether there were bioassay results 

available for certain time periods and certain 

locations. So it was both the technology 

being available but also what the status of 

the results were, what kind of data, in fact, 

were available as far as we could tell. 

 And there are some, I think, some 

fairly useful tables in the white paper that 

deal with both questions of the availability 

of bioassay, as well as the completeness of 

the data. I think table I and table II, I 

think are the key tables in that document. 

 That is pretty much where we are. 

So there are two white papers that have been 

presented on this issue. And Bob, you can -- 

 DR. BISTLINE: Okay. 

 MR. FITZGERALD: -- get into the 

details of the findings a bit more. Those are 

thumbnails. 

 DR. BISTLINE: Yes. Joe said these 

papers really overlap a great deal in some 
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respects in dealing with the reliability of 

the data. And some of the points that are 

brought out in the paper on completeness are 

some of the same basic points that were 

brought out in the adequacy that we just have 

been discussing for the last couple of hours. 

 So rather than getting into a lot of the 

detail that we have already had some 

discussion on, I think we will consider going 

into more of the completeness of the data and 

the review of the databases that we have done. 

 And on some of the points that we 

talked about before, again, it is reiterated 

here that NIOSH should demonstrate the 

feasibility of performing dose reconstruction 

to unmonitored potentially exposed workers and 

particularly NIOSH should demonstrate how they 

will reconstruct internal exposures from gamma 

and beta emitters in the absence of gross 

gamma and beta monitoring data. 

 SC&A assessment of plutonium urine 

bioassay data indicates that the electronic 
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file available in the Mound environmental 

safety and health system or MESH is complete 

and consistent with the raw bioassay records 

available for this evaluation with a few 

exceptions. So that data does appear to be 

pretty complete and very useful. 

 In the case of the polonium 

urinalysis data, a discrepancy was noted 

regarding the number of records in the POLON 

data file in MESH and the PORECON file, where 

the PORECON file contains several thousand 

more records than the POLON. The evaluation 

of POLON data to work on and the individual 

exposure records indicated that the three 

sources were not all inclusive of the data. 

And early fecal sample data and in-vitro 

monitoring data are incomplete in the 

electronic and individual exposure records. 

However, other sources of this information 

exist in log books and these data could be 

important in the assessment of high-fired 

oxide intakes or incidences. 
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 Earlier, bioassay data for other 

radionuclides can be obtained from data sets 

complied by the MJW during the pre-1989 dose 

reconstruction effort. And the number of 

sources required to compile a complete 

internal monitoring history can be numerous 

and may not be available in MESH and/or the 

DOE individual exposure file for a claimant. 

 And one of the other issues that I 

will be addressing here some is the issue that 

the petition raises the issue of Mound plant 

employee health records being removed from 

Mound and buried in Los Alamos, New Mexico and 

the Nevada test site. Records buried at NTS 

were imaged into a searchable classified 

records database and imaged copies are 

available through DOE Albuquerque and the 

office of science and technical information. 

So, that addresses that issue or we will talk 

about that issue. 

 Joe mentioned that there are a 

couple of applicable tables that are 
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important, we felt, for NIOSH to look at, 

Table 1 and Table 2 in the report. And if you 

 notice in that column, in those columns, 

years with bioassay data and methods proposed 

by ORAU to reconstruct internal doses, that 

there are numerous time periods for some of 

these radioisotopes where there is no data 

found and no methods proposed for the years 

that some of these specific isotopes' data, no 

method proposed prior to years with some of 

these isotope-specific data. 

 And so those tables are important 

to take a look at. And Table 2 is the 

internal dosimetry data for other 

radionuclides in Mound prior to 1990. And 

again, it breaks it out by 1960s, '70s, '80s 

and the number of workers sampled and the 

comments on the data that was found. 

 There is limited other radionuclide 

data in the 1960s, '70s and '80s, which 

typically do not cover all years when 

radionuclides were handled at Mound. 
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 In the case of strontium-90 and 

yttrium-90, fission products, and radio 

tracers, no internal monitoring data has been 

located to date. Radium-226 bioassay results 

were available for the SEC period; however, 

they were not available from March first of 

1959 through December 31st of 1989. 

 The results labeled as actinium-227 

were not available from March 1, 1959 through 

December 31, 1989. However, thorium-227 and 

actinium-227 daughter were available starting 

in 1989. And I think, Brad, you touched on 

that issue during our discussion of the 

adequacy but it is reiterated in this 

completeness paper. 

 In summary, SC&A identified several 

concerns related to the appropriateness of the 

bioassay sampling program at the Mound site 

based on the review of the ORAU 2008 paper on 

major isotopes process material and bioassay 

roadmaps, and the availability of bioassay 

data from both electronic and hard copy. 
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 The actual collection of bioassay 

data does not correspond to the years when 

materials were handled at the site, indicating 

that although bioassay procedures may have 

been available, they were not implemented for 

the entire period of potential exposure. 

NIOSH has not explained how they will address 

these gaps in monitoring data. 

 And in the absence of isotopespecific bioassay, NIOSH is defaulting to 

gross alpha analysis, which they have not 

demonstrated is inclusive of all alphaemitting radionuclides at Mound. And again, 

this gets back to the gross alpha issue that 

we were talking about before the break some. 

 And in the absence of isotopespecific bioassay data for beta gamma 

emitters, NIOSH is defaulting to the gross 

beta results, which have not been located or 

to ratios derived from source terms and NIOSH 

has not proposed a method for assessing dose 

from these radionuclides where they compose a 
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majority of all of the source terms. 

 And for some radionuclides handled 

at Mound, such as iron-55, iron-59, iodine131, strontium-90, prior to 1993, no proposed 

bioassay method has been provided by NIOSH nor 

does the roadmap suggest a surrogate approach. 

 And approach for identifying bioassay gaps 

for potentially exposed workers should be 

developed and a determination made on whether 

feasible methodologies can be developed to 

account for these gaps. 

 As far as data comparison, as a 

means of confirming the validity of NIOSH's 

position on this matter, SC&A performed a 

comparison between primary and primary 

internal monitoring records, as Joe mentioned, 

and bioassay cards available, log books, and 

log data sheets or 24-hour urine reports and 

electronic urinalysis data for plutonium and 

polonium. A complete list of available data 

sources can be found in Appendix I. 

 The goal was to characterize the 
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integrity of the data in MESH, which is used 

as a principle source of the internal 

monitoring in the form of printout found in 

hard copy records and to identify systemic 

gaps that may exist in the data provided. 

 And as Joe mentioned, 25 

individuals were identified available to work 

in the working group and that information will 

be made available. The goal in the selection 

of the 25 individuals chosen for evaluation 

was to choose claimants who worked at Mound 

through a majority of the SEC petition period 

and throughout the site on a variety of 

projects. And this information was determined 

from data available in the NOCTS. 

 In the evaluation of the 25 

subjects for internal data completeness, it 

became apparent that compiling an individual's 

complete internal monitoring record required 

pulling data from multiple sources, some of 

which are not readily available in the 

electronic or hard copy files. This raises 
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questions about how data are compiled for use 

in dose reconstruction. And if a person goes 

back to Appendix 2, it gets into some of this. 

 So we have some reservations with regard to 

completeness. 

 In the SC&A sampling evaluation of 

25 former Mound employees for internal data 

completeness, it became apparent that the 

number of sources required to complete the 

internal monitoring history can be numerous 

and may not be available in electronic form. 

Given the circumstances, SC&A recommends that 

the working group request further validation 

regarding NIOSH's broad support for the 

completeness of bioassay records for dose 

reconstruction. 

 And Appendix III of this report, 

SC&A recommends to the working group 

additional completeness evaluations and/or 

records of retrieval efforts which further 

demonstrates whether data are available and 

can be accurately interpreted for dose 
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reconstruction with sufficient accuracy at the 

very least. NIOSH should be requested to 

demonstrate how they can effectively compile 

all internal monitoring data, including the 

data not available in DOE individual exposure 

record and the MESH files and demonstrate how 

this data will be used in dose reconstruction. 

 I would like to also get into a 

little bit on the issue of the offsite 

records. There was considerable time spent 

looking at the issue of the buried records, 

which we discussed previously and at previous 

times. The SEC raised concerns about the 

shipment of those records to Los Alamos and 

NTS. The issue becomes whether the buried 

records contain dose reconstruction data that 

are not available elsewhere and are critical 

to conducting dose reconstruction with 

sufficient accuracy. 

 And the evaluation report indicated 

that three former workers involved in the 

records transfer were interviewed and 
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extensive documentation related to shipment of 

records has been retrieved and reviewed, based 

on the information collected and reviewed. 

The ER indicates that the records did not 

contain data related to employee health 

records that would prevent the reconstruction 

of doses with sufficient accuracy. 

 And SC&A has expressed concern that 

the buried records may contain information 

relevant to a dose reconstruction that is not 

duplicated elsewhere. And this would include 

personnel monitoring, environmental 

monitoring, field radiological control 

measurements, incidences and health physics 

issues. 

 NIOSH has requested further 

clarification from SC&A regarding the basis of 

this conclusion, and in this report we have 

gone into looking at some of these issues to 

try to clarify this for you to respond to. 

And Mound did send records, there are 1639 

potentially contaminated laboratory notebooks, 
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and these records contained financial data, 

scientific and technical reports, research 

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safety analysis reports, litigation records, 

and classified drawings out to NTS. And SC&A 

recommends to the working group that an 

inventory of the imaged records be reviewed 

for potential relevance to the records of dose 

reconstruction and be declassified and 

retrieved, if possible, such as monitoring 

records that may be involved in some of that. 

 A shipment of 485 boxes of inactive 

classified contaminated or potentially 

contaminated records was sent to Los Alamos. 

And in 1998, 43 of the 458 boxes were returned 

to Mound from LANL in support of the pre-1989 

dose reconstruction project. And this is 

something just reiterated here as a point that 

it has been discussed before. 

 But the point that I think is 

important is that in the inventories of these 

records, if you look in Table 3 of the 
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identified contents of the Mound documents 

recovered by MJW, you will find that there is 

a great deal of information dealing with urine 

analysis data, incidence logs, and, if I 

remember right, I think there were some, yes, 

there was nose swipes and polonium urine 

analysis data. 

 And the list appears to contradict 

the assumptions of NIOSH and the Mound records 

manager that no primary personnel records were 

present in the collection and that this 

classified collection by its general nature 

would not be expected to contain the kind of 

records described by SC&A. Although this 

particular subset of the 458 boxes was 

retrieved, imaged, and indexed, the questions 

raised by this review include the following. 

 On what basis were these 43 boxes 

selected? To what extent do they represent 

random sampling of a larger collection, as 

opposed to a complete targeted survey of all 

boxes that some likelihood of relevance to the 
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dose reconstruction? Did the retrieved data 

contain new information not duplicated 

elsewhere? And does such unique information, 

if present, contribute significantly to 

radiological matters influencing dose 

reconstruction. 

 Lab books were part of the burial, 

which may include information on personal 

dosimetry. However, nothing unique because 

that information in the notebook is not 

primary information; any bioassay or dosimetry 

records should be in the individual's 

personnel file. This is the response which 

NIOSH has provided and the MJW health 

physicist involved in the LANL records review 

in March of 1998 stated that -- this 

individual was 99 percent sure that no 

bioassay data were overlooked in the 

retrieval. 

 But it was found that, in looking 

at the data though, that two individuals had 

data in the polonium log book records shipped 
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to LANL that were found missing from the 

polonium database, three individuals had data 

in the polonium log book records shipped to 

LANL that were collected prior to the earliest 

data for the individuals in the polonium 

database, and the fecal data identified in 

retrieved LANL logbooks were not available in 

other record sources at Mound. 

 So the conclusion made attempts to 

contradict the assumption of the ER that the 

records buried in LANL were not found to 

contain primary employees' records. And there 

is a list of issues here that are brought out 

in this white paper. 

 In the ER NIOSH references 

interviews conducted with three former 

workers, two former record managers, and a 

researcher, and NIOSH makes no reference to an 

additional interview conducted with a former 

Mound health physics person who had an 

opportunity to review the contents of 26 boxes 

prior to their shipment to LANL. 
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 In this interview, NIOSH was 

provided with a brief inventory compiled by 

the health physicist indicating that 

environmental monitoring, personnel exposure, 

incident, and other information was included 

in this subset and reviewed. In fact, this 

information is available in the site research 

database within the Mound records transfer 

history by Long in 2007. 

 And SC&A provided the list of boxes 

to OSTI to determine if any of these records 

were available in imaged form. The column in 

Table 4 indicates whether or not images of the 

boxes' contents were located in OSTI. Of the 

26 boxes reviewed prior to shipment, OSTI was 

able to locate images for records from 13 of 

the 26 boxes. And the remaining 13 boxes that 

are not available to OSTI are presumed to be 

buried at LANL. This further corroborates the 

fact that these box numbers are not included 

in that review. 

 And so you can see in Table 4, 
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there is a listing of the records and bioassay 

procedures for actinium, health physics 

personnel monitoring data, procedure 

development for urine and fecal analysis, 

urine analysis spikes, and radium analysis 

procedures are some of the kinds of records 

that were in there. 

 In summary, the petition raises the 

issue of Mound plant employee health records 

being removed from Mound and buried in Los 

Alamos, New Mexico and NTS. Records buried in 

NTS were imaged into the searchable classified 

database and imaged copies are available 

through DOE. There is no indication in the ER 

that these documents were screened for records 

pertinent to the SEC petition. And the 

records sent to LANL were never thoroughly 

inventoried prior to their disposal except for 

a small fraction of the 458 boxes that were 

inventoried in some detail. 

 And these reviews of the records 

indicate that the radiological data include 
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urine analysis, fecal, and monitoring 

incidence, animal studies and procedure 

development. The ER does not provide an 

adequate description of how NIOSH verified 

these buried records, particularly personnel 

monitoring records were available elsewhere. 

And the ER does not document any verification 

that classified monitoring data within the 

LANL record set and other classified record 

sets were captured in unclassified sources. 

 So with the limited information 

available regarding the contents of the buried 

records, their relevance to dose 

reconstruction and their relevance to the 

development of the coworker or bounding 

models, whether they are critical to 

conducting dose reconstruction with sufficient 

accuracy is indeterminate at this point. 

 MR. FITZGERALD: I don't want to 

run too tight on time. 

 DR. ULSH: Oh, 12:30. Right, okay. 

 MR. FITZGERALD: I might add for 
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those on the phone, these are fairly detailed 

50, 60 page white papers. So we are putting 

Brant at a little disadvantage. But he has 

had them for a few weeks. 

 DR. BISTLINE: He's a fast reader. 

 (Laughter.) 

 DR. ULSH: Again, we will be 

issuing a detailed response to this report. 

And just like our discussion earlier this 

morning, there are a lot of issues laid out on 

the table here and I am not sure that we are 

going to be able to address all of them. 

 But we are looking forward to 

looking at the data for the 25 individuals 

that you reviewed. I know that Kathy is in 

the process of getting that data for us. So 

we will take a good hard look at that. 

 With regard to the buried records 

issue again, I knew that as soon as this was 

in the evaluation report, as soon as I saw it 

in there, I knew that we would be dealing with 

it over and over again. We will, of course, 
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look at what it's in your report, but I can 

already give you a preview of what is going to 

happen, where we are going to wind up. We 

interviewed the people who exist with the most 

relevant hands-on information that is 

available. And that is the records manager 

who was involved in the transfer of these 

records, and also the MJW health physicist who 

happens to be on the line. Right, Liz? 

 MS. BRACKETT: Yes, I am. 

 DR. ULSH: Hold on. It is hard to 

hear you, Liz. Can you speak up again? 

 MR. KATZ: Go ahead again, Liz. 

 MS. BRACKETT: I am speaking 

directly into my hand set. 

 MR. KATZ: No, no. The volume was 

turned down here. It is my fault. 

 MS. BRACKETT: Oh, okay. 

 DR. ULSH: So Liz, I will give you 

a crack at it in just a second. 

 MS. BRACKETT: Okay. 

 DR. ULSH: Liz is on the ORAU team, 
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and she was the health physicist for MJW who 

went down and reviewed these records. So she 

can talk a little bit about how she chose the 

records and what she found. 

 These are the people who are 

directly involved with this issue. And we 

have interviewed them. We have told you what 

they said. And at the end of the day, what we 

are going to have is simply a weight of the 

evidence approach. We will address the issues 

 that you brought up about some of the records 

that were in there. But the urinalysis and 

other records that you mentioned were not, in 

most cases, far and away most cases, were not 

unique, where not the primary bioassay data. 

 So at the end of the day, it is 

going to be the word of the people who were 

involved in this versus speculation about what 

might be in those boxes. That is just where 

we are going to wind up. There is no more 

information short of getting a back hoe and 

going down there and digging these things up -
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intercede. I mean, I agree this is a tough 

one just because you are dealing with 

recollections and what have you. But is there 

a pathway where you could validate what isn't 

at OSTI that was scanned and stored there? I 

seem to think that was -- the only thing that 

we could come up with was just to validate the 

essential. And what were the records that 

ended up in those locations or collections 

from that, the so-called buried collection? I 

can't recall if that was done. 

 I know that we discussed that. 

That was the only thing I could see other than 

that you were saying, based on recollections 

and whatnot. 

 DR. ULSH: Liz, do you want to jump 

in and make your comments? 

 MS. BRACKETT: As you already said, 

I am the health physicist that is mentioned in 

here. And then there are some quotes from MJW 
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documents that are misrepresented here in 

their application in actually several spots. 

The rebuttal, to my recollection, I mean, the 

99 percent sure, that was just my feeling that 

we had found all of the polonium data. That 

wasn't necessarily saying that it was from Los 

Alamos or that we looked at everything from 

Los Alamos. But the quotes that follow are 

from the Phase I interim report from MJW. 

This is not the final report and, in fact, all 

of these paragraphs that discuss records 

stored at Los Alamos are justification for 

going back to Los Alamos and getting records. 

 So this predates the looking, the review of 

most of the records. 

 DR. ULSH: Liz, where are we 

talking about? 

 MS. BRACKETT: -- is that we are 

contradicting the ER. That in fact is not 

correct. 

 DR. ULSH: Liz, the quotes that you 

are talking about, where are they in the white 
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paper? 

 MS. BRACKETT: Page 28 of the data 

completeness document. 

 MR. FITZGERALD: And Liz, is there 

something that you are saying this predated 

the retrieval. Is there something that was 

more current that followed? 

 MS. BRACKETT: There is a Phase I 

final report which I would like to quote from. 

 MR. FITZGERALD: Okay. 

 MS. BRACKETT: Well Brant said that 

I would speak to how I chose records. I did 

not collect the records to be reviewed. I 

don't recall how that was done. I am sure 

that Mound was involved because they were the 

ones who shipped the records. I had no 

knowledge. I don't recall if I reviewed any 

inventories or what the process was at the 

time. So I am afraid I can't elaborate on 

that any more. 

 But if I go to the Phase I final 

report, we did review a number of log books 
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returned from Los Alamos, and they sent us 

copies. They didn't necessarily return 

everything. There was, I think, an issue with 

some of them being potentially contaminated. 

So rather than ship them back, they made 

copies. 

 And in addition to reviewing those, 

we reviewed microfiche data, microfilm and 

microfiche that was located at Mound and had 

always been there, had not been shipped. And 

the Phase I final report says that we have 

reviewed over 5,300 historical log books 

either in hard copy or on microfilm. And it 

says what was discovered during the review of 

the logbooks or microfilm at Mound was that 

all of the Mound logbook data retrieved from 

Los Alamos in March 1998 and requested hard 

copy material returned from Los Alamos in 2000 

was recorded on these microfilms. So this 

says we found absolutely no new data coming 

back from Los Alamos. All of it was still 

onsite at Mound. 
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categorically addressing, I think, the heart 

of the issue. You are saying quite apart from 

some of these quotes, you can attest that all 

of the relevant -- 

 MS. BRACKETT: I am not personally 

attesting. I am reading the Mound final 

report. The MJW Mound -- 

 MR. FITZGERALD: Okay, you are 

saying MJW is attesting to the completeness. 

 MS. BRACKETT: I am saying that is 

what was written in the report ten years ago. 

 That is what the report says, that all of the 

log book data that was retrieved from Los 

Alamos was found in microfilm. So I would 

assume that that is correct. That wouldn't 

have been written if it wasn't an accurate 

statement. 

 DR. ULSH: Now, of course, you can 

always speculate, well -- 

 MS. BRACKETT: Yes, we didn't 

review everything. Obviously, we didn't 
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review all of the books. So I am not saying 

that -- I am not categorically saying that 

everything that was at Los Alamos was at 

Mound. But what we looked at, all the data 

that we looked at, we found again in microfilm 

on the Mound site. It was in the basement of 

A Building, I think. It was in the classified 

record section where there were lots of 

microfilms in a safe there. 

 MR. FITZGERALD: Yes, so you are a 

source of validation, though, since you had 

actually looked at the Los Alamos data and 

looked at the later microfiche. 

 MS. BRACKETT: Yes. 

 DR. ULSH: So what we can say is 

the weight of the evidence being 5,000 log 

books that were looked at were verified to be 

present on fiche at the Mound site. Can we 

prove to you that there is another 5,000 

buried in the holes that were not there? No, 

and we are never going to be able to. But 

there is no evidence to suggest it. That is 
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our position. So -- 

 MS. BRACKETT: I had asked before. 

 Is this microfilm still available anywhere? 

It was at the Mound site in -- 

 MR. FITZGERALD: Well that got to 

my other question about -- I thought the way 

to put this to bed originally was just to find 

the records wherever they went. And I thought 

maybe OSTI was the location. If we could make 

that one last step, I think that would kind of 

put this to rest. 

 I mean, I think your validation is 

valuable, but I think that would actually, if 

you could find the microfiche or find out 

where the microfiche went or where it was 

copied, that would kind of -- 

 DR. ULSH: Well, I understand. 

What I hear you saying is that this collection 

of microfiche, if we can locate it, verify 

that it is at OSTI or somewhere else, the 

question -- 

 MS. BRACKETT: I believe it is 
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microfilm not microfiche. 

 DR. ULSH: Microfilm. 

 MS. BRACKETT: I misspoke at first. 

 DR. ULSH: Okay, so you are 

proposing that as a follow-up action item. I 

understand. But even if we do that, someone 

could still speculate and say that there are 

others that you didn't look at. 

 MR. FITZGERALD: These are just 

degrees of validation. I think, you know, 

originally it was one of these that didn't 

seem to have more validation than just a 

recollection. I think what Liz is pointing to 

is something a little stronger. And locating 

the microfilm would be a little bit stronger. 

 Would it be 100 percent? I don't think so. 

But I think this was raised in the petition 

and certainly is, as you pointed out earlier, 

Brad, is a kind of compelling completeness 

question to address, even though I think we 

would admit that in the end, you can't be 100 

percent able to validate, but I think we would 
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be able to validate to the extent possible. 

 I would think the trail for the 

microfilm, I mean, I think the Mound records 

went only in a couple different, two or three 

different directions. So you might be able 

to, you might be able to substantiate where 

they ended up. 

 MS. BRACKETT: I had asked about 

this a few times, but I don't know if it was 

ever followed up on anywhere. 

 DR. BISTLINE: Liz, this is Bob 

Bistline. I was just wondering when you were 

reviewing boxes or inventories, I should say. 

 Was the emphasis really on internal and 

external radiation exposure data, or did it 

include area sampling, air sampling, and those 

sorts of kinds of information as well? 

 MS. BRACKETT: It was, actually it 

didn't include external data at all. We were 

focused only on internal. I don't recall. 

When we were looking through the boxes, when 

we were doing the review of the microfilm, we 
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had several Q cleared I think former employees 

from Mound, some retired folks. And I know 

that they did pull up process lab books. They 

were looking at that to see if we could look 

at processes and air monitoring and all. But 

to be honest, when I was at Los Alamos looking 

at log books, I don't recall if we were 

looking for that or just bioassay data. 

 But like I said, when these other 

individuals who weren't health physicists, 

they had been operational people, they were 

looking at a broader scope than what I had 

been focused on, I think. 

 DR. BISTLINE: Okay, thank you. 

 DR. ULSH: Okay, so that is the 

buried records issue. Josie, I am sure you 

are going to sum up what the action item is on 

that. But I think it is we go and look to see 

if we can test whether or not the microfilms 

against which these log books were compared 

are in fact available at OSTI or somewhere 

else. Right? 
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 CHAIR BEACH: Right. 

 DR. ULSH: Okay. There were a 

number of other issues, Bob, that you laid 

out. And like I said, I don't know that we 

will get to all of them. You mentioned the 

roadmap. I guess we are going to talk about 

that a little later so I will save that for 

then. 

 You asked how dose reconstruction 

will be done for beta and gamma emitters in 

the absence of bioassay. Right? I think. 

Yes. You want to handle that? Especially 

strontium. I know that strontium was 

mentioned. 

 MR. STEWART: Yes, and go back to 

Table 1. If we could just talk about Table 1 

for a while, I think we could iron a lot of 

these out. I assume that when we see comments 

in bold, those are the salient points, as far 

as SC&A is concerned? 

 MR. FITZGERALD: Yes, I think those 

are the question points -- 
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 MR. STEWART: Okay. 

 MR. FITZGERALD: -- that have -- 

and this is sort of a short version of a 

roadmap in a way but it is based on a roadmap. 

 MR. STEWART: Sure. I have some 

comments and some questions as well. 

 MR. FITZGERALD: Right. 

 MR. STEWART: Some clarification 

questions for our response here. 

 We talked a lot about actinium so I 

won't address that here. We will skip over 

americium because there is no bold statement 

in there. When we get to bismuth-210, there 

is no method proposed prior to years with Bi210 specific data. 

 If you are talking about the 

precursor to polonium-210 as part of the 

polonium process, I think the polonium 

bioassay would be conservative in that case. 

Bismuth-210 has a half-life of five days and 

the polonium-210 would grow in rapidly. Also, 

if you compare the DAC values as, I didn't 
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realize we don't use DAC values as an index of 

the radiotoxicity. The radiotoxicity of 

bismuth-210 is a factor of 45 less than the 

Po-210. So, that would be one of those cases 

where you would look for the needle rather 

than the haystack. Because Po-210 bioassay 

was commonly conducted at Mound. 

 Skip over to cobalt-60. This is 

not, again, not a pervasive radionuclide at 

Mound. Not something that I would assume a 

presumptive exposure to any individual onsite. 

 So this is connected with certain processes. 

 So what I am going to need to do is look at 

the roadmap, see what these time frames are 

and go back and look. 

 A number of times and I am sure 

this has been pointed out before but I will 

just belabor it. King can be unreliable in 

some circumstances, and his dates are not 

always correct. And also, he also lists 

material whether it was available for uptake 

or not. So it is not a hundred percent guide 
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that said this is in the atmosphere available 

for our person to have an intake of. 

 So cobalt-60 I will want to look at 

that. Cesium-137, you know, we just didn't do 

a lot of work with that or cobalt-60, as far 

as I could tell. So we are going to have to 

see where in the roadmap this comes up and, 

you know go back and look at it. 

 The next item, iron-55, iron-59, 

these dates indicate that this is associated 

with a reactor waste purification program. We 

did talk about a dose reconstruction 

methodology for that technology, which was 

ended at about that time frame, '54, but in 

fact, the health and human services 

designation letter does not state that we can 

reconstruct that. 

 Tritium, we will skip. 

 Iodine-131, the time frame here is 

'76 to '81, and I am trying to understand 

where that could have been an exposure. I did 

find one area where it was used to test a 
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waste disposal methodology. And so if anyone 

happens to know off the top of their head what 

process this is referring to, I would like to 

check that out. 

 MR. KATZ: We can find it. It is 

in the roadmap. 

 MR. STEWART: The only one I could 

see that I saw on my quick look through there 

was a process they used to test a method for 

cleaning wastewater, and that was from 

purchase of 10 millicuries of radioactive 

material. Iodine, cobalt, cesium-137 and 

strontium-90. 

 No, I would say there is probably 

no bioassay for that but we have an amount and 

we can bound the dose. If there are other 

instances of that, you know, we can look at 

those as they come up. 

 Manganese-54, I don't have a method 

for that. I didn't see it because it is in 

the Appendix B so I haven't looked at that 

issue as yet. Polonium-210 daughters, anybody 
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want to say anything about that? Anybody have 

any further information on why that is in 

there? 

 MR. FITZGERALD: Yes, some of this 

is off the roadmap, but we will have to sort 

of go back and forth. 

 MR. STEWART: Polonium-210 has a 

single daughter, stable lead-206. 

 Skip down now to strontium-90. It 

keeps coming up. There was some radio 

separation work done by -- and it is 

documented by a couple of published papers. 

This was done with a stock solution that was 

used, and I don't remember the exact dates. 

It was used to test a separation method. And 

then the same stock solution was used ten 

years later. We didn't come up with a method 

to do that. We said, we know who those two 

individuals are, and we can bound it with 

assumptions about the amount of stock solution 

they would have used. 

 The amounts are all written in the 
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papers. There may be other instances where it 

 would show up. I see that that was a part of 

the waste disposal methodology test. We can 

look at that. 

 Thorium daughters. It is true that 

you won't see bioassay for thorium daughters 

because, once again, you are typically looking 

for the haystack rather than the needle in 

this case. But the current TBD has a 

methodology to assign equilibrium amounts of 

the daughters. It is in Table 5-7. So what 

would happen if you had a positive thorium 

result, the TBD would drive the dose 

reconstructor to assign equilibrium amounts of 

certain daughters. So that methodology is 

there. But we wouldn't expect to see bioassay 

for each of those. And that is the last of 

the bolded items. 

 Okay, now we go to other 

radionuclides. Other radionuclides are an 

issue, and I also do some work for the Los 

Alamos site. So certainly that is an issue 
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there as well. I believe of these we are 

going to leave this for the detailed response, 

rather than go through each one of these. But 

once again, I will just point out that these 

don't compose, for the most part, they don't 

compose presumptive exposures for the entire 

universe of Mound workers. Now our approach 

will certainly take that into account. 

 MR. FITZGERALD: You have done a 

number of dose reconstructions on Mound. What 

are you doing now with these certain other or 

exotic nuclides? Do you have somebody that -- 

I think this was a question that was raised a 

little earlier. 

 MR. STEWART: Right. Yes, and I 

have seen those data indications. They are 

not common. You don't expect them to be 

common. 

 MR. FITZGERALD: Right. 

 MR. STEWART: When you see a 

process operator working SM PP, you expect to 

see 238 as a DR. And you see 238 for that 
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operational career. You don't ask questions. 

 You assign the dose and then you move on from 

there. 

 And certainly the numbers of 

individuals involved are against us here, as 

far as seeing all the other radionuclide data 

because there is a very large number of Mound 

workers. Fortunately, a small number of them 

have contracted cancer. And of those, not all 

have put in claims. And so any one dose 

reconstructor may not even encounter a person 

who even had a possibility of -- 

 MR. FITZGERALD: Well, I was just 

wondering how you flagged. It may not be a 

bioassay result, so much as where they worked 

operationally. It just seems like -- 

 MR. STEWART: And that does come 

up. Certainly, it does. What you will see 

is, is you will get a partial picture from 

each record that you review. You'll look at 

the interview. You will look at his or her 

area of employment. You know, we'll certainly 
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look at the bioassay records. And you will 

ask yourself, are these records consistent 

with what this person says he was exposed to? 

 I always go back to this certain 

claim as an example because it is a claim that 

had early employment at Mound, which means 

that full external dose records are included. 

 The guy was one of those guys that did these 

chemical processes, he was a chemist, and a 

number of polonium results, sure enough, he 

wrote a couple of chapters of the book 

Polonium. So certainly that polonium data is 

consistent with what he had talked about or 

with what he had done, his work, his published 

work while at the plant. 

 Oh, by the way, he was involved in 

an incident where he was possibly exposed to 

some pure radium. Well, we don't talk a lot 

about pure radium in the TBD, but he happened 

to be working with some. And in the claim 

file were records of bioassay and records of 

the incident as well. 
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 So, in that case, I said okay, the 

data in the interview corresponds with what I 

am seeing in the record. Now as a dose 

re-constructor, when I would start to ask 

questions would be what if he mentions an 

incident and he doesn't have something? And 

it certainly happens. 

 I think I brought up case number 

one before. It was a Mound employee, and 

there were a number of unanswered questions 

for that case. And really all that was 

available to us were overestimation methods. 

And that is what we did. The guy was still 

around. A very informed person, scientist, 

knew a lot about what he had been exposed to, 

and DR took forever. And basically, we just 

had to come up with some outrageous doses 

because we just didn't know. 

 Were they accurate? No, not at 

all. 

 MR. KATZ: But they were over 

estimating it. 
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 MR. STEWART: They were over 

estimating it. 

 MR. FITZGERALD: I'll give you an 

example. I was interested in you mentioned 

you really knew the two people that handled 

strontium-90 solutions. I mean, it was sort 

of like you key in on those individuals to be 

able to address that. 

 For example, the worker that might 

have worked on some of the reactor residue or 

whatever in the early days. Yes, I look at 

notions there is really no fission product 

monitoring. 

 MR. STEWART: Right. 

 MR. FITZGERALD: But you know, you 

could certainly, just by virtue of the 

activity, figure out that might be a potential 

there. 

 MR. STEWART: Sure. 

 MR. FITZGERALD: But you know, 

without, you know, we are looking at this and, 

well, there's no real results. How would you, 
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you know, factor that in, if there is not a 

basis? 

 MR. STEWART: Since the HHS 

designation letter came out, I wouldn't. 

 DR. ULSH: Well, a couple of things 

to keep in mind, Joe. In terms of the reactor 

waste program where you are going to see the 

fission products, that occurred in the early 

'50s, which is during the SEC period. 

 MR. FITZGERALD: But there was, I 

mean I guess we hadn't talked about later, but 

I mean, you are saying basically again the 

presumption is that there really isn't any 

residues until perhaps the D&D period. 

 DR. ULSH: Yes, I would say so. I 

mean, not for fission products. It was such a 

small, short-lived program. 

 But to answer your larger question, 

for these situations where we know exactly who 

was involved, the strontium example, our 

assertion is the thorium program would be one. 

 We will get to this later, but the most 
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insoluble of the metal tritides, we know 

exactly who could have been exposed to that. 

 I think what we would do certainly 

going forward. I mean, you may or may not be 

aware that the Mound TBDs are under revision. 

 A lot of that is going to try to capture the 

outcome of this process. But when that 

revision happens, I think what we would do for 

those situations where we know exactly who was 

involved, we would want to compile that 

somewhere so that if we get a claim in, we can 

flag that person and say okay, he should be 

considered for this particular element. 

 DR. ULSH: Yes, but let me just 

tell you. I mean, it sort of keys in on you 

either know who the individuals are, you know 

the activity. There are two or three 

different flags, or you just pick it up by 

virtue of what they volunteer in the CATI 

interview or something. If that were the 

process, then I think a lot of these would be 

addressed. 
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 Now there are some that I think, 

you know, it is unclear to me how you would 

address it because it is difficult for an 

individual to know they were in the operation 

or the time period or whatever. And D&D is 

another question entirely. But certainly that 

would be a method to tag a small number of 

potentially exposed workers to a particular 

nuclide and address the ability to monitor, 

the ability to do dose reconstruction. 

 MR. STEWART: Sure, and that is a 

comment, peer review comment, that we get a 

case sent back with DR is that, you know, the 

individual described some potential exposures 

that you didn't address. You know, why didn't 

you look at this particular radionuclide. 

 MR. FITZGERALD: I guess what we 

are coming to this is also in the adequacy, is 

what is the strategy or approach to addressing 

other nuclides. You know, not the mainstream 

but the other nuclides. Not involving a lot 

of people. Very specific operations. Very 
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specific narrow time periods. Certainly, you 

are going to come across them but not very 

often. And what is the approach? 

 And I think when we look at the ER, 

I think we can understand it and it is very 

clear that the mainstream nuclides were 

addressed pretty thoroughly and there was a 

lot of data, clearly. But for these sort of 

cats and dogs, these other nuclides, and this 

is the same with other sites, it wasn't quite 

as clear in the ER what the approach would be. 

 And I think beyond all this sort of 

analysis of where the holes and gaps are, I 

think that is the underlying question. What 

would you do? What is the strategy for making 

sure that, you know, even the absence of data, 

the exposure potential is recognized and 

something is done. 

 DR. ULSH: Well, I think in terms 

of -- this is an issue that may pop up later. 

 I suspect it will, demonstrating sufficient 

accuracy, you know, that whole issue. I think 
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what we would be obligated to provide to you 

would be a sample dose reconstruction, where 

we would show how we would address potential 

exposure to some of these other radionuclides. 

That I would certainly agree is something that 

we need to -- 

 MR. FITZGERALD: Yes, we are kind 

of -- that is kind of what we are talking 

about is -- 

 CHAIR BEACH: You are talking about 

a basic walkthrough from the start of dose 

reconstruction how you handled it and what you 

just said. 

 DR. ULSH: Yes, I mean, it is 

typical that a sample dose reconstruction is 

going to be provided for other sites. It 

would actually be a dose reconstruction report 

for a fictional claimant, of course, where we 

would demonstrate that methodology. 

 Now, in terms of -- I mean, there 

is a couple of questions wound together here, 

Joe. One is can we demonstrate a bounding 
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technique. That, I think, is a valid SEC 

question we need to answer. 

 MR. FITZGERALD: Right. 

 DR. ULSH: But in terms of who you 

apply that to, and this goes back to the 

discussion that we had at the previous working 

group meeting -- 

 MR. FITZGERALD: I know. Right, 

right. 

 DR. ULSH: -- that will probably 

come up later. 

 MR. FITZGERALD: Yes. 

 DR. ULSH: Our position is still 

that that is not an SEC issue. That is a dose 

reconstruction issue. I know that there may 

be some dissension on that. 

 MR. FITZGERALD: I know. I would -

- it is getting closer to lunch. So I would 

like to unpack that question about the 

bounding model bounding approach versus the 

enabling parameters or data that would make 

that model feasibly useful at a particular 
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site. And I think maybe to some extent with 

stable tritium compounds and some of the other 

issues, we are going to get into that. I 

mean, I think that is a central question. We 

don't probably need to do it now but we are 

going to have to get into that question. 

 But I think we have an honest 

disagreement about whether or not one can 

refer to the implementing data, the sitespecific data that would enable that model to 

be effective and feasible to that site, to be 

a site profile question. But, you know, I 

think we have touched on it, but we really 

haven't had that discussion. So I think it is 

a good discussion to have. 

 DR. ULSH: Preview of things to 

come. 

 MR. FITZGERALD: Right. 

 CHAIR BEACH: I think Kathy. 

 MS. ROBERTSON-DeMERS: I have a 

question. Okay, you go to the employee file 

and you look at the CATI interview when you 
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are doing the dose reconstruction. And we 

have demonstrated that it is not complete. It 

doesn't have all the bioassay data. So what 

do you plan on doing with respect to all the 

other bioassay data that is out there? 

Somebody may say I was involved in the radium 

or thorium processing, but the data may not be 

available to you, and you may assume that they 

aren't because the data is elsewhere. 

 DR. ULSH: Well, you made a 

statement there that I think we are going to 

have to evaluate. And that is that you have 

demonstrated that the data are not complete. 

I assume when you say that, you are talking 

about the dosimetry files provided to us by 

the Department of Energy. 

 MS. ROBERTSON-DeMERS: Right. 

 DR. ULSH: Okay, now keep in mind 

that is a statement that was made in your 

white paper that we have not yet responded to. 

 So I am not prepared at this time to grant 

that that is the case. We have to take a look 
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at it and we will respond. But we haven't, I 

mean, we haven't look at that yet. 

 MR. FITZGERALD: Well, we did touch 

on the fact that there are going to be 

instances where the data just isn't available 

for whatever reason. And that gets into, you 

know, location-specific, activity-specific 

operations. And there is other tags that one 

can use to get into a application of a -- 

 DR. NETON: We have encountered 

this before a number of times -- 

 MR. FITZGERALD: Yes. 

 DR. NETON: -- I mean, where you 

have laboratory sources and quantities and I 

think we can produce, for those kind of 

situations, bounding values based on what 

happened or what did happen. 

 MR. FITZGERALD: Yes. 

 DR. NETON: I mean, because the 

chemist working with liquid solutions and is 

doing some extractions and never goes to dry, 

I would question whether there was any 
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potential for an inhalation exposure, anyway. 

So that becomes very much a case-by-case 

analysis. 

 MR. FITZGERALD: Yes, and it is a 

familiar discussion. And we have had it at 

various sites. In some cases, it covers 

everything but. And there is some good 

reasons, whether it is fission products at Los 

Alamos. There are good reasons why you just 

can't get there from here. 

 So we are at that process where we 

just sort of identify what seems to be the 

holes, but I suspect that we will hear and 

understand how those holes will be addressed 

in terms of an upper bound approach. That is 

kind of where we are at now. 

 MR. BUCHANAN: I have a question. 

This is Ron Buchanan. You do not presently 

have a list of these 20 or 15 or 5 people that 

when a person does a dose reconstruction and 

says hey this guy was assigned to this group 

of five or something of these special 
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isotopes. 

 Right now, you look at where the 

person worked and say well, we should 

investigate this, maybe. But you don't have 

that in place at this time. Is that correct? 

 DR. ULSH: It is not our routine 

policy right now. I mean, for instance, let's 

talk about special metal tritides, the most 

insoluble of the tritides. We know who the 

dozen or so people are. We don't currently 

flag every Mound dose reconstruction to bounce 

against that list of 12. That is something 

that we are going to need to implement. 

 Does that answer you question? 

 MR. BUCHANAN: Yes, thank you. 

 CHAIR BEACH: Okay. And then from 

a Working Group standpoint, I would like to 

request NIOSH, of course, we have mentioned it 

a couple of times, answer in detail the SC&A's 

white paper with a, you know, response to all 

the questions that were asked within the 

Appendix 2 and 3. And then once again, I am 
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going to push for an end date in the one to 

two month time period. That may be tomorrow 

at the end of the day, as we discussed with 

the first white paper that we will come up 

with some kind of a closure time to have a 

white paper on the table for the working 

group. 

 Again, if that is acceptable. 

 MR. STEWART: I would suggest we 

consolidate this paper with the one we 

reviewed before the break. 

 CHAIR BEACH: Consolidate them into 

one white paper? 

 MR. STEWART: Our response. Our 

response. 

 CHAIR BEACH: That's fine. 

 MR. FITZGERALD: It was, actually, 

one consolidated paper but it got to be a 

little unwieldy so we split it. But that is 

fine. 

 CHAIR BEACH: Yes. My concern as 

long as the questions are answered within 
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there, that is fine. 

 MR. FITZGERALD: Yes. 

 CHAIR BEACH: Anybody else have 

anything from the Work Group? 

 MR. FITZGERALD: Well, I would 

support the suggestion if not know some point 

to walk through some of these sample dose 

reconstructions just because I think it would 

clarify, you know, pretty much where this all 

started from. You know, we couldn't really 

get from the ER what the approach would be for 

these other nuclides. I think we touched on 

some of the possibilities, but it would be 

much clearer if we could see a few samples. 

And really one step is to sort of test the 

envelope. You know, there are several 

possibilities here that you could certainly 

run through, and that would kind of push the 

envelope and say okay, this is a pretty tough 

one. I mean, there is no data and you would 

have to do this or that. But that would be 

helpful. 
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 CHAIR BEACH: Well, and I think 

Brant agreed to do one, but how many would you 

like to see? 

 MR. FITZGERALD: I would leave it 

up to NIOSH. I think it would test the issues 

which, you know, we have talked about multiple 

exposures, we talked about exposures where 

there is no data. You know, just some of the 

ones that will be the harder ones. If you 

happen to know the two people that were 

exposed to strontium-90, I wouldn't propose we 

do that. I think that is a lot clearer how 

you would approach that. But the ones that, 

from your vantage point would challenge the 

dose reconstructor. I am not saying it is not 

doable but would be a challenge. 

 I think that would help understand 

what the approach would be for some of these 

exotics without spending a lot of time. 

Because I think the matrixes are useful but 

the how part is the part that is going to be 

the most valuable. 
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 MR. STEWART: Sure, and I think a 

lot of the issues that we have gone back and 

forth on are fundamentally understanding 

issues between how we do it and how -- it is 

just not easy to communicate -- 

 MR. FITZGERALD: Well, I don't want 

to spend time talking -- in a sense what we 

are saying is well we see there is no results, 

and the implication is how can you do it 

without results. I would like to see it is 

sort of okay, what is the approach. You 

acknowledge the results are not plentiful, but 

how would you go about doing the ER. I think 

that would help. 

 CHAIR BEACH: With details. And so 

I have got three action items out of this 

discussion. Does anybody else? 

 I had NIOSH respond in detail to 

SC&A's data completeness white paper. And 

then I had locate the microfilm from Mound for 

SC&A to look at, and then the sample dose 

reconstruction, which could be in addition to 
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the detailed answer. But not to lose focus of 

any of those. 

 DR. NETON: Did we actually agree 

to take that action item to find the 

microfilm? I mean, I think it was open for 

discussion. 

 CHAIR BEACH: Oh, was it? 

 DR. NETON: I don't recall that we 

said we would go find the microfilm. Did we? 

 CHAIR BEACH: I am sitting next to 

Brant. I am pretty sure I heard him say that. 

 DR. NETON: I still wonder what the 

value of finding it is, other than to say it 

exists. It is not some fictitious cadre of 

microfilm. 

 MR. FITZGERALD: Well, I think 

there is certainly a universal sense that the 

only thing we have is recollections. It would 

be useful to know that whatever was generated, 

what Liz was pointing to is in fact still in 

the holdings. I think the petitioners raised 

it, and it is in the ER, and it sort of has 
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been, I think, Brant characterized it as sort 

of a bit of a problem because there is no way 

to really -- 

 DR. NETON: Well see my problem is, 

I mean, that creates the expectation if you 

don't find it there is some hole. And I am 

not sure that if we never found it, we would 

change our approach. 

 MEMBER ZIEMER: Josie, could I make 

a comment here? 

 CHAIR BEACH: Yes, Paul, please. 

 MEMBER ZIEMER: Well, I don't 

regard the MJW report of ten years ago 

recollection. The report is the report. So I 

think that has its own level of reliability. 

You know, you can accept what they found. 

 The question of whether or not you 

have to go back now and find those things that 

they looked at seems to me problematical. 

 MR. FITZGERALD: To find the 

microfilm is problematic? 

 MEMBER ZIEMER: No, no, I am saying 
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that clearly they exist or existed, and the 

verification was done at that time. That is 

not just recollections. I mean, you have that 

report. 

 DR. ULSH: Well, you raise an 

interesting question. I think if Liz -- Liz, 

are you still on the line? 

 MS. BRACKETT: I'm here. 

 DR. ULSH: Okay. Well, when you 

say that the log books were found in the 

microfilms, I assume, and you jump in here and 

correct me if I am wrong, but any bioassay 

data that was found was incorporated in MJW's 

databases, the PORECON and PURECON. 

 MS. BRACKETT: Yes, and in fact, I 

meant to point this out earlier, too. In one 

of these white papers, I think it might have 

been the quality assurance one rather than 

this, but there is mention, there is quotes 

from MJW saying that there were gaps in the 

log books that we didn't find. But in fact, 

there is no gaps in the data. So the log 
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books weren't the only source of bioassay 

data. The were cards also. The log books 

were used only to verify data that were 

already there. 

 So when we found log books, we 

verified data that we had, and I guess there 

are some instances where we found data that 

had been missing. But anything, in that case, 

would have been entered into the database. 

 MEMBER ZIEMER: Well, we can 

discuss that further. I just wanted to make 

that observation. Could I make a couple of 

other comments at this point? 

 CHAIR BEACH: You bet. 

 MEMBER ZIEMER: Yes, one is more of 

a question. Josie, did you distribute six 

documents? I have only located three, and I 

think the ones that we have discussed I don't 

have. 

 CHAIR BEACH: You were actually, I 

sent you three that were cleared documents. 

 MEMBER ZIEMER: Okay. 
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 CHAIR BEACH: And there were others 

that were supposed to come out this morning 

that I have not seen. 

 MEMBER ZIEMER: Oh, okay. 

 MR. KATZ: But Paul, they weren't 

sent out in cleared version, you know, privacy 

and reviewed version. 

 CHAIR BEACH: Thank you. 

 MR. KATZ: But they were sent out 

previously in the protected version. 

 CHAIR BEACH: Yes. 

 MR. KATZ: So you would have 

received them all much earlier than that. 

 MEMBER ZIEMER: How much earlier? 

 MR. FITZGERALD: April time frame. 

 MEMBER ZIEMER: Oh, okay. Then, 

and I will go back in my other files and see 

if I can pick those up but I only have the 

three here with me. 

 The other comment, and this deals 

with cesium and strontium and I think those 

are minor players in reality. But I just 
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wanted to point out that for the time periods 

of the 50s and the 60s, virtually everybody in 

the country had body burdens of cesium and 

strontium that were detectible and, in fact, I 

know when we did whole body counting through 

the '60s of non-nuclear people from anywhere, 

we always had interference of cesium from 

atmospheric weapons testing, even though the 

testing in the atmosphere ended in the late 

'50s, you still detected it in people's bodies 

on through the '60s. So, if in fact, I don't 

know if anyone is using gross beta for those 

urinalyses, but it would be very surprising if 

you didn't see cesium anyway. It certainly 

was easily detected with whole body counters. 

 I don't know how readily you would see it 

with gross beta urinalysis. But it certainly 

was there. And the same is true of strontium. 

 In fact, you might recall the 

concerns about strontium in children's teeth 

through that period, just as a comment on the 

fact that there was a background body burden 
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to start with. 

 MR. STEWART: Yes, and that is 

taken into account in our TBDs, we use NCRP 

guidance to look at those background levels so 

when we see cesium-137, we will usually 

subtract it out. 

 MEMBER ZIEMER: Use that baseline. 

 MR. STEWART: Yes. 

 MEMBER ZIEMER: Okay, very good. 

 MR. STEWART: Yes, and just to 

clarify one point that seems to be coming up 

regularly at these meetings, we don't use 

gross beta at Mound. 

 MEMBER ZIEMER: I didn't think so. 

 Someone was talking about it earlier. 

 MR. STEWART: We had an 

unfortunate, I think, slip in the ER where it 

showed up, possibly there. But in fact, we do 

not use gross beta at Mound. 

 MEMBER ZIEMER: Right. Very good. 

 DR. ULSH: So what is the status on 

the microfilm? 
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 CHAIR BEACH: You tell us. Are you 

going to look for it? 

 DR. NETON: I feel like I'm missing 

something. Let's say we did find it. What 

would be the use? What would be done with it? 

 DR. ULSH: Well considering all 

that -- considering my take on it, the 

question that I asked Liz that the useful 

bioassay data was already pulled out and 

included in PORECON and PURECON. 

 DR. NETON: Right. So it would 

essentially be a verification that MJW did an 

adequate job pulling out the bioassay data. 

Is that correct? 

 MR. FITZGERALD: Well, it would 

also be a validation. I think what Liz was 

saying earlier is that what they retrieved 

from the Los Alamos records were in fact put 

on the microfilm and she was there when that 

processing was done and the comment was, you 

know, clearly, there is a record. There is a 

microfilm record. 
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 I will defer to the workers. I 

mean, at this stage, it is a question and I 

don't disagree with Brant, it is a degree, a 

validation and if the work group is satisfied, 

it has sufficient validation based on the MJW 

record, plus Liz's comments. I mean, that is, 

you know, I think this is a judgment call as 

to how much validation does a work group need. 

 CHAIR BEACH: And do you have a 

comment, Kathy? 

 MS. ROBERTSON-DeMERS: Well, there 

is two sets of microfilm that we are talking 

about here. One of them is the microfilm that 

was sent to or that was created from documents 

that were sent to Nevada for burial. And I 

think one of the suggestions was to just go 

through that data because it is classified and 

see if there is any relevant monitoring data 

in it. 

 DR. NETON: Wait a minute. Wait a 

minute. 

 Where are these micro -- these 
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records are then. 

 MS. ROBERTSON-DeMERS: These are 

the records that we referred to as the DOE and 

I will refer to it -- 

 DR. NETON: That is not -- 

 MS. ROBERTSON-DeMERS: -- with 

respect to -- 

 DR. NETON: -- a new record search, 

though. Those records exist and they can be 

looked at. 

 MS. ROBERTSON-DeMERS: And I think 

what we were recommending is that you go 

through the inventory and make sure that there 

is nothing -- 

 DR. NETON: Well that is fine. 

 MS. ROBERTSON-DeMERS: -- nothing 

there. 

 DR. NETON: But what I was 

questioning is the value of going and trying 

to find microfilm records that Liz evaluated 

already. 

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that is a second set of microfilm. 

 DR. NETON: Okay, that is what I am 

talking about. 

 MS. ROBERTSON-DeMERS: Okay, that 

set of microfilm is available at OSTI. 

 DR. NETON: Are you certain of 

that? 

 MS. ROBERTSON-DeMERS: That is what 

the records manager at Mound documented as far 

as how they progressed through the process. 

 DR. NETON: Okay and so if they are 

available at OSTI, what value would they 

provide if we went to get them. 

 MS. ROBERTSON-DeMERS: Now, these 

are classified again. Okay? And it might be 

beneficial to do a spot check on some of the 

personnel monitoring data to make sure that 

all of that classified data was captured. 

 DR. ULSH: But didn't MJW do that? 

 DR. NETON: MJW already did that. 

This would be QC check on MJW's work. That is 

what I am hearing. And we have a lot of 
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projects going on here and I am just trying to 

save resources where it is appropriate. 

 MR. ELLIOTT: If I may? This is 

Larry Elliott. 

 NIOSH has stated its position and 

we are going to stand by that. We don't have 

any reason to question the report from MJW. 

If the Working Group feels that it something 

they want to pursue, then I suggest you take 

it up with OSTI and pursue it in that regard. 

 Brant, you don't have any need to 

go back and look and validate further in this 

regard? Yes or no? 

 DR. ULSH: No, no. 

 MR. ELLIOTT: I mean, if you want 

to go there. But I am just saying, otherwise, 

we are done with that. 

 CHAIR BEACH: Okay, well I think at 

this time what I would like, just speaking for 

myself and the Working Group, is that we will 

wait for NIOSH's response to the white paper 

and go from there, if the rest of the working 
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group is in agreement. I mean, speak for 

yourselves. 

 MEMBER ZIEMER: That is why to get 

the official response from NIOSH. I already 

stated what I felt about -- 

 CHAIR BEACH: Yes. 

 MEMBER ZIEMER: -- the MJW report. 

 I think there is no reason not to accept 

that. I don't think that report is suspect at 

all. 

 MS. BRACKETT: This is Liz 

Brackett. I just wanted to say, you know, you 

are saying that you are accepting our review 

but I just wanted to make sure that everybody 

understands. You know, we were only looking 

for internal bioassay data. 

 MEMBER ZIEMER: Right. 

 MS. BRACKETT: So you know, we are 

not speaking as to the complete universe of 

what might have been included in those 

records. So that was clear. 

 CHAIR BEACH: That is a good point. 
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 Thanks, Liz. 

 DR. NETON: I think -- good point. 

 We can respond and put our position on the 

table when we evaluate the report. 

 CHAIR BEACH: Okay. And at this 

time, if there is nothing else, it is lunch 

time and we will reconvene, what do I have, 

about 20 to 1:00 or 20 to 2:00? 

 MR. KATZ: It is about 20 to 1:00 

right now. 

 CHAIR BEACH: So, 20 to 2:00. 

 MR. KATZ: One hour, about 20 to 

2:00. Thank you everyone on the phone. 

 MEMBER ZIEMER: Josie or Ted? 

 MR. KATZ: Yes. 

 MEMBER ZIEMER: Ziemer here. I may 

not be with you at that time. If not, I will 

certainly be back in the morning. 

 MR. KATZ: Okay. Thanks, Paul. 

 MEMBER ZIEMER: Okay. Bye-bye. 

(Whereupon, at 12:38 p.m., a lunch recess was 

taken.) 
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 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 

 (1:41 p.m.) 

 MR. KATZ: This is Ted Katz with 

the Mound Working Group. We are reconvening 

after lunch. Welcome back. 

 Let me check on the phone to see 

whether we have Dr. Ziemer. Paul are you with 

us? 

 MS. ADAMS: Yes, Ted, we can hear 

you. 

 MR. KATZ: That is Nancy. I was 

just checking to see if Paul was with us. 

 CHAIR BEACH: He thought he 

wouldn't be with us. 

 MR. KATZ: Oh, that's right. 

That's right. This afternoon. That's right. 

 Exactly. 

 Okay and by any chance, Bob, have 

you joined us? Bob Presley? 

 CHAIR BEACH: He said he would not 
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be with us. 

 MR. KATZ: Okay, he said that he, 

he sent me an email saying he might call in 

from time to time. 

 Okay, then otherwise, just to 

remind the folks on the phone, please keep 

your phones on mute, *6, if you don't have a 

mute button. And Josie? 

 CHAIR BEACH: Okay, we are going to 

shift gears just slightly and go into adequacy 

and completeness of external dose. And Joe, 

did you have a brief history on this also? 

 MR. FITZGERALD: Yes, just a little 

history on this thing. 

 This is the sort of the sister 

question of reliability to the internal dose 

discussion we had this morning. And again, I 

think it has been one of the charges that the 

Work Group and the Board has had and has asked 

SC&A to look at as reliability. 

 In terms of external dose, we 

certainly indicated that there was a 
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conclusion that the external dose was adequate 

and sufficient for dose reconstruction. So 

what we proceeded to do was a limited 

sampling, as we did with the internal. In 

this case, we felt that based on the 

interviews we had with the workers and the 

dose records, we felt that quite frankly, it 

was a fairly complete database on external but 

wanted to do the sampling just to again 

compare the electronic database with the 

originating documents that were on the file in 

terms of external exposure. 

 So, we did 22 cases and Ron 

Buchanan, who I think has spoke to the Work 

Group and you have heard from him last year on 

some of these same issues, I think what we can 

do is recap. We have already kind of briefed 

out this issue. But just to bring everybody 

up to speed and make sure we put the Work 

Group in a position to come to a conclusion of 

some sort, we are going to go ahead and walk 

through that one more time. So perhaps you an 
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talk about the sampling we did and some of the 

results. And also, I guess, there is a 

corollary issue on integrity. There are two 

issues pending now. 

 MR. BUCHANAN: Okay, this is Ron 

Buchanan and I followed up last year on some 

of the questions on the completeness and 

integrity of what the external dose data was. 

 And what I found was that there was original 

handwritten data sheets which is what I wanted 

to go back to and compare them to the latest 

MESH database that the dose re-constructor 

actually uses. And the thing was if there was 

a limited amount of handwritten datasheets, 

there was only handwritten datasheets for the 

'50s and '60s and then there were some 

handwritten summaries through '68. 

 And so what I did, I have compared 

the original cards, handwritten summaries and 

the latest MESH database for 22 cases that I 

selected out of 698 claims. There was a total 

of 698 claims on Mound at the time; 447 of 
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those claims had starting dates of January of 

1950 or later, in the '50s and '60s where I 

could find some original data sheets. 

 And 22 of these claims I selected, 

20 were workers, process workers or whatever, 

technicians that could have had some dose. I 

did select two that were secretaries and 

something else that probably shouldn't have 

had any records. I wanted to check and see if 

the badging policy was consistent with what we 

thought it was. And so I went through about 

4,000 pages of DOE records for these 22 

claims. I found that 19 of them did have the 

summary data sheets, so there was three 

benchmarks that you could compare. There was 

about 530 years worth of total work history. 

 The result was that -- now this is 

a small sampling of claims but we just wanted 

to see if there was a problem or not and so 

that is the reason we did that, a small 

number. This represents five percent of the 

total claims that had data after 1950 and we 
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found that 100 percent of the claims had MESH 

data sheets in their DOE records. They had 

the original cards, photographs of original 

cards, photographs of the summary. And then 

also in the MESH database files were in their 

records sent them, to NIOSH by DOE. 

 We found that 100 percent of them 

had DOE records. Even the two that didn't 

weren't monitored. We found that 99.6 percent 

of the photon dose was correctly transferred 

from the cards to the MESH database and there 

was only one 20 millirem dose that was left 

off of the very early records. All the other 

records matched. 

 We found that 100 percent of the 

neutron dose was correctly transferred from 

the original cards to the MESH database. Now 

we did find the only area that we noticed a 

difference in was that while the original 

cards would have dashes or blanks in the MESH 

database, apparently goes in and puts in a 

zero if there is a dash or a blank in the 
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original card. And so there is a lot of zeros 

contained in the MESH database, which aren't 

on the original cards. 

 And so this might give the dose 

re-constructor the idea that the person was 

monitored when they weren't and the actual 

result was zero. And so that was the only 

real discrepancy we found. 

 As far as actual positive dose, the 

zeros, the recorded zero and the recorded 

positive dose were 100 percent accurate but 

there was zeros in the MESH database. Really, 

they weren't monitored during that period. 

And what this could lead to would be if the 

worker should have been assigned coworker dose 

or something, he was in a radiation area, if 

the dose re-constructor uses zero, he would be 

assigned a lower dose than if he would be 

usually assigned a coworker dose. 

 And also it could make the coworker 

database, if the coworker database was taken 

from the MESH database, it would make it 
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towards the low side, including the zeros. 

 So our conclusion was and realized 

we only did this, we only had to do this 

comparison for the '50s and '60s because there 

was no handwritten data after '68. And so the 

'70s and '80s we couldn't compare to see if it 

was transferred. 

 And you had your original 

handwritten datasheets. You had your 

handwritten summaries and then you had 

electronic systems up until you ended up with 

a MESH data system, which was the latest. 

 But this was kind of a snapshot, a 

spot check of the 40, 50 years worth of data 

transfer. And we did not see anything that 

would indicate a problem. 

 MR. FITZGERALD: I think the notion 

was if we had seen something that was pretty 

pronounced, we would have gone back to the 

workgroup and said, you know, we need to 

perhaps do additional sampling. But since the 

sampling came out pretty consistently solid, I 
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think that is where we are. That is where we 

have been on that issue. 

 CHAIR BEACH: I guess the only 

question I would raise is back on those zeros 

and would ask NIOSH to explain if that is in 

fact a concern. 

 DR. ULSH: I can take a crack at 

that. 

 I understand what you are saying, 

Ron, about this might lead a dose 

re-constructor to conclude that someone was 

monitored when in fact they were not 

monitored. And you said in that situation, 

that might lead the dose re-constructor to 

assign missed dose instead of coworker dose. 

Well, you are right. I mean, that is the way 

that we tend to do things. But a Mound, you 

have to understand we don't have an external 

coworker model because it is our position that 

if you had external exposure potential, you 

were monitored with one exception. And that 

is, for neutrons, people who went into the 
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facilities on what were called visitor badges, 

visitor meaning not -- it doesn't mean that 

someone wasn't a Mound worker. It means that 

they were not permanently assigned to that 

building. 

 For instance, in the early days in 

SM Building, we know that they did this. If 

you were a plumber or a pipe fitter, you know, 

called up to the SM building, for instance, it 

wasn't your permanent assigned building. You 

would be assigned, you could be assigned a 

visitor badge. So you would have a photon and 

a neutron visitor badge. And if, unless the 

photon badge gave above a certain reading, and 

I don't recall exactly what that was, they 

wouldn't read the neutron badge. 

 So that is one situation where you 

might have an unmonitored dose, and we are 

proposing, and as you know, from our 

conference call earlier, you know, like in the 

past month here, for our neutron dose 

reconstruction methodology, in that case, we 
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are proposing for the early years, a neutron 

coworker model to handle exactly that 

situation. 

 But that is not built from MESH 

data. That is built from the health physics 

progress reports. So you wouldn't have that 

kind of initiative. 

 For the other situations where you 

have a zero, for instance, at Mound what would 

happen is we would typically assign, because 

of our position, and this goes back to what 

workers have told us and what Meyer has said 

in his history of dosimetry that if you had 

the potential for external radiation 

exposures, you were monitored. 

 So, conversely, if you didn't have 

monitoring, that would indicate that you did 

not go into the radiation areas and we would 

assign environmental dose. So, what you are 

talking about is assigning a missed dose, 

instead of an environmental dose. And I would 

present to you that that is claimant favorable 
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because the missed dose that we assign is 

always far higher than the environmental dose, 

environmental external. 

 Don do you have any? Since you do 

the dose reconstruction -- 

 MR. STEWART: That is right there. 

 That is correct. The draft TBD that will be 

turned in soon for ADC review, actually brings 

out that exclusive point, that some of these 

zeros are artifacts of the record keeping 

system rather than actual zero dose results or 

less than LOD results. 

 We typically just leave those alone 

because we don't have any way to say that they 

are not actual instances of monitoring. 

 DR. ULSH: And it is claimant 

favorable to assign a missed dose. 

 MR. STEWART: And it is claimant 

favorable. We have discovered some years 

where we can recover doses by dosimeter, using 

the HP number and the TBD will include those 

years. Typically, we won't do that. 
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 Typically, we will say he has got 

zeros in 1968, therefore, we will assume he 

was monitored for the whole year. Whereas, if 

that one item made that case compensable, we 

could go back and reconstruct the dose for 

1968 and find out how many zero dosimeter 

results there were, if in fact there were any 

for that. You would have complete records for 

'68, '69 and a couple of years in '70s prior 

to the time when we have complete records in 

MESH. 

 But yes, we have one provision, one 

TIB that we can go back and in some cases, we 

cannot assign missed neutron dose. And that is 

TIB-23. This is a complex-wide TIB that is 

used. It was used to get rid of some of the, 

or to rule out, neutron doses in the face of 

many negative photon results because we were 

just assigning very high doses. Because Mound 

is not the only site that will have artifact 

zeros. 

 In fact, we don't apply that very 
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much at Mound because I mean, if you have got 

some instance of a positive neutron dose in 

the worker's history, you can't just simply 

say oh, well, he must not have been monitored 

all except for that one year. But typically, 

we don't apply that at Mound. It is possible 

to use that, if all the conditions are met 

from the TIB. 

 And that's it. 

 CHAIR BEACH: Anybody else have 

anything? 

 MEMBER CLAWSON: I was just trying 

to follow through. You said that you did this 

sampling up until the '60s. It was through 

the '50s? 

 MR. BUCHANAN: Yes, there was only 

the original ones that I could compare to 

during the '50s and '60s. The handwritten 

cards and summaries ended in '68. And so, 

from '69 forward there was no handwritten 

cards to compare them to. 

 MEMBER CLAWSON: So then you are 
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just going to the MESH? 

 MR. BUCHANAN: Well, I couldn't do 

any comparison. I could only compare '50s and 

'60s to the present MESH. I could not compare 

any data from say what was the '70s to MESH or 

'80s to MESH. 

 And I guess my contention was, 

first of all, that is all I had to compare it 

with. I couldn't do any other comparison. 

And if it did trace back faithfully to the 

1950s, then it made it through all of the 

electronic database switches up through MESH. 

 You know, if a person in 1952 was 

assigned 100 millirem, then it was taken from 

the handwritten cards to the handwritten 

summary to the handwritten summary through the 

various electronic databases and correctly 

entered into MESH, then that would indicate 

that something over 40 or 50 years was 

correctly carried forward. But I did not have 

anything to validate that what was originally 

read in the '70s or '80s was correctly carried 
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to MESH. Because that was all entered in 

electronic form and then into MESH when that 

came about in what '88 or something like that. 

 MEMBER CLAWSON: Well, then we have 

a couple of electronic databases in there that 

this went to or did we -- 

 MR. BUCHANAN: In between. In 

between '68, the last handwritten and MESH, 

there were several, I think at least one or 

two, in between the handwritten and MESH. 

 So when a person was read in 1970 

and entered into that electronic database, 

then that had to be transferred to the next 

one in and on into MESH. But I have no way to 

even look at that because I don't have any 

original records, handwritten records from 

that era. 

 MEMBER CLAWSON: Didn't we take 

care of this a little bit earlier, just a spot 

check to make sure what was switched over? 

 MR. FITZGERALD: Well, we looked at 

the systems but this was sort of proof of 
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principle in going back and actually taking 

actual dosimetry records for individuals and 

just establishing that you could, in fact, 

confirm that they were complete, the 

transcription was correct. 

 And of course, this was a first 

order review and the premise was we would use 

this sort of as reconnaissance to see if 

anything would surface. Now, this was on top 

of having interviewed 40 some workers, of 

which I think you were on some of these 

interviews. 

 MEMBER CLAWSON: Right, I was. 

 MR. FITZGERALD: This was a 

straight forward questions. We asked every 

one of them in terms of the external badging 

and the completeness of that and how rigorous 

it was in RAD areas. And we got a pretty 

informed answer: it was pretty rigorous. And 

so this was to validate that the records, in 

fact, were likewise complete. 

 Could we do more? We certainly 
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could do more but based on this sampling, you 

know, that is, we feel that that pretty much 

gives us a confirmation, at least from that 

standpoint that that is complete. 

 MEMBER CLAWSON: Okay. 

 CHAIR BEACH: I guess as a Work 

Group, point of view, I would suggest that we 

close this item, officially close this item. 

And that is up for debate, discussion or 

anybody disagree with that. 

 DR. ULSH: So that is issue 18 and 

19? 

 CHAIR BEACH: Eighteen and 

nineteen, external dosimetry records. So is 

that the path forward then? Does everybody 

agree with closing this? 

 MR. FITZGERALD: That doesn't 

include neutrons. 

 CHAIR BEACH: No. No, it does not 

include neutrons. Just this report. 

 MEMBER CLAWSON: But you are 

talking about that you were using the 
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environmental versus coworker because you 

didn't have coworker model. Right? 

 DR. ULSH: Right, we have not 

developed a coworker model. 

 MEMBER CLAWSON: Okay, so we are 

using the environmental for the workers? 

 MR. STEWART: For unmonitored 

individuals. 

 MEMBER CLAWSON: Unmonitored, okay. 

 DR. ULSH: And that hinges, Brad, 

that hinges on the position that if you went 

into a radiation area, you wore a dosimeter. 

So conversely, if you didn't wear a dosimeter, 

you were not in the radiation areas that we 

assigned as environmental. 

 MEMBER CLAWSON: Yes, and the 

reason I was bringing this us because the same 

with those interviews that we had that there 

was a lot of different talk about the 

environmental out there of different problems 

that they had out there. 

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that in the environmental issue -- 

 CHAIR BEACH: Twenty. 

 MR. FITZGERALD: -- which is later 

on this afternoon. And we in fact did convey 

not only the worker input but our own concerns 

to what extent those contamination events or 

instances, or whatever were considered in the 

environmental, occupational environmental 

dose. 

 MEMBER CLAWSON: Okay. That is all 

I wanted, to make sure we weren't losing focus 

on that. Thanks. 

 DR. ULSH: If I could ask, just for 

a point of clarification when we are excluding 

neutrons, I assume what we are talking about 

here is not necessarily the integrity of our 

neutron records but rather the methodology -- 

 MR. FITZGERALD: Sorry, yes. 

Right. I'm glad you raised that because the 

context of how we carved out the neutron issue 

is exactly, that is not the integrity of the 

measurement so much as how the dose 
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reconstruction or estimation would be done, 

based on the neutron dosimetry. Yes. 

 CHAIR BEACH: Well, now, I don't 

want to, I want to make sure that we are clear 

on what we are actually closing and the 

original matrix item was 18, adequacy of the 

external dose records, and 19, integrity and 

completeness of external dose records. 

 MR. FITZGERALD: Right. 

 CHAIR BEACH: And that is it, at 

this point. 

 MR. FITZGERALD: Yes. The context, 

again, is this is something that is standard 

for the Board to review and investigate 

estimate support. And this was the approach 

that we brought to the Work Group which 

approved the approach when we did the sampling 

and these are the results. Now, the Work 

Group has the discretion to ask us to do more 

but this is as far as we have gone. 

 CHAIR BEACH: Well, barring any 

other discussion, I guess we will consider 
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that closed. Brad, are you comfortable with 

that? 

 MEMBER CLAWSON: Yes, I just wanted 

to make -- 

 CHAIR BEACH: I know we don't have 

Bob and Paul to -- 

 MEMBER CLAWSON: I just wanted to 

make sure that the environmental, -- 

 CHAIR BEACH: Yes, we will get to 

that one. 

 MEMBER CLAWSON: -- that will be 

coming out later on. 

 CHAIR BEACH: Yes. Okay, silence. 

 Then that moves us to the next item 

for discussion and that would be item six, 

stable tritium compounds. 

 MR. ELLIOTT: But before you go 

there. 

 CHAIR BEACH: Yes? 

 MR. ELLIOTT: This is Larry. Could 

you state for the record how you close that 

out for me? How is it closed? Is it closed 
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because NIOSH did something. Is it closed 

because SC&A concedes the point or what? 

 CHAIR BEACH: I guess it is, in my 

terminology, and I don't know how to 

officially do that, it is closed because what 

we asked SC&A to do from a Work Group 

standpoint was to look at the work that NIOSH 

did and they concluded that there was no 

evidence that there was a problem with the 

external dose reconstruction. That is from my 

view. 

 MR. ELLIOTT: Thanks. That helps 

me understand how you see it closed. 

 MR. BUCHANAN: The external dose 

records. 

 CHAIR BEACH: Records. Thank you. 

 Let me finish that comment. And we all agree 

with that so -- 

 MR. FITZGERALD: Well, for 

clarification sake, it wasn't a contention so 

much because it is something that I think the 

Board has always asked SC&A to do is look at 
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the reliability of the data. 

 CHAIR BEACH: Correct. 

 MR. FITZGERALD: In this case, the 

sampling was the approach to do that. And 

that is it. You know, it wasn't disagreement 

on that. 

 CHAIR BEACH: Yes, and the only 

other thing we could do is ask you to do 20 

more and see how that turns out. 

 MR. FITZGERALD: Well, I mean, 

there is different ways to skin a cat. But 

you know, given the feedback from the workers 

and given the review of the databases, I think 

we felt confident that with this sampling that 

we could come to this conclusion of an 

external database. 

 So, -- 

 CHAIR BEACH: I agree. All right. 

 Now, are we ready to move on? 

 MR. FITZGERALD: Yes. 

 CHAIR BEACH: All right. So, we 

are moving into issue six, stable tritium 
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compounds. And I believe, Joe, you are going 

to lead that discussion? 

 MR. FITZGERALD: Yes and carefully. 

 I have basically extracted pretty 

much the status from existing documents. I 

think, you know, we haven't really had a 

chance to articulate this issue in Work Group 

discussions before. So I want to go ahead at 

least for the benefit of everybody here and on 

the phone, just kind of walk through where we 

have been and where we are now and set it up 

from there. 

 So, I ask your forbearance. I am 

going to do a reading to make sure I don't get 

off track here. 

 "In its original evaluation report, 

NIOSH assumed that most of the tritium 

exposure at Mound was related to the uptake of 

tritiated water, HTO, which was effectively 

monitored with reliable dose assessments 

starting in 1957." This comes from the SC&A 

statement in the issues matrix. 
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 "The prevailing internal dose TBD 

applies a correction factor to doses from 

MESH, so they will reflect the current NIOSH 

tritium dose assessment model. The ER states 

that the quantity and quality of available 

tritium urinalysis results are sufficient for 

estimating maximum dose or to alternatively, 

precisely estimate doses." 

 SC&A, in the SEC issues matrix, 

this was a response from last February, and 

this is our statement, the ER assumes tritium 

uptakes are from tritiated water and does not 

include a discussion on the potential for 

exposure to other tritium compounds. And what 

we are talking about essentially is tritides 

and organic tritium, two key examples. It 

further observes that there are no bioassay 

data from 1947 to '56, although tritium was 

handled during that period. So right from 

matrix. 

 Okay, in its July 5, 2008 response 

to the matrix, NIOSH indicates that as long as 
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records are available for tritium bioassay, 

doses can be bounded, regardless of the form 

of material, whether it is tritides, HTO, 

whatever. 

 It further notes that various Mound 

databases contain over 200,000 individual 

tritium bioassay records. And it also quotes 

Meyer. This is from the Meyer document, "That 

the program, the longest longevity at Mound is 

the tritium program." 

 Now, with respect to STCs, stable 

tritium compounds, NIOSH indicates that the 

technical basis document will be revised to 

include conditions for applying the stable 

tritium compound technical information 

bulletin, i.e., OTIB-0066, which applies OTIB11. 

 A Working Group meeting held on 

July 14th of last year did not address this 

matrix issue but it was acknowledged in other 

discussions at how OTIB-0066 is to be applied. 

 It is not to keep the not yet clearly defined 
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and this is going back a year. So that may 

have changed but that was kind of where we 

were at that point. And that "case-specific 

information suggesting potential exposure is 

not common." 

 A special technical meeting was 

held on this issue in a secure location on 

July 15, 2008 to address this issue. It was 

agreed by the Work Group members present, I 

think it was Brad, you were there, and Bob 

Presley, NIOSH and SC&A that a further roadmap 

review of STCs or stable tritium compounds was 

warranted, as well as a NIOSH demonstration of 

how dose estimation would actually be 

accomplished on an individual worker basis. 

And this would be based in part on a list of 

implementation questions that we provided at 

that meeting to Brant and the other 

participants. 

 And frankly, these stand as the, on 

this particular issue, as the outstanding Work 

Group requested actions on the issue. And 
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this dates back to that meeting. 

 Although STCs were not discussed at 

the Work Group's October 24th meeting, this 

was the last meeting, SC&A provided the 

advisory board at about the same time, a 

review of OTIB-0066. This is part of the 

procedures review and that was provided on 

November 25, 2008 that makes a series of 

findings and, as provided in excerpts, just a 

few bullets that were included in that review 

of OTIB-0066. 

 One comment was the types of STCs, 

the quantities handled, time periods of 

potential exposures, and the physical behavior 

of the tritium compounds in the environment 

must be known to effectively develop and apply 

OTIB-0066. A second comment was OTIB-0066 

does not ensure that resultant doses are based 

on adequate monitoring data. 

 Although urinalysis, the basis for 

application of the models outlined in OTIB0066, there is no guidance provided on the 
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interpretation of urinalysis results and its 

technical shortfalls. Effective methods for 

personnel and workplace monitoring were not 

implemented for STCs during Mound operations. 

 And a final bullet, again, from our 

comments in OTIB-0066, OTIB-0066 provides no 

guidance on how to distinguish between intakes 

of STCs, elemental tritium, and/or tritiated 

water, which occur simultaneously or overlap 

at Mound. In other words, you do have an 

environment where you do have all the above 

available for exposure and that is something 

that we feel is a limitation to what we 

understand is the implementation of OTIB-0066. 

 Among SC&A's recommendations was 

that characterization of the potential tritium 

exposure at a facility including SECs is 

critical to the application of models in OTIB0066 and must be documented more fully. 

Claimant favorable assumptions can't be made 

in the absence of this information. 

 April of last month we issued a 
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white paper entitled response to modeling of 

intakes for special tritium compounds that 

more or less conveyed a lot of these same 

findings that were provided in the review of 

OTIB-0066 but perhaps was more specific to the 

Mound circumstances. 

 And additional considerations 

provided in that review include reference to a 

statement that individuals exposed to STCs can 

be identified through individual rosters and 

employees working in tritide areas at Mound. 

So, we did understand that, as Brandt has 

already indicated, that there is rosters of 

employees, I guess, 12 is the number you 

mentioned that apparently are available at 

Mound. So we did understand that and included 

it. 

 In terms of our bottom line at this 

point in time, and again, this is with the 

white paper submitted and everything, we think 

there is two critical SEC related questions 

that remain for the Work Group. One is 
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whether a boundary model can be developed with 

the compounds handled at Mound. And again, we 

have the issues that we stated for OTIB-0066. 

 And two, if the necessary site-specific data 

are available to apply the model development. 

 If a bounding conceptual model can 

be developed for the first issue, then it 

would still be necessary for "proof of 

principle purposes" for NIOSH to demonstrate 

that its model can be applied to Mound workers 

with sufficient accuracy by indicating one, 

and this is in the white paper, to whom the 

model will be applied. And I think it sounds 

like there is some progress on that front. 

Two, how NIOSH will recognize exposures to 

special tritium compounds. And there is a 

number of compounds that certainly exist at 

Mound. It is one of the more complex sites. 

Three, how results below the minimum 

detectable concentrations will be handled for 

these compounds. Four, how they will 

differentiate bioassay results with tritiated 
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water versus organically bound tritium and 

special metal tritides. Five, what critical 

organs will be assumed for the different STCs 

that I just mentioned. Six, how NIOSH would 

be identifying exposures to stable tritium 

compounds in the absence of tritium bioassay 

data. 

 In this case, we are talking MESH 

has only tritium dose based on HTO prior to, I 

believe, September of '81. So the question is 

how would you certainly do this before then. 

 And then finally, what assumptions 

will be made in the absence of critical 

modeling data and parameters. And maybe one 

of the key ones, of course, is solubility of 

specific compounds, but there is other 

parameters as well. Certainly, one of them is 

particle size. I think we discussed that. 

That is one of the issues we discussed. 

 Finally, these, and we are calling 

these proof of principle issues, these proof 

of principle issues are not merely site 
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profile issues because, in our view, the 

validity of a proposed model as a dose 

reconstruction approach stands not only on the 

technical merits of its conceptual basis but 

also on the feasibility of how it is applied 

to site-specific circumstances. 

 On that basis, you know, we still 

don't view OTIB-0066 at this point as having 

been demonstrated as defining an upper bound 

with tritide doses at Mound. That is not to 

say it cannot be demonstrated but hasn't been 

demonstrated at this point, in our view. 

 So that is pretty much where we are 

and where we have been, well, I guess the last 

seven or eight months. 

 CHAIR BEACH: Are you ready? 

 DR. ULSH: I'm ready. 

 CHAIR BEACH: Thanks, Joe. 

 DR. ULSH: Well, not surprisingly, 

I guess, I do have a couple of thoughts on 

this. With regard to the special tritium 

compounds at Mound, you have to differentiate 
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based on the behavior in the body. I mean, 

obviously, we are all familiar with tritiated 

water, which tends to leave the body rather 

quickly and deliver pretty low doses. 

 Some of these special tritium 

compounds, in particular, the metal tritides, 

are less soluble than tritiated water, which 

means that they tend to stay in the lungs 

longer or the respiratory tract longer. And 

the most insoluble of these tritides can 

exhibit type S or even lower solubility but it 

is not infinite. 

 And we are certainly aware of what 

tritides are in use at Mound. We have 

compiled that information. As Joe said, we 

have to talk about this carefully because some 

of this information is sensitive. And I think 

it is also important to point out that a metal 

tritide is not necessarily a metal tritide, is 

not necessarily a metal tritide. In other 

words, there is differences between different 

types of metal tritides. 
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 For the least soluble of the metal 

tritides, and this is where, I guess, my first 

point of difference with SC&A, in terms of I 

don't think it is necessarily critical to 

identify which metal tritides we are talking 

about. What is important is to identify the 

solubility behavior. I mean, if we want to 

call it tritide X, tritide Y, and tritide Z, 

as long as we are all understanding what the 

solubility that goes along with that, that is 

the important point for dose reconstruction. 

 Now, can we go to an appropriate 

location and talk about the exact identities? 

 Sure, we can. And I suspect that some of you 

already know what they are anyway. But with 

regard to the least soluble of these tritides, 

it was a very small program. We have 

interviewed former workers who were directly 

involved with this issue at Mound and they 

have given us the list of names. So, Joe, it 

wasn't exactly a roster of people but it was 

the names of the people that were involved in 
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the program as provided to us by former 

workers. So, it is a list of the people who 

could have been exposed to this particular 

least soluble tritide. 

 And for those people, we proposed 

to do just like we do in any other situation 

where there are a number of possible 

solubility classes, and that is to add them to 

the mix. So let's say one of these -- I will 

just throw a dozen out there, although I can't 

swear that it is 12. It might be 13 or 10. I 

don't remember exactly. 

 If one of these people comes in as 

a claimant. And if they have a cancer in a 

respiratory tract or a lung, then we are going 

to apply tritides that would probably give you 

the most claimant favorable organ dose. For 

any other organ, it would not be the claimant 

favorable choice. And then there are a 

separate class of tritides that are less 

soluble than tritiated water, certainly, but 

they don't approach the insolubility of that 
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particular one. 

 For those, you know, of 

intermediate solubility, they had more widespread use. More widespread exposure 

potential, and we propose to do that, just 

like we do at any other site. That would be 

among the universe of potential forms of 

tritium that they could have been exposed to. 

 And it is important to note that, 

well, it is our position that if you could 

have been exposed to tritides, you were on 

tritium bioassay. 

 So, you might want to talk about 

that a little more but that is our position. 

So, if you have tritium bioassay, you can just 

model it with any of the applicable solubility 

classes. 

 Now with regard to that highly, the 

least soluble of the compounds, it is not like 

a situation where like, Brad, that you had 

talked about earlier where the crafts people 

could have jut wandered through the area and 
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been exposed. This was confirmed to us by 

several former workers. This program was very 

tightly controlled. It was performed in 

particular locations that were access 

controlled. You had to have a clearance to 

even get in the door. People did not just 

wander into this room. And it was cleaned up 

by the researchers who were actually doing the 

program. So for that particular compound, I 

don't think it is an issue that you could have 

just had roving people or anyone wandering by. 

 That just did not happen. There was at least 

one incident of contamination but we know 

about that. We know who was involved with it 

and the exposures potentials are pretty low. 

 So, with regard to the seven 

questions that Joe laid out--and I think this 

is going to be the toughest nut for us all to 

crack here--it is our position that if we get 

to a point where a model can be developed and 

we could contend that a model has been 

developed in this OTIB-0066, then the question 
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becomes how do you implement it. And as I 

understand SC&A's position that under the 

sufficient accuracy guidelines, we would have 

to answer these seven questions. To whom a 

model would be applied, how you recognize 

exposure to special tritium compounds, et 

cetera. 

 Well, I would say that those are 

not SEC questions. Those are TBD questions. 

To whom the model will be applied? Well, that 

is an implementation question. And 

furthermore, I just stated how we are going to 

apply that model. For the intermediate 

solubility tritides, it is going to be 

everyone onsite could have been exposed to 

that material. So, that is the answer to that 

question. 

 MR. ELLIOTT: Everyone who was on 

a tritium bioassay program. 

 DR. ULSH: Correct. Correct. 

Sorry. Everyone who was on a tritium bioassay 

program, might have had that as a potential 
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form that they could have been exposed. 

 How we will handle the results 

below the minimum detectible concentration? 

The same way we handle it for every other 

bioassay result. There is nothing different 

here. 

 How we will differentiate bioassay 

results for tritiated water versus organically 

bound tritium special metal tritides, we 

won't. We will just treat that as one of the 

possibilities that they could have been 

exposed to. 

 What critical organs for different 

STCs? Well the critical organ is the lung and 

respiratory tract. Because that is why. They 

are less soluble than tritiated water, which 

means they don't leave the lungs as fast. For 

other organs, they deliver less dose than if 

it was tritiated water. 

 How we are going to identify 

exposures to STCs in the absence of tritium 

bioassay data. I would contend that you don't 
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have exposure to STCs in the absence of 

tritium bioassay data at Mound. 

 And what assumptions will be made 

in the absence of critical modeling data such 

as solubility? I am not aware of a situation 

like that. We know how to model with the 

least soluble compound. We know how to model 

the other compounds with standard ICRP models. 

 So, I don't see an SEC issue here. 

 If we want to get into the individual 

compounds and where and when it was performed, 

we can do that in the appropriate setting, 

which is not today or here. 

 MS. ROBERTSON-DeMERS: Can I ask 

one question? 

 DR. MAURO: Brant, this is John. 

Is it okay for me to ask a couple of questions 

right now? 

 CHAIR BEACH: Sure, John, go ahead. 

 DR. MAURO: Yes, what I heard is 

something that I wasn't aware of is that 

tritiated water is the limiting form of 
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tritium for all organs except the lung. 

 DR. ULSH: Well, the lung and the 

respiratory tract. 

 DR. MAURO: Well, right. That is 

what I meant. 

 DR. ULSH: I would be careful there 

John. Basically, I am saying that those other 

organs in the body would be higher if you 

assumed tritiated water than if you assumed 

one of these metal tritides, for any organ 

except the lung and respiratory tract. 

 DR. MAURO: And that is true for 

organically bound tritium also? 

 DR. ULSH: I'm not sure. 

 DR. MAURO: Well no, the reason I 

raise the question is because if that is the 

case, it does -- I understand where you are 

going. Basically what you are saying is for 

all workers that you are going to do dose 

reconstructions for that have a cancer other 

than a respiratory tract cancer, you will 

simply assume the bioassay results that you 
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are looking at are based on exposure to 

inhaled tritiated water. But it sounds like 

maybe it is a little more complicated when you 

are dealing with organically bound tritium. 

It may not be that straight forward. 

 DR. NETON: But John, this is Jim, 

it doesn't really matter. I mean, we could 

run all possible scenarios and pick the 

highest dose. I mean, that is no different 

than we do for any S, W, S -- F, or Y type 

analysis. 

 DR. MAURO: I understand. Now, 

this case, the second question I have is if 

you were to, because of lack of knowledge or 

because you don't want to enter the world of 

classified information, you go with the most 

bounding assumptions. And let's assume that 

right now OTIB-0066 provides for that. That 

is, you know, in other words, whatever the 

limiting form is, you could assume that and 

place an upper bound on the dose to the 

respiratory tract or whatever organ it might 
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be of concern. 

 Now, it is my understanding that 

there is only a very, very small number amount 

of the tritium handled at these other 

facilities that were tritides or perhaps 

organically bound. The vast majority is the 

tritium handled at any of these facilities was 

tritium gas or tritiated water. 

 Now that brings me to my question. 

 Is there a plausibility issue here. That is, 

would you be assigning to large numbers of 

workers doses that were not plausible, if you 

were to take that tact? That is, we will just 

default to the worst possible form of a 

tritide and assign that to all of the people 

where we have some question or there might be 

some question as to when and where and how 

much tritides you might have been exposed to. 

 Is that an issue that needs to be 

discussed -- a plausibility? 

 DR. ULSH: Well, I have some 

thoughts on that, John. First of all, I don't 
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think we are talking about large numbers of 

workers, because tritides would only turn out 

-- or organically bound, would only turn out 

to be an issue when you are talking about lung 

and respiratory tract cancers. So that it is 

a smaller subset of the claimants. 

 And furthermore, it would have to 

be of those people with lung and respiratory 

tract cancers, it would have to be someone who 

is not already compensated. And as you 

probably know, we already compensate threequarters of those anyway. 

 DR. MAURO: Okay. 

 DR. ULSH: And then finally, for 

that remaining 25 percent of those particular 

types of cancers, would the doses be so high 

that it is implausible? I don't think so. 

They are going to be large, sure, but I don't 

think it is going to be implausibly large. 

 DR. NETON: And John, this is Jim, 

I agree with what Brant said. I also point 

out, you know, we do this all the time with M 
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and S. 

 DR. MAURO: Well, you know, with M 

and S, we very often are in a circumstance 

where there is a very real possibility that 

that is what you are dealing with. In other 

words, the uranium, I thought you were still 

talking uranium. Very often, you are not 

quite sure what the best form is and it is 

plausible that everyone might have been 

exposed to M or S. 

 In this circumstance, we know that 

everyone was not exposed to tritides. And 

that is where my question -- 

 DR. NETON: I would disagree. If 

you take a uranium foundry and we are applying 

M and S in a foundry, chances are it is all S. 

 But we will default to M to get the dose 

higher because it is possible that person was 

exposed. 

 DR. MAURO: Oh, okay. I guess I 

was under the -- you know, I am so used to the 

U-308 issue, it is sort of ambiguous. 
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 DR. NETON: Right but think about 

it. I mean, we will default to M, even in a 

uranium foundry with oxides because it is 

possible that the person could have been 

working some other job location, some other 

situation. And I would argue that if it is 

implausible, we would assign a different dose. 

 DR. MAURO: No, I hear what you are 

saying. So you are saying -- well, you are 

saying that you do assign perhaps 

unrealistically high doses at uranium 

foundries by assuming M and S. You know, 

whatever is limiting. You have been doing the 

same thing here. 

 DR. NETON: I think if there is two 

plausible exposure scenarios and we can't pick 

between one because we lack information, we 

will pick the one that gives the higher dose. 

 DR. MAURO: So when you lack 

information about whether the person -- see, I 

guess in the situation like the metal foundry, 

you are saying that you will assign, even 
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though you are likely dealing with type S, you 

will assign an M if the person has a cancer 

that would give you a higher dose there. 

 DR. NETON: Absolutely. 

 DR. MAURO: Now, you would argue 

that the reason you are doing that is just to 

make sure that you don't underestimate the 

person's dose. 

 DR. NETON: Right. 

 DR. MAURO: But you know, someone 

could argue that well, is it possible that 

that person was in fact exposed to type M, 

even though it was a foundry. Were there 

activities going on there where there might 

have been M. I guess we haven't had this 

discussion before but if it is not plausible 

that the person was exposed, you know, we 

really, that is an issue, something that I 

think should be on the table as part of this 

discussion. 

 When the conservative assumptions 

that are applied get to the point where you 
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don't meet the plausibility requirements of 

Part 83, and I think that goes to the heart of 

well certainly not only the tritium tritide 

issue but even the matter you brought up 

before on the foundry. 

 DR. ULSH: Okay. John, I think if 

we were to come to you and say this least 

soluble of tritium compounds, we are going to 

apply that to everybody, even though it was 

only maybe a dozen people, we may have more of 

an issue to talk about here. But there are, 

as you know, there are a variety of tritides 

that were handled at Mound, other than that 

one. And by the way, that is why we are 

saying only that particular group of people 

has that entered as a possibility but for 

these intermediate solubility tritides, those 

were more widespread and I think there is more 

of a potential, especially during the D&D 

years, for instance, to be exposed to that. 

 Was the vast majority of the 

tritium handled at Mound HTO? Yes, sure. But 
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I think there is a reasonable possibility that 

people might have been exposed to these 

intermediate solubility tritides. 

 DR. MAURO: So you are saying that 

the approach you are taking may not be that 

implausible. That is, at any given time, the 

way Dr. Ziemer mentioned is that if you have a 

person and you are asking yourself the 

question, granted that collectively the 

exposures were to tritiated water but for any 

given person at a given point in time, you 

really don't know. Then it is plausible that 

he might have been exposed to one of the let's 

say the more insoluble tritiums. 

 Basically, I am taking your 

position right now. I am trying to find the 

virtue of your positioning. So what I am 

hearing you saying is that yes, even though 

collectively the total number of curies that I 

might have moved through as tritides is an 

extremely small fraction of the total amount 

of tritium that went through as tritiated 
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water. For any given person at any given 

point in time, one could argue that well, it 

is possible at that point in time for that 

particular sample, that is a result of an 

exposure to one of the less soluble forms of 

tritium and, therefore, it becomes plausible. 

 I just sort of like worked my 

through it to convince myself that your 

position is reasonable. 

 MR. ELLIOTT: John, this is Larry 

Elliott. If I were to answer your question I 

would say that we would be implausibly high if 

we were going to apply the highest insoluble 

tritide to everybody that was in the tritium 

bioassay program. That would be implausible 

because we know from the interviews and from 

the records that only 12 or so people were 

involved. That would be implausible to apply 

that to everybody in the bioassay. 

 DR. MAURO: Okay. 

 MR. ELLIOTT: But what we are 

saying here, we think it is plausible to apply 
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this dose for the immediate insoluble tritides 

because we feel that they were widespread and 

we can't place people in proximity to them. 

 DR. MAURO: That helps a lot. I 

didn't realize you were making almost like a 

three-tiered distinction. 

 Regarding the first tier, these 12 

individuals, for those individuals is this 

something that goes behind the sensitive 

information window? In other words, when you 

picked those people and the reasons you picked 

those people, this is something that, is that 

information that has to be held as sensitive? 

 DR. ULSH: The reason that we 

picked them? Is that what you asked? 

 DR. MAURO: No, when you picked 

them. I guess you just picked them and said 

these are the people but the rationale for 

picking them and not someone else to be 

included in that group. I guess the way you 

get there, though, is true knowledge of 

sensitive information. 
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 DR. ULSH: The rationale is the 

interviews that we conducted with former 

workers, that which has been provided to the 

Working Group. 

 DR. MAURO: So all of this can be 

discussed in an open setting. That is where I 

am headed. 

 DR. ULSH: Depending on what you 

mean by all of this, yes. 

 DR. MAURO: Well, I mean how you 

picked the 12 people and that yes, your 

justification for these 12 people being 

treated in one way as opposed to these other 

people being treated another way and the 

justification for making that distinction. 

 MR. FITZGERALD: The framework. 

 DR. ULSH: Yes. Yes, the 

supporting documentation has been provided. 

That is our interview notes. Of course there 

are Privacy Act considerations. 

 DR. MAURO: Oh, well, yes. When I 

meant sensitive I meant more by way of 
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classified information. 

 DR. ULSH: Yes, these were people 

who were involved in assessing doses from 

these particular compounds and, the people 

that we interviewed, and they provided a list 

of workers who were directly involved with 

this work. So that is -- 

 MR. CHEW: You want me to talk a 

little bit about the program? 

 CHAIR BEACH: I think Kathy has 

been waiting to say something. 

 MR. FITZGERALD: Yes, we can switch 

gears and let Kathy and Bob comment as well. 

 MS. ROBERTSON-DeMERS: Okay, can I 

clarify something for you? The absence of 

tritium bioassay data, what we meant was the 

fact that only the dose data was available 

prior to September '81. 

 MR. SHARFI: Both the dose -- back 

to the actual urinalysis. 

 MS. ROBERTSON-DeMERS: Is that what 

you guys are doing? 
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 MR. SHARFI: I'm sorry? 

 MS. ROBERTSON-DeMERS: Is that what 

you guys are doing, is taking that dose and 

converting it back to the urinalysis -- 

 MR. STEWART: The dose 

re-constructors, no. We are simply assuming a 

very large MDA assigned missed dose. 

 DR. ULSH: Well that might be a PER 

that is coming. Keep in mind, Kathy, that the 

Mound TBD was one of the first ones that we 

did. And it predates OTIB-0066. So, that 

might be part of the reevaluation that we do 

when we go back and look at it. 

 MS. ROBERTSON-DeMERS: I have got a 

couple of other questions. 

 MR. FITZGERALD: Go ahead. 

 MS. ROBERTSON-DeMERS: How do you 

know that you have identified the most soluble 

form of tritide when there is such limited 

studies out there on solubility of these 

compounds? 

 MR. CHEW: It's insoluble. 
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 MS. ROBERTSON-DeMERS: The 

insoluble. Sorry. 

 DR. ULSH: There have been direct 

studies of the particular compounds that were 

present at Mound and the solubility of those 

compounds. 

 MS. ROBERTSON-DeMERS: All 35? 

 MR. CHEW: Kathy, can I speak a 

little bit for the program, and recognizing a 

sensitivity, Kathy, I will just go over a 

little bit about the program itself. 

 There was a directive from the 

Department of Energy that asked Mound 

Laboratory to go ahead and try to find some 

metals that would be for tritides there would 

be an ability to store long-term for tritium. 

 That was a real, we know that. Okay? 

 And so with this, Mound took that 

directive and there was quite a large fund to 

try everything. That is why the news came up 

and said well gee, it looks like as many as 40 

or 50. Yes, they tried. Actually, they made 
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very small gram samples of those particular 

tritides. All right? 

 It really boils down to about 10 or 

20 that we really focused in on. All this was 

done in a glove box operation. Let me just 

describe to you the process itself. 

 Actually, tritide is a small sample 

of this particular metal in a case like this 

would be and put it in a jar and basically had 

lines tied to it. And at a normal frequency, 

the basically open the stop cock to determine 

what the outgassing is. And if outgassing was 

high, then obviously it was not going to be 

good enough for the long-term storage. That 

was the term. 

 Well, believe it or not, a majority 

of the metal tritides are fairly soluble. 

They outgas very quickly. And the reason for 

that is that there is a radiation damage, 

believe it or not, from the data, in some of 

the metal itself. It just broke up the 

crystal structure. I actually had the chance 
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to even see that first-hand. We applied and 

we had a particular metal, we tritized it. It 

turned black. It turned black because of 

radiation energy immediately out there. So 

obviously, that is not good. 

 So from that standpoint, that is 

what the program is all about. Now, bear in 

mind when we come back to the story, these 

particular, especially the ones that were 

stable tritide, they were handled like 

particulars. Mound has a very good history of 

understanding how to handle particular glove 

boxes. This was a glove box operation. These 

were handling glove boxes. 

 So therefore, number one, the 

potential exposure was only due to the very 

fact that either a procedure or something went 

wrong with that particular experiment when 

they were doing it. And that is why it was 

limited to only a very few people handling the 

stable or the real stable tritides. 

 The stability of those tritides and 
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those particular compounds are still sensitive 

information because they would be of valuable 

information to the program itself. So bear in 

mind, that several times when there was a 

small particular incident of losing a few 

small amount of particulates of it, the swipe 

samples were taken if there was a particular 

incident and they were always asked the 

question about the person potentially walking 

into the room here. Brant has already 

expressed it, these were classified projects 

and those rooms were locked. They were type 

red, I think that is what the distinction was. 

 MR. SHARFI: Yes, they were key in 

lock. You can't just walk in there. 

 MR. CHEW: And because of the 

sensitivity. 

 So, I think to answer the question 

and John, for you, I think we can pretty much 

fully identify. We have the information from 

both the classified appendices to the 

document. We know which tritium compounds 
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were handled and in what particular room. And 

they have identified a particular period. And 

during the basis of the interview, we were 

able to clearly identify who specifically was 

handling of -- I think one specific stable 

isotope that was of primary concern. 

 DR. MAURO: Mel, this is John 

again. 

 MR. CHEW: Yes, sir? 

 DR. MAURO: The OTIB-0066 -- is 

Joyce Lipsztein still on the line? If she is 

not, we reviewed OTIB-0066 favorably. We only 

had one minor comment on a dose conversion 

factor for organically bound tritium. But 

Kathy has raised a question that I think goes 

to really to Joyce and that is, you know, 

based on our review and Joyce is pretty close 

to this issue working with ICRP, her finding 

when she reviewed the models developed, the 

generic models presented in OTIB-0066 for 

tritides, were favorable. That is, she felt 

that you know, given you had a measurement in 
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urine and given you knew what the person 

inhaled, what form he inhaled of the tritium, 

you could reconstruct the intake from the 

bioassay results. 

 However, Kathy, I think you raise 

an important question that maybe goes back to 

OTIB-0066. That is, are there, in other 

words, is OTIB-0066, when it was developed, 

did it capture, the, I would say, the most 

stable versions? If that is the case, then I 

think we are okay. I mean, we are okay with 

OTIB-0066, in terms of the model. But it 

sounds like there is some question and that is 

why I asked if Joyce was still on the line. 

There may be some forms that are even more 

stable than those that have been treated in 

OTIB-0066. 

 DR. BISTLINE: This is Bob 

Bistline. I would like to get into the 

discussion here. 

 DR. MAURO: Okay. 

 DR. BISTLINE: We had some 
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discussion with another site that also handled 

tritides and handled five different forms of 

tritides. And they tried to do some 

solubility studies and also some absorption 

studies and so forth. And the project got 

canceled and they said they couldn't. And 

these people are authorities on tritides. And 

they said that there is really no good 

information or very little information 

available on solubility and absorption 

capabilities. And they have handled and they 

handle it right now. And the question I 

raised was, was with regard to the absorption 

and the diffusion and reactivity of tritium 

with metals that they come in contact with and 

especially for long storage. 

 DR. NETON: Well, keep in mind 

tritium has a fairly short half-life. 

 DR. BISTLINE: Tritium has a short 

half-life. 

 DR. NETON: And so its solubility, 

it can be limited by its radiological half-
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life. 

 DR. BISTLINE: It can. That's 

right. 

 DR. NETON: Well, it is. 

 DR. BISTLINE: It is. It is. 

 DR. NETON: It does not have a 

solubility class that is longer than it's what 

ten-year half-life? 

 DM. CHEW: 12.226 years. 

 DR. NETON: So therefore by 

definition, the worst case solubility of 

tritium is 12 years. 

 DR. MAURO: Yes, that is true. Is 

that what you want, by the way, approximately, 

when you are at your upper bound for -- 

 DR. NETON: I don't know. I would 

guess if you looked at S, class S, it probably 

is somewhere -- I don't know. 

 DR. MAURO: Okay, but I hear where 

you are going with that. 

 DR. NETON: Where I am going is 

there is a practical limits of the dose that 
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tritides can deliver. 

 DR. BISTLINE: Yes, I agree on 

that. But you know, we had a tritium issue at 

Rocky. 

 DR. NETON: Yes, it is somewhere 

between 12 years and a lot less than 12 years. 

 But it can be bound. 

 DR. BISTLINE: But if you bound it 

with 12 years, then I can agree. 

 CHAIR BEACH: Well back to John's 

comment on OTIB-0066, I thought there were six 

findings and I guess I am not clear on where 

John is saying there wasn't any findings or 

issues with OTIB-0066. So, -- 

 MR. FITZGERALD: Well there were 

findings on the application of OTIB-0066. 

 DR. MAURO: You know what? I am 

sorry. I didn't want to mislead anyone. Our 

generic findings on OTIB-0066 were that it was 

favorable. 

 MR. FITZGERALD: The conceptual 

model was favorable. 
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 DR. MAURO: -- we did comment. 

 CHAIR BEACH: It said the model was 

but there were still issues with how -- 

 DR. MAURO: Exactly, there were 

issues with implementation. 

 CHAIR BEACH: How it was going to 

be applied. 

 DR. MAURO: Exactly. Exactly. 

 MEMBER ZIEMER: This is Ziemer. 

Can I make a comment? 

 CHAIR BEACH: Sure, Paul. 

 MEMBER ZIEMER: I think I mentioned 

this before but perhaps worth repeating. Many 

of these things that we call tritium compounds 

are not true compounds. They are tritium 

absorbed on something. Tritium tritide is an 

example. It is mainly absorbed in the metal 

matrix. So the tritium outgasses is almost 

constantly at any temperature, certainly more 

at elevated temperatures, but the solubility 

issue, in my mind, becomes a little bit 

confused when we are thinking about it as the 
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solubility of a metal compounds. 

 I don't know if John Mauro if any 

of your folks can clarify. Are you talking in 

terms of the metal compounds as a compound? 

Solubility of a metal? 

 DR. MAURO: When we reviewed OTIB0066, there were certain biokinetics of the 

clearance from the lung. And there was an 

upper bound value for the most soluble form, 

the least soluble form of tritium. And as I 

recall, it had to do with the breakdown of the 

particle itself in the lung. Eventually, the 

particle begins to break down and the tritium 

leaves for the most stable form of his 

tritides. Now, there is probably, I believe 

there was a continuum though of the kind of 

thing you just described. There are other 

forms where the tritium more readily leaves 

the metal matrix. But the most -- 

 MEMBER ZIEMER: Yes, using a matrix 

is not really bound like a Q compound, I 

think. 
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 DR. MAURO: Yes, I tell you I did 

not look into it from that respect; in other 

words, what was the chemistry of the way in 

which the tritium was bound. I think it was 

more of an empirical issue. That is, the ICRP 

folks looked at it and so did Joyce. It 

really had to do with the clearance, the rate 

at which it was cleared. 

 MEMBER ZIEMER: Right. Regardless 

of how it came off. Right. 

 DR. MAURO: Yes, but how it -- 

exactly. 

 MEMBER ZIEMER: Yes, okay, I am 

with you. 

 MR. CHEW: Paul, this is Mel. You 

are absolutely correct. When you actually 

have to make a metal to have the tritium 

pulled onto, you need to have to do it in like 

a vacuum deposition. Okay? That is an 

example of how you would actually make a 

tritium target for an accelerator. That is 

for the example where it really holds on. 
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 But you are right, these are the 

tritium compounds which will continue to 

outgas. As a matter of fact, when we 

discussed it with the workers, they said when 

you actually saw it exposed to any moisture or 

any air, even some of the more stable ones 

that they thought would have an initial 

outgas. 

 MEMBER ZIEMER: Yes, in fact, I 

think the tritium continuously exchanges with 

the hydrogen in the air in some of these. 

 MR. CHEW: That is correct. 

 MEMBER ZIEMER: Yes. 

 MR. KATZ: Kathy? 

 MS. ROBERTSON-DeMERS: I just have 

one comment and that is that Joyce was not 

privy to all of the information, obviously, on 

tritides when she did that analysis. And that 

is why we followed up with a Mound specific 

report. 

 DR. ULSH: Well, okay but to answer 

your earlier question Kathy, how do we know 
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the solubility of all of the metal tritides -- 

 Go ahead, Mel. You probably would 

do a better job than I would. 

 MR. SHARFI: When we wrote the 

Mound STP TBD, we specifically had inherent 

knowledge of what they worked with and what 

were the metals that disassociated their 

tritium sloped. So, we were I guess privy to 

information to specifically target our 

modeling based on the material we worked with 

at Mound. 

 Now, I mean, if you get outside 

Mound I'm sure other sites may have done other 

work but our target for developing the Mound 

metal tritide TBD was specific for the 

material and inside knowledge of what we 

worked with. And I probably can't go too much 

more into that knowledge but so we had a very 

clear knowledge of which metals would result 

in some of the longer tritium retention and 

that is where we specified our work into. 

 MS. ROBERTSON-DeMERS: And how did 
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 MR. SHARFI: That would be -- that 

is getting into that classified -- the people 

that actually worked that material, it was 

designed for particular needs. And those 

people who designed that material would know 

which holds tritium longer or shorter. 

 DR. ULSH: But I think you are 

talking past each other. You are saying you 

know what tritides were present at Mound. And 

Kathy is asking how do you know that there is 

not one of those tritides that is less soluble 

than the one we are talking about? 

 MR. SHARFI: Well, they made them. 

 I mean, there is a purpose to them. It is 

not that they just randomly had these -- 

 MR. FITZGERALD: Well, there is two 

issues, too. I think Mel explained earlier 

that you had lab or bench top concentration or 

activity levels -- and you had maybe a dozen, 

ten that might have been in a greater 

quantity. So you have two gradations. You 
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know, one is the solubility question and one 

is whether it was a tiny lab amount versus 

something that was being pursued further. So 

you know, there is different variables in 

there. 

 One thing that concerned me early 

on in this thing and again, I think this 

wasn't addressed in the ER. So just in terms 

of context, we just raised it as an obvious 

issue which you are familiar with but it 

wasn't treated for good reasons. But OTIB0066, as of last year, we asked Stu Hinnefeld 

this question, you know. What is the history 

of its application at the time? He said it 

never had been applied. It hadn't been used 

in dose reconstruction. I was wondering if 

you know that has changed or not. 

 DR. NETON: I don't think so. I 

think it has not been applied, to my 

knowledge. Mound would certainly be the place 

for it to be applied. There is other sites. 

 MR. SHARFI: -- I don't much about 
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 MR. FITZGERALD: Yes, well, this 

first came up at Savannah River as a question, 

tritides and at that time, I think OTIB-0066 

was still in the wings in all discussion and 

everything. 

 MR. ELLIOTT: But we have been 

consistent in saying that it is a site profile 

implementation issue and their site profiles 

have to be revised to address that. 

 MR. ELLIOTT: We haven't done that 

yet. 

 MR. FITZGERALD: Yes, I am not even 

going there. I am just saying OTIB-0066 as a 

means to model this. 

 DR. NETON: Yes, I am not sure why 

that is important, though. I mean, is OTIB0066 a valid means of assessing tritide dose. 

 That is, I think, the question. Whether we 

apply it or not is kind of -- 

 MR. FITZGERALD: Well, I guess the 

question it goes to though is -- 
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 DR. NETON: -- it's not irrelevant, 

but -- 

 MR. FITZGERALD: -- whether, you 

know, again, we raised the implementation 

issues in both the comments on 0066 as well as 

in this context is, you know, there is just no 

application that one can look at as a proof of 

principle. And I think that -- 

 DR. NETON: Well, wait, wait. This 

is a very simple TIB. And basically, I am 

looking at it right now. 

 MR. FITZGERALD: Right. 

 DR. NETON: It assigns the least 

soluble tritide compound to Type S. It says 

it is no slower or it does not go any faster 

than S. 

 MR. FITZGERALD: But Jim, the 

question that has driven this from last year 

is whether or not the specific data and you 

know, certainly what we are hearing today is 

the first time that, although we have had some 

hints, I guess earlier. But you know, the 
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first time we are actually hearing, okay, 

certain parameters who, you know, the three 

tiers, the who part might be answered. You 

can actually identify. That wasn't clear last 

year. 

 DR. NETON: Okay. 

 MR. FITZGERALD: The compounds in 

terms of being able to envelope the important 

compounds and of course, the question of 

importance is something that I think is being, 

I think has been sorted out to some extent. 

 DR. NETON: Right. 

 MR. FITZGERALD: And how one is 

going to, as an approach, distinguish between 

the different forms of STCs, I think I have 

heard that, too. 

 These are all parametric questions 

about whether or not OTIB-0066 would have the 

key ingredients to demonstrate. And when I 

raised the question last year saying, you 

know, these are very basic parameters. But if 

there is just no implementation of the model 
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and no guidance as to what the pieces are 

going to be, there was no -- 

 DR. NETON: I don't see this any 

different than Super S at Rocky Flats, to be 

honest with you. We developed a model that 

was defined, it was examined by SC&A and it 

clearly said it will bound intakes for Super S 

material. And that is what we proposed here. 

 CHAIR BEACH: Doesn't the Work 

Group need to validate site specific data with 

sufficient accuracy using -- 

 DR. NETON: Which site specific 

data are we talking about? 

 CHAIR BEACH: -- using OTIB-006? 

 DR. NETON: But the site specific 

data is we would apply either very insoluble 

or moderately soluble. We picked the most 

claimant favorable solubility class. 

 MR. FITZGERALD: But let me walk 

back because I think the analogy is a useful 

one, because we did get into OTIB-0049 and the 

validation, I think Joyce did a lot of work on 
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that, really focused on the autopsy data and 

showing that 0049 in fact was an upper bound 

for real cases. I mean, they are real cases 

pulled from various sites. 

 In fact, I think as I recall, there 

was a fairly upper bound case from Rocky, 

upper bound case with Hanford, and this whole 

thing, I think, came down to hinging on the 

fact that when you looked at the curve, there 

is no question that that factor of four, I 

think it was, was going to envelope the 

highest cases. 

 And I think that was the proof of 

principle in the sense that not only was there 

a good model but that model was validated 

against real data. I think in this case what 

we are saying is that we are in the same place 

of saying, okay, the equivalent of the OTIB0049 model is OTIB-0066. There is a model. 

 DR. NETON: Right. 

 MR. FITZGERALD: And we have looked 

at the model and conceptually, I think, 
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actually Joyce has spent some time with it and 

it, too, looks pretty good. But the second 

step that she took on OTIB-0049 which would be 

the equivalent here, is saying okay, you know, 

when you actually apply it to real cases, is 

it going to demonstrate an upper bound or not. 

 And I think when I asked the 

question last year has anyone used it, 

frankly, I wanted to cut to the quick and say 

well if you have applied it, then we can at 

least look at how the data was, the Moundspecific information was applied and we gained 

some confidence that not only did the concept 

hold true, technically, but the application of 

that concept to Mound data. 

 Now, if some of that data, if you 

could not have found -- of the workers who 

were throwing their hands up and saying, you 

know, we don't know who those people are. I 

mean, you know, we could take a guess but we 

really don't know that. And I would say that 

is kind of a challenge to the model because 
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you might have a model but you know, I mean, 

there is just the parameters that feed that 

model may not be available. 

 And so the proof of principle is 

can you actually identify the workers, 

identify the compounds, you know, so forth and 

so on. 

 DR. ULSH: So let me ask you this. 

 If we came to the Working Group and SC&A and 

laid sample dose reconstructions that used 

OTIB-0066, would that address your concerns? 

 MR. FITZGERALD: Well, I think that 

would be the proof of principle. Again, we 

don't have anything other than the concept, 

the model that seems to be conservative. What 

you are saying is encouraging because I think 

the pieces that would go into that model are 

available but you know, we haven't actually 

seen it demonstrated. 

 CHAIR BEACH: We would have to see 

it demonstrated. 

 MR. FITZGERALD: And the difference 
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with OTIB-0049 I think that really made the 

difference is not just the concept but when we 

actually saw the curve over the autopsy cases, 

that was the, to me that was the final word. 

I mean, there was no question that even in the 

worst cases, the estimation was going to be 

much more conservative. An upper bound was 

demonstrated on those. 

 DR. NETON: Well, we didn't make 

these numbers up, Joe. I mean, this is based 

on literature searches. I mean, the 

references are in here. 

 But I think you are right. We can 

certainly produce the -- 

 MR. FITZGERALD: But what is the 

equivalent? I mean, I don't disagree. 

 DR. NETON: Well, I think we found 

the equivalent. 

 MR. FITZGERALD: What is the 

equivalent for OTIB-0049? 

 DR. NETON: We don't have autopsy 

data for -- 
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 MR. FITZGERALD: Well, I know. I 

know but what would be the equivalency, the 

analogy to being able to show that this model 

would constitute an upper bound if you had the 

sufficient data? 

 DR. NETON: Well, I think the 

equivalency is to demonstrate that these 

compounds, the compounds that we have applied 

here that are based on documented literature 

search information adequately bound. And 

apparently, SC&A originally agreed that that 

was okay because this model was not -- this 

was a generic model to apply to special 

compounds of tritium. And we heard nothing 

back from SC&A saying that these weren't 

sufficiently bound. 

 DR. MAURO: Jim, that is true but I 

guess the information we are hearing now is 

that there might be -- 

 DR. NETON: Well, but see now -- 

 DR. MAURO: -- maybe the chemical 

forms or the forms of the tritium -- 
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same issues on our comments on 0066. I am not 

quite sure that -- 

 DR. MAURO: -- work toward our 

knowledge of tritiated compounds based on our 

knowledge and from working with ICRP 

investigation into this matter. It sounds 

like you folks got a lot more sophisticated. 

There are a lot more forms of tritium that are 

in play here and there may be forms that are 

more limiting. 

 But Jim, you had mentioned that in 

the end, if you go with just the radiological 

half-life and the clearance rate for the 

lungs, that places an upper bound certainly on 

the lung dose. And as I understand it, for 

any other organ, the limiting form would 

always be tritiated water. 

 MR. FITZGERALD: John? John, can I 

intercede? 

 DR. MAURO: Yes, sure. 

 MR. FITZGERALD: We have, all 
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along, since Savannah River, in fact when we 

first raised this issue as a part of the site 

profile review at Savannah River, had raised 

these very same issues and recognized that it 

is a generic issue, have expressed the same 

concerns every time tritides have come up. 

 DR. NETON: But that was before 

OTIB-0066 was written, Joe. Savannah 

River site profile -- 

 MR. FITZGERALD: But we provided 

comments on OTIB-0066 last year. 

 DR. NETON: I don't recall OTIB0066 saying it was not sufficiently 

conservative. I don't recall that comment at 

all. 

 MS. ROBERTSON-DeMERS: There were 

several questions in OTIB -- several findings 

in OTIB-0066 related to the orientation of the 

-- 

 CHAIR BEACH: I guess that is one 

of the things that I was going to bring up. 

 DR. NETON: Okay, well, so is this 
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 MR. FITZGERALD: Well, I don't want 

make it an OTIB-0066 meeting but we did 

comment on these issues. 

 DR. NETON: Yes, is this an OTIB0066 issue or is this a Mound issue, I guess? 

 CHAIR BEACH: Well, both of them 

come to play in my mind because OTIB-0066 -- 

 MR. FITZGERALD: I don't think you 

can separate it. I think it is a generic and 

a site specific. I think there is an overlap, 

quite frankly. 

 DR. NETON: Sure. 

 CHAIR BEACH: OTIB-0066 is being 

used here but we had a -- or SC&A's comments 

have never been talked about or reviewed by 

NIOSH. So that was part of one of my comments 

is to request NIOSH to address SC&A's comments 

to OTIB-0066. 

 MR. FITZGERALD: Yes, actually when 

we were asking for any data on, or any results 

from the application of OTIB-0066, we are 
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talking about DOE-wide or complex-wide, mainly 

because I think we were just interested in how 

the model would be applied, not even Mound 

specific. 

 CHAIR BEACH: Right. 

 MR. FITZGERALD: And so I think 

there is an overlap here. 

 DR. BISTLINE: Okay. So, there are 

site returns, people have worked for the site 

returns had potential. 

 MS. ROBERTSON-DeMERS: In addition, 

HT and HTO diffuse into material, which is 

where you get the problems in D&D. 

 DR. ULSH: Right and that is why we 

are going to apply those intermediate 

solubility tritides to pretty much everybody 

to handle those kinds of situations. 

 So given the answers that I have 

provided today to these seven questions and if 

we commit to providing you with sample dose 

reconstruction that implements OTIB-0066, 

providing that those things are done, are we 
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done on this? 

 CHAIR BEACH: What about addressing 

the review of OTIB-0066 to start with? 

Because that has never been addressed. And I 

would assume this would be the right format to 

do that. 

 DR. ULSH: As I understand it, the 

review of OTIB-0066, the comments that SC&A 

had dealt with implementation. Correct? And 

-- 

 DR. MAURO: Brant, that is my 

understanding, too. The last time I read the 

review and the issues resolution process that 

we went through at the procedures Work Group, 

there was a clear boundary between 

implementation issues and what we would call 

biokinetic modeling issues which are generic. 

 DR. ULSH: Okay. And the only 

biokinetic modeling issue, as I recall, that 

we had a concern with had to do with 

organically bound tritium and the clearance 

rate. 
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 And you folks agreed that there 

needed to be a correction made. And so we 

closed out all the issues and transferred 

basically the issues that were site specific 

regarding implementation. They were 

important. Don't get me wrong. But from the 

procedures Work Group perspective, those 

matters were appropriately dealt with on a 

site-by-site basis on how you were going to 

implement it at that site. 

 So, OTIB-066 -- my understanding is 

OTIB-066 issues from the Procedures Work Group 

perspective in the biokinetic realm, have all 

been resolved. And the only issues remaining 

is how are you going to implement it at each 

of the different sites. And this is an 

important discussion we are having because I 

think the strategy that you just described, 

Brad, does address the implementation issues. 

 And the question is, does it address it to 

the satisfaction of the Work Group? 

 But I don't think it bounces back 
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to the Procedures Work Group. I think those 

issues have been resolved. 

 CHAIR BEACH: And I think Kathy has 

a comment. 

 MS. ROBERTSON-DeMERS: I would 

recommend that you have them respond to our 

white paper on tritium compounds -- 

 CHAIR BEACH: Yes, I haven't gotten 

there yet. 

 MS. ROBERTSON-DeMERS: -- instead 

of OTIB-0066. 

 DR. NETON: Well, wait a second. 

 DR. MAURO: I agree. 

 CHAIR BEACH: Well, we were just 

talking about OTIB-0066. I hadn't asked about 

this yet. I agree with you, Kathy. 

 DR. NETON: Well, let me see if I 

understand because I think we are talking 

about the same things in different 

terminology. 

 I mean, what I am hearing is that 

the solubility of the tritide compounds has 
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not been called into question that has been 

used in OTIB-0066. There were some issues of 

organically bound tritium but the 

implementation doesn't mean are there more 

insoluble types of tritides than S out there 

in the complex. 

 Because if that is an issue, then 

we have got -- 

 MR. FITZGERALD: I think that 

discussion has to be somewhere else. I think 

there are, you know, I think that is something 

we had planned for a while but we haven't had 

it yet. 

 MS. ROBERTSON-DeMERS: And please 

be aware that the person doing the analysis on 

the models was not cleared and did not have -- 

 DR. MAURO: That is correct, Kathy. 

 You know, I think that you just hit the nail 

on the head. The issue on is it possible that 

there were some chemical forms at particular 

sites which are not captured, are not bounding 

by the upper bound assumptions used in OTIB-
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0066. And whether you want to call that a 

generic issue or a site-specific issue, I 

mean, that is certainly something that needs 

to be addressed. And I don't know, you know, 

and this is a question I think is before NIOSH 

and the Work Group. And I think NIOSH needs 

to address that. 

 That is, when you pick this 

bounding approach for these 12 individuals or 

13, are you saying that you are going to use 

the limiting exposure pathway that is adopted 

in OTIB-0066 or perhaps something more 

limiting that goes beyond -- more conservative 

than OTIB-0066? 

 DR. ULSH: So is SC&A saying that 

there is something less soluble than that one 

particular compound that we know of? 

 MR. FITZGERALD: No. What we are 

basically saying is that, and I purposely 

identified the discussion we had last year, 

because we have unfinished business which, you 

know, Mel, I think you were part of this, we 
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were going to come back and just kind of 

confirm some of the questions I think Mutty 

started getting into it a little bit that 

would give us confidence that in fact that is 

the case. 

 So we are not saying we have 

specific evidence. We are saying we have 

never, I think closed out that question that 

was raised in our meeting last summer, which 

was to have this second session which would 

put this to bed. And I think we still need to 

have that but we have already talked about 

this. But again, that is where I think it 

stands right now. 

 CHAIR BEACH: And does anybody mind 

if we just go ahead and take a break? 

 We are into an hour and a half and 

then we will resume this conversation at 3:15, 

unless you guys want to keep going. 

 Do you think you will lose the 

thread? 

 (Laughter.) 
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 CHAIR BEACH: I don't think we will 

lose it. I just think it is break time. 

 MR. KATZ: 3:15. 

 MR. CHEW: I don't know if we can 

close it right now, Brant. I think in the 

discussion that we are going to probably have, 

you know, we obviously have identified all, we 

have identified all of the compounds and the 

metal tritides here. So you want us to look 

at that making sure that -- 

 MR. FITZGERALD: Yes, that was the 

action, was to go and -- 

 MR. CHEW: -- the one that we --

there was none more that we identified that 

was more stable than the one that -- 

 MR. FITZGERALD: That was the 

question from last year and you were going to 

go off and do that and come back and we just 

never came back. 

 MS. ROBERTSON-DeMERS: Right. And 

provide a reference on how we determine that 

stability. 
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 MR. CHEW: It would be classified. 

 MR. KATZ: And that with that, we 

are going to take a ten minute break. 

 MEMBER ZIEMER: Ted, I will be gone 

after the break. 

 MR. KATZ: Okay. Thanks, Paul. 

(Whereupon, the foregoing meeting when off the 

record at 3:05 p.m. and resumed at 

3:19 p.m.) 

 MR. KATZ: Okay, so this is the 

Mound Working Group and we have just, we are 

just coming off of a break. And we had lots 

of discussion about tritium compounds and I am 

not sure if we are moving forward to the next 

issue. 

 CHAIR BEACH: No, we are still on 

tritium. Is there any more discussion before 

I kind of summarize where I think we are? 

 MR. FITZGERALD: Let's hear the 

summary first. 

 (Laughter.) 

 CHAIR BEACH: Well, I am just going 
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to give a real small summary. Other than what 

I have already asked for, I would like to see 

a written response to SC&A's white paper from 

NIOSH. And I would also like to move that we 

schedule a secure meeting to discuss a couple 

of the issues that were brought up at the last 

secure meeting that have never been dealt 

with. I believe Joe touched on them earlier. 

 The roadmap, and then demonstrate how some of 

this is going to all be accomplished. 

 MR. KATZ: I think we need more 

discussion about that. In terms of there was 

some discussion about proof of principle or 

whatever. I don't think that needs to be done 

in a secure setting. Is that right, Brant? I 

mean, you can do some dose reconstructions as 

examples without -- 

 DR. ULSH: Well, it depends on how 

you define proof of principle. We can 

certainly provide sample dose reconstructions. 

 CHAIR BEACH: But I think we would 

like to have SC&A provide some -- 
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need discussion. I feel uneasy about having 

an open discussion about designing a proof of 

principle. Because I think, for example, some 

of the 12 individuals I would like to know 

what they did, who they are, and maybe they 

would be part of this ER. But you know, that 

would have to be done, I think, in a secure 

location. 

 I am just saying, I think we need 

to know at least what the functions, what work 

they did, and maybe choose one of those as a 

sample dose reconstruction. 

 MR. FITZGERALD: Joe, I would like 

to add when you do discuss this matter, I 

would be very interested in knowing whether 

the limiting path exposure that is in OTIB0066 is in fact bounding for all forms of the 

stable tritides that are at Mound. Or do you 

believe that you are going to have to with the 

more limiting? 

 MR. FITZGERALD: Well, I think has 
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to go toward sort of demonstrating upper 

bound, which -- 

 DR. MAURO: Yes. 

 MR. FITZGERALD: -- at this point, 

money has raised some interest on my part to 

understand better what was done at Mound when 

he was there. And I think the basis for that 

information and also some better knowledge of 

the 12 individuals and maybe from that design 

what this test, I don't know if you would call 

it a test, proof of principle looked like. 

 I think it should be aimed toward 

an upper bound. Not simply just dropping 

numbers into an OTIB-066 model because I think 

what we are trying to get to is, yes, as with 

OTIB-0049, you know, we can take some of the 

least soluble and design it so that it gives 

you pretty good assurance that that would 

represent an upper bound. 

 DR. MAURO: The only reason I say 

that is if it turns out that OTIB-0066 does in 

fact, in its limiting case, bound all 
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circumstances for Mound, well, that would mean 

that you could just, you know, default OTIB0066 as being the limiting pathway or, if it 

turns out no, there were circumstances that 

were unique at Mound and OTIB-0066 really 

doesn't place an upper bound, we need to know 

that. 

 DR. ULSH: I can already answer 

that. 

 DR. MAURO: You can? 

 DR. ULSH: Yes. The tritides that 

were present at Mound are covered by OTIB0066. They are listed by name in there. 

 DR. MAURO: Okay and the most 

limiting form in OTIB-0066 does bound Mound? 

 DR. ULSH: The most limiting form 

listed in OTIB-0066 is hafnium tritide and 

there is nothing at Mound that is less soluble 

than that. 

 DR. MAURO: You have answered my 

question. Thank you. 

 DR. ULSH: You're welcome. 
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 MR. ELLIOTT: We will further 

answer this question in the documentation we 

provide in response to the white paper. And 

we will give you example dose reconstructions 

but we are not going to give names. We are 

not going -- of the 12 people, we are not 

going to identify particulars about those 12 

people. 

 The sensitivity about their work, 

if you want to understand that, you can do 

that in a secure briefing situation but we are 

not going to come to the table with a proof of 

principle that looks like one of the claimants 

from that 12. 

 MR. FITZGERALD: Not but we can 

certainly pick parameters or characteristics 

that would be realistic but not traceable to 

an individual, which would be helpful. 

Because we don't know, you know, the 

information I think you have garnered in terms 

of this roster is something we have not seen. 

 I think it would be useful to see it. 
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 DR. ULSH: I think you have seen 

it. It was in the interview notes that we did 

with the three workers, I won't say the names 

but -- 

 MR. FITZGERALD: We will take a 

review but I would suspect those have been 

screened. 

 Well, I think we can discuss this 

further. We don't have to settle it at the 

table but I think we need to -- 

 MR. KATZ: Well, I just wanted to 

be clear about the secure meeting. If you 

want to go to a secure meeting to confirm 

that, for example, that their model is 

capturing the least soluble factor, for 

example, that sort of thing, to make this kind 

of confirmations, I think that is fine. There 

is no problem with that. I just don't want 

this closed meeting to be a debate about 

methods itself because those should happen in 

public here. 

 CHAIR BEACH: Right. 
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 MR. FITZGERALD: Yes, I don't think 

we are talking methods. I think we are 

talking about confirming. 

 MR. KATZ: Right but for confirming 

things, I think that is fine. That is what I 

just want to make clear. 

 MR. FITZGERALD: And as I would 

think input to perhaps settling on a couple of 

scenarios to test out using OTIB-0066, I think 

that would be the only other purpose I could 

think of. 

 CHAIR BEACH: Well and then to take 

a look at the addendum to the roadmap. 

 MR. FITZGERALD: Well, the roadmap. 

 The addendum to the roadmap. 

 CHAIR BEACH: Yes. 

 MR. FITZGERALD: Right. Those 

would be sort of three nexuses. 

 CHAIR BEACH: Okay? You just have 

that look, Brant. 

 DR. ULSH: You are in charge. 

 CHAIR BEACH: No, that is all I 
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have. And then I guess we can discuss that 

time period at some other point. 

 MR. FITZGERALD: Well, yes, I think 

that has been an open discussion as far as 

having that next session. 

 CHAIR BEACH: Anybody else, any 

comments or -- 

 MR. LaBONE: This is Tom LaBone. 

 CHAIR BEACH: Hi, Tom. 

 MR. LaBONE: How are you doing? 

 CHAIR BEACH: Good. 

 MR. LaBONE: Could I make a few 

points about OTIB-0066? 

 CHAIR BEACH: Sure. 

 MR. LaBONE: Do we have enough time 

to do that? 

 CHAIR BEACH: Sure. 

 MR. LaBONE: Okay because I think 

it would help focus any further discussion 

that you have. 

 I wrote OTIB-0066 and in it there 

are three models for tritium compounds. There 
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are the tritides, organically bound tritium, 

and the tritiated water. And there are 

standard ICRP models for those three types of 

compounds and that is what OTIB-0066 uses. 

There is no OTIB-0066 model in the same sense 

that there is an OTIB-0049 model, kind of 

thing. 

 And really all OTIB-0066 tried to 

show was that for those compounds, if you take 

a look at what comes out in the urine that you 

could use in existing OTIB, an existing 

methodology, which is OTIB-0011 to analyze the 

urine data and come up with a reasonable dose. 

 And I think that if you go through 

and you know -- SC&A had some comments that I 

need to address -- but in principle if you are 

calculating a dose to a systemic organ like a 

prostate or a liver and you have enough urine 

samples, say you have a urine sample every 

week, I don't need to know what the material 

was, if it is one of those three compounds. 

 So, the whole discussion about 
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solubility is moot if it is a cancer of a 

systemic organ. Where it becomes really 

important what the solubility is, is if you 

are talking about a respiratory tract cancer 

or possibly GI tract. I don't know. Just 

something where it is not in the systemic 

body. 

 MR. FITZGERALD: Didn't you say, 

though, that would be, by and large, the 

greater number? I don't know. Is that 

something that was mentioned, that the 

respiratory tract would be more implicated 

greater than systemic? 

 DR. NETON: Yes, the more 

insoluble, the higher the respiratory tract 

dose. 

 MR. LaBONE: Well, it is just if 

you are working on a dose reconstruction that 

involves a systemic organ -- 

 MR. FITZGERALD: Right. 

 MR. LaBONE: -- then, the 

solubility, I don't know need to know any. 
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 MR. FITZGERALD: Yes. 

 MR. LaBONE: And the person had an 

adequate number of urine samples, I don't need 

to go hunting for what was the material and 

what was its solubility. 

 MR. FITZGERALD: Right. 

 MR. LaBONE: And that is all I was 

trying to point out. So when you sit down to 

discuss, it is a, it kind of focuses the issue 

in on it is of importance for respiratory 

tract cancers. It is not a broad, across-theboard issue for every dose reconstruction. 

 And I don't think there is any 

vigorous disagreement with that. But again, 

just listening to the discussion, it helps to 

narrow it down. It is a smaller problem or a 

smaller issue than if it applied to everybody. 

 So that is really all I wanted to make the 

comment on then. 

 MR. KATZ: Thank you, Tom. 

 CHAIR BEACH: Okay, if we are 

finished with the tritides, we will move on. 
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 The next agenda item is PriceAnderson related bioassay issues number 21. 

And I believe, Joe, you were going to take the 

lead on this one. 

 MR. FITZGERALD: Yes, this is one 

we have been working iteratively, I think 

going back and forth with NIOSH doing reviews 

as well as we. And it involved a concern that 

was raised about actinium-227 urine bioassay 

samples that were collected. You know, in 

1991, this is the Price-Anderson Act 

enforcement issue that I think certainly most 

people at Mound were familiar with. And it 

raised a number of questions about the 

validity of bioassay and whether or not the 

way that was handled was reflective of how the 

bioassay program was being implemented at 

Mound, just you know, at that time frame as 

well as historically. 

 And back in July, NIOSH presented a 

white paper on the subject that pretty much 

itemized a brief description of each of the 
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three DOE enforcement actions relevant to 

dosimetry details. Mound's response to the 

enforcement action is what they did and any 

SEC implications and provided a pretty 

detailed chronology of actinium-227 problems 

as well. 

 So, in terms of the NIOSH and SC&A 

actions, we focused on essentially the 20 RWPs 

that the Work Group wanted us to disposition 

from the standpoint of what the implications 

were for the adequacy of bioassay and whether 

or not that would surface an SEC issue, in 

terms of the validity of bioassays. 

 And without going through a 

detailed chronology, I know the time is going 

to get a little tight, where we came out, each 

of the 24 relevant Price-Anderson related RWP 

issues were dispositioned by both NIOSH and 

SC&A. And the only exception, we had five 

items from our listing, and this is in the 

white paper that we provided NIOSH and the 

Work Group back last month. We only had five 
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items left and they essentially went back to 

this question of data adequacy which we 

address in Issue 11. 

 So some of these issues get back to 

the adequacy of urinalyses for actinium, 

rather than other implications. So, we have 

kind of handed it off as part of the overall, 

and it is mentioned in the Issue 11 white 

paper. But we ended up feeling that there 

weren't any SEC issues that came out of that 

detailed dispositioning of the RWP issues. 

 We did have three questions, 

really, that remained beyond the question of 

the SEC implications we felt were important 

ones to address. The first is how will dose 

reconstruction be completed for individuals 

who entered under RWPs without appropriate 

tritium bioassay and did not submit a post-job 

tritium bioassay sample in a timely manner. 

 And the second one was, and these 

are all hows, how will dose reconstruction be 

completed for individuals who entered under 
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RWPs without appropriate Pu, thorium, uranium, 

radium, actinium, or americium bioassay 

samples that did not have a follow-up sample 

to those discovered in '95. 

 And finally, the third question 

that was pretty much what was left from this 

review, how will dose reconstruction be 

completed for the 11 individuals who submitted 

actinium bioassay samples that did not have a 

follow-up sample to those discovered in 95. 

 So really those are clarifying 

questions. You know, again, I think we agree 

with the conclusions that NIOSH reached on its 

review of the RWPs. And we agree that we 

don't see any obvious SEC implications from 

those RWPs but we do have those three 

questions. 

 And that is pretty much where we 

ended up and that is kind of abbreviated. 

There was a long history on this one and we 

spent a lot of time, as did NIOSH, going 

through all these RWPs and looking at the 
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history of the enforcement actions. So, it is 

a pretty detailed analysis. 

 DR. ULSH: All right. Gene Potter, 

are you on the line? 

 MR. POTTER: Yes, Gene Potter, ORAU 

Team. No conflicts with Mound. 

 DR. ULSH: All right. Gene is the 

guy on our team who pretty much handled the 

investigation of these Price-Anderson Act 

issues. So Gene, do you want to respond? 

 MR. POTTER: You know, I don't 

think that I can, you know -- since we haven't 

coordinated on this, I don't think I can 

respond directly to how dose reconstructions 

can be done but I have looked up some 

additional data, if you would like me to 

present that. 

 DR. ULSH: Sure. 

 MR. POTTER: On the first question 

which related to no tritium bioassay followups by some people within 30 days of their 

last entry on the RWP, there were seven RWPs 
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involving tritium. They were called out in 

the follow-up to the Price-Anderson. 

 And if you look at, and SC&A 

observed that there were 38 to 67 percent of 

the individuals who did not submit a sample 

within 30 days. If you look at the individual 

RWPs, you find that for the first one -- three 

people submitted within 30 days out of three 

workers. The second one with 64 out of 105; 

24 out of 46; eight out of 13; two out of 

four; one out of three; three out of eight. 

For the total number of entries, worker 

entries was 105 within 30 days out of 182 

total worker entries. So we are literally 

dealing with a glass half full, glass half 

empty type argument. 

 And of course, NIOSH does not do 

DRs RWP by RWP. But if I were an internal 

dosimetrist and looking at data, I would say I 

certainly could bound the doses for those 

individual RWPs. 

 MR. FITZGERALD: That would be a 
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coworker, basically? 

 MR. POTTER: Well, no. I am not 

suggesting that this actually be done, unless 

you know, Liz wants to choke me or something. 

 I am just saying that there are lots of, you 

know, you can look at this as there is lots of 

tritium data missing or you can look at it as 

there is lots of tritium here that was 

collected. 

 In addition, the picture might 

actually be a little bit better than what this 

data shows and others that, you know, I don't 

want to put anyone on the spot, but others 

there may be able to make a comment on this, 

that in the end, in the modern era at Mound, 

how the RWP program worked was that workers 

were only sampled on a period basis, not at 

necessarily after every entry on the RWP. 

 So for instance, a person may be 

going from tritium RWP to tritium RWP and only 

receiving a tritium sample at some point when 

the database was queried. And so this would 
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fall more into a chronic-like scenario that 

NIOSH is likely to use in reconstructing these 

doses. I should, you know, comment that I am 

not a qualified dose reconstructor on Mound 

but that is my assumption. 

 If we looked at the second 

question, which basically involved people not 

getting follow-up bioassays on plutonium, 

thorium, uranium, radium, and actinium in some 

cases, and americium, there were 14 RWPs that 

involved plutonium. Let's just take a look at 

plutonium, for example, instead of running 

through all of those which would be quite 

time-consuming. 

 I did a similar sort of thing only 

I looked at bioassays for plutonium submitted 

within 90 days, which is probably a more 

reasonable thing since plutonium is more 

insoluble. And if I looked at the first four, 

I won't run through all of the numbers for 

you, but if I looked at the first four, where 

we were successful or the data showed that 
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Mound was successful, three out of three times 

for the first RWP; seven out of nine times; 

eight out of 11 times; and one out three times 

for 90 days but it would be two out of three 

if you fudged it to 91 days. 

 Overall, there were 77 samples 

successfully submitted within 90 days out of a 

possible 101 last entries. So, I should 

mention that the average for submitting 

samples was somewhat over 50 days, depending 

on how you calculate it. 

 In addition to the comments I made 

earlier about whether a person could have 

possibly been sampled on a periodic basis and 

not necessarily when they made the last entry 

to a specific RWP, this analysis that I did 

and was presented in the data before cutoff at 

the end of 1997, so we extended the picture 

into 1998 for plutonium, which as I mentioned 

is more insoluble, the picture would probably 

be better than stated. 

 The third question was the actinium 
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samples for 11 individuals. And this is from 

the 2001 Price-Anderson enforcement action for 

the August of 2000 discovery of 15 unanalyzed 

samples. Later it was determined four of the 

15 had submitted samples. So that leaves you 

with 11. We were unsuccessful in finding any 

record of who the 11 people were by name but 

by doing database queries, we found a list of 

14 individuals who met the specific criteria. 

 So I personally, I should say, I don't speak 

for NIOSH, but I personally feel that the list 

of 11 is likely to be included in this 14 and 

therefore, this should not be an SEC issue. 

We know who these folks are. 

 And again, I don't want to comment 

on how specific dose reconstructions may be 

done but that is the results of the additional 

data search that I did. 

 MR. FITZGERALD: Okay. And what 

did you search on? What were your search 

parameters? I mean, how did you find these 

14? 
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 MR. POTTER: Oh. 

 MR. FITZGERALD: Time frame and 

location? 

 MR. POTTER: I think it is 

described in the paper that you reviewed. Let 

me see if I can find it quickly so I don't 

make an error relying on my memory here. 

 I believe it is described on page 

10 of 16. 

 MR. FITZGERALD: Okay. Well, don't 

take the time. I mean, we will go back but I 

am just curious. 

 MR. POTTER: Basically if I could 

describe it in generalities, folks were not 

sampled within a certain time period and had 

not submitted a follow-up sample. So you 

know, that is sort of the way I did it. 

 DR. ULSH: So kind of like the 

other issues that we have discussed that SC&A 

has issued white papers on, I would propose 

that we respond to their white papers. 

 CHAIR BEACH: That is what I wrote 
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down. 

 DR. ULSH: I thought you probably 

did. 

 MS. ROBERTSON-DeMERS: This is 

Kathy. Can I make a clarification? 

 CHAIR BEACH: Sure. 

 MS. ROBERTSON-DeMERS: I think the 

bigger question on number two is if the 

individual went in on an RWP and then never 

submitted the sample after he made that entry, 

versus submitting it within 90 days. So maybe 

he left Mound before submitting a follow-up. 

 DR. ULSH: So are you saying then 

that we might have used -- 

 MS. ROBERTSON-DeMERS: Now, the 

question is directed at that type of a person. 

 DR. ULSH: No, I understand. 

 MR. FITZGERALD: Well, if that 

person existed. 

 DR. ULSH: Sure. We used the 

criteria or Gene used the criteria of 90 days 

but I guess maybe it was 100 days or 180 days. 
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 That guy is probably not of concern. It is 

the guy that never gave one that you are 

worried about. 

 MS. ROBERTSON-DeMERS: Right. 

 DR. ULSH: Okay. 

 Now, I don't think that that is a 

Mound-specific issue. It is an issue anywhere 

that, I mean, I think that the sites did the 

best that they could to get exit bioassay 

samples from people. But there is always a 

chance that someone could -- 

 MR. SHARFI: They thought that they 

won't give a termination sample, there is 

nothing a site can do. 

 CHAIR BEACH: That comes up in some 

of our D&D time period also. Yes, okay. 

Anything else on 21? Any comments from the 

Work Group? 

 Are we ready to move on to -- I 

didn't ask. What is the end time for people? 

 I mean I don't want to hold people past when 

they normally stay at work. 
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 DR. NETON: About 9:00. 

 (Laughter.) 

 CHAIR BEACH: Oh, so we can clearly 

get through the next couple of items? Is that 

agreeable? Yes? I want to know at least what 

time they want to leave. 

 MR. KATZ: Let's give it a shot. 

 CHAIR BEACH: Give it a shot. Okay. 

 So, let's move on to shallow dose 

issue number 16, once again led by SC&A. And 

I think Joe is also handling that one. 

 MR. FITZGERALD: That one I am 

going to defer to Ron. We had a technical 

call a couple, two or three weeks ago and I 

don't know if we talked about shallow but did 

we? Okay, so this -- why don't you just give 

a summary of where this came from. 

 MR. LEWIS: Joe, I don't mean to 

interrupt but this is Greg Lewis. I just 

wanted to let you know that DOE is on the 

call. We joined a little late but I just 

wanted to make sure everyone knows we are 
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available, maybe not for direct questions but 

if there are things come up on this call that 

you need addressed, we can make sure to get 

the answers for you and let you know. Thanks, 

everybody. 

 MR. FITZGERALD: Thanks, Greg. 

 CHAIR BEACH: Great. 

 MR. BUCHANAN: Okay, this is Ron 

Buchanan with SC&A. And the shallow dose was 

brought up several times and we wanted to kind 

of bring this up to date and what needs to be 

done with this, at this point. 

 Shallow dose, of course, just a 

quick review, is defined as a non-penetrating 

dose, which is the low energy gammas, betas 

that would come from a low-energy emitter. 

And at Mound, one of the complicating issues 

was that initially they had beta radiation, 

and then they didn't have any for quite a 

while, and then they had some later on. 

 And so that led to two problems 

when we analyzed the records from Mound was 
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that 1) that led to a large gap in beta 

dosimetry period just because they didn't 

effect any. So there wasn't any reading of 

the open window. In the dosimetry if they 

took the open window minus the shielded 

window, that was the shallow dose but that 

wasn't done a lot of the times because they 

didn't expect any dose. There was kind of an 

informal directive that if they had seen some 

darkening of the window, they would read it. 

There wasn't any real hard and fast policy 

though. 

 And since they did not expect much 

shallow dose, they did not calibrate for it. 

And so there was no real calibration for 

shallow dose until the 1979 area. And then it 

really didn't get DOE Lab accredited until 

about 89, 88-89 period. And so this was after 

TLDs had been in for ten years or so. 

 And so what SC&A did was bring up 

the fact that whether this is really an SEC 

issue that has not been identified but we did 
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want to bring up this issue and see where it 

stood. And so we presented these three 

factors, the lack of monitoring, the lack of 

calibration, and three, DOE accreditation. 

 And so this led to two action items 

from NIOSH. Last fall, they provided us with 

a list of 108 shallow dose cases that I went 

through and will present a short summary on 

and then they also brought it in March of 09, 

a review of the Mound shallow dose prior to 

1991. 

 And so I would like to summarize 

where we are at on those. And so last fall 

from these 108 cases, I went through an 

analyzed 18 of these cases that were shallowdose cases and determined how many of them had 

any recorded shallow dose. And of the 18 that 

I selected, randomly from the workers 

description, they might have them. I didn't 

select like secretaries or administrators, but 

technicians and stuff that might have some 

shallow dose. I found four of the 18 had some 
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record of shallow dose and that these were 

years without any adjustment factors when the 

dose reconstruction was done. And usually it 

was the number right out of the dose of 

record. So there was no adjustment made to 

them. 

 And so, then I went and reviewed 

the NIOSH's white paper in response to these 

issues and found that essentially what NIOSH 

proposed was recognizing that there was no 

monitoring and perhaps sometimes should have 

been monitoring for shallow dose. They came 

up with essentially a summary table on page 10 

of their white paper, table four, which they 

went back and looked back at the workers that 

might be exposed, had the potential for 

exposure to shallow dose and have to assign a 

shallow dose and what they did was used a 

shallow dose to photon dose ratio. So, if the 

worker was monitored for photon dose, then 

they would assign a factor of anywhere from 

one to four as a shallow dose. And this was, 
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depending on the year and location that the 

worker worked. 

 And so I went through and analyzed 

this and SC&A does not have any SEC issues 

with their proposed white paper but where we 

do stand on it is we felt two issues. Number 

one, we felt that it was incomplete for the 

latter years because they started calibration 

in 79 and started using TLDs in the 70s. And 

but they didn't get lab accreditation, no lab 

accreditation until 88-89. And so we would 

like to see what adjustments need to be made 

to the dose of record for shallow dose or for 

shallow dose as a function of photon dose 

during the TLD area of 10 DOE accreditation. 

We felt that the white paper was incomplete in 

that area. That is number one. 

 Number two is that we feel that 

although the correction factors given for the 

previous time frame are agreeable, we don't 

know it is complete until we see it actually 

implemented in the TBD. 
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 MR. STEWART: Just to update you on 

that, the external TBD for the Mound site is 

currently under review. And right now, it has 

a due date to ADC review of June 6th. So, and 

I am writing it and I also wrote this. So, 

this is in there. 

 MR. BUCHANAN: The dose charts, the 

tables and such are in there. 

 MR. STEWART: Yes. Yes, this will 

go in there and not as a piece of whole cloth, 

but where appropriate, sections are broken out 

in this table. 

 CHAIR BEACH: So do we put your 

name on the action item then, Don? 

 MR. FITZGERALD: It's going to go 

there anyway. 

 CHAIR BEACH: Just kidding. Okay. 

 MR. KATZ: Thanks for volunteering. 

 MR. STEWART: Actually, probably 

the best way to measure implementation is 

simply to review the draft when it comes out. 

 CHAIR BEACH: So SC&A to review the 
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draft. 

 MR. STEWART: Once approved. Once 

we reach the right level of approval, then 

turn it to SC&A. 

 CHAIR BEACH: Right, right. And 

then the only other question from the Work 

Group is that NIOSH would answer SC&A's 

concerns in their white paper, responding to 

your earlier white paper. 

 MR. FITZGERALD: If he is going to 

do a white paper, I mean we gave the original 

feedback. 

 MR. BUCHANAN: Yes, we gave the 

feedback to the white paper. 

 MR. FITZGERALD: Yes. 

 CHAIR BEACH: Back in April, yes, 

but we have never had an answer to it, I don't 

believe. Did we? Or is that -- 

 MR. KATZ: It sounds like this is 

the answer. 

 CHAIR BEACH: This is the answer to 

it. Oh, okay. 
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 MR. BUCHANAN: Well, there has not 

been a direct answer to our -- 

 MR. STEWART: In terms of your 

comments one and two, no. I can address 

comment two because we are implementing this 

program in the TBD. That was -- we are doing 

that. 

 CHAIR BEACH: Right. 

 MR. STEWART: I haven't addressed 

comment one yet. 

 MR. BUCHANAN: Okay. And there are 

site profile issues addressed in our reply 

that wouldn't be SEC issues. 

 MR. FITZGERALD: They are 

identified as such. So you know, we label 

them that way and understood that, you know, 

the SEC review process as site profile issues 

are identified, we hand them off but we don't 

pursue them until the next edition of the site 

profile. 

 CHAIR BEACH: Right. 

 DR. ULSH: So really there is only 
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one outstanding question and that is what 

adjustments need to be made to the dose of 

record between 79 and 89. 

 CHAIR BEACH: Yes. 

 DR. ULSH: So, I will address that 

question. 

 CHAIR BEACH: Okay. Are we ready 

to move on, then? Yes, okay. The last to 

pick today is the environmental issue number 

20 and SC&A is going to lead that. 

 MR. FITZGERALD: Yes, this was a 

secondary issue that we included in the site 

profile. And what I mean by secondary is that 

with the Price-Anderson, we had some 

clarifying questions we wanted to raise but 

certainly didn't feel there was a complete 

basis to identify it as a full SEC issue. So, 

it was on the cusp. And the reason we raised 

it was a comment or a statement in the ER that 

Mound did not generally experience significant 

site-wide ambient contamination and there was 

less concern about the potential for internal 
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dose related to ambient working conditions. 

 And this, I think, Brad, you were 

raising some questions about site 

contamination, historic site contamination 

events. And we had a number of workers that 

raised issues like that. And so our question 

was, you know, you are going to apply an 

ambient value. To what extent does the 

ambient value reflect this history, 

relatively rich history? We have offered some 

examples but the response was I think you all 

felt these were more examples of localized 

contamination that would not impinge on this 

ambient value that would be applied for the 

site, site-wide. And we sort of got into this 

discussion about the statement itself. I 

think there was even an offer at some point 

during the discussion just to consider 

removing the statement. 

 I think our concern is just the 

statement more than anything else, that there 

were sources of contamination at Mound and it 
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wasn't clear how that would be included in the 

ambient calculation. I think the response was 

there would be a maximum ambient value 

applied. And I thought that was a reasonable 

clarification but, Brad, you may want to -- 

this was the issue you raised earlier that we 

raised in that context. 

 MEMBER CLAWSON: Well, you know, I 

was just trying to see where you were going 

with the outside because I guess from some of 

the interviews that we have had and so forth 

like that, they have brought up concerns with 

that. 

 I guess one of the issues that they 

had brought up was that it was totally there 

was a coal-fired plant that was down the road 

that was supposedly spreading all of this 

contamination at the site and that it had been 

taken away, that actually it was coming from 

the site. 

 Then getting back to, I know we 

don't want to talk about the microfiche but I 
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thought also too on that microfiche that we 

should have talked about it earlier. Part of 

the thing that came out on that was that they 

actually had stacked results were coming out 

of that and that they had ambient information 

of what had actually gone out of the stack and 

so forth like that. 

 And I was just wondering, how are 

we going to do the ambient exposure, I guess 

you could say, or the outside exposure. And 

this covers all areas of it because it covers 

the D&D era and then it also covered the 

earlier years of what people were getting, 

especially out of the stacks and so forth like 

that. And I just had some questions of how we 

were going to do that. 

 DR. ULSH: Well, keep in mind that 

Mound, like other sites, issued environmental 

monitoring reports that talked about -- I 

mean, they had a variety of samplers around 

the site. And I think that we would propose 

to use that data the same way we do at other 
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sites for ambient environmental. And that 

typically includes taking the maximum possible 

exposure at the site based on the monitoring 

results and applying that, certainly, to 

unmonitored individuals. Especially at Mound, 

in light of what I said earlier, where the 

position is that if you were not monitored, 

that is where we would assign an ambient 

environmental dose. 

 Jim was correct. We got into a bit 

of a discussion about that statement from the 

ER. I recall that discussion, too. I 

couldn't find it in the record anywhere but I 

know we had it because I remember it just like 

we did. And SC&A took some exception to our 

statement that they didn't have site-wide 

ambient contamination widespread. I think 

some of that may be a bit of semantics. When 

we talk about site-wide, what do we really 

mean? 

 Mound certainly had contamination 

incidents, one of which I think was cited by 
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SC&A and that was the contamination at the 

canal near Mound by the plutonium spill. And 

our response was that well that contaminated 

the sediments in a canal and workers were 

mucking around in that periodically. And when 

we are talking about ambient site-wide 

contamination, this is walking-around dose. 

This is what you get just walking from 

building to building or from your car to the 

gatehouse. 

 And there were a few other examples 

I think that you all presented. Contaminated 

equipment turning up where it wasn't supposed 

to be, that kind of thing. And I think we 

took issue with that. We said that those 

really aren't examples of ambient site-wide 

contaminations but this, I think, is more of 

semantic discussion. We would propose to do 

environmental doses at Mound, just like we 

would do anywhere else. 

 MR. FITZGERALD: Yes, the bottom 

line is you would take the maximum monitoring 
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value for a given year -- you do it by year, 

right? 

 DR. ULSH: Yes. 

 MR. FITZGERALD: And you would 

assign that as the ambient, the maximum 

ambient, which I think is where we came out, 

finally. I mean, that is one reason it was 

listed as a secondary because we had a 

question about the statement and wanted to 

clarify exactly what that meant. We 

interpreted it perhaps the wrong way and I 

think what we heard was this was how it was 

going to be done. And I think that was fine 

but it took a lot to get there. It was fine 

by the time we did figure out what that 

statement meant. 

 DR. ULSH: Well, given that we had 

the same recollection on that -- 

 MR. FITZGERALD: Yes. 

 DR. ULSH: -- what is the opinion 

about whether or not this is an open SEC 

issue? 
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 CHAIR BEACH: Kathy has got her 

hand up real quick. 

 MS. ROBERTSON-DeMERS: Can I ask a 

question? 

 MR. STEWART: Yes. 

 MS. ROBERTSON-DeMERS: How far back 

do you have the environmental reports? 

 MR. STEWART: Raw data-wise, they 

started reporting soil and water measurements 

in the very early days, in the 40s. 

 DR. ULSH: I think the actual 

official ambient -- I'm sorry. The official 

environmental monitoring reports, the 70s or 

80s, it seems. That was, I think, the 

reporting vehicle for those. 

 MS. ROBERTSON-DeMERS: And a 

different question. How far back do you have 

the reports, the environmental reports 

available to you? 

 DR. ULSH: I would have to look 

back in the record for that, Kathy. I don't 

really know exactly. 
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 MR. STEWART: I don't know either. 

 I did not write in the TBD. 

 DR. NETON: But the TBD is covered, 

I am quite sure in some way. 

 DR. ULSH: Yes. 

 DR. NETON: There is a whole 

section on ambient environmental. 

 MR. STEWART: Yes, have you looked 

at the references in the TBD? 

 MS. ROBERTSON-DeMERS: That was -- 

not yet. 

 MR. STEWART: Okay. 

 DR. ULSH: Well, that TBD was 

written a number of years ago but I would 

encourage you to not just assume that, if it 

is not listed in the TBD, we don't have it 

because there has been a lot of data capture 

between then and now. 

 MR. FITZGERALD: Going back to 

Brant's original comment, that was lifted into 

this sphere as a question but you know was 

sort of listed as a demarcation after 19. And 
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somehow the demarcation kind of got lost in 

the shuffle. But certainly 20 and 21 were 

considered clarifying issues that were 

included to get a response, as opposed to 

helping them as big SEC issues. And somehow 

they got lost in the shuffle but I think we 

are satisfied on the environmental side. 

 CHAIR BEACH: So I am hearing that 

SC&A is satisfied as long as NIOSH agrees to 

remove that statement or change that 

statement. How did that go? 

 MR. FITZGERALD: Well, I think we 

understand what the statement means. We 

didn't at the time when we saw it in the ER. 

 CHAIR BEACH: But it doesn't 

necessarily have to be removed. 

 MR. FITZGERALD: I don't think so. 

 I think we understand what the meaning of the 

sentence is, or the statement is. 

 DR. ULSH: Yes, we are on record 

with this discussion. 

 MR. FITZGERALD: Yes, I didn't mean 
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for it to balloon. 

 CHAIR BEACH: That was an April 

discussion, I believe. 

 MR. FITZGERALD: Right. Right,, 

right. We have had this discussion but I 

think that would take care of it. I would 

propose that the Working Group close it. 

 CHAIR BEACH: Okay and I understand 

that. How does the Working Group feel about 

closing that item? 

 MEMBER CLAWSON: I don't really see 

a problem but I do have one question and it 

keeps coming back to this. So we are actually 

redoing the whole TBD or we are reevaluating 

the TBD? 

 MR. STEWART: Currently under 

revision is the external TBD and that will be 

done soon. And that is one of the six 

sections. 

 We will also need to necessarily 

review the revised internal section, 

incorporate the proposed for tritium and the 
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other radionuclides that we talked about 

today. 

 MEMBER CLAWSON: And the reason I 

am bringing this up is because we evaluated 

this earlier TBD and now we are seeing things 

that are changed. Well, we don't know what is 

changed. 

 DR. ULSH: Yes, you are right, 

Brad. I mean, this was one of the earliest 

site profiles that we wrote. It was, I think, 

one of the earliest ones that SC&A reviewed 

and they issued comments on it. 

 MEMBER CLAWSON: Right. 

 DR. ULSH: We are picking that TBD 

up again. We are going to be considering a 

number of things; SC&A comments on the first 

TBD, the additional information and discussion 

that has come up as part of this SEC process. 

 So, I am trying to capture all of that into a 

sensible revision TBD. 

 MEMBER CLAWSON: Okay and my 

question was Joe, are we going to follow up on 
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the changes that are made to those? 

 MR. FITZGERALD: Well, yes. 

 MEMBER CLAWSON: You know, we are 

closing these issues but I just wanted to see 

how they play out into the TBD. 

 MR. FITZGERALD: Well, there is two 

avenues post-SEC. One of course is that the 

Advisory Board can always task us with redoing 

the next revision. And that has already 

happened in a couple of locations where a new 

edition of the site profile comes out and the 

Advisory Board tasks us with reviewing and 

seeing what has changed and providing 

comments. 

 The other is something I think Mark 

Griffon has raised in the past, which is sort 

of these site profile issues that come out of 

an SEC discussion, but there isn't either a 

work group or there isn't a revision of the 

site profile. And that is a little tougher 

issue. 

 MEMBER CLAWSON: Okay, and that is 
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kind of -- 

 MR. FITZGERALD: That is not the 

case here. 

 MEMBER CLAWSON: Right. 

 MR. FITZGERALD: It sounds like we 

are actually going to have this picked up in a 

new edition. 

 MEMBER CLAWSON: And this is why I 

was bringing this up because I have been 

working with Mark on some of these issues and 

so forth. 

 MR. FITZGERALD: Right. 

 MEMBER CLAWSON: I just wanted to 

make sure that by closing these that, you 

know, we just see how they are reincorporated. 

 MR. FITZGERALD: This works but I 

do agree that the other venue is a little 

harder because we don't have that easy ability 

to tackle it. 

 MEMBER CLAWSON: I appreciate that. 

 DR. MAURO: This is John. 

Procedurally, if the Work Group is an SEC/Site 
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Profile Work Group the way I believe Hanford 

and Fernald is, though you have resolved, 

let's say, certain issues in terms of, oh, 

this is not an SEC issue, it is a site profile 

issue, then and that work group is active, 

well that just continues and we continue to 

meet and work on those issues. 

 However, we have had circumstances 

where we have commented on the site profile 

and the site profile has been reissued and 

let's say a year passes, we would not 

automatically review that document unless the 

Work Group asked us to review it. In other 

words, once we have submitted our comments on 

a site profile and then the site profile is 

reissued, perhaps it does and perhaps it does 

not, we would not automatically take any 

action unless the Board or the Work Group asks 

us to do that. 

 MR. KATZ: Thanks, John. And this 

Work Group, I mean, the Board can task, too. 

It doesn't have to be a work group. The Board 
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can task a re-review of a site profile that 

has been substantially changed. This Work 

Group is specific to the SEC. 

 CHAIR BEACH: That's right. 

 MR. KATZ: It is not a site profile 

work group. And of course, the Board can also 

convert this work group to a site profile work 

group, if it so chooses. 

 MEMBER CLAWSON: Well, and I think 

we have kind of learned some things through 

the years. We really don't close out the site 

profile until after the SEC -- 

 DR. NETON: Well, yes, the matrix 

would remain. You know, all of the site 

profile issues will remain open. And then Ted 

is right. The Board could reconvene this 

working group or form another working group to 

close out the site profile. 

 MEMBER CLAWSON: Okay, I just 

wanted to make sure. 

 CHAIR BEACH: Well, we were just 

wondering if that was more of a formality than 
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anything else. 

 DR. NETON: What had happened 

before was occasionally, there would be 

working groups that were already site profile 

working groups and then an SEC petition would 

come onboard and then it would convert, but 

that is not the case here. 

 CHAIR BEACH: Okay, so at the 

recommendation of SC&A, the Work Group 

recommends that we close Issue 20, which was 

never actually viewed as an SEC issue, I 

believe it was a secondary, with acceptance of 

NIOSH's practice of a maximum value being 

derived for Mound's occupational environmental 

ambient dose. 

 Does that cover it? Is everybody 

comfortable with that? Do we close two today? 

 DR. NETON: Just for everybody's 

information, I pulled up the Mound 

environmental site profile and it turns out 

that I think the official environmental 

reports only go back to 71. And what we did 
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was use, I think, effluent data when we had 

stack effluent emissions the delta chi over q 

values and picked the highest receptor point 

on site for those earlier years going all the 

way back. The official environmental reports 

were not available in the very early years. 

 MR. CHEW: Can we get a late start 

on day two? 

 CHAIR BEACH: No. 

 MR. CHEW: I'm teasing. I'm only 

teasing. 

 CHAIR BEACH: No. No, no, no. 

 I guess that would conclude our 

work for today, if everybody is in agreement. 

 MR. KATZ: Thanks, everybody, for 

all of the hard work. 

 CHAIR BEACH: Yes, thank you. 

 MR. KATZ: And folks on the line, 

thanks. 

(Whereupon, the above-entitled matter was 

concluded at 4:08 p.m.)