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 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

 CENTERS FOR DISEASE CONTROL

 NATIONAL INSTITUTE FOR OCCUPATIONAL

 SAFETY AND HEALTH 

 + + + + +

 ADVISORY BOARD ON RADIATION AND

 WORKER HEALTH 

 + + + + +

 TBD-6000 WORK GROUP

 + + + + +

 FRIDAY

 OCTOBER 11, 2013

 + + + + +

 The Work Group met telephonically

at 10:30 a.m. Eastern Daylight Time, Paul L.

Ziemer, Chairman, presiding.

PRESENT:

PAUL L. ZIEMER, Chairman

JOSIE BEACH, Member

WANDA I. MUNN, Member

JOHN W. POSTON, SR., Member
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ALSO PRESENT:

TED KATZ, Designated Federal Official

DAVE ALLEN, DCAS

BOB ANIGSTEIN, SC&A

BOB BARTON, SC&A

ROSE GOGLIOTTI, SC&A

JOHN MAURO, SC&A

DAN McKEEL

JIM NETON, DCAS

JOHN RAMSPOTT

MUTTY SHARFI, ORAU Team

JOHN STIVER, SC&A
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 T-A-B-L-E O-F C-O-N-T-E-N-T-S

Welcome and Roll Call . . . . . . . . . . . . .4

TBD 6000, Rev 01

Presentation of DCAS August 2013 White Paper: 

"Determination of Settling Time"

 John Mauro . . . . . . . . . . . . . . . . .8

SC&A Review

 Bob Anigstein. . . . . . . . . . . . . . . 54

Work Group Discussion/Recommendations. . . . 80

Public Comment

 Dan McKeel . . . . . . . . . . . . . . . .125

Adjourn . . . . . . . . . . . . . . . . . . .184
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1 P-R-O-C-E-E-D-I-N-G-S

2 10:28 a.m.

3 MR. KATZ: Okay. So, thank you, 

4 everybody. This is the Advisory Board on 

5 Radiation Worker Health. It's the TBD-6000 

6 Work Group. There's an agenda for the meeting 

7 posted on the NIOSH website, subject to a little 

8 bit of amendment, but under the Board pages, 

9 under meeting pages, under today's date. And 

10 there are a variety of papers to go with the 

11 meeting also at that site. So if you want to 

12 follow along with discussion, it might be 

13 helpful to see the papers. 

14 Okay, then. Let's do roll call. 

15 We're speaking about specific sites, so please 

16 speak to conflict of interest, too, for 

17 Agency- related personnel. And let's begin 

18 with Board Members, with the Chair.

19 (Roll call.)

20 MR. KATZ: All right, then. So 

21 let's just all mute our phones except when we're 

22 speaking: *6 to mute your phone; *6 to take your 
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1 phone off of mute.

2 And, Paul, it's your agenda.

3 CHAIRMAN ZIEMER: Okay. Thank you 

4 very much. Good morning, everybody. I'll 

5 officially call the meeting to order. I want to 

6 remind you that the focus of the meeting today 

7 is on General Steel Industries. The meeting was 

8 original scheduled to have two items at our June 

9 20th Work Group meeting. We had a task by NIOSH 

10 to summarize in a White Paper their approach to 

11 settling velocity. They had explained it there 

12 verbally. SC&A expressed a desire to see it in 

13 writing so that they could better respond to it. 

14 So we have that document from NIOSH 

15 on settling velocity, or determination of 

16 settling time and we have a response from SC&A 

17 on that document.

18 The second document was that NIOSH 

19 agreed to summarize in a White Paper the various 

20 portions of the dose estimates for GSI. They 

21 issued a White Paper on August 21st. SC&A 

22 reviewed that and we got the comments. I think 
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1 the date of the comments was October 6th. The 

2 co-petitioner also had comments on that on 

3 August 30th and some follow-ups after that. 

4 So we have those documents to focus 

5 on today. And just for scheduling purposes, my 

6 plan is -- I have to adjourn us at 2 o'clock. 

7 That's my own schedule and I can't go beyond 

8 2:00. So I'm going to try to make sure we get 

9 through all of this today. And if possible we 

10 will be able to take a look at some of the open 

11 items on the matrices, on the issues matrices. 

12 But the initial focus here is on these two main 

13 items. 

14 Also I'm not planning -- we really 

15 got started a half hour later than we'd planned. 

16 The meeting was originally planned for 10:00, 

17 but somehow got posted on the Web site as being 

18 at 10:30. So my plan is to go straight through 

19 to 2 o'clock. Individually, you can just take 

20 breaks as you need them. You're sort of on your 

21 own. If you need to get a little food in you, just 

22 grab a snack while the meeting goes on. But the 
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1 plan is just to proceed on through.

2 So we're going to begin with the item 

3 on the agenda that's entitled "TBD-6000 Rev 1." 

4 We have the presentation by DCAS and Dave Allen. 

5 And I don't know, Dave, that we need 

6 to actually go through that. We all have had 

7 copies of that for over a month and I think the 

8 way for us to proceed here would be to go ahead 

9 and have SC&A present their comments and then 

10 we'll see where we are on this, if that's 

11 agreeable. Unless, Dave Allen, if you had any 

12 specific comments you wanted to make first.

13 MR. ALLEN: Yes, that's agreeable 

14 to me.

15 CHAIRMAN ZIEMER: Okay. Then I 

16 think we'll proceed. And I think Bill Thurber had 

17 the lead on this part of it for SC&A.

18 Is that correct, Bill?

19 DR. MAURO; Yeah, Paul, this is John 

20 Mauro. Bill was not able to join us. However, 

21 I did work closely with Bill on this work product 

22 and I'll be able to summarize it and hopefully 
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1 answer any questions.

2 CHAIRMAN ZIEMER: Okay. 

3 DR. MAURO: So I'm ready to go, if 

4 you guys are ready to go.

5 CHAIRMAN ZIEMER: Yes, proceed, 

6 John.

7 DR. MAURO: Okay. In fact, I can 

8 set the stage real quickly. What we're dealing 

9 with is an aspect of TBD-6000 dealing with 

10 settling time. A good way to think about it is 

11 you got a big area where people are doing metal 

12 working. They're grinding stuff and they're 

13 rolling stuff and airborne dust is out there and 

14 people working there are exposed to the 

15 inhalation from airborne uranium, externally 

16 exposed from large pieces of uranium rods, et 

17 cetera. And also from any uranium that deposits 

18 on the ground. And that's the issue here, the 

19 uranium that deposits on the surfaces.

20 And that's important from two 

21 perspectives. It represents a source of 

22 external exposure and resuspension as a source 
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1 of internal exposure. And it's especially 

2 relevant after the operations stop, because then 

3 that source really becomes the only source of 

4 exposure in what you would call maybe the 

5 post-operational time periods. 

6 So, now, when you're dealing with 

7 that source, the stuff that's on the ground, 

8 first and foremost you've got to estimate how 

9 much is there? How many becquerels per square 

10 meter of uranium residue or dust oxide is on the 

11 ground? And we've had a number of exchanges on 

12 that model. 

13 I think we agree with just about 

14 everything except one issue. And one issue is 

15 the accumulation time. You could visualize. 

16 You've got this dust in the air. It's settling 

17 at some velocity and it just keeps settling and 

18 it accumulates. Well, in theory, you know, if 

19 it goes on for 10 years, you're going to have 10 

20 years' worth of accumulation and build up an 

21 awful lot. But that doesn't happen. 

22 And we actually have a lot of good 
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1 data to help us understand how long does it take 

2 before the stuff that falls settles and achieves 

3 some level of equilibrium? Because, as you can 

4 imagine, as it's accumulating it's also leaving 

5 because it's re-suspending and it's being moved 

6 around and it's being exhausted from the 

7 facility. And NIOSH's position, based on a 

8 review of various data sources -- Adley, Simonds 

9 Saw -- is that a good accumulation time before 

10 equilibrium is reached is about 30 days. And we 

11 looked at that. 

12 And we have a paper, and I'm going 

13 to go through it very quickly, that came out on 

14 October 13th. And for those of you who have it 

15 handy on their machine in front of you, we could 

16 very quickly get to the bottom line. If you 

17 would go to table 3 on page 7 -- it's only an 

18 eight-page report -- if you can go to that table, 

19 that's what we're going to talk about for a few 

20 minutes here.

21 We went in and basically did a very 

22 similar calculation that was done by NIOSH, 
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1 except we did something a little different. 

2 NIOSH used a data set that came from this large 

3 complex -- I think it's called the Hanford Metal 

4 Melt facility -- where they had lots of data on 

5 airborne levels, on deposited levels. We have 

6 good information on deposition velocities. And 

7 they calculated from the data, well, how long did 

8 it take before the material on the surfaces 

9 reached equilibrium? And they collected all 

10 the data. 

11 But it's a big area. There are some 

12 rooms that are large; some rooms that are small. 

13 And collected all the data and got rid of some 

14 data that was really not appropriate, but in the 

15 end came up with their data set of what's in the 

16 air and what's on the surface. And calculated, 

17 well, how long did it take for it to -- and 

18 collecting all the data. And they came up with 

19 30 days before equilibrium is reached.

20 We did the same thing, except, to 

21 keep it simple, we said, well, you know, let's 

22 break the building up, because the building 
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1 isn't one building. It is really a large area 

2 called, I think, the bay area. And then there 

3 are a number of smaller rooms where they did the 

4 same thing. We have airborne levels and we have 

5 deposit levels. 

6 And so what we really have is a 

7 richer data set. That way you could say, well, 

8 let's look at the large bay area, which is the 

9 size of a half of a football field, and then let's 

10 look at the smaller rooms where other things were 

11 going on, where we have data, air and deposited, 

12 and look at them separately and to try to get a 

13 distribution of what the duration time for 

14 settling is. Because I think we could squeeze 

15 more information out of the data sets by doing 

16 it that way.

17 And that's what this table shows, 

18 table 3. We do have some differences between 

19 our approach and NIOSH's approach in some of the 

20 assumptions. And we could get into that if 

21 you'd like, but I think the important point and 

22 the bottom line is that when we did the analysis, 
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1 we broke it up into different segments. 

2 As you can see in table 3, we've got 

3 it broken out into different time periods and 

4 different rooms. And you will notice that our 

5 results effectively come in about the same, if 

6 you aggregate everything, to where NIOSH came 

7 in. And notice that, if you look into that table 

8 3, on the last two entries, Main Bay Winter, Main 

9 Bay Spring, we come up with time to achieve 

10 equilibrium. It's the far right- hand column 

11 that says days to equilibrium. We come up with 

12 15.7 days and 17.4. So, for the main bay area, 

13 our finding is that it reaches equilibrium even 

14 more quickly than the numbers that NIOSH 

15 reported at 30. 

16 But then we also looked at a number 

17 of the other smaller rooms which are on the order 

18 of maybe 20-by-20, 30-by-30 feet. And you could 

19 see that some of the smaller rooms where we have 

20 data, we come up with some numbers that are 

21 higher, in some cases substantially higher, than 

22 the 30 number. Which all rings true. Because, 
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1 remember, NIOSH aggregated all the data, so it 

2 sort of like averaged out everything. So coming 

3 in at 30 makes sense, more or less, you know, 

4 given some small differences in assumptions that 

5 we used and they used. 

6 But we'd also like to point out, 

7 though, that there are some rooms where clearly 

8 the characteristics of the air turnover and the 

9 removal rates are obviously different, and as a 

10 result equilibrium is achieved in quite a bit 

11 longer than 30 days. And that's our finding.

12 And, you know, we have other 

13 assumptions that we could get into that I 

14 consider to be the fine structure of the 

15 analysis. But I think the real important point 

16 here is that perhaps the best -- I guess the story 

17 at the end is it looks like a 30-day number is 

18 a really good number, especially if you're 

19 dealing with relatively large areas, like the 

20 bay area, which I think was something like 1,200 

21 square feet. I think that was the number. 

22 But for relatively smaller rooms, on 
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1 the order of let's say 500 square feet, we have 

2 the numbers here in the report, perhaps that 

3 accumulation time is not as claimant-favorable 

4 as it should, the 30-day, one-size-fits-all. 

5 And that could be important. Most 

6 of the time this is not important because we're 

7 dealing with doses that are coming from this 

8 residual level. But if the only exposures 

9 you're interested in -- if you're doing a dose 

10 reconstruction, and let's say at a site, and the 

11 exposure to the person you're interested in is 

12 for the residual period. You know, you're not 

13 really concerned about operations. Let's say 

14 they granted an SEC for the operations period; 

15 often that's the case. But there's no SEC for 

16 the residual period at an AWE facility. Then this 

17 does become important in performing a dose 

18 reconstruction. 

19 And our recommendation is: take that 

20 into consideration. That is, when you're doing 

21 the residual period and you're estimating what 

22 has accumulated on the surface, for the purpose 
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1 of doing external and internal exposure, just 

2 automatically applying the 30-day deposition 

3 accumulation time may not always be 

4 claimant- favorable. And really that's the 

5 bottom line of our story. 

6 CHAIRMAN ZIEMER: Okay, John, let 

7 me ask you a question, then. It isn't clear to 

8 me precisely what you’re recommending, whether 

9 you're recommending that the upper value be used 

10 for everything, or that there be a gradation, 

11 that if the size is known, that you take that into 

12 consideration. Or if it's unknown, you would 

13 assume the higher level. Is that the 

14 recommendation?

15 DR. MAURO: I don't think there's 

16 any words here to that effect, but I think that's 

17 a good take-away. That seems to be the 

18 reasonable thing to do. 

19 You know, if you know the size of the 

20 area, yes, the 30 certainly -- and it's big -- and 

21 it often is big -- 30 certainly is a good number. 

22 But if you don't, or if you know it's a small 
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1 area, relatively, you know, maybe you want to 

2 go -- and they'll have about a factor of two or 

3 three effect. So, yeah, I think the latter 

4 statement that you made I would agree with 

5 completely.

6 CHAIRMAN ZIEMER: Let me ask NIOSH 

7 to give their response to this.

8 MR. ALLEN: Yes, this is Dave Allen. 

9 One point I tried to make in the White Paper that 

10 we wrote was the number of days versus other 

11 parameters is -- what the individual parameters 

12 is not so important as what the purpose of these 

13 numbers and the final result is. And the whole 

14 purpose of these numbers is to come up with a 

15 surface contamination value.

16 In this recent document from SC&A, 

17 they adjusted the air sample values. They're 

18 still using the settling rate lower than what 

19 we're using, and they're coming up with times 

20 associated with these different parameters.

21 DR. MAURO: Yes.

22 MR. ALLEN: What I did was looked at 
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1 their unadjusted airborne concentrations and 

2 our assumptions, which is the settling rate of 

3 0.00075 meters per second and a 30-day, 

4 24- hour-a-day settling time. And it ends up 

5 giving you a higher surface contamination for 

6 six out of the seven values, or lines, that they 

7 have in table 3. 

8 The one exception is the furnace 

9 room in the spring where the SC&A come up with 

10 a 166-day settling time. That would produce, I 

11 guess, a higher concentration. Actually it 

12 wouldn't because of the airborne. It gets 

13 confusing.

14 DR. MAURO: You know, David, I 

15 agree. I think it's good that we're going here, 

16 because you're right, we used that 0.00052 

17 settling velocity based on the slip. 

18 I have to say that, in retrospect, 

19 you know, we try to -- because we discussed this 

20 in the past, the settling velocity. And I think 

21 our analysis, you know, is I think the 0.00052 

22 is probably a good number because it tries to 
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1 bring a little bit more sophistication to the way 

2 in which these particles actually settle. You 

3 saw our report. But at the same time, I would 

4 hate to sort of pick away at something like that. 

5 I like the 0.00075 number and I don't 

6 think we should go down the road -- and so I'm 

7 agreeing with you -- of trying to get to a level 

8 of resolution at a site where we really can't. 

9 I mean, you know, the slip velocity depends on 

10 the size of the particle, its shape and issues 

11 that aren't always easy to address. So I would 

12 have to agree with what you just said. That is, 

13 let's stay with the 0.00075. 

14 But where I would tend to disagree 

15 with you is that the other part of the 

16 calculation has to be how long is the activity 

17 airborne? In other words, one of the 

18 assumptions I believe you made is that the 

19 airborne levels that were at the Adley data, for 

20 example, were at that airborne concentration, 

21 the measured values in those different rooms, 24 

22 hours a day. 
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1 But we believe that, well, that may 

2 be a 30- percent overestimate of what the average 

3 airborne concentration was. Because they were 

4 not working on, you know, triple shifts. I 

5 think they only had one shift or so, or something 

6 like that, per day. So the time period when you 

7 had the dust loadings that were measured was 

8 probably only during the operations. So I think 

9 that that is an adjustment that I would say we 

10 need to make. 

11 So I agree with you, don't let's gild 

12 the lily with regard to the 0.00075. But at the 

13 same time, I do think that we do have to factor 

14 in, when you do your calculation, coming up with 

15 what we believe the average, 24-hour average, 

16 dust loading is in the room, take into 

17 consideration when there is -- you know, when 

18 there's only, let's say, one shift eight hours 

19 a day is when you have that dust loading and the 

20 rest of the time you don't. So there's where I 

21 think we still need to talk a little bit.

22 MR. ALLEN: Well, I don't disagree 
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1 with you on that one, John, but the point here 

2 is that when you adjust -- you adjusted the 

3 airborne levels, which is one way to do it. It's 

4 mathematically identical to adjusting the time 

5 that it's settling per --

6 DR. MAURO: Yeah, exactly. 

7 MR. ALLEN: And with the weekends 

8 considered in there, et cetera, the 0.32 factor 

9 you came up with is similar to settling for 7.68 

10 hours per day instead of 24.

11 DR. MAURO: Yes, yes.

12 MR. ALLEN: But right there is a 

13 factor of three difference if our default is to 

14 use 24 hours per day.

15 DR. MAURO: Yes, but we also 

16 acknowledge that there is a build-up and a 

17 decline period. I agree. So it gets a little 

18 complicated.

19 MR. ALLEN: Right, it does. But 

20 I'm just saying, for your values to work out, you 

21 have to essentially assume the airborne value 

22 for a little less than eight hours per day times 
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1 the number of days you have in the table, whereas 

2 we would assume 24 hour a day times 30 days. 

3 DR. MAURO: Well, you're losing me. 

4 Why would 24 hours a day work, I mean, if you 

5 don't have that dust loading 24 hours a day? I 

6 mean, the actual empirical data that shows you 

7 the accumulation on the plates, in Adley, you 

8 know, they were sitting there for 24 hours a day, 

9 but the airborne dust loading was not at that 

10 level that you used for 24 hours a day. So you 

11 have to take that into consideration, and I don't 

12 think you did.

13 MR. ALLEN: I understand that, but 

14 you guys did and in the end the surface 

15 concentration you would calculate out is smaller 

16 than what we would have calculated out.

17 DR. MAURO: Is that right? Okay. 

18 I'm not going to dispute that. So I don't think 

19 we have any disagreement here. What I'm saying 

20 is that we looked at this the way we looked at 

21 it. All our assumptions are there. And you're 

22 pointing a couple things out that I'm not 
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1 disagreeing with. 

2 You know, we certainly could go back 

3 and see what would happen if we left the 0.00075. 

4 And do you agree that the concept that you have 

5 to take into consideration, the fact that you 

6 only have a dust loading for part of the time; 

7 in other words, as opposed to assume the dust 

8 loading is there for 24 hours a day?

9 MR. ALLEN: Well, I think your 

10 analysis showed that the values we've chosen for 

11 this even account for that.

12 DR. MAURO: I know I was looking at 

13 your numbers and I checked them, you know, in 

14 getting ready for the meeting. Unfortunately, 

15 Bill can't be here to carry this one at a higher 

16 level of detail than I can. But I did your check 

17 your numbers and they're actually in table 1 

18 right in the beginning of our report, if you go 

19 up to the beginning o page 5. And I think built 

20 into those numbers is 24 hour a day. 

21 So, in other words, the air dust 

22 loading that we have in the table for the 
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1 geometric mean -- if you have it in front of you, 

2 for 534 and the derivation of the settling days, 

3 et cetera, all that information -- I believe that 

4 reflects the assumption that the air 

5 concentration of micrograms per cubic meter is 

6 present for 24 hours day. Am I right? I mean, 

7 did I get that wrong?

8 MR. ALLEN: I believe you're right, 

9 but I'd have to review these numbers, honestly.

10 DR. MAURO: Yeah. Well, Paul, what 

11 I think we have here -- I mean, I know it's 

12 important that we get to GSI and you want to -- I 

13 don't think we have anything -- I think that we 

14 fundamentally agree that there is a strategy 

15 that should be used here. 

16 We carried it a level of granularity 

17 that was a little higher, a little finer in order 

18 to explore the value and the merits of the 30. 

19 And our take-away is that 30 is a good number for 

20 large areas, like areas the size of half a 

21 football field. But when you get to smaller 

22 rooms, there might be a problem. 
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1 And now these other matters that 

2 we're talking about, such as what is the air dust 

3 loading you should use, I think we're in 

4 agreement that when you're calculating what's 

5 accumulating on a surface the right thing to do 

6 is what is the -- for, you know, the accumulation 

7 you would use the concentration that represents 

8 the 24-hour average, because that's what 

9 accumulates. Accumulation is going on all the 

10 time, 24 hours a day. But the airborne dust 

11 loading is not always at the high level that you 

12 might measure during operation. It might be 

13 high during operation. And then if they are not 

14 working 24 hours a day, it's lower. So we're in 

15 agreement. And where the numbers come out, they 

16 come out.

17 We also agree, SC&A, that I don't 

18 think we should gild the lily on the 0.00075. We 

19 did do that here. It carried into our analysis. 

20 We used 0.00053 because it had the slip factor. 

21 But I would also agree that maybe that's taking 

22 it a little bit too far in terms of trying to, 
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1 you know, sharpen the point to a point that we 

2 can't go.

3 So, I mean, I think, in principle, 

4 the only thing that we're arguing here is that 

5 take into consideration that maybe the smaller 

6 rooms behave different than these large open 

7 areas. And also take into consideration the 

8 daily average concentration of the airborne dust 

9 loading. And that's really what we're 

10 saying.**

11 Now, the numbers we have, that we've 

12 calculated, you know, the assumptions we use are 

13 what they are. And I would say that, you know, 

14 if, David, you feel that some of those numbers 

15 need to be adjusted because maybe we didn't do 

16 it the way you felt it should be done, I'm not 

17 going to disagree with that. I mean, I can't say 

18 you're right or you're wrong, but, you know, if 

19 there is some aspect to how we derived these 

20 numbers, some assumptions we've made that you 

21 feel need to be corrected, I'm fine with that. 

22 It's really the concept that I'm interested in. 
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1 So, Paul, you know, I think it would 

2 be unfair to automatically conclude that, yes, 

3 you know, SC&A's numbers here are what should be 

4 adopted. I would say, no. You know, maybe a 

5 little more polishing of the apple is needed in 

6 what should be the numbers that represent large 

7 rooms versus smaller rooms. And where we come 

8 out on that, you know, may be a little different 

9 than our table after both NIOSH and SC&A maybe 

10 have a chance to look at some of the points that 

11 David is making. 

12 David, are we in agreement 

13 fundamentally that that approach that I just 

14 described is how we should go?

15 MR. ALLEN: Well, I'm not positive 

16 I followed the whole approach you described.

17 DR. MAURO: Well, all it means is 

18 that, when you look at the Adley data, don't just 

19 aggregate all the numbers from all the rooms. 

20 Let's parse it out where we can and see if the 

21 settling times are substantively different for 

22 different rooms.
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1 DR. NETON: Hey, John, this is Jim. 

2 I'd just like to interject something here. I 

3 think what we really need to look at is the 

4 ultimate goal here, which is to estimate the 

5 surface concentration as a result of airborne 

6 activity. What does it accumulate to? What's 

7 the value? And what Dave has said, and it's 

8 true, we use values that are more conservative 

9 than what you've used in your calculation. We 

10 use this 0.00075. We've assumed that it settled 

11 over 24 hours. But in using those conservative 

12 assumptions we end up with a higher surface 

13 contamination than you have generated or 

14 predicted using your more realistic 

15 assumptions.

16 DR. MAURO: Is that right? I mean, 

17 I can't --

18 DR. NETON: That's the bottom line 

19 here. So the reality is what you've done with 

20 your more sophisticated model is to demonstrate 

21 that our conservative model appears to be 

22 exactly that: it's conservative.
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1 DR. MAURO: All right. Let me 

2 think about that for a second. Jim, but if you 

3 have a higher -- you went with a higher -- I mean, 

4 let's just talk about the settling velocity.

5 DR. NETON: Settles faster.

6 DR. MAURO: If it's settling 

7 faster --

8 DR. NETON: Right.

9 DR. MAURO: So then if you're 

10 settling faster, the time it takes --

11 DR. NETON: And 24/7.

12 DR. MAURO: It's going to 

13 accumulate. It's going to reach equilibrium 

14 sooner.

15 DR. NETON: Yes.

16 DR. MAURO: Granted. And then the 

17 average concentration, if it's lower -- you 

18 know, in other words, if we go with the average 

19 for the 24 hours as opposed to the eight-hour. 

20 Now, if the concentration is lower, though, 

21 that's going to make it longer. So I don't think 

22 both assumptions --
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1 DR. NETON: No. No, if you're 

2 settling a high concentration for 24 hours --

3 DR. MAURO: In other words, you want 

4 it to --

5 DR. NETON: All I can tell you is if 

6 you do the calculation your way using your -- you 

7 know, the surface concentration is a product of 

8 the settling rate, the air concentration and the 

9 time that it settles. Right?

10 DR. MAURO: Right, but there's also 

11 the average concentration in the air. So, I 

12 mean, you know what it is, we got three 

13 parameters: deposition velocity; the average 

14 concentration in the air, which I think, you 

15 know, you folks used what I consider to be a 

16 higher concentration.

17 DR. NETON: Exactly. So we're 

18 settling a high concentration over with a higher 

19 settling velocity which maximizes the surface, 

20 the contamination on the surface.

21 DR. MAURO: And then the outcome, 

22 you're saying, ends up with activity on the 
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1 surface that's higher than ours.

2 DR. NETON: That's what we've been 

3 saying all along.

4 DR. MAURO: My goodness. 

5 DR. NETON: Except for this one case 

6 of the furnace room in the spring.

7 DR. MAURO: Yes. Well, listen, 

8 Jim, very good. I mean, I'm not going to dispute 

9 you. I'd sure like to --

10 DR. NETON: But you need a chance to 

11 run the calculations. But that's what David's 

12 been saying since the last meeting.

13 DR. MAURO: Oh, okay. Listen, I 

14 accept that, Jim. I'd like to pass this on to 

15 Bill. I said, I'm filling in for him. But what 

16 you're saying makes sense to me. 

17 Paul, I wish I could be 

18 conclusionary here at this time, but, you know, 

19 I would like to have a chance just to talk about 

20 this question of -- and you're right, ultimately 

21 the issue is the build-up -- not the settling 

22 duration, but are we sure we're being 
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1 claimant-favorable in the amount, becquerels 

2 per square meter on surfaces? 

3 And what I'm hearing is arguments 

4 that that's really the point. And I agree with 

5 that. But I would like to give Bill a chance to 

6 look at this before, you know, we close the door. 

7 I'm sorry I can't answer the question 

8 definitively and agree right now, but what 

9 you're saying certainly seems reasonable. 

10 CHAIRMAN ZIEMER: This is Ziemer. 

11 Yes, we can certainly do that. We would want 

12 that to occur fairly soon so that we can close 

13 this out. I think this is the only remaining 

14 open issue on the matrix for TBD-6000. 

15 DR. MAURO: I think you're right. 

16 A real quick aside: I have a 2010 matrix for 

17 TBD- 6000. Is that the latest matrix?

18 CHAIRMAN ZIEMER: Yeah, October 

19 12th, 2010. And then we have this follow-up on 

20 Revision 1 that Bill Thurber worked on, and 

21 that's where this question has arisen.

22 DR. MAURO: Okay.
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1 CHAIRMAN ZIEMER: So it came up in 

2 that context. Actually, most of the items were 

3 in abeyance or resolved on the original one. 

4 But, in the meantime, this revision came out and 

5 we had that sort of open item.

6 DR. MAURO: Okay.

7 CHAIRMAN ZIEMER: So we do need to 

8 get this closed so that we can take formal action 

9 on it. But I think what you are 

10 suggesting -- and then we'll get some comment 

11 from others here on this -- was for SC&A to 

12 double-check the calculations that give the 

13 surface contamination level, right?

14 DR. MAURO: Right. Exactly. 

15 Exactly. And that won't take long. Bill will 

16 be available Monday and I'll sit down with him. 

17 We'll talk it over. I mean, I understand 

18 exactly what Jim and David are saying. I'll 

19 just talk to Bill about it. He and I will put 

20 our heads together, you know, with John Stiver, 

21 and we'll get something out quickly.

22 I know next week we'll be in Denver, 
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1 but perhaps Bill could put together something 

2 that week while we're in Denver. In fact, we 

3 could even, perhaps, you know, let you know so 

4 that you have it for the Denver meeting. And it 

5 would be nice to be able to say, yes, we've 

6 resolved this. 

7 I mean, I have to say, my instincts 

8 tell me that Jim is right and David is right in 

9 terms of the build-up, but I don't want to do that 

10 until I give Bill a chance to --

11 CHAIRMAN ZIEMER: No, understood.

12 DR. MAURO: Yes.

13 CHAIRMAN ZIEMER: Understood. Let 

14 me ask if other Work Group Members have questions 

15 or comments on either the paper or for Dave or 

16 for John.

17 MEMBER MUNN: Well, this is Wanda. 

18 I had several questions coming into this, but I 

19 think that what I've heard in the discussion here 

20 has cleared up most of them. As a matter of 

21 fact, I think it's probably cleared up all of 

22 them. I had some questions about 
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1 concentrations and the amount of work hours that 

2 were being assumed and that sort of thing, but 

3 it sounds to me as though that's pretty well been 

4 covered.

5 One of the requests that I have with 

6 respect to where we're going with the overall 

7 TBD-6000 issues is that it would be very helpful 

8 for me, I don't know if others would like to have 

9 an updated copy of the matrix or not, but it would 

10 be very helpful for me if I could receive an 

11 updated version of the matrix so that I had a 

12 better feel of exactly where we were.

13 CHAIRMAN ZIEMER: Yes, I think we 

14 can certainly ask SC&A to distribute that. I 

15 believe the updated version of the original 

16 matrix is dated October 7th, 2010, but this 

17 material grew out of supplementary comments on 

18 Rev 1 that were prepared by Bill Thurber, and 

19 that's dated May 13th of this year, 2013.

20 MEMBER MUNN: Yes, we have that in 

21 our files for reference.

22 CHAIRMAN ZIEMER: And if you look at 
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1 that one, there's a number of sort of bottom line 

2 bullet points in that. Of those bullet points, 

3 there was agreement on everything except this 

4 one issue where we asked for NIOSH's response, 

5 which is what generated the White Paper. And 

6 there was one other thing, one other bullet point 

7 where there were some actual errors in the tables 

8 of section 7 of TBD-6000 which NIOSH already 

9 agreed to correct. 

10 So those were the two open items. 

11 But if we can bring this to conclusion fairly 

12 rapidly, we could close out the TBD-6000 issues 

13 so that they're all in place.

14 MEMBER MUNN: It would be helpful.

15 DR. MAURO: Yeah, Paul, I think that 

16 I'm optimistic that we could do that within a 

17 matter of a couple days. That is, we'll get on 

18 it on -- well, Monday's a holiday. Well, 

19 anyway, we'll get it on this week. And it's not 

20 going to take very long with the help of Rose and 

21 Bill to put all this to bed, get a final updated 

22 matrix that reflects the May 13th material, and 
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1 of course today and the other White Paper 

2 material that is here. And also, as I said, my 

3 instincts tell me that we probably have just 

4 resolved this matter, but we'll give Bill a 

5 chance. And that will all be reflected in the 

6 matrix.

7 If for any reason our take-away 

8 later is that, no, we're not really in agreement 

9 here, I will certainly immediately let you know. 

10 But, as I said, it sounds like we are.

11 MEMBER MUNN: That would be very 

12 helpful, John, and much appreciated. Thank 

13 you.

14 DR. MAURO: Sure.

15 CHAIRMAN ZIEMER: Okay. Other 

16 questions or comments, Josie or John?

17 MEMBER POSTON: I don't have any 

18 questions. I agree with what Wanda said.

19 MEMBER BEACH: And this is Josie. 

20 I agree, also, with the discussion. I just have 

21 a quick question. John, what you're going to 

22 discuss with Bill, is that going to bring in the 
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1 30-day settling time versus the --

2 DR. MAURO: Yeah, it really means 

3 the settling time is really not relevant.

4 MEMBER BEACH: Okay.

5 DR. MAURO: What's relevant 

6 is -- and I agree with this -- is what's the 

7 concentration in becquerels per square meter 

8 that you're going to assume is the starting point 

9 for your residual period? And is it 

10 claimant- favorable? And, you know, what we're 

11 hearing from Jim and David is that, when you go 

12 to first principles, that their levels that they 

13 calculate are higher than what we would 

14 calculate. Now, intuitively, I mean, if that's 

15 true, it's true. But we would like to check 

16 that.

17 MEMBER BEACH: Okay. So I just 

18 wasn't clear on that.

19 DR. MAURO: Yeah, and that would be 

20 great if it turns out it comes out with a higher 

21 value. Now, I don't know why then we would have 

22 different settling times. That seems to be 
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1 non-conservative, but I could see how those 

2 things could play themselves out. And the most 

3 important thing is what is the build-up on the 

4 surface that's going to be used? And that 

5 doesn't take long. And I'm sure that Bill and 

6 Rose would be able to take care of it, you know, 

7 next week while we're doing our thing in Denver 

8 and to get this finished up for everyone's 

9 consideration sometime next week.

10 CHAIRMAN ZIEMER: Okay. Thank you 

11 very much. Any other comments? 

12 (No response.)

13 CHAIRMAN ZIEMER: So we'll look 

14 forward to hearing from you guys fairly soon. 

15 We can talk at the meeting next week about the 

16 potential -- I'm hopeful. I'm not optimistic 

17 that we're going to be able to get far into the 

18 matrix today of Appendix BB, but I would like us 

19 to be able to move into that fairly rapidly as 

20 well. So we may be able to schedule a meeting 

21 in the fairly near future to address both of 

22 these, what really will end up being the matrices 
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1 issues. So make sure that we're in a position 

2 to address open items that may not have been 

3 closed or dealt with fully.

4 Okay. Let's move on specifically 

5 now to GSI.

6 MEMBER MUNN: Paul, I have one 

7 question before we go. 

8 CHAIRMAN ZIEMER: Oh, yes.

9 MEMBER MUNN: Are we going to be 

10 using our Live Meeting capability with visuals 

11 at all?

12 CHAIRMAN ZIEMER: I don't know the 

13 answer to that. Do we need anything --

14 MEMBER MUNN: I just was thinking 

15 I'd get off that screen if we're not going to have 

16 material. 

17 CHAIRMAN ZIEMER: Live Meeting is 

18 available ad the Work Group Members. I don't 

19 know if SC&A has something they wanted to 

20 present.

21 DR. ANIGSTEIN: This is Bob 

22 Anigstein. I have a briefing that I was going 
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1 to present.

2 MEMBER MUNN: Oh, good.

3 DR. ANIGSTEIN: And Ted and Zaida 

4 both have sent me invitations. I don't know 

5 about everyone else.

6 MEMBER MUNN: That's fine. Thanks 

7 much.

8 CHAIRMAN ZIEMER: Well, I'm looking 

9 here and I think the Work Group Members are on 

10 there. I assume that what you are going to 

11 present is just a summary of what's in your 

12 document itself?

13 DR. ANIGSTEIN: Well, it's slightly 

14 expanded because of Dave Allen's latest 

15 communication. But you are correct, it's not 

16 new material.

17 CHAIRMAN ZIEMER: Well, I want to 

18 make sure that whatever you present here we will 

19 be able to make it available fairly quickly. I 

20 know it has to be reviewed through -- fairly 

21 quickly to petitioners and members of the public 

22 so that there's not a big time delay before they 
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1 get to see the --

2 DR. ANIGSTEIN: Sure. I will send 

3 it to Ted as soon as we're finished.

4 CHAIRMAN ZIEMER: Okay.

5 DR. McKEEL: Chairman Ziemer, this 

6 is Dan McKeel. May I make a comment, please?

7 CHAIRMAN ZIEMER: Sure.

8 DR. McKEEL: I requested that if 

9 anyone -- Dave Allen or Bob Anigstein, 

10 SC&A -- were going to make a presentation at this 

11 meeting that I be sent a copy. That must have 

12 been at least a month ago. It may have been two 

13 months ago. So, you know, this is very, very 

14 disturbing. It happens over and over. You all 

15 know that the petitioners need this information. 

16 There's no reason that couldn't have been sent 

17 to me ahead of time. So that's my comment. 

18 CHAIRMAN ZIEMER: Yes, thank you, 

19 Dan. I don't think this has been made available 

20 to any of us in advance. I assume it probably 

21 got prepared last night or something.

22 DR. ANIGSTEIN: You're right.
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1 CHAIRMAN ZIEMER: But, in any 

2 event, it does have to go through that process, 

3 so we'll try to get it available as soon as we 

4 can. You will hear verbally what is being 

5 presented. But I know you want the written 

6 material as well, so we'll do our best to get that 

7 out to you.

8 So we have the White Paper that Dave 

9 Allen prepared in August. And then we have the 

10 response from SC&A, which was dated October 6th. 

11 And then shortly after that on -- the date that 

12 I show here is October 10th, we got some feedback 

13 from Dave Allen reacting to the SC&A comments. 

14 So we have all of that. And then we also -- I 

15 assume everybody has had a chance to see Dr. 

16 McKeel's comments as well, and we'll give him an 

17 opportunity to comment as well. 

18 And I think, Dan, on our agenda where 

19 it says -- you're showing as item D, if you're 

20 agreed, I'll move you up so that you're -- we're 

21 not going to dispose of Appendix BB issues until 

22 you have a chance to comment on the documents 
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1 here that are before us. So I'll move you up to 

2 comment right after the SC&A review here. 

3 DR. McKEEL: Thank you.

4 CHAIRMAN ZIEMER: So I think again 

5 we've had the chance to see the original paper 

6 by Dave. 

7 Dave, unless you have comments on 

8 it, we'll save your responses until after SC&A. 

9 Do you have any comments, general comments to 

10 kick that off, or shall we right into the SC&A 

11 review?

12 MR. ALLEN: No, that would be fine.

13 CHAIRMAN ZIEMER: Okay. So, Bob?

14 DR. ANIGSTEIN: Okay. I didn't 

15 expect to be on immediately. One second. Let 

16 me get into the Live Meeting.

17 DR. MAURO: I'm sorry to interrupt, 

18 but this is John. I went to Live Meeting, it 

19 came in on my email, and I'm looking at 

20 something, and there's a blue screen that says 

21 nothing is currently shared. Is everyone else 

22 looking at the same thing?
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1 DR. ANIGSTEIN: Yes, nothing is 

2 shared.

3 DR. MAURO: Oh, okay. I just --

4 DR. ANIGSTEIN: It'll change in the 

5 next 60 seconds.

6 DR. MAURO: Ah, that's why I asked. 

7 Okay. I'm where I should be. Thank you.

8 CHAIRMAN ZIEMER: So we'll stand by 

9 for a minute while that material is pulled up.

10 DR. MAURO: Okay.

11 MEMBER MUNN: I'm beginning to 

12 regret having asked the question.

13 DR. ANIGSTEIN: Oh, dear. Let's 

14 see. Can anyone help me with this? Because I 

15 tried this out yesterday, We seem to have a 

16 problem, and I did find a place where it says 

17 "share." And now I don't see a screen which 

18 allows me to share. Ted, can you -- oh, Dave 

19 Allen is currently sharing, but --

20 MR. ALLEN: Sorry, Bob, that was me. 

21 I was trying to figure it out myself.

22 CHAIRMAN ZIEMER: Well, okay. 
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1 Click on the thing called "content" at the far 

2 upper left. 

3 DR. ANIGSTEIN: Upper left I just 

4 see attendees, voice and video meeting. 

5 CHAIRMAN ZIEMER: Further left. 

6 Before "attendees" there's another thing called 

7 "content."

8 DR. ANIGSTEIN: Nope, not on my 

9 screen. 

10 CHAIRMAN ZIEMER: Really? You see 

11 something called "attendees?"

12 DR. ANIGSTEIN: Yes. I see 

13 "attendees" and I see my name.

14 CHAIRMAN ZIEMER: "Attendees" on 

15 mine is the second box from the left. 

16 DR. ANIGSTEIN: No.

17 CHAIRMAN ZIEMER: The first item is 

18 called "content." And then if you click on 

19 that --

20 DR. ANIGSTEIN: No, no, I don't have 

21 anything to the left of "attendees."

22 MEMBER MUNN: That's interesting, 
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1 because mine shows you as desktop under 

2 "content."

3 DR. ANIGSTEIN: My desktop has Paul 

4 Ziemer has started sharing.

5 CHAIRMAN ZIEMER: I clicked on your 

6 name, which --

7 DR. ANIGSTEIN: Link to Live 

8 Meeting. 

9 MR. KATZ: Paul?

10 DR. ANIGSTEIN: Yes.

11 MR. KATZ: Paul, let's try 

12 something. Paul or Dave, why don't you forward 

13 your link to Bob?

14 CHAIRMAN ZIEMER: How do I do that?

15 MR. KATZ: You just copy and paste 

16 your calendar invite into an email and send it 

17 to Bob. Or send it to me and I can send it to 

18 Bob if you don't --

19 DR. ANIGSTEIN: Excuse me. Send it 

20 to my regular, my [identifying information 

21 redacted].
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1 MR. KATZ: Yes, so if you don't have 

2 that, I can send it to him. You can send your 

3 link to me and I'll send it to him.

4 DR. ANIGSTEIN: The funny thing is 

5 I tested it last night and it worked.

6 MR. KATZ: Oh, then, yeah, I don't

7 understand. Well, which way did you go in this 

8 morning? Did you go in through my forward or 

9 through your original thing that you used 

10 yesterday?

11 DR. ANIGSTEIN: Yeah, I went into 

12 your forward.

13 MR. KATZ: Okay. So, drop it. 

14 Drop your Live Meeting and go in from the invite 

15 you had before that you tested last night.

16 DR. ANIGSTEIN: Okay. All right. 

17 Just a second.

18 MR. KATZ: Yes. Yeah, go ahead and 

19 go back in that way. Then, Paul, you don't need 

20 to do anything because he has it.

21 CHAIRMAN ZIEMER: Okay.

22 MR. KATZ: That will work.
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1 DR. ANIGSTEIN: Okay. 

2 MR. KATZ: Okay. So go back to what 

3 you used last night, that link.

4 DR. ANIGSTEIN: I will. Give me a 

5 second. Give me a second. 

6 MR. KATZ: Yes. No, I know. I'm 

7 just saying that should work.

8 DR. ANIGSTEIN: I hear you. Just 

9 give me a second.

10 MR. KATZ: Because probably your 

11 problem is that I think Zaida doesn't have me as 

12 a presenter, and that's probably why you're 

13 showing a different screen. And I forwarded you 

14 my link.

15 DR. ANIGSTEIN: I see invitation to 

16 Live Meeting. Okay. Join the meeting. 

17 Continue. Content. Yes, it is different.

18 MR. KATZ: Yeah, good. Thank you.

19 DR. ANIGSTEIN: Share desktop. 

20 Okay. Nothing is currently shared. Okay. 

21 Does anyone see it?

22 MR. KATZ: Yeah, that works, Bob.
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1 MEMBER MUNN: Yes, we see what's 

2 going on on your desktop.

3 DR. ANIGSTEIN: Okay. Very good. 

4 All right. So, sorry for the delay and 

5 confusion. 

6 MEMBER MUNN: No problem.

7 DR. ANIGSTEIN: Okay. I'll try to 

8 go through this quickly. One second. Sorry. 

9 CHAIRMAN ZIEMER: Bob, let me 

10 interrupt you a minute. On our screens your 

11 slides are very large, at least on mine.

12 MR. KATZ: That's true for 

13 everybody, I think.

14 DR. ANIGSTEIN: They're too large?

15 MR. KATZ: Yes.

16 DR. ANIGSTEIN: Oh, I don't know. 

17 I'm using full screen.

18 CHAIRMAN ZIEMER: Well, they're 

19 more than full screen. 

20 DR. ANIGSTEIN: Okay.

21 CHAIRMAN ZIEMER: They're about 

22 double screen size.
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1 DR. ANIGSTEIN: Ah, wait a second. 

2 Right. If you give me a little bit --

3 MR. KATZ: Right, just go to 75 

4 percent or --

5 DR. ANIGSTEIN: Is this better? 

6 CHAIRMAN ZIEMER: Make them 

7 smaller. You're at about 100 percent. Make 

8 them about 75 and see what that does.

9 DR. ANIGSTEIN: Is this too large 

10 still?

11 MEMBER MUNN: Yes, it is.

12 DR. ANIGSTEIN: Okay. Our screens 

13 are different. How is this?

14 CHAIRMAN ZIEMER: Much better. 

15 Still a little large, but --

16 DR. ANIGSTEIN: All right. I'll 

17 make it 50 percent. Okay?

18 CHAIRMAN ZIEMER: That works.

19 DR. ANIGSTEIN: Very good. Okay. 

20 I guess I'm used to doing this for the meeting, 

21 you know, when we really are a live meeting with 

22 a projector.
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1 MEMBER MUNN: Yes.

2 DR. ANIGSTEIN: Okay. So just for 

3 purposes of reference, the time periods we're 

4 talking about, October 1st through the newly 

5 revised start of operations. And the main 

6 source of exposure, the two sources of exposure 

7 were the two radium sources and what was then the 

8 24 MeV betatron. Then on May 21st, GSI acquired 

9 the cobalt-60 sources and they presumed to have 

10 stopped using the radium because they were under 

11 orders from State of Illinois to do so. 

12 Somewhere late 1963 -- I just 

13 arbitrarily said the October 1st, because it's 

14 not likely to have been any earlier than 

15 that -- the new betatron went into operation. 

16 And the main difference between the new betatron 

17 and the old betatron is that the new betatron 

18 building was physically connected to the 

19 production buildings. So it was right off the 

20 No. 10 building. 

21 And so there was a potential for 

22 people working -- workers in the, I think they 
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1 were called cleaning and finishing buildings, to 

2 be exposed to the new betatron depending on the 

3 certain exposure circumstances. Where it was 

4 not possible with the old betatron. So there is 

5 a new change there. 

6 And it happens to be the year after 

7 the radium sources went out of use. And, 

8 consequently, since NIOSH for convenience tends 

9 to work with calendar years -- so '62 would still 

10 be the radium era, and '63, I propose, should 

11 be -- and we have proposed in the past -- let's 

12 call it the new betatron era. And then June 

13 30th, '66, is the last purchase order, so it was 

14 the end of the operation period, beginning of the 

15 residual period.

16 Okay. The bounding sources during 

17 these periods -- so the radium -- actually I just 

18 covered it. Radium would be the bounding source 

19 during the radium era, which was essentially the 

20 first 10 years of operation. Then at all times 

21 you have some potential for stray radiation from 

22 the betatron, but particularly during the 
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1 betatron era, because earlier any doses from 

2 that operation would be overshadowed by the 

3 doses from the radium. And at all times you 

4 would have delayed radiation from activated 

5 metals. So it could be either steel or uranium. 

6 And then the third source of 

7 radiation would be the exposure to the skin to 

8 beta radiation, which would be either from 

9 handling even the natural uranium before it is 

10 irradiated, and much more so with the irradiated 

11 uranium, which has photo-activated uranium 

12 isotopes, and the activated steel. 

13 The bounding scenarios. There are 

14 areas of agreement. I'm not even mentioning the 

15 administrative personnel where NIOSH has 

16 proposed an exposure scenario, and SC&A is in 

17 agreement with it.

18 During the radium era, the Work 

19 Group at the meeting on February 21st agreed, it 

20 was mutually agreed that we would have a 

21 triangular distribution. The lower end would 

22 be a calculation, I believe, that NIOSH had made 
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1 of 6.279 rem. I think it's a bit precise, but 

2 anyway. The mode would be 9.69 rem based on an 

3 SC&A calculation. And then the upper would be 

4 the limit, the AEC exposure limit, because in 

5 this AEC application -- in this application of 

6 AEC, GSI stated that, "when we were operating 

7 with the radium," even though they weren’t 

8 controlled by AEC, "we always abided by the 

9 then-applicable AEC limits." 

10 So it seems that they were aware that 

11 the AEC limits changed over time. And NIOSH has 

12 the change over from 15 rem to 12 rem in 1957

13 because that was the publication date of an NBC 

14 Handbook. However, that was not adopted by AEC. 

15 There were just, I guess, bureaucratic or 

16 administrative delays. And through the end of 

17 1960, there was a 10 CFR 20, which I'm sure most 

18 of us are familiar with. And earlier than that 

19 they were following, I believe, NBS Handbook 44, 

20 both of which in effect allowed doses up to 15 

21 rem a year. It would be on a weekly basis, a 

22 monthly basis, but it translated to a possible 
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1 dose of 15 rem a year.

2 There was a Federal Register notice 

3 in late 1960 saying that, effective January 1st, 

4 1961, the new 10 CFR 20 dose limits went into 

5 effect, and those permitted 3 rem a quarter. 

6 And depending on the prior exposure history of 

7 the worker it could be as much as 12 rem a year. 

8 So SC&A's position is that we're in 

9 agreement with the numbers, but the changeover 

10 should be January 1961, not 1958.

11 And also, NIOSH had it with the 

12 12-rem limit going through 1963. I don't know 

13 if that was an error, because there was no radium

14 in 1963. The radium sources were retired in 

15 1962. 

16 So we propose ending in 1962 -- I 

17 mean, through 1962, just for making the 

18 convenience of the entire calendar year. And 

19 then the new betatron, since it went into 

20 operation sometime late in 1963, if that's 

21 consistent with NIOSH's procedures, start that 

22 scenario in 1963. And in both cases through 
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1 1966. And what we mean, the middle of the 1966 

2 when the period of operations ended. 

3 Then I would say the major thing of 

4 this agreement is we both agree that the layout 

5 man who is working in the No. 10 building just 

6 outside the betatron -- and this is a realistic 

7 scenario in that often they 

8 would -- radiographic casting, look at the -- and 

9 then they would take it out of the betatron room 

10 because they wanted to get another casting in, 

11 and unload it nearby. And the layout man would 

12 then literally crawl over the casting, if it was 

13 kind of a shape, and with the film or the previous 

14 exposure in hand, mark the areas where the 

15 grinders and chippers and welders would have to 

16 repair the casting. 

17 I made this analogy at the previous 

18 meeting: very much like a dentist takes an X-ray 

19 and says, a-ha, here's a cavity. This is where 

20 I have to drill and put in a filling. It's a very 

21 close analogy. They have hidden cavities and 

22 they grind them out and then the welder fills 
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1 them in.

2 Okay. So there's more than a 

3 twofold difference in the dose that we 

4 calculate. We calculated in roentgens. 

5 NIOSH, I'm not sure what units they used, because 

6 in one report they say R or mR. In another 

7 report they say rem. And the number is 

8 identical, so I think they're using the units 

9 interchangeably.

10 And then the neutron dose comes from 

11 exactly the same scenario, because the electrons 

12 hitting the platinum target in the 

13 betatron -- the primary purpose is to generate 

14 X-rays, but they also generate neutrons. 

15 The reason for this disagreement, 

16 NIOSH used 15 different shooting scenarios which 

17 we do not agree with. Some of them are at a 

18 45- degree angle to the axis. It's a 

19 cylindrical casting that we use as an example, 

20 but we haven't had detailed information on it, 

21 even photographs of it. So we just use that as 

22 a typical casting. And they would not make 
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1 radiographs at a 45-degree angle to the axis. 

2 It just would not provide any useful 

3 information. So there are several of those 

4 scenarios. Those 15 scenarios, a number of them 

5 have that angle, I think maybe 10 of them, which 

6 we think are unrealistic.

7 The betatron positions, they've 

8 just put the thing arbitrarily in several 

9 different positions, three or four different 

10 positions in a betatron shooting room. Again, 

11 we found that an arbitrary selection. 

12 But the main argument we have is that 

13 out of those 15 scenarios NIOSH made the 

14 stipulation that we have the -- I should have 

15 shown it. I did have a drawing. Just a second. 

16 I did have a drawing. Well, here is -- I don't 

17 have it shown here. I have it another place. 

18 But somewhere in this region where you can see 

19 my mouse moving was a storage area. It was a 

20 storage rack for the film badges that were kept 

21 there when the workers were off duty, or at least 

22 left the betatron room. 
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1 And NIOSH's position is that those 

2 badges could not have received more than 10 

3 millirem a week because the vast majority of the 

4 badges have a reading of M for minimal, which 

5 means 10 millirem or less. And therefore they 

6 say that no matter what the scenario is, those 

7 badges could not have been exposed, the control 

8 badges. And that is contrary to information. 

9 First of all, we do know that's where 

10 the film badges were stored. The NIOSH model 

11 treats this whole region as empty space. In 

12 reality there are walls there. There is 

13 furniture there. There is equipment there, of 

14 which we have no detailed information. So the 

15 MCNP model calculated the exposure to the film 

16 badge rack as incomplete. It also assigns an 

17 unrealistically low density to this brick wall. 

18 Now, we're responsible for that, 

19 because in the original analysis we performed 

20 back in 2007 we were trying to maximize the dose 

21 to the control room operators. So since we 

22 didn't know what this wall was made of, we gave 
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1 it the lowest plausible density. We have since 

2 learned, based on the information that was 

3 obtained from NRC through Dr. McKeel's FOIA 

4 request, there was more detail and that these 

5 were filled, as you would expect, from good 

6 practice. These were substantially thicker 

7 walls or denser walls than we had originally 

8 assumed and that NIOSH used in their model. So 

9 there are many reasons why the exposure to this 

10 film badge rack in the NIOSH analysis would have 

11 been overestimated.

12 But the most important reason is the 

13 information that we obtained directly from 

14 Landauer - it just so happens one of our 

15 associates is a former officer from Landauer who 

16 has good contacts and relations with the current 

17 Landauer staff, and he confirmed -- I mean, he 

18 was not there in the 1960s, but he did obtain 

19 information from the records. He asked the 

20 current vice president in charge of operations 

21 to check the record. 

22 And the story they came up with, 
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1 which I included both the summary in my report 

2 and a copy of his memo to me as an appendix, is 

3 that essentially any exposure to the badges 

4 while they were not being worn was zeroed out. 

5 The control badge was zeroed out against itself. 

6 I know that sounds illogical, but that's what 

7 they did. They took the control badge and 

8 subtracted that reading from every other 

9 reading, including that of the control badge. 

10 And only in the case if the control badge read 

11 more than 50 mR and was higher than half of the 

12 other readings, then they would say, okay, here 

13 we have an anomaly and they will report that to 

14 the customer. 

15 But absent that, we really don't 

16 know what the exposures to those unworn badges 

17 were. And you cannot use that, in our opinion. 

18 We cannot use that as a basis for limiting which 

19 of these 15 exposure scenarios can be applied. 

20 So we disagree with the 15 exposure scenarios to 

21 begin with. And then we disagree with the 

22 method in which they were selected. 
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1 And another area of disagreement is 

2 the location of the layout man. This area, 

3 that's not shown here, but this is actually a 

4 diagram produced by the MCNP program itself. So 

5 here is the position of the betatron. Here is 

6 a cross-section of this hollow casting. You see 

7 the horizontal planes, those two lines. And 

8 here would be the railroad track on which the 

9 casting enters and leaves, a straight track. So 

10 the NIOSH model has the layout man in the center 

11 of the railroad track. Well, that's 

12 unrealistic because then you could not have any 

13 railcars coming in or out. 

14 In our analysis we put it on either 

15 side of the railroad track. And it came out, and 

16 it's logical in retrospect, that this was the 

17 most exposed position, because you 

18 have -- except for the fact that there is a thin 

19 sheet metal roll-up door probably 16th of an inch 

20 seal here, you have direct line of sight from 

21 here to the betatron in this orientation, which 

22 is realistic. We do have information from a 
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1 now- deceased betatron operator that those 

2 castings were shot on the railroad track at times 

3 and that this was one of the castings.

4 So whereas the beam is strongly 

5 focused for -- it's not collimated; it is 

6 strongly focused forward. But nevertheless, 

7 there is some stray photon radiation coming off 

8 in this direction and the neutrons are 

9 probably -- I'm not that familiar with neutron 

10 generation, but the neutrons are most likely 

11 omnidirectional. So you do get your neutrons 

12 drifting in this direction. So that's the main 

13 basis for our disagreement. 

14 There was also a badge called 

15 betatron control. We have no knowledge about 

16 this. I mean, it is listed in the film badge 

17 reports. Towards the end they stopped using it. 

18 It may have also been in the old betatron 

19 building, because the supervisor, who's also now 

20 deceased, we interviewed, had his office -- and 

21 he was there until about -- he left the betatron 

22 operation something like November 1964. And he 
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1 had his office in the old betatron building. 

2 It's just as plausible that the betatron control 

3 badge was in his office. We don't know. It's 

4 sheer speculation to say that it was kept in the 

5 betatron control room, absent any such 

6 knowledge.

7 And then, finally, the NIOSH model 

8 included a heavy steel door. I saw in their 

9 earlier MCNP files it was about 0.85 inches, 

10 which is pretty thick steel, whereas the workers 

11 say that it was just a thin sheet metal door like 

12 the kind you would have in a garage door, you 

13 know, a roll-up door on a garage. So, again, we 

14 disagree with the model for that reason.

15 Now, coming to beta exposures. I 

16 have to make a comment about the report by Dave 

17 Allen that just came out, that was distributed. 

18 I didn't get it until yesterday afternoon. 

19 There's a statement in the report that states 

20 that the NIOSH report came out in August, which 

21 is correct, and that the SC&A report giving other 

22 values, our values of beta doses came out on 
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1 October 6th. Now, literally that is correct. 

2 However, there is a misperception that this was 

3 new information. 

4 In fact, the beta doses that are

5 listed in this slide and are in the report, our 

6 October 6th report, were first reported to NIOSH 

7 and the Work Group in March 2012. And that 

8 analysis has not changed. And we have repeated 

9 in at least one other -- there was at least a 

10 presentation made in April to this Work Group 

11 which had these same numbers. So these numbers 

12 are not new information. And it is, I think, 

13 misleading to imply that NIOSH only saw this for 

14 the first time on October 6th.

15 Sorry to have to take that tone, but 

16 there was an implication there that I think is 

17 misleading.

18 Okay. That aside, the other 

19 statement made in Dave Allen's report is that 

20 because he inferred that by looking at our steel 

21 doses he found that if you doubled the steel 

22 doses you get better agreement. No, if you
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1 double NIOSH's steel dose -- he didn't see our 

2 steel doses separate. If you double the 

3 steel -- I'm sorry, I'm skipping around. 

4 There are two components of skin 

5 dose for the betatron operator. And that is 

6 handling uranium and handling irradiated steel. 

7 In other words, the uranium they have to handle 

8 while setting it up the first time. So it's just 

9 natural uranium. 

10 We do assume the Putzier effect 

11 where the edges of these round slices, 

12 cylindrical slices, have this enhanced beta 

13 activity due to the migration of the short-lived 

14 uranium, the other products to the surface of the 

15 casting. And then you have the greater 

16 component which is the activation, or more 

17 correctly you create uranium-237 and -239, which 

18 are both short-lived beta emitters. So that's 

19 the other source of exposure.

20 And then, since the hours of uranium 

21 operation during each year are limited and 

22 they're based on the purchase orders from the 
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1 Mallinckrodt Chemical Works, the rest of the 

2 time the operator is presumed to be irradiating 

3 steel. And since there are many repeat 

4 shots -- I mean, you have the film, they use the 

5 standard chest X-ray film, so it's 14-by-17 

6 inches, if I remember correctly. 

7 So a large casting can be many feet 

8 across, so they keep shooting the same casting 

9 over and over again with overlapping shots. And 

10 so the operator is exposed to the activation 

11 products in the steel from the previous shots. 

12 So that's the second component of his exposure.

13 So Dave Allen's yesterday's report 

14 claims that if they double the exposure from the 

15 steel, then they will come close to matching 

16 SC&A's numbers. And they concluded that SC&A 

17 must have failed to take into account that the 

18 exposure -- that they would only be exposed, you 

19 know, at close range to the steel 50 percent of 

20 the time. That is an incorrect assumption. 

21 I verified our calculations and we 

22 calculated it and there is a factor of two, 
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1 divided by a factor of two to account for the fact 

2 that it's not likely that the entire time the 

3 operator is near the steel, in the shooting room 

4 with the steel casting, that he would be up close 

5 to the steel. 

6 For the uranium we actually have him 

7 at one foot and at one meter, 50/50 for the whole 

8 body, and contact at one meter for the skin and 

9 forearms. For the steel we didn't bother with 

10 the one meter because it's such a low exposure 

11 that we just essentially gave a zero. And we 

12 just had at 50 percent at one foot. So that is 

13 not the explanation.

14 The only plausible working method 

15 which can resolve this would be -- again we sent 

16 NIOSH, as requested, the calculations we had 

17 made back in 2007-2008. We have revised them 

18 simply because that was a trial version of MCNPX 

19 during the activation. And they have refined 

20 and put out a final publicly-released version 

21 which produces much higher concentrations of the 

22 activation products in the steel. And those we 
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1 have not exchanged between us and NIOSH. 

2 So this would require an exchange of 

3 information. You know, if the Work Group and 

4 NIOSH so desires, we can get NIOSH's MCNP files. 

5 I assume they probably use Excel spreadsheets 

6 like we do, for the follow-up calculations, and 

7 we could examine those. And we can share ours 

8 with NIOSH and we can find out, you know, where 

9 the difference lies. 

10 And I agree that the difference is 

11 most likely in the steel. Simply looking at 

12 these numbers on a percentage basis, the 

13 differences are smaller in the early years when 

14 the uranium -- with heavy uranium work, and that 

15 by far dominates the beta dose. And then it gets 

16 smaller. And here towards the end there is 

17 little uranium work, so most of the dose comes 

18 from the steel. And so now it becomes like a 

19 factor of two, almost a factor of two. 

20 There is a consistent difference for 

21 the dose -- this is for the contact dose -- with 

22 the dose at other skin, which we assume would be 
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1 one foot apart, and we don't know what that is. 

2 It could be the thickness of the clothing. I 

3 know we had at one time, in connection with 

4 another site, there was an error in a 

5 NIOSH -- what we would consider a NIOSH analysis 

6 of what is the thickness of a T-shirt or a sweater 

7 that was much -- it was just an unrealistic 

8 number that was -- or I don't know if they're 

9 still using that. I really shouldn't 

10 speculate. I don't know what the reason is.

11 So I think that's -- okay. Oh, and 

12 then internal, for an internal exposure, we have 

13 come close to agreement -- this is my last 

14 slide -- to internal exposure based on the last 

15 several meetings. The one thing we point out is 

16 that at the last Work Group meeting, at the last 

17 teleconference, when I went over the notes, I 

18 have it on record that at least Jim Neton agreed 

19 with our proposal that during what we call the 

20 dark years from October 1st, '52, to February 

21 28th, '58, there are no purchase orders. So we 

22 do not know what the exposure should be during 
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1 that time. 

2 SC&A proposes, based on the 

3 subsequent purchase orders, that there is a 

4 maximum time, which happens to cover a 12-month 

5 period, but it's not a calendar year -- it's, you 

6 know, July 1st to June 30th -- I believe it was 

7 in '61, I think it is, where the maximum for the 

8 year was 437.5 hours based on, you know, we're 

9 paying you so many dollars and you're getting so 

10 much per hour. 

11 So these were the maximum hours. 

12 And it was my understanding that NIOSH agreed to 

13 use those hours under the concept -- you know, 

14 this is like the co-worker model -- if you don't 

15 know, if you have an unbadged worker, one 

16 alternative is assigning the highest dose of the 

17 badge workers, so to assign the highest annual 

18 hours during that period. And NIOSH used what 

19 they considered a more characteristic of 337.5. 

20 So we're 100 hours apart. 

21 And so therefore, since we agreed on 

22 the inhalation parameter, we have agreed on the 
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1 exposure time, you know, the fraction that the 

2 workers would be inhaling, we agreed on the 

3 concentration. I believe it was 68.7 dpm per 

4 cubic meter. And we agreed that they would be 

5 exposed 100 percent during the working hours of 

6 the uranium. So we have, you know, not 

7 surprisingly, a higher intake when it's averaged 

8 over a calendar year of 113 per day versus 91 per 

9 day. 

10 And then we have another period. 

11 And here we have an exact number that we 

12 calculated from the purchase order for that 

13 exact four- month period, March through June 

14 '85, where we have 375. That's annual. So, I 

15 mean, we take those years and prorate them. So 

16 one-third would be 125 hours. So it comes out 

17 to 375 hours per year, again higher than the 

18 NIOSH number. And so again we come up with a 

19 higher inhalation during that period. For the 

20 remainder of that time, we agree with the NIOSH 

21 calculation for '58 through '66.

22 Where we strongly disagree is the 
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1 residual period. We agree with the assumption 

2 about a 30-day settling of the -- I mean, it's 

3 not mechanistically realistic, but it's at least 

4 acceptable results that we agree with, 

5 calculating the floor concentration as if the 

6 95th percentile airborne concentration settled 

7 out over a period of 30 days at 0.00075 meters 

8 per second. So we're in agreement there. And 

9 we're in agreement on the resuspension factor of 

10 10 to the minus 5 during the operation. 

11 Now, the day the operations ceased, 

12 the only difference is the contract ended. So 

13 GSI was no longer radiographing uranium. The 

14 activity on the floor on June 30th, 1966, is 

15 exactly the same as on July 1st, 1966. And we 

16 agree with NIOSH on that. However, the 

17 resuspension factor suddenly drops in the NIOSH 

18 analysis from 10 to the minus five -- I should 

19 have said per meter down here. It suddenly 

20 drops from 10 to the minus 5 per meter to 10 to 

21 the minus 6 per meter. That's not reasonable 

22 and not realistic and it's not 
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1 claimant-favorable because the resuspension is 

2 due to activity in the betatron room. 

3 And the betatron room, since there 

4 were only something like 13 hours during that 

5 last 12- month period, the vast majority of 

6 activity was radiographing steel. And they 

7 continued radiographing steel. And they were 

8 just as busy as they were during the operational 

9 period. There were just as many men walking 

10 across the floor, stirring up the dust, forklift 

11 trucks coming in, wheeled vehicles stirring up 

12 the dust. So there is no reason why the 

13 resuspension factor would drop. 

14 The ten to the minus six per meter 

15 as the resuspension factor came out of an NRC 

16 report. I believe it was numbered NUREG-1720. 

17 And it applied to a quiescent area that has been 

18 decommissioned, has been decontaminated to the 

19 extent reasonable and is basically in a 

20 caretaker status. And that's a reasonable 

21 upper-end value to use for a facility such as 

22 that, because the purpose of that particular 
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1 NUREG was to do a radiological assessment of 

2 decommissioned facilities. And that's what 

3 they agreed on. 

4 This would not apply here. 

5 Certainly there was no major -- we don't know 

6 about the clean- ups. We've heard anecdotal 

7 information that one time or another there were 

8 clean-ups subsequent, but we don't know that 

9 they specifically were clean-ups. They were 

10 certainly not clean-ups under the supervision of 

11 a health physicist or a health physics 

12 technician who had monitored the ground and 

13 said, "okay, guys, here's some contamination. 

14 Clean up here. No, we're okay here." 

15 So our position is that they should 

16 continue using a 10 to the minus 5th resuspension 

17 factor. But we do agree that you should apply 

18 this exponential decrease in OTIB-70. So every 

19 day it decreases by a small fraction. So like 

20 by the end of -- I'm just trying to quote a number 

21 out of my head. But by the time of the FUSRAP 

22 clean-up in 1993 there would just be a small 
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1 percentage left. So the doses would decrease, 

2 but not by the sudden drop, n-fold drop on the 

3 day that the operation period ended. 

4 So, okay. That pretty much winds 

5 up the presentation.

6 CHAIRMAN ZIEMER: Okay. Thank you 

7 very much, Bob. I know that Dave had some 

8 initial responses, some of which you've already 

9 sort of referred to, particularly the issue of 

10 the 50 percent and the 100 percent.

11 But, Dave Allen, why don't you give 

12 us your comments at this point now based on what 

13 you heard and what you'd seen before?

14 MR. ALLEN: Okay. There's a number 

15 of issues there, and I think the first one, or 

16 one of them on the list, is the number of uranium 

17 work hours. I mean, I used the work hours that 

18 we had been using before because I did not recall 

19 any agreement from NIOSH on that particular 

20 issue from the last Work Group meeting. So then 

21 after I saw the SC&A report from a few days ago, 

22 I went back to the transcripts and I still didn't 
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1 gather that from the transcript. 

2 But I'm considering that particular 

3 issue not a major one, and I still think it should 

4 be the value that essentially started in the 

5 period where people -- you know, where we had a 

6 record and not the one year a few years later 

7 where it jumped up and using that. 

8 DR. ANIGSTEIN: I can give you a 

9 page reference to where Jim Neton specifically 

10 was referring to 400 hours.

11 MR. ALLEN: Yeah, and I read that 

12 and I still didn't get that out of it. But that's 

13 beside the point. If the Work Group wants to use 

14 those SC&A hours, and if that's the only issue 

15 holding things up, I definitely don't want that 

16 to hold anything up and I would agree to use the 

17 SC&A values. No problem.

18 DR. NETON: Yeah, this Jim. I'm 

19 okay with those values. I guess, is this 

20 consistent with what we're using for the 

21 external dose assignments as well?

22 DR. ANIGSTEIN: Well, it's not --
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1 DR. NETON: Because, I mean, it 

2 shouldn't be inconsistent with that.

3 DR. ANIGSTEIN: Of course not.

4 DR. NETON: And so what are the 

5 years that SC&A has decided -- or what are the 

6 hours that SC&A is using?

7 DR. ANIGSTEIN: The same hours as 

8 here. The same hours as for the internal, 

9 obviously. I mean, it should be obvious.

10 DR. NETON: If they're consistent, 

11 I agree with Dave: I don't think this is a show 

12 stopper. And given that we have no records back 

13 in that time period, I'm okay with going with the 

14 number of hours that SC&A -- and apparently I 

15 agreed to, although my memory is a little dim 

16 from that meeting, but it makes some sense to me. 

17 You know, given the lack of information in that 

18 time period, to go with the highest value is 

19 somewhat consistent with how we've behaved at 

20 other facilities when we were lacking 

21 information. So I'm okay with that. So I think 

22 that issue is no longer an issue, in my mind.
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1 CHAIRMAN ZIEMER: Okay. 

2 DR. NETON: That may be the easiest 

3 one.

4 CHAIRMAN ZIEMER: Well, you can 

5 agree to that one. Go ahead, Dave. What other 

6 items did you want to address?

7 MR. ALLEN: Okay. I'm taking 

8 things a little bit out of order, but I think 

9 we'll go for the easy ones first. And next one 

10 on my list is the date of the regulation change. 

11 And I'm assuming Bob's correct on 

12 that. I went with the date that the NBS 

13 publication came out, and it makes perfect sense 

14 that it took a couple more years before those 

15 regulations were propagated. So, 1961 -- or 

16 through the end of 1960, as I understood you, we 

17 would use the 15. And then starting January 1, 

18 '61 we would use the --

19 DR. ANIGSTEIN: Twelve.

20 MR. ALLEN: And we're okay with 

21 that. Just making a note here before I go too 

22 far.
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1 CHAIRMAN ZIEMER: Okay. Yeah, and 

2 I can confirm what Bob said, because I was 

3 involved personally when that was changed in 

4 terms of being a licensee. So I know that that 

5 occurred. So we have agreement on that. Okay. 

6 Proceed.

7 MR. ALLEN: And then the next easy 

8 one is Bob pointed out that in my White Paper I 

9 had the radium era ending at the end of -- I'm 

10 sorry, what did I do? I had it ending at the end 

11 of '63. And as Bob, I think, speculated on the 

12 phone there, that was probably just a mistake. 

13 And that's what it was. It was a mistake on my 

14 part. The radium era should be -- I want to get 

15 this right -- through the end of '62, and layout 

16 man dose starting January 1, '63. I think 

17 that's what SC&A --

18 DR. ANIGSTEIN: Yes.

19 MR. ALLEN: Yes. We're in 

20 agreement on that, too. That was a mistake. 

21 CHAIRMAN ZIEMER: Thank you. 

22 Proceed.
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1 MR. ALLEN: Okay. The rest of them 

2 not so easy. First with the resuspension 

3 factor, I know we've continued to have 

4 disagreement with SC&A on that on a variety of 

5 sites, et cetera. But, I mean, the basis that 

6 Bob's talking about just now is that it's an 

7 abrupt change. And that's true, but that's an 

8 abrupt change in an estimate. The truth is, 

9 with just a few hours in 1966 there that they 

10 working with uranium, we think the more 

11 realistic would be ten to the minus sixth, but 

12 we're using ten to the minus fifth because we 

13 don't know at what points in there they work with 

14 it, et cetera. 

15 And, I mean, the basis for that comes 

16 from that NUREG, and as far as the studies that 

17 were used to develop those numbers, and from at 

18 least one of those studies it was a uranium 

19 facility and a study was conducted on the weekend 

20 of an operational facility. So it seems like 

21 aged and activity, because they did a similar 

22 activity without actually the uranium, a 
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1 simulated vigorous activity or something to that 

2 effect. But I think, in that if we're going to 

3 start saying what is aged and what's not, we 

4 might have to define that, if that's what you're 

5 saying.

6 DR. ANIGSTEIN: Well, other 

7 references indicate that contamination 

8 essentially weathers in and the resuspension 

9 factor gradually, exponentially goes down with 

10 time. And that is exactly accounted for by the 

11 OTIB- 70. Whether we say that the resuspension 

12 factor goes down or whether we say that the 

13 contamination level goes down, it's the same

14 effect. 

15 And then, actually, if you were to 

16 take the OTIB-70 approach and say, okay, this is 

17 the NIOSH assumption as to the activity on the 

18 floor at the end of operations, you know, June 

19 30th, 1966, let's decrease it by the fraction. 

20 And it so happens it's 27 years for the final 

21 FUSRAP clean-up. So we decrease it by that 

22 fraction in OTIB-70. You actually come out with 
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1 one-tenth the average activity on the floor than 

2 what was measured by the FUSRAP in the old 

3 betatron building. 

4 So, if you want to use that, you can 

5 say it doesn't go down as quickly as OTIB-70 

6 assumes. But if you say, well, this is a 

7 combination of the actual decrease of the 

8 contamination level and the gradual decrease in 

9 the resuspension factor, then the factor of 10 

10 exactly works out. 

11 MR. ALLEN: Well, I think you're 

12 talking about the direct readings of 

13 contamination.

14 DR. ANIGSTEIN: I'm talking about 

15 the -- in an earlier report I took all the numbers 

16 where they took measurements on the floor of the 

17 old betatron building, the random, not the 

18 biased measurements, but the random 

19 measurements. With the biased measurements 

20 they were of course looking for contamination, 

21 so naturally they found more in localized hot 

22 spots. And it's much higher numbers. It did 
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1 not go down by the OTIB-70 fraction.

2 MR. ALLEN: Yeah, my point --

3 DR. ANIGSTEIN: But that's okay. I 

4 mean, we're still willing to accept the OTIB-70 

5 fraction as a calculational tool, because built 

6 into that -- whether it was intended or 

7 not -- built into that is both the gradual 

8 removal of the contamination, the gradual 

9 exponential decay; not radioactive decay, of 

10 course, of the contamination; and the weathering 

11 in of the remaining contamination, which sort of 

12 makes sense. Obviously, the looser dust goes 

13 away more quickly and the more tightly bound dust 

14 stays longer.

15 But I think you end up with a much 

16 more realistic estimate, I would suggest, with 

17 this approach, because it doesn't give, you 

18 know, unrealistically high release rates 

19 because of the OTIB-70 decrease. If we were to 

20 say that it's 10 to the minus 5th and then the 

21 concentration stays constant for 27 years, I 

22 would agree that that's unrealistic, that it's 
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1 an exaggeration. But I think the other is a 

2 reasonable compromise. 

3 As a matter of fact, in the original 

4 Appendix BB -- and I'm quoting from memory 

5 now -- it gives a different concentration on the 

6 floor and then it cites a number, a single 

7 measurement, that is cited in the -- let's see, 

8 the final was 1993 and there was an earlier 

9 investigation in 1988. I think I've got those 

10 years right. And they cite a number. And the 

11 Appendix BB says, oh, it's half of what we 

12 estimate, so our estimate must be a good number. 

13 Well, actually that's not a logical conclusion 

14 because it should go down by a lot more than half

15 if you use OTIB-70. 

16 So I'm not sure I'm making myself 

17 clear. If you use OTIB-70, we get a tenfold 

18 disagreement between the actual measured 

19 concentration, the average concentrations 

20 measured in 1993, and the predicted ones based 

21 on the assumption of the floor contamination 

22 that NIOSH and SC&A agrees on. 
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1 But if you increase the resuspension 

2 factor by a factor of 10, the net effect of the 

3 airborne concentration and the intake cancels 

4 out and we come out with a pretty good number.

5 MR. ALLEN: Well, I have to admit 

6 you did lose me about halfway through there. 

7 I'm following about half of that argument. 

8 You are saying that the FUSRAP 

9 contamination surveys, compared to our 

10 production contamination estimate reduced by 

11 the OTIB-70 value to that time frame -- you say 

12 it came out higher or lower?

13 DR. ANIGSTEIN: Ten times higher.

14 MR. ALLEN: The actual measurement?

15 DR. ANIGSTEIN: The actual 

16 measurement. I did it two ways: the way I 

17 reported it, I took all the non-detects and 

18 assigned them the MDA value. But even if you 

19 just look at the detects and ignore those, you 

20 know, it's the same rough number. It's within 

21 a factor of two. And in both cases it comes out 

22 roughly 10 times higher than you would predict 
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1 by taking your number and multiplying it by the 

2 27 years, which is something like three percent, 

3 if I remember correctly from OTIB-70.

4 DR. NETON: Bob, this is Jim. Have 

5 we seen that analysis? I mean, I hate to ask, 

6 but --

7 DR. ANIGSTEIN: No, no. No. No.

8 DR. NETON: Yeah. 

9 DR. ANIGSTEIN: Sorry. This is 

10 something that John Mauro and I kicked around in 

11 a conversation and I did not include that. I 

12 agree it should be. We can send you a little 

13 memo on that.

14 DR. NETON: I think that might be 

15 appropriate, because if what you're saying is

16 true, I think you've got something there. 

17 DR. ANIGSTEIN: Okay.

18 DR. NETON: And, you know, I think 

19 we even went back and modified TIB-70 to talk 

20 about resuspension factors and said that we 

21 would do it on a case-by-case basis.

22 And maybe this is one of those cases 
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1 where, if there are data there, we definitely 

2 need to consider it. So I think that's where I'd 

3 leave it at this point, because, you know, it 

4 sound reasonable off the top of my head, but I'd 

5 like to see the data. I'm sure Dave would as 

6 well.

7 CHAIRMAN ZIEMER: So, Bob, SC&A has 

8 already done this analysis, you say? Well, it 

9 sounds like you have. I mean, is it in a written 

10 form that you could provide it pretty --

11 DR. ANIGSTEIN: Well, we do have the 

12 concentrations from the floor. That I have. 

13 That is actually part of what I call the 

14 alternative model, which was not accepted. But 

15 the data is there. Just our theory about 

16 working backwards from that. And I can 

17 certainly excerpt that and forward it. And the 

18 rest of the calculation will, you know, take a 

19 few minutes to write up. Yeah, I can prepare 

20 something.

21 DR. NETON: Yeah, I don't think you 

22 need to put anything elaborate together, Bob. I 
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1 think we understand the logic. Just sort of the 

2 data, you know, calculation?

3 DR. ANIGSTEIN: Yes, will do. 

4 DR. NETON: Okay.

5 CHAIRMAN ZIEMER: And provide that 

6 to the Work Group as well, just so we have that 

7 in our records. 

8 DR. ANIGSTEIN: Of course.

9 CHAIRMAN ZIEMER: Now, I want to 

10 make sure I'm understanding, though, in terms of 

11 the 10 to the minus 6th versus 10 the minus 5th 

12 issue, your argument initially was that nothing 

13 really changes on the day we go into the residual 

14 period, so why should that value suddenly change 

15 by a step function? And there's a certain logic 

16 to that. I think the 10 to the minus 6th, of 

17 course, assumes that a place has been cleaned up 

18 and it's sort of a quiet work area.

19 DR. ANIGSTEIN: Yeah, or a non-work 

20 area. Sort of a custodial.

21 CHAIRMAN ZIEMER: A custodial area. 

22 Would you be proposing that the 10 to the minus 
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1 5th remain throughout the residual period, or 

2 that --

3 DR. ANIGSTEIN: Yes, the 10 to the 

4 minus 5th remains throughout the residual period 

5 and it would be sort of counterbalanced by the 

6 gradual decrease by OTIB-70. So that when you 

7 come to the time of the FUSRAP clean-up, if you 

8 use the greatly reduced floor concentration 

9 according to OTIB-70 and the NIOSH assumptions 

10 scenario and apply 10 to the minus 5th, you will 

11 get approximately the same predicted air 

12 concentration as you would if you used the actual 

13 measured numbers and 10 to the minus 6th.

14 CHAIRMAN ZIEMER: Yes. So this 

15 would be sort of part and parcel to what you're 

16 talking about in the analysis that you would 

17 provide?

18 DR. ANIGSTEIN: Yes, exactly.

19 CHAIRMAN ZIEMER: Because, you 

20 know, intuitively, one would think, all right, 

21 I agree, the step function at the front end 

22 doesn't make sense, but is there some point at 
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1 which it reaches the other mode where it really 

2 is 10 to the minus 6th? But maybe your analysis 

3 sort of compensates for that. Anyway, you're 

4 going to provide that for NIOSH and --

5 DR. ANIGSTEIN: Yes, I'll try to get 

6 it out next week, early.

7 CHAIRMAN ZIEMER: Do I have any?

8 MR. ALLEN: What was that?

9 CHAIRMAN ZIEMER: Questions or 

10 comments on this issue from the Board.

11 MEMBER MUNN: Oh, we didn't hear 

12 that from you. At least I didn't hear it here.

13 I will look forward to seeing Bob's 

14 analysis. It's not intuitively obvious to this 

15 intuition exactly why that would be so, but I 

16 think that I'll be able to follow his analysis 

17 just fine. Thank you for being able to provide 

18 that for us, Bob. That would be helpful for us, 

19 I think.

20 CHAIRMAN ZIEMER: Okay. Dave, 

21 other comments on the other issues?

22 MR. ALLEN: Yeah, moving on to the 
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1 other issues I think where we have disagreement 

2 that's not new here is layout man gamma dose and 

3 the beta dose to the betatron operator. 

4 The layout man gamma dose, we have 

5 looked at the e-mails or the correspondence that 

6 Bob had, you know, about the Landauer dosimetry 

7 and --

8 DR. ANIGSTEIN: I'd like to add, if 

9 I may interrupt, I also had telephone 

10 conversations. So I provided a summary of the 

11 discussion, and not every single item is in that 

12 memo that he provided to me.

13 MR. ALLEN: Okay. But what is in 

14 the memo, I mean, it's not super clear to me, but 

15 it did seem to contradict some of the other stuff 

16 you're saying.

17 DR. ANIGSTEIN: Well, it's not as 

18 clear as it could be. And I did have a 

19 discussion with him afterwards and he confirmed 

20 my interpretation or my understanding. I 

21 shouldn't say interpretation. He confirmed my 

22 understanding of it. Then I asked him to please 
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1 write a memo. And it was some time before he got 

2 around to it, so maybe --

3 DR. NETON: Yeah. Bob, this is 

4 something we might want to get on a technical 

5 call with, because, first of all, as you've 

6 indicated, it's sort of counterintuitive as to 

7 what you're suggesting that their process was. 

8 And it seems to be contradictory in the 

9 attachment that Mr. Zlotnicki wrote. When he 

10 talks about the Landauer procedures, he talks 

11 about how they subtracted the base fog density 

12 from everything --

13 DR. ANIGSTEIN: Yes.

14 DR. NETON: -- including the 

15 control badges, which is fine.

16 DR. ANIGSTEIN: Yes.

17 DR. NETON: And he said if they 

18 subtracted the base fog from the 

19 controlled -- then he said in a normal 

20 situation -- if the control badges were stored 

21 in a low background area, he said in a normal 

22 situation this meant the client controls that 
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1 were stored in a low background area would report 

2 as minimal or effectively zero. 

3 Which I would agree with. If they 

4 were low background and they subtracted the fog 

5 and they came out below the detection limit, they 

6 would report as zero. But it specifically says 

7 they would report them as minimal.

8 In the very next paragraph, when 

9 they're talking about the client badges, it says 

10 the residual dose remaining on the client 

11 control would be subtracted from the batch of 

12 client badges, which makes sense. The next 

13 sentence, "effectively," it says, "the control 

14 badge was set to zero."

15 DR. ANIGSTEIN: Yes, exactly.

16 DR. NETON: That to me is 

17 interpreted to mean they were set equal to the 

18 background dose. It doesn't say that they were 

19 made zero.

20 DR. ANIGSTEIN: Well, okay. I 

21 agree with you that this is a little bit 

22 inconsistent and you only have sort of my -- you 
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1 know, I did provide a documentation. And I 

2 think a technical call -- and if we schedule it 

3 appropriately, Mr. Zlotnicki, excuse me --

4 DR. NETON: Yeah, because Mr. 

5 Zlotnicki's --

6 DR. ANIGSTEIN: -- can 

7 certainly -- you know, he's on our -- he's 

8 available to us and I'm sure he will be happy to 

9 participate.

10 DR. NETON: Yeah, I was thinking 

11 about actually having this before the call, but 

12 we didn't get around to it. But I think this is 

13 a critical area because essentially it is the 

14 determining whether those badges are useable. 

15 And I would agree that if they really made those 

16 badges M, which I find very hard to understand 

17 why they would do that, then, you know, the 

18 badges would not be useable. But, again, I 

19 think this is a critical issue.

20 DR. ANIGSTEIN: Okay. But most 

21 likely it's not something that we can resolve 

22 prior to the Board meeting.
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1 DR. NETON: I don't think so. But 

2 it is a critical issue, I think.

3 DR. ANIGSTEIN: Yes, I agree.

4 DR. NETON: And after reading this 

5 very closely, I don't get the SC&A 

6 interpretation out of this. And I take your 

7 word for it you had more detailed conversations, 

8 but I guess --

9 DR. ANIGSTEIN: No, no. I'll be 

10 happy to. I agree with you completely and, you 

11 know, I will be happy to arrange that.

12 DR. NETON: Now, I'll say that, 

13 given that this remains to be the only 

14 outstanding issue related to the dose of the 

15 layout man. If the other issues can be agreed 

16 upon and this becomes the last issue, then we 

17 need to do this.

18 DR. ANIGSTEIN: Yeah. Well, and 

19 the beta dose.

20 DR. NETON: Well, and the beta dose 

21 as well. But what I'm saying is, as far as the 

22 layout man dose goes, this is one of I guess about 
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1 three issues that come into play: the shielding 

2 of the control badges and the angle of the shots 

3 that Dave chose. Those are two other issues 

4 that need to be resolved as well. 

5 And, again, we have to discuss those 

6 two issues, and if this is the only one 

7 remaining, then we pursue this. Okay.

8 CHAIRMAN ZIEMER: This is Ziemer. 

9 I'm going to suggest, if you can -- I'm not sure, 

10 were you just talking about a technical call with 

11 this Joe Zlotnicki?

12 DR. NETON: Zlotnicki, yes.

13 DR. ANIGSTEIN: The English 

14 pronunciation is Zlotnicki.

15 CHAIRMAN ZIEMER: Yeah. Now, is 

16 Joe formally affiliated with SC&A?

17 DR. ANIGSTEIN: Say again?

18 CHAIRMAN ZIEMER: Is Joe formally 

19 affiliated with SC&A?

20 DR. ANIGSTEIN: Oh, yes, he's an 

21 associate. He's an SC&A associate.

22 CHAIRMAN ZIEMER: Might be of 
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1 value --- I'm not saying don't use Joe -- but 

2 might be of value to have someone who's 

3 independent, from Landauer involved as well. 

4 If you could get Craig Yoder, that would be good.

5 DR. ANIGSTEIN: Yes, well, let's 

6 see, I would suggest --

7 CHAIRMAN ZIEMER: He's been their 

8 technical guy for many years.

9 DR. ANIGSTEIN: Yes. I would 

10 suggest, if that's -- I know he's not on the phone 

11 now -- that Stu Hinnefeld, you know, is 

12 personally acquainted, I think that they were in 

13 school together, with Craig Yoder, who is 

14 currently an officer with -- and I believe that 

15 he was the contact that Joe Zlotnicki uses. I 

16 mean, he contacts him and then maybe it gets 

17 passed on to some technicians who look up the 

18 records. But it might be more appropriate for 

19 Stu to contact Craig and ask him if he would like 

20 to participate. 

21 DR. NETON: I would suggest that it 

22 may be as simple as an email posing the question
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1 directly. I mean, we only have one question.

2 DR. ANIGSTEIN: Okay.

3 DR. NETON: How were the control 

4 badges reported in this era to the client?

5 DR. ANIGSTEIN: All right.

6 DR. NETON: Were they automatically 

7 reported as M or did they actually report the 

8 dose?

9 DR. ANIGSTEIN: Should that email 

10 come from us or from NIOSH?

11 DR. NETON: Well, it depends on -- I 

12 guess if you're -- and you suggested it might be 

13 a reasonable idea that Stu contact Craig Yoder. 

14 Maybe he should make the first contact. I don't 

15 want to speak for Stu, but we can investigate 

16 that and see if Stu feels comfortable pursuing 

17 that way. If not, I don't know.

18 DR. ANIGSTEIN: No, because NIOSH 

19 actually at one point had a contract with 

20 Landauer.

21 DR. NETON: I understand. Yeah. 

22 DR. ANIGSTEIN: So this would just 
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1 be -- I know he's no longer active, but at least 

2 they would, you know --

3 DR. NETON: Yes, and this might be 

4 something that could be cleared up in just a 

5 single email exchange.

6 DR. ANIGSTEIN: Okay.

7 DR. NETON: I mean, very simple. 

8 So I think that I will pursue that with Stu and 

9 see if we can get this to be answered, you know, 

10 fairly quickly. And I'm only going to ask one 

11 question: you know, how were the control badges 

12 results reported to clients during this time

13 period? Okay. We'll take that action and I'll 

14 see if we can get that done quickly.

15 I do know that Craig Yoder is a very 

16 busy man, and in the past when we've been dealing 

17 with him it's been hard to get in touch with him 

18 because of his schedule. So that may be a 

19 limiting factor, but we can --

20 CHAIRMAN ZIEMER: Craig Yoder is at 

21 the vice presidential level, so that is why it 

22 becomes difficult.
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1 DR. NETON: Yes, I'm not 

2 complaining or anything. I'm just saying 

3 that --

4 CHAIRMAN ZIEMER: Yes, right.

5 DR. NETON: -- he's busy. But I 

6 think we'll try that. And, again, this maybe 

7 can be answered in a single email exchange over 

8 a day or so. So we'll try that, if that's 

9 acceptable.

10 CHAIRMAN ZIEMER: Thank you very 

11 much, Jim.

12 DR. NETON: What's that?

13 CHAIRMAN ZIEMER: Thank you very 

14 much.

15 DR. NETON: Okay.

16 CHAIRMAN ZIEMER: Okay. Let's go 

17 on to the additional questions. Dave, you want 

18 to -

19 DR. McKEEL: Dr. Ziemer, this is Dan 

20 McKeel.

21 CHAIRMAN ZIEMER: Yes, Dan?

22 DR. McKEEL: I would like to put in 
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1 a timely comment to that, if I may.

2 CHAIRMAN ZIEMER: Sure. Oh, of 

3 course.

4 DR. McKEEL: I endorse the idea. I 

5 think it's a very good idea to get in touch with 

6 Landauer directly, but if the overture to Mr. 

7 Yoder either doesn't work or it's taking a long 

8 time, I want to remind everybody that when I 

9 originally got the annual GSI Program 2084 film 

10 badges from Landauer, I called and spoke 

11 directly to a man named Chris Passmore, 

12 P-A-S-S-M-O-R-E, and he engaged a woman named 

13 Emily Quirke, Q-U-I-R-K-E. And we had 

14 telephone calls and exchanged letters. And for 

15 a while they were very helpful and they sent me 

16 the annual film badge records. And then Larry 

17 Elliott, who was the OCAS director at the time, 

18 wrote a letter which informed Landauer that 

19 petitioners actually had no special entree to 

20 such records. And so after that time it became 

21 more difficult.

22 But I would strongly suggest, since 
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1 Chris Passmore and Emily Quirke were the two 

2 people who actually did the research, found the 

3 badges and sent them to us -- I'm not sure if 

4 they're still at Landauer, but they might be, and 

5 they would also be two people that could be 

6 interviewed about this. 

7 I agree that this is absolutely, 

8 absolutely crucial. And, you know, I cannot 

9 underscore how important it is to get the badges 

10 straightened out. 

11 One of the other points I want to 

12 remind everybody about, while it's fresh on my 

13 mind, is that Bob Anigstein said that the 

14 drawings indicated that the film badges were 

15 kept on a rack. Singular. And Terry Dutko, who 

16 is now deceased, a betatron operator at GSI you 

17 all well know, sent us drawings; and they've been 

18 circulated and you all have them, I'm talking 

19 about everybody, the Board, NIOSH, SC&A, that 

20 actually carried through two locations for the 

21 film badges in the betatron facilities. And he 

22 clearly said that the film badges were kept at 
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1 both facilities.

2 But also there was unanimous opinion 

3 backed up by affidavits of the GSI workers that 

4 they were unaware of anything referred to or 

5 called a control badge among the film badges at 

6 GSI. And our affiants included, for example, 

7 [identifying information redacted], who was the 

8 clerk who managed the film badge distribution 

9 program at GSI for several years. But all of the 

10 workers said they simply aren't aware of that.

11 So I think it's important to not only 

12 get -- I think we need to get Landauer's full 

13 comments in writing and then make certain that 

14 that full set of comments is put on the record. 

15 And I don't think a phone call actually 

16 accomplishes that purpose. I don't think a 

17 technical call where Ted Katz writes up a summary 

18 of the call -- I don't think that accomplishes 

19 that purpose. 

20 I don't think there's anything that 

21 will substitute for a letter on Landauer 
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1 letterhead signed by a person or persons 

2 with -- I think it would be better even if you 

3 talked to Craig Yoder, that he ought to consult 

4 with Chris Passmore and Emily Quirke and make 

5 sure that the information we get from Landauer 

6 is as complete and accurate as possible on this 

7 issue, which I couldn't agree more with Jim Neton 

8 is absolutely crucial. So I appreciate you 

9 letting me make that comment.

10 CHAIRMAN ZIEMER: Well, thanks for 

11 those additional names, Dan, because 

12 particularly if Dr. Yoder isn't available, 

13 certainly can follow up with these folks and 

14 maybe all of them will get involved. 

15 But the ball's in NIOSH's court then 

16 to follow up on this. And initially this will 

17 be in writing, email. If we need to get a formal 

18 letter at the other end, we can certainly do that 

19 as well. 

20 But, okay. Let's proceed. And 

21 then, Dave, do you have some additional items now 

22 to respond to?
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1 MR. ALLEN: Yes, I think the last 

2 one on the list there is the beta dose. And I'm 

3 going to apologize to Bob right off the bat. My 

4 original draft that was sent out yesterday I 

5 believe it did have “speculate” in there, that 

6 they didn't use that 50 percent. And in my rush 

7 to edit things and get that piece of information 

8 out, I'd somehow changed the “speculate” to 

9 “concluded.” And that wasn't intentional. 

10 That was my fault. But my main reason for trying 

11 to get that out was if it were that simple, we 

12 could possibly put this to bed. And that's why 

13 I wanted to get it out. 

14 Bob has pointed out in his review 

15 that it's not that simple and that's not what 

16 happened. And unfortunately I don't see any 

17 real way around that other than us trading files, 

18 like Bob said, to try to figure out where the 

19 difference is.

20 CHAIRMAN ZIEMER: Okay. Well, the 

21 analysis that SC&A is going to provide is the one 

22 on the contamination levels, but what do you need 
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1 on the beta?

2 MR. ALLEN: Well, we just simply 

3 don't know what the difference is, why they're 

4 getting some numbers and we're getting another 

5 set of numbers. 

6 DR. ANIGSTEIN: Which way should 

7 we --

8 CHAIRMAN ZIEMER: So both of you 

9 both think that you're using the same parameters 

10 and the same calculational methods, right?

11 MR. ALLEN: Right, that's why there 

12 shouldn't be a huge difference like that.

13 DR. ANIGSTEIN: Well, okay. Which 

14 way? Should it go both ways, or, Dave, would you 

15 like to send us the files and we have our MCNP 

16 people here, myself and then a couple of my 

17 consultants, who can review them and, you know --

18 MR. ALLEN: Well, I'd love to see 

19 yours and I'm willing to send you mine.

20 DR. ANIGSTEIN: Okay. Well, you 

21 see it's not that simple. Ours is a set of 

22 interlocking spreadsheets which would require 
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1 some explanation. I mean, I'll be happy to send 

2 them, but I'm just warning it's not an 

3 immediately transparent process.

4 MR. ALLEN: Well, I agree. There's 

5 complicated calculations. I'd probably have to 

6 provide you some explanation as to mine, too. 

7 So let's --

8 DR. ANIGSTEIN: I'm open to 

9 direction, whichever way you want.

10 CHAIRMAN ZIEMER: Just trade 

11 between the both of you.

12 DR. ANIGSTEIN: All right.

13 MR. ALLEN: Yes.

14 DR. ANIGSTEIN: All right. It's 

15 going to be a little while before we do that. I 

16 mean obviously it's not going to be before the 

17 Denver meeting.

18 MR. ALLEN: Yes, between explaining 

19 them, getting them traded and somebody else 

20 analyzing, it's not going to happen by 

21 next -- what is it, Wednesday?

22 DR. ANIGSTEIN: Yes.
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1 MR. ALLEN: Right. That's clear.

2 MEMBER BEACH: This is Josie. Is 

3 that something that would maybe require a 

4 technical call, or would you just do that via 

5 email, explaining your numbers?

6 MR. ALLEN: Well, the explanation I 

7 was talking about is just explaining what's in 

8 a spreadsheet, because sometimes, especially 

9 me, I'll write these up with numbers and, you 

10 know, the headers are cryptic, you know? So for 

11 somebody else to make any sense of it, I'll have 

12 to say, okay, in this column, you know, this is 

13 what we did and stuff, so they could have a better 

14 chance of actually following through that.

15 CHAIRMAN ZIEMER: So you just need 

16 to prepare the information in a way that they can 

17 understand what you're did. Sounds like it's 

18 written information rather than a technical 

19 call.

20 MR. ALLEN: Right. I don't think 

21 that's something you want to try to explain on 

22 a call, at least the first shot around. And then 
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1 maybe some clarification if it's not clear.

2 DR. ANIGSTEIN: Yes, I agree with 

3 Dave that we exchange information. Then I would 

4 say, probably, on our end, I would say we issue 

5 a report, a brief report or a memo saying this 

6 is what we found.

7 MR. KATZ: Yes, Bob, this is Ted. 

8 Once you've both done your analyses of each 

9 other's spreadsheets, you probably need to trade 

10 some emails before you put out any final report 

11 to make sure you each understand each other's 

12 material.

13 DR. ANIGSTEIN: Sure.

14 MR. KATZ: Yes.

15 DR. ANIGSTEIN: Or we can put out 

16 sort of a draft report and send it, if we don't 

17 already do that, because it's easier. I 

18 personally find that writing a report sharpens 

19 my thinking. So if I write it down and then I 

20 can send it, we can have -- you know, before 

21 issuing it officially we can exchange it and have 

22 it commented on, if that's acceptable. It's the 
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1 same thing basically. You know, an email with 

2 an attached note to it.

3 MR. ALLEN: Well, I think some 

4 emails may probably be warranted just to make 

5 sure we understand each other's --

6 DR. ANIGSTEIN: Yes, right, right, 

7 right. But it won't necessarily -- it might be 

8 an email attachment.

9 MR. ALLEN: Yes, I mean just a 

10 clarification type of --

11 DR. ANIGSTEIN: Exactly.

12 MR. ALLEN: What did you do here 

13 versus --

14 DR. ANIGSTEIN: Yes.

15 MR. ALLEN: -- an evaluation? Not 

16 an evaluation in the emails, but some sort of a 

17 clarifications-type --

18 DR. ANIGSTEIN: Well, in email, I 

19 mean the first be a transmission of the file with 

20 a note explaining what we did.

21 MR. ALLEN: Right.

22 DR. ANIGSTEIN: And then once we get 
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1 your material, we'll send you another email with 

2 comments and questions. 

3 MR. ALLEN: Right.

4 DR. ANIGSTEIN: So there will be an 

5 opportunity to respond, to clarify, respond, 

6 acknowledge. And then in the end perhaps each 

7 can issue a report saying we're right, you're 

8 wrong, or you're right, we're wrong.

9 (Laughter.)

10 CHAIRMAN ZIEMER: Okay. Well, 

11 that's certainly a way to get a handle on why 

12 you're seeing these differences. You know, if 

13 it's just a simple calculational thing versus 

14 some major underlying assumption that is very 

15 different, we need to identify that.

16 Are those the only items now where 

17 we have to address on the original paper here 

18 then? Is that the last one, Dave?

19 MR. ALLEN: I think it was, yes.

20 CHAIRMAN ZIEMER: Jim Neton, did 

21 you have another item that was on there that you 

22 had a question on?
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1 DR. NETON: Well, you know, there's 

2 still a couple outstanding items on the badge 

3 rack issue, you know, unrelated to the detection 

4 limit of film badges, and that is the model that 

5 Dave Allen used to generate the photons at the 

6 badge rack. 

7 And Bob Anigstein's comment on the 

8 shielding between the betatron room and the 

9 control room -- I mean and the badge rack. I 

10 don't know whether, you know, those are worth 

11 discussing today before we decide this. You 

12 know, if the film badge issue is as SC&A portrays 

13 it, then I guess the other arguments are not 

14 worth discussing, because unless Dave Allen can 

15 correct me, I think that that's the key issue. 

16 So maybe we have to decide if this is 

17 still -- solve this issue first. But those are 

18 the only two issues I can think of.

19 CHAIRMAN ZIEMER: Yes, and it's not 

20 clear to me whether that issue needs to be 

21 resolved before we get the -- I think we still 

22 need the Landauer information. 
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1 DR. NETON: Yes, I agree. If the 

2 Landauer backs up, is exactly the way Bob 

3 Anigstein has interpreted it, then I think the 

4 other issues may be small potatoes compared to 

5 this.

6 CHAIRMAN ZIEMER: Yes. So I guess 

7 my question is do you want to do anything further 

8 on this now, or hold this off until you get the 

9 other information?

10 DR. NETON: Well, after thinking 

11 about it some, it's probably best to solve this 

12 issue first, I think.

13 CHAIRMAN ZIEMER: The badge rack 

14 issue?

15 DR. NETON: Yes, because we could 

16 debate a lot about the other two issues and this 

17 one would trump the other two, I think.

18 CHAIRMAN ZIEMER: Okay. Well, 

19 let's go to it, then. Let's see.

20 DR. ANIGSTEIN: I'm sorry, I'm 

21 losing track. The badge rack issue. Which 

22 other two issues would be put aside?
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1 DR. NETON: Well, I think the key 

2 issue to answer right now is the reporting 

3 practice of Landauer --

4 DR. ANIGSTEIN: Yes.

5 DR. NETON: -- for the badge rack 

6 control.

7 DR. ANIGSTEIN: But the beta dose is 

8 completely separate, independent of that.

9 DR. NETON: The beta dose?

10 DR. ANIGSTEIN: Do you want to 

11 proceed with that, or you want to not proceed 

12 with it?

13 DR. NETON: You're talking about 

14 the beta dose with the MCNP files?

15 DR. ANIGSTEIN: Yes, I mean that's 

16 completely separate from this.

17 DR. NETON: Oh, yes. No, that 

18 needs to be pursued. I have three issues down. 

19 And, you know, the --

20 DR. ANIGSTEIN: Right. Okay.

21 DR. NETON: -- ten to the minus 

22 sixth versus ten to the minus fifth you're going 
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1 to send us data.

2 DR. ANIGSTEIN: Right. Right. 

3 Right.

4 DR. NETON: We're going to try to 

5 poll Landauer on the practices of reporting --

6 DR. ANIGSTEIN: Right, yes.

7 DR. NETON: -- during that era. 

8 And then the trade files for the MCNP.

9 DR. ANIGSTEIN: Right. So these 

10 are all independent?

11 DR. NETON: Yes, they're all 

12 independent. What I was talking about was the 

13 other two issues related to using the badge 

14 rack --

15 DR. ANIGSTEIN: Oh, I see. I got 

16 you.

17 DR. NETON: You know, that made the 

18 exposure --

19 DR. ANIGSTEIN: Yes, I understand. 

20 Yes. Yes, there will be -- once you don't use 

21 the badges, then the rest is moot.

22 DR. NETON: Exactly.
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1 CHAIRMAN ZIEMER: So the question 

2 is what do we need to do on the badge rack issue 

3 now.

4 DR. NETON: Well, I think the issue 

5 is to contact Landauer and get hopefully a clear 

6 answer as to how they behaved.

7 CHAIRMAN ZIEMER: Right. And once 

8 you have that, then we can determine whether this 

9 other needs to be pursued then.

10 DR. NETON: Yes, and the other ones 

11 still may be okay. You know, it just depends on 

12 how accurate they are and what adjustments may 

13 or may not need to be made to make them more 

14 accurate, yes.

15 CHAIRMAN ZIEMER: Okay. Let me ask 

16 again, Work Group Members, any questions on 

17 proceeding in this way?

18 MEMBER MUNN: No, that sounds 

19 perfectly logical to me. 

20 MEMBER BEACH: I don't have any 

21 either, Paul.

22 CHAIRMAN ZIEMER: Okay. John?
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1 (No response.)

2 CHAIRMAN ZIEMER: I was talking to 

3 John Poston.

4 MEMBER POSTON: Can you hear me?

5 CHAIRMAN ZIEMER: Yes, there you 

6 go.

7 MEMBER POSTON: Yes, I'm okay with 

8 it.

9 CHAIRMAN ZIEMER: Okay. Now I want 

10 to give Dr. McKeel a chance to comment also on 

11 the Dave Allen paper and the related issues that 

12 we've talked about here. 

13 And, Dan, we have your document, a 

14 critique of Dave Allen's August GSI White Paper. 

15 And I think there's some follow-up. I think you 

16 had another one a day or two later. Well, that 

17 was information on an abstract. And your papers 

18 are also on the website. But why don't you go 

19 ahead.

20 DR. McKEEL: Okay. Are you hearing 

21 me now?

22 CHAIRMAN ZIEMER: Yes, go ahead, 
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1 Dan.

2 DR. McKEEL: Okay. Good. Well, I 

3 have some comments about what's been discussed 

4 in the meeting and then I had a few things that 

5 I knew needed to be addressed. So if you don't 

6 mind, I'm going to kind of take it in reverse 

7 order and wind up with the comments about the 

8 immediate discussion today as the last item so 

9 I can get through these.

10 I want to stress that I sent this 

11 Work Group four papers. Two of them were from 

12 August of 2013 and one of them was the rebuttal 

13 paper that I had to Dave Allen's White Paper on 

14 the GSI estimated doses. So I'll address that 

15 in a minute. The other papers were two reports 

16 from the Health and Safety Lab of the AEC New York 

17 Operations Office, and that's NYO Report- 4699. 

18 And there is a 1957 original paper and there is 

19 a Supplement 1 from the next year. 

20 And what's interesting about those 

21 papers is the AEC conducted in the '50s -- it may 

22 have gone on later, I'm not sure, but in the '50s 
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1 they had these two reports about what they call 

2 the Accelerator Surveillance Program. And 

3 these two reports report their information on 

4 going to at least 38 sites that had accelerators 

5 of various kinds: cyclotrons, most importantly 

6 betatrons, larger accelerators. 

7 But the highly interesting part of 

8 these papers is they went to extensive lengths 

9 to carry their measuring instruments to the 

10 site. And so they measured the photons and they 

11 measured neutrons, and they spent a lot of time 

12 discussing the neutron results. And of most 

13 interest and highly pertinent to General Steel 

14 Industries, in fact so important I would rate 

15 this as maybe the most important paper about 

16 betatrons that we have yet seen about GSI. 

17 But in the Supplement 1 paper, which 

18 I review pretty extensively in my White Paper, 

19 they include data on three 22, 25 MeV betatron 

20 sites. One is at Memorial Sloan- Kettering 

21 Hospital and I assume it's the same machine 

22 that -- the Health Physics Society president was 
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1 the head of that department -- and was later 

2 donated to the Smithsonian Institution. And 

3 then they have additional data on two betatrons, 

4 both of them at the University of Illinois. One 

5 of them I gather was used for research purposes 

6 and the other was definitely used in the medical 

7 school. 

8 And for all of the accelerators the 

9 reports had highly interesting data. Number 

10 one, they included pictures, two-dimensional 

11 drawings, some photos of the machines being 

12 used, but also of the facilities themselves. 

13 And these were like the ones we have for GSI. 

14 They were not blueprints, but they were 

15 sketches, and very informative sketches. 

16 They also had and collected film 

17 badge data, real measured film badge data from 

18 the workers who operated those accelerators. 

19 And then they had extensive photon measurements 

20 from the operating accelerators and that 

21 included not just the machines themselves, but 

22 also the facilities and most interestingly in 
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1 the case of the University of Illinois Medical 

2 School betatron, of the surrounding buildings. 

3 And so this is the only place that I'm aware of 

4 where they have -- where an AEC/HASL/NYO team 

5 went out and made extensive actual measurements 

6 of betatron photons and neutrons and included 

7 with that film badge data from the workers that 

8 were involved.

9 And I assume from what Paul told me 

10 that all of you all had those papers and have read 

11 those papers. I've got to tell you I'm 

12 surprised since I sent those out in August 

13 that -- you know, and all of September went by, 

14 some of August and up until today. I've gotten 

15 no feedback from either NIOSH or the Board about 

16 those important papers. And so I'm assuming 

17 that you all have all read them. I certainly 

18 don't have time to go into them right now.

19 The latest two papers I sent to you 

20 all are just informational really, but they also 

21 have something that's new and needed, I believe. 

22 Those two papers are -- on May the 17th, HHS 
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1 approved an administrative review for GSI, and 

2 the three panel HHS members have been working on 

3 that since May 17th. I have not heard from them. 

4 I didn't expect to. So it's been five months. 

5 They have not made their decision apparently, 

6 nor have I heard from HHS what their 

7 recommendation was and what Secretary Sebelius' 

8 final decision was on that matter.

9 And then on the 7th of October, I 

10 sent you an addendum paper to the administrative 

11 review that did several things. One is the 

12 first paper, the administrative review had 44 

13 errors I cited for the three-member panel. And 

14 they were errors of omission, commission, policy 

15 matters, as well as technical and scientific 

16 matters. And to those I've added 20 new errors 

17 I think that have been made since the Board voted 

18 9 to 8 to deny SEC on December the 11th, 2012.

19 Ted has distributed that document to 

20 the entire Board and I sent each of the Members 

21 of the Work Group, the Board Members a copy as 

22 well. I sent copies to NIOSH as well. And I 
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1 assume that Ted also distributed copies perhaps 

2 to SC&A.

3 The other thing I did in that last 

4 paper was -- I have been highly interested of 

5 course ever since the Board voted to see when the 

6 Appendix BB and transferred SEC issues that were 

7 made part of the Appendix BB matrix would be 

8 addressed. And so far I think it's fair to say 

9 they have not been addressed since 12/11/12. So 

10 I made a list in there of the 19 still open 

11 issues; that is, issues that were either 

12 transferred, or were marked as in progress, or 

13 were marked as open, but that were not definitely 

14 closed by all Members of the Work Group. 

15 And, you know, it's my 

16 understanding, I think everybody agrees, that 

17 all of these issues have to be systematically 

18 worked through before NIOSH can be even in a 

19 position to revise Appendix BB Rev 0, which was, 

20 you know, put in in June of 2007.

21 I also have to note that in those two 

22 matrices that I reviewed, again the Appendix BB 
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1 one is from 11/26/12, the SEC matrix issue is 

2 from 12/5/12, they have detailed timelines which 

3 elegantly lay out what's been done about the GSI 

4 TBD-6000 and Appendix BB. 

5 What I was interested in is really 

6 from a scientific and personal view and the way 

7 business is conducted is there's no mention at 

8 all of the fact that between 2007, July 2007 and 

9 today I've submitted 52 White Papers that I 

10 authored and have posted to docket 140 for GSI 

11 and shared with the Work Group and the Board 

12 about GSI. And I personally think that 

13 petitioner input should be weighted higher than 

14 that and it certainly should have merited an 

15 entry into the timelines of the decision 

16 matrices on the important issues.

17 My third point is that I thought that 

18 the NYO-4699 papers were so important because 

19 they were the first and only measured photon, 

20 neutron and operator film badge data that we had 

21 on comparable betatrons to the GSI ones. So I 

22 ask that he task SC&A to review those papers. 
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1 Paul said that everyone had read my papers. And 

2 so he didn't think that SC&A needed to review 

3 them. But I notice today, for instance, in the 

4 discussions that have taken place so far, none 

5 of those papers have really been mentioned at 

6 all.

7 I think it's extremely important 

8 that this Work Group look particularly at the 

9 neutron doses. The authors of the NYO-4699 

10 stress how significant that was, and they cite 

11 for instance, at the University of Illinois 

12 Nursing School, that there were still overdoses 

13 of the neutron from betatron vaults that were 

14 shielded similarly to the ones used at GSI. But 

15 there was spillover of neutron doses into the 

16 nursing facilities, into the hallways of the 

17 living areas of the adjacent dormitories.

18 And unlike the modeled doses, it is 

19 extremely interesting that these papers detail 

20 the neutron-measuring devices that they used, 

21 and in some accelerators they used up to three 

22 different devices to triangulate and make sure 
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1 that the doses they measured were as accurate as 

2 possible. It's also a good primer on how 

3 difficult it is to measure neutrons from 

4 different kinds of accelerators using, quote, 

5 standard methods. In fact, they found you 

6 really couldn't do it. You had to have several 

7 sources, all of which when combined gave you a 

8 much clearer picture.

9 So anyway, I encourage everybody to 

10 look at that and discuss it and make it part of 

11 the agenda for any next meeting there is of this 

12 committee.

13 Then I want to turn very briefly to 

14 Dave Allen's GSI dose estimate paper. You know, 

15 I found in my rebuttal that there were just 

16 numerous things I disagreed with, and the first 

17 one relates to what I've just been talking about, 

18 and that is that he speaks of -- and also the 

19 first comment today by Dr. Anigstein -- they both 

20 agree that the radium era doses to workers should 

21 be bounded by the two radium sources. 

22 But what's omitted from that fact, 
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1 at least Bob Anigstein and SC&A acknowledge that 

2 there was a 22, 24 MeV betatron operating at GSI 

3 from October the 5th, '52 through 1962, so during 

4 the entire radium era. What they both ignore is 

5 the fact that the radium sources didn't give off 

6 any neutrons. And so they ignored the betatron 

7 neutron doses during the radium era. They need 

8 to be modeled, but the model needs to be 

9 validated using the NYO-4699 measured neutron 

10 data to compare with.

11 We all know that this is not true, 

12 but if you read Dave Allen's paper, you would 

13 think that the only source at GSI, the only 

14 source term was the two radium sources. So not 

15 only was the old betatron ignored, but so were 

16 the two 250 kV X-ray machines and so were the 

17 iridium-192 sources. And I've sent you data 

18 from Paul Sinn recently that he estimated that 

19 there were 25 to 50 uses of the St. Louis Testing 

20 Lab's iridium-192 sources at GSI. He's not very 

21 clear about the dates for that, and it may be that 

22 it started after the radium era, but those 
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1 up-to-50 iridium source exposures are not 

2 mentioned in Dave Allen's paper at all.

3 I wanted to comment that we're 

4 spending a lot of time retaining this term layout 

5 man at GSI. We have established I think now 

6 conclusively that although this was an 

7 operational term, that actually no person, no 

8 employee of GSI ever held this job as an 

9 exclusive job category. So whatever you assign 

10 to the layout person, they also accumulated dose 

11 due to other types of exposure.

12 I noticed that in this paper, 

13 although -- and I've noticed very carefully 

14 since we've supplied data and NIOSH supplied 

15 data from October 1952; our data was from 

16 November and December of '52, that this Work 

17 Group has not even mentioned the papers that went 

18 into arriving at that conclusion showing that 

19 the 24 MeV old betatron was used in conjunction 

20 with the AEC and Mallinckrodt in an experimental 

21 program they had to develop better imaging of 

22 uranium using uranium billets, actually 
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1 sections of uranium billets, and using a uranium 

2 shield that Mallinckrodt had designed and 

3 brought over to GSI in order to improve the 

4 quality of the radiograph team. 

5 Nobody's ever calculated those 

6 doses. Nobody's ever modeled those doses. And 

7 of course there are no actual purchase orders for 

8 those dates either. There are statements from 

9 the AEC operations report that that work 

10 existed. 

11 Anyway, there are lots and lots of 

12 other objections I had to that paper and I'm 

13 going to have to trust that you all have read 

14 that.

15 The fifth thing, next to last thing I 

16 want to talk about is an awful lot of the dose 

17 assignments from the years 1958 to 1962, before 

18 the Landauer Film Badge Number 2084 Program 

19 began, is based on film badge reports from one 

20 part-time radiographer, [Identifying 

21 information redacted], and SC&A has detailed 
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1 that data quite elaborately. 

2 [Identifying information redacted]

3 also supplied John Ramspott and I with the same 

4 set of his data. And so it includes not just 

5 that one page that has the 18 quarters of data 

6 and so forth, it also has reports for later years 

7 that show a dose received by him of zero. And 

8 [Identifying information redacted] worked at 

9 GSI until 1973, when it closed. And the 

10 complete Landauer data set that SC&A and NIOSH 

11 are privy to includes all the weekly data through 

12 1973 as well. 

13 Well anyway, my original annual 

14 report from Landauer also has annual reports up 

15 through 1973. And it is possible even though a 

16 lot of information is redacted from those 

17 early -- not a lot actually, but some, the names 

18 are redacted, you can follow through -- well, 

19 even not all the names are redacted from that 

20 set. So but you can follow through this one 

21 particular individual's data in the data set 
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1 that I got from Landauer, and there are non- zero 

2 numbers in those later years. So there's a 

3 discrepancy.

4 The result of all this was we have 

5 urged [Identifying information redacted], even 

6 though he has not filed a claim, to obtain his 

7 Landauer film badge data. And we helped him do 

8 that. He initially contacted NIOSH about 

9 getting his report in June. They wrote back to 

10 him and said that he could do that, but he would 

11 have to send them some forms attesting to who he 

12 really was and in compliance really with the 

13 Privacy Act laws. [Identifying information 

14 redacted] did that and those papers were mailed 

15 back to NIOSH in mid-July of this year to a woman 

16 named Mrs. Aquino, A-Q-U-I-N-O, who had sent the 

17 original letter to [Identifying information 

18 redacted].

19 [Identifying information redacted] 

20 tells John Ramspott and I as of yesterday, he has 

21 heard nothing back from this request for his 
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1 Landauer film badge records. So it's been from 

2 mid-July through August, through September and 

3 now October. So it's been almost three months 

4 and he's not received his Landauer film badge 

5 data. And it seems to me that that needs to be 

6 addressed immediately by NIOSH and to get him 

7 those film badge data.

8 Final thing I want to say is just a 

9 couple of comments that relate to things that 

10 were said today during the meeting. I've 

11 already pointed out that both Dr. Anigstein and 

12 Dave Allen feel that radium is bounding for 

13 1952- 1962 exposure, external exposures. And 

14 that totally neglects the fact that radium gave 

15 off no neutrons, but the betatrons were giving 

16 off neutrons that entire period. So the radium 

17 gamma protons certainly don't bound the 

18 contribution to dose from betatron neutrons.

19 Second point is we spent a lot of 

20 time -- Dr. Anigstein spent a lot of time going 

21 over material that has already been discussed in 
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1 great detail, including the information about 

2 the 15 NIOSH scenarios and the angles used and 

3 SC&A objections to all that, but during that 

4 discussion he also mentioned the presence of a 

5 storage rack. And I want to reiterate and 

6 underscore that there were two racks. 

7 So when you model the exposure to the 

8 control badges, you don't know which of those 

9 racks those badges were. You have to model them 

10 both. They were in two different locations on 

11 two different walls 90 degrees apart. And as 

12 was said, the betatron control room was just one 

13 of many rooms in that structure. And the film 

14 badges were in another room on different -- in 

15 two other rooms actually on two different walls 

16 of the building. And you have those drawings so 

17 you should be able to model them. 

18 I want to reiterate that I do not 

19 think that accepting telephone information from 

20 Mr. Zlotnicki, who was employed by Landauer, but 

21 he's not employed by Landauer now -- I don't 

22 think that's sufficient. I think and agree that 
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1 we need to speak to Landauer and get an answer 

2 to them in writing.

3 And as you know, we have put on the 

4 record numerous objections why the film badge 

5 data for those 89 betatron operators of a 

6 workforce of 3,000 people is not representative. 

7 So we don't think you should use that film badge 

8 data for anyone but betatron operators, and that 

9 means you don't have any way to calculate. 

10 There is no film badge data. There is no 

11 bioassay data, no monitoring data of any kind for 

12 the rest of the people at that plant.

13 My same comments I would say about 

14 the models that were developed for the layout 

15 man. You know, again, this was just a rehash of 

16 things that were discussed extensively and here 

17 we are months later and they're still listed as 

18 an open issue. And it was clear from the 

19 discussion today that NIOSH and SC&A don't agree 

20 about that. 

21 There was a comment today about a 

22 math error in TBD-6000 that was going to be 
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1 fixed, but when you actually read that matrix 

2 issue, NIOSH says they will fix it when Rev 1 of 

3 TBD- 6000 is revised. And at least based on 

4 NIOSH's experience with Appendix BB Rev 0, they 

5 may not revise TBD-6000 for a long time.

6 Next comment I wanted to make is 

7 there's been a lot of discussion about the 

8 resuspension factor. I wrote a paper about why 

9 I thought TIB-70 was not a good model for what 

10 happened at GSI. And the primary reason 

11 was -- and I didn't think even the ten to the 

12 minus fifth number was necessarily the best one 

13 to be chosen. 

14 And what I pointed out in that paper, 

15 and John Ramspott provided volumes of 

16 information about this, is we know that not only 

17 the betatron facilities where the uranium was 

18 shot, but that in all of the buildings that the 

19 uranium passed through when it came in on 

20 railroad trucks -- and that would include 

21 Buildings at least 5, 6, 7, 9 and 10 -- what we 

22 referred to in all our papers as the uranium 
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1 transport path -- that there was uranium all 

2 along that transport path in the railroad 

3 tracks, around the railroad tracks. And we know 

4 that, in the 27 years of the residual period, 

5 there were multiple businesses, steel 

6 businesses that came in and had operations in 

7 those other buildings. So we believe that the 

8 resuspension and settling of uranium at GSI 

9 during the residual period was a cyclical 

10 phenomenon.

11 The other comment is that everybody 

12 seems to have forgotten that in the original 

13 discussion of the resuspension factor, John 

14 Mauro actually argued that there were instances 

15 in the literature; and this was also argued when 

16 the Procedures Review Committee took up TIB-70 

17 recently, this year -- that there were 

18 statements in the literature that a resuspension 

19 factor could be as high as ten to the minus two 

20 per meter or ten to the minus three, ten to the 

21 minus four. So even higher than the ten to the 

22 minus five. 
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1 My conclusion: ten to the minus five 

2 is totally arbitrary. You have no idea what it 

3 was. And, you know, the buildings that the 

4 uranium was suspended in at GSI included small 

5 rooms and it included very large rooms, 

6 Buildings 8, 9, 10, 5, 6, 7 were all 

7 interconnected. They were basically one big 

8 roof with some steel walls in between them which 

9 weren't complete. 

10 And finally, I wanted to put in my 

11 two cents' worth about what was actually said at 

12 the June 2013 meeting about uranium hours. If 

13 everybody remembers, as soon as that meeting was 

14 over, I was so struck by the lack of clarity on 

15 the uranium hours issue that I actually 

16 submitted my annotated notes on that meeting. 

17 And one of the things that I highlighted was that 

18 there certainly was a discussion about the 400 

19 hours, and there was a discussion which I took 

20 to be that the highest numbers of hours, the 437

21 hours in '61, was going to be used throughout 

22 that period. 
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1 And it is my recollection that that 

2 was basically what Dr. Neton was saying, but 

3 after rereading that transcript over and over, 

4 I had to say to myself -- and I put in my report 

5 it wasn't clear what was agreed upon. So, you 

6 know, that's a general comment for all of these 

7 issues. 

8 I think at the end of a Work Group 

9 meeting there should be a definite statement 

10 just like you do for why the Board recommends 

11 denial or approval of an SEC that explicitly 

12 gives action items that are to be followed up on. 

13 And it really would be good, when we're having 

14 meetings that are all about do SC&A and NIOSH 

15 agree, to put the areas of agreement and 

16 disagreement in that list of action items at the 

17 end of the meeting. 

18 Anyway, once again I sincerely 

19 appreciate you giving me some time to address the 

20 group and I look forward to the rest of the 

21 discussion.

22 CHAIRMAN ZIEMER: Okay. Dan, 
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1 thank you for those comments. I want to follow 

2 up a little bit on the document dealing with the 

3 survey of the accelerators. First of all, I'll 

4 tell you that I did read the document and went 

5 through -- it's a totally extensive document. 

6 But some things occurred to me as I read it, and 

7 I want to maybe ask Jim and Dave this question, 

8 and also SC&A folks can respond to it also. 

9 But it occurred to me as I looked at 

10 those surveys done by the AEC, and they were done 

11 decades ago, where they have information about 

12 the shielding of these accelerators and the 

13 radiation levels at different locations, but 

14 would it be feasible and/or even useful to take 

15 the MCNP model and see how it predicts the actual 

16 readings based on the output of those machines 

17 and the shielding that is provided. Now I'm not 

18 saying to do it for all of those, but perhaps a 

19 couple individual ones that would be similar to 

20 the GSI one. 

21 The reason I'm thinking about 

22 that -- and I think in part Dr. McKeel has 
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1 suggested this would be a kind of independent 

2 validation of the usefulness of the code for this 

3 type of application. But maybe, Jim or Dave, 

4 you could respond. Is that something that is 

5 feasible or useful? And maybe, John Mauro or 

6 Bob, you could also respond.

7 MR. ALLEN: Well this is Dave Allen. 

8 I can start responding. And when I first got a 

9 hold of that document, that was what my intent 

10 was. And it is lacking more information than 

11 what we had for GSI, I mean as far as dimensions. 

12 And I thought I could maybe guess at some 

13 dimensions, et cetera. 

14 Then you start looking at thickness 

15 of the shielding material and what that material 

16 is. And you know for the ones that aren't next 

17 to some sort of window that I'm going to guess 

18 is a lead window or something. For the ones with 

19 just a thick wall I could almost guess concrete 

20 there. But then on most of them I don't even 

21 really have a beam orientation. I mean I could 

22 toss a number of orientations in there to try to 
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1 reorient the numbers or whatever, but in the end 

2 it's going to end up being, you know, a number 

3 of guesses on here. And I didn't know how much 

4 worth that would be for anybody. 

5 CHAIRMAN ZIEMER: Well, I wasn't 

6 sure whether the information was adequate to be 

7 used for that purpose. It just had occurred to 

8 me. And of course the actual survey was done 

9 really to -- for a couple reasons. One was to 

10 determine adequacy of shielding throughout 

11 these different facilities. And of course one 

12 of the things they found in general, it seemed 

13 that the shielding was not adequate. This was 

14 largely the case almost everywhere they went. I 

15 know Dr. McKeel mentioned the nursing facility. 

16 That was a good example where they really didn't 

17 have adequate shielding.

18 The other part of course was the 

19 neutron issue. And my understanding of when you 

20 say the radium sources are bounding, you have 

21 already taken into consideration both the gamma 

22 and the neutron component of the betatrons. Is 
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1 that not correct?

2 DR. ANIGSTEIN: This is Bob. The 

3 2008 report specifically modeled the 24 MeV 

4 betatron in the old betatron building and 

5 neutron doses to the operator are listed. And 

6 that has not changed. I mean we have had no 

7 reason to change that.

8 DR. McKEEL: Dr. Ziemer? Dr. 

9 Ziemer?

10 CHAIRMAN ZIEMER: Yes, go ahead.

11 DR. McKEEL: This is Dan McKeel 

12 again. Well, yes, they have modeled the neutron 

13 doses in 2008. That's interesting to me that 

14 the 2008 data is mentioned, because I've said for 

15 a long time that all these reports on summary 

16 doses by SC&A and NIOSH should also include that 

17 early data. It's almost like that data never 

18 actually was generated. It was generated. But 

19 again, this is modeled by MCNPX. 

20 I have sent this Work Group three 

21 papers just as illustrations to support a point 

22 that I've been making all along; and that is that 
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1 when you formulate an MCNPX dosimetry model and 

2 you want to get that accepted in a respected 

3 scientific peer-reviewed journal, that number 

4 one, you aren't going to get that accepted unless 

5 you have validating measured data. 

6 Now, I understand that the measured 

7 data is in some senses limited for the betatron 

8 installations that I mentioned in NYO-4699. 

9 However, it is the same kind of betatron that was 

10 used at GSI. They do give accompanying film 

11 badge data. They do give diagrams of the 

12 facilities. They do give wall thicknesses. 

13 And in fact in many of those instances they do 

14 mention what the wall thicknesses were. So it's 

15 my opinion that instead of people making 

16 off-the-cuff ad hoc comments on what those 

17 papers showed, that's the very reason that I 

18 think it's still highly important to have SC&A 

19 take NYO-4699 and to review that paper. 

20 And I really think it's important 

21 for Dave Allen and NIOSH DCAS to take those 

22 papers and to explain, particularly for those 
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1 three sites -- Memorial Sloan-Kettering 

2 Hospital in New York City, the University of 

3 Illinois Medical School and the University of 

4 Illinois Research betatron -- and say exactly 

5 why you can or cannot use that as surrogate data 

6 to validate the MCNPX models at GSI. I think you 

7 can.

8 What you're relying on -- now let's 

9 remember, there is no data at all, real data 

10 except from that one radiographer for 1952 to 

11 1962 -- '59. So you know, what everybody's 

12 relying on is AEC radiation limits. That's like 

13 saying that if you said how fast do drivers in 

14 the United States drive on the super highways? 

15 And you say, well, we've taken an average and, 

16 you know, the average speed limit is 65, but in 

17 some places it's 70, in other places it's 55. So 

18 we're going to say that 67 miles an hour, that's 

19 the average speed limit in the United States, and 

20 we're going to multiply that times the number of 

21 drivers per year, and that's the miles driven in 

22 the United States. That's the speed, the miles 
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1 per hour on average driven in the United States 

2 in one year. 

3 Well, nobody would accept that, 

4 obviously. And yet you're trying to do the same 

5 thing. You're taking the statement of an 

6 individual at GSI who had many reasons to be 

7 favorable in his comments and accepted that as 

8 the gospel truth and set the limits for 10 years 

9 of this site. So I guess that's what I want to 

10 say about it.

11 CHAIRMAN ZIEMER: Okay. Thank 

12 you. 

13 DR. McKEEL: And, Paul, I guess I've 

14 got to ask you again. I would like you to put 

15 on the record why it is, given my last comment, 

16 why you still do not think it's necessary to have 

17 SC&A review this very important paper? I will 

18 say one thing, too: you made an error when you 

19 said that that paper shows that the shielding was 

20 inadequate at most sites. As a matter of fact, 

21 if you read that paper carefully, it says overall 

22 that the accelerator radiation safety programs 
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1 in place are pretty good. And the main place 

2 that it has problems are some very specific sites 

3 in those things. 

4 For instance, in one of the 

5 betatrons, they had a hot spot right next to the 

6 control room door. Well, in many of the other 

7 areas though they were below-the-limit reading. 

8 So actually that's not true to say that they 

9 found universal poor shielding. It wasn't true 

10 at all. 

11 And when you characterize the study 

12 as decades ago, actually decades ago, it's '56, 

13 '57, right there in the period we're talking 

14 about, right there in the middle of the radium 

15 era at GSI. So that makes it even more relevant 

16 and it fulfills the Board criteria for surrogate 

17 data for being contemporary with the exposures 

18 at GSI.

19 So again, I am asking and I would 

20 appreciate an explanation of why you don't think 

21 SC&A should review this paper and why NIOSH 

22 shouldn't respond to it in a formal way in 
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1 writing. 

2 CHAIRMAN ZIEMER: Well, I can't 

3 answer for NIOSH. I think I told you why I 

4 didn't think I should task SC&A to review the 

5 paper, but that if the Work Group wished them to 

6 do that, then we could certainly consider that. 

7 And in fact I've raised this issue about whether 

8 or not we can use that information, which if we 

9 could for the purposes of validating the use of 

10 the model, then that would certainly involve 

11 both NIOSH and SC&A doing this.

12 DR. McKEEL: Well, you've given 

13 your opinion that it doesn't need to be modeled, 

14 but you really haven't asked the other Members 

15 of the Work Group whether they think SC&A should 

16 be tasked to review these papers that I feel are 

17 of absolute paramount importance. So I'm not 

18 tromping you on your prerogative, but I still 

19 wish you would do that and let them put 

20 themselves on the record. If they say no, fine, 

21 they say no. But I don't think it's on the 

22 record. 
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1 CHAIRMAN ZIEMER: Okay. Certainly 

2 the other Members of the Work Group can comment 

3 on this. I certainly don't object to tasking if 

4 the Work Group wishes to do this. What I told 

5 Dr. McKeel originally was that I felt that all 

6 of the participants have copies of that 

7 information to evaluate as they proceed through 

8 with the other documents. It hasn't been our 

9 practice in general -- I'm not sure about the 

10 other Work Groups -- to do tasking outside of the 

11 tasking of the NIOSH work products, but we 

12 certainly have the other information. But, 

13 Work Group Members, you're certainly welcome to 

14 chime in on this.

15 MEMBER BEACH: Paul, this is Josie. 

16 CHAIRMAN ZIEMER: Go ahead.

17 MEMBER BEACH: From what I 

18 understand here, NIOSH looked at it. Dave Allen 

19 said that there were some problems with him being 

20 able to look at that analysis because of missing 

21 points. And I haven't heard from SC&A. Is 

22 there any merit to taking the time to look at 
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1 this?

2 DR. MAURO: This is John. I don't 

3 hear anything from Bob. Bob, are you on line?

4 DR. ANIGSTEIN: Sorry, I was on 

5 mute.

6 DR. MAURO: Oh, okay.

7 DR. ANIGSTEIN: Yes, I have not had 

8 the time, I have not had a chance to review the 

9 papers that Dr. McKeel submitted. Right now 

10 from what I've heard from Dave Allen, if he says 

11 he doesn't feel that there are enough -- he's 

12 certainly familiar with what is required for an 

13 MCNP analysis, and if he thinks that there is not 

14 enough information and there's not enough 

15 specific data, I would be inclined to accept his 

16 opinion until I've had a chance to -- you know, 

17 until I find out otherwise.

18 Mostly having set up many, many, 

19 many MCNP analyses, both for the NIOSH project 

20 and other work, the limiting factor is always 

21 lack of information, lack of data on specific 

22 materials, densities, composition. And so the 
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1 MCNP becomes a model, I think a very accurate 

2 model. The MCNP Code has been amply -- it's been 

3 in use for something like on the order of close 

4 to 50 years. It's been amply validated in many, 

5 many, many field studies. I mean this is the Los 

6 Alamos National Laboratories, one of the 

7 foremost research institutions in the world when 

8 it comes to nuclear science. The MCNP Code has 

9 been used to design nuclear weapons, for better 

10 or for worse. 

11 And, but the model -- I'm trying to 

12 get to -- I'm being a little roundabout -- is MCNP 

13 accurately models the information that is 

14 presented to it. If the information is 

15 inadequate, is not precise, is not what is really 

16 in the real world, then the model -- in other 

17 words, it's only as good as the input data. You 

18 know, there's a saying in computer talk: garbage 

19 in, garbage out. So if the data is not adequate, 

20 then all we can do, as Dave said, is take a guess 

21 and then it's a matter of luck, maybe. Maybe the 

22 MCNP results will confirm the measurements. 
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1 Maybe they won't. It will not say anything one 

2 way or another about the ability of MCNP. It 

3 only is a reflection on the input data.

4 So my off-hand opinion is that it's 

5 not likely that this will produce information 

6 that will be useful for GSI, especially since the 

7 limiting scenario, as we just discussed, in the 

8 SC&A analysis for exposure to betatron photon 

9 radiation is the layout man who's in an 

10 essentially unshielded location. And so it's a 

11 very, very simple model. He actually has line 

12 of sight, except for a thin sheet metal door, 

13 which is essentially transparent to high-energy 

14 photons, so you can say line of sight of the 

15 betatron target. So it's a very simple 

16 analysis. 

17 We have a detailed drawing thanks to 

18 information that was obtained by NIOSH under 

19 contract from a former Allis-Chalmers engineer. 

20 We have a very detailed drawing of the platinum 

21 target. We have a fairly good idea of what the 

22 intensity of the beam was based on the 
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1 measurements on the X-ray beam, so we can 

2 back-calculate the electron beam. And 

3 therefore, the physics there is fairly 

4 straightforward and very, very well known.

5 So I don't think that there will be 

6 any value. There might be sort of a value in 

7 appearance. If we happen to come up within a 

8 reasonable fraction of the measurement data, 

9 that will be fine. And if we don't, it won't 

10 prove anything.

11 DR. McKEEL: Dr. Ziemer?

12 CHAIRMAN ZIEMER: Yes? Yes?

13 DR. McKEEL: Dr. Ziemer, can you 

14 hear me now? This is Dan McKeel.

15 CHAIRMAN ZIEMER: Yes. Yes, go 

16 ahead. Go ahead.

17 DR. McKEEL: All right. Well I 

18 have to just reply to that, as I have done many 

19 times before, but there is something a little bit 

20 new. 

21 I've sent the Work Group by now three 

22 peer- reviewed scientific journal articles in 
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1 which MCNPX was used to model various aspects of 

2 radiation dosimetry. In all of those articles, 

3 just as I have stated, the model was tested 

4 against real measured data. We can call it 

5 empirical data. Whatever you want to call it. 

6 I call it measured data. In all of those 

7 instances the agreement between MCNPX and the 

8 measured data was 2 to 20 percent, plus or minus 

9 2 to 20 percent. 

10 In 2008, 2012 actually, NIOSH and 

11 SC&A were modeling the betatrons. Even though 

12 in some cases they were sharing input files to 

13 MCNPX, the closest they ever could come was 200 

14 percent, twofold. And in many papers they said, 

15 well, the agreement is reasonable. No, that 

16 agreement is not reasonable. It's not good 

17 enough. 

18 And we have another example. We 

19 have an example here of beta dose. You know, 

20 they're comparing beta skin doses now and they 

21 can't agree on what those doses should be. And 

22 then there are a number of instances, if you look 
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1 back over the last 17 or 18 Work Group and 

2 technical meetings where SC&A and NIOSH were 

3 sharing models, sharing files and their results 

4 didn't agree.

5 So I've just got to say that, you 

6 know, we've already found out that at least Dr. 

7 Anigstein did not have a chance to read this 

8 paper, so he's making comments about a paper that 

9 he has never read. And I can promise you from 

10 my 36 NIH grants where I was on different sides 

11 of the table, but the ones that I had where I was 

12 being grilled, if I'd given an answer like that 

13 to that review committee, my grant would have 

14 never gotten funded. 

15 So I think that at the very least, 

16 you know, it's imperative that everybody read 

17 those papers and then in some fashion maybe they 

18 come to the Work Group meeting and present a 

19 review, a verbal review of NYO-4699. 

20 I want to put this on the record 

21 to be very, very clear: I'm not a health 

22 physicist, that's true. I'm not a physicist, 
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1 but I am a physician and I have been at this now 

2 for a long time, since 2005 with GSI, and I think 

3 I understand a lot about betatrons. And I have 

4 contributed a lot of original information that 

5 this Work Group never would have gotten had I not 

6 put forth that effort. John Ramspott has 

7 contributed a lot as well. 

8 I think at this stage of the 

9 proceedings with the crucial nature of those 

10 film badges and the fact that the NYO-4699 papers 

11 do excellent measurements of the neutron fluxes, 

12 that at the very least somebody on the Board, on 

13 SC&A, at NIOSH needs to review those papers and 

14 send us a review and say what they think of those 

15 papers. And as a matter of fact, they can 

16 critique my paper if they want to. If they think 

17 I've got it all wrong, fine, do that.

18 But my own opinion is I think this 

19 is a ridiculous argument that Dave Allen makes 

20 where he says that he doesn't have enough data 

21 to model the results achieved using MCNPX. 

22 Nobody said you have to use MCNPX to arrive at 
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1 data. You know, let's not forget NIOSH is now 

2 normalizing their external betatron data for the 

3 film badges, which even today, 10 months after 

4 the Board voted, they say the film badge data may 

5 not be any good. Well, if the film badge data 

6 wasn't any good, GSI should have gotten an SEC 

7 back in December.

8 So anyway, I just don't think that's 

9 okay. I mean what the NYO-4699 paper does do is 

10 it gives doses, you know, in millirems or rems 

11 per year. And one column in all of those tables 

12 gives the fraction of the total dose that's 

13 accounted for by neutrons. 

14 Now, my feeling is I produced a 

15 paper that in my opinion NIOSH and SC&A, who have 

16 both been working on betatrons since 2005 -- they 

17 should have had those papers. You know, they 

18 are not new papers. They are on OSTI. OSTI is 

19 one of the main sources that NIOSH researches in 

20 just getting basic information together for 

21 their scientific papers. And they didn't get 

22 those papers. Or if they knew about them, they 
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1 didn't let on to this Work Group that they knew 

2 about them.

3 I asked Josh Kinman are they listed 

4 in the SRDB? And he said he couldn't find them, 

5 either one. Jim Neton was kind enough to send 

6 me the URL for the second, the original NYO- 4699 

7 paper, and I put that URL in my paper. 

8 So I believe there is data in those 

9 papers that is directly relevant to SC&A's dose 

10 calculations and to NIOSH dose calculations. 

11 And I'm not talking about modeling everything in 

12 MCNPX. The reason that you're modeling 

13 anything in MCNPX is because you don't have full 

14 or nearly full, or anything like full bioassay 

15 data. And as far as the film badges, you know, 

16 you have '63 to '66 of photons, period. No 

17 neutron data. No beta data. The film badges 

18 weren't read for that at GSI.

19 So I'm glad you all put this on the 

20 record. I think every person in that room, if 

21 they don't think these papers ought to be 

22 reviewed and the reviews put on the record, I 
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1 think is making a huge scientific blunder. And 

2 anyway, I won't take up any more time. That's 

3 just the way I feel about it and it's a very, very 

4 strong feeling.

5 CHAIRMAN ZIEMER: Okay. And that 

6 is so noted, Dan. We appreciate your input on 

7 that. In my mind if there were to be a formal 

8 review, it would be my impression that the 

9 responsibility would be to NIOSH as a starting 

10 point. In my mind I wouldn't be thinking about 

11 tasking SC&A to review this paper, per se. If 

12 it has importance, NIOSH needs to take a look at 

13 it. I think they have started to. I don't know 

14 whether it's of any value outside of the 

15 modeling. 

16 Dan, I heard you sort of imply that 

17 it might be thought of in terms of surrogate 

18 data.

19 DR. McKEEL: Absolutely.

20 CHAIRMAN ZIEMER: Yes, and I don't 

21 know if that's a possible consideration. 

22 Certainly NIOSH is here at the table. They're 
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1 aware of the paper. They can certainly consider 

2 that, I would expect. 

3 And, Jim and Dave, you certainly 

4 would want to take a cursory look and maybe a 

5 further look to see whether or not there is a 

6 possibility of additional usage of this. You 

7 apparently have looked at it from the point of 

8 view of the MCNP modeling, but is there any 

9 useful surrogate data there that would be of 

10 value as well?

11 But let me hear from the other Work 

12 Group Members.

13 MEMBER MUNN: This is Wanda. I 

14 have real reservations about the Work Group 

15 itself taking a position that we should be 

16 instructing either the Agency or our own 

17 contractor as to how they should pursue their 

18 investigations.

19 We are charged with the 

20 responsibility of seeing that adequate 

21 attention is being paid to the issues that are 

22 brought forward and I believe that we've 
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1 certainly devoted a reasonable amount of time, 

2 probably more than reasonable, to hearing the 

3 concerns and to hearing the exchanges between 

4 the parties involved with respect to issues that 

5 have been raised. Absent the group feeling that 

6 adequate attention is not being paid, then it 

7 appears very unwise for us to establish a 

8 precedent of telling any of the parties involved 

9 which material they should and should not be 

10 addressing. That's all I have to say.

11 CHAIRMAN ZIEMER: Okay. Josie? 

12 John? Any other comments?

13 MEMBER POSTON: Paul, I really 

14 don't have any substantive comments. I think, 

15 you know, before I would make any suggestion or 

16 having input I'd like to go back and reread the 

17 documents.

18 CHAIRMAN ZIEMER: Josie?

19 MEMBER BEACH: Yes, Paul, it's 

20 Josie. I agree with your thoughts on it, that 

21 it would have to come from NIOSH and possibly 

22 they would be willing to take a look at it and 
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1 address it and let us know as a Work Group, you 

2 know, how it would fit in for GSI.

3 DR. McKEEL: Paul, this is Dan 

4 McKeel again. Well, I would strongly endorse 

5 that. And what I was trying to point out is I 

6 wasn't -- I sent this paper in the beginning to 

7 NIOSH, you know, and I haven't heard a word back 

8 from them. I haven't even had the courtesy of 

9 them saying thank you for sending this 

10 interesting new paper; we'll look over it and 

11 appreciate your efforts. That's just common 

12 courtesy. In the scientific community not only 

13 is it common courtesy, it's de rigueur. You 

14 have to do that. That's just part of the 

15 process. And it wasn't done. 

16 So I would say my request has been, 

17 is, still is today I would like them to take this 

18 paper and to consider it. But, you know, words 

19 alone -- for example, Dr. Poston, whom I deeply 

20 respect, he said he'd like to reread the paper. 

21 Well, you know, that's why I sent it to you in 

22 the middle of August so you'd have plenty of time 
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1 to read the paper. You assured me that 

2 everybody had read the paper. Bob Anigstein 

3 hadn't read the paper. So I have no confidence 

4 this morning who's read the paper.

5 CHAIRMAN ZIEMER: Dan, I don't 

6 think I assured you that everyone has read it. 

7 I said everyone had it available to read.

8 DR. McKEEL: Of course they did, but 

9 everybody --

10 CHAIRMAN ZIEMER: Yes, but I 

11 certainly didn't take a survey. I don't take a 

12 survey to see what people have read and haven't 

13 read. I can't assure they've read anything.

14 DR. McKEEL: I know, but that's the 

15 reason you told me that it didn't need to be 

16 tasked to SC&A. And that's your prerogative. 

17 But you didn't --

18 MEMBER POSTON: Well, it seems to me 

19 that --

20 DR. McKEEL: You didn't --

21 MEMBER POSTON: It seems to me that 

22 using the word read implies that I've read the 
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1 paper, I've had a lot of things I've read over 

2 the last few weeks that I couldn't tell you 

3 exactly what's in them or so forth. I'd have to 

4 go back and review them. And that's all I was 

5 suggesting that I do.

6 MR. RAMSPOTT: Dr. Ziemer?

7 CHAIRMAN ZIEMER: Yes.

8 MR. RAMSPOTT: Hey, this is John 

9 Ramspott.

10 CHAIRMAN ZIEMER: Yes, John.

11 MR. RAMSPOTT: Can I make a quick 

12 comment?

13 MR. RAMSPOTT: You bet.

14 MR. RAMSPOTT: I've been listening 

15 to this and I have read that paper, and I mean 

16 General Steel is not the only place with a 

17 betatron or a cyclotron or any of the equipment 

18 that's in this paper. I'm amazed someone had 

19 not found it before Dr. McKeel did. And I think 

20 I even asked in one of the meetings, and the 

21 transcripts would probably bear it, and I think 

22 Dr. McKeel asked it, too, is there a good 
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1 published paper that anybody knows of that 

2 actually tells what happens when a betatron does 

3 what it does at GSI? And I never heard anybody 

4 say yes. 

5 So I think everybody owes Dr. McKeel 

6 a -- I mean I personally thank you. I've never 

7 seen this paper. And for people not to be 

8 willing to maybe take a little time with it when 

9 it probably applies to 80 or 90 percent of the 

10 sites that you people are reviewing daily is 

11 pretty amazing to me. This is the first good 

12 shred of information. 

13 And I do know that if you go to the 

14 University of Illinois Research Lab, or Research 

15 Library like I did, you'd probably find those 

16 floor plans for those buildings that those 

17 betatrons were in. I have no doubt. I mean 

18 that's where the betatron was invented. I've 

19 seen documents about those betatrons, but I bet 

20 the floor plans are there if we looked a little 

21 harder. And it's a research lab, or a research 

22 library open to the public. 
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1 But the main thing is that TBD-6000, 

2 which we were talking about earlier, I don't even 

3 think it says anything about non-destructive 

4 testing. That I still find amazing. This 

5 looks like a good direction towards that issue, 

6 too. It seems like GSI is the only place, you 

7 know, a device like this is really investigated 

8 only because of Dr. McKeel and my efforts. And 

9 now it's been picked up by everybody. 

10 So just a comment. I'm just amazed. 

11 Thank you.

12 CHAIRMAN ZIEMER: Okay. Thanks, 

13 John. I guess I want to hear from Jim Neton.

14 Jim, can you give us some indication 

15 of the feasibility of NIOSH taking a broad look 

16 at this from a point of view of possible use as 

17 surrogate data, or have you already looked at it 

18 from that point of view? 

19 DR. NETON: I've looked at the 

20 paper as well, principally like Dave did, from 

21 the perspective of its utility for what Dr. 

22 McKeel would like to see as a validation of the 
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1 model. And I agree with Dave, I don't see any 

2 usefulness apparent in doing that because again 

3 of the lack of detailed specifications in those 

4 papers that would allow us to have to make a lot 

5 of assumptions.

6 With regard to the surrogate data 

7 issue, I'm not quite clear what would occur here, 

8 keeping in mind that the SC&A model using the 

9 MCNP is already assigning a nine rem exposure per 

10 year to the layout person based on the MCNP 

11 model. And personally I haven't looked at it 

12 exactly, but I cannot believe that there was 

13 anyone in those facilities receiving more than 

14 nine rem per year from betatron operations. And 

15 that has to do with shielding and that sort of 

16 thing. And I just don't see as a good fit for 

17 surrogate data. I'm not seeing it. I could be 

18 wrong. Someone could point to me a better use 

19 of it, but you know, surrogate data would have 

20 to be under the same conditions, the same 

21 shielding conditions just like we've talked 

22 about, and I don't see that.
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1 DR. McKEEL: Dr. Ziemer, this is Dan 

2 McKeel. I must respond to that, please.

3 CHAIRMAN ZIEMER: Sure.

4 DR. McKEEL: All right. Well, 

5 let's see. So Dr. Neton says it has to be the 

6 same kind of data from the same source and so 

7 forth. This Work Group was perfectly willing to 

8 accept data from a cobalt-60 80-curie source 

9 used in the new betatron building in 1971, past 

10 the operations period at GSI, to use that as a 

11 model to predict external exposures to betatron 

12 operators, layout man, and things like that. 

13 Now, everybody admits that a 

14 cobalt-60 source is not the same in many ways as 

15 a betatron for the same reasons. You know, yes, 

16 it has photons, very little neutron dose, an 

17 omnidirectional source. Betatron is highly 

18 focused in a tight beam. 

19 And then the comments about assuming 

20 doses. As I read EEOICPA, the language is very 

21 explicit. They say that NIOSH has to be able to 

22 reconstruct the dose for every kind of cancer for 
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1 every worker that works in the facility. The 

2 concept of bounding is not really -- I've gone 

3 into this before with this group. I strongly 

4 disagree that you can point to, for example, 

5 doses from the new betatron and assume that that 

6 bounds the doses from the old betatron. You 

7 have to model that and then show that. 

8 And I want to give an example of 

9 another thing from our part-time radiographer 

10 [Identifying information redacted] from the 

11 data that SC&A has analyzed extensively and put 

12 in their report. The same report that shows the 

13 18 quarters of photon data that they extrapolate 

14 from 1963 back to 1958 has another entry in 

15 there, and it's called Pittsburgh Testing. And 

16 it says that this same individual, prior to his 

17 dose at GSI, got 7.2 rems in 2 quarters while 

18 working at Pittsburgh Testing Company. 

19 So we've interviewed [Identifying 

20 information redacted] about that. Pittsburgh 

21 Testing is a company that does non-destructive 
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1 testing radiography work in many states. Its 

2 headquarters was headquartered in Pittsburgh. 

3 He did jobs while he was there. He said he 

4 exclusively used an iridium-192 source. So 

5 based on that testimony, which I have relayed as 

6 well, he got 7.2 rems from an iridium-192 source 

7 in 2 quarters. Now you can consider that as 

8 either an incident or just a really dangerous job 

9 where you get really high doses, you know? And 

10 I don't need to explain that 7.2 rems in 2 

11 quarters extrapolated to 4 quarters is 14.4 rems 

12 for that year. 

13 All I'm trying to say is the 

14 iridium-192 sources trivialize cobalt-60 

15 sources as a source of significant exposure, 

16 trivialize neutron doses, everything 

17 trivialized. All of a sudden, radium-226 is it. 

18 And there's not one shred of measured data for 

19 the radium sources. There's not even good MCNPX 

20 data for the radium sources. 

21 So I think that a lot of these a 
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1 priori items saying no value for MCNPX, that 

2 could be NIOSH's opinion. And not useful as 

3 surrogate data, that's scientifically absurd. 

4 And I use that word very carefully for everybody 

5 there. That's a really bad scientific 

6 statement to make. There couldn't be any better 

7 surrogate data. It's fulfills all the criteria 

8 just right off the bat. University of Illinois. 

9 And again, all you have to do is read 

10 the paper which obviously everybody has not 

11 carefully done. And I would say this: I have 

12 taken the time to write a paper about NYO-4699 

13 and I think you all owe it to me that you read 

14 my paper and include that in your analysis. So 

15 again, I'm not going to prolong this anymore. 

16 I'm sure you don't want to either. 

17 I'm going to ask NIOSH and Jim Neton 

18 to look at that paper, please, with those two 

19 aspects in mind. Is it valueless as a 

20 validating tool when it's the only measured data 

21 available for betatron with film badge records 

22 and neutron data, and you can call that valueless 
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1 as a model validation, and it's valueless as 

2 surrogate data, I would like to see that in 

3 writing and the reasons why, as a scientist. 

4 And I have to say this: and this may 

5 seem presumptuous, but I would say as a scientist 

6 with a curriculum vitae that probably matches 

7 all the people in that room, you know -- so on 

8 that level I think it is from one of your peers 

9 that's asking you to do this. And I'm asking you 

10 to do it today. And that's really all I do have 

11 to say. Thank you.

12 CHAIRMAN ZIEMER: Okay. Thank 

13 you, Dan. Okay. NIOSH has heard your request. 

14 As the Work Group Chair, I'm not going to demand 

15 that they do that, but they've heard the request.

16 I think one point Jim was making was 

17 that the proposed modelers would probably end up 

18 assigning a dose than assign a few years as 

19 surrogates, because in the most part -- and I 

20 think you've pointed out, Dan, for the most part 

21 the exposures would not be excessive. So they 

22 were probably much lower. I don't recall exact 
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1 numbers, but there were a few cases where they're 

2 higher. But in any event, NIOSH has heard your 

3 request and we'll let them proceed as they see 

4 fit.

5 DR. McKEEL: Well, can they give an 

6 answer as to what they're going to do? You know, 

7 Paul, one of the problems with this Work Group 

8 is you bring things up and then there's never a 

9 conclusive answer to them. I'd like to have an 

10 answer. Are they going to review the paper, yes 

11 or no?

12 DR. NETON: I will keep that under 

13 consideration, Dr. McKeel, and put out an 

14 answer, but right now my feeling is the use of 

15 an academic or a medical facility as a surrogate 

16 exposure model for a steel facility is not an 

17 appropriate comparison. That's my opinion, but 

18 we will issue an opinion on whether we're going 

19 to review it or not.

20 DR. McKEEL: Thank you.

21 CHAIRMAN ZIEMER: Okay. Thank 

22 you. It's now five minutes to 2:00. I don't 
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1 think we're even going to get into the Appendix 

2 BB matrix. We won't have time to do anything on 

3 that. 

4 I'm going to prepare a report for the 

5 Board meeting which will simply be a summary of 

6 what we've covered today and what the 

7 deliverables are going to be. I'll put that in 

8 writing so there's no question on it. And then 

9 we will try to set up a Work Group meeting in the 

10 fairly near future, assuming the government is 

11 still in operation and we can do that.

12 MR. KATZ: So, Paul, this is Ted. 

13 Do you need any help from SC&A for your 

14 presentation?

15 CHAIRMAN ZIEMER: I don't think so.

16 MR. KATZ: Okay.

17 CHAIRMAN ZIEMER: I think I'll just 

18 summarize what we've covered here today.

19 MR. KATZ: Okay.

20 CHAIRMAN ZIEMER: Okay. Any other 

21 comments at this point?

22 DR. ANIGSTEIN: Yes, I have one. 
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1 This is Bob. I have one comment about Dr. 

2 McKeel's comments, and that is I have the same 

3 exposure history record that he was referring to 

4 for the radiographer who had worked at 

5 Pittsburgh Testing and his dose was simply 

6 assigned to him on the AEC record on the 

7 assumption that he got the maximum allowable 

8 dose. It was not a measured dose. The 7.5 rem 

9 for 2 quarters was simply --

10 DR. McKEEL: 7.2 rem.

11 DR. ANIGSTEIN: It says right here 

12 calculated at 3.75 rem per quarter, which is one 

13 quarter of the 15 rem maximum limit at that time. 

14 There was no measurement.

15 CHAIRMAN ZIEMER: Okay. There is 

16 no particular reason to debate that at this 

17 moment.

18 DR. ANIGSTEIN: Okay.

19 CHAIRMAN ZIEMER: But I'm going to 

20 adjourn here unless there's any pressing issue 

21 that we need to raise.

22 (No response.)
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1 CHAIRMAN ZIEMER: If not, I thank 

2 you all for your participation. We'll see many 

3 of you in a week or so and then get information 

4 back on when the next meeting will be. Thank you 

5 very much.

6 MR. KATZ: Thanks, everybody.

7 (Whereupon, the above-entitled 

8 matter went off the record at 1:58 p.m.)

9

10