NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1716 14TH ST. NW, STE. 200 

(202) 234-4433 WASHINGTON, D.C. 20009-4309 http://www.nealrgross.com 

Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

141st Meeting

Wednesday, August 18, 2021

The meeting convened at 1:00 p.m., Eastern Time, 

via video teleconference, Henry Anderson, Chair, 

presiding. 
2 

Members Present: 

Henry Anderson, Chair

Josie Beach, Member

Bradley P. Clawson, Member

R. William Field, Member

David Kotelchuck, Member

Genevieve S. Roessler, Member

Phillip Schofield, Member

Loretta R. Valerio, Member

Paul L. Ziemer, Member

Registered and/or Public Comment Participants: 

Roberts, Rashaun, Designated Federal Official

Adams, Nancy, Niosh Contractor

Barton, Bob, SC&A

Behling, Kathy, SC&A

Blaze, D'Lanie

Buchanan, Ron, SC&A

Calhoun, Grady, DCAS

Cardarelli, John, DCAS

Chalmers, Nancy, ORAU Team

Cook, Maddie, DCAS

Crawford, Chris, DOL

DeGarmo, Denise

Fitzgerald, Joe, SC&A

Gheen, Angelica, DCAS

Gogliotti, Rose, SC&A

Guido, Joe, ORAU Team

Hand, Donna

Hughes, Lara, DCAS

Kinman, Josh, DCAS

Kranbuhl, Alek, DCAS

Lewis, Greg, DOE

McCloskey, Pat, ORAU Team

Naylor, Jenny, HHS OGC

Nelson, Chuck, DCAS

Reeves, Kandyce, DCAS

Rutherford, LaVon, DCAS

Sheanshang, Daniel, ORAU Team

Taulbee, Tim, DCAS

Whitten, Dianne
3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health 141st Meeting 

Wednesday, August 18, 2021 1

Welcome 4

NIOSH Program Update 7

DOL Program Update 18

DOE Program Update 21

Procedures Review Finalization 28

Board Work Session 66

Public Comment 101
4 

Proceedings

(1:00 p.m.) 

Welcome 

Dr. Roberts: So good morning and good afternoon to 

everybody. I'm Rashaun Roberts, and I'm the 

Designated Federal Official for the Advisory Board on 

Radiation and Worker Health, and I would like to 

welcome you to Board Meeting 141. 

So let me first of all get through some preliminaries 

for the meeting. Today is the first half day of the 

virtual Board meeting, and tomorrow will be the 

second and final half day. Like today, tomorrow's 

session is scheduled to start promptly at 1:00 p.m. 

Eastern Time.

All of the materials for the days, the meeting 

agendas, presentations, background documents and 

so forth are posted on the NIOSH website for this 

program under the scheduled public meetings, the 

August 2021 tab. If you will be participating in both 

days by telephone only for both days, you can go to 

the website and access all the materials, and you can 

follow along with the presentations, and the materials 

were provided to the Board members and other staff 

prior to this meeting.

If you take a look at the agenda on the website, 

there's a Zoom link which will enable you to hear and 

watch the presentations through Zoom. But I want to 

advise you that you'll only be able to speak -- you 

will only be able to speak to the group and I believe 

to hear the presentations through the telephone 

lines.

Speaking of telephone lines, in order to keep 

everything running smoothly and so that everybody 

speaking can be clearly understood, I'd ask each of 

you to mute your phone unless you're speaking of 

course. If you don't have the mute button, press *6 

to mute. If you need to take yourself off press *6 

again.
5 

And also because we may be unable to see each 

other, some of us might be unable to see each other. 

Please identify yourself before your comments and 

questions. Let me also mention that we do have a 

Public Comment session that comes at the end of the 

day today. It will be between 5:30 and 6:30 Eastern.

I do encourage people to be ready right at 5:30 

Eastern for public comments, because at that time 

we go right to the comments and if we run through 

all of the comments at the time, we will end the 

session. 

We won't conclude before 5:30, but we will conclude 

at any point after that once everyone in the public 

who would like to comment has done so. So again, 

please join us right at 5:30 for the Public Comment 

session so that you're assured to have your 

opportunity.

And also so that you're aware, comments during the 

Public Comment session, speakers are generally 

limited to about -- limited to about five minutes. I will 

remind everybody of this again later this afternoon.

We're going to move into roll call. We do need to 

address conflict of interest for the Board, and actually 

there are no conflicts to address for today's agenda. 

So let's go ahead and do roll call, and we will start 

with our Chair, Andy Anderson.

(Roll call.)

Dr. Roberts: Great, okay. Anybody else? I'm sorry, 

was someone saying something? Okay. Are there any 

members of the public who would like to register their 

attendance at this point?

Okay. I don't hear anyone, so let's go ahead and 

move further into the agenda. Again, please 

periodically check Zoom or your phone to ensure that 

you're on mute when you're not speak. If you're on 

Zoom --

Ms. Blaze: Excuse me, hello. This D'Lanie Blaze. I'd 
6 

like to register my attendance.

Dr. Roberts: Oh great. Hi D'Lanie.

Ms. Blaze: Hi.

Dr. Roberts: Great, anyone else?

Ms. Blaze: It's double muted, thank you.

Dr. Roberts: Hi, yeah. Happens to the best of us. 

Anyone else in the public who would like to register 

attendance? 

Okay. If you happen to be on Zoom, the mute button 

is located at the lower left-hand corner of your screen 

if you kind of hover over it. And again, if you're 

participating by telephone and you don't have the 

mute button, press *6 to mute. If you need to take 

yourself off, press *6 again. 

So with that, I think all of that business is covered. 

So with no further delay, let me turn the floor over to 

the Board chair, Dr. Henry Anderson. Andy?

Chair Anderson: I'd like to welcome everybody to the 

141st meeting. Hopefully before too long we will be 

counting increases in meeting numbers and have 

them all be virtual. But we're going to be virtual it 

sounds like till at least the end of this year, and we'll 

see how things progress and maybe hope for a face 

to face meeting come next spring.

So with that, I'd just welcome everybody. As you 

know, recruitment is going on. NIOSH is looking at to 

have additional Board members added to our group. 

So hopefully that will occur in the not-too-distant 

future and the nominations have been closed. 

I understand there's been a fair number of 

nominations, so NIOSH will have quite a few people 

to choose from and I think the goal is to keep, follow 

the directive and statute to have a balanced board. 

So we may be choosing some individuals to fill out 

some of the areas where we've had some loss.
7

So in any case, that will be going on and NIOSH I'm 

sure will keep us informed as that moves forward. 

Hopefully, any new members can be bought on, 

brought on when we have a face to face meeting so

we can have lunch and get to know them a little 

better than just by seeing faces.

I see Billy you've got your -- Bill Fields, you've got 

your picture up and I see your hair as a different color 

than when we see you in person. So with that, I'd like 

to welcome everybody and we'll move on to a 

program update from Grady if you want to switch 

over to his screen.

Mr. Calhoun: So Andy, you say I need some 

photoshopping going on there or what?

Chair Anderson: Yeah. I don't know what happened. 

I had trouble, but I'm using my CDC computer and 

where my other computer has all my nice 

backgrounds, and it refuses to accept them on my 

different computers. I've got a messy back office.

Member Beach: I was wondering why he was picking 

on poor Bill. 

Chair Anderson: Right.

Member Field: I'm going to have to dye my hair now 

see.

Chair Anderson: Oh no. He's a fellow Midwesterner 

so -- okay Grady.

Mr. Calhoun: Can everybody see my screen there?

Chair Anderson: Yep.

NIOSH Program Update

Mr. Calhoun: Okay. It's not exactly how it's supposed 

to be I don't think, but as long as you can see it, I'd 

be happy with that. Okay. I too am glad to be here, 

but like Dr. Anderson, gosh I wish I could see 

everybody in person again. It's kind of a bummer 

being stuck in my office, which has been in my room 
8

for the last year and a half.

So without further ado, Contracts and Staffing. We 

hired one health physicist due to retirement of one. 

We've got, unfortunately we have another one of our 

health physicists retiring this month, Tom Tomes if 

you all know him. He's going to be retiring this 

month, so we're going to begin the recruitment and 

hiring process beginning in the next fiscal year. So in 

the next couple of months we'll start that. 

And as you can imagine, workshops, town halls and 

outreaches have been pretty few and far between. 

We don't have any finalized since our last meeting 

although DOL does, DOL has one planned in the nottoo-distant future. But none with normal joint 

outreaches that we do with NIOSH. 

I'll get into some of this at the end when we talk 

about our IT modernization, but a lot of these 

statistics are what we could -- what we could glean 

from the data that we can access right now. We have 

160 requests at the Department of Energy. That 

doesn't mean that those are late, I would say that. 

That just means they haven't responded yet. Only 16 

of those have exceeded the 60 days.

Right now, the transfers are going -- they're being 

requested from the Department of Labor, and then 

they're coming to us. So it's a little bit different 

system for now, and like I said I'll get into a little bit 

of that in that last slide.

We've gotten 53,392 cases from Labor, and we've 

returned 51,653. We still have 772 at NIOSH ORAU 

for dose reconstruction and just under a thousand 

have been closed administratively. We submitted 

46,397 to DOL with dose reconstruction. 6,989 were 

pulled from dose reconstruction by DOL and for 

various reasons, and 3,567 were pulled because they 

qualified for special exposure cohort compensation.

Probability of Causation. Of the 46,397 DR (audio 

interference), 12,564 were greater than 50 percent; 

33,824 were less than 50 percent. So we're still 
9

running about the same percentages.

Active cases at NIOSH for dose reconstruction, 772. 

We have 578 that are actually in the process. 91 of 

the initial draft reports are with the claimants, and 

then 103 cases that we're preparing for dose 

reconstruction and that means we're just 

accumulating the data that's necessary to start that.

And here's the one everybody is going to be 

interested in. As we've mentioned in the last meeting 

or two, we're going -- we're undergoing a very 

significant IT modernization with our applications. 

DOL continues to forward cases to us for dose 

reconstruction. DOE continues to collect personal 

dosimetry for cases, and right now DOL is actually 

informing DOE of which cases are coming up so DOE 

can correct the dosimetry that's necessary.

We have, right now are in the process of getting 

mechanisms so we can return to our task of actually 

making that request to DOE. But for now, DOL is 

making those requests so DOE doesn't miss a beat. 

For the cases that we had already received, ORAU is 

continuing to complete the dose reconstructions. 

Those cases will ultimately come to us for approval. 

They have not yet, at least not on a consistent basis 

and that's just due to our manual process that we 

have in place right now.

What we're doing for this, during this manual process 

is we're focusing on terminal expedite cases. So when 

Department of Labor tells us that they have 

somebody that's terminal, we still have some manual 

process that we put these to the front of the line and 

try to get those out as quickly as we can. They're the 

highest priority.

The Site Research Database, as you all know, is still 

extremely limited. We're working on that. I've been 

speaking with Rose Gogliotti of SC&A. We're in the 

process of trying to get the dose reconstruction 

supporting documentation for the Dose 

Reconstruction Review Committee for cases they're 
10

reviewing.

We're trying to get that in place as quickly as we can, 

and the Board and SC&A will get access as soon as 

we have access. So there's a lot of moving parts here, 

you know. We talk about Phase 1 and Phase 2. Phase 

1 is very manual. That's pretty much where we are 

right now. Phase 2 will be, you know, a lot more 

automated and as of yesterday we're thinking that 

that's going to start around January of 2022.

But it's not an all or none type scenario. We're 

continuing to make improvements to the way that we 

can create documents within this secure space and 

process claims. Another challenge we have right now 

is getting the information back and forth to 

Department of Labor. So again, that's because of our 

IT modernization effort and is no reflection on 

Department of Labor.

So that's all I have. I believe (audio interference). So 

if you have any questions on that I will gladly field 

those.

Chair Anderson: Grady, just a question. For the 

research database access, is the IT issue one of kind 

of getting to the database or undergoing potential 

changes to the database? So things that might have 

been in there previously will now have been 

characterized separately and be removed or be in a 

different access, or is this basically we're really just 

waiting to get into the door of the library, rather than 

the books in the library are going to be all --

Mr. Calhoun: Yeah, yeah. All the books in the library 

will be there.

Chair Anderson: Okay.

Mr. Calhoun: Right now, what we're working on is, 

you know, there's a lot of changes to our 

applications. But you know, it's not worthwhile for 

you or us to not be able to have a search mechanism 

like we used to. So they're looking, our IT folks are 

looking at ways of coming up with a similar search-
11

type mechanism, so that we can do the kind of 

queries that we used to do.

So it's an access issue and it's also we've got to make 

sure that once we get access to the hundreds of 

thousands of documents we have in there, that 

there's a meaningful way for us to search for what 

we need to look at. So yeah, yeah it's -- all the books 

are going to be there, so keep your library card.

Chair Anderson: Because I think some of the problem 

in the past is things would be four levels down in 

trying to know when you go one level and then you 

look at 10,000 lists of documents, which is the next 

level you want to go to. So the search engine 

becomes really critical.

Mr. Calhoun: It absolutely is, and yeah. We 

understand that and we don't have that capability yet 

ourselves.

Chair Anderson: Okay.

Mr. Calhoun: We're not going to hoard; we're not 

going to be keeping these accesses, if you will, to 

ourselves. Once we get them we will certainly be 

giving them to you and your contractor as well.

Chair Anderson: Okay.

Member Ziemer: Grady, this is Paul Ziemer. I have a 

question. Can you tell us what the status of the 

package that went to the Secretary on Savannah 

River is, or is that something that Nancy Adams 

would have to answer?

Mr. Calhoun: Yeah, I think that -- yeah. I have been 

told by the Secretary, but I think I would prefer to 

wait until I see the signed document.

Member Ziemer: Oh okay.

Mr. Calhoun: But as of, as of right now, there are --

there are no outstanding issues that would surprise 

anybody about that.
12

Member Ziemer: But the whole package is in the 

Secretary's office?

Mr. Calhoun: Yes sir.

Member Ziemer: Yeah. That's what I was wondering.

(Simultaneous speaking.)

Mr. Calhoun: Both for Savannah River and Superior 

Steel.

Member Ziemer: Thank you, appreciate it. Thank 

you.

Member Beach: Grady, this is Josie. I have a 

question. It's actually a two-part question, one part 

for you and one part for DOL later. But on Slides 5 

and 7 you -- the numbers are 772 cases, and DOL's 

are much higher than that. When I was doing the 

math on even adding up some of those numbers, 

your numbers come in way lower than the numbers 

that DOL's reporting on their presentation.

Mr. Calhoun: Yeah.

Member Beach: Will you let us know --

(Simultaneous speaking.)

Mr. Calhoun: Yeah. I can tell you exactly what that 

is, is we've basically lost access to the databases to 

track all that.

Member Beach: Okay.

Mr. Calhoun: So we don't have as accurate a number, 

so we kind of try to piecemeal what we do know for 

that. So what we're used to relying on isn't there right 

now. 

Member Beach: Okay.

Mr. Calhoun: That's what the differences are right 

now. I mean DOL and our numbers are never quite 

the same, but they're sometimes closer than that. So 

the reason is lack of access to our numbers on our 
13

side, not DOL. 

Member Beach: Okay, and for the IT modernization, 

we have no access to the O drive, K drive, and also 

when you go in just to get into the website, it looks -

- it appears different this week than it did even last 

week. So that's what we can expect right now; is that 

correct?

Mr. Calhoun: Yeah. The O drive, K drive, whatever 

(audio interference) kind of things that you're used 

to seeing, that's part of the IT modernization. If 

you're referring to the actual DCAS Internet site, that 

has nothing to do with modernization. That's just the 

same, but they -- they must have made it look a little 

different.

Member Beach: Well that, it just -- when you go to 

access it, the last couple of days it shows that you're 

already accessed to it, which is unusual because you 

had to follow a lot of different steps with your --

Mr. Calhoun: Oh oh, you're talking with the bin card, 

right?

Member Beach: Yeah.

Chair Anderson: Yes.

Mr. Calhoun: Oh, I thought you were talking about 

our website (audio interference). You're right. I hit 

exactly the same thing and --

Member Beach: And that's just in the last day or two, 

right?

Mr. Calhoun: Yeah. That has nothing to do with IT 

modernization that I know of. That's exactly right.

Chair Anderson: That happened to me this morning 

when I was trying to get it, and it's totally different.

Member Beach: Can anybody answer why that's 

occurring, because that's -- that's new since 

yesterday that I know of.
14

Mr. Calhoun: I would -- nobody here on this call is 

going to be able to answer that I think. You know, I 

can -- I can check, but I've run into exactly the same 

thing.

Member Beach: Okay, so yeah.

Mr. Calhoun: Yeah. There's no reason for that, but 

the fact of the matter is that you were logged in and 

it's keeping you logged in I believe is what it seems 

like to me.

Member Beach: But that, yeah. That yeah, seems 

odd. Okay, thank you. That's all I have for --

Chair Anderson: Any other questions?

Member Clawson: Yeah Grady, this is Brad. You said 

that you guys are working on the terminal cases right 

now. I'm just wondering, because I was notified of 

several terminal ones in Hanford and I know you can't 

tell me online here but --

Mr. Calhoun: Generally. I think I can tell you 

generally is that once DOL, Department of Labor 

knows a case is terminal, and this is how we've 

always gotten the notification, they let us know and 

we put that to the top of the line. You know as of 

right now, there's less than ten that are in the system 

that are like that.

Member Clawson: Okay, that sounds good. That's 

what I wanted to make sure.

Mr. Calhoun: And if those -- if you know of one, make 

sure that the people actually contact Department of 

Labor to let them know if they haven't.

Member Clawson: Okay. I'll let Pat know. I just, you 

know, sometimes we get just notifications from other 

people, and I just wanted to make sure. I thought 

that we were still working on that, and putting them 

at a high priority. But I just want to make sure.

Mr. Calhoun: Yes.
15

Chair Anderson: Any other questions?

Member Valerio: Grady, this is Loretta. I have a 

question. So on these terminal dose reconstructions, 

are you obtaining the dosimetry records directly from 

the site? Are those being funneled through DOL and 

are you running into any obstacles getting those 

records to expedite these claims?

Mr. Calhoun: No, we are getting them directly from 

DOE. SERT still works. There have been a couple of 

firewall issues we're working through, but the big 

issue right now and it's too much information for you 

but it's SAMS is the issue, and that's the portal that 

basically is used to transfer information back and 

forth between DCAS and DOL.

The information that we get from DOE is through 

SERT, and for the most part that's been working.

Mr. Barton: Grady, this is Bob. Just to clarify, I mean 

no one wants (audio interference) that is here. But 

you actually have Phase 1 and Phase 2, and said 

research database will be available to us all as soon 

as it's available. But am I correct in assuming I'll not 

be in till January?

Mr. Calhoun: No, no. It will be before then for sure. 

Mr. Barton: Okay.

Mr. Calhoun: Yeah. We actually have an area set up 

right now that we can place some files in for access. 

But those are pre-selected piles like the Dose 

Reconstruction Review Subcommittee. We know 

exactly what files they want. The issue is going to be 

for us to develop a search tool, so that not only can 

you look you can store them somewhere because you 

don't want to --

We all know you can't just open up one file and then 

have to go look for another file without having that 

one file stored somewhere. It's convenient for us all 

to have it stored. So that's one of the issues we're 

working through. So I certainly don't anticipate it 
16

taking, taking anywhere near January so --

(Simultaneous speaking.)

Mr. Barton: --for the near term, if we needed a 

specific SRDB reference, will we be able to make that 

request and --

Mr. Calhoun: I would. I would. If you need the actual 

SRDB number, you know, you know let, let me or 

LaVon know and we'll try to get that into the system. 

That should be pretty doable.

Mr. Barton: And the other question I had was really 

to you have DR Tools modules that are usually used 

for dose reconstruction, are obviously really 

important for you to do like the blind cases and the 

DR audits. Is there -- I mean let's, do we have any 

sense when those might be available for us to use 

again --

Mr. Calhoun: I'll check. I'll check on that. That should 

be something that's very much that needs -- we need 

it too. Mr. Barton: Yeah.

Mr. Calhoun: To approve dose reconstruction. So you 

know, that may be available very soon. But let me 

check on that to make sure that you guys get access 

to it as well.

Mr. Barton: I appreciate it Grady, thank you.

Mr. Calhoun: I'll write that down.

Member Clawson: Hey Grady, this is Brad. What 

about, what about contractors that don't want to be 

in SERT like Boeing or, you know, for Santa Susana. 

What, how are we working with that?

Mr. Calhoun: Well Brad that is -- I didn't know of that 

wrinkle, so I'll have to check with that. I don't know 

if -- I don't know what the mechanism was for that 

typically, but I'll have to check. I don't know that. I 

don't know if DOL knows that information off the top 

of their head or DOE I mean. But when Greg's turn 

comes, maybe he can address that if he knows. But 
17

ask anyway.

Member Clawson: Okay.

Chair Anderson: Any other questions? Okay then, 

let's move on to Program Update from DOL. Chris 

Crawford, change to your screen?

Mr. Crawford: Can you hear me? Hold on, let me get 

it here.

Chair Anderson: So Grady, are you the -- you the 

opener of the files?

Mr. Calhoun: Yes sir I am.

Chair Anderson: (Audio interference).

Mr. Calhoun: Can you see that one? Chair Anderson: 

Yes, no.

Mr. Calhoun: Can you see DOL, Department of Labor 

presentation?

Chair Anderson: I don't.

(Simultaneous speaking.)

Mr. Calhoun: Okay, hold on.

Mr. Taulbee: I think you have to stop sharing yours 

and then start sharing again.

Mr. Calhoun: Oh okay.

Chair Anderson: That's a good start.

Mr. Calhoun: Well, yeah. I'm not really the IT guy. 

Let's see --

Chair Anderson: Back to training, Grady.

Mr. Calhoun: There we go. How about now?

Chair Anderson: Nope.

Mr. Crawford: Oh there it is.
18

Mr. Calhoun: Okay. I'm going to mute myself, but I'll 

listen to Chris when he tells me to switch slides.

DOL Program Update

Mr. Crawford: This is Chris Crawford. Can you hear 

me?

Chair Anderson: Yes.

Mr. Crawford: Great. Thanks Grady once again for 

handling the slides, and let's go to the second slide. 

Mr. Calhoun: It's not moving here, hold on.

(Pause.)

Member Beach: Chris, you jinxed him.

Mr. Calhoun: There we go, there you go. Page down, 

I gotcha.

Mr. Crawford: Great. This is our usual money slide. 

You see that Part B Compensation has amounted to 

7.3 billion to date. Part E Compensation, 5.6 billion, 

and medical bills, 7 billion, for a total of $19.9 billion, 

and with 219,796 cases filed.

Slide 3. We've paid 1.69 billion for DR cases. That's 

without SECs, with 15,843 payees. We've also paid a 

small category 176 million with both an approved 

SEC and a DR with a PoC greater than 50 percent, 

and 1,351 payees fell under that category.

Slide please. There we go. For referral case status, 

our numbers show 54,479 cases referred to NIOSH 

for dose reconstruction, of which 52,770 cases have 

been returned to DOL from NIOSH. 46,234 of those 

came back with a dose reconstruction, and 6,536 

were withdrawn from NIOSH with no dose 

reconstruction.

Our numbers show, and this is where Jody saw the 

discrepancy, 1,709 cases currently at NIOSH, with 

1,088 initial, original referrals to NIOSH and 621 

reworks or returns to NIOSH.
19

Next slide. Here we the cases with a DR and a final 

decision. These are not SEC cases except for a very 

small number. Of these 36,853 cases with a dose 

reconstruction and a final decision and have final 

approvals at 12,608 and final denials at 24,245. This 

ratio has held up for quite a long time.

Slide 6 please. Now for Part B cases filed, we see that 

11 percent were cases referred to NIOSH that were 

SEC cases. 31 percent were original cases that were 

just sent to NIOSH initially. 38 percent were 

beryllium or silicosis-related cases. 7 percent were 

RECA, and then there are 13 percent of SEC cases 

that never were sent to NIOSH.

All right. Also a familiar slide, Part B cases with a final 

decision, and this includes SEC cases. We have 

108,507 cases with final decisions in Part B. There 

were Part B approvals for 57,837 and denials of 

50,670, which is 53 percent approval, 47 percent 

denials.

Next slide, there we go. For work sites, the usual 

suspects are the Nevada Test Site, Savannah River 

Site, Hanford and Y-12. Okay. At this meeting, Y-12 

and Oak Ridge are being specifically discussed. Y-12, 

these are both big sites as you see. We have 22,365 

cases with 5,487 returned with dose reconstruction, 

9,922 final decisions. 

Grady, do you want to go one more slide and then 

come back to this one? We'll follow Y-12 all the way. 

So Part B approvals Y-12, 6,097. Part E approvals, 

6,956. Total compensation and medical bills paid 2-

1/2 billion. 

Back to 9 Grady, thank you. Oak Ridge Laboratory, 

X-10, we've had 10,964 cases. 3,117 were returned 

by NIOSH with a dose reconstruction. We have 4,840 

final decisions. 

10. We have Part B approvals of 2,744, Part E 

approvals 3,190, $1.1 billion in total compensation. 

Slide 11. This is an upcoming outreach event, a little 
20

rare as you see but we have one coming up next 

week, one week from today on the NIOSH and the 

DOL Ombudsman's Office, and of course we don't 

know how many people will attend that. But that's 

the role of the Ombudsman's Office, how the 

Ombudsman can assist the claimant and give 

practical information and tips on the claims process.

Next slide. Here are events already held, outreach 

events. We had a stakeholder update July this year 

with 153 attendees. In June, we had a medical bill 

reimbursement processing meeting with 232 

attendees. May, we had a policy discussion with 108 

attendees, and then in April we had a medical benefit 

coverage meeting, two attendees. I believe that's the 

end. Let's check the next slide Grady. There we are.

And that's the end of the presentation. If there are 

any questions, I'd be happy to try to answer them.

Member Beach: This is Josie. Do you mind if I start 

Henry?

Chair Anderson: Oh, go ahead.

Member Beach: I just have a question on -- I'm not 

going to ask the numbers between NIOSH and DOL. 

That was one I was going to ask, but so DOL's 

number of cases, what you list is different on your 

Slide 4 than it is on your website. 

I know there's a difference of a couple of weeks. Is 

that, is there a reason why that would be different? I 

think your website was August 8th, and then this one 

was of July.

Mr. Crawford: Well that's right. We do use different 

end periods, end dates for the statistics, which 

certainly would cause some discrepancies there. Is 

there a difference in how the cases are 

representative? Does DOL use unique workers or 

cases when they're using -- for their numbers?

Mr. Crawford: So a case refers to a unique employee, 

okay, where the claimants can be a much larger 
21

number than that. There are multiple claimants in 

some cases.

Member Beach: So I guess that's my question then. 

Do you use unique workers or case workers? Okay, 

thank you. That's all I have.

Mr. Crawford: Sure. 

Chair Anderson: Any other questions? Okay, no other 

questions. Let's move on to DOE. Greg, let's get his 

slides up. 

Mr. Calhoun: Greg, am I sharing for you? I popped it 

up there.

DOE Program Update

Mr. Lewis: Yeah, this is Greg. I can see it. Can 

everybody hear me? I'll take that as a yes. Grady, 

you can go to the second -- go to the second slide 

please. I'm still seeing the first slide. 

Here we go. So I think the big item for me, I'm just 

going update everyone on a little news, and I figure 

much like Grady said, I think, you know, people 

probably most want to know about what's going on 

with the IT modernization effort.

You know, Grady mentioned it a little bit, but we've 

been involved in this as well. We've been meeting 

weekly with DOL and NIOSH or I have, to discuss the 

effort and make sure we're all on the same page as 

far as the different actions being taken. 

Our role at DOE, of course, is much smaller. The one 

thing that we are doing, as Grady mentioned, is 

Department of Labor, even though NIOSH isn't 

receiving all of the new dose reconstruction cases or 

is not able to work on all of them yet with the IT 

issues, Department of Labor knows who they would 

be sending over.

So DOL is sending us lists every two weeks of the 

cases that they would have referred to NIOSH. So 

we're starting the -- we're starting the process of 
22

gathering those records so when NIOSH does come 

back online and starts to make the actual request in 

our SERT system, we should have most of those all 

ready to go, all pulled and, you know, reviewed and 

sitting there ready to go. So hopefully, you know, 

NIOSH is not going to have to wait another 30 to 60 

days for us once they are back online.

So we are doing that, and then of course we're also 

continuing to, you know, when NIOSH is able to make 

request in SERT, whether it's a terminal or just 

something they're able to work or continuing to work 

those. And then we also have the ones that, you 

know, there are a few that are later that we're still 

working on from before the modernization that we're 

trying to get back out.

So that's the, you know, that's our role in that 

modernization effort. The only other thing I'll 

mention, I think the last couple of meetings I talked 

about are, you know, how we're adapting to COVID 

and able to respond to the requests. 

For the most part most, you know, and in fact this is 

probably true for most of the pandemic, our sites 

were able to still gather records and respond. We 

had, in particular we had problems at two sites, and 

that's the Nevada National Security Site or Nevada 

Test Site and the Y-12 site. Now Nevada, there was 

a number of issues in play mostly because the 

security there and where their records are located.

They were down for, fully down for three to four 

months at the beginning of the pandemic, and then 

they had some key staff retire. So they've been 

catching up, but they have been catching up steadily. 

I've been monitoring their progress and they still 

have a number of late claims. But they're, each 

month they're getting that number down, and I think 

they anticipate being back even by hopefully the end 

of September possibly October. But they are working 

that number down and getting those claims out.

Y-12 has been going a little bit up and down, but their 

issue is the Federal Records Center, which almost all 
23

Y-12 records that they use to respond to DOL and 

NIOSH requests are held at the Federal Records 

Center. Those have been open -- they were closed 

initially, then they opened back up, closed again, 

open-close. 

So it's been a little bit of a see-saw there with the 

Federal Records Centers. But the Y-12 number has 

also been coming down recently. So we're continuing 

to work Y-12 and unfortunately if you saw, I think, 

on Chris' slides, those are two of the biggest four 

sites, of course. But we're trying to do the best we 

can and we're making progress on both.

Next slide, please, and I'll go through this. These are 

sort of my standard slides, so I'll go through this 

fairly quickly. But if, you know, anyone has questions 

or wants more detail I can always go back at the end.

So at DOE, we of course provide records. That's our 

core mandate. We work with DOL, NIOSH and the 

Advisory Board to provide worker and facility records.

Next slide. We do this responding to individual claims 

in SERT. We also work with NIOSH and DOL for site 

characterization projects. So you know, the stuff 

we're talking about today and also as well as 

Department of Labor is always working with us to 

update their site exposure matrix.

And then we also conduct research on covered 

facilities, and we actually I think are preparing a 

Federal Register notice with a couple of changes for 

smaller facilities. We anticipate that coming out in the 

next month or so.

Next slide. I'll skip over this. You know, most of you 

know our process is not, is not straightforward. It's 

not one file for one individual. We might have to go 

to multiple places on site for, particularly for workers 

that had a long career. Their records could be in 

multiple locations, databases, hard copy, microfilm, 

microfiche, that kind of thing.

Next slide. And recently, I just went back for about a 
24

month looking at some of the requests that have 

come in. I know we've been responding with the DOE 

Office of Legacy Management, and also had a recent 

request for Hanford as well as Idaho National Lab. 

There's been others, but those were kind of three of 

the bigger ones we've had recently, and of course all 

of the facilities you're discussing today. We've likely 

responded, you know, a while ago to get NIOSH and 

SC&A the material they needed to come up with their 

documents.

Next slide. And document reviews we continue to, 

you know, even -- it was a bit challenging earlier in 

the pandemic because less staff. They were really at 

a skeleton crew in our Office of Classification. So the 

folks at headquarters that reviewed these 

documents, you know, they had a few folks in but 

many folks not, and this is something that they do 

have to do, you know, inside a secure area.

But you know, they do have more folks back in the 

office now. I think those reviews are happening 

pretty quickly at a headquarters level, and I believe 

so at the sites too. I know, you know, it can be more 

of a mixed bag out of the sites, particularly because 

the documents that we see at headquarters are the 

final reports so those tend to be shorter.

The documents the sites are reviewing are the actual 

source documents, so those can be hundreds of 

pages long. So they're a little bit more challenging, 

but I believe most of our sites are keeping pace with 

NIOSH's need, and if that's not the case please let 

me know.

Next, next slide. I talked a little bit about facility 

research earlier. We are preparing and working on a 

Federal Register notice and we're, you know, fairly -

- it's not really frequent, but we do have a few sites 

here and there that we're looking at. There's kind of 

a steady trickle of sites that we end up reviewing for 

coverage, and we do that of course along with DOL 

and NIOSH.
25

Next slide. So our Former Worker Medical Screening 

Program, I'll just put in a plug there. You know, as 

you might imagine because they're bringing in people 

for, you know, live, in-person medical screenings, 

they were down for quite a while at the start of the 

pandemic.

But most of our former worker programs, in fact all 

of them have been screening lately, you know. 

They're really watching the numbers in different 

areas closely and in some areas they have had to halt 

screenings again due to the recent rise in cases. But 

they're following it all closely and the doctors 

associated with the former worker program are very 

cognizant of safety, and for the most part we are still 

doing screenings now.

So if anyone here has folks that might want to take 

advantage of that, it's pretty, it's -- we work hard to 

find a screening location close to someone's house or 

it's very convenient, and it's done by occupational 

medical physicians. So they're very aware of the 

things that people might have come in contact with 

in their work at a DOE site, and we screen and test 

accordingly.

So next slide. This is just the contact information for 

the former worker program, and I think the last slide 

is questions. So if anyone has questions.

Member Ziemer: Greg, this is Paul Ziemer. I have a 

question. Can you hear me okay?

Mr. Lewis: I sure can.

Member Ziemer: Yeah. Well, I've had an ongoing 

interest in the staffing that DOE has in the 

environment, health and safety arena, and I was 

looking this morning on your website. I noticed your 

health and safety group or Office of Health and Safety 

is currently headed by an acting director. I think it's 

Brad Davy, who also is the director of the -- I guess 

it's the Worker Safety. So he's kind of doing a double 

job like.
26

I wonder what the status of the leadership in the 

Office of Health and Safety is? Are they looking for a 

regular person or will they continue the, using an 

acting director?

Mr. Lewis: Well, that's an excellent question and your 

timing is -- I think if this meeting was a couple of 

weeks later, I would have a name for you. 

Member Ziemer: Oh.

Mr. Lewis: What I can tell you is someone has been 

selected, but I don't believe the official 

announcement has been made. So I think at the next 

meeting, I will certainly have information for you and 

that individual may even be able to participate. 

But yes, there is an acting. Brady Davy is acting, and 

he should not be acting for very much longer. I think 

another couple of weeks we will have the new, the 

new director of the Office of Health and Safety.

Member Ziemer: Oh yes. But I wasn't actually looking 

for a name per se. I just wondered what the status 

was and I have some concern as to how it might 

affect your operation to have just an acting director 

in place. So I'm glad to hear that it's moved along.

Mr. Lewis: Yeah, it's absolutely moving along. I'll also 

say Brad Davy has been very supportive and, you

know, actively working with us to communicate 

through upper management, and I think we've been 

in very good hands. But there will be a permanent 

individual in that job very shortly.

Member Ziemer: Thank you very much.

Member Clawson: Hey Greg, this is Brad. I guess you 

heard my question that I asked Grady, I guess, 

especially with Boeing and stuff like that with this 

process that we're going through. Can you kind of 

shed a little light on how this is going to work with 

them?

Mr. Lewis: Well you mean with the process with the 
27

NIOSH modernization?

Member Clawson: Yes, but also too where they don't 

want to be a part of SERT for whatever reason. You 

know, we've had trouble before, you know. 

This Santa Susana has kind of been an interesting 

site to be able to work through because it has its own 

nuances that are problems in my eyes, of 

information-gathering and so forth with Boeing. So I 

was wondering how, how this is going to work with 

this modernization part?

Mr. Lewis: Well so I don't think the NIOSH 

modernization effort is really going to have much of 

an impact on Boeing per se and that, you know, I 

don't know if that's a good thing or a bad thing. We 

have had some challenges getting records out of 

them in a timely manner, and they don't use SERT.

That's more for, you know, we made a good run at 

trying to get them on SERT. It's not a DOE issue that 

we can't get them on SERT. But there are corporate 

firewalls and there are corporate requirements. It 

just wouldn't allow them to, you know, there were 

certain things that they needed to be able to do from 

a firewall/IT perspective that they were not willing or 

able to do to get onto SERT.

So we do have a work-around in place, and 

fortunately they don't, you know, if the number of 

cases that they did was, you know, closer to Y-12 or 

a Nevada Test Site or something like that, I think the 

work-around would be extremely cumbersome. But 

given that they don't do huge numbers of cases, the 

issues, you know, the hold-ups and the timeliness 

issues I really don't think, other than a few times 

early in the pandemic where they had sent 

information and it took us a while to get in and get 

them.

Really the issues aren't related to them not being on 

SERT or, you know, they're not really IT issues. It's 

just a matter of sometimes on their end it takes more 

of a while to pull the records and get them over to 
28

us.

Member Clawson: Okay, thank you.

Chair Anderson: Any other questions?

Anybody on mute who's trying to talk? 

Mr. Lewis: All right. Well thank you, Dr. Anderson.

Mr. Calhoun: Okay, this is Grady, and I'm going to 

stop sharing and let whoever is next take it over.

Chair Anderson: Next is Gen and Oak Ridge National 

Update.

Member Roessler: Henry, I think you're on the wrong 

day.

Member Ziemer: I'm showing Josie Beach as being 

next on the program here.

Chair Anderson: Okay --

(Simultaneous speaking.)

Chair Anderson: Okay. Then we'll go Procedures 

Review. 

Member Beach: Okay, and I think --

Chair Anderson: I got switched. I've got an old --

Procedures Review Finalization

Member Beach: All right. I want to look if Kathy's all 

ready to go. I will say the Subcommittee, there was 

a lot of discussion at the last Board meeting, as you 

all recall. We, Kathy had presented or we had 

presented a new way of working through some of our 

backlog. We hope to have a meeting to discuss some 

of the issues that were discussed during the last 

Board call, but we were unable to meet.

So those are all going to be held in reserve. But Kathy 

very nicely went ahead and moved forward with 

several cases, and if you -- if you have any questions 
29

for me, I'll hold on for a sec. If not, I'm going to turn 

it right over to Kathy. Okay Kathy, it looks like you're 

up. Thank you so much for the hard work that you 

put into this.

Ms. Behling: Can you hear me? 

Member Beach: Yes.

Chair Anderson: Now we got you, yep.

Ms. Behling: You got me, very good. You're welcome 

and let me just -- I think Josie just started out exactly 

the way I was going to. At the last Board meeting, 

we agreed to revisit some procedure reviews that 

were previously presented to the Board but not 

formally closed.

So that's what I hope to do today, and during our last 

presentation, this is the list that I included that those 

procedures that have been discussed by -- with the 

Board. Now today, I'm going to cover most of these. 

There are several that I did not include because after 

pouring through lots and lots of transcripts, I realized 

the OTIB-0052, the PER-0014, PER or OTIB-0020 and 

the other 52 that was discussed, they were 

thoroughly complex and there's still some 

outstanding issues.

I think that we'll probably discuss those separately. 

They're intertwined a little bit also. So we'll probably 

discuss those separately.

Member Beach: Kathy, let me -- stop just for a 

second. I had 52 and 20, and you said also 14; is that 

correct?

Ms. Behling: PER-14, yes.

Member Beach: Okay.

Ms. Behling: Like I said, they're all intertwined to 

some extent. Construction trade workers and 

external co-exposure methodologies and guidance. 

So I think it, it would serve us well to put those all 

together, and maybe do a separate presentation for 
30

those. It seemed to make more sense to me.

So the first, first OTIB that we will go through the 

first guidance document is OTIB-0070, and NIOSH 

uses this procedure to assess internal doses at AWE 

facilities during the residual radioactive periods. The 

OTIB provides guidance on internal dose for 

resuspension of surface contamination, and this was 

initially reviewed by SC&A in August of 2008 and 

presented to the Board on March 12th, 2013.

Now there were a total of 15 findings associated with 

this OTIB, and I did put together a handout for 

everyone because to list all of the findings and the 

details associated with those findings. I thought for 

purposes of this presentation, I tried to summarize 

just the key findings so that we could move through 

these.

However, while I'm walking through these OTIBs and 

procedures, if there is anything that -- any finding 

that I'm not discussing during this presentation or 

something that you want more details on, please stop 

me and I will try to get your answer, your questions 

answered and we can go into more details about very 

specific findings.

Member Beach: And Kathy before you move on, I 

apologize. I want a little bit of a clarification here. Do 

we want to stop after each one of these procedures?

Ms. Behling: Yes.

Member Beach: For questions, and then Rashaun, 

will we go ahead and formally close those out after 

each one? I'm not sure how this --

Dr. Roberts: That would be my recommendation, to 

go one by one.

Chair Anderson: Well let's do them one -- I think they 

should go pretty quickly.

Member Beach: Okay thanks Kathy.

Ms. Behling: Yeah. That's exactly what I intended to 
31

do. Rather than go through them all, let's stop, 

pause. Let's talk about each one and then perhaps 

we can formally close them out at that point.

Member Beach: Okay, because I was thinking back. 

We didn't close out the two that you presented at the 

last meeting formally did we, or am I mistaken?

Ms. Behling: No, we did not.

Member Beach: Okay. That's kind of what I thought, 

so I wanted to make sure that didn't happen moving 

forward.

Ms. Behling: Yes, yeah.

Member Beach: Okay, thank you.

Ms. Behling: I was going to ensure that didn't 

happen.

Member Beach: Yes.

Ms. Behling: Okay. As I said, the OTIB-0070, there 

were a total of 15 findings and several of the findings 

had to do with the resuspension factor and how the 

source term depletion rate was derived. The 

resolution to that finding was NIOSH issued a 

Revision 1 of the OTIB, and introduced appropriate 

information in there to adequately address this 

concern, or these concerns. There were several 

findings.

The second major issue or major OTIB findings were 

associated with an Attachment B, and Attachment B 

of this document was the thorium source term data. 

We questioned the use of the air concentration 

survey data, and NIOSH came back and said that this 

appendix was really never used, and when they 

published Rev 1 it was taken out. It was eliminated 

from Rev 1.

So that pretty much summarizes just the key findings 

associated with OTIB-0070, unless any of the Board 

members want to ask about any specific findings. And 

if not, we'll go on to the Board discussions. 
32

After the presentation on, you know, in March 2013, 

Board members asked two questions, and I have 

gone through again these transcripts and tried to 

paraphrase the best I could the discussion of, that 

was held after the presentation. If there is any 

additional questions, again we'll stop and talk about 

that. 

But the first question had to do with is this default 

resuspension factor appropriate for an outdoor 

setting, and the answer to that is that no. It's really 

only used for indoor activity at facilities where there's 

been post-operational clean-up, that that's been 

performed at that facility. So that seemed to satisfy 

the Board on that question.

And then Question 2, does this default resuspension 

factor, is it appropriate for all the AWE facilities? In 

the OTIB, there is specific instructions for facilities 

that did not have the post-operational clean-up 

performed, that you do -- you do a site by site 

analysis and you don't necessarily just blindly 

assume this default resuspension factor.

And with these responses, the Board had no other 

discussions on the OTIB-0070, and so I think this is 

probably an appropriate time to stop and determine 

if there any additional questions or if we can perhaps 

formally close this document.

Member Beach: Okay, and noting that the 

Subcommittee closed these in the subcommittee.

Ms. Behling: Correct.

Member Beach: And we'll open it up --

Member Ziemer: Basically when we -- this is Paul 

again. Would we be saying that we are closing 15 

findings in this action or --

Member Beach: Yes.

Member Ziemer: --what would this action be here?

Member Beach: It would be that we are closing the 
33

15 findings previously closed by the Subcommittee, 

but opened for discussion because the whole Board 

has to take the action. So yes, it would be all 15.

Member Ziemer: Thank you.

Chair Anderson: Is that okay with everyone?

Member Beach: Yeah, and what kind -- do we need 

to take this to verbal vote Rashaun or?

Dr. Roberts: Yeah. I think you do a motion, you 

know, that the findings are closed or things have 

been resolved with the documents, and then people 

say aye or they voice opposition if they don't, okay?

Member Beach: So comments or concerns, or 

additional questions? 

Then, Rashaun, can I make the motion?

Member Ziemer: Just a clarification note. I believe 

under Robert's Rules, I'm not trying (audio 

interference) on Roberts, but if that were true the 

order, a recommendation from the Subcommittee 

constitutes a motion and it does not require a second.

Member Kotelchuck: Correct.

Member Beach: Okay. So then these all will be under 

that classification, that we agreed they're ready to 

close, and just talking about OTIB-0070 here. 

Rashaun, do you want to take that vote?

Member Ziemer: I think the Chairman has to --

Chair Anderson: Well, okay.

Member Beach: Oh, I'm sorry, yes.

Chair Anderson: The motion is to close out the 15 

issues that have been raised and previously 

discussed and closed by the Committee. So all in 

favor?

Member Beach: And this was discussed at a Board 

meeting also previously.
34

Chair Anderson: Henry?

Member Kotelchuck: May I suggest to expedite things 

that we just have a show of hands for each of them, 

and then at the end of all of them, we actually have 

a formal roll call vote, which we'll vote on all of them 

at once, so that we only need one roll call.

Chair Anderson: Yeah, or what I'll do, I can just ask 

anybody, does anybody object at this time and then 

we'll do the vote at the end, rather than go through 

the show of hands and it's --

Member Kotelchuck: That's fine, good.

Chair Anderson: Yeah. Is that okay Paul as our 

parliamentarian?

Member Ziemer: Yes, that would work.

Chair Anderson: Yeah. So does anyone object?

Member Ziemer: Or you can say without objection it's 

carried.

Chair Anderson: Okay. Without objection, we will 

accept the recommendation by the Subcommittee.

Member Beach: Okay, and understanding that Kathy, 

I know we'll update the BRS with, with all the current 

or the information necessary, correct Kathy?

Ms. Behling: That's correct, when we get access to 

the BRS.

Member Beach: Absolutely, absolutely.

Ms. Behling: Okay. I think we can move on then. 

Thank you. Okay. Let's move on to OCAS-IG-001, 

and this is External Dose Reconstruction 

Implementation Guideline. 

This guideline is general guidance for reconstruction 

of external dose, and to be reemphasized that it's 

just general guidance. SC&A reviewed Rev 1 and Rev 

2, and then we were asked to do a focused review of 
35

Rev 3 to ensure that all of the previous findings were 

addressed. 

And the -- this was presented to the Board again on 

March 12th, 2013 at the Board meeting. There were 

24 total findings, and I've tried to summarize those 

findings in these tables. The first finding had to do 

with issues such as structure and clarity and 

specificity of the guidance, and NIOSH accepted that 

and did make appropriate changes in Rev 1 of the 

Implementation Guide.

We also questioned that there was some 

inappropriate limits of detection values, which was 

corrected in Revision 2. There were some, several 

issues on neutron doses that carried over in the two 

revisions, and then it ultimately in Revision 3 there 

were neutron to proton ratios added for evaluating 

the missed neutron doses.

Again on this slide, there was an under-estimation of 

dose conversion factors that we identified for the 

bone and red bone marrow, and actually SC&A or 

NIOSH introduced into Revision 2 a table that added 

collection factors not only for the bone and the red 

bone marrow, but also the lung and the esophagus, 

so that resolved this particular finding.

Moving on, the appendix -- appendices to the 

Implementation Guide identified dose conversion 

factors for PA, rotational, isotropic and AP 

geometries. It was determined because of the 

positioning of the dosimeter, which also was worn on 

the lapel on the front, that the DCFs were -- all other 

geometries were inappropriate.

And so in order to resolve this, NIOSH initially put out 

separate guidance, which recommended that the 

dose reconstructors use only the AP geometry, and 

that was ultimately introduced into site-specific 

documents and also workbooks. 

There were several, there were some issues and 

findings associated with that angular sensitivity of 

the dosimeters was not accounted for, and so 
36

wording was put into Revision 2 that directs the dose 

reconstructor to site-specific documents. Also issues 

associated with dosimeter uncertainty and the 

selection of uncertainty distribution, and NIOSH 

indicated that site-specific documents and workbooks 

address these concerns.

Moving on, this is -- those are the -- that's a 

summary of the findings that we had. I don't know if 

anyone has additional findings based on the handout 

that I gave you, you can please, you know, we can 

talk about those. But here were the two questions 

that were asked at the end of that presentation.

The first one had to do with does IG-001 assess film 

badging inadequacies, and IG-001 predates all other 

guidance. It was one of the first documents that was 

published. And so film badge limitations are actually 

addressed in site-specific documents.

And the second question was did SC&A consider the 

experience gained through the dose reconstruction

process? Here again when we reviewed this, it was 

very early on in the process. So no, we did not look 

at dose reconstructions as part of this review. It was 

early in the process.

So we can pause here again and ask any questions, 

or we can determine if we want to close out IG-001.

Member Beach: Okay, thanks Kathy. Any questions 

or comments regarding IG-001?

Chair Anderson: And you move to close it out, right?

Member Beach: Yep. Yes we are. Same as before. 

The Subcommittee recommended closing, and we did 

have full Board discussion in 2013.

Chair Anderson: Yeah. So if there are no objections, 

we'll accept the motion by the Subcommittee to close 

out IG-001.

Okay.

Member Beach: Thank you.
37

Ms. Behling: Okay. Then we'll move on to OCAS-TIB0010, Revision 2. This is a Best Estimate for External 

Dose Reconstruction for glovebox workers, and the 

TBD provides a collection factor for best estimate of 

external dose reconstruction to lower torso organs for 

workers who worked in gloveboxes and they wore 

their dosimeters on their lapel.

I'll just mention here because of the questions that 

were asked in the findings, the collection factors were 

determined by calculating 30 gamma flux points on 

the chest and 30 gamma flux points on, covering the 

abdomen. Then there were ratios taken between the 

abdomen flux and the chest flux, and the mean of 

those ratios was used as the correction factor. So 

that's how the correction factor for this best estimate 

was derived.

And SC&A reviewed this document back in June of 

2006, and the Board (audio interference) out this 

TBD. The presentation for TBD-0010 was July 17th, 

2013. 

Okay. There were nine total findings, and key 

findings included again lack of specific information 

regarding the model, the model glovebox data, and 

in Revision 3 of TIB-0010, NIOSH added an Appendix 

B, which provided all the information that we were 

asking for regarding the modeling.

The TIB did not specifically identify the lower torso 

organs, and there was information added in Section 

2 of Rev 3 to resolve that finding. And then there 

were three findings I grouped together here for 

questions about the design of the analysis, 

assumptions of glovebox model and the Attila 

software. 

Actually those findings were put in abeyance back in 

2013, the resolution to those findings were supposed 

to be that the OTIB or the TIB was going to be 

updated to recommend using 95th percentile instead 

of the mean correction factor.

Now while I was preparing this presentation, I went 
38

in and noted that TIB-0010 has been revised. There's 

a Rev 4 out there, but the recommendation best I can 

tell is still saying to use the mean value and not the 

95th percentile value. So this is something after I go 

through the questions that the Board has. Seems to 

me this is something that we may need to hold off on 

approving, but that's obviously your decision.

So let me go through the questions. Okay, several 

questions here. The questions regarding the specific 

design of the glovebox as used in the model. 

NIOSH's response was that the modeling and the 

shielding and those types of things is not that 

important as the geometric considerations for the flex 

measurements that were done on the chest and on 

the abdomen. That was more important than the 

design of the glovebox. That was not how -- that's 

what, how the correction factors were modeled and 

designed.

A second question also about shielding, and if there 

-- if shielding was considered in the model design. 

Again, the response was no, this is a geometric 

correction factor. 

One question was do we take into the account, did 

they take into account the height of the worker, and 

NIOSH responded yes, that they used reference man 

height, but also indicated that the 95th percentile 

value would encompass badges from -- to include the 

lowest possible organ.

Again, another question had to do with was the -- if 

the worker wore a leather apron did that -- was that 

taken into? And again, NIOSH's response was it was 

not important in deriving this correction factor. That's 

more of a question for how we interpret the badge 

location.

And then finally a question was asked, is this used for 

best estimate, dose reconstructions and the answer 

was yes. So that summarizes your questions and as 

I said, the last issue there associated with the in 

abeyance finding, moving to where recommending a 
39

95th percentile value rather than a mean value has 

not been updated in TIB-0010, based on -- based on 

what I could see, and so I'm not sure how the Board 

wants to proceed.

Member Beach: Kathy, I would say we should hear 

from NIOSH on this, and if NIOSH has an answer for 

that, if they could address that now. But I believe we 

should leave this open. I agree with that 

recommendation. I don't know how other 

Subcommittee members feel.

Member Ziemer: This is Paul. I'd like to ask whether 

SC&A has actually reviewed that final revision, the 

one you just --

Member Beach: Yeah. She said she just did, yeah.

Member Ziemer: Oh, she did (audio interference) for 

this. But was there an official review of it?

Ms. Behling: Not of Rev 4. The last -- no we did not 

review Revision 4. I happened to look at Revision 4 

that I could report back as to whether this in 

abeyance finding was (audio interference), but it was 

not.

Chair Anderson: When did Rev 4 come out?

Ms. Behling: Let me look. I don't have that date in 

front of me. Let me -- just one second.

Member Ziemer: While she's looking at that, again 

this is Ziemer. In any case, we probably should keep 

that in abeyance so SC&A gets a final look at it.

Ms. Behling: Yes.

Member Ziemer: And at the organization.

Mr. Taulbee: This is Tim.

Member Beach: Go ahead Tim.

Mr. Taulbee: If I could go ahead and respond to this. 

We have not revised TIB-0010 yet, and the reason 
40

for this at this time has been that we are going 

through the process of implementing new dose 

conversion factors through ICRP-0116. 

And so some of, you know like which ones are, you 

know, considered surrogate or not surrogate, but 

which ones are in the lower abdomen and all of that 

is not really changing. But how we do the dose 

conversion factors is going to change, and it's --

we're basically rolling in TIB-0010 into that 

methodology, so it will really be organ-specific 

geometry correction factors instead of the large area 

that we had done before that resulted in that 95th 

percentile.

So the methodology is changing. We're not quite 

there yet. We're still doing some of that modeling, 

but we do expect to have it done within the next six 

months type of time frame. So we're not really --

we've held off on updating TIB-0010 for that reason, 

because when we get down to it we're going to be 

doing a very, very, very large PER. 

Basically all of the claims that we will have to redo 

that were non-comped or at least look at because of 

the changes to the dose conversion factors. We're 

going from 17 dose conversion, organ dose 

conversion factors, now I believe it's to 32 for both 

male and female. So there will be very large 

differences from that standpoint.

So this is why we've held off on updating TIB-0010. 

And frankly from my standpoint, I was surprised to 

see it on the agenda for this discussion. But --

Member Beach: Yeah. So are you saying Tim that it's 

going to go, you're going to have a 5, TIB Revision 

5? So 4 is --

Mr. Taulbee: Absolutely, yes.

Member Beach: Okay, all right. 

(Simultaneous speaking.)
41

Mr. Buchanan: Revision 4 was November 2011.

Ms. Behling: That's what I was going to say, yeah. 

Rev 4 was 2011.

Member Beach: 2011. Okay. So let's, as Paul 

suggested, put this in abeyance and we'll just hold 

off on this, if everybody's in agreement.

Member Ziemer: Or is it the whole thing or just --

Member Beach: The whole, the OCUS-OTIB-0010, 

yeah. We won't take action on this one.

Mr. Taulbee: I would expect that once we release Rev 

5, that that's the version that SC&A should review at 

that point, and see if these are satisfied, all of them 

are satisfied in the new revision from that standpoint, 

because the methodology is going to change quite 

significantly.

Member Beach: Okay.

Member Ziemer: Wait just a second. Can you back 

up a couple of slides? Were there some other -- were 

there some other parts of the old Tim that could just 

be closed, I mean just to get them off the books? Or 

is the whole thing?

Ms. Behling: Yeah. What we're trying to do here is to 

close out I think, although I will say the BRS does 

allow us to go in and close out finding by finding. So 

if you only want to keep open Findings 5, 6 and 8, we 

can do that also. But the BRS allows us to do that, 

going one by one and --

Member Ziemer: Well, I was just thinking Josie, 

simply for the record since we don't have the revision 

(audio interference), is there any reason not to close 

out the ones that could be closed anyway?

Member Beach: No, no. I agree with that also. So 

leaving 5, 6 and 8 open.

Member Ziemer: Leaving 5, 6 and 8 in abeyance and 

they may disappear anyway. But get the other ones 
42

off the books.

Member Beach: Sure, I agree with that.

Ms. Behling: Okay, okay. Yes, we can do that. 

Member Beach: Any other objection to that or any 

objection to that?

Chair Anderson: We'll accept that, yep. Good.

Member Valerio: I have a question. So what's going 

to stay in abeyance is Findings 5, 6 and 8; is that 

correct?

Member Beach: Yes.

Member Valerio: All right. I just needed to clarify. 

Thank you.

Chair Anderson: Okay. OTIB-0023.

Ms. Behling: Okay, and can I move on to OTIB-0023? 

Yes.

Member Beach: Yes.

Ms. Behling: Okay. OTIB-0023 provides guidance for 

missed neutron doses based on dosimeter records 

and whether it's appropriate to assign this dose 

during the typical N times LOD over 2 method, or an 

alternative method. It was reviewed by SC&A in June 

2006 and presented to the Board previously in July 

of 2013.

There were eight total findings, and several findings 

had to do with the clarity and some inconsistent 

terminology and inconsistency between OTIB-0023 

and IG-001. And those inconsistencies and clarity 

issues were addressed in Rev 1 of OTIB-0023, when 

Rev 1 was issued. 

Our second finding has to do with the detail of 

information that was available, and initial guidance 

listed -- in the initial OTIB-0023, the guidance listed 

two conditions where missed neutron doses should 
43

not be assigned if both those conditions were met. 

Condition 1 states that if the N times L over -- L over 

D divided by 2 is greater than 75 percent of the 

proton dose and that proton dose includes recorded 

and missed dose, as well as Condition 2, then missed 

dose -- neutron dose would not be assigned. That 

was questioned while we were reviewing this 

document, and as a result of that in Revision 1 NIOSH 

eliminated Condition 1. So that resolved this finding.

And reconstruction of missed neutron dose is 

unrealistic and the neutron to proton assumption of 

75 percent of the proton dose was not claimantfavorable. That was another set of findings and again, 

with the elimination of Condition 1, this finding was 

resolved.

So that's a summary of our key findings, and as a 

result of the presentation, the Board did not have any 

questions associated with the review of OTIB-0023. 

Member Beach: Okay.

Chair Anderson: So the committee, so the committee 

moved to close this?

Ms. Behling: There were no questions, but there was 

no formal closure at that meeting.

Member Beach: At the full Board meeting; correct?

Ms. Behling: Correct.

Chair Anderson: But your committee did vote to close 

it, is that right?

Member Beach: Correct.

Chair Anderson: So we can adopt -- the full Board 

here can adopt your motion to close out OTIBs-0023 

review?

Member Beach: Correct.

Chair Anderson: If there are no objections, we will do 
44

so. We'll close it.

Okay. We're getting caught up on a lot of these.

Ms. Behling: Yes. I was assuming maybe there would 

be questions just based on the details that I had 

provided and the handout, and I know it was a little 

tedious probably going through the handout and I 

apologize. But I did want to make all the Board 

members aware of all of the specific findings and how 

they were resolved.

Member Beach: Yeah, and Kathy the handout was not 

tedious at all. It was exceptional so --

Chair Anderson: No.

Ms. Behling: Thank you, great.

Member Kotelchuck: Right, agreed. Yeah Dave, 

agreed. It was very helpful, which is why I can go 

over the slides that you presented, because I have 

seen the handout. So thank you.

Ms. Behling: Okay, great, thank you. Okay. I'll move 

on to OTIB-0010 now, and OTIB-0010 is the standard 

complex-wide correction factor for over-estimating 

external dose measure using film badges. This 

assesses the degree of standardization of film badges 

and develops a method for assigning and overestimating dose.

This was reviewed by SC&A in January of 2005 and 

presented to the Board in October of 2013. There 

were ten total findings and the key findings. First of 

all, there was guidance -- there was a lack of 

guidance on assessing missed or zero dosimeter data 

and uncertainties. That was corrected by adding a 

Table 2-1 to Rev 01. 

Also, there was no guidance on the correction factor 

when the reported dose is greater than zero but less 

than LOD, and NIOSH in Rev 1 specified that the LOD 

value of 40 millirems should be used in those cases. 

Also, guidance between OTIB-0010 and PROC-006 
45

was inconsistent, and PROC-006 was revised and the 

inconsistency was corrected in that revision.

Lastly, the correction factor of 2 and the LOD value 

of 40 millirem is not excessively conservative was our 

finding, and NIOSH's response was when you apply 

this correction factor to all reported doses and missed 

doses respectively, it's sufficiently conservative and 

that was agreed upon by the Subcommittee. 

So for Board questions, the Board members asked 

whether and why NIOSH was still using an overestimating approach, because I think it was the ten 

year review that indicated NIOSH should not be 

relying on this over-estimating approach as much as 

they had in the past. 

It was stated during that meeting that they rarely 

used this. However, just due to time and expense 

associated with doing a more best estimate type of 

case in some instances, the over-estimating 

approach is used occasionally. So that satisfied that 

question.

Also a question was asked, is the 40 millirem LOD 

value really claimant-favorable, and again NIOSH 

said that they are using that LOD value typically use 

LOD over 2 for missed doses and they're using it, the 

LOD value not the LOD over 2, and also maximizing 

the amount of zeros. I'll go into that in the last 

question here.

There was asked in Finding 9, what does that 

standard correction factor of 2 correct for? The 

answer was it corrects for the film badge uncertainty 

for uncertainties. Lastly, there was a question on how 

a missed dose compared to records with zeros, less 

than detectable and blank cycle's handled. And again, 

NIOSH responded by saying they really maximize 

missed doses.

If they were to have summary data and the -- they 

would make assumptions about data. That dose all 

occurred in one badge cycle, and they would treat the 

rest of the year, the missed doses for calculating all 
46

the other cycles, which is a claimant-favorable 

assumption.

So that seemed to satisfy the Board and answer their 

questions, and if we -- if you would like to vote on 

closing this OTIB.

Chair Anderson: Any, are there any objections to 

closing OTIB-0010's review? No? If there are no 

objections, then we will accept the recommendation 

by the Work Group, the Subcommittee on Procedures 

to close out the review of OTIB-0010.

Ms. Behling: Okay, thank you. Okay, now we'll move 

on to PER. This is PER-0012, and this PER is the 

evaluation of highly insoluble plutonium, which is our 

type Super S plutonium. OTIB-0049 is the OTIB that 

provides the correction factor for exposure to Type 

SS or Type Super S of plutonium, and which 

increases the internal dose to the group by about a 

factor of 4.

The issuance of OTIB-0049 prompted PER-0012. The 

PER, SC&A reviewed the PER in March of 2010, and 

then we have a Subtask 4 protocol in our procedure 

that says we also recommend that we look at, we 

review some of the reworked cases that were 

impacted by the issuance of PER-0012, and that was 

done in July of 2012. The review of both the PER and 

the cases were presented to the Board in October of 

2013. 

PERs are a little bit different. We have subtasks 

associated with those, so I'll go through these 

subtasks. Our first subtask assesses the 

circumstances that necessitated the PER, and as I 

previously said, it was the identification, the 

existence of Type Super S plutonium and issuance of 

OTIB-0049 to correct for that slowly retained or that 

highly retained plutonium.

And that, SC&A reviewed OTIB-0049. It also 

reviewed OCAS-PEP-0012 and PER-012, and I'll just 

make mention here that in the early days of the 

program evaluation reviews, they had a program 
47

evaluation plan. And that was eliminated somewhere 

around 2008 and everything is included now in the 

PER. 

Subtask 2 is the assessment of specific methods for 

corrective action. If SC&A had not reviewed OTIB0049 prior to the issuance of PER-0012, that's where 

under Subtask 2 we would do that. However, we did 

-- there was a critical review of OTIB-0049 done back 

in 2007. So there were on findings associated with 

Subtask 2.

Subtask 3, that's the review of NIOSH's assessment 

of how many DRs need to be reworked, and in this 

case NIOSH looked at DRs that were completed on or 

before February 2007, and that was the issuance of 

OTIB-0049. That involved facilities where there was 

exposure to Type Super S plutonium and PoCs that 

were less than 50 percent.

SC&A agrees that they've captured all of the cases 

that they need to rework and we had no findings. 

Under Subtask 4, SC&A recommends a number of 

cases that should be reviewed from the population of 

reworked cases. For this particular OTIB or PER, 

OTIB-0049 has four target tissues and up to four 

means of monitoring, monitoring methods that could 

be looked at.

And so we recommended to the Board to select ten 

cases, so that we could cover all of the potential 

options and just because -- due to the pool of data or 

cases that were out there, the Board selected nine 

cases that met the criteria that we suggested.

And then finally under our Subtask 4, we actually go 

in and we reviewed the nine cases that were selected 

by the Board. But that is, that audit is -- it is a 

focused review that looks at only the issues that were 

addressed in PER-012. So namely we assessed 

whether the internal doses associated with the Type 

Super S plutonium, were performed accurately and 

in accordance with OTIB-0049.
48

And for all nine cases, we had no findings. We 

concurred with the approach and we found that the 

methodology was consistent with OTIB-0049. So we 

go on to questions, and Board members had no 

questions at the end of that presentation. 

Chair Anderson: That was a lot of work.

Member Beach: Thank you Kathy, yes. Chair 

Anderson: A great deal of work, and that's why there 

were no questions. Well done. Oh my. So and I 

assume the committee, I see they move to close this 

--

Member Beach: Correct.

Chair Anderson: --PER-012 out, and so if there are 

no objections, the full Board will accept the 

committee's, Subcommittee's recommendation to 

close out PER-012. 

Ms. Behling: Okay. Hearing no objections, I'll move 

on. Okay. This is an overarching issue. It was named 

Overarching No. 9, and it has to do with skin 

exposure. What this overarching issue addresses was 

SC&A's concern about modeling of fine and large 

particle deposition on the skin, hot particles.

It was presented to the Board in April of 2018. I view 

the overarching issues we identify them as concerns 

as opposed to findings, and in Concern 1, NIOSH 

derived a dose of 16 millirem per year to the bare 

skin. SC&A felt that that was based on unsupported 

and unrealistic assumptions, and those assumptions 

included that the skin contamination persisted for 

only eight hours, and that at the end of eight hours 

100 percent of the contamination would be removed 

by a shower, and that only bare skin was subject to 

the contamination exposure.

The resolution to this concern, NIOSH discussed its 

approach of addressing fine particles to the 

satisfaction of SC&A. However, there were still some 

lingering questions about whether the uranium could 

be removed with these from skin and clothing. So 
49

subsequently NIOSH presented findings of the 

research that they did on the quantitative and 

qualitative removal of uranium with soap and water. 

That resolved our concerns with, our first concern.

Concern No. 2, how does IREP use the dose to 

calculate the PoC, given that hot particle is a very 

small area on the skin? How does that get interpreted 

into a whole body dose? NIOSH explained that, 

explained that relationship and also indicated that 

there is specific guidance in OTIB-0017 for nonuniform skin exposure.

They went on to say that they consulted with SENES 

just to confirm that the guidance and the correction 

factors are, I should say the log-normal distributions 

that were introduced into OTIB-0017, which is 

designed to cover this topic, that they weren't, that 

that guidance was claimant-favorable.

Okay, and Concern 3 is same basic question, but 

rather than small particles we asked the same 

question about large uranium flakes, and again same 

resolution, that the information was provided into 

protocols described in OTIB-0017.

Okay, and now here are four questions after that 

presentation. The first question was do we know that 

the workers do take a daily shower, you know, after 

their shift, their work shifts? NIOSH said that they 

didn't really look into that aspect, but they do know

that a lot of the facilities, especially at the -- where 

they did rolling operations, that that was --

showering was required. So that question wasn't fully 

answered.

The second question, how is the averaging of small 

versus large particle versus whole body being 

addressed by IREP? NIOSH again pointed to OTIB0017, where there's been a log-normal distribution to 

account for various scenarios, small particles and 

larger particles that could have contaminated the 

skin.

And another question, the Board members say that 
50

okay, we know that there's skin contamination on 

bare skin and -- but we don't know where the 

contamination occurred. Now we're taking a bare skin 

estimate and averaging it over the entire body. Is 

that claimant-favorable?

NIOSH's response was that to account for the 

unknown nature of where the contamination 

occurred, there were various log-normal distributions 

developed for different size particles. 

As a result, the Board members felt that they didn't 

have all their questions answered satisfactorily, and 

so they postponed action on the review of the 

Overarching 9 issues, and they did ask NIOSH to 

come back at a future meeting and provide more 

information.

So at the next full Board meeting in August of 2018, 

NIOSH made a presentation and that presentation 

indicated that okay, we know that there's a hot 

particle. We're going to assume there is a hot particle 

deposit on a worker's skin that was never measured 

and now you have a skin contamination.

When you look at that data, it falls into the realm of 

a binomial distribution. Since IREP does not have a 

binomial distribution, the SENES had developed a 

claimant-favorable log-normal approximation of that 

distribution, which was incorporated into OTIB-0017 

as previously discussed in the concerns.

They didn't, NIOSH did mention that SENES is in the 

process of producing a binomial distribution test 

model for IREP, to determine if the log-normal 

distributions are truly claimant-favorable. So the 

proposed resolution was that NIOSH is -- was in the 

process of revising OTIB-0017, and the Designated 

Federal Official joined that meeting, did ask SC&A to 

do a focused review of the OTIB when it was revised.

However, as I was going through this presentation, 

the OTIB-0017 has not been revised from Rev 1 since 

2005. So there you have it, and I don't know how you 

would like to proceed here. But all of -- all of the 
51

concerns for the overarching issues really hinged on 

the revision to OTIB-0017, which has not happened 

yet.

Member Beach: So I guess we need to hear from 

NIOSH, if NIOSH has an idea of when OTIB-0017 is 

in the review process.

Mr. Taulbee: Yes, we do. We have been working on 

this for quite a while, and it has taken us much longer 

than what we anticipated to get this document 

revised. It is currently nearing the completion and it's 

in the internal review and comment resolution phase 

with -- between us and ORAU, and the expected 

release of this is December of this year.

Member Beach: Okay. So thank for that Tim, and I 

would recommend that we again put this into 

abeyance until OTIB-0017 is reviewed. Is that 

agreeable with the Subcommittee?

Member Ziemer: I have one question on that. 

Abeyance usually means we've resolved the issues 

and we're just waiting for the new document to come 

out. 

Member Beach: Oh okay.

Member Ziemer: Are the issues really resolved on 

this, or is it really in process? It's not clear to me on 

that one Josie. What's your thought on that?

Chair Anderson: It seems to be more of a deferred.

Member Beach: Yeah. I don't think that -- I don't 

think they've been answered. Kathy, would you agree 

with that?

Ms. Behling: Yes, I would.

Member Beach: Okay. So then it wouldn't be in 

abeyance. It would be --

Member Ziemer: It would still be in process then, 

right?
52

(Simultaneous speaking.)

Ms. Behling: In progress.

Member Beach: Okay, okay.

Ms. Behling: All right, we'll do that.

Chair Anderson: So we don't need a motion on it?

Member Ziemer: I don't think we do. I think --

(Simultaneous speaking.)

Member Ziemer: This becomes just a piece of 

information, right?

Chair Anderson: Yeah. Well of this linkage between 

the various OTIBs is challenging, so we need to crack 

that. When 17 comes out, we have to see what 

impact it has on 9. 

Member Ziemer: Well I think conceptually this is a 

really tough one. I'm interested to see how, what 

NIOSH recommends on it because it's -- there's some 

issues that I think will arise regardless of how we 

attempt this. But anyway, I'm looking forward to the 

response.

Chair Anderson: Just a question to NIOSH. Do the 

claims have site-specific data on where the cancer 

occurred, skin cancer?

Mr. Taulbee: In many cases we do. We get that from 

the Department of Labor with the medical records of 

where the skin cancer occurred. At some sites, we 

actually get information on skin contaminations, 

where the contamination occurred. But not always. 

In AWE sites, it's actually very difficult and we 

generally don't have that. But at some of the larger 

sites, we do have that information.

Chair Anderson: Okay, thank you.

Member Schofield: Hey Tim, this is Phil. I've got a 

quick question. When they're planning on using this 
53

for whoever's doing the dose reconstruction, which 

and how are they going to determine which lognormal distribution to use? 

Mr. Taulbee: Well that's in the guidance of the 

document that's being revised here. So I guess I 

would like to defer the answer to your question until 

you see the new guidance that's coming out, and 

address it at that point. Is that okay sir?

Member Ziemer: That's fine, thank you.

Chair Anderson: Okay. Moving on.

Ms. Behling: Okay. This is our last one, and I don't 

know how relevant this is going to be at this point in 

time, but this is actually our review of OTIB-0017. I 

will go through it, just so that you have an 

understanding of what our -- what the concerns were 

and what your questions were, because it goes 

beyond what was introduced in the overarching 

issue.

Again, the OTIB-0017 is our shallow dose OTIB 

interpretation of, you know, dosimetry data for 

assigning shallow doses and it provides guidance for 

assigning shallow doses to the skin, testes and breast 

for non-penetrating radiation. 

SC&A reviewed this way back in June 2006 and it was 

presented to the Board in April of 2018. There were 

a total of 15 findings and several findings had to do 

with the clothing-specific attenuation factors should 

there be different various clothing-specific 

attenuation factors used.

The response was that the OTIB allows dose 

reconstructors to choose on the clothing attenuation 

factor based on whether it's a minimizing, 

maximizing or best estimate case. Also there were 

several findings. Again, this is regarding the direct 

deposition of hot particles on the worker's skin that 

are not detected, and this is what prompted the 

Overarching 9 that we just discussed. 
54

There was questions as to whether four millimeter 

clothing thickness is, is not claimant-favorable, and 

NIOSH responded that four millimeters assumptions 

for pants and undergarments and not lab coats. The 

correction factor cited in Attachment A are not 

claimant-favorable when the source is near the 

testes, and the film badge would not measure them 

as the film badges on the lapel.

NIOSH responded that based on the quality 

assurance and training and a lot of guidance 

documents and site-specific documents, that it is 

(audio interference) correctly by the dose 

reconstruction, dose reconstructors.

We also mentioned that the OTIB is not claimantfavorable in instances of unknown factors, and 

NIOSH responded that it is claimant-favorable due to 

its recommendations for DCFs, LOD, attenuation and 

radiation type and energy, which should cover 

unknown factors.

Okay. There was a Finding 12. Again that -- oh this 

is questions, questions from the Board. The question 

was with regard to Finding 12 where -- and Finding 

12 had to do with there was an agreement that there 

would be an update on the logical order of the general 

approach section. The Board member commented 

that everyone's agreed on this; however, the 

document is still in abeyance or these issues are still 

in abeyance because the document hasn't been 

revised since 2007. 

There was a question as to when they thought the 

OTIB would be revised. At the time, NIOSH thought 

they were going to have that revision done fairly 

quickly. 

The Board also asked about Finding 7 and the four 

millimeter assumptions for the clothing. There was a 

discussion on undergarments are designed to 

breathe and cannot be considered impermeable, and 

there was a question as to whether that assumption 

is implicit in the four millimeters.
55

NIOSH responded that they did not know the answer 

to that question, and that additional research would 

be necessary. So as with the OTIB or the Overarching 

9, the Board decided to postpone action on OTIB0017, and asked for clarification at a future meeting. 

Again, NIOSH did present information on Finding 7 at 

the August 2018 meeting, and NIOSH went in and 

assessed, reassessed attenuation of three different 

set of clothing. Using the mean value of the new 

measurements, NIOSH got similar results for 

strontium-90 and yttrium-91.

However, they determined that for the rhodium and 

ruthenium, the correction factor differed by a little 

more than a factor of 2, .5 versus .2. They said that 

this would all be resolved and the resolution would 

be a revision to OTIB-0017. As we previously stated, 

OTIB-0017 has not been resolved yet.

There was a follow-up question by a Board member, 

who said that their initial question really did not have 

to do with the thickness of the garment but 

permeability of the undergarment. NIOSH responded 

that again, they would take this up and introduce 

appropriate terminology and discussion in the revised 

OTIB-0017. 

And that, as we just discussed, OTIB-0017 is still in 

the process of being revised.

Member Beach: Okay, and we should see that in 

December; correct Tim?

Mr. Taulbee: That is the current schedule according 

to our project plan.

Member Beach: Okay.

Chair Anderson: Tim, I mean and just in this set here 

there were quite a number of issues that were 

pointed to would be addressed in OTIB-0017. Tim, do 

you have a listing of those for tracking so we don't 

end up with sending this back to the committee? 

There's so many of these that are going to be handled 

on all the different issues, that the likelihood of you 
56

missing one if you don't have a good tracking system 

is pretty, pretty high.

Mr. Taulbee: Well I think SC&A has done a very good 

job of listing them for us here.

Chair Anderson: Yeah.

Mr. Taulbee: And we will make sure that they are all 

addressed, that we haven't missed any. This is part 

of what has taken so long in getting this revised, is 

going through and doing the research and resolving 

many of these issues.

Chair Anderson: 2005 is a long time ago, right?

Mr. Taulbee: Yes, it is.

Member Beach: Yeah, and Henry this will still go back 

to the Subcommittee. We'll have to review. SC&A, 

we'll have to assign SC&A to review and then make 

sure everything was captured so --

Chair Anderson: Yeah. Since this is the last one, I 

mean now it's continuing. But what is the next steps 

for your Subcommittee?

Member Beach: Well, we had hoped to have a 

Subcommittee meeting so we could go through 

these. I was going to pose that question myself. So 

should we go ahead and formally close out the ones, 

and vote on the ones that we discussed here, and 

then move on to talk about what our next steps are? 

Would that be okay?

Chair Anderson: I would think so, yeah.

Member Beach: Do you want to list them Andy, or do 

I need to?

Chair Anderson: If you can do it, I think and yeah. 

Well or I guess since you, the committee and we went 

through them kind of one at a time, approved or 

closed them out, I think we can just simply say we -

- if there aren't any further objections, we can accept 

your recommendations for the set of reviews that you 
57

did, with the exception of those that were held open.

Member Beach: Okay. So we held open -- at the 

beginning Kathy talked about 052, 014 and 20 which 

she did not present on, and we held -- we held open 

OCAS-TIB-0010 and NIOSH Overarching 009. 17 

wasn't on the list, but it is -- it is in our grand scheme 

of things. 

So closing out OTIB-0070, IG-001. Closing out on 

TIB-0010 1, 2, 3, 4, 7 and 9, leaving open 5, 6 and 

8, and then closing OTIB-0023, OTIB-0010, PER-012. 

I think that captured all of them.

Chair Anderson: Good. Any disagreement with that?

Member Ziemer: A question before you take your 

final vote. On this last one, I didn't hear anything on 

Finding 1 and 6. 

Member Beach: Are you talking about on 17?

Member Ziemer: Yeah. We talked about 2 through 5 

and 7 through whatever it was. What's the status of 

1 and 6? I didn't have a chance to look that up.

Member Beach: So the Subcommittee closed those 

two items --

Member Ziemer: That's what I was wondering. Those 

are already closed?

Member Beach: Kathy -- yeah. Kathy did we --

(Simultaneous speaking.)

Member Ziemer: If they are, we need to --

Member Beach: Are those items that we can close 

here or would we rather wait until we review the final 

procedure?

Ms. Behling: I'm sorry. Are you asking me this 

question? 

Member Beach: Yeah. So as Paul brought up, 

Questions 1 and 2. On your list, we actually closed 
58

those within the Subcommittee, 1, 2, 3. But I don't 

know if the Board (audio interference).

Member Ziemer: The slides showing 2 through 5 and 

then 7 through, let's see. Anyway.

Member Beach: Yeah. Well, I'm looking at the main 

body and that shows all of them so --

Member Ziemer: Oh okay.

Member Beach: Kathy, are you --

Ms. Behling: Yes. I just summarized some findings. I 

should have put down 1 through 5, because I didn't 

specifically call out Finding 1. It was sort of 

embedded in some of the other findings here.

Member Beach: Yeah.

Ms. Behling: But this all should be included in my 

summary.

Member Ziemer: So that would be --

(Simultaneous speaking.)

Member Beach: Okay. I would recommend that we 

leave the whole thing open because of the complexity 

of it.

Chair Anderson: That seems reasonable, yeah.

Member Kotelchuck: Just a -- Kathy?

Member Beach: Dave?

Chair Anderson: Go ahead Dave.

Member Kotelchuck: Kathy, just a mini-typo, but it's 

worth mentioning.

Ms. Behling: Okay.

Member Kotelchuck: On Slide 39, you want the 

underpants design to breathe not to breath. So I just 

thought --
59

Member Beach: Good catch. Thank you for that 

correction.

Ms. Behling: Yes.

Member Kotelchuck: I don't want any breath on any.

Chair Anderson: Spellcheck won't catch that.

(Simultaneous speaking.)

Member Kotelchuck: I know it won't because they're 

both good English, at least for meaning however.

Ms. Behling: At least it induced a little bit of laughter.

Member Beach: Yes.

Member Kotelchuck: Yeah, exactly --

(Simultaneous speaking.)

Member Beach: Okay. I think we can take a vote 

Andy, if everybody's ready, unless there's some 

objections.

Chair Anderson: No. Let's take a vote. Rashaun, do 

you want to go through individual votes to accept or 

do we want to just use the other of hearing no 

objections?

Dr. Roberts: Well in my reading of transcripts of how 

this has been done in the past, I think it's been the, 

you know, verbal agreement, you know. All in 

agreement aye; all opposed. So that's how I've read 

it.

Chair Anderson: Okay.

Member Kotelchuck: All right.

Chair Anderson: So --

Member Clawson: But that was also when we were 

all sitting at the (audio interference) there.

Chair Anderson: Yeah. I mean it's hard to -- I mean 
60

it's easier to say does anybody object, and if there 

are no objections, then we can say it was 

unanimously accepted by the Board.

Member Kotelchuck: Yeah.

Member Beach: Correct.

Chair Anderson: Rather than a cacophony of voices 

saying "aye," drowning out a one nay. So all in favor 

or all opposed say --

(Chorus of aye.)

Chair Anderson: Okay. So there's no opposed. So the 

Board adopts the recommendation as you stated to 

close out and keep others open.

Member Beach: Okay, thank you, and so your other 

question was moving forward, and I would 

recommend -- I don't believe we can have a 

Subcommittee meeting until we have access to the 

web or to the O drive; is that correct?

Ms. Behling: I don't know who you're expecting to --

Member Beach: I expect Rashaun. I guess I'm asking 

Rashaun.

Ms. Behling: If I could just interject something here.

Member Beach: Yes, go ahead.

Ms. Behling: What I can tell you is that there was a 

lot of tasking that was done during the previous 

Procedures meeting, and SC&A has completed a 

number of those. We were able to get the data that 

we needed so that we actually could go through some 

of the OTIBs and various things to do our view.

So we are in a position now, we are ready to make 

those presentations to the Board if that is something 

that we can do without having access to information 

on -- we won't have access to the BRS, but we could 

still make the presentation to the Subcommittee.
61

Member Beach: Subcommittee. I was going to ask 

you that, because I realize I've been seeing several 

of them drop into my inbox. So a couple of things 

moving forward then. Rashaun, if you could send out 

a notification for a Subcommittee meeting. I think the 

Subcommittee can talk about moving forward.

One thing I would suggest Kathy is if you can update 

that the list that you sent us that had all the 

documents that need to be closed out officially, if you 

could just keep that updated, kind of make it a living, 

breathing document as we move forward through 

these.

Ms. Behling: Okay, yes.

Member Beach: If that makes sense to other 

Subcommittee members.

Chair Anderson: And how are you selecting which 

ones to review next?

Member Beach: I kind of think that would be -- we 

should talk about that in the Subcommittee.

Chair Anderson: Okay. Well as I'm just asking 

because going from there to then tasking to getting 

reports, I think it's good to get this whole bunch here 

voted away. 

I think that, you know it's -- I just don't have a good 

sense of what do you have on your plate. What are 

the ones that seem to be most pressing or are you 

just going through them in numerical order?

Member Beach: Well this lists -- Kathy, I don't think 

we approved where to start or other than the first 

two that we did at the last Board meeting. But I 

believe Kathy you just chose these ones? Was there 

a method to your choosing?

Ms. Behling: I presented these today because these, 

except for OTIB-0052, PER-0014 and OTIB-0020, 

just because these were the ones that had previously 

been presented to the Board. So I felt that we could 
62

start with these.

Now if we, as we move forward, as I said I do think 

there needs to be a separate presentation on the 

OTIB-0052. That's construction trade workers. PER0014, which is the PER, so associated with the 

construction trade workers, and OTIB-0020, which is 

(audio interference) co-exposure.

That should be a separate presentation from my 

perspective, and then when we move forward, I 

believe you all adopted the matrix approach. And so 

I will go into that 31 list of procedures that have been 

finalized by the Subcommittee, and put together the 

matrix and submit that to the Board, and then make 

presentations on that.

That would be a new presentation, new presentation 

material, things that you have not seen or talked 

about before.

Member Beach: Okay. So is it your recommendation 

then to do the three you mentioned next, the 52, 14 

and 20 as a -- those three in the next presentation 

grouping?

Ms. Behling: Yes, yes.

Member Beach: So we could look forward to that at 

our April meeting?

Ms. Behling: Or December.

Member Beach: Or excuse me December. I'm 

forgetting December, yeah. So just at the December 

meeting, correct. Thank you.

Ms. Behling: Yes.

(Simultaneous speaking.)

Chair Anderson: Have these been looked at by your 

committee, or are they going to go to present to the 

whole Board?

Ms. Behling: You know, as I went through the 
63

transcripts, these were the most difficult because it 

seemed to me that although it was discussed at the 

Subcommittee meetings back at that time, 

sometimes the BRS wasn't updated as completely 

and with as much detail.

And it seemed to me that there were some issues 

that weren't completely resolved at the 

Subcommittee level. So during the next 

Subcommittee meeting, which I assume will be 

before the December Board meeting, I think we need 

to have a discussion on that. 

If we don't feel we're prepared to present this to the 

full Board, we'll just go into other procedures that 

have been closed out by the Subcommittee and we'll 

start working on the matrix for those. Does that 

sound reasonable?

Member Beach: In my mind, yes it does.

Chair Anderson: Yeah, yeah, yeah. And the other 

would be to ask, as we've heard NIOSH is working at 

17, 017, are there other OTIBs that are under review 

by NIOSH? I don't think it makes too much sense for 

the committee and for SC&A to do a lot of work on 

one that is going to be shortly revised and may 

address the issues.

Seems to me it's taken a long time to do some of 

these, and I think the more we can try to streamline 

it and make it as effective as possible, it's important.

Member Beach: Correct. I do like this approach 

though, that these are the ones that had come before 

the Board, and yes there's a couple of them we 

couldn't close out. But it brings the attention back to 

them and so we can move forward with them.

Chair Anderson: Yes. No, I mean we got to get caught 

up and then it's moving forward from there. 

Member Beach: Yes.

Chair Anderson: What's the process of the selection? 
64

I mean there's a lot of these that haven't been looked 

at.

Member Beach: Correct, and some less complicated. 

I'm sure that will --

(Simultaneous speaking.)

Chair Anderson: Yes, right, correct.

Member Beach: --go through quickly.

Chair Anderson: Okay. Are there any other questions 

or issues Josie you want to raise, or others?

Member Beach: Just to reinstate to set out, because 

I know we need a couple of months in advance to 

maybe get the dates moving forward as soon as 

possible Rashaun.

Dr. Roberts: Yes, and that's what I -- so it sounds 

like we want to move forward with the Subcommittee 

meeting prior to the December meeting, which 

doesn't give us a lot of time, you know, given that we 

--

Member Beach: Yes, and with as much leeway before 

that meeting as possible.

Dr. Roberts: Right, yeah. So we're going to have to 

relatively quickly get on organizing for that meeting.

Chair Anderson: Get the agenda for it?

Dr. Roberts: Yes, exactly, and get it scheduled.

Chair Anderson: Pick a date and then see what you 

need.

Dr. Roberts: Yeah. It can be done, but it's going to 

be tight.

Chair Anderson: Yeah. Okay. I think we've -- we've 

just about reached break time, so unless there's 

other issues people want to raise on these or other 

questions? 
65

Let's see. We're a little bit behind so --

Dr. Roberts: How much time do you want to give, 

Andy?

Chair Anderson: Do we want -- how much, 15 

minutes? Is that okay for people?

Member Beach: Yes.

Dr. Roberts: Okay. So we'll come back -- I'll take role 

at about 3:30.

Member Ziemer: Actually it looks like we're ahead 

aren't we?

Dr. Roberts: Yeah, we are ahead. We could go with -

-

(Simultaneous speaking.)

Member Ziemer: We're not behind.

Dr. Roberts: Yeah. 

Member Ziemer: I think we're 15 minutes ahead.

Dr. Roberts: We are, that's correct.

Chair Anderson: Right. I'm sorry, yeah.

Dr. Roberts: So do you want to do a longer break and 

then come back when the work session is scheduled 

to begin?

Member Beach: Yes.

Chair Anderson: Okay, sure.

Dr. Roberts: Okay, and I will take roll at that time.

Member Kotelchuck: Okay.

Dr. Roberts: Great, thanks.

Member Kotelchuck: Four o'clock.

Chair Anderson: Four o'clock.
66

Dr. Roberts: Four o'clock.

Chair Anderson: So you get 45 minutes. Don't forget 

to come back.

Member Kotelchuck: Not to worry.

Chair Anderson: Okay.

Member Kotelchuck: See you later.

(Whereupon, the above-entitled matter went off the 

record at 3:17 p.m. and resumed at 4:00 p.m.)

Dr. Roberts: Okay. I have four o'clock exactly, and it 

appears that the court reporter is on. Let me go 

ahead and do roll call, starting with Anderson.

(Roll call.)

Dr. Roberts: I have a feeling Loretta might have been 

trying to speak, but I didn't hear her. At any rate, we 

do have enough to proceed.

Chair Anderson: Okay, then I'll call the meeting back 

to order.

Dr. Roberts: Okay, great. 

Board Work Session

Chair Anderson: The rest of this afternoon, we're 

going to be doing the Board Work Session, and we 

want to begin it with -- at the SEC issues and 

Savannah River Work Group meeting, the use of the 

NOCTS database came up for coworker models and 

other uses. 

And so what we, Rashaun and I thought it would be 

a good idea to go back over when it has been used 

and how has it been evolving, and we charged SC&A 

to put a quick review together. 

Bob is going to go through that, and then we can 

have a discussion about do we need to do anything 

further? Do we have questions specifically moving 
67

forward? Do we want to have a -- assign this to one 

of the Work Groups to work on, or just think about 

for future discussion? So Bob, you want to go 

through?

Mr. Barton: Okay. Let me just get myself off of mute 

here. Thank you for that intro. Let me just get this 

back up here, so hopefully it appears on your screen 

as it appears on mine.

Chair Anderson: Yep.

Mr. Barton: Yeah, thank you. This question did come 

up. Obviously, there's been a lot of discussion about 

co-exposure modeling for quite some time now.

And specifically questions arose about the use of 

NOCTS, which is the claimant, claimant sample 

essentially from all these different sites and how it 

applies, and can it be substituted for actually going 

in and capturing and coding all the data that would 

be available at the site, which oftentimes can be 

difficult to do and we'll get into that.

So there are closing columns obviously and basically 

this is -- it wasn't a full Board item. It's here during 

a Board Work Session really I think to get you all 

thinking about it, because it is a tough issue. It's 

really a policy discussion in my mind, and so this is -

- what we tried to do here is summarize some of the 

more poignant reports over the years that either 

tangentially address this item or directly address it. 

So then we looked through those and then some of 

the discussions that have happened certainly more 

recently about it, so that we can get you folks 

thinking about it and we'll figure out where to go from 

there. So not to bury the lead, but that is our (audio 

interference). 

There's some interesting -- how appropriate is the 

use of NOCTS as the primary data source when we 

go to formulate co-exposure models? Of course coexposure models are in place for workers who we 

don't have monitoring records for, which could be for 
68

a variety of reasons. Either they weren't monitored 

up to the standard that we consider in present day 

and they should have been, or it may have been 

monitored but for whatever reason those records are 

not available, got lost or illegible, that sort of thing.

So there's a lot of applications there, especially in 

SEC contracts. Now when we started to really dig into 

this, I mean the discussions by the Board and its 

various Work Groups, they go back more than -- it 

says back over a decade here. 

Really they've been there since the start, but I think 

really in 2009 is really when the Board reached the 

issue of how you assign dose to an unmonitored 

worker, how you relate the exposure records we do 

have for monitored workers to somebody who should 

have been monitored. But again like I said, we just 

don't have those records to use for dose 

reconstruction.

So we were tasked at SC&A to go through a lot of 

these transcripts and really summarize a lot of the 

relevant documents that have already been produced 

relevant to this issue. So if you like reading 

transcripts, this was a great task. 

Next slide. All right. These are really the screen name 

reports that we think really speak to this issue as a 

whole. You have OTIB-0075 and I'll -- we just 

finished a discussion where there's a lot of OTIB 

numbers and it's tough to keep them all straight. But 

this one, it's really in the title. 

It's Using Claimant Data Sets for Coworker Modeling, 

and this was first released again back in 2009, so 

over a decade ago and revised in 2016. It has been 

the subject of a lot of discussions, especially among 

the Savannah River Work Group and then the SEC 

Issues Work Group, and then the Joint SRS and SEC 

Issues Work Group more recently.

The second one here is an actual really like a pilot 

study for co-exposure modeling, and actually it 

develops the guidelines, which is IG-006, which we'll 
69

talk about a little bit. 

But again this was -- TIB-0081 was really the first, 

the test drive to see how all these different concepts 

that we talked about in the Implementation Guides 

for co-exposure modeling such as representation, 

completeness, adequacy, stratification. All those 

different things sort of came to fruition, where we can 

actually see it in practice.

And then Report 94 was in support of the Savannah 

River Site SEC discussions, which really looked into 

the NOCTS data that we had for subcontractors, 

which I'm sure you all remember was a big topic of 

discussion back in April.

So the first of those big three, again TIB-0075. Again 

this was the -- essentially the technical basis for why 

it's believed that claimant data is an acceptable 

substitution. Maybe that's not the right word. I know 

surrogate's not the right word either. 

But the use of claimant data to represent the full 

worker population as really a mechanism to increase 

the efficiency and the timeliness of being able to do 

these co-exposure evaluations.

So TIB-0075 was initially issued back in 2009, and 

then revised many years later to add in additional 

data that had been received, (audio interference) 

received in particular and we're going to get into that. 

But also the concept of the time-related one person 

one sample, which is a way to take a huge amount of 

data and be able to put it into essentially statistic for 

each worker by a specified time frame such as one 

year, and being able to weight it.

So that if you had many samples for a worker during 

a given year, so that you weren't giving undue weight 

to any particular sample. So what was analyzed in 

those, in the OTIB-0075 was three separate data sets 

where we had essentially adequate database files, 

where we can look at the full worker population and 

then also pull out just the claimant sample. 
70

Let's compare the two statistically and we'll see how 

they shake out. Is there anything that gives us 

concern that, you know, the claimant population did 

not represent a representative sample of the full 

worker population, which is obviously the main 

question here. 

If we're going to be using just claimant, claimant data 

to develop these co-exposure models, we want to 

make sure that the claimant data really represents 

what we would have found if we had gone back and 

pulled all the records available for the full worker 

populations.

And so that report, TIB-0075, again this really kind 

of gets to the root of this entire question. We only 

looked at three different data sets. You had 112, 

which was uranium urinalysis from 1950 all the way 

through 1988. Also plutonium urinalysis that we had 

at Mound for 1960 through 1990, and then tritium at 

Savannah River in the 1990's.

And so that report really went out in (audio 

interference). Can we see anything statistically 

different between the claimant population and the full 

database, which we luckily had available for analysis.

So our review of TIB-0075 was really focused on two 

issues. The first one is obviously the most cogent for 

today's discussion, is whether we can ever prove that 

NOCTS data is going to be representative of the full 

worker data if we had it. And also there's a big focus 

again on Savannah River at that time, because that 

was really the vehicle to really test a lot of these 

concepts that were being discussed about how you 

go about developing a co-exposure model for the 

workers who we don't have records for, again for 

whatever reason.

So what did we find? Well, when SC&A looked at that 

both back in the 2010 time frame and then when the 

revision came out five or six years later, we found 

that in those three cases yeah, it is statistically 

similar at these aggregate levels. The claimant 

records are statistically similar to the full worker 
71

population.

So essentially, you know, one can argue that they are 

adequate for use in developing co-exposure 

estimates, where you don't have necessarily easy 

access to the full worker population. But it was only 

three examples, and that was sort of the caveat. We 

said yeah, in these three instances then yeah, we 

agree you're statistically similar. 

But again we just, you know, wanted to point out that 

it is just those three examples that we looked at. 

So the second document that I listed there was -- I'm 

sorry. My house sometimes sounds like a kennel. The 

OTIB-0081. Again, this is the test drive of how we're 

going to go about using these guidelines we created 

for how you go about evaluating representation and 

completeness and data adequacy. 

That was for Savannah, and so OTIB-0081 does that. 

It provides the co-exposure estimates for, on 

monitored workers at SRS that we used in dose 

reconstruction.

This is really the first use, as I said you know, based 

on TIB-0075, which did the comparison between the 

claimant population and the full worker population. 

We're going to use, we're going to use NOCTS' data 

for Savannah River to develop at least a few of the 

facets of the co-exposure model.

Now the exceptions were for trivalent actinides, 

which includes thorium and also neptunium where we 

just didn't have enough. There was not enough data 

in the claimant population. So NIOSH went back and 

coded data from capture log book files, which are 

essentially hard copy records that have to be entered 

into an electronic database and go through the 

appropriate quality assurance criteria, you know, the 

whole nine yards.

But for the other ones like plutonium and uranium 

fission products and tritium, we just used the -- or 

TIB-0081 rather used just the claimant data, not the 
72

full site data. Now we did review, SC&A reviewed TIB0081, but really at that time the question whether 

using solely NOCTS data instead of going and 

capturing and coding the full site population was 

really beyond our tasking.

So it essentially was not addressed in that review, 

and that's really why we're talking about it today. 

The third report here was 94, which again was 

developed as part of the SEC discussion for SRS, and 

this was to take a look at the NOCTS data and answer 

the question or provide an analysis to look at whether 

the subcontractor population, subcontractor 

construction trade workers, were adequately 

monitored and were those records complete for the 

purposes of the SEC discussion.

From that report, NIOSH concluded that the 

subcontractors were monitored and they were 

represented at least as well as the other SRS 

workers. 

And so that the completeness of the subcontractor 

data was going to be adequate for dose 

reconstruction. When we say that, what was really 

sought after was to say is this data adequate for 

developing the co-exposure model to handle 

unmonitored subcontract workers (audio 

interference).

The co-exposure model was developed for really two 

stratified groups. One was the, essentially the full 

operational workers and then the second one was 

construction workers. That was really the question 

that Report 94 was developed to address.

In our review of that document, we found that one of 

the issues was that it sort of homogenized all internal 

monitoring into one metric, and we're really asking 

the question well, they were monitored internally but 

you know, for what? And were they monitored for the 

correct things?

You know, in some cases especially at a site like 
73

Savannah River, you're going to have the smaller 

operations involving exotic radionuclides such as like 

americium and things like, of that nature. But you 

have to have a huge percentage of the population 

that's monitored for it but what, you know, 

percentage of the population who should have been 

monitored for it really were?

So that was one of the things that it didn't quite break 

out in that iteration of Report 94. But then 

furthermore, we found that it didn't substantiate the 

actual question of representativeness of the claimant 

data as compared to the overall site population. It 

wasn't what it set out to do. The purpose of the report 

was really to take a look at hey, what do we have in 

NOCTS data and what does it tell us about these 

important questions?

I think from SC&A's standpoint, we feel like that the 

concepts of representation really should closely align 

with what we see in the co-exposure guidelines that 

we developed in IG-006, and that were approved by 

the Board in 2019. I believe it was December 2019, 

and that's are these co-exposures that we're 

developing, these models that are based on 

monitored workers, are they developed from workers 

with comparable activities and relationships in the 

radiation environment? 

And that really, that comes almost directly out of the 

guidelines. If it's not a direct quote, it's very close. 

And also representative of the distribution of 

exposures for the population we're really trying to 

reconstruct doses for, or provides a plausible upper 

bound for those workers.

So some specific discussions. Again, part of this --

part of this presentation and the memorandum, 

which I should have mentioned at the outset, that's 

on the website for you all to peruse, was to look at 

some of the discussions that have happened either in 

Work Groups, in the full Board subcommittees about 

the application of NOCTS for developing these coexposures.
74

As I said previously, you know, as was shown in the 

Report 94 analysis, that there was a pretty high 

percentage of the subcontractors in NOCTS who had 

internal monitoring data. However, we're asking the 

question well again, monitored for what? Were they 

monitored for the correct radionuclide based on their 

job-specific work tasks? How complete was that 

specific to SRS, where they had a job-specific 

monitoring program, that if you weren't on a routine 

program, you're supposed to be on a job-specific 

program and how complete was that, how effective 

was that. That was a lot of questions that were 

discussed.

But again, these are pretty recent. This is 2019 to 

2020. In 2019, actually knowledge that, you know, 

you can look at NOCTS. But at some point the 

completeness based on that has to be inferred. You 

don't have the full suite of data that you might have 

if you went and captured everything that is available 

for these various sites.

And now this third bullet is very important, because 

this really gets to the matter of well, we might be 

losing some information if we're not capturing, 

encoding and analyzing all of the data for a site. But 

certainly using what is in the house for NIOSH, which 

is going to be the claimant population, the NOCTSbased data, certainly has the advantage. It's simpler, 

it's more timely and it's much more efficient.

But the question before you all today and moving 

forward, and again this is sort of a kickoff meeting 

just to get you all thinking about this, does that really 

meet the intent of what was outlined in IG-006, which 

was basically the road map that was created over a 

decade of discussions on how we go about dealing 

with the unmonitored worker.

So again, a little bit more about some of the general 

discussions that have taken place. There's a lot of 

references to transcripts in here. I encourage you all 

if, you know, to go look at those discussions. They're 

really fascinating to look back at how far we've come 
75

in developing a lot of these things.

There's going to be a bunch of slides at the end of 

this presentation that give you direct links to these 

transcripts, so you can go and read through what 

everybody said. I will admit that going through them 

myself, I was a little embarrassed about some of the 

things I said and the way I said them, but it is what 

it is. I think the point got across. But what -- some 

of the particularly poignant observations made in this 

one is particularly from 2019, is that the worker, you

know, there was no literature that really just linked 

people who had developed illnesses, in this case 

obviously radiogenic cancers and other cancers, as 

actually being representative of larger populations.

So we just didn't have necessarily the body of work 

to make that technical basis judgment. And also 

noted during that meeting, and again you can go 

back to the transcripts, is the co-exposure 

Implementation Guidelines. They prescribe that as 

representation of the overall workforce, just a subset 

of that workforce.

Now again from this transcript at about the same 

spot, it was pointed out that in the claimant 

population there are people who have developed 

illnesses and they've been harmed. So, you know, is 

it -- is it really a question of it being representative 

or they might even -- the population of claimants 

may even be biased higher. That point was put forth, 

and similar type discussions occurred at some of the 

later meetings and I note them here. But really the 

issue is just never quite resolved. 

So what is actually in the Implementation Guidelines? 

The Implementation Guide says that user friendly 

data is a useful starting point. So you can look at the 

distribution of who was monitored, when were they 

monitored? Are there noticeable gaps? Also the 

Implementation Guide says that you can use NOCTS 

to verify the completeness of if you already have a 

site-specific data set.

So basically you can use the claimant population to 
76 

verify the completeness of a larger data set you have 

for the full worker population. And so we believe that, 

really that the intent as written in the 

Implementation Guide as it stands is that NOCTS is 

really used as a backup to validate or check did you 

-- did they monitor the right people, the right job 

categories, the right locations, the right time periods?

But it, as it currently stands, doesn't provide 

guidance or indication that you can simply use 

NOCTS as a substitute for site-specific data sets when 

you're trying to go in and develop these co-exposure 

models.

So just to sort of sum things up here, we absolutely 

agree that NOCTS has a lot of great features that 

allow us to do these evaluations in an SEC context, 

in establishing whether if you have a site-specific 

database how complete is it or are you seeing gaps 

in what is being provided by the site.

But what we didn't see is anywhere where the Board 

really voted or gave their blessing that you could 

essentially substitute NOCTS data in lieu of actually 

going and capturing what available records there are 

for full monitored population. But again, one thing 

that the -- the counterbalance here is that it does 

take a lot of time, a lot of effort and a lot of (audio 

interference) to go in and do that kind of work.

Because a lot of times, you might be able to get an 

electronic database from a site, and a lot of times we 

won't. What you're left with is boxes of records that 

then have to be entered into a suitable database that 

NIOSH can then analyze to create their co-exposure 

distributions. So it's a process, it's a process, and the 

question again I'd like to reiterate is that is the 

information that we're potentially losing by not going 

through that process of actually capturing the full 

suite of monitoring records for a given site, is that 

outweighed by the essentially what is a lot more

efficient?

The question is can we consider the claimant 

population as basically a random sample? Because if 
77 

not, it's a semi-random sample of the workforce, and 

is it -- is it close enough that we can use it without 

running against a lot of the policies that were set out 

in the Implementation Guide.

I think this last bullet here is that, you know, the real 

question is can we ever really know if the claimant 

population is representative of the full population? 

Right now we have those three examples I talked

about that were in OTIB-0075, in which SC&A agrees 

with NIOSH. Statistically, they're very similar.

But the question is can we use that as the technical 

basis to say, basically create a universal 

programmatic assumption that the claimant 

population represents the full population when we go 

to make these co-exposure models. I think that was 

my last slide, and I have a question slide here.

Also, I was given the honor of giving this presentation 

today, but I know Joe Fitzgerald and Ron Buchanan 

are also online, and they've been at the center of a 

lot of these SEC and co-exposure model discussions. 

So I guess before turning it over to questions, Joe or 

Ron? If you're out there, do you want to add anything 

that I missed or perhaps bungled a little bit, you 

know? Come on in.

Mr. Buchanan: No, I don't have any extra.

Mr. Barton: Okay. Then I guess on to questions.

Chair Anderson: I guess Bob a question, and one 

question I'd have. Where this came up was with SRS, 

which is a very complicated site, very large site with 

a great deal of data. The question then becomes is 

that unique? I mean is this, the use of the data at a 

Hanford, which is another big site, or some of the 

other very large sites, is there a certain size of the 

database or the NOCTS amount of data that's come 

in over what period of time and what kind of 

malignancies are being claimed?

That we could have kind of narrow this down to say 

well, it might be worth looking at in some sites. But 
78

in sites where there really isn't a whole lot of data, 

especially for specific subgroups of workers, it's 

worth looking at from the standpoint of, you know, it 

just started out as a secondary data source to 

confirm or to help support, you know, was a random 

sampling done of workers or were they systematically 

screened sort of thing.

Any sense of looking at the various sites or data 

that's available and could we potentially look at what 

would be the core amount that's needed? 

Mr. Barton: Yeah. That's a very difficult question, and 

as you read through some of these transcripts, you 

can see that the Board has struggled with that for a 

number of years. I would point out that even at 

Savannah River, where just the size of the site meant 

you were going to have lots and lots of data, that 

even for certain things, you know like those trivalent 

actinides, NIOSH said well, you know, the claimant 

says this is not adequate for that. We need to really 

go back and code in more data and really get the full 

suite.

For americium, that was the case. They went through 

and they captured all the log books and they coded 

all of them, and that was part of the co-exposure 

model. 

(Simultaneous speaking.)

Chair Anderson: There were some, some differences 

in years that are being missed and things like that as 

well. So --

Mr. Barton: Right, and it's -- it's difficult because I 

certainly understand. I mean we totally agree with 

NIOSH that that's a lot of effort to go and do that. 

It's a lot of effort, it's going to take a lot of time. So 

the question is is it ultimately going to give us a 

better answer to the point where (audio interference) 

that that level of effort and the time it takes is going 

to be worth it for the program?

I'm not sure you can answer that question 
79

universally. And that, that is really I guess the 

subject that I wanted to be broached today, was 

could we come to a universal programmatic 

assumption where we say listen, the claimant 

population is going to be close enough to a random 

sample to where we can use it.

And really I don't -- I'm not sure how you answer 

that. You can't answer it analytically unless you're 

going to compare each site, and unless you have a 

database to compare it to, it's difficult unless again 

the Board adopts the policy position that we believe 

the claimant population is close to a random sample 

and is representative of the full site population, 

where we have infinite resources to go gather all this 

data, encode it and analyze it.

It's a question that takes on different nuances for 

every site you look at. But again I point out that 

yeah, Savannah River had a ton of data, but even 

then for certain operations like the trivalent actinides 

that were separated, it was necessary to go and grab 

the full site population, and that's probably going to 

be the case at a lot of these larger sites.

You mentioned Hanford. I mean even sites like 

Fernald come to mind where, you know, you had 

400,000 uranium bioassays, but it wasn't that simple 

of having that, you know, incredible number of data 

points because there were other operations going on 

with thorium. 

So I mean I think each site's different, but the real 

question is I think higher level. It's can we make an 

assumption where we can say that the claimant 

population is a suitable representative sample of the 

full population at these various sites?

Chair Anderson: Comments, questions others have?

Member Ziemer: I'll throw something into the mix 

that has occurred to me, and I can throw it out there. 

I'm not prepared to answer my own question, but 

there's one area that we probably can't address that 

couldn't make the argument that the two populations 
80

are not the same, but not in the way we're thinking 

about it. 

It's very possible that the claimant population has a 

bias toward underlying conditions including genetic 

issues that would make their susceptibility for 

equivalent doses, their susceptibility to cancer or 

risk, their personal risk factors higher. It would have 

nothing to do with the monitoring issue, which could 

be completely representative of both groups.

Chair Anderson: Yeah.

Member Ziemer: So and if biological factors were 

more of a determinant, then that would argue that 

the populations are only different in that respect, but 

not in the respect of how they are monitored. It's just 

a thought to put into the thinking as we're going 

forward, because we have that issue of no studies 

showing that the monitored or that those with claims 

were -- the idea being that perhaps they had higher 

doses might be. But no studies show that.

But if we're talking about biological susceptibility and 

biological risk, that's not an issue we deal with per 

se.

Chair Anderson: Right.

Member Ziemer: (Audio interference) thought as you 

think about this whole picture.

Member Clawson: This is Brad. In dealing with this at 

Savannah River and everything else like this, they're 

wanting to come up with a one-size puzzle fits 

everything. And as every one of us that has worked 

on any of these sites or dealt with these sites, every 

one of these sites has their own unique 

characteristics and processes that we just can't 

capture in this population.

It to me was I understand about the time, the 

expanse and everything else like that. But guess 

what? If we don't have the data, we've already got 

something in place right now to be able to take care 
81

of that, and that's the SECs. But to be able to come 

in and try to be able to use all this NOCTS data and 

everything else I think is not right, and it's not -- it's 

not what the system was set up to do in my personal 

opinion.

Member Ziemer: Well inherently I think it would be 

hard to argue that the NOCTS data is somehow 

biased for just those who were claimants. That's all 

I'm saying.

Member Ziemer: Yeah. I understand what you're 

saying, and I'm just -- you know, we've been, we've 

dealt with this one for a few, you know, quite a while, 

I think the last four years, and I -- I have not seen 

anything that has shown me that it would be the best 

route to go.

Chair Anderson: Yeah. That's another question too 

that you have stop to think about is that a person 

inhales a particle, and whether that particle may only 

be temporarily stuck in their throat, it may be stuck 

in their lungs temporarily. But you never know when 

it's going to be that, as a lot of people like to use the 

term "that magic beebee" that triggers something.

There's just no way of knowing this, you know, 

exactly why it will trigger in some people and other 

people it won't. Two people working side by side, one 

can get a whole, get a rather large dose and the other 

one won't, just based on a few feet of difference. Or 

somebody will have contamination on their hands, 

and they will go eat, whereas the other guy washes 

his hands.

Now you've got a problem here that -- particularly 

among a lot of these people who weren't monitored. 

Like a lot of the contract crafts and stuff are escorted. 

Well, your escorts are trained. They're not going to 

go eat without washing their hands. A lot of those 

craft, some of those craft guys probably will. They 

are used to that.

So I mean, you know, when and where that location 

is of that contamination or that wound is, it's a 
82

crapshoot and there is no way to use NOCTS data and 

sit there and say well, these guys got this. And a lot 

of times it's where they got it and how it set there 

before it moved on. That is a question that we cannot 

answer.

Member Kotelchuck: Henry.

Chair Anderson: Go ahead.

Member Kotelchuck: I have a different kind of 

question about the design of Bob's study. Two out of 

the three data sets were urinalyses, and of course 

what you get in the urine may come from several 

different routes of entry. That's considered a virtue. 

I would have hoped that you might do something that 

didn't involve the human body intervention by 

saying, taking the -- taking the film badges of the 

entire population out of the NOCTS population, and 

wouldn't get into how, what route of entry is going to 

result in a certain amount of material in the urine.

So, so two out of three -- so I would have liked to --

I would have hoped that you could have found some 

other plants where or those plants where you could 

look at film badge data. 

The other thing is the tritium dose. That's done, 

measured with scintillation counters primarily.

Mr. Barton: I believe that all three would have been 

based on urinalysis. I think that tritium, it's called 

dose because it's so easy to calculate a dose based 

on tritium urinalysis. I will definitely kick that over to 

NIOSH to confirm that. But I believe all three studies 

were urinalysis.

Member Kotelchuck: Aha, okay. That to me is a fairly 

serious limitation in terms of broadly applying or 

seeing whether we can broadly apply NOCTS to the 

entire population. And as I say, I think film badge 

data, if we can get it and I suspect there are places 

where we can get it, would be helpful in trying to 

make a decision, help us understand.
83

I don't disagree with what, you know, other people 

said. I may be skeptical at one level of use of NOCTS 

data for the whole sample. But in a study, I think we 

need to have something beyond three urinalyses.

Chair Anderson: Other comments people have or 

thoughts? We aren't going to resolve -- we aren't 

going to resolve this today, but what I'd like to do is 

--

Member Beach: Andy, before you jump -- before you 

go forward, is there any path forward for validating 

the NOCTS? I know there have been some samples 

and I believe it was addressed today. But is there any 

other work that can be done? 

Mr. Barton: Well, to answer your question Josie, and 

Joe might be able to step in here too, there's really -

- there's really kind of three paths forward I guess. 

The first one would be say we looked at it in those 

three cases which were the urinalysis cases that Dr. 

Kotelchuck was just discussing, and we believe that's 

going to be applicable across the entire program.

The second one would be we could take a look at 

more sites, you know, and what's the correct number 

of sites? I don't have an answer to that. I'm not sure 

there is an answer to that. It's really again this boils 

down unfortunately it's a policy question.

The third option there is that you don't believe that 

you could ever sufficiently validate it to be able to 

make a programmatic assumption for all the sites. 

One thing that I think we point out in our memo, I 

didn't have a slide on it, but LANL is coming up for 

the series or reports.

I know LaVon updated earlier today on that. I'm not 

sure if we'll get into that discussion later in the Board 

Work Session. That might be another opportunity to 

take another look at it. I guess the question for you 

all is, you know, we take a look at that and we'll find 

out. Is that going to be enough? I think that's kind of 

a fundamental question that needs to be wrestled 

with.
84 

Member Field: Bob, this is Bill. I had a question. In 

one of the earlier slides, it was stated that there was 

statistically similar. I think I understand what you're 

meaning, but when you talk about statistically 

similar, were you talking about the exposures were 

the same, or that it was statistically similar in the 

work groups that were archived?

Mr. Barton: It was the analysis of those young 

results. So you come up with, it's called a time 

weighted one person-one statistic, and when you 

compare the distributions, you have a distribution 

that we had developed based on the all worker 

population, which you essentially had that data for, 

and then you compare it to the claimant population 

for those same three sites.

The two distributions that were developed for those 

workers were statistically similar.

Member Field: I was just wondering if something like 

Monte Carlo could be done to look at -- to really try 

to model the uncertainty and the prediction of well, 

how well they actually do represent it?

Mr. Barton: Well, certainly something akin to that 

occurred recently for Savannah River. I don't want to 

necessarily start --

(Simultaneous speaking.)

Mr. Barton: --trying to describe the statistics of it, 

but they have this bootstrap analysis that was done 

to compare the two populations to see, you know, 

what differences there are really. I think that level of 

statistics was done for those three cases, and the 

questions is the three cases in NOCTS. It's not an 

easy question.

Member Field: Yeah. So I guess it's a matter of 

statistically similar versus how predictive can you be.

Chair Anderson: Well, and it's -- you're trying to 

assign doses to the unmonitored workers. And so 

part of it is are the unmonitored worker represented? 
85 

Are they similar to the ones who were monitored? 

And that's somewhat problematic in that they weren't 

-- I mean (audio interference). They weren't 

monitored because they -- and that was partially at 

Savannah River as well, that they didn't need to be 

monitored. 

So you know, and that's always hard to know. Did 

they have a protocol in place that they should have 

been monitored but they weren't, or so I think there's 

all of those kind of questions that come into play 

when you're using this database to assign doses to 

unmonitored workers. So it really becomes are 

unmonitored workers representative of the overall 

population, or are they somehow a selected group 

and were they not monitored but at higher risk? 

Those are kind of difficult questions to answer.

Member Ziemer: So Henry, are you suggesting that 

we should have some (audio interference) sort of like 

we do for surrogate data, to say what conditions do 

you have to meet to use NOCTS data.

Chair Anderson: Well I, I don't know if we can do 

that. I mean that would be my question to Bob, and 

I would -- I think the simplest thing is kind of what 

we did when we reviewed the -- when our committee 

looked at those three examples you gave, we said on 

a -- you know, it may well work there. We stopped 

short of saying this is now a universal principle that 

we can adopt.

So it's kind of -- the fallback here is case by case. 

Well that isn't terribly helpful because you don't know 

until you've put all the effort into trying to dig out all 

the old data, which again year after year of finding 

more boxes of -- well that's going to provide the 

answer kind of moving forward.

But if there could be some generic or general 

characteristics that we want to look for to say that, 

you know, then it may be worth exploring at a 

specific site, rather than saying you can or you can't. 

Mr. Barton: Well, I think, I think you really hit the 
86

nail on the head there, because how do you -- how 

can you validate it for any given site unless you 

already went through the process of gathering that

data and comparing it? And so that's really the 

question.

Chair Anderson: Yeah. 

Mr. Barton: The other thing I would say is you were 

mentioned, Dr. Anderson, that you know, are the 

unmonitored workers represented by the monitored 

workers? But it is one step further than that because 

we're looking at only a subset of the monitored 

workers, which is in the claimant population.

And then there's certainly factors that Dr. Ziemer 

pointed out that go into, whether it's biological 

factors that go into it, the timing, you know. There's 

a lot that could go into it. 

But the question is, is it close enough to a random 

sample of the worker population such that we can 

consider it a random sample and thus use it as a 

representative data set for all cases where we need 

it where we have an unmonitored worker and you 

don't have data for them and you need to reconstruct 

their dosing.

Member Clawson: Let's just take a look at something 

else too. We're trying to do this for the unmonitored 

worker. This is a compensation program for people 

that have been injured and so forth like that. So we're 

trying to take all of this other information, and to me 

trying to use this like this is just smoke and mirrors, 

because we are never going to get to the point that 

we can actually say yes, this is totally representative 

of it, because we don't know what the people that are 

unmonitored got. 

Bottom line, that's what it comes down to. We can 

guesstimate and everything else like that, but that's 

not -- that's not what we're here for. We're doing the 

best we can, but we've got to do it with the 

information that we have and be able to put our 

stamp of approval on it.
87

I've been against this. I have a hard time with our 

coworker model, but guess what? That's what we 

agreed to have and that's what we pushed forward 

with and work with. 

Member Ziemer: Brad, we're still required if we can 

bound it. We don't have to have the exact value for 

workers.

Member Clawson: Well, and that's true Paul. But 

what if we don't -- what if we have insufficient data?

Member Ziemer: Well then we can't bound. Then we 

can't bound. I'm just saying that not having 

individual data is not the criteria.

Member Clawson: Right. We have but --

Member Ziemer: --whether we can bound it or not.

Member Clawson: But when we have insufficient data 

and we can't do that, we have the process of an SEC.

Member Ziemer: Oh yes, right. Nobody's arguing 

that.

Member Clawson: And to me, what we're trying to do 

is step away from that and try to use this other stuff. 

Let's just be brutally honest.

Chair Anderson: I'll ask Bob, since you're our 

contractor that did this work, do you see any, any 

things that your group could do that would help us 

move forward, or are we really left with we either 

have to say do it or don't do it, or do we go to case 

by case, and if NIOSH thinks that they need a -- this 

is their only option for co-exposure determination, 

have them put it forward and then we on a case-bycase review it.

Mr. Barton: You know, I can't see a way that we could 

ever just put a number on it and say as long as we've 

reached this level of justification, that it will fly in all 

cases. However, that doesn't mean that more 

examples. In addition to the three that were done in 

TIB-0075, it adds to a greater level of comfort for 
88

lack of a better phrase.

Chair Anderson: So do we have any sites that are --

I mean that there's past sites and there's sites to 

come. Some of those that are coming up, I think you 

mentioned might be ones where NIOSH is looking at 

using NOCTS data for a co-exposure model. Is that, 

are those examples we maybe want to do some 

exploring with?

Mr. Barton: Well, I think that these questions would 

certainly come up during that process. I did mention 

LANL, but I don't want to step on NIOSH's toes about 

what they have in development. I don't know what 

that is. But yeah, again this is -- this is sort of again, 

sort of a kickoff session --

Chair Anderson: Yeah.

Mr. Barton: --just to get everybody thinking about it, 

because I think, you know, what we're -- we'll 

eventually have to deal with it at each site. The 

question is, is there something -- can we convince 

ourselves or get a level of comfort where we can say 

no, the claimant population isn't a random sample, 

but it's a semi-random sample and we're confident 

that we're not somehow missing something by not 

capturing all the information that is available.

The only way to maybe perhaps move it beyond just 

a philosophical discussion is to, as these sites come 

up, to specifically look at, you know, what are we 

basing our co-exposure distributions on? Is it based 

on NOCTS and what did NOCTS tell us? What are, 

what are the limitations for the population?

But again, I wish, I wish I had a more definitive 

answer on how to answer this question but there 

simply isn't one. It's a philosophical question about 

whether you're claimant population is a suitable 

subset to use, to substitute in for going and capturing 

everything.

Chair Anderson: Other Board members have any 

comments? I think -- I mean what I'm hearing is 
89

there continues to be considerable skepticism about 

the appropriateness of the NOCTS data for the 

purposes that have been proposed. So it's kind of 

user beware. If NIOSH feels that they can make a 

stronger case on some sites for this than others, they 

just have to be aware that there's going to be some 

skepticism raised and therefore they're going to have 

to do perhaps a better job in justifying the utility of 

this for a specific site.

I don't know. Do other members have any thoughts? 

Do we want to --

Member Beach: Well Andy, I know we're expecting 

our LANL report sometime in September. So that 

Work Group would be convening against soon after 

that or after SC&A has a chance to look at that. It 

may be that that will come up for discussion and we'll 

have a little more tools.

Plus I want to go back and read all the different 

transcripts that Bob pointed out that I didn't have a 

chance to get to before this meeting. 

Chair Anderson: That's fine.

Member Beach: But it sounds like moving -- moving 

forward, it sounds like we're going to be reintroduced 

to this a lot.

Chair Anderson: Okay. That's kind of my sense, that 

it's not going to go away in the matter, and the 

question is with what we have now, do we have a 

definitive way forward and I would say no. I would 

say your LANL group is going to be one and we just 

have to think about this some more and maybe that's 

your Work Group. That's the one we need to look to 

to work on this issue.

Member Kotelchuck: And Henry, I agree with you. I 

don't see that we're going to be able to make ever a 

definitive statement about when we can or can't 

apply it, and therefore we're just going to have to 

continue on with people suggesting use of NOCTS 

and we look at it case by case. It's not going to go 
90 

away as you say.

Chair Anderson: Yeah. I mean it's a real tempting 

database to use. It's now been in place quite a long 

time and has gotten quite large. So if it would meet, 

you know, sufficient criteria it would be a boon to be 

able to use it. But I'm not sure we're there right yet. 

Any other -- I mean we have some other issues for 

our Board session today. 

We just wanted to introduce this and get those that 

haven't been thinking about it thinking about it. 

Again, if any of the others of you want to say a few 

words or think about it more. But it's something I'm 

going to raise again for the Board to think about over 

time. 

But I think Bob, you've done a good job bringing 

together the history of it. I didn't realize it went back 

to 2009, so it's -- when you think in terms of the 

other criteria for what used to be coworker modeling, 

how long it took to come up with those guidelines, I 

don't expect a simple solution for this one here. Paul, 

any other thoughts? 

Mr. Barton: I was just going to add that I think part 

of it is that when we've developed -- when the Board

developed those guidelines that are IG-006, NOCTS 

is mentioned in there, just not necessarily in this 

way. It's used as a tool that we can look at well, even 

among this subset of the worker population, let's look 

at who was monitored. There's a great example in 

there from Nevada Test Site, where we were able to 

look at the claimant population and say well, who was 

monitored at Nevada Test Site? It turns out that 

involves a lot of the rad tags and the security people, 

who didn't necessarily go past the check point.

And so that was the reason, one of the reasons why 

the SEC was recommended there. That's the utility of 

using NOCTS not just absolutely, is that it can give 

you a great wealth of information because we have 

information on job titles and various other things. But 

the guidelines as they stand right now don't address 

whether we can sort of make a blanket assumption 
91

that claimant population can replace the full suite of 

data were we to go get it from these various sites.

I think that's -- that's really were it arose from, 

because the guidelines as written right now are not 

clear on it so --

Chair Anderson: Yeah. Well there's also I've talked to 

quite a number of workers who felt they really didn't 

deserve to be compensated. So even if they had the 

cancer, their family would make a claim. So there's 

all sorts of as we talked about the genetic risk factors. 

There's also as we know now with COVID and the 

vaccines and testing and all of that, there's also social 

personal issues of I was paid for my work and I did 

the best I could, and nobody's really to blame.

So we don't really know how all of those factors fit 

into it. So any other last comments? Then I guess 

we'll wait to see the LANL report when it comes out, 

and I don't know if any of the NIOSH folks want to 

weigh in now or not.

Mr. Taulbee: This is Tim. No, nothing really to weigh 

in at this time. I'm not sure the LANL reports are 

going to move more in that direction, but we'll see. 

Chair Anderson: Okay. Well that's, yeah. Okay. At 

least you know where some of the concerns lie, so 

you just have to beef up the support if that's the 

direction you feel we have to go. 

Mr. Rutherford: This is LaVon Rutherford. I will say 

that the LANL reports at this time have no intention 

of using the NOCTS database in itself.

Chair Anderson: Okay. Well then we'll just push it off 

until it does raise its head again. Okay. Any other 

comments on this? We appreciate the work you did 

Bob and your group in pretty short order, and I think 

there's some support documents that are going to be 

helpful to us as we move forward.

So Rashaun, I think there's some -- what other Board 

issues do we have here?
92

Dr. Roberts: We, I think it makes sense to transition 

into the Work Group and Subcommittee reports, if 

folks have things to report for those.

Chair Anderson: Okay. Work Group reports.

Member Kotelchuck: Well yeah. I'll start.

Chair Anderson: Go ahead Dave.

Member Kotelchuck: I'll start with Ames, the first one 

on the list, because it's a strange conclusion. We 

have never met, which is really unusual. However, as 

soon as Tom Tomes went over the data, it was 

reported directly to the Board that we just didn't have 

enough data and we gave it an SEC in December of 

'17.

Since then, he's been trying to do some data capture 

so that he can update the Site Profile, which makes 

sense. I, it's just been very slow and I gather Tom by 

the way will be retiring soon. So, so I feel like -- I feel 

as Chair of the group that we've been waiting to get 

the data, so that we could have a meeting to talk 

about updating the Site Profile.

But until we have -- until the data is complete as best 

we can, there's nothing much to do so we haven't 

met. If anybody can say, Tom is not on the call I 

believe, if anybody could say, you know, that work is 

now well enough done that we're ready to hold a 

meeting, I'd be very glad to hold a meeting. But 

otherwise, I'm just watching and waiting, and then -

-

Mr. Rutherford: Dr. Kotelchuck?

Member Kotelchuck: Yes.

Mr. Rutherford: Yeah, this is LaVon again. Yeah. Tom 

is definitely retiring and passing that on. We haven't 

identified a person who's taking that over. Part of the 

issues with Ames is it isn't to that 835 area, that 

we're dealing with similar issues at LANL and other 

sites, and we're kind of seeing how things are playing 
93

out. 

We've done a lot of data captures and we've pulled 

data, we've had interviews. But we're kind of seeing 

how some of this is going to work out in order to 

update, make a final conclusion on that period. So I 

would suspect -- I mean at this time, you know, as 

things progress with LANL I think you'll see that we 

will update and move quickly on Ames after that.

Member Kotelchuck: Oh, very good. I would 

appreciate it. Now on -- I mean I just want the other 

Board members to not figure that we're doing nothing 

because we have never met. We're keeping up with 

it and I appreciate when we'll get some further data 

when the issues are resolved.

And I'll be glad to hold a meeting, and I hope the 

Board members who are members of the 

Subcommittee, of the Working Group will remember 

who they are. I know who they are. But I don't want 

to scare them. As soon as I hear, we'll start meeting.

Chair Anderson: We don't need to go through all 58 

pages here. I mean I thought the status, the Work 

Group Subcommittee activities report was very 

comprehensive. I would only ask the chairs is there 

anything wrong there or additions that we need to 

put into this, because I think this is a very helpful 

document just to keep track of all that's going on for 

quite some time.

So if there's changes or additions or I think early on 

when the memberships were circulated, people didn't 

realize they were (audio interference). They thought 

they were and they weren't. We want to get that all 

current. So if you haven't looked it over, please look 

it over for those who have been involved, and 

hopefully this does accurately reflect what's going on. 

But it's really quite comprehensive.

Member Kotelchuck: It was a good -- it was a useful 

report.

Chair Anderson: Yeah.
94

Member Kotelchuck: Summary report.

Member Beach: Andy, there was one missing and I 

sent it to Rashaun, and now I don't remember which 

one it was.

Chair Anderson: Right.

Member Beach: I was trying to go back and look 

through my notes. It's like Rashaun, do you 

remember which one I emailed you and --

Dr. Roberts: I don't actually.

Member Beach: I don't think you ever responded to 

me, so I'll look through my emails. I think Joe 

actually caught it and Joe's on the line. He'll know 

which one it is. 

Chair Anderson: There's a Work Group Coordination 

Report as well. It's an Excel spreadsheet. 

Member Beach: Okay, it was missing off that 

spreadsheet. 

Chair Anderson: Yeah.

Member Beach: Okay. Well, we'll go back and look or 

I will.

Chair Anderson: Yeah. Well I guess we'll encourage 

everybody to -- it all came, and it was a lot to read. 

If you see something that ought to be added let's --

these are the documents we want to keep current 

and work from. 

Member Kotelchuck: Yes.

Chair Anderson: So Board coordination, executive 

summary there. That's a little more manageable. 

Member Kotelchuck: Yep.

Chair Anderson: And Rashaun, the public comments? 

There were many there.

Dr. Roberts: Okay. So are we done with the Work 
95 

Group reports and --

Chair Anderson: I mean do we have -- we have a 

couple of ones that are scheduled to meet shortly so 

--

Dr. Roberts: Right.

Member Kotelchuck: Right.

Dr. Roberts: So we have the Subcommittee on Dose 

Reconstruction reviews.

Member Kotelchuck: September 29th. The 29th's set.

Dr. Roberts: Okay, and I think that may be the only 

one currently. Okay. So if that's all people have to 

report, then I can continue. So from the April 2021 

Board meeting, there were a few comments that 

were offered by the public, and the vast majority of 

them really revolved around raising questions and 

voicing support for adding the SRS SEC. So there 

wasn't much beyond those kinds of comments.

In terms of planning meetings, I just want to make 

sure that I have everything correct with what we 

have determined already. So I think we have 

established that our telephonic, our telephone 

planning meeting for the December Board meeting 

will be on Wednesday October 20th.

And then we have scheduled the two- day meeting, 

which will in all likelihood need to be done virtually 

because I don't anticipate that there will be a change 

in travel policy. And then we have a lot of -- a lot 

going on with variants and surges in cases across, 

you know, the country.

So I'm anticipating, as Andy had said earlier, that 

that's going to be another virtual two-day meeting, 

and that we have scheduled for Wednesday the 8th 

and Thursday the 9th of December. And if anyone 

recalls differently, please let me know. But from --

that's what I have down so far. 

Then we have the next teleconference scheduled for 
96 

Wednesday, February 16th, 2022. So those are the 

ones that I think we have established the dates 

around. We could talk about setting the date for the 

April meeting, which hopefully would actually be in 

person at that, at that time. I know last time we said 

we were going to meet in Spring this year, but those 

plans went ka-bosh. So I'm hopeful --

Member Beach: I thought we -- Rashaun, I thought 

we did have those dates. I have listed the 26th, 27th 

and 28th. I think the meeting was 27-28 is what.

Dr. Roberts: 27-28, okay. 

Member Beach: That's what we talked about last 

time.

Dr. Roberts: Okay, so 27-28, okay. Does that --

Chair Anderson: Yeah. I've got a question mark on 

26 but --

Dr. Roberts: That would have been the travel, yeah.

Chair Anderson: Yeah.

Dr. Roberts: Okay. So 27-28, and did we set anything 

for June of next year? 

Member Beach: No.

Dr. Roberts: Okay. So then starting with that, I mean 

we could go ahead and try to tentatively identify 

some dates now for that one. And that would just be 

a teleconference.

Chair Anderson: For June?

Dr. Roberts: For June of next year. So if we're 

keeping to our Wednesday-Thursday pattern, we 

could go for some time in mid-June of next year, the 

15th or the 16th of June.

Member Beach: Those work for me.

Chair Anderson: Yeah.
97

Member Kotelchuck: Fine, fine.

Dr. Roberts: Okay. So maybe --

Mr. Calhoun: I can't make the week before.

Member Ziemer: I'm good, either one.

Dr. Roberts: Okay. But Grady, that was -- was that 

you? So you, you would be available for like the 15th 

of June?

Mr. Calhoun: Yes.

Dr. Roberts: Okay, perfect. Okay, so we'll say 

tentative.

Member Beach: And we're starting those at 7:30 now 

instead of 8:00; correct?

Dr. Roberts: Yeah, yeah. I think 10:30 Eastern, yes, 

yes.

Member Beach: Okay.

Dr. Roberts: Okay. So I will put that down, and then, 

you know, usually we'd like to go ahead and plan out 

by about a year. So let's go ahead and talk about 

August, probably targeting middle month like we did 

today. Would that be okay? So something like the 

17th and 18th of August 2022. 

Chair Anderson: So the June meeting, that's a 

potential -- that's just a call?

Dr. Roberts: That's just a call.

Chair Anderson: Yeah, okay.

Dr. Roberts: The August meeting would presumably 

be in person.

Chair Anderson: Yeah.

Member Beach: Those dates work for me.

Dr. Roberts: So okay.
98

Member Kotelchuck: Yeah, that's fine.

Dr. Roberts: Okay. So --

Member Ziemer: What was the August date?

Dr. Roberts: The 17th and 18th.

Member Ziemer: Yeah, okay.

Dr. Roberts: Would that be okay?

Member Ziemer: Yes.

Member Beach: Uh-huh.

Dr. Roberts: Okay, the 17th and 18th. Okay.

Member Ziemer: Rashaun, are you anticipating that 

by April we might be meeting in person, or is this 

really just too early to even think about?

Dr. Roberts: I really am hopeful that we can actually 

have that face to face meeting. But as you know, 

things could take a turn. So --

Member Ziemer: So wait and see.

Dr. Roberts: Yeah, and as Andy said, it would just be 

nice, especially if there are new members, to be able 

to actually come together physically in person. But 

you know, we're kind of at the mercy of what's 

happening.

Member Ziemer: Well, we have plenty of lead time 

before April, so we don't need to decide right now.

Dr. Roberts: Right, exactly, exactly. Okay. Well it 

looks like --

Chair Anderson: What are the -- what are the August 

dates again?

Dr. Roberts: It is 17th and 18th of August.

Chair Anderson: Okay. 

Dr. Roberts: Okay, great. So again, we have a 
99

teleconference February 16th, which is a Wednesday. 

For April the 27th and 28th of next year. A 

teleconference set for June 15th of next year, and 

then the presumably face to face meeting August 

17th through 18th of next year.

Chair Anderson: Any thoughts about a site for 

August?

Member Beach: Or April.

Chair Anderson: Or April.

Dr. Roberts: Yeah. April would be the in-person.

Chair Anderson: Yeah.

Dr. Roberts: Yeah. Doesn't that kind of depend on, 

you know, various factors that may be too early to 

tell at this point?

Chair Anderson: Well, if we have any sites that are 

going to be discussed or we have SECs to finalize, it 

would be nice to have it near the --

Dr. Roberts: Right, near that particular site.

Chair Anderson: If not, Brad and I will just pick a 

place where there's good fishing.

Member Clawson: Amchitka sounds good.

Chair Anderson: Yeah, I know.

Dr. Roberts: Well, I think we have time to discuss 

and decide, unless people want to offer candidates 

now.

Member Schofield: The Bahamas.

Dr. Roberts: I'm with you, yes. Okay. Well, we can 

circle back to this. But that really concludes the 

business session, unless anyone has anything else.

Member Kotelchuck: Nope.

Dr. Roberts: Okay well --
100

Chair Anderson: Are there any public commenters?

Dr. Roberts: Actually I was given a public comment 

to read into the record, and that's the only thing I 

was contacted about prior to this.

Chair Anderson: Okay. If not we could -- if not, we 

could take a break for 15 minutes.

Dr. Roberts: Yes, and I would just remind, if there's 

-- there are members of the public who do want to 

speak, to please be on the line at 5:30, because we 

will start at that time. And your, your comments 

should be limited to five minutes.

So how about if we reconvene? If we're going to take 

a break Andy, we could come back at 5:25.

Chair Anderson: Okay, sure.

Dr. Roberts: Does that sound okay?

Chair Anderson: I mean unless you could read in the 

public comment?

Dr. Roberts: I think I may need to wait until the 

actual session.

Chair Anderson: Okay.

Dr. Roberts: So I think I'll do that.

Chair Anderson: Then let's come back at 5:25.

Dr. Roberts: Okay, great. Thank you.

(Whereupon, the above-entitled matter went off the 

record at 5:14 p.m. and resumed at 5:26 p.m.)

Chair Anderson: Okay.

Dr. Roberts: Okay, let me just check in for the court 

reporter. Are you on? Okay, thank you, and Andy, if 

you don't mind, I can do a quick roll call.

(Roll call.)
101

Dr. Roberts: So Andy, I have a quick question for you 

just to kind of get coordinated. Did you want to run 

the comments session? 

Chair Anderson: No, you can. I mean is there any --

I don't -- you're going to read one in. If not, you just 

-- you just do it.

Dr. Roberts: Okay, that sounds good.

Chair Anderson: But if we had a list of names, I'd be 

happy to go forward, but we haven't got that.

Dr. Roberts: Yeah, yeah. Not this time, and like I said 

I got the one comment. But yeah, maybe I should 

wait until everybody's back at 5:30 and if we don't 

hear from anyone else, then I just read it Andy.

Chair Anderson: Okay, great. 

Dr. Roberts: So just sit tight for a couple of minutes.

Chair Anderson: Anyone else have any issues under 

Board work that are -- they would like to raise?

Dr. Roberts: Actually, I did want to make mention 

about the circulation of the current membership for 

the Work Groups and the Subcommittees, and Josie 

yes, I remember that you made a comment about 

something being missing. I also received some other 

comments about people either not being on the Work 

Group that they were noted as being on and etcetera.

So what I'm going to be doing is cleaning up the 

membership list and recirculating it, just so we can 

be clear of who's in what groups and then make sure 

that all the groups are listed. So that's just an FYI.

Public Comment

Dr. Roberts: Okay. I'm going to pull up the note. 

(Pause.)

Dr. Roberts: Okay. So I have 5:30 Eastern Time, and 

I just wanted to welcome everybody back. This is the 
102 

Public Comments Session, and so if there are any 

members of the public who would like to make a 

comment, please feel free to do that now. And again, 

you have about five minutes to complete your 

comment. So would anyone like to?

Ms. Degarmo: My name is Denise DeGarmo, and I 

would like to make a comment.

Dr. Roberts: Sure, please do.

Ms. Degarmo: Okay, good afternoon. Let me take a 

minute to introduce myself. I'm Dr. Denise DeGarmo, 

the Petitioner Representative for the Pinellas Plant on 

SEC Petition 256, which is currently in the evaluation 

process.

NIOSH has said it expects to release this report in 

September, meaning it could be under consideration 

during the December Board meeting. Thank you for 

allowing time for public comment. Many of you may 

know me. For those who may not, I'm the recipient 

of numerous grants which helped fund over 20 years 

of research on nuclear weapons facilities and their 

workers, and I've had the honor of presenting my 

research globally.

I received my Ph.D. in Political Science from the 

University of Michigan-Ann Arbor in 2001, which a 

specialty in International Relations, a focus on 

security and nuclear weapons and comparative 

politics, and (audio interference) financial resources 

in the environment. 

I'm a professor emerita in the Department of Political 

Science at Southern Illinois University-Edwardsville, 

where I taught for more than 15 years. During my 

career, I've successfully published over 30 peerreviewed books, journal articles and government 

publications. 

In the past, I've conducted research for former 

President Barack Obama when he was the junior 

Senator from Illinois, and former Congressman John 

Shimkus, also from Illinois, regarding the Dow 
103

Madison Special Exposure Cohort Petition, and some 

of you may be familiar with my work on that petition. 

As the primary petitioner on the Pinellas Plant SEC, I 

would like to make a few comments regarding this 

petition, in the hopes you will take my comments into 

consideration between now and the December Board 

meeting. The overall history of General Electric's 

Pinellas Plant and its contribution to the United 

States' nuclear ambitions is well-documented.

In short, the primary mission of the Pinellas Plant was 

to produce precisely timed neutron generators, which 

served as the triggers for nuclear bombs. While ooh 

and ahh over the brilliant technological 

advancements made at this nuclear weapons facility, 

we seem to have forgotten the names and faces of 

those workers who made these accomplishments 

possible.

Rather, we have reduced them to a claims number 

used to process them through the burdensome 

program known as the DEEOIC. Let me provide you 

a brief introduction to some of those workers who will 

be affected by your decision, whether it is in 

December or later.

A Sunday visit to Pinellas most certainly involved a 

trip to church with Worker No. 1, when no one else 

would listen to his pleas for help while suffering from 

excruciating pain and disfigurement associated with 

incurable squamous cell cancer of the salivary 

glands. God was his last hope. The only thing that 

eventually released his suffering was his death.

Worker 2 suffered from multiple bouts of breast 

cancer, in which she was left disfigured, sorry. In 

which she was left disfigured. Although frail, she 

never hesitated to engage in conversation around the 

kitchen table. We focused on days spent at the 

Pinellas Plant, remembering the friends who died 

from cancer, praying for those friends who were still 

alive but infirm, and how plant managers had a 

cavalier attitude towards safety and downplayed 

workers' exposures.
104

Worker 3 became a second parent to me. We spent 

hours drinking coffee, reminiscing about her days at 

the plant. She was never quite sure what she worked 

on, but was told it was classified. She spoke often 

about her spouse, who also worked at the Pinellas 

Plant, and he died from brain cancer. I was at Worker 

3's side when the doctor told her he had found a 

malignant neoplasm of her upper lobe and left 

bronchus. When Worker 3 succumbed to the cancer, 

I was holding her hand.

Worker 4 died from invasive pulmonary 

adenocarcinoma. Worker 4 and I would always meet 

at the local IHOP. We drank coffee and ate pancakes 

while discussing the details of his employment at 

Pinellas. He was so excited when he was hired by 

General Electric because GE offered good pay and a 

health benefits package.

Worker 4 had no idea that his job would expose him 

to some of the most dangerous radioactive materials 

on earth. He was furious that Pinellas Plant allowed 

him to be exposed to radiation without his knowledge 

and consent. Unfortunately Worker 4 passed away 

suddenly, only hours after our last breakfast date.

The basis of the Pinellas Plant SEC Petition 256 rests 

on a little-known report entitled "The Department of 

Energy Environment Safety and Health," dated May 

1990, the Tiger Team assessment of the Pinellas 

Plant. The Tiger Team descending on the Pinellas 

Plant on January 15th, 1990 with the mission of 

providing independent oversight and assessment of 

the compliance and management of environment 

safety and health programs, while identifying root 

causes for non-compliance.

When the Tiger Team completed their mission at 

Pinellas, there were 177 findings. Obviously I don't 

have time to discuss all 177 points, so I will limit 

myself to the key findings of the Tiger Team that 

impacted the health and safety of workers.

Workers were exposed to hazardous airborne 

particulates because the ventilation systems were 
105

not tested and maintained in a manner consistent 

with generally accepted industrial practices. The 

radiological safety controls associated with the 

accelerator and X-ray machines were lacking in 

formality and were not in compliance with generally 

accepted standards.

The personal dosimetry program at Gen did not 

ensure personal radiation exposures were accurately

determined and recorded. Accreditation of the 

dosimetry system was not completed, along with the 

formalization of employee exposure investigations by 

1990, as required by DOE Regulation 5480.11.

The facility and site did not ensure effective 

implementation and control of radiologic protection 

activities. The Health Physics internal appraisal 

program was not in accordance with the DOE 

Regulation 482(1)(b), Section 9.D and DOE 

Regulation 5480.11.85. The radiologic procedures at 

Pinellas Plant did not provide for the control and use 

of radioactive materials and radiation-generating 

devices in regard to safe operations.

The plant lacked formal documentation of 

investigations into personal exposure anomalies, and 

supervisors were not required to acknowledge the 

facts surrounding the assignment of radiation 

exposure to their personnel. The contamination 

control program did not ensure that workers were 

protected from unnecessary radiation exposures. 

The bottom line is that this report calls into question 

the ability of NIOSH to accurately estimate radiation 

doses for employees. The dedication of the Pinellas 

workers to serve their country in a time of need 

translates into their extinction. As you know, they 

died from their war wounds, cancer.

Cancers resulting from years of radioactive exposure 

they knew nothing about. Their medals of honor 

consist of breathing tubes, ostomy bags and scars of 

cancer surgery. Their fight for freedom has relegated 

them to wheelchairs and walkers. Please remember 

that there are real people behind the claims numbers 
106

and medical diagnoses.

This special exposure cohort petition, Petition 256 is 

for them and should be approved. This SEC has 

certainly been a collaborative undertaking between 

worker and researcher. I could not have written this 

petition without the support of the workers of the 

Pinellas Plant.

Another person who proved invaluable to the petition 

process is NIOSH SEC counselor Josh Kinman. I 

thank him from the bottom of my heart for providing 

clarity and insight into a very difficult submission 

process. He was a great sounding board. Josh, you 

are a wonderful asset to the NIOSH organization. 

Thank you to the NIOSH staff health physicist and 

others for reviewing this petition in the most 

thoughtful of ways. 

I'd also like to thank Oak Ridge Associated University 

as providing a safe environment in which workers 

were interviewed. They finally felt that someone was 

listening to them. I hope you will do the same for 

these workers as you consider this Petition when you 

receive the report. Thank you, and I will be 

submitting a written copy of my statement for the 

official record.

Dr. Roberts: Thank you so much. 

Ms. Degarmo: Thank you for the opportunity. 

Dr. Roberts: Is there anyone else in the public that 

would like to register for comments? 

Ms. Hand: My name is Donna Hand.

Dr. Roberts: Hi Donna.

Ms. Hand: Yes. I'd like to also put in some comments. 

Specifically, is that the Board has statutory duties 

and that must be done, and part of that is to 

recommend the SEC. According to the regulations, 

once the SEC has been accepted or qualified, then a 

full evaluation will be done. 
107

Right now, we're just having the evaluation done by 

NIOSH, where in the past you would have the Work 

Group and SC&A do it at the same time as NIOSH. I 

wonder how come the Pinellas Plant SEC is not 

getting that same treatment. You're waiting for the 

report from NIOSH itself, and it's been delayed and 

delayed and delayed.

Again, the NIOSH are the -- the stipulation in this 

action is 180 days. Well, once they receive the 

Petition, and it's been going along a lot longer than 

180 days. This information has been at NIOSH. This 

information has been at the Working Group. 

Whenever the Working Group held meetings, we 

(audio interference) the Site Profile Technical Basis 

Documents.

This information was brought to previous SEC 

petitions, that it has been qualified for the Petition 

now, the 256. You also know that the metal tritides 

at Pinellas Plant, there's five different ones. You also 

know that they, you know, the tritium was not only 

the gas but -- and the heavy water everything, but it 

was also the particles itself, the plate.

Peter Darnell, the previous person at NIOSH that was 

qualifying whether, you know, you can do the dose 

reconstruction or not as well as Brian Gleckler and 

even Grady Calhoun, was well aware that they had 

problems with it (audio interference). You also have 

documentation in the file since 2004 that the tritium 

dose ranged from anywhere between 6 millirems all 

the way up to 398 millirems, but yet they took the 

average of 126 millirems. Then all of a sudden they 

said no, we're only going to use 100 millirems.

Again, this is just using the information based on the 

(audio interference) files, and that the actual site 

itself or the documentation from the site itself. That's 

the problem that you have. The basic law says to 

characterize the working environment that the 

worker is in. 

So I don't know if you care if you're a construction 
108

worker, you're maintenance, if you're a janitor or if 

you're the actual person that worked on the trigger 

itself, you know, doing the metal tritides, the 

supervisor.

What was their environment that they were working 

in? Can you characterize it? None of the radiation 

doses of the Pinellas Plant workers are given a 

neutron dose, and the law says you shall have the 

neutron doses. They're not given any of the radiation 

devices that generate radiation, you know, like the 

industrial X-rays that they have to look through to 

see, make sure the (audio interference).

So these issues here, as well as Landau badges 

saying that, you know, we had to send them back,

we couldn't read them. That was all in the 

documentation that was received by NIOSH in 2004, 

because when I did a Freedom of Information Act, it 

took them two years to copy all that material, and I 

have three Banker boxes full of that information that 

you have.

You also stated that the RTGs, well we're not going 

to, we don't have to do those because they were 

already encapsulated and there were still thermal 

neutrons getting out. They did the encapsulation of 

the equipment themselves right there. It was a 

warehouse-type facility. They didn't have, you know, 

the cubicles.

So again, I would request that we have a task to 

where a Working Group and SC&A do an evaluation 

at the same time, so when this comes before the 

Board, the Board will have all the information to 

decide on the SEC. Thank you.

Dr. Roberts: Thank you for your comments. Anyone 

else care to comment at this time? 

Well not hearing anyone at the moment, I'll go ahead 

and read the comment that was sent to me. 

"Good evening Dr. Anderson and members of the 

Board. My name is Terrie Barrie from the Alliance of 
109 

Nuclear Worker Advocacy Groups. Thank you for this 

opportunity to make public comments.

"I raised concerns at the last Board meeting in April 

about NIOSH's use of the NOCTS database for their 

co-exposure models. My opinion hasn't changed 

since then, despite reading NIOSH's and SC&A's 

reports. Let's take a look at the practical side of using 

this database.

"NIOSH says in the 2016 revision of OTIB-0075 that 

the complete data set for Y-12 contains bioassay 

information for 7,527 monitored workers. The NOCTS 

database only contains information for 1,585 

claimants. In other words, only 21 percent of the 

monitored workers have filed a cancer claim five 

years ago.

"Cancer claims are filed every day with DOL. DOL 

sent 6,582 cases to NIOSH over the years, with 197 

cases currently at NIOSH as of 8/8/21. There may be 

more cases at NIOSH this week, but DOL did not 

update that page before I submitted these 

comments. 

"I'm pretty confident that more claims have been 

sent to NIOSH since 2016. Has NIOSH updated the 

number of bioassay information to reflect this? How 

are they going to handle receiving new bioassay 

data? Will they revise the methodology, the plan 

weekly as they collect new bioassay records from a 

new claim? How would this be less labor intensive 

than using the complete database?

"And if NIOSH doesn't plan on updating the 

methodology weekly, how would that be claimantfriendly let alone be a reasonable method for dose 

reconstruction? Historically, NIOSH as always 

assumed that the bioassay and any other monitoring 

data they have for a site is accurate and followed the 

best practices of the time. I do somewhat understand 

that it may be acceptable, but some data may be 

excluded for one reason or another.

"But the footnote on page seven of the OTIB says 
110 

that NIOSH excluded five workers with extremely 

high urine results from the complete database. Their 

reason is that if they included those five workers with 

extremely high urine results, 'that the claimant data 

set would always agree with the complete data set.'

"Like I said, I do understand that it is not unusual for 

statisticians to not include some data. What I don't 

understand is why the exclusion of the workers with 

the high urine levels would be a fair analysis. 

Obviously, NIOSH thinks the records are accurate. 

Otherwise, I think they would have mentioned that 

they weren't.

"I also have a concern that workers, that if the 

complete data set is not used, it is likely that 

monitoring data will be missed and skew the entire 

methodology NIOSH comes up with. For example, I 

know a Rocky Flats worker who publicly testified that 

he had one of the highest systemic burdens of 

plutonium at Rocky Flats. He did not have cancer, so 

no claim was filed.

"If only the information from NOCTS is used, his 

bioassays would not have been used in the claimant 

data set. He did not work alone. He had coworkers 

who would have experienced the same exposure as 

he did. How can NIOSH claim that this is an effective 

way to develop dose reconstruction methodology 

that would be reasonably accurate? I thank you for 

this time to offer my comments."

Okay, and that's the end of the comment. So I'll ask 

again if there's anyone else in the public that would 

like to comment at this time?

Okay. Well I'm not hearing anyone at the moment, 

so let me hand it back to you, Andy.

Chair Anderson: Okay. I'll accept a motion for us to 

adjourn until tomorrow at 1:00 p.m. I think it's the 

same dial-in or connection numbers. We don't need 

a new one?

Member Ziemer: So moved.
111 

Member Beach: Seconded.

Chair Anderson: Okay. We're ready to go.

Member Clawson: Let's do it, come on. Okay.

Chair Anderson: Have a good evening everyone.

(Whereupon, the above-entitled matter went off the 

record at 5:50 p.m.)