NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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

Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

Savannah River Site (SRS) and SEC Issues Work 

Groups Joint Meeting

Tuesday, March 23, 2021 

The Work Group convened via video teleconference, 

at 10:30 a.m. EDT, Bradley Clawson and Henry 

Anderson, Chairs, presiding.
. 

2 

Present: 

Bradley Clawson, SRS Work Group Chair

Henry Anderson, SEC Issues Work Group Chair

Josie Beach, SEC Issues Member

James Lockey, SRS Member

Gen Roessler, SEC Issues Member

Phil Schofield, SRS Member

Paul Ziemer, SEC Issues Member

Also Present: 

Rashaun Roberts, Designated Federal Official

Nancy Adams, NIOSH Contractor

Terrie Barrie

Bob Barton, SC&A

Ron Buchanan, SC&A

Grady Calhoun, DCAS

John Cardarelli, DCAS

Nancy Chalmers, ORAU Team

Josh Fester

Joe Fitzgerald, SC&A

Rose Gogliotti, SC&A

Richard Griffiths, SC&A

Roger Halsey, ORAU Team

Warren Johnson

Mike Mahathy, ORAU Team

Jenny Naylor, HHS

Chuck Nelson, DCAS

LaVon Rutherford, DCAS

Tim Taulbee, DCAS
. 

3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Savannah River Site 

(SRS) and SEC Issues Work Groups Joint Meeting 

Tuesday, March 23, 2021 1

Roll Call/Welcome 4

Bioassay for Subcontractor Construction Trade 

Workers at Savannah River Site 1972 -1997 6

Bootstrap analysis of SRS Bioassay Data 74

Petitioner Comments 126

Board Correspondence 131

Work Group Discussion 141

Adjourn 154
.

4

Proceedings

(10:30 a.m.)

Roll Call/Welcome

Dr. Roberts: I do have 10:30. So I want to wish 

everybody a good morning. This is the Advisory 

Board on Radiation and Worker Health. I'm Rashaun 

Roberts. I'm the DFO for the Advisory Board.

And this is a joint meeting of the Savannah River Site 

Work Group and the SEC Issues Work Group. I want 

to let you know, as per usual, that the agenda and all 

of the background materials and presentations for 

this meeting are on the NIOSH website if you look 

under the scheduled meetings, today's date. These 

materials were also distributed to the SRS and SEC 

Work Groups prior to today. So if you've taken a look 

at today's agenda, you'll see that the meeting is 

primarily focused on the Savannah River Site.

Before we officially move into that business, let's do 

roll call. And I would like all Working Group Members, 

NIOSH, SC&A, and others to address conflict of 

interest. However, to simplify things a little bit, I'll 

speak to conflict of interest with regard to Members 

of the Savannah River Site Work Group. In order for 

them to serve on the Work Group, they can't have 

any conflicts of interest. 

So, with that, let's go ahead and move into roll call. 

(Roll call.)

Dr. Roberts: Okay, excellent. Well, thank you, and 

welcome again to all of you. I do need to go over a 

couple of additional items before I give the floor to 

Brad Clawson, who's the Chairperson for SRS.

In order to keep things running smoothly and so that 

everybody can everybody can be clearly understood, 

everyone please mute your phone. If you're 

participating by phone, please mute it, unless, of 
.

5

course, you're speaking. If you don't have a mute 

button, press *6 to mute, and *6 to take yourself off 

mute. If you're on Zoom, the mute button is at the 

bottom lower lefthand corner of your screen. Also, to 

make sure that you're muted, using that button to 

take yourself off mute, you'll have to press it again.

Also, in the interest of maintaining a productive 

meeting and to ensure that we also get a good 

transcription of this meeting, I ask everyone to 

please be patient with this process. And please do not 

interrupt people when they're presenting or 

speaking. Everyone, from the presenters to the 

petitioners and members of the public, should be 

given the opportunity at their designated times on 

the agenda to make whatever points they're going to 

make so that things can move forward. And I really 

would like to thank everyone in advance for 

observing this courtesy to others throughout this 

meeting.

So, once again, if you didn't hear earlier, the agenda, 

the presentations, and other materials that are 

relevant to today's meeting can be found on the 

NIOSH website so you can follow along. So, without 

further delay, I'll go ahead and turn the meeting over 

to Mr. Brad Clawson.

Chair Clawson: Thank you. Can everybody hear me, 

okay?

Dr. Roberts: You're a little low for me.

Chair Clawson: Well, I'll see what I can do to better 

that.

Dr. Roberts: That's better.

Chair Clawson: Anyway, let's just do a little bit of 

background because we have a motion that has been 

tabled to the Board for SRS. And we've come up that 

we need to evaluate and we've had SC&A evaluate 

part of the bootstrap, whatever that was process, and 

I believe it was 94 and 92. 
.

6

Anyway, and so without further ado, according to my 

agenda, NIOSH is going to start out and give their 

discussion, and then SC&A will report on theirs. So, 

Tim, is it going to be you or it is going to be John.

Dr. Taulbee: It'll be John speaking.

Chair Clawson: Okay. John, I'll turn the time over to 

you then and let you go from there. All right.

Mr. Calhoun: This, this Grady. Can I say a few things 

real quick?

Chair Clawson: Sure.

Mr. Calhoun: I just want to make sure that, in the 

interest of time, we make sure that we got plenty of 

time at the end of this thing. And if the Work Group 

decides that they still want to go forward to add a 

Class, we to make sure that we understand what the 

basis is.

And then I will help to write that. Not necessarily that 

I will agree with it, but I will try to write whatever 

you guys decide on just to kind of streamline the 

process. I just want to make sure we've got time at 

the end for that. And that's really all I have to say.

Chair Clawson: I understand that, Grady, and I 

greatly appreciate that. That's very kind of you. We 

kind of did a straw man on it a little while ago. So 

that'll probably be one of the basis of where we'd 

start that at. But, yes, we'll try to get through this.

I really don't, after all the reading that I've done, I 

have not seen anything that has really changed. A lot 

more data, everything else out there, but not the 

substance or criteria that I feel that we need. But 

we'll take that in consideration and I'll turn it over to 

John.

Bioassay for Subcontractor Construction Trade 
.

7

Workers at Savannah River Site 1972 -1997

Dr. Cardarelli: All right, thanks, Brad. Thanks, Grady. 

I'll share my screen here. Hopefully, everyone should 

just be able to see the presentation for "Bioassay for 

Subcontractor Construction Trade Workers at the 

Savannah River Site from 1972 to 1997." I believe 

that's showing appropriately here.

And this is basically RPRT-0094, which we talked 

about a little bit in the previous meetings back in 

November and December. It's a brief summary of 

that presentation that was written by Roger Halsey, 

one of our contractors with Oak Ridge Associated 

Universities.

And the overview, it will simply be defining what the 

purpose of that original RPRT-0094 was, our results, 

and a summary of the conclusions. So, really, the 

purpose of RPRT-0094 was to extend the period of 

evaluation of SRS subcontractor bioassay data 

completeness.

We were looking at 1989 to 1998, in one of the 

previous reports, and we extended that as early as 

1972 that went up through 1997. So really, the 

purpose was to look at how complete the data would 

be for developing a co-exposure model and applying 

that for dose reconstruction purposes.

In this particular basic analysis, we only looked at the 

NOCTS, which is the claimant data for NIOSH. And 

we wanted to basically understand any trends 

associated with the radiological monitoring of the 

subcontractors in this particular subgroup of workers.

Now, what is our NOCTS data from the construction 

trade workers perspective? Right now, our coexposure models are all construction trade workers 

combined together. That would be the DuPont, or the 

prime construction trade workers with these 

subcontractors.

And that's what we call all construction trade 
.

8

workers. You're either exposed or you're not 

exposed. If you're not exposed, there's possible, it's 

likely you could have been monitored simply because 

you were in an area that potentially could have 

presented you to an external radiation where you put 

a dosimeter on.

So you would have been monitored. And if there was 

no exposure, you would be not exposed. And then, 

you could become a claimant., if you filed. Obviously, 

if you're not exposed and you remote monitored, you 

could still become a claimant. If we go -- I'm getting 

a feedback. Okay.

If we look at the exposed category of all construction 

trade workers, you either monitored or not monitor, 

similarly with the non-exposed. And obviously, if 

you're exposed and monitored, those are the type of 

information we would gain an understanding of how 

well the monitoring practices were at the site.

There may be circumstances where you were 

exposed and not monitored. And in that case, we 

would be using the co exposure model to help apply 

those reconstruction efforts to account for the nonmonitored workers there.

All right, so what did we find in this basic data 

accountability review? This is one of the charts from 

RPRT-0094. The white part is the all other claimants, 

which is everyone in 1972 through 1997 that filed 

claims.

Then we show with the blue what percentage or what 

number, the number of SRS claimants that are actual 

subcontractor construction trade workers of that. And 

you can see it's a small proportion in the early 70s 

and it builds up somewhere in the mid-'80s, and 

begins to slightly decline.

And really what you can take away from that is 

simply that's just the way that the monitoring 

philosophies and practices were. they used 
.

9

subcontractor trade workers at different periods of 

time and at different frequency.

So it's just to give you a big picture view of, that we 

do have data associated with subcontractor trade 

workers covering the entire time period that we're 

claimants.

Member Lockey: John, Jim Lockey. Can I ask a 

question about that slide? Just as -- just as --

Dr. Cardarelli: Yes.

Member Lockey: So what all other claimants are 

contractors, right? Prime contractors and 

subcontractors together?

Dr. Cardarelli: Yes. They could be, they could also be 

non-construction trade workers. These are all claims.

Member Lockey: It's all claimants from the facility, 

whether construction, subcontractor, or prime 

contractor, or anybody else?

Dr. Cardarelli: Correct.

Member Lockey: Okay.

Dr. Cardarelli: So in 1972, there was just under 2,000 

claimant. And then, there was around 100, 

subcontractor construction trade workers in that 

particular population. It's very straightforward.

Now, if we wanted to just look at subcontractor 

monitoring within the claimant population, we had 

somewhere on the order of almost 6,100 total SRS 

claimants throughout this time period. Of that around 

900, or 15 percent were subcontractor construction 

trade workers.

And most, if not all, of the job titles of the 

subcontractor construction trades are represented. 

So we are missing a particular occupations, which is 

a key factor in understanding whether or not, you 

know, do we need to evaluate occupations that were 
.

10

not monitored.

And here, we're showing you that just about every 

occupation had some monitoring associated with or 

are in the claimant database. So we've looked at 

those who were externally monitored, because you 

would receive a dosimeter if you have any potential 

of going into a radiological area.

And then, we looked at those with internal 

monitoring, and we broke them up, basically, on 

tritium bioassay, non-tritium, which would be the 

plutonium, uranium, and fission products, actinides 

things of that nature.

And then, whether or not you had any hope on 

counting data because that's another way we can 

characterize your potential for internal exposure.

Member Lockey: And before you leave that slide, one 

other question. That 6,097 that represents 

contractors and subcontractors only, right?

Dr. Cardarelli: Which cell?

Member Lockey: At the top 6,097 total SCR 

claimants?

Dr. Cardarelli: Yes, this is the entire claimant 

database that was evaluated between '72 and '97.

Member Lockey: Is that? No. That wasn't my 

question.

Dr. Cardarelli: I'm sorry.

Member Lockey: Does it, is it represented just to 

contractors and subcontractors?

Dr. Cardarelli: Roger, can you give clarity to that? Or 

Tim?

Mr. Halsey: Yes, it is all contractors and 

subcontractors. Any worker who worked at Savannah 

River during those years and made a claim, 
.

11

regardless of who they work for, or what their job 

was.

Member Lockey: Who's a contractor or 

subcontractor, correct?

Dr. Taulbee: It is, yes.

Member Lockey: Because it doesn't represent the 

whole population from the previous slide. It doesn't 

to that. So let's --

Mr. Halsey: I'm sorry, who would be a contractor? It 

represents everybody. The previous slide is 

individuals per year. So it's many people working 

multiple years.

Dr. Taulbee: Yes, if I can explain that a little more, 

Dr. Lockey. What you're seeing in this particular slide 

is that some people worked in every year. Okay, so 

they work '72 through 1982. And so they will be 

counted in each one of those bars. When you go to 

the next slide, John, this is, 6,097 is the total unique 

SRS claimants over that large span.

Member Lockey: Okay, okay. So that really 

represents the individual claimants over that span 

representing the whole population.

Dr. Taulbee: That is correct.

Member Lockey: Okay. Thank you.

Chair Clawson: Hello. This is Brad. Do we have one 

showing all the people that don't have data for too?

Dr. Taulbee: We don't have that depicted. But I 

mean, as far as the total number of workers on site 

that were externally monitored, that could be 

developed. But we don't have that readily available.

We only looked at -- the purpose of RPRT-0094 was 

to look at the claimant database. Those records do 

exist, but you'd have to go back and look at all of the 

population of monitored workers.
.

12

Chair Clawson: Well, the reason why I'm saying this 

is, you're showing we've got 6,097 individuals over 

this time period, and 886 of them are subcontractors. 

And so, that really looks good. But it also does not 

bring up to us how many people we don't have squat 

for.

And then, we come down here to the bottom. And I'd 

like to see, we just got tritium there. What about 

plutonium? What about cesium, strontium? What 

about any of the other ones? We do not -- all we see 

is tritium.

Dr. Taulbee: Well, we combine the, all of the others 

into the non-tritium bioassay. So we summed them 

together. And John will get to that in just while.

Chair Clawson: Okay, maybe -- okay, appreciate 

that. I'll turn it back over to you, John.

Dr. Cardarelli: No problem. I'm glad we're having 

that discussion here.

Member Lockey: Hey, Brad, Jim Lockey. It's okay. 

Because as we go these slides it's easier for me to 

ask questions when the slides up. If that's okay with 

you?

Chair Clawson: What's that? I couldn't hear you 

Lockey?

Member Lockey: Brad, it's easier for me to ask a 

question about a slide when it's on the screen rather 

than going back in time. If that's okay.

Chair Clawson: I understand that. And I agree with 

you fully. And we do have crayons for you to be able 

to help. Lockey, I'm joking.

Member Lockey: I understand. You have to 

understand Brad, I'm hard of hearing, and then, I 

remembered you from Idaho, and I thought maybe it 

has something to do with it. So I wasn't sure.
.

13

Chair Clawson: Yes. Okay, thanks. Go ahead, John. 

I'm sorry.

Dr. Cardarelli: No problem. So a lot of this, I think 

it's very good to ask these clarifying questions 

because it can get very confusing, especially when 

we start talking about percentages, and what those 

mean. And so I invite those type of clarifying 

questions here.

So the focus of the NOCTS data evaluation, we looked 

at the extra monitored subcontractor construction 

trade workers, obviously, because if you went in any 

radiation area, you had a radiation badge.

But that doesn't necessarily mean that all extra 

monitoring, required internal monitoring. There were 

many times people would have been in an 

environment where it, just internal monitoring was 

not a potential exposure, nor required by any of the 

defense in-depth monitoring criteria.

And what I mean by that is, there would have been 

no air monitoring, surface contamination monitoring, 

incident monitoring things of that nature, which 

would require or trigger a special bioassay or even 

require routine bioassays.

So the benefit of this analysis was we were looking 

at all areas. External radiation covers pretty much 

the entire site. Something like 35 areas represents 

data used in our dose reconstruction efforts. And we 

conducted a simplistic internal analysis.

This was just to basically gain an understanding of 

what data we have on existing claimants that were 

potentially internally exposed. So why did we do this 

simple approach? And what I mean by this simple is 

how and why we combined all of the actinides or what 

we call them non-trading exposed workers.

Simply because there are areas at the site where you 

could be potentially exposed, say to plutonium, but 

may never have been exposed to things like tritium 
.

14

or fission products. So, and this would be 

subcontractors in reactor areas, where they would 

likely didn't need plutonium, but they needed tritium 

and vision products.

So another example would be subcontractors and 

plutonium areas that didn't need tritium or 

monitoring. So when you see something on the order 

of 20 percent or five percent, or even 60 percent of 

the workers were monitored, if you take the 60 

percent, that doesn't imply that the other 40 percent 

should have been monitored, and we're not.

It just means that 60 percent of those who were likely 

exposed in that particular area were monitored. It 

doesn't mean we missed 40 percent. So I think that's 

an important clarifying comment when we look at 

these kind of statistics moving forward.

And likewise, subcontractors in tritium areas didn't 

need plutonium or fission product monitoring. So, 

you know, we've got to be careful when we start 

talking about these percentages.

Ask questions so we can clarify exactly what those 

mean. And so, we're asking ourselves this 

fundamental question. Are subcontractors sufficiently 

represented or bounded in the co-exposure 

modeling? If they are, then we can move forward 

with our co-exposure modeling as part of those 

reconstruction effort.

And I keep, want to emphasize right now the current 

co exposure model is all construction trade workers 

combined together. That would be the primes and the 

subs into one co exposure model. Later on -- go 

ahead.

Chair Clawson: John, I have a question. And while 

we're here, because it was a question at the -- it's 

been a question throughout this process. And after 

spending days on these papers, it remains a question 

for me. What about americium? Why do we have such 
.

15

deficient data in americium? What's the explanation 

for that?

Dr. Taulbee: This is Tim, if I could interject an answer 

that for you, John.

Dr. Cardarelli: Please do.

Dr. Taulbee: Okay. Americium, during the production 

era, americium was really a byproduct in a sense of 

the plutonium. Plutonium and tritium were the two 

main products from Savannah River.

And so, when you're producing plutonium, fresh 

plutonium has very low americium content. So they 

were really controlling more for the plutonium than 

the tritium, or more for plutonium and tritium than 

they were for other radio nuclides.

If you saw plutonium, then, you might do for further 

follow up on americium. But the biggest trigger would 

be the plutonium in the HP line, and FB lines, JB lines, 

all of the plutonium processing lines in the canyon 

areas

Simultaneous, there was small amounts of research 

going on in separation of americium as part of the 

californium production processes. These were done 

in three areas at the site, as opposed to the major 

operations that were going on in the canyons.

So these were very small. They were in, 773A, was, 

contains two of the areas. F wing was the primary 

one. Where those areas were, americium would be 

separated from plutonium. So plutonium could not be 

an indicator then.

The other areas would be MPPF, the multipurpose 

processing facility, which was at the tail end of F 

Canyon. And in that particular operation, operated up 

until around 1980 - 1981, and then went into standby 

type of mode.

So this is why you don't see a lot of americium 
.

16

monitoring. Because it was really isolated to three 

areas. And that's why you're seeing such a limited 

amount of americium data.

Member Lockey: So Tim, let me, so I understand 

what you just said. In 773A, in the two areas there, 

it would have been appropriate to monitor for 

americium as a separate radio nuclide in those two 

facilities, is that correct?

Dr. Taulbee: That is correct.

Member Lockey: You cannot use plutonium as a 

surrogate?

Dr. Taulbee: You could not in those areas where the 

separations were being conducted, that is correct.

Member Lockey: Okay. So in, where plutonium was. 

What about in the other areas? Would you use 

plutonium as a surrogate for americium?

Dr. Taulbee: Yes, you could, you certainly could 

because of the, it takes time for the americium to 

build in. And in our TBDs, Technical Basis Documents, 

we assume things like five-year age plutonium or 10-

year age plutonium to get that americium 

component.

And so in those other areas, we can come up with 

claimant favorable assumptions. Because the 

plutonium that's being fresh and being made is the 

dominant one and it hasn't aged for five to ten years 

that the workers are physically working with. So the 

americium component is very low compared to fiveyear and 10-year aged americium. It grows in over 

time.

Member Lockey: It grows in over time. So you're 

using the plutonium as a surrogate, then, is that 

true?

Dr. Taulbee: That is correct. Yes, sir.
.

17

Member Lockey: Okay. Thank you.

Chair Clawson: Tim, I've got a question though. I 

thought that they brought some plutonium back after 

it had been out there in a lot of the processes and 

stuff like that. And I thought they did research on 

some of that. And I thought we were having 

americium, and so forth, coming out of it.

Dr. Taulbee: I don't believe so, Brad. I'm trying to 

remember of any, where they would bring, you know, 

pits back to do anything. I don't believe that that was 

routinely done. It maybe a one off or two off in 773A. 

But I don't, I don't recall that.

Chair Clawson: This is some of the hockey pucks that 

come out of Rocky flats that had been there for a 

while. And they were looking at, my understanding, 

if I read the material right, it was looking at a lot 

more of the decay process that they were getting 

into.

And there's some classified stuff with that. And I just, 

I thought I remember reading that in Savannah 

River, but it could have been one of Rocky flats too. 

But I was under the impression that they had an 

americium issue with that.

Dr. Taulbee: I don't think so.

Chair Clawson: But that being said, we, it's okay. 

We'll won't go there. I thought there was some 

research that was done on that at Savannah River.

Member Lockey: So Tim, one or question. In 773A, A 

and B, in those two sections. What was the workforce 

there? What was the, how was it populated? With 

what? How many workers? what was the populate 

with what? How many workers? 

Dr. Taulbee: Oh, this is coming off the top of my 

head. It would, the total number of workers would 

be, I believe, in the 400 to 500 range, maybe, 600, 

700. But I'd have to go back to the external 
.

18

dosimetry records to try and give you an exact 

number of the number of workers in that area.

Member Lockey: And they weren't construction 

workers, they were other workers, I take it, right?

Dr. Taulbee: That's correct. It was primarily 

researchers, operations, people working inside of the 

laboratory.

Member Lockey: No americium data on those 

workers?

Dr. Taulbee: Yes, sir, we do.

Member Lockey: Okay, thank you.

Dr. Taulbee: I believe Bob Barton has his hand up.

Chair Clawson: Yes, Bob?

Mr. Barton: Thank you, Jim. Yes. Just a follow up on 

Dr. Lockey's question, which just mentioned that 

we'd be using plutonium as a surrogate or indicator. 

That's not currently how it's constructed, though.

I mean, you have an americium co-worker model. So 

we're not using a radio or plutonium bioassay, 

currently. Is that NIOSH's plan potentially moving 

forward?

Dr. Taulbee: Current dose reconstructions, if we've 

identified somebody is in, working in the F area or 

the canyon areas, and they don't have americium 

monitoring, we do assume a five-year age or a 10-

year age.

Correct me, if I'm wrong, somebody from the ORAU 

Team. But that is what we assume, currently, for 

those workers, that they are -- for the americium 

component. Okay? If they've got plutonium 

monitoring in those areas in those areas.

Mr. Barton: So you wouldn't apply the exposure, 

then?
.

19

Dr. Taulbee: Not currently, no.

Mr. Barton: Okay.

Dr. Taulbee: I guess, just to clarify just a little bit, I 

mean, if we've got indication, they worked at MPPF 

with separated americium, or if they worked in 773A 

in the F wing, you know, from their caddy or from 

other indicators, then, yes, we would apply the coexposure model. Okay? For those three areas where 

americium was separated, and plutonium is not a 

good indicator. Okay?

Mr. Barton: So the co-exposure model that has been 

developed, thus far, for americium, that's only going 

to be applied by evidence that they were in one of 

those three separations areas?

Dr. Taulbee: That's correct.

Mr. Barton: Okay.

Dr. Cardarelli: Okay. Thanks, Tim. In RPRT-0094, we 

have on the order of 886 subcontractors with their 

detailed work histories that are kind of color coded. 

This is just an example of -- if we go on the left you 

see the craft. We have three electricians, an insulator 

and a labor.

The second column is the internal monitoring 

evaluation. And that's really driven by the color 

coding. So green would indicate that they did have 

internal monitoring. That could be for plutonium, 

uranium, active tritium, you name it.

The red would mean that there is no information that 

they were monitored for internal exposures. And the 

yellow would simply be that they were employed 

sometime after 1997 and we may not have 

information on that.

So if we looked at 1984, the top electrician, the end, 

as you see in the legend, would be a non-tritium urine 

bioassay. Now, that could be plutonium, uranium, 
.

20

fission products, or any of the actinides.

And that's just basically to give us an indication that 

some workers, this worker was monitored for some 

internal radio nuclide that was not tritium. But you 

can see in 1981, they were monitored for extra 

radiation and a tritium. And then, in '82, they were 

not, they had a non-tritium urine bioassay.

And as you go across, the ND, would be there's no 

data because they were not employed that year, or 

the NEI would be, simply is not employed. There's no 

external or internal monitoring there. I'm sorry, they 

were employed, but they had no external or internal 

monitoring.

So we looked at 880, 800 and I think 86 

subcontractors. It's in the back of the report. And it 

was a quick visual way of indicating. If you see a lot 

of green, there was a lot of internal monitoring. If 

you see a lot of red, there was no internal monitoring, 

but there was potentially external.

And it's just a visual way for us to quickly gain a big 

picture of a very large group of subcontractor trades. 

So we think that was a useful tool and I wanted to 

present this here in this presentation. It was also 

described by Tim in the last presentation he gave.

Moving on, one of the key takeaway points here, is 

this is looking at the radiation work permits, which is 

an area of a lot of interest. And this one is associated 

with plutonium analyses only. And that's the purple 

bars from '72 through 1998.

And you'll notice that the purple bars are missing in 

the mid-1970s. And again, in the 1989 to 1990 

period, largely because we either don't have any job 

plan data, we couldn't find it or doesn't exist. And 

there's no radiation work permit data.

However, if you look at the green bars, that's not this 

data. And we are showing that we can fill in these 

missing gaps using claimant data and the bioassay 
.

21

data that they provide. So there's ways for us to fill 

this in.

And one key takeaway might be, if we had no 

radiation work permit across this entire period, we'd 

still have a tremendous amount of data to be used 

for co-exposure modeling, and dose reconstruction 

purposes. So it's a nice to have, but it's not required. 

Any comments or questions? Tim, I see your hand 

up. You're on mute.

Dr. Taulbee: Yes, sorry. I just wanted to emphasize 

that the 1980 to 1988 was not for the full site. That 

is just 773A. Okay? I just wanted to point that out to 

make sure everybody's clear of that.

The 1991 through 1998, purple bars are for the full 

site. Okay? Now, the NOCTS data is just globally in 

all. And Dr. Lockey and Brad, both of you went off 

mute. So I think you have questions.

Chair Clawson: Yes, I do. So in our co-exposure 

model, what does it require you guys to be able to 

provide for us to be able to say completeness. What 

are the requirements?

Dr. Taulbee: Okay. In the co-exposure 

implementation guide, it is do we have monitoring 

data that covers all of the potentially exposed job 

titles and the facilities that they could have worked 

in? Do we have evidence of that? And that's -- thank 

you, John, for going to that slide.

And this is where we looked at all of the workers that 

are currently claimants and do we see any missing 

crafts or trades? We don't. And that's what is shown 

right here. And so, that's, that's the key component 

here. Are we seeing that people are missing?

And if you recall the example I gave back in 

December, with the Nevada Test Site when they did, 

when we looked at that particular data, we found that 

only security guards and radiological technicians 

were monitored. And only a couple of crafts were 
.

22

monitored. So there was missing people. Okay?

So that means that the data set was incomplete. We 

don't see that here when we look at the NOCTS data 

set. We're seeing all of the crafts being monitored 

here. And when we look at the areas that -- go back 

to that final slide there.

Dr. Cardarelli: Which one?

Dr. Taulbee: Actually, this one, and then, the next 

one will be fine. So you see all of the crafts off to the 

left. And we look at, what was there monitoring? Do 

they have internal? Do they have external 

monitoring? And we see that. That's the net appendix 

or our Attachment B of RPRT-0094.

And so, we're looking across the entire time, and 

we're seeing non-tritium bioassay, tritium bioassay. 

We're seeing external monitoring of this workforce. 

And we're also seeing gaps of employment here of 

times when they're not working. We know they're not 

working based upon their DOL history. And so there's 

no reason that there would be monitoring data there.

And so, we're seeing that. Now, if the whole thing or 

if everything was red here, where you see the 

external monitoring with no internal monitoring, that 

would be a significant issue that would speak to 

completeness. Okay? Does that make sense to you, 

Brad?

Chair Clawson: Okay. So that being said, I'm seeing 

electricians here, but I'm not seeing any other crafts. 

Did you just choose just the electricians and then 

labor?

Dr. Taulbee: No. That's just for the example here for 

the presentation. If you go to Attachment B of RPRT0094, you'll see all 886 subcontractors. We've got 

them all listed there. Twenty six percent are more 

electricians, 22 percent are pipe fitters, 9 percent are 

laborers, etc. So you will see all of these crafts in that 

Attachment B of RPRT-0094
.

23

Chair Clawson: Okay. And then, if we go, John to the

last slide there, you're telling -- right there. So 

there's no job plans or data from the '74 up to the 

'80. All we've got is 773A?

Dr. Taulbee:: Actually, from the '74 to 1980, we don't 

even have the data from, or '75 through 1979, we 

don't even have job plans for 773A. That we just had 

no information, whatsoever, if you recall from RPRT0092.

So we couldn't do anything. We can't compare 

anything. But there is NOCTS data. There are some 

trades, subcontractor construction trades that are 

monitored. But if you look, there's very few actually 

monitored during that time period.

Chair Clawson: Somebody was talking. Go ahead.

Dr. Taulbee: What you'll see is that there's much, 

there's many, many less, that's a terrible English, 

sorry. There are less subcontractor construction 

trades in those years of '77, '78, and '79. Especially, 

compared to what we see in the 1980s and 1990s.

Member Lockey: Tim, Lockey.

Dr. Taulbee: Yes, sir.

Member Lockey: So, you know, throughout all these 

documents, the other question that always comes to 

my mind, and I think SC&A have raised it, or pointed 

it out in different ways. Is that, this period of time, 

particularly from '77 to '79, is problematic.

The data that I'm looking, here, is, this is non tritium 

data, correct?

Dr. Taulbee: That is correct.

Member Lockey: Okay. So do you feel that in that 

timeframe, in the '74, '75 up to '79 timeframe, you 

have adequate data there, in that timeframe do a coexposure model?
.

24

Dr. Taulbee: We do because we've combined the co 

exposure model for all construction trades, and we 

have a lot of maintenance and E&I technician, people 

who were doing work that were DuPont construction 

in that time period that we feel we can bound the 

doses in that time period for those particular workers.

That's the basis as to why. If you separate out to 

where we can't combine the DuPont construction 

trades and the subcontractors, then no, I would 

agree with you that we do not have sufficient data 

here.

Chair Clawson: Hey, Tim, when you -- and no 

disrespect, but, you know, so many times I've heard 

we have sufficient data. What are we talking number 

wise? Because we've come to find out sometimes the 

sufficient data may be 20, 20 points or something like 

that, which, for a site like this, I don't feel as 

substantial.

Dr. Taulbee: Well, there's -- I'm having difficulty 

answering your question here Brad. Because there 

isn't a definitive number. Okay? As to what we use 

from that standpoint. We try to use more than 30 for 

the model.

But if you have a random sample that is truly 

random, then, you can do it on less. You can get the 

same results. So there isn't a definitive number from 

that standpoint. We've used the NOCTS data because 

it was the most convenient to use without having to 

go through a large amount of data coding.

We know there's more data available. If you looked 

at the slides that I presented back in December, 

where we're presenting the total number of 

plutonium bioassay, we know there's, there's more

data than what we used in our co-exposure model 

that is available that could be coded and used from 

that standpoint.

And when we did the comparisons, what we found 
.

25

when we added more data, the numbers didn't 

change significantly. So that's, that's why we feel I 

mean, good about those areas.

Chair Clawson: Well, let me throw something out that 

kind of bothers me because you can go into DOL and 

look at the occupational radiation dose for 1986 for 

Savannah River, and it says 18,936 people.

Dr. Taulbee: What do you? I'm sorry. What are you 

looking at?

Chair Clawson: DOL Occupation Exposure Report For 

1986. And if you go down and look at it, individuals 

over there, Savannah River, you look and there's 

18,936 people.

Dr. Taulbee: Okay.

Chair Clawson: So, you know, that's a fair amount of 

people too. And granted some, you know, that's just 

the ones that are being monitored. We don't have 

that.

Dr. Taulbee: John, if you could go up a few slides to 

your external monitoring one, that one. And what 

you'll see there in 1986, Brad, to give perspective 

here, is that we have, that's near the peak.

The actual peak is around 1990. But we have about 

2,700 claimants in that time period. Okay? That's our 

claimant population. These are people who got 

cancer and filed a claim with us. Okay?

Chair Clawson: Right.

Dr. Taulbee: So that's where we feel this is the 

population that we're trying to estimate the doses 

from. And so, how many of those workers have 

monitoring data to estimate doses for those who did 

not have monitored? Okay?

Chair Clawson: Okay.

Dr. Cardarelli: So another key factor, though, I'll add 
.

26

to the, from the Implementation Guide, is, it's just 

not the number of data that's available, it's, are we 

having those people most likely exposed being 

properly monitored?

Chair Clawson: Right.

Dr. Cardarelli: And, and that's a key factor in that. 

You can have 1,000. But if it's the wrong group of 

people, that would not be appropriate for conducting 

a co-exposure model. And we believe that the people 

most likely exposed through all of their monitoring 

practices were properly monitored and characterized, 

as you can see in the pie chart here.

So we don't feel like we're missing, folks. And we also 

feel like we're capturing those most likely exposed. 

And a subtlety, it's not critical, but it's important to 

understand that these are conservative numbers, 

especially, what you might see here.

Because we've excluded certain subcontractors who 

went on to become primary contractors. We wanted 

to keep the data set as pure as possible from -- so if 

you were a sub at one point and became a prime, you 

would not be included in this particular thing.

So it's a minor issue, but it just demonstrates that 

you know, that if we looked at in totality, the 

numbers would slightly increase here. So I thought I 

would add that clarification for what we consider to 

be completeness by the Implementation Guide. The 

number and those most likely exposed being properly 

monitored.

Chair Clawson: Okay.

Member Lockey: I have one more question. Go back 

to previous slide, would you? So let me, in 1978, 

what's that 5 percent or something? Ten percent, 

right? Had, you had NOCTS data on, right?

Dr. Taulbee: Yes.
.

27

Member Lockey: Okay. What's the denominator? 

What's the numbers there?

Dr. Taulbee: Okay. The denominator is the number 

of workers externally, number of subcontractors 

externally monitored. Okay, that's the denominator.

Member Lockey: And what is it?

Dr. Taulbee: Let me pull up the report, and I'll get 

you that number here.

Dr. Cardarelli: I think, Tim, on this one, this is the 

number of SRS claimants. And 1978 looks to be 

around, I don't know, 250.

Dr. Taulbee: I don't believe --

Mr. Halsey: If I can jump in. It's 254 in 1978. This is 

Roger Halsey.

Dr. Cardarelli: Yes.

Member Lockey: So, 254 claimants? And you have 

data on 10 percent of them? Is that right?

Dr. Taulbee: Yes.

Member Lockey: So go to, let's 1992. Give me that 

data.

Dr. Taulbee: Around 400.

Mr. Halsey: 434. And let's see, which internal 

monitoring? Oh, I'm sorry, 1992, you said?

Member Lockey: I'm sorry?

Mr. Halsey: 371. And with internal monitoring it 

would be 347.

Member Lockey: So it's 371. And you're --

Mr. Halsey: Wait a minute. I'm sorry. I'm giving you, 

I'm, I'm, I did all internal monitoring and I should 

have done with non-tritium bioassay and whole body 
.

28

count.

Member Lockey: Yes.

Mr. Halsey: I apologize, here. Let me get to the right 

chart, apologize. Okay. It would be, 1992 is 348 with 

external monitoring. And then --

Dr. Cardarelli: NOCTS data is close to 100 percent. 

It's over 90 percent.

Dr. Taulbee: Yes, 330. Is that right? Yes, 330, whole 

body count or non-tritium bioassay for 1992, comes 

out to 95 percent.

Member Lockey: So I guess my question is, I think 

the data from 1981, particularly, is very rigorous. 

We're good. I see that. But somehow, when, in 1979, 

you have 10 percent out of 254. That, you think you 

can do co-worker reconstruction with that type of 

data, in that timeframe?

Dr. Taulbee: Again, it depends upon if the Work 

Group and the Board is okay or accepting of us 

combining all of the construction trades workers 

together.

Because we have a large number of maintenance and 

electronics instrumentation, control techniques, 

technicians, basically electricians that did a large 

fraction of the work that subcontractors did later in 

the 1980s and 90s, in that time period.

If we combine the two together, we have a lot more 

construction trades worker monitoring data. When 

you separate out the subcontractors from it, yes, I 

agree with you that we do not have, I mean, 10 

percent monitoring would not be sufficient from that 

standpoint.

So, you know, if we're constrained where we can't 

combine those two, the DuPont construction and the 

subcontractor construction trades groups together, 

then yes, the subcontractors were not monitored to 
.

29

the degree that we could develop a co-exposure 

model in the 1970s.

Member Lockey: During that timeframe. Okay. Yes, 

and I think having those percentages is very 

informative for me anyway. Because my look at the 

1982, you know, 330 out of 348 is, you know, I would 

publish that any paper in the country. But I would 

have problems with 10 out of 254 as been 

represented during that timeframe.

Chair Clawson: But that being said, this is where we 

get into the difference between the primes and the 

subcontractors because the primes, we, you've heard 

the term turn and burn.

The subcontractors were coming in, they were being 

utilized burnout and sent off. It's especially during 

this time period. So now we've just taken NOCTS, 

which I don't think is representative of the 

subcontractors. And we've just kind of fluffed it up.

Dr. Taulbee: If I could clarify.

Chair Clawson: But let me, let me finish, Tim, on this 

one. The thing is, and it is proven that we were 

running them in there and running them out. It was 

a turn and burn experience for Savannah River.

That's what the construction trades were. And a lot 

of them going back and forth. I think we're just 

putting a bunch of fluff on myself, but. Because I 

think we're covering up what the real issue, what the 

real problem was. Go ahead, Tim.

Dr. Taulbee: Just one minor point of clarification 

here. RPRT-0094 is just subcontractors. So the data 

that you see in the Table 5-4 on page 17 is just the 

subcontractor construction trades.

And that, and where Dr. Lockey, you're talking in '77, 

'78, '79, where we have 5 percent monitoring and 

'77, '78 and 11 percent in 1979, those are just the 

subcontractors. When you get to the 1992, where 
.

30

we're talking the 95 percent monitoring that Dr. 

Lockey was pointing out, those are again, just the 

subcontractors.

That particular table is not adding in the DuPont, 

CTWs. Okay? What makes us think that that five and 

11 percent, in the 1970s is okay is because we've 

later added in the DuPont CTWs. Okay? I just don't 

want to get those two confused there. That table --

Member Lockey: Well, it's pretty easy to be confused, 

because as we go through this, we're from one side 

to the other side. And then, this year, we're using this 

part of it. And then, we're going to be able to use 

that. But --

Chair Clawson: And this table's just subcontractors 

I'm looking at, right?

Dr. Taulbee: That is correct, sir. Table 5-4.

Chair Clawson: But the, you know, the question is, 

remains, do we have enough data to say that 

subcontractors are similar to the prime contractors? 

Right? And when I look at this table, at least during 

that timeframe, it gives me heartaches. Okay?

Dr. Taulbee: I understand.

Chair Clawson: Okay.

Dr. Cardarelli: I think we'll have a little bit more 

detailed data and the follow up bootstrap analysis. 

But are we okay with this particular to move on?

Dr. Taulbee: Yes. I think we're ready for your 

conclusions.

Chair Clawson: Yes, I'm sorry. Yes, we are. Yes, I'm 

good.

Dr. Cardarelli: No problem. Okay. So again, this was 

an evaluation of kind of the overall data as presented 

in NOCTS. And in the 1990s, we observed the high 

percentage of subcontractors were monitored and 
.

31

would be sufficiently represented in a co-exposure 

model.

And the '80s, slightly less but moderate percentage, 

and they were monitored and would still be 

sufficiently representative in a co-exposure model. In 

the 70s, Dr. Lockey, which you mentioned, initially, 

there was a moderate percentage of subcontractor 

trades that were monitored for internal exposure.

However, there's a market decrease, as you pointed 

out in the late 70s, followed by then the surge of 

monitoring in the 1980s. This pattern was observed 

in limited, also, radiation work permit evaluation, as 

we were just talking about the purple and the green 

bars chart.

So with this information, the overall trend that we 

have observed in these data is that the subcontractor 

construction trade workers who were monitored, 

were represented at least as well as other SRS 

workers.

The completeness of the data is more than adequate 

by our definition and the Implementation Guide for 

dose reconstruction purposes and for the basis of the 

SRS co-exposure model.

Now, remember that co-exposure model is a 

combined co exposure model between prime CTWs 

and sub CTWs. So that concludes this presentation. I 

just briefly wanted to for discussion remind folks that 

there are extra slides which kind of give a history of 

the site, some of the radiological control measures 

when they were implemented in time.

How we did some full body count. And there's some 

additional charts that were in RPRT-0094, which I did 

not go over here. But if we do get into those 

discussions, these may be proven to be helpful. So 

with that, I will turn it back over to you to Mr. 

Clawson. For further discussion,

Member Lockey: John, Jim Lockey. Go to your 
.

32

conclusions slide. I have just one question. Who is 

other SR workers here? What's your definition?

Dr. Cardarelli: That would be the, in my, -- it's the 

DuPont prime construction trade workers.

Member Lockey: All right. So this is, other SR 

workers, here, is prime construction workers. Right?

Dr. Cardarelli: Yes.

Member Lockey: Okay.

Dr. Cardarelli: It could, frankly, it could also be for 

non-construction trade. It's, but the overall trends 

were similar.

Member Lockey: Okay. And I think slide 21, go to

slide 21. Is this, is greater than 60 percent of 

construction trade workers had external monitoring 

data, right?

Dr. Cardarelli: Yes.

Member Lockey: Right. And so, if they did not have 

extra monitoring data, that would indicate either they 

should have been monitored, and they weren't, or 

there was no indication for them to be monitored?

Dr. Cardarelli: Yes. I would interpret that is, if you 

were not safe, it's 60 percent. That doesn't mean the 

40 percent were not monitored. It means that they 

probably were not going into radiological area, which 

would require them to have external monitoring.

So they would not have been exposed, rather than 

be potentially exposed and not monitored. That's a 

clarification, I think needs to be understood with the

way to look at this. We're not missing 40 percent.

Dr. Taulbee: If I could state that just a little different 

way. One of the problems with the subcontractors 

coming in is, they would be doing new construction, 

as well. So a lot of our metrics were based upon those 

who are externally monitored. It was required if 
.

33

they're going into any radiological area that they 

would be wearing a film badge or a TLD.

And so, what you're seeing here is the people who 

did not get any external monitoring, likely, were 

working on new construction at the plant and not 

exposed to either external or internal.

Member Lockey: Okay. So what you had postulated 

to us, what you had put in previous slides to us, is 

that everybody, not everybody had to be monitored 

because they weren't job tasked with exposure.

And a certain percentage of people that needed to be 

monitored, didn't have, did not have not dosimetry 

because it was an indicated based on the monitoring 

data. Correct?

Dr. Taulbee: Can you say that last part one more 

time?

Member Lockey: I think what you've been saying to 

us in previous presentations was not all workers went 

a job tasks that needed to be monitored. In other 

words, they were doing something that monitoring 

was not required. Other --

Another segment of workers would be in a job tasks 

that needed to be monitored, but the monitoring data 

was such they did not have to have in total dosimetry 

performed. Correct?

Dr. Taulbee: That is correct. Yes, sir.

Member Lockey: Is that what your next slide is 

inferring in relationship to tritium?

Dr. Cardarelli: Yes, sir.

Dr. Taulbee: That's exactly right. Because in this 

particular case, this would be people who were 

externally monitored and monitored for tritium 

exposure. If they worked, in say, the plutonium 

areas, there was no potential for tritium exposure. 
.

34

Okay?

The tritium exposures were limited to the five 

reactors, as well as, the tritium facilities. So if you 

worked in the, if a subcontractor worked in M Area 

where uranium was, they were not exposed to 

tritium. If they worked on the HB lines or JB lines, 

they were not exposed to tritium.

So there's a difference by radio nuclide as to where 

they worked. And if you go up, this goes back to I 

think, John, your slide 4 or 5 where we gave a broke 

-- down one, shoot up. I'm sorry. I'm looking for the 

one where you have the breakdown of who should be 

monitored and where. There, all right, up one, there.

And here's where we gave that breakdown. I mean, 

SRS is a very large site. There's 312 or 310 square 

miles. So if you worked in the reactor areas, you 

would need to be monitored, potentially need to be 

monitored for tritium and fission products. If you 

worked -- but not for plutonium.

If you worked in the plutonium areas, again, you 

would not need to be monitored for tritium. So that's 

why taking these percentages doesn't really, is not 

definitive. Okay?

Not everybody who worked on site was exposed to 

plutonium. Not every subcontractor is exposed to 

plutonium. It depended upon where they worked. Not 

everybody on site was exposed to tritium. It 

dependent on where they work.

Member Lockey: Thank you.

Dr. Taulbee: Okay.

Chair Clawson: Okay. But now we get back to what 

we got into with some CATI reports where you 

separate people out because they weren't monitors 

because they were doing new construction.

So they could do new construction from 8 o'clock in 
.

35

the morning till 4 o'clock in the afternoon. After 4 

o'clock, they can go to work at another place under 

different overtime and different contractor.

Dr. Taulbee: Yes, sir.

Chair Clawson: So this is where you get into all of the 

problems with saying, well, they didn't have 

monitoring because they didn't need it. But there was 

nothing stopping them on their over times. And it 

happened continuously to go do a hot job after that. 

So just want everybody to keep in mind that, too.

Dr. Taulbee: Absolutely, Brad. And that's part of why 

we did the global analysis that you see with the color 

codes of Attachment B. To look at it on an annual 

basis of how they might have moved around. And did 

they have any internal monitoring from that 

standpoint? That's why we took a larger level.

Court Reporter: This is the Court Reporter. I'm sorry 

to intrude. Phone participant with number ending 

222, I'd ask you to mute your line.

Chair Clawson: I appreciate that. That's nice. Okay, 

anything else that you'd like to put out there, John, 

or Tim? Okay. Joe or Bob, I guess it's up to you now.

Mr. Fitzgerald: Okay. Thanks, Brad. This is Joe 

Fitzgerald. And just to recap from last time, the 

Workgroup SC&A did consider NIOSH's proposed 

weight of evidence approach as a means to resolve 

the question of bioassay data completeness and 

representing this for subcontractors that run off 

bioassays.

That was the sort of tasking we were given from the 

last meeting of actually the full Board. And the 

weighted evidence approach for those who are just 

getting back into this, is it combines the claimant 

bioassay data NOCTS, which we just heard, and 

logbook plutonium data.

All of which would complement the analysis in RPRT-
.

36

0092, which was the subject of the last Workgroup 

session, which evaluates data completeness, based 

on bioassays related to work permits. So again, our 

charge was to look at these other two aspects that 

were being brought to the table as of last December.

I just want to preface what we're going to go through 

in terms of the fact you'll hear a lot of information, 

analyses and conclusions, I think, regarding bioassay 

data for subcontractors, SRS. A lot of what we just 

went through.

But I think what we need to ask ourselves throughout 

all of this is whether that data, and it's considerable, 

Savannah River is a big site with a long history. 

Whether that data is relevant as a means to answer 

the question that was posed by the Advisory Board 

back in 2017, over four years ago.

Which is whether NIOSH can: 1) demonstrate 

whether the pronounced gaps in job-specific bioassay 

data in 1997 existed prior to that year, very basic 

question; and 2) whether that data is available, 

whether data is available that can represent what 

may be missing from that data set.

And that's pretty much what we're talking about 

today. But I want to remind the Work Group and 

whoever else is listening in that going back to the last 

Workgroup meeting, SC&A concluded from our 

review of RPRT-0092 that NIOSH is unable to 

demonstrate from its analysis, as presented in that 

report that the data gaps in 1997 did not exist in prior 

years.

And from our review, was unable to show that any 

such gaps could be bounded or represented by what 

data was discussed or analyzed in that record. So in 

a sense, today, we continue to address that, this 

latter question, the second question about what data 

is available.

And, again, we'll walk through what we have 
.

37

identified as not so much issues with NOCTS. 

Because again, we're very familiar with NOCTS. 

NOCTS was one of the databases that NIOSH 

considered from the get-go as far as looking at 

subcontracted completeness, along with the Center 

of Protect Workers' Rights data as a starting point.

And decided not to pursue either one at that time. So 

we're familiar with this as an option. But we're going 

to kind of discuss why we think that's a problem in 

terms of application. Okay? That's the distinction.

And also, before we walk through all that, I wanted 

to provide in a slide or two a little bit more context 

by what we mean by job-specific, and routine 

bioassays as they were applied to Savannah River 

during the timeframe we're talking about.

And, you know, you have heard us before, and you'll 

probably continue to hear us constantly 

distinguishing question. The application of what's 

called routine bioassay data as a means to represent 

jobs specific bioassay data.

And again, for the reason that they were not collected 

did on the same basis. And were likely based on 

different radio nuclide source terms. So this first slide 

-- thank you, whoever did that.

Really, I think puts in contrast, in a very basic way. 

These are the words of Westinghouse Savannah 

River, from the 1990s in terms of their policies and 

procedures. And again, I think it's important to 

realize that there is a distinction.

That job-specific bioassay program was designed to 

collect bioassay samples from workers whose routine 

bioassay program does not include some or all of 

nuclides present at the worksite and who are not on 

a routine program.

And to go further, as Westinghouse defined it, it's 

very important realize that being on a routine 

sampling program does not automatically cover the 
.

38

bioassay sampling requirements specified on the 

RWP or requested through the job plans.

And that routine sampling programs that may not be 

appropriate for work involving non-routine mixes or 

concentrations of reactive material.

Now, I think, again, it's important realize that the 

stimulus for doing a lot of this retrospective analysis 

of data in the 70s, 80s, and 90s was the very, was 

the finding that a preponderance, 79 percent at least 

in 1997, of job-specific bioassays were missing.

And the question of whether that circumstance 

preexisting 1997 and would, in fact, impair a 

representative co exposure model for those prior 

years. There is very, again, a very basic question 

posed by the Advisory Board back four years ago.

So I think, again, we have to kind of remind 

ourselves, though, that when we try to apply routine 

bioassay data to describe or to bound job-specific 

data, we have to be very careful because they're two 

different things. Next slide, please.

So the key question, the thesis, if you may, that 

we've been working against is that, again, the 

question is completeness of job-specific bioassay 

data, and whether there's any way to bound or 

represent what may be missing in that database for 

the years that we're talking about.

That transient short-term subcontractors, we did talk 

about that a bit. And have talked about it a lot in the 

past, are certainly affected by the job-specific 

bioassay program, but they're not the sole group 

affected.

Obviously, a number of different worker categories 

were under our RWPs and under job plans that would 

have been required to leave a job-specific bioassay.

And as we, I think, Brad mentioned, certainly, we 

continue to question the, the ability or the 
.

39

justification for subsuming subcontractors that may 

have been exposed to non-routine mixes, nonroutine source terms, and non-routine radiological 

exposure circumstances into the general CTW 

database.

So, again, and we've always returned to this basic 

question, did deficiencies exist in the completeness 

of this job-specific bioassay program before 1997 

that would preclude formulation of a representative 

co-exposure model? Again, consistent with the coexposure implementation guide?

And that is the question that continues to be before 

us. So again, I just wanted to set that preface. And I 

will, I guess, turn to Bob Barton. I think Bob is going 

to walk us through our actual review of RPRT-0094.

Mr. Barton: Thank you, Joe. Hopefully, everybody 

can hear me okay. And that's a really a very good 

summary of what we think are is the key issue.

Member Lockey: Wait a second. Joe, can you go back 

to the previous slide, please? I have a couple of 

questions here. The second, main question is, not so 

group. What do you mean by not so group? What 

groups are you talking about?

Mr. Fitzgerald: Well, RWPs, not to mention job plans 

during the DuPont era, were required when you had 

non-routine source terms or non-routine mixes of 

nuclides or particular work that was relatively unique 

and required an RWP or a job plan that would 

describe the actual, you know, work and how it would 

be done, and what specific protections might be 

required.

And that was not exclusively applied to 

subcontractors. Any worker, operator, whatever, who 

was involved in that kind of work, that would entail a 

job plan or RWP would be entailed to get a jobspecific bioassay.

So we're saying that, you know, the circumstance in 
.

40

1997, which was the trigger for a lot of scrutiny, was 

the finding that, you know, 79 percent of those jobspecific bioassays were lacking for the year 1997.

And that's where the question arose, what about the 

prior years? How many workers would be, I mean, 

what was the data gap that may have existed in those 

prior years that would pose a problem?

Member Lockey: So I guess what I'm hearing you say 

is, the inference there is that, is what is applying --

what you are applying to subcontractors may have 

actually applied to prime contractors, as well as, all 

other workers at Savannah River. Is that correct?

Mr. Fitzgerald: Well, that's always been the case. I 

think subcontractors, by virtue of their work are most 

heavily affected, because, again, they were brought 

in to do specific work. And then, a lot of his work was 

transient, and particularly, you know, in some cases 

involve higher exposure. So that group was heavily 

influenced.

But I think we have always pointed out that it wasn't 

just by virtue of the fact that permits didn't not only, 

you know, only apply to subcontractors. That 

obviously, others would have been implicated in 

terms of job-specific bioassays. 

Member Lockey: Okay. And one other question. 

There was in the 1997 review, there was 79 percent

non-compliance, there was 21 percent compliance. 

Correct?

Mr. Fitzgerald: That was the finding, initial finding by 

Westinghouse, yes.

Member Lockey: In that 21 percent, where there was 

21 percent compliance, is there any indication that 

the data generated in that 21 percent was any way 

different than the general overall data, monitoring 

data, or bio-exposure data? Was --

Mr. Fitzgerald: Well, I think it as has been made, 
.

41

clear in the past, Westinghouse, went back and 

actually reviewed all these records and re-sampled 

all the workers that had missed, the 79 percent that 

had missed submitting bioassay samples.

And all of the workers showed no uptakes or intakes. 

So that was a means to validate that even though the 

bioassays weren't collected, there was no exposure 

situation, or exposure issue involved with those lack 

of missing bioassays. So the riding question wasn't 

so much that in 1997, whether those missing 

bioassays or bioassays in general involved 

exposures.

It was whether before then, if because of the 

proportion missing, whether before then that would 

posed an issue of the data completeness for that 

category of bioassays that would make it difficult, if 

not impossible, do a co exposure model.

And that was the premise behind the surveys and 

reviews that started in 2017. Is to actually get a 

handle on that particular question. You know, what 

does that gap pre-exist 1997? If so, to what extent?

And is there any way that one could mitigate against 

that missing data, if so. And that was where RPRT0092 was coming from. Essentially to look at that 

particular question.

Member Lockey: I remember that. I remember you 

saying that before. And I and when they went back, 

the Westinghouse went back and looked, there was 

not divergence in the data, the data was, was 

reflective of what was going on at the time. All right, 

I appreciate that.

Member Ziemer: Joe, this is Paul Ziemer. Could I ask 

a follow up question here? For clarity, in your mind is 

the absence of a special work permit or job-specific 

bioassay permit in itself sufficient to assume that the 

data itself for bioassays is also absent? I mean, isn't 

it quite possible that even though we don't have the 
.

42

work permit, the data is still there?

Mr. Fitzgerald: Yes, exactly. And that was a central 

question. And I think you're talking about what we've 

been calling linkage. A linkage between a permit or 

job plan and the actual bioassay that would come 

from that.

And that was something that both NIOSH and SC&A 

looked at quite in detail, because that's really 

important. The question is, they certainly performed. 

They certainly wrote up job plans and RWPs for the 

source terms that were unique or involved mixtures 

that were unique. That was certainly what was 

entailed.

But could you actually link the subsequent jobspecific bioassay, to those permits or job plans? And 

if you couldn't, did it really matter? And certainly, our 

analysis says that, no, actually.

Certainly, during the DuPont era you couldn't link any 

job-specific bioassays to the actual job plans. They 

didn't have our RWPs at Savannah River until the 

'90s. But in the '70s and '80s, with the job plans, you 

know, there certainly would be job-specific 

bioassays.

But there wasn't any linkage in the sense that you 

could actually see the requirement laid out and 

actually find a job-specific bioassay that would be 

tied to that individual, that particular exposure.

And that was a basis for our concern that if you, in 

fact, were experiencing these gaps as late as 1997, 

how sure could you be that you actually were 

capturing this data from these job plan based 

exposures?

And even into the '90s, where you instituted an RWP 

program, which I might add is fairly late in the game 

to be actually doing RWPS.

But even where the RWPs were put in place in the 
.

43

'90s, given the fact that you were missing as many 

as 79 percent by 1997, how sure are you that in fact, 

there was a program that would actually collect, 

require collection? And actually, you know, review 

exposures for those individuals under our RWPs 

before, 1990 to 1996.

And that was, you know, not to complicate it too 

much. It was just a very basic question of data 

completeness that we've asked for every single site. 

If there's evidence that you're missing a fairly 

substantial percentage of a particular data category, 

in this case, job-specific bioassay.

How sure are you for the time period in question that 

you have that data? And if there's some question 

about its completeness, is there any way that you 

could bound or represent what may be missing?

And as I just went through in that prior slide, the 

problem I see is that by its very definition, RWP, 

Radiological Work Permits are written up for jobs, 

and you know, this definition is Savannah River's, 

right from Westinghouse's procedures and policies.

RWPs and permits are written up specifically for 

those jobs whose source terms, the very nuclides in 

question are unique. The mixtures are not ones you 

would come across in routine work.

So our concern is, you know, applying a database 

based on the normal or routine work that may be 

taking place without distinguishing that from the 

non-routine work, may not be appropriate. That it 

may not represent that kind of work, because that 

kind of work is unique, by definition.

So that's kind of where we're at as far as you know 

that premise. Now RPRT-0092, if we're able to 

identify sufficient work permits and job plans and 

show that job-specific bioassays could be linked to 

those permits.

And you had a representative database, and it was a 
.

44

database of those job-specific bioassays. Then we 

probably would be finished with this because you 

would be able to characterize the kind of exposures 

and the data that was derived from these job plans 

and RWPs.

But to date, we cannot do that. Okay? We have to 

turn to, you know, not this. We have to turn to 

routine data to try to figure out how that might 

describe that which we do not have, which is the very 

specific job-specific bioassay data that came from 

these permits.

So that's kind of, in a nutshell, you know, what this 

is all about. We have nothing against the analysis of 

NOCTS data. I mean, I think everyone's familiar with 

NOCTS. But I think the application in this particular 

case is what we're concerned about.

Member Lockey: So Joe --

Member Ziemer: Just as a follow up, and I appreciate 

that clarification. I think one of the, sort of followups, I think we kind of did this would be if there's a 

systematic absence of that data that correlates with 

systematic missing work permits, it ought to show up 

in the claimant files eventually.

As the claimants who show where they work through 

their CATI interviews and that sort of thing. Is there 

a great amount of missing and bioassay data 

amongst the worker group, inspection Work Groups? 

And I think the NOCTS data doesn't show that, does 

it?

Mr. Fitzgerald: Let me just comment. And maybe, 

Tim will say something. But I think the real problem 

you have is in terms of the management history and 

the worker non-response to the actual program.

In other words, this was brought up in a number of 

independent reviews, both by DOE, the Tiger Team, 

and the Westinghouse self-assessments that, you 

know, there was a system, the job plan system 
.

45

during the DuPont era, and the RWP system during 

the Westinghouse era.

But it wasn't enforced. That they didn't manage it in 

a way which would compel or require workers to 

respond and to, to submit bioassay samples. Of 

course, this led to an enforcement action eventually 

that forced the overhaul of it.

But I would question whether you would have a lot of 

workers that even realized that they had a system or 

an obligation on job-specific bioassays because 

again, there wasn't a management system that made 

it clear that they were required to submit.

And I would be surprised if very many of the workers 

would, in a CATI, or in a submission would 

acknowledge, or be even aware that they would have 

had a job-specific bioassay, or were obliged to submit 

a job-specific bioassay.

That system of account of accountable bioassays did 

not get put in place until the mid '90s and wasn't 

enforced until 1998. And that's pretty late in the 

game to have an enforceable radiological work permit 

system that required and enforced job-specific 

bioassays.

And I think that's been the undercurrent of why this 

has become quite a nettlesome issue. Because really, 

you know, that's something that you would expect to 

see in a mature radiological program, which is RWPs 

with required bioassays specified in a system that 

would ensure that those bioassays were submitted 

and analyzed. That did not happen until 1998.

Member Lockey: Joe, I have one other question. Joe, 

based on the on the existing RWPs where there is 

data that exists, when you went back and looked at 

that existing data, was there any indication that that 

data was not representative of the cohort in general?

Mr. Fitzgerald: I think we looked at the data from 

DuPont, the data from Westinghouse and the RWPs 
.

46

were not implementing at Westinghouse until '93, 

'94. In other words, that did not become a working 

program until '93, '94.

And we were looking at whether or not you could look 

at the completeness of the job-specific bioassays at 

that point. But to answer your question, I think it's 

clear that there was a system where the RWPs 

actually stipulated what bioassay would be required.

And we could identify job-specific bioassays in the 

database. And certainly you had a lot more of those 

bioassays. So the answer your question, 

circumstances changed after they implemented 

RWPs in '94.

The question remains, though, whether the 

compliance was adequate or not simply because of 

that, finding in '97. So there's several years there 

where it's not clear whether even though they had a 

policy in place, whether in fact the workers were 

honoring it, and the management was enforcing it.

So that part of it, I think we reserve judgment in 

terms of, of whether you could, whether you could 

actually identify sufficient data points.

But we're pretty clear that during the DuPont era, 

where you had job plans that were not, did not have 

clear job-specific bioassays stipulated and you could 

not find or link job-specific bioassays to those job 

plans, which was you know, certainly RPRT-0092 

attempted that.

I think we feel that there's a stronger basis for feeling 

like there is not a very good database to draw from 

and you could not make any conclusions on 

representativeness of that.

Member Lockey: Maybe I wasn't clear in my question. 

I guess, what I'm asking is where there are existing 

RWPs and there is data related to those RWPs, does 

that bioassay data look any different than the data in 

general? Have you looked at that?
.

47

Mr. Fitzgerald: Let me, you know, Ron, Ron 

Buchanan, are you, you're on the line, right? Ron 

actually -- okay, Bob?

Mr. Barton: Yes, I might be able to illuminate a little 

bit. Because I think what you're asking, Dr. Lockey 

is, when you had a bioassay that was linked to a jobspecific requirement, was it decidedly different than 

what you're seeing in the rest of the population?

Member Lockey: That's correct.

Mr. Barton: One facet you really have to understand 

is, there's no way to identify what was a job-specific 

bioassay. Even in RPRT-0092 when we went through 

and with a very limited sampling or not even a 

sampling. NIOSH grabbed everything they could. It 

was only for A Area. And there were some years 

missing in there as well.

We basically looked and said, okay, well, they were 

on, this is our job plan. And now let's see, were they 

monitored, essentially at all, and we can't 

differentiate whether that was a routine bioassay that 

occurred, you know. It could be many years down the 

line, and still count as being covered for that RWP.

There's no labels for the job-specific bioassays and 

these are the routine bioassays. There's just simply 

no way to differentiate it. And again, when we went 

into RPRT-0092, to assess the completeness and 

representation there. Again, it was limited to area 

and there's a gap during in the late 70s, and larger 

gaps for things like americium in the separations 

areas.

We just simply do not have the way to have that 

connection, unambiguous connection between what 

the RWP was requiring for its job-specific bioassay 

and what the workers were actually sampled for. I 

mean, it's just simply, you can't look at a bioassay 

result and say, okay, this one's a routine one, and 

then, this one's a job-specific one.
.

48

So it's very difficult to actually make a meaningful 

comparison between these RWP or job plan 

mandated bioassay samples, and the preponderance 

of routine bioassay that that is available. And there's 

a lot of out there.

I guess, as we've been trying to sort of focus the 

discussion is, if you're, if you are actually missing 

jobs specific bioassay for these workers who were 

doing non-routine tasks and weren't on a routine 

bioassay program, then, you know, how can you 

make that connection to say that they are sufficiently 

represented in any subsequent co-exposure model?

Member Lockey: I'm having trouble understanding. If 

you do have RWPs, where it specifies that certain 

radio nuclides be monitored, some of which are going 

to be done routinely. And some which are specifically,

are specified to be monitored. And that data is not 

retrievable is what you're saying.

Mr. Barton: I think that's accurate. I mean, there's 

just no way to differentiate whether it was a routine 

sample. Again, for some that plutonium it might have 

been, you know, five years down the road that they 

submitted a sample. And then in the RPRT-0092 

analysis, we counted that as being covered, 

essentially. And then, we come up with those 

percentages.

And again, it's RPRT-0092, SC&A's view that really 

was to get to the root of, are these workers who were 

performing these non-routine duties under the jobspecific bioassay program who weren't routinely 

monitored, are they sufficiently represented in any 

follow up co-exposure model?

And, again, we can't say with any specificity, whether 

it's a job-specific bioassay or routine. So we just, like 

I said if there's a bioassay sample for the correct 

nuclide, further on down the line within a reasonable 

timeframe?
.

49

Member Lockey: So you have no data to say one way 

or the other whether those specific bioassays, or 

RWPs, are different than the population in general? 

You don't know when they occurred?

Mr. Barton: Yes, that's correct. There's no way to 

differentiate or compare the two groups because 

they're just simply not labeled as such.

Mr. Buchanan: This Ron Buchanan. I'd like to point 

out that the RWPs and the job plans to not specify 

the particular nuclides in a consistent basis that 

needed to be monitored until about the 1994.

That even though there the RWPs were implemented 

by Westinghouse in 1990, they did not become 

specific to, in general, for what nuclides need to be 

monitored until several years after Westinghouse 

took over. So it wasn't an overnight thing.

And most of the former job plans and RWPs said 

internal monitoring, but it didn't often say what 

nuclides. And so, it's almost impossible to get a 

linkage between those incomplete RWPs, and job 

plans, and bioassays.

Member Lockey: Thank you, thank you.

Member Schofield: Yes, this is Phil, I've got a 

question. A lot of people, as Brad pointed out, they 

could work for one employer during the day. They'd 

go work swing shift for another employer.

And if they did give a sample, my understanding is 

this, from what you're saying from the data is that 

sample they may have worked in an area of 

plutonium or they may worked in the area for where 

they're doing work with americium, or mixed fission 

products.

And when they do give a sample, they aren't 

necessarily looking at the whole thing of one day's 

exposure. And we know hot jobs due to the very 

nature, the risk of getting contamination, the risk of 
.

50

inhaling or ingesting something is much higher.

Mr. Fester: No, hang on one second. Okay? All right.

Mr. Barton: Time, you seem to have had your hand 

up for a while. Did you want to jump in?

Dr. Taulbee: I wanted to circle back if I could to Dr. 

Ziemer's original question about did he see any 

difference with the 21 percent and the 

subcontractors. One of the things I wanted to point 

out is, that was one of the, that was one of the driving 

reasons that we developed RPRT-0094 was to look at 

that.

That if, in fact, that 21 percent of these workers, only 

21 percent of the subcontractors were monitored, we 

should see that in the claimant data and we do not. 

We see a much higher percentage of the

subcontractors being monitored.

And part of that comes back to the difference 

between the routine bioassay and the job-specific 

bioassay. On in RWP, if a worker is going in and 

signing in on the RWP, they were to check their 

radiation qualification badge.

If they were on a routine program for that jobspecific bioassay, then they did not have to submit a 

job-specific bioassay, they were covered under the 

routine program. If they checked their qualification 

badge, and it did not say the radio nuclide indicated 

on the RWP, then they would have to submit a jobspecific bioassay.

So you've got workers on the same RWP exposed to 

the same radio nuclide mix that Joe was talking 

about. Some are routinely monitored. Some are in 

the job-specific monitoring. This particular finding the 

notice of violation was just for the job-specific.

And so, when you when the Savannah River broke 

this down and did their after action analysis -- and 

this is on slide 17 of the December presentation that 
.

51

I gave, where it goes through all of those numbers 

and all the different boxes.

And you can see where the breakdown and where the 

issue came from on that. Ninety five percent of the 

workers signing in on these RWPs were on the routine 

bioassay program for the radio nuclide mix on that 

RWP.

Five percent needed to file these job-specific 

bioassays. And of those 5 percent, only 21 percent 

complied. I just think that's important to bring up. 

Thank you.

Member Ziemer: Well, that might suggest, then, that 

the routine when values would cover the data base 

or the data for that particular nuclides in terms of a 

co-worker model.

Dr. Taulbee: That is right, sir. And that's our position.

Mr. Fitzgerald: Yes. And our position I think would be 

that to apply the 1997 experience to all prior years 

would be a reach, would be a speculation because, 

again, the notion, the basis for the Board's inquiry 

and the RPRT-0092 and valuation was to provide any 

demonstration that the circumstances in 1997 were 

either different or similar for prior years.

And, you know, the permits or whatever weren't 

available necessarily for all that timeframe. And you 

can't, and we've gone through the RPRT-0092 in 

some detail. You can't substantiate whether or not 

that circumstance existed for all prior years. And 

particularly if you go back before the RWPs were 

implemented.

And I keep emphasizing that, that the radiological 

qualification badge, the RWPs were very specific 

prescriptive bioassay requirements, that were, those 

were all products of Westinghouse's revision of the 

radiological programming at Savannah River that 

took place in the early '90s, when they got the 

contract and after the Tiger Team.
.

52

And so, you know, those features that would give you 

some confidence that, you know, these bioassays 

were being taken, and that you could, in fact, you 

know, apply some of these, these trends for the prior 

years, I don't think can be done with confidence 

before that time period before RWPs became a 

feature at Savannah River.

So and that's, that's kind of where we were coming 

from. That we were reserving judgment for the RWP 

era, for the reasons that Tim has mentioned. That, 

you know, certainly, it was a working RWP program 

that had the bells and whistles that one would expect.

And there was a lot more data and the circumstances 

in '97, as far as the exposures seemed to us that one 

could apply that during that particular era.

But prior to an RWP program at Savannah River, 

given the experience with the non-compliance, we 

didn't see any demonstration that you could do that 

for those prior years and have confidence that jobspecific bioassays would involve exposures that were 

the same as, or less than, those workers that were 

doing routine work.

Again, I would refer you back to the definitions that 

Westinghouse supplied. That, you know, again, these 

were required for non-routine source terms. Unless, 

there's more questions, maybe Bob you can start 

walking through the slides?

Mr. Barton: Sure thing, Joe. Thank you for that. So -

-

Dr. Roberts: Excuse me, Bob.

Mr. Barton: Yes?

Dr. Roberts: Can I just remind folks on the phone to 

stay on mute. I'm seeing multiple numbers popping 

up as people are speaking. So please check your 

phones and mute them. Thank you.
.

53

Mr. Barton: Thank you, Dr. Roberts. So we're really 

what we're discussing, and we're trying to keep it 

focused on again, this key question back from the 

previous slide about potential deficiencies in the jobspecific bioassay program and how does that affect 

representation and completeness when you're trying 

to formulate a co-exposure model?

So really, the things that we've looked at since 

November and December, those most recent 

discussions, obviously, RPRT-0094, which was the 

subject of the previous NIOSH presentation.

Which is a compilation of essentially all the NOCTS 

data to look at percentages of workers who were both 

externally monitored, that's really the trigger point. 

If they weren't externally monitored, they didn't 

factor into any of the percentages and RPRT-0094.

And by the way, that's something that SC&A and 

NIOSH absolutely agree with. We had that in our 

report, as well, because there was a lot of nonradiological work that was going on in which it 

wouldn't require any sort of external dosimetry and 

if you don't have external dosimetry it's logical to 

make a leap that you wouldn't need internal 

monitoring.

What RPRT-0094 did is separate it into -- well, first 

of all, any internal monitoring was one metric that 

they used. But then, they also separated out tritium 

from that. So you had it monitored externally and 

also monitored for anything non tritium and that's 

RPRT-0094.

So that's, that was really the main focus of work 

that's gone on since November, December. We're 

actually tested -- look at '94, back in, prior to that in 

late October. RPRT-0094 actually came out in 2019, 

I believe.

And our initial read on that, was that, you know, since 

it has the actual unambiguous connection to these 
.

54

job plans, you're basically just looking at the overall 

percentage of routinely monitored subcontract 

workers. So even back in 2019, our focus wasn't on 

'94. It wasn't on the overall number, the percentage 

the preponderance of data.

Our focus was really on '92, which was the 

proceeding report, which actually took what job plans 

and RWPs we had, and then, tried to trace what 

follow up, internal monitoring there was for that.

So RPRT-0094 is sort of a different animal entirely 

because it loses between the job-specific bioassay 

and the actual monitoring requirements from these 

are RWPs and job plans.

The second thing we looked at, which was also 

presented back in November, to the Work Group, and 

in December to the full Board was plutonium logbook 

data. Now this goes past just the claimants. This, all 

of the captured plutonium logbook data for 

subcontractors and we'll get into that a little bit later 

in this presentation.

And then also, later on, on the docket today is the 

stratification analysis, involving tritium and the 

bootstrapping methodology. And so, we combined 

that in into this presentation just for, I guess, 

simplicity and to try to streamline it.

So I'm not going to talk too much about the tritium 

right now to allow NIOSH to present their work in 

their findings. But that is really the third facet that's 

happened since our discussions last, in the winter.

The '94, what it what does it do? It provides

estimates of the numbers and fractions of, again, the 

claimant population of subcontractors who were 

externally monitored, and who also had some form 

of internal monitoring, again, in this period from 1972 

through 1997.

And again, the trigger point was you had to you had 

to be a subcontractor who was monitored externally. 
.

55

And then, we would go in and to see what sorts of 

internal monitoring you had whether it's plutonium 

bioassay, tritium bioassays, whole body counts, 

chest counts, that sort of thing. And it was done by 

year.

So as I said, we were actually tasked to look at this 

back in last October, and it was sort of a focus review. 

Again, let's see, how does this report fit in with this 

entire discussion of whether a co-exposure model for 

SRS subcontractors, is it consistent with the 

implementation guidelines?

Which two of the four main facets are completeness, 

and representativeness? The other two are adequacy 

and stratification. Adequacy obviously refers to just 

can you trust that the data is actually reflecting the 

exposure that you're trying to reconstruct? That's not 

really, it's not part of this conversation at this time.

And the other one, stratification is, okay, if we've 

established completeness, and representativeness, 

in other words, we have a data set that we can be 

reasonably comfortable can be used to create a coexposure model. Now, do we need to split it into 

different distributions based on job types or exposure 

scenarios?

And again, the other focused part of this review was 

to substantiate can you use a claimant data sample 

to reflect the full worker population at a site? And this 

is sort of an interesting issue that's sort of been 

hanging out there for a while now.

And this goes back to a report called TIB-75, which 

provides some examples of comparing just the 

claimant data set to a full sites data set to see if it's 

actually a representative sample.

But that was the other facet that we look into. And 

they looking back through some of the transcripts 

related to that discussion for TIB-75 about whether 

you can use NOCTS to represent an entire site, a lot 
.

56

of those findings that are relevant here are still open.

And they were intended to be transferred to 

procedures and also the SRS Work Group for 

discussion. But they haven't yet to be fully 

adjudicated or accepted by the Board.

So again, our review, approach for RPRT-0094 and 

specifically is the primary question, does the analysis 

obviate our original concerns with the potential 

deficiencies in these jobs-specific, the permit driven 

job plan bioassay program?

And that's the entire discussion really, which we 

show, lay out nicely. And so, we presented our 

analysis of RPRT-0094 and basically was just to take 

another look at that claimant data and really build 

upon what NIOSH presented in RPRT-0094, to give it 

a little bit more granularity.

Instead of just saying, non-tritium bioassay as one, 

just one specific metric. We say, well, what happens 

if we try to separate it out into the actual different 

radio isotopes that were supposed to be monitored 

for?

So our primary concerns is that, again, as I sort of 

intonated earlier, that RPRT-0094 analysis 

homogenizes the internal monitoring data into really 

a single metric. One of them is just are you internally 

monitored?

But that doesn't really answer the question, are you 

internally monitored for what you're supposed to be 

monitored for? If you're supposed to be monitored 

for uranium, and you have a tritium bioassays, it 

doesn't really tell you much.

And as I said, RPRT-0094 doesn't, it does separate 

out tritium in some of its analysis and tables, but you 

really have tritium, internal monitoring, and then 

everything else is sort of grouped together, 

homogenized into one metric.
.

57

And we felt it would be appropriate to dig a little bit 

deeper into the data to see, okay, just because you 

have some form of internal monitoring doesn't mean 

that you're actually covered for everything you 

should have been monitored for.

We didn't find that it substantiates that you can use 

a NOCTS sample. It doesn't really go into that 

whether the NOCTS data set is actually 

representative of the full site population that's really 

not discussed.

So that's sort of a non-starter there. But more 

importantly, it doesn't address the issues of 

completeness and representation for this permit 

driven job-specific monitoring, which is really the 

name of the game here.

So here's just -- I don't want to go through finding 

my finding. But here's kind of a summary of our 

results. So what we have here is, we broke out into 

these five radio nuclide categories, you know, 

plutonium, fission products, uranium, neptunium, 

and americium.

And we also split it into what we're calling the DuPont 

era, through 1990, even though Westinghouse, I 

believe, took over in late 1989. But based on some 

of the analysis that was done in RPRT-0092, really 

the two eras we're talking about is '72 to '90, and 

then, '91 and up.

As you can see in columns two, this is the range of 

the percent of externally monitored subcontractors 

who also had internal monitoring for each of these 

radio nuclide categories.

So for example, plutonium in that DuPont era, if you 

were externally monitored, in a given year, the range 

of percentages or subcontractors in the claimant 

population would go from three to 34 percent of the 

externally monitored subcontractors also had 

plutonium monitoring.
.

58

And you can see these can be compared to what was 

presented in RPRT-0094 based on these table 

footnotes here. So as you can see, again, it's non 

tritium monitoring. It's just the one homogenized 

category presented in RPRT-0094.

And so for the DuPont era, for example, RPRT-0094 

shows that in any given year was five to 87 percent. 

And what we're saying is when you break it out into 

these different categories, it can be significantly 

different for some, not so different for others.

Notably, again, the plutonium up through 1990 was 

basically about a third of the subcontractor claimant 

population that was monitored externally, also had 

tritium monitoring.

This is, so this will give it by year. And this is kind of 

a busy chart. But I mean, this is the overall results of 

our review here. Again, we were just talking about 

plutonium.

So that's the blue circles, you can see there and as I 

said, just like in the NIOSH presentation, that there's 

that gap in the late 70s that we both saw. And as you 

can see, notably for plutonium, again, you're less 

than a third for most years until you get to about 

1991. And then it jumps up above 50 percent. And 

then you have the -- it increases substantially.

Another notable thing that you can see here is that 

right around 1987 is a big jump for uranium and 

neptunium. And this is really the advent of what was 

called the FASTSCAN whole body counter, which 

we're not exactly sure if they were necessarily 

looking for enriched uranium or neptunium.

But the counter did have the capability to measure 

those radio nuclides. So we counted that as 

applicable internal monitoring.

And as you can see, fission product starts out pretty 

high up there. You got 60 a little bit above 70 

percent. And then, it drops down into the later 70s, 
.

59

and then, rises again. And obviously, as you get into 

that Westinghouse era it seems to be a lot stricter 

bioassay coverage.

As you see a lot of, there's just sort of a hump there 

in the 1990s. And it was it was definitely observable 

in the claimant data set that oftentimes they, the 

bioassay stamp will be on the same date. And it 

would be for fission products. Something like 

strontium-90, you know, uranium and all on the 

same day. That's why you see those sort of mapped 

together there in the 1990s.

So, in summary, for our conclusions for RPRT-0094 -

- and I'll just read this into the record for 

completeness, here. SC&A does not find that the 

analysis of claimant's subcontractor data in RPRT0094 adequately addresses the original concerns of 

permit driven job-specific bioassay monitoring.

It is estimated position that the original concerns 

related to the job-specific bioassay program can only 

be adequately addressed to a direct connection 

between radiological work permit, RWP monitoring 

requirements, and available internal monitoring for 

those workers as was analyzed in RPRT-0092.

Now moving on, this was the second thing we looked 

at beyond RPRT-0094, which was presented by 

NIOSH again back in the November Joint SRS SEC 

Issues Workgroup and also to the full Board. Joe, I 

don't know if you want to step in here. I know you 

took a pretty close look at the plutonium logbook 

bioassay.

Mr. Fitzgerald: Well, just very briefly, yes. Basically, 

I went through pretty much the entire logbook 

database. And it does, in fact, cover a lot of Savannah 

River Sites between the years in question.

And I looked at the type of bioassays. There was 

certainly column provided that gave the type of 

bioassay that was involved. And I could not find a 
.

60

distinction between the job-specific bioassays and 

routine --

Certainly my review showed that it was the 

preponderance was routine, or specials, or 

terminations. You know, pretty much what you would 

expect. And, again, because you can't distinguish the 

job-specifics, I think what you're applying is a 

considerable amount of routine plutonium bioassay 

samples that would have covered both CTWs and 

subcontractors as well.

But, again, it's not clear how that's going to answer 

the question that we're trying to answer, which is, 

can you use that as representative of those that 

would have been on job-specific bioassays?

There's no way to answer that from this database 

that's provided there. That's pretty much the bottom 

line on that. There was a considerable amount of 

data. I'll concede that.

Mr. Barton: Thanks, Joe. And this is a slide about 

tritium. But since NIOSH hasn't presented their 

material yet, we'll just skip over that one. And but 

basically, our conclusions on this new material that 

hadn't been really discussed, or broached, or 

reviewed since our last meetings in November and 

December, is that RPRT-0094, I mean, it we don't 

disagree with the analysis.

And it does show as Joe just mentioned, there is a 

preponderance of data, routine monitoring data. 

There's a lot of it. However, it doesn't really meet the 

intent of the Implementation Guide.

That's IG-6, in which you have to establish that the 

data set you have, it doesn't matter how big it is, it 

matters, whether you actually have representative 

data of all of the workers who should have been 

monitored.

And if you don't, where are the missing workers? 

Where would that be? In this case, it's we feel the 
.

61

job-specific permit driven bioassay, which was meant 

to cover the non-routine types of exposures.

And again, just to reiterate what Joe said, looking at 

the plutonium logbook data, again, there's a lot. And 

it's primarily routine. But does that address the 

question of whether there's a group of workers out 

there that's missing from your co-exposure model?

And are they actually bounded by what you do have? 

And I guess, our real, main issue here is that if it's 

very difficult to know. How do you know what you 

don't have? And I think that's the uncertainty that's 

sort of underlying this entire SEC discussion.

If there's a missing group of people, and that group 

of people are those who should have been covered 

by this job-specific monitoring Program, which had 

issues as late as 1997.

And, you know, our survey of whether that was a 

problem earlier, really didn't answer the question, 

which that was intended to be in RPRT-0092. We 

simply don't have the job plans to be able to look at 

to see if those people were covered.

And the ones we do, again, there's some missing 

years, it's only for one area. And even then, for things 

like the separated americium, we certainly found that 

there seemed to be issues with workers submitting 

these necessary bioassays to be able to say, with any 

degree of confidence that any subsequent coexposure model is going to cover those exposures.

The last bullet here, again, is about tritium. So I'm 

going to skip that one until we get to the actual 

tritium discussion. Which is that, again, as I said, we 

believe that the only adequate analysis to be able to 

solve this problem was contained in RPRT-0092.

Which was severely limited by the job plans we had 

to be able to look at, and the years, and in some 

cases, specifically, americium that was separated. 

The numbers weren't all that impressive in our mind. 
.

62

And obviously, that is a judgment call.

And just to reiterate, what our conclusion was from 

RPRT-0092. Without the validation of subcontractor 

data completeness, that the RPRT-0092 evaluation 

was to provide, there's been no substantiation that 

there are sufficient job-specific bioassay 

measurements available to ensure that the co-worker 

data in TA-1, which is the co-exposure model, are 

either bounding or representative of the exposure 

potential subcontractors performing permit driven 

work across the SRS site.

And that was our RPRT-0092 conclusion, which we 

feel is really the was the litmus test for this entire 

discussion.

Mr. Fitzgerald: And, Bob, this is Joe. Just going back 

to the exchange that I think Paul and Tim had a little 

while ago. And this gets to, perhaps, a root issue that 

the SEC Work Group may have to ponder. Because, 

you know, we have the IG-0060, the co-exposure 

implementation guide, that was developed. And 

actually Savannah River was a bit of test case, first 

time in practice.

But this question of, you know, NOCTS being applied, 

and what you can -- and I'll use the word infer, 

because I think that was used at our last Work Group 

meeting back in 2020. I think Tim was saying that, 

you know, RPRT-0094, the NOCTS-based approach, 

provides a way to infer completeness.

What we have struggled with, and I think what makes 

that difficult, is: is that good enough based on what 

the intent was on IG-006, you know? Certainly, 

looking at NOCTS, looking at the routine database, 

you know, because there's so much data, one can 

infer or deduce or assume that that data ought to 

represent, you know, what may be missing. In this 

case, maybe very specifically the job-specific 

bioassay. 
.

63

But does that meet the criterion which is in the 

implementation guide, where, you know, 

completeness must be determined from sufficient 

measurements for workers with comparable activities 

and source terms, relationships to the radiation 

environment?

We think it falls short. I think the idea of inferring 

completeness or deducing completeness based on 

other data, even if you have a lot of it, brings into 

question how that's being applied. And that I think 

goes to, certainly, a question the SEC Work Group 

would have to contemplate, you know, in terms of 

interpreting what those words mean, because, really, 

it says something very specific that doesn't --

certainly, deducing or inferring or assuming doesn't 

meet that test. 

And I think that's been the struggle we've had with, 

you know, with NIOSH certainly proposing these 

different avenues of applying what data we do have, 

which is a considerable amount of routine data, 

considerable amount of NOCTS data. But can it be 

used? Is it relevant to what the co-exposure model 

requires? And that part we do not agree with at this 

point. But, certainly, the SEC Work Group 

specifically, that would be a charge that they would 

have to address, because, right now, we don't think 

the inference of completeness that would come from 

NOCTS is sufficient.

Dr. Taulbee: Dr. Lockey, you're on mute.

Member Lockey: It's a good place to be sometimes. 

Bob, can you go back to Slide 8 for me? I just have 

a -- for my own clarification. What was the overall 

site worker production you were talking about there? 

What was that population? Was that just construction 

workers or is that everybody?

Mr. Barton: RPRT-0094 specifically looks at the 

subcontractors that are available in NOCTS. 886 total 

claimants were identified (audio interference) 
.

64

contractors. So, that's what RPRT-0094 looks at. And 

that's what we looked at, as well.

Member Lockey: Well, this is the construction 

workers, correct?

Mr. Barton: Subcontractor construction workers.

Member Lockey: Subcontractors. Okay. And your 

bullet number 3 says it does not address the 

completeness and representation of permit-driven. I 

understand your statement there. Does the available 

data indicate that it's not representative?

Mr. Barton: Well, I'm not sure how you'd know.

Member Lockey: You have exposure data. You have 

bioassay data.

Mr. Barton: Yes.

Member Lockey: Is there any data available that says 

it's not representative when you divide into 

subcontractor group versus contractors?

Mr. Barton: Well, I think the original question was, 

you know, if there's a gap in --

Member Lockey: I understand there's gaps.

Mr. Barton: Yeah. I'm not sure how you prove a 

negative.

Chair Clawson: Bob, let me help you there with this 

one. Hey, Jim, tell me how much data we're missing.

Member Lockey: I understand that. But I have to --

I'm asking the question, Bob. You have existing data, 

okay? There is a fairly large data point, okay? And 

what I'm asking you, is there any data in that large 

data file that we have that indicates that this data is 

not representative? Did you look at that?

Mr. Barton: I'm not sure how I'd be able to tell if it's 

not representative if it's missing.
.

65

Member Lockey: Well, there is data that's not 

missing. So, you use the data that's not missing. And 

you want to know if the data that's not missing is 

similar to the other data. Is it similar to the prime 

contractor data, or is it different? That's what I'm 

asking.

Mr. Barton: Well, once again --

Member Lockey: I know there's data missing. But 

there's ways to handle that. And I guess what I'm 

asking is, did you go back and look at the data that 

you actually have to see if there's any difference in 

the distributions and in the confidence intervals?

Mr. Barton: I think what we'd be looking at is the 

comparison between primarily, or overwhelmingly, 

routine bioassays. And I believe NIOSH will be 

addressing that, at least for tritium, in the upcoming 

presentation. So, is there a difference between the 

routine bioassay data? NIOSH will address that. And 

--

Member Lockey: I wasn't asking about -- I'm asking 

you, did your group --

Mr. Fitzgerald: Let me try to answer that, at least 

from a different standpoint. You're saying, did we 

compare or look at, if A is the NOCTS or routine 

database, and B is what's available and job-specific, 

and compare them, I would say there's no way to do 

that because B is missing.

The whole dilemma has been the inability to compare 

anything because we're missing the essential data, 

the distribution of that data, or any distinguishing of 

that data to compare it with any of the other 

databases that NIOSH has come up with, whether it's 

NOCTS, the routine, the plutonium log books, you 

know, incident database. I mean, there's a whole 

bunch of data, but it is all from the routine database. 

And it forces one -- and I've said this before -- it 

forces one to not compare and establish that, in fact, 
.

66

they're comparable or uncomparable. It forces you to 

infer or deduce that it would appear that you have 

enough data covering enough sites that it would 

presumably bound or represent that which is missing, 

without knowing what is missing.

So, you don't have a means to actually compare A to 

B. You're looking at A and judging whether, by virtue 

of the amount of data and what kind of data you 

have, that, in fact, it would in fact represent what's 

missing.

But, again, that isn't what IG-006 calls for, in our 

interpretation, our reading of the guide. And I think 

that falls short of actually establishing that 

comparison. You can't compare if you're missing 

what you're comparing with. And that's what the 

problem is here.

Member Ziemer: This is Ziemer. Let me ask for 

clarification. Even if it wasn't missing, it's not clear to 

me that you could compare them, based on what Tim 

said, that a larger number of the people who were 

working under a special permit already had routine 

data, or routine bioassay for that site. And, therefore, 

it doesn't show up as available to make the 

comparison. So, even if none of the information was 

missing, could you even make the comparison?

Mr. Fitzgerald: Yeah, and, Paul, the dilemma is that 

there's no way to know that in the earlier years 

because there was no management system that 

would generate those records and give you 

confidence that you, in fact, had that information. 

There's just no way of knowing because the data 

wasn't collected that way.

Member Ziemer: Yeah, I agree. 

Mr. Fitzgerald: Well, I think --

Member Ziemer: And I think it's still true maybe in 

the later years, too.
.

67

Mr. Fitzgerald: Well, it's unclear, because, certainly, 

the RWP program, once it was implemented in '94 

and put in place and you started, you know, getting 

prescriptive bioassays performed, I think that gives 

you a much different situation than before that point.

And we acknowledge that in our conclusions on 92, 

where we made it clear that once we get into that era 

there certainly is more likelihood that you could do 

what you're talking about, which is be able to show 

that the exposures of people that were both on 

routine and non-routine, you know, they were similar 

or representative. I think you can -- and that hasn't 

been done, per se, but I think that can be done. 

There's an avenue of doing that.

Before you had RWPs and management systems that 

would require the bioassays and actually prescribe 

those bioassays, we believe that, you know, that's 

not possible. And certainly before 1990 in the DuPont 

era, we don't see any evidence of it. So, it is 

timeframe-based.

I think what you're saying with RWPs I think is true. 

I think there is an avenue that you can actually 

demonstrate that, but only after the RWPs were put 

in place and implemented and you actually had the 

data. And that's mid-'90s.

Member Lockey: So, Joe, my understanding is you 

can't, for people that were part of a job plan or RWP 

and they were monitored as far as a routine 

monitoring program, you can't identify those 

samples, right? You can't differentiate?

Mr. Fitzgerald: We don't know. We don't know what 

overlap there was in terms of those that were 

routinely monitored and those that had job-specifics.

I think you can know that later in the '90s when you, 

you know, had better -- well, you actually had 

documented RWPs that prescribed your bioassays. 

Then you can make that distinction. In '97, as Tim 
.

68

pointed out, very much so you can make that 

distinction. But not before the site adopted an RWP 

program. Before that time, there just wasn't a tight 

program, which was actually a major finding of the 

Tiger Team in 1990, that a lot of these bioassays 

were not being collected and there was a problem of 

management enforcing it. So, you know, you had 

that going back certainly to that timeframe and 

before.

Member Lockey: So, if they were being collected as 

routine they may not -- you can't identify them as 

part of that specific job plan or -- or say job plan, is 

what you're saying?

Mr. Fitzgerald: Yeah. There just wasn't any way you 

could identify that. And the management program 

just wasn't set up and established and managed that 

way, so you don't have a paper trail, you don't have 

an expectation.

Member Lockey: Got you. Okay. I understand. That's 

helpful. 

Member Ziemer: One additional follow-up, because 

I'm trying to understand sort of the practical side of 

this when it comes to dose reconstruction. If you go 

back to the early period where there's a RWP that 

simply said you had to have bioassay. It didn't specify 

what it was. And you had workers who simply didn't 

leave the samples, so they weren't bioassayed.

When it comes to a claim -- and let's say it's a worker 

who has no bioassay, but you can identify him as 

having been in that facility, then you are assigning a 

coworker -- yeah, let me use the correct wording 

here, the old coworker word -- based on those for 

whom we do have the routine bioassays for that 

facility. Is that correct, Tim?

Dr. Taulbee: That is correct, sir. And to just elaborate 

a little bit upon that. With the implementation guide, 

the two criteria for completeness that we were 
.

69

looking at is, are the jobs covered, all of the 

individual job types covered, in each of the years 

over the time period of the co-exposure model? The 

other component is, are all of the facilities covered 

that would have that potential exposure? 

Those are the two criteria. There really isn't any jobspecific or any RWP, any of that other type of criteria 

that is in the implementation guide. There are sites 

that do not have any RWPs in the 1970s and '80s for 

which we will be developing a co-exposure model on 

and we can't go through and do this direct 

comparison that SC&A is indicating that is required.

That was never our intent in the implementation 

guide. It was to look at, are all the jobs covered and 

are all of the facilities covered? That's what we are 

calling from a completeness standpoint. Now, so, I 

wanted to make that particular point here. And we 

believe that we've met that with this particular -- for 

this site.

The other component here is, you know, when you're 

looking at something the RPRT-0092 that doesn't go 

back further in time at all of the facilities, it does go 

back for 773A, for A Area, into the 1980s. There's 

good comparisons there. Other areas there's not. 

This was part of why we looked at RPRT-0094, was 

do we see any big changes in the total monitoring of 

the workforce during these different eras?

And as Dr. Lockey pointed out, in the 1970s, we 

clearly see that there is less monitoring. The 1980s, 

we see an increase in monitoring. And then the 

1990s, more the modern era, where there's a lot of 

monitoring amongst the subcontractor construction 

trades workforce.

So, that was part of the reason that we looked at all 

of the areas. The bioassay log books is that 

component that gives us some assurance of the 

plutonium. I mean, were subcontractors monitored in 

the major plutonium areas? And that was something 
.

70

that John presented back in November, and I 

indicated in December, where we looked at the two 

main areas where most of the subcontractor 

monitoring comes from are the two main plutonium 

facilities, F and H area. 

So, it's looking at everything in concert, is what gives 

us the picture that we're looking at as to why we feel 

that the co-exposure model is complete and 

representative. Thank you.

Mr. Fitzgerald: And, Paul, if I can respond to that 

same question. First, SC&A is not requiring or 

implying NIOSH needs to actually compare things like 

permits or RWPs and what not, consistent with what 

was done in 92, in order to come to a conclusion on 

this.

That was NIOSH's proposed way of settling the 

question of subcontractor data completeness for 

RWPs and job plans. So, that was, as we point out in 

our report, a carefully designed approach to answer 

that question consistent with the co-exposure model 

criteria.

The second thing is we're not, I think, interpreting 

something different than what the implementation 

guide provides. I read it once. I'll read it again. I 

mean, it basically says that the completeness is a 

going-in proposition, is one of the first things that one 

ought to look at in terms of the hierarchy. And it 

should be determined from sufficient measurements 

for monitored workers with comparable activities and 

relationships to the radiation environment.

And I wanted to point out that, you know, this jobspecific versus routine is not an esoteric thing. 

Actually, job-specific bioassays are distinct and are 

for non-routine source terms, non-routine exposures. 

And that's the reason the RWPs and job plans were 

written up, and why these job-specific bioassays 

were required.
.

71

So there's a definite reason for that. And, yes, as I 

was saying before, again, RPRT-0094 provides a 

considerable amount of data, claimant data. But that 

was data we had when we started this whole process. 

And we didn't pursue that avenue because, one, you 

always have the question of whether it's 

representative of the actual working population or 

not. But, more importantly, in this case, it can't easily 

be compared with the non-routine data that's 

missing. You can infer, you can deduce that you don't 

see anything, but you can't establish that, in fact, you 

have enough measurements that you can compare A 

to B or compare routine to non-routine.

I think you're, again, forced to assume that because 

of the amount of data and the facilities covered and 

what not, that it encompasses it. But there's no way 

to show that.

And, again, we keep going back to it, but if the 

question is, do we see some anomaly, see something, 

an outlier in the NOCTS database which would 

suggest that this data is missing? How would you 

know? Because you don't even -- you can't even 

characterize the bioassay data results from this 

whole category of job-specific bioassays because you 

can't distinguish it and there's a good chance that 

most of it's missing. You just don't know. That's the 

problem. There's a lack of information.

Member Ziemer: Yeah, I'm not disputing that at all, 

Joe. I appreciate your clarification.

One thing I would like to point out is that a jobspecific bioassay sampling is not specifically related 

to unusual jobs or special hot jobs where you're 

burning people out. It's specific for workers who are 

not already on a routine for the area where they're 

being sent.

So I don't think we should assume that a job-specific 

bioassay implies that it's an unusually hot job. It

implies that we need to specify for workers who are 
.

72

not already on a routine for that location that they 

have to get a bioassay. And I think there's a big 

difference in the two. So, the issue of saying, well 

this is for people --

(Simultaneous speaking.)

Member Ziemer: It may cover jobs that are unusually 

high or hot, but not necessarily.

Mr. Fitzgerald: Yeah. And that's exactly why I put up 

that one slide. Because, you know, rather than 

interpreting how the contractor may have 

implemented the bioassays in that vein, this 

particular slide, I mean, this is the policy, this is the 

approach taken by Westinghouse between jobspecific bioassays and routine bioassays. 

And I agree, Paul. There's nothing here that says it's 

only for hot work. It just says that the source terms, 

the material that's being handled, if you're going to 

do a job, if it's not routine, if it involves non-routine 

mixes or concentrations, then that would require a 

job-specific bioassay and, by inference, an RWP.

So, yeah. And that's the issue, that --

(Simultaneous speaking.)

Mr. Fitzgerald: Because it's going to be different.

Member Ziemer: It doesn't mean that it's different or 

non-routine. It means that workers who are not 

already on a routine for that area need to have that 

added bioassay. They're not already collecting for it. 

It's bioassay samples --

Mr. Fitzgerald: Yes. And I think the --

Member Ziemer: It doesn't say the work is nonroutine or unusual mixes.

Mr. Fitzgerald: Yeah, the second bullet, right. And 

that's what the first bullet says. The second bullet 

says, you know, just keep in mind that they are also 
.

73

reserved for situations where you have the nonroutine source terms.

Member Ziemer: Exactly. But not necessarily only 

that. That was the point. Yeah. Thanks, Joe.

Chair Clawson: Yeah. This is Brad, too. And I go back 

to what I got into with this in the earlier years, is 

when we were doing bioassay we only had certain 

bits and pieces that we were being bioassayed for. 

But our area had many other isotopes of concern. 

And this is where the special went into, because we 

were not there. And part of our problem that we got 

into was that we didn't have guidances to send us 

into these special work permits, or whatever, 

because when they told us we were monitored, we 

were being monitored for everything.

So when they'd come to find out that we were in 

these areas and made these dives, we weren't being 

monitored for those. And this is just a personal thing 

from me of why this is kind of a problem at Savannah 

River here.

I want to make something else clear, too, is I want 

everybody to realize what I have put up there for an 

SEC is from '72 to '90. And there's a reason for that. 

It's because trying to compare what Westinghouse 

did and DuPont did is night and day. It is totally 

different. I do not believe that DuPont intentionally, 

or anything else, did anything wrong. But their 

monitoring program was totally different. And they 

didn't implement a lot of the DOE guidelines that they 

were supposed to.

And even into 1997, Westinghouse, taking over for 

them, was still having a problem implementing the 

guidelines that they were supposed to. So I want 

everybody to realize when, because we're always 

talking '97, '90 this, '90 that. I purposely set the SEC 

because trying to wrestle with all of this is very hard. 

And this is why I separated it to these years, is 

because this is the only way that I felt that we could 
.

74

get a good overall feeling of what was going on.

We're going to deal with the '90-on at another time. 

But we keep calling in '97 because of what happened 

there, and a lot of the Tiger Team reports and 

everything else like that. But I want people to realize 

that this SEC that I pushed for was from '72 to '90. 

And for good reason.

Okay. That being said, is there any more questions? 

Any other Board Members have any questions for Bob 

or NIOSH? 

(No response.)

Chair Clawson: Okay. That being said, do we want to 

go on, Tim or John, and --

Dr. Taulbee: We can. But could we take a short 

comfort break?

Chair Clawson: No. 

(Laughter.)

Chair Clawson: Yes, we can. Let's take a 15-minute 

break, if that's okay, Rashaun. Let's see, what have 

we got? We've got, oh my goodness. How about if we 

come back at 1:20 p.m. Does that give everybody 

enough time? 

Okay. Sounds good. Thanks.

(Whereupon, the above-entitled matter went off the 

record at 1:04 p.m. and resumed at 1:23 p.m.)

Bootstrap analysis of SRS Bioassay Data

Chair Clawson: So, with that being said, I'll turn the 

time back over to John, and we'll go over the 

implementation of the bootstrap analysis.

Dr. Cardarelli: All right. Thank you, Mr. Clawson. This 

should not take too long of a presentation. It's 

actually a summary of two pieces of work that we 
.

75

distributed. One was the statistical analysis done by 

Dr. Nancy Chalmers, who's a principle scientist for 

statistics with the ORAU Team. And, of course, then 

the summary, which is this particular presentation of 

that work and its implications on trying to understand 

how the uncertainty analyses around our coexposure models can be applied, and what does that 

really mean.

So, briefly, I'll give a background, and I'll ask some 

questions or some comments that have been made 

in previous Work Group discussions. I'll describe 

briefly what the bootstrap analysis is. And then we'll 

talk about the observations and implications and 

some basic conclusions.

This is a common assumption that we've been talking 

for the last several Work Group meetings, and that is 

subcontractor construction trade workers were hired 

for more hazardous work than DuPont construction 

trade workers, and therefore had greater potential 

for internal exposures.

We present this as a statement, but it's really quite 

an assumption. And we are very curious, by 

understanding the uncertainty analyses in the coexposure models, if this assumption is paid out by 

the particular data.

So, what are the questions that we were looking at 

as a result of this? First, do the subcontractor 

construction trade workers exhibit higher internal 

exposures than DuPont construction trade workers? 

And that's really -- that's the first question. 

The second one goes to whether or not subcontractor 

trade workers, should they have their own coexposure model?

And the third one is the current situation, which is: 

are the current co-exposure models, which is a 

combination of DuPont with sub construction trade 

workers together, is that model acceptable for dose 
.

76

reconstruction purposes?

So, these were kind of what was in our mind when 

we started pulling this together. Again, a similar type 

of graphic here. And I'm going to walk down the dark 

arrow path. And we have all construction trade 

workers. Our target population is really made up of

those who have been exposed, because we have data 

on them.

The study population that I'm talking about are only 

those who are in our target population, but have been 

monitored. And you can be not exposed and still be 

monitored. We talked about that in the last 

presentation.

And then the sample study, or the study sample in 

this particular slide, happens to be the NOCTS data 

from the claimant, which is basically any exposure 

data from the claimants. And we apply our models to 

it to construct an exposure estimate or dose estimate 

or an intake to those in the target population who are 

not monitored. 

So, that's kind of how the use of the co-exposure 

models are applied to provide dose estimates to 

people who are exposed but not monitored.

So, this particular slide breaks down roughly the 

number of samples that were used in this particular 

analysis. And we used the tritium exposure data 

because, number one, it was already available in the 

NOCTS data and the conversion to dose was very 

simple. Given the timeframe that we had to conduct 

this work under, this is something that we could 

demonstrate the bootstrap method, understand the 

uncertainties, pull some implications from it, and yet 

demonstrate what we have here.

Again, if you take a look at the first line, 

subcontractor construction trade workers, there's 

over 12,000 tritium samples among 237 individual 

subcontractor trades workers. Among DuPont 
.

77

construction trade workers, there is around 20,000 

samples, resulting from 185 unique workers. Now, if 

you combine those two columns you'll have what we 

call the combined CTW, which is the current coexposure model. And that's how we get our 32,477 

tritium samples, made up of 421.

There's an asterisk there because some workers fell 

between subcontractors at DuPont. But the numbers 

add up if you account for the small number of 

workers that might shift between the two different 

groups.

And, of course, non-construction trade workers is 

110,000 tritium samples among 728. And, again, this 

is from NOCTS data, so this is claimants only.

And, of course, if you were to combine it all together 

we have over 140,000 tritium samples from 1,000 

unique workers, 1,079. So that's kind of like the 

global picture of the dataset that we were working 

under for this particular analysis. 

Dr. Taulbee: Dr. Lockey, you're muted.

Dr. Cardarelli: Dr. Lockey, you're on mute.

Member Lockey: John, go back. So, the 110,000 --

no, next slide. You used the 110,000 nonconstruction trade workers in the analysis, right?

Dr. Cardarelli: Well, what you're going to be seeing 

is not the data associated with the non-construction 

trade workers. But I think in Dr. Chalmers' report she 

does include some of that information. But in this 

presentation we will not be focusing on the nonconstruction trades.

Member Lockey: I didn't think you included it in your 

presentation, but I think Dr. Chalmers did.

Dr. Cardarelli: Yes.

Member Lockey: Okay. I just wanted to make that 
.

78

clear. Okay.

Dr. Cardarelli: Okay. Yeah, I will be only focused on 

the subcontractor construction trade, or the 

construction trade workers in this particular 

presentation.

One of the first steps in doing this bootstrap analysis 

is really a graphical display of the data. In the two 

different axes that we see here on the left, the doses 

in millirem, and it's really a logarithmic scale. And on 

the bottom is the standard normal quantiles. And 

that's what is called a Q-Q plot. And if the data itself 

fits the model very nicely, this is one way to 

graphically represent that.

And the data here on the far left lower corner is the 

lowest exposure. We have 66 particular construction 

trade workers in the year 1986. And we rank them 

by order. And then the upper right hand corner is the 

highest exposed individual for that particular year.

And then we can generate a geometric mean and the 

geometric standard deviation from this data. The 

geometric mean is derived directly from the 50th 

percentile. And as you can see here, it's the zero 

quantile, standard normal quantile. And then we 

extrapolated over to get the geometric mean of about 

6.5 millirem, the line you see here.

To get the geometric standard deviation I added this 

normal curve kind of subtly in the back to understand 

where the 84th percentile, or the .84 quantile, comes 

from. And that's, frankly, one standard deviation 

among the standard normal quantile. And if you add 

up all of the percentages, this is 84 percent of all the 

data. And then we extrapolate this over to the Y, or 

the dose. And you'll see that if you take the 84th 

percentile, divide it by the 50th percentile, that is 

defined as the geometric standard deviation.

And in this particular example, 1986, the geometric 

standard deviation was 3.17. And all of this is based 
.

79

upon the 66 individual workers who had some tritium 

results in that year.

And so, what is bootstrapping? Really, all it is is 

sampling with replacement. And for the example that 

we just saw, the year's 1986. We had 66 construction 

trade workers. The geometric mean was about 6.5 

millirem, with a GSD of 3.17. And what we've 

effectively done with the sampling with replacement 

is we take the 66 people, and we put them all back 

in the pile, and we randomly select 66 different 

values. But instead of pulling it out, we replace the 

person back in.

So, in essence, we have 40 some-odd people. Well, 

we have 66 different people. In the most extreme 

case, it is possible -- not likely, but it is possible with 

replacement that you pick the same person 66 times 

to derive that. Highly unlikely. 

And we do this up to 10,000 times. And as you see 

here, these were the actual results, from the first run, 

the average was 7.8 millirem with a GSD of 2.72, all 

the way down to the 10,000th time we tried this, 

where we got 5.2 millirem with a GSD of 3.19.

So we do this to come up with a better understanding 

of the uncertainty around that particular model. 

Again, the true data is 6.5, or the sample data that 

we would derive it from, of 6.5 millirem, with 3.17 as 

the GSD. But what are the uncertainties around that? 

And that's the benefit of the bootstrap.

We look at that population 10,000 times and we 

estimate these statistical parameters that have 

unknown properties. And in this case, we're after the 

95th confidence interval around that data.

So, this is the next slide, shows the original data with 

a line drawn through it, which is the model of that 

data. You can see it has a very good fit visually. And 

then now we've added the light blue lines, or the 

dashed lines, which represent the 95th confidence 
.

80

interval of the model.

So, in effect, there are 10,000 of these linear lines 

that all fall, 95 percent of them fall within those blue 

boundaries. That's how you would look at those 

10,000 separate looks of this data. So it gives us a 

good indication of how widespread the uncertainties 

might be.

Now, what I've done in this particular slide is first 

show you the mean, which was 6.5 millirem. But now 

we've created, instead of those 95th percent 

confidence intervals, we color-coded that in. And now 

we call it a confidence band. It's just an easier way 

of interpreting the spread.

Now, this was based on 1986 with 66 construction 

trade workers. If we were to redo this entire analysis 

and only look at subcontractor construction trade 

workers, we're no longer looking at 66, we're looking 

at 39 construction trade workers. And the dose itself 

for those 39 is slightly lower than that of the original 

66. But the uncertainty band, which appears to be 

pink or a little bit of red in this particular picture, has 

substantial overlap. So, one could argue, is there 

really a technical difference between these two?

And then, if we were to take this a little further, and 

look at just the DuPont, now we're no longer looking 

at 66, we're not looking at 39, we're looking at 66 

minus 39, which is he remaining 27 construction 

trade workers that were DuPont workers. We could 

look at just their exposure potential for tritium, in this 

example. And we have their uncertainty co-exposure 

confidence band that also substantially overlaps the 

original one. So this is a quick way of us visualizing 

how well the spread of the particular data is around 

tritium.

Now, this is another product that was generated. And 

let me take a little time here. On the lefthand side 

this is a density plot with bootstrap uncertainties. So, 

on the left, if we did this 10,000 times, this is zero to 
.

81

500 times. That's more of a histogram, as you see 

across the top. The bottom, or the X axis, is actually 

the dose.

So, even though the DuPont construction trade 

worker, the light blue on the far right, that's around 

6-point, maybe even 7-point-something millirem, it 

looks lower than the other two, but the dose is 

higher. It's lower because it has a wider spread of 

distribution, largely due to the fact that it's a much 

smaller population, so you have a greater uncertainty 

associated with that.

And just like the construction trade worker, this was 

the 6.5 millirem that you see here. And it's got a very 

tight distribution around that uncertainty, from the 

density quad. And that's largely driven because that 

has the highest number of construction trade

workers.

And then, finally, the subcontractor construction 

trade workers is more of the red or the pink version 

that you see here. And that has the lowest exposure, 

close to 6 millirem, even though -- and its uncertainty 

is fairly tight, a little bit tighter than that of the 

DuPont.

So, these are two different products that come 

together to give us an observation around the 

uncertainty associated with the bootstrap techniques 

for us to understand the dynamics in these coexposure models.

So, what are we taking away from it? First question? 

Did I hear questions?

(No response.) 

Dr. Cardarelli: Okay. The first one was 

representativeness. What we talked about earlier is 

what we are seeing in these particular data for tritium 

results on using NOCTS.

Obviously, during the 1970s the DuPont construction 
.

82

trade workers dominated the particular number of 

available data points to be analyzed. And then in the 

1980s the subcontractor construction trades 

dominated the number of available data points. 

That's something we've already been aware of.

The second implication is the stratification leads to 

increased uncertainty, which is one of the primary 

reasons we're asking input from the Working Group 

of whether or not we should further stratify.

What you see in this particular product is you have 

the geometric mean in dose in millirem on the X axis. 

And on the Y axis you have the geometric standard 

deviation. Now, these two parameters are linked to 

each other. So it creates the ellipse around the 

central data point, because if you change the mean 

you're going to modify the geometric standard 

deviation. And this is a way for understanding both 

of those uncertainty in this graphic interface here.

So, just to remember, this was construction trade 

workers. There's 66 of them in 1986. The average 

was around 6.5 millirem, with a GSD of around 3.l.

If we were to just now look only at subcontractor 

construction trade workers, this is those 39 

construction trade workers, what you'll notice is, first 

of all, the dose is slightly smaller. It's around 6 

millirem. And the uncertainty around that number 

gets to be a little bit larger. And that's largely driven 

by the fact that it's got less numbers. So it's going to 

show greater uncertainty.

And then, if we only look at DuPont workers, which 

are 27 in this particular year, you could see that the 

uncertainty around that dose estimate, which comes 

to around 7.5 millirem, the uncertainty is much 

greater. And, again, that's driven because the 

numbers are smaller. So, is it worth it to break the 

co-exposure into two separate stratified groups, 

DuPont, or prime versus subs? That's one of the 

questions we'll be asking input from the Working 
.

83

Group on.

So, I just put both of these products together for 

1986. We've already seen them both. And these are 

two graphical tools that we can use to kind of look at 

each individual year if we needed to. And they're all 

provided in Dr. Chalmers' report, of how we might 

want to consider is there particular years that we are 

concerned about? Or, overall, what is the uncertainty 

with these various models? So, those are useful tools.

The third implication is, what we've observed is that 

the sub construction trade workers were generally 

lower exposed to tritium than DuPont construction 

trade workers. And you can see that in the red 

triangles, which were routinely lower in the overall 

dose. If you take a look at 1986 we're around 6.5. 

Very tight grouping here, which is one of the reasons 

we showed that.

But if you go back into the '70s the subcontractor 

construction trade workers, even with the 95 percent 

confidence intervals around that dose estimate, are 

generally lower than that of the DuPont. And certainly 

when we have the combined, which is the green, you 

can see that there's substantial overlap for most of 

the years, such that the all, or the current coexposure model seems to be representative of both 

of those cohorts.

But there are years in which they're substantially 

different, like 1978 year, where the construction 

trade workers are very much smaller in dose relative

to that of the DuPont construction trade workers, 

even after taking into account the 95th confidence 

intervals.

The other implication, and I think this is rather 

obvious, is there's a constant downward trend in 

tritium dose. This probably is the result of improved 

radiological controls and decreased exposure 

potentials over time. It could also be due to a change 

in the operations, tritium production rates, and things 
.

84

of that nature. But we can certainly see there's a 

reduction over time.

What's interesting about this is that the fifth 

implication is, if the dose itself is less than 100 

millirem and I put the red bar across the bottom here, 

that wouldn't even qualify legally that dosimetry be 

even performed for tritium because that does not 

trigger the ten percent requirement or the 

requirement for monitoring workers. If you can show 

that their exposure potential is less than 100 millirem 

it wouldn't be necessary. It doesn't matter.

But they were monitored, and we do have this 

information. So, what you see here is most of the 

subcontractor construction trade workers over the 

course of '72 to 1990, almost all fell below that 

monitoring criteria, except for 1972. But even that, 

with the uncertainty bar, fell below that. So that's an 

interesting observation from this data.

So, our last implication is, can we -- oh, Dr. Lockey, 

you're on mute.

Member Lockey: Yes, John, one question. That's 

based on the 95 percent confidence, right?

Dr. Cardarelli: Yes. You can see the 95th per 

confidence intervals, which are the thin lines going 

above and below each of the geometric mean. Tim, 

you had a comment?

Member Lockey: But the implication for monitoring, 

it's not the mean, it's the 95 percent confidence. Is 

that correct?

Dr. Cardarelli: Yes. Tim.

Dr. Taulbee: Right. This is the 95th percentile that 

we're plotting here, Dr. Lockey.

Member Lockey: Right.

Dr. Taulbee: And the 95th percentile confidence 
.

85

interval about that 95th percentile.

Dr. Cardarelli: Yes. Yes.

Member Lockey: I understand. But --

Dr. Taulbee: Okay.

Member Lockey: The implications for monitoring at 

100 millirems is based on the mean or the 95 

percentile presumed?

Dr. Taulbee: It's actually based upon the potential for 

the individuals in that area. But it's also combining all 

of their exposures, external, internal, et cetera, 

under the modern standard. So, it's a little bit of a 

misnomer to try and just pin it down to 95th or to 

50th percentile from that standpoint. 

Member Lockey: Right.

Dr. Taulbee: So, I guess the point that we probably 

should have better emphasized here is that these 

doses are low. And that when you get out into the 

1980s type of time period it would be questionable 

as to whether you would even need to monitor these 

particular workers. But the site did, from this 

standpoint.

Dr. Cardarelli: And this is tritium.

Member Lockey: You don't take -- you're not taking 

into consideration other radionuclides here, correct?

Dr. Taulbee: No. No. This is just the tritium.

Dr. Cardarelli: This is, yeah, just to demonstrate how 

we gained an understanding of the uncertainty 

around our models. And, again, tritium was selected 

because the conversion to dose was very simple and 

the amount of data that was available allowed us to 

do this very quickly.

So, now, are the results that we're seeing for tritium, 

are they really applicable? Can we generalize them to 
.

86

all of the other radionuclides, like plutonium, fission 

products, things of that nature? We believe you can, 

for a variety of reasons, and the fact the site itself 

was monitored, the defense in depth approach for 

protection.

And I'm showing the results from one of our previous 

studies that Tim presented in December, using 

plutonium Type S exposures between '73 and 1987.

And what we see here for the DuPont construction 

trade workers on the 50th percentile, or the mean, 

the intake of 15.71 dpm per day was estimated. In 

the subcontractor trade workers it was about half of 

that, 6.97.

So, the DuPont construction trade workers 

themselves, in essence, had a higher exposure 

potential than the subs, which is something that we 

also see, that same trend in the tritium. We saw it in 

1979 and 1987, same exact situation.

But when you go to the 95th percentile there's a 

small shift. Where in the early '70s the DuPont 

construction trade workers, which by the way 

dominated the number of construction trade workers 

at the site, were more highly exposed than the subs. 

But in the 1979 and 1987 period, when the sub 

construction trade workers tended the dominate the 

population they were slightly higher.

And I wanted to point one thing out. Dr. Ziemer 

mentioned in one of the previous meetings that, is 

there truly a difference between 279 dpm per day 

versus 326.1 dpm per day between the DuPont and 

the sub construction trade workers respectively?

The answer is, well, probably not, from 

understanding the statistical uncertainties. The 

difference here is we don't know what the statistical 

uncertainty is around each of these particular 

numbers. But we're demonstrating through the 

bootstrap technique that that can be done. It just 
.

87

would be very challenging to do.

And that's part of our conclusions here, is we believe 

data used to generate these models, we believe they 

meet the completeness definition as described in the 

implementation guide. But the assumption that the 

subs were hired for more hazardous work than 

DuPont, and therefore had a greater potential for 

tritium external exposure is not supported by this 

particular data set.

And then the subcontractors experienced lower 

tritium doses than DuPont construction trade workers 

at the 50th and 95th percentiles. And I mentioned 

which we slides we talked about on those.

The other conclusion is we've seen significant overlap 

in the uncertainty, which implies there's no practical 

difference between subs and DuPont's, which would 

go to our desire to maintain the current co-exposure 

model, which is combining them.

If we do keep the current model what we can say, at 

least for tritium, is that they would produce bounding 

or representative dose estimates for subcontractor 

construction trade workers.

If we were to conduct this type of analysis for 

plutonium or other internal radionuclides it would be 

very time consuming and difficult due to the 

complexity of the procedure to estimate intake or 

dose.

And what we mean by that is you could do the 

multiplication approach for all the sensor data 

associated with that, which we didn't have for tritium. 

We'd have to do a time-weighted one-person onestatistic, and then run it through the Integrated 

Modules for Bioassay, or the IMBA program, to 

estimate the intake modeling.

And then on top of that you have to do that 10,000 

roughly times for all of the other bootstrapping 

techniques. And that could be done fairly quickly once 
.

88

you get through this point. But, nonetheless, to do it 

for hundreds of individuals to get that level of 

understanding would take months and months to 

accomplish.

So, the concluding slide here is, do the subcontractor 

construction trade workers exhibit higher internal 

exposures than DuPont? That was our first question. 

The bootstrap analysis done here does not support 

that particular hypothesis.

Should the construction trade workers have their own 

co-exposure model? We really bring that question to 

the Work Group.

And then, are the current co-exposure models based 

upon this and some of the plutonium work that we've 

presented, are they acceptable for dose 

reconstruction purposes without going to further 

stratification?

So, with that, I'm happy to answer some questions.

Member Roessler: I have a question, John.

Dr. Cardarelli: Yes.

Member Roessler: Yes. It's Gen. I don't know how to 

make the hand go up there. And I'm sure we're going 

to have a lot of discussion on this and the 

conclusions. This bootstrap uncertainty analysis 

procedure, is that now a generally accepted way to 

do this sort of thing?

Dr. Cardarelli: I would argue that it's a pretty 

standard statistical approach to understanding 

various statistical parameters where you have a 

difficult time getting it.

Member Roessler: Okay. Thank you.

Member Beach: Can I have a follow-up question on 

that? This is Josie. I had the same question Gen did. 

Is there some examples of where the bootstrap 
.

89

method has been used, right off the top of your head?

Member Lockey: This is Jim Lockey. We've used it a 

number of times. And we have large occupational 

databases that goes across various job tasks and job 

positions where we have a substantial number of 

data and we have to ask the question, do we stratify 

or we don't stratify? How representative the data is.

And what the bootstrap analysis allows us to do is 

that you retrieve a sample, and then you put that 

sample back in and you randomly resample. And you 

do that time after time, up to thousands of time. And 

by doing that you really strengthen the database that 

allows you to look at the geometric mean and 

geometric standard deviation relationship, the 

quartiles. It sort of gives you an idea of how strong 

or not strong your data is. 

In this example, we pulled the subcontractors apart 

from the contractors. And we found that when we 

pulled them apart the uncertainty increases, with the 

stipulation that they sort of have the same bell 

distribution. Then that means they pretty much 

belong together. They fit together well.

If we would pull them apart and the two groups' 

uncertainties decrease, that means they most likely 

need to be separated. But the idea is, this sampleresample in a random fashion allows you to generate 

large numbers using the original database in a 

random format.

So, for example, if you had some outliers, you have 

a possibility of sampling those outliers five times in a 

row and putting them into your calculations to see 

how that influences the overall model.

It's helpful for us in looking at these types of large 

data, because in very few databases do we have all 

data. It's very unusual. And in some of our studies 

we have a substantial number of data but we still do 

it to make sure that we are not misrepresenting 
.

90

something. So, the answer, Josie, yes, it is used.

Member Beach: Thanks, Jim.

Member Ziemer: This is Paul. Could I ask John or 

maybe Tim, when we talk about bringing in 

subcontractors for more hazardous work, for internal 

dose, do they actually calculate a working time limit 

for a job based on internal dose?

Dr. Taulbee: It depends upon the area and the time 

period. We have seen where they were doing some 

tracking of the DAC-hours when they were doing 

some refurbishing on one of the B lines in the late 

1980s, I believe, from that standpoint.

In general, though, the bringing workers in for more 

hazardous work is really more tied to the external 

dose where they were directly measuring what the 

external dose was, and they didn't want to burn 

people out. 

Member Ziemer: But that's exactly my point. When I 

worked at Oak Ridge, we did a lot of what we called 

burning people out, and we stood there with 

stopwatches in our health physics group and timed 

them, and they would get a -- well, we actually 

worked in terms of daily dose limits, and that might 

occur in 90 seconds or something like that. 

Dr. Taulbee: Right, and --

Member Ziemer: And those were clearly burning 

people out. On internal, typically, you don't want 

them to get any exposure.

Dr. Taulbee: Exactly.

Member Ziemer: You're working with zero. Now you 

could calculate, perhaps, if something went wrong, 

there might be then some concentration. 

But I have never actually seen anybody have a 

limited work time for internal if they were properly 
.

91

masked or had the external meeting protection. 

So that's what I was really concerned about, the idea 

that we were burning people out. Internal would be 

much more likely that their exposures would be 

similar to the regular workers -- or workers.

Dr. Taulbee: That is correct, sir. The one exception 

to that is tritium from that standpoint, from the 

internal standpoint. There are some times where you 

will use stay times because of saturation of the 

bubble suit or so forth. 

Member Ziemer: Right.

Dr. Taulbee: So that's one of the benefits of using 

this tritium analysis here. But really, our main --

Member Ziemer: Right. But the tritium is -- the doses 

are so low to start with. So, I mean, those 5 

millirems, I don't even worry about the error bar in 

that. You don't even worry about the 5 to start with. 

But that's my personal view. 

Dr. Taulbee: Dr. Anderson has his hand up.

Chair Anderson: Yeah, I would just say that bootstrap 

can be helpful, like per Jim's research projects where 

you have these large databases. 

What it does in this instance, it's really trying to 

increase your numbers, which then reduces -- since 

you're sampling out of the same timeframe you're 

now just adding a whole lot of additional people in 

but you're not really adding any samples. 

So it somewhat skews your statistics to look more 

significant when in fact, you don't -- in this instance 

here, you only have the 66 or 27 people you're really 

working with and that -- again, we're talking here 

about people who are drawn out of a group that have 

filed for compensation. 

We really don't know how representative that group 
.

92

is of the overall group that's been exposed unless we 

were to look at the other measurements. 

So it's a interesting statistical technique, but I'm not 

sure that it proves that it's representative, and you 

got to -- the group where you start has to be 

representative. But we don't know that. 

Dr. Taulbee: Well, I would say, Dr. Anderson, that 

from a representativeness standpoint, these are all 

claimants. 

So these are all people who got cancer, and from the 

standpoint of -- from a dose-cancer relationship, this 

would not be diluted by people with low exposures 

who did not get cancer. 

These are people who are all claimants. Every single 

one of them that we used in the analysis here are 

claimants and so we're using a group of monitored 

workers and developing this and stratifying to apply 

to a group of unmonitored workers. 

Chair Anderson: But you don't know what the 

unmonitored workers -- what the distribution of 

cancers is in that group. And you don't -- I mean, the 

other thing, you look at the cancers -- so they're all 

cancer. But a lot of them are going to be prostates 

and other -- I mean, are they all eligible and got their 

number of days in and all that? 

So, you know, who actually hears and gets to file is 

not a random sort of event, I don't think. So how 

representative is it of all the workers at Savannah 

River Site who may have been exposed? There's a lot 

of people who may have had high exposures who 

don't file a claim. 

Dr. Taulbee: That is true. But if you're -- I mean, this 

population, if anything, because of the cancer 

preselection component should be higher than those 

amongst the general SRS population. 

So that's where we feel this is representative, and 
.

93

then we further, you know, stratified to do this 

comparison to figure out more of how much 

uncertainty is there within this group. 

Member Lockey: So these cases are all cancers 

compared to everybody else, correct?

Dr. Taulbee: These are all claimants who have filed -

- who have filed claims. They all have cancer to be in 

the NOCTS data set.

Member Lockey: Right. Okay. And so this would be, 

if anything, if they have cancer, you would suspect 

their exposure levels to be higher? 

Dr. Taulbee: That is correct, sir. 

Chair Clawson: But not officially. There's a lot of 

people that have come down -- have not had cancer 

and have way higher doses. It's just part of the thing 

of the human bodies. 

Member Lockey: But if you're -- if you're saying that 

increasing dose is related to cancer in general, we 

would say that this would be about bias population. 

If we're looking for increasing radiation dose, you 

would pick a cancer cohort to say that's probably 

where we're going to see the increased radiation 

dose.

Chair Clawson: You could. One of the things that's 

interesting to me about this -- and I've told you guys 

this a long time -- this program is like a great big 

computer. You put garbage in, you're going to get 

garbage out. 

This is also something else I want to remind people. 

This is a comp program. This is not go out and 

evaluate if we've monitored or got to there. 

This is also why we have an SEC put in place, too, 

because if we don't have the data, sufficient data, 

this is why it's there. I think -- I think it's all really 
.

94

interesting stuff. Don't get me wrong. I think some 

of these analyses and stuff like that have really been 

quite educational to me. 

But I just keep coming back to that -- what this 

program was all set up for, what we are supposed to 

be doing with it. 

Member Lockey: What I see with this data is that it 

is -- in this data set, looking at tritium, that this is 

pretty solid data. 

I mean, if you resampled this 10,000 times, we're 

looking to try to make it diverge and you can't do it. 

It is solid data. I mean, at least for tritium. Now, 

whether tritium is representative of other 

radionuclides, et cetera, I guess we would have to 

discuss. 

And I wasn't looking for this, but that the 

subcontractors had a substantial lower dose in 

comparison to the DuPont was a revelation to me and 

I didn't understand that. 

I thought from what we'd been thinking that the 

subcontractors in relationship -- or this relationship 

to tritium the subcontractors had a lower dose. 

Whether that applies to the other radionuclides or 

not, I guess, raises the discussion that in some cases 

it's somewhat applicable to the plutonium and other 

cases not. 

And then the third point I got from this is that after 

1980, at least for tritium, if you're just looking at 

tritium, the biological plausibility of an adverse 

outcome at that dose is -- will be very difficult to 

measure. 

Chair Anderson: I mean, one of the other things 

about the bootstrap, what that does is it helps you 

control for outliers. So the more your data is 

distributed in a normal curve, the more likely are you 

able to randomly select and have it be representative 
.

95

that way, and that's partially why the more times you 

go through it, if it isn't a bell-shaped curve, you're 

going to be sampling more lower people than you are 

on the higher end. 

If it's normally distributed then, basically, you ought 

to be able to almost reproduce it. So it helps you 

understand, one, I mean, you're using a geometric 

mean partially because this tends to be a one-sided 

tail on your exposure estimates. 

So it's a helpful technique to understand visually how 

your data is distributed. But I'm not sure it really 

helps with being representative. 

Member Lockey: I would agree with Dr. Anderson, is 

that if we pulled the two parts apart, subcontractors 

out of the whole group, and the subcontractors had 

a lot more outliers, we would see that, that that 

group then also in their comp zones with resampling 

would become tighter, which would have indicated 

that that group really is different than the contractor 

group. 

Chair Anderson: I mean, the other thing to look at 

here is when we talk about outliers, these exposure 

that are in this particular example with tritium 

already are pretty low. So you're bordering on the 

non-detect side of things. 

Member Lockey: I don't think censored data was put 

in this, was it?

Dr. Taulbee: No. One of the nice things about tritium 

is that we really can measure extremely low doses. 

So --

Member Lockey: Well, I don't think censored data is 

appropriate here, right? 

Dr. Taulbee: That's correct. There isn't any in this 

case.

Chair Anderson: In this case. Oh, okay.
.

96

Dr. Taulbee: There will be with plutonium or --

Chair Anderson: Yeah. 

Dr. Taulbee: -- and mixed fission products and 

others. In fact, censored data would be a significant 

issue. 

Chair Anderson: Yeah. 

Member Lockey: So you've got to explain again to me 

why you think this may be representative of the other 

radionuclides.

Dr. Cardarelli: Well, that's our implication six, and we 

have looked at the plutonium Type S, largely because 

it has a long retention period in the body where 

tritium doesn't. It's very -- it clears very quickly. 

That analysis here that Tim kind of presented back in 

December kind of showed that at the 50th percentile

the DuPont CTW's exposure, at least in the '70s, was 

about twice that of the subs and then they were 

about the same, roughly, in 1979 and 1987. 

That's the same type of trend we saw for tritium. So 

you know, that -- there's an extrapolation there. But 

we don't have the uncertainty numbers around that. 

And then, of course, on the 95th percentile, if you 

take a look at the right hand side you get to see a 

little flip flop. 

But the numbers themselves, I would argue, 

probably have enough uncertainty around them that 

there's probably no strong statistical difference. But 

I cannot say that with the data that we present here. 

I'm just showing you what the point estimates are. 

Dr. Taulbee: The point that I would add just a little 

bit to that is the 50th percentile of the data is more 

driven by what I would call routine low-level 

exposures, if you will, from that standpoint. 

The upper 95th percentile is going to be driven by 
.

97

your incidents that occurred, and because the DuPont 

CTW 95th percentile and the subcontractor 95th 

percentiles are quite similar from that standpoint, 

this is why we feel that this would be applicable to 

other radionuclides. 

The upper tail of your distributions are going to be 

driven by the incidents, especially for the other radio 

-- or for mixed fission products, for plutonium, etc. 

So that's why we feel that this is applicable from that 

standpoint. It's not just the tritium analysis, but 

when you couple that with the limited plutonium 

analysis that we presented back in December and 

showed these intake numbers being quite similar, 

this is why we feel we can generalize it. Does that 

help? 

Member Lockey: One other question. The tritium 

analysis -- this data mainly comes from work in and 

around a nuclear reactor?

Dr. Taulbee: The reactors as well as the tritium 

facilities. They did take -- there were tritium targets 

that were irradiated in the reactors, and then they 

were separated in the tritium facilities to extract the 

tritium. 

But actually the majority of the exposures come from 

around the reactors. Once they got it into the tritium 

facilities it was mostly a glove box type of operation. 

But those are the two areas. 

Member Lockey: What was the other radionuclides 

around the tritium facilities? 

Dr. Taulbee: None, just the tritium. 

Member Lockey: Just the tritium?

Dr. Taulbee: Yes. 

Member Lockey: Okay. 

Chair Clawson: So John, I just need you to clarify to 
.

98

me. So what you're telling me is that you feel the 

bootstrap analysis addresses the completeness 

concern that we have?

Dr. Cardarelli: Certainly. I think we addressed that in 

the last presentation and our argument, by looking 

at the Implementation Guide 006 for completeness, 

it's not just the number of measurements -- which 

some people constantly refer to -- it's also whether 

or not we have a fair and equal distribution of 

occupations that are represented that were most 

highly exposed. 

So we're looking at the number of measurements, 

those occupations, and are those occupations that we 

do have data on, were they the most likely exposed 

in the group, and we believe the answer to that is 

yes. 

Chair Clawson: Okay. Well, that being said, does 

anybody else have anything they want to discuss on 

this before we go on to SC&A? 

Dr. Cardarelli: Well, the last two bullets, is there -- it 

would be great if we could get some feel from the 

Work Group on either one of those two bullets. 

Dr. Taulbee: Why don't we wait until after SC&A's 

presentation, John?

Dr. Cardarelli: Okay. That's fair. 

Mr. Barton: Okay, well I guess that's my cue and, 

really, there's sort of two main facets to this. 

There is how does this bootstrap analysis relate to 

the SEC discussion -- which is a the entire discussion 

today -- and the second part sort of in a more of a 

global sense is can this type of tool, this 

bootstrapping tool be used, essentially, across the 

program to determine when stratification is 

necessary. 

So those are really two different -- two different, I 
.

99

guess, lines of discussion and really, on the first one 

and how this relates to the actual SEC discussion that 

we have been having about representativeness and 

completeness, and just because of the timing of when 

this work came out SC&A, obviously, didn't have time 

to do a full complete review of the tool itself in a -- in 

a programmatic sense. But we do have some initial 

thoughts on it and so we can discuss that a little bit, 

too. 

But let me just -- let me throw up SC&A's 

presentation one more time. Again, we only had, 

really, one slide on this -- the tritium bootstrapping 

analysis in the context of the SEC discussion. 

One thing we note is that tritium -- NIOSH and SC&A 

specifically agreed when we were setting up the 

sampling plan for RPRT-0092 -- which, again, is the 

direct comparison between RWP monitoring 

requirements and subsequent follow-up monitoring -

- we left that out as not being able to answer the 

question, basically because it's such a low dose 

potential, as was shown in the presentation, and it's 

just the reactor areas. 

So, I mean, even when we were developing the 

sampling plan to answer the question about this issue 

of completeness of job-specific bioassays and the 

representativeness for those workers in any 

subsequent co-exposure model, we both agreed to 

leave tritium out.

Now given that, we completely understand why it was 

used, just from the ease of converting from these 

bioassay samples to an annual dose, and it's a lot 

easier exercise, as John enumerated, than trying to 

do something with plutonium where you -- now you 

want to start modeling intakes over a certain -- you 

know, a certain exposure period. 

Now what we see in this SEC context is that this 

bootstrap analysis really establishes whether you 

need to stratify. But before you even get to that step, 
.

100

let's -- let's remember the four major tenets of the 

implementation guide -- adequacy, are you 

measuring what you should be measuring, 

completeness, and representation, which are really 

tied at the hip, whether your data set is really 

reflective and can be used for your worker population 

-- and then after you establish that both of those, 

now you talk about whether you need to separate it 

out into different co-worker models. 

I don't think you can work -- it's our opinion anyway 

at SC&A that you can't work backwards from 

stratification to prove that two groups of workers are 

the same or not the same if there are questions 

regarding your completeness and representation in 

your data set, and I guess SC&A's opinion on this is 

pretty simple. 

Then it doesn't address completeness and 

representation of the subcontractors who are doing 

these permit-driven -- again, transient workers, 

you're not generally going to be on a routine program 

and we're supposed to be monitored via job-specific 

permit-driven monitoring. 

And I'd also point out that even though we didn't 

consider tritium in the RPRT-0092, which was really 

meant to answer the question of whether we have a 

relatively complete or sufficiently complete data set, 

there were problems with the tritium, job-specific 

bioassay as well, as shown in documentation even 

into the '90s because there was no form that was 

established until, I believe, about 1996 and so -- and 

they say, you know, there are Price-Anderson 

violations for issues with the job-specific monitoring 

program. 

So again, we go back to this may be beneficial in 

establishing whether you need to pull out different 

groups for the purposes of creating different coexposure models. 

But before you do that, you really have to establish 
.

101

and answer the questions about completeness and 

representation. 

So I think those are our thoughts on the 

bootstrapping in relation specifically to the Savannah 

River SEC question we have been discussing today. 

Now the other side of the coin is whether this is an 

appropriate analysis to do in a programmatic sense 

for all the sites once we have established that coexposure models are feasible and appropriate; is this 

an appropriate tool to analyze whether you need to 

pull out different worker populations?

And I think that's a larger question that probably 

needs a deeper dive. But I really want to focus 

everyone's attention to the fact that we're talking 

about whether the two groups should be stratified 

when I'm not sure that the question of completeness 

and representation has necessarily been answered as 

yet and reflective of the discussion that occurred 

prior to this presentation on tritium bootstrapping 

analysis. 

So again, in our conclusions, and this is the third 

bullet specific to the bootstrap analysis again, we 

don't feel that it establishes that the subcontractors 

who are supposed to be on these job-specific 

bioassays permit driven are appropriately 

represented in the co-exposure model. 

And so any comparison may be missing a significant 

portion of the exposed population. We simply don't 

know. We don't have the information, and I think that 

is really the main takeaway from an SEC context. 

So as far as we see it, the tritium bootstrapping tool 

is useful, and we haven't done our full review on it 

yet about how it's -- how it's applicable to broader 

situations, other sites, other radionuclides and the 

sort. 

But I think the question of whether it changes our 

position on the SEC matter, we don't see that does, 
.

102

because if there's a lack of completeness or 

deficiencies in completeness and representation via 

the job-specific monitoring program, then any 

subsequent comparisons sort of lose their, I guess, 

relevancy, in our view.

And I'll stop here for now. I know we have -- you 

know, Richard Griffith is on the phone, who is our 

statistician. He's done some preliminary work on it, 

and so he might have some questions about that 

second facet about using this tool in general across 

the program. 

But I'll stop here for now and I guess field any 

questions for what is a pretty, I feel, is a simplistic 

view on how this affects the SEC discussion. 

Member Lockey: Bob, let me ask you a question 

about the tritium analysis. I was just looking at how 

rigorous the data was and how uncertain the data, 

and apparently there's not much uncertainty of the 

data when you pull it apart. 

So it looks like the subcontractors' and contractors' 

relation to tritium can be treated as one. But I was 

surprised that the tritium data indicated that the 

subcontractors have substantially lower tritium 

exposure than the contractors, and that's not what I 

would have thought I would have found based on our 

previous discussions.

So what's your thoughts about that? 

Mr. Barton: Well, I guess the entire concept of 

differences in exposure potential really is not 

necessarily borne out of the quantitative analysis, 

which, again, if you don't have a relatively complete 

and representative data set you're not going to be 

able to make any quantitative determinations or 

quantitative determinations are going to be difficult 

to address the data that you don't have, that you 

don't know how those workers would have shaken 

out in these different distributions. 
.

103

But it really was borne out of qualitative statements 

made by the claimants themselves. 

Member Lockey: No, I understand that. But I think -

- would you not expect that if the subcontractors who 

were being put in the job tests where -- that were 

more dangerous or dirty, would you not expect that 

the tritium results would have reflected that?

Mr. Barton: Assuming that the tritium results were 

collected in the first place. Again, that's the question.

Member Lockey: Or do you -- would you assume that 

any of the tritium results -- there were tritium results 

that were collected, okay, and none of those tend to 

show that. 

So that means that the ones that were missed or the 

ones that were dirty or high, and the ones that were 

collected were the ones that were low. That seems 

not plausible to me. 

Chair Clawson: Well, let's take -- this is Brad. Let's 

take a look at it like this. 

If 90 percent or maybe, let's say, 65 percent of the 

construction trade people are out building buildings 

and we're using the other 25, 30 percent in doing hot 

jobs, but you've got all of your DuPont construction 

people working continuously in these facilities, what 

would you expect to see then, James? 

The DuPont people were going to be higher because 

we have got a much smaller group in these points 

that are going to --

Member Lockey: If the -- if the DuPont people were 

doing the more dangerous jobs, they would be 

higher. I guess what I'm asking, Brad, is in the 

database -- in the database for the subcontractors, I 

would expect at least some of that data to reflect 

tritium concentrations that are more reflective of the 

DuPont results, and I don't see that and I don't 

understand that. 
.

104

Chair Clawson: Well, have you ever thought that 

maybe the information coming in is flawed? Because 

I'll tell you, I'll be honest with you and I was surprised 

but I --

Member Lockey: But even that, Brad, what we're 

saying is the information that is flawed is all the 

information that's high. 

That's the flawed information, or screening out the 

high information. And that would be a very -- if that's 

the case, then I would understand it. 

But on a random basis, I would expect to see some 

of the tritium data in the subcontractors to be 

reflective and similar to what the DuPont data was, 

unless there's an active movement to just exclude 

any monitoring in a potential where there's high 

tritium for the subcontractors.

Chair Anderson: Well, and here's a question that --

another would be, if you're in an area where you're 

being tested for plutonium, would you also be tested 

for tritium? 

I mean, is it a suite, or if you're in a hot area you're 

going to be -- being tested for your most concern and 

is tritium always looked for where it could be that 

those who are in the tritium facility where that's the 

only radioactive element they'd be exposed to and 

they may have lower levels in those areas. 

It could be that your hot jobs are not being tested for 

tritium because they're being monitored for other 

elements. Is that -- I just don't know the programs 

that well.

Dr. Taulbee: No, that is not -- that's not the case. 

They would do the monitoring based upon the 

radionuclides that were of interest in that area. 

In particular, the vast majority of the tritium bioassay 

that we have is from the reactor areas where the 

tritium exposures occurred, as well as the tritium 
.

105

facilities. That's where all of the data is. It's where 99 

percent of the data is coming from. 

So it's not that if they're working in a plutonium area 

then, you know, we're going to sample them for 

tritium. That's not the case. 

That's not how Savannah River set up their 

programming, and if you look at the bioassay control 

procedures detailing who is monitored and where, 

then you find that it is done by area and by the 

radionuclide of interest in those areas.

Chair Anderson: You only have one radionuclide of 

interest?

Dr. Taulbee: In the reactor areas, no. You've got both 

tritium and fission products. In the plutonium areas 

it's predominantly plutonium from that standpoint.

In the A Area, you do have more of a mix because 

they were doing more research in that area where 

you'd see plutonium mixed fission products.

You actually don't see tritium there because in the A 

Area they didn't work with tritium in high levels. They 

worked with it as protium or deuterium. They didn't 

need to do the research with tritium directly. We 

learned that from interviews.

Chair Anderson: Okay. 

Member Ziemer: Well, this is Ziemer. One other 

possibility is that many of the subcontractors might 

have not worked the full year as a regular employee. 

But we sort of end up -- if you normalize this to 

exposure per day of work, it might look very 

different.

Jim, maybe you can clarify. A subcontractor, do they 

typically -- are they there the year round like a 

regular worker or are they just brought in for special 

jobs?
.

106

Dr. Taulbee: They are brought in for special jobs, but 

some of them are there for year round. It depends 

upon the work that was going on. 

One thing that we have learned with at least tritium 

monitoring and discussions with workers is that 

tritium monitoring when they were doing the jobs 

was done daily, and they would get together the 

following morning and the foreman would go through 

the list of bioassay results of -- and some people were 

excluded from the workplace at that time due to a 

higher bioassay than the set point. 

So they were monitoring tritium really on a more 

daily basis, depending upon the specific job. 

And one thing I would like to point out is that in John 

-- one of John's slides there, if you look at the coexposure model that we currently have, in the 1970s 

the DuPont CTWs far outnumber the subcontractor 

CTWs with regards to their representativeness in the 

co-exposure model. 

But the inverse is true in the 1980s. There are more 

subcontractor construction trades workers in those 

1980s, and yes, thank you, John, for showing this 

slide right here. 

So this speaks to the representativeness that people 

have been bringing up, and Bob, you brought up. In 

our current co-exposure model, post-1981 on a 

individual basis, and remember, we're using 

individuals here, it's -- with tritium we can calculate 

dose. 

We don't have to do TWOPOS from that standpoint. 

We can calculate an individual's dose. And so there 

are more subcontractors represented in that 

combined construction trades model -- trades worker 

model than DuPont construction trades workers in 

those latter years. 

And you can see the number of workers that are 

represented there, and this is amongst the claimant 
.

107

population that you see here. 

Member Lockey: Does that mean that the DuPont 

workers had the -- had the more dirty job tests 

during the latter part? 

Dr. Taulbee: No, it's more of the shift of relying more 

on subcontractors and less on their in-house people 

that shifted from the 1970s into the 1980s. 

And so that's why we see more of the subcontractors 

coming in in the population for this -- for this coexposure model. Does that make sense? 

Member Lockey: It makes sense. I think -- I was just 

trying to find something. 

Dr. Taulbee: Okay. And if you -- scroll a couple slides 

down, John. 

And what you'll see is when this happens that we 

have got more -- there. When we have got more of 

the subcontractor construction trades workers, it's 

also coinciding with more control of the work along 

those lines. 

And so this data in the late 1980s is exceedingly low 

from that standpoint, and you got to keep in mind 

that the subcontractor construction trades workers 

are the dominant in that particular -- in that time 

period. They're post-1980. And we're seeing that, 

you know, the two groups there's really no practical 

difference between them. 

Member Lockey: But in general, the DuPont workers 

had the higher exposures?

Dr. Taulbee: In general. Yes, sir. 

Member Lockey: Okay. 

Dr. Taulbee: And one of the reasons that we included 

tritium here, and I know Bob spoke to this as -- you 

know, it was excluded from RPRT-0092 because we 

didn't feel that this was a SEC issue. 
.

108

The tritium was well monitored and that there really 

was no question that we could estimate doses for 

subcontractor construction trades workers or DuPont 

-- for anybody at the site. 

Tritium was an easy bioassay analysis to do. They did 

a lot of it, as you see, you know, just in this time 

period. Within the NOCTS population, we have 

140,000 bioassay and 32,000 of just construction

trades workers. 

So they did a lot of this bioassay, and one of the 

reasons we did this was the initial straw man of a 

potential Class Definition that we saw shortly before 

the Board meeting in December included all radio --

all internal radionuclides, and that's what causes us 

a great deal of concern here because we know we 

have got tremendous amounts of tritium monitoring. 

And in addition to that, these doses are very low for 

this population. 

And I tried to bring that out in my December 

presentation but apparently didn't get my point --

Chair Clawson: So what you're saying is if I stipulate 

the tritium not -- that they're able to do tritium but 

nothing else then you'll be happy with it?

Dr. Taulbee: That is not correct, sir.

(Laughter.)

Chair Clawson: Oh, no? Well, that's such a small dose 

we shouldn't worry about it, you know. You know, I 

guess of my problem that I'm going back to is that 

we have for years now been going over this 

construction trades versus the other trades. 

All the different revolutions that we have done on all 

this that have kind of fallen to the wayside we could 

organize them by As and Bs and then different 

badges and everything else like that. 

And I'm -- this is my personal opinion, but I really 
.

109

have a hard time feeling that we have got a good 

grasp on this, because Dr. Lockey brought up 

something. He says, boy, this is sure interesting that 

the DuPont people are higher than the others. 

You know what? There's 10 or 12 different reasons 

probably why that is. But the one that really struck 

me that got me interested is because in the late 

1990s, because that's when it came to Idaho, was 

that you weren't on a bioassay program or monitored 

internally if your department could say that you were 

under 100 millirem. But we still made dyes. We still 

made everything.

And then all of a sudden we come down here and see 

all those construction trades were just sitting right 

below 100 millirem. That's the one that interested 

me. That's the one that I find really, really 

interesting. 

But that being said, somebody wanted to interject 

something. I'm sorry. I --

Mr. Fitzgerald: Yeah, Brad -- yeah, let me interject 

on this discussion about, you know, DuPont higher, 

lower, you know, where did the subs fit in, the fact 

that you had so many more subs showing up in the 

late '90s relative to tritium records doses.

I think we can't divorce this from what was actually 

happening operationally at the site. You know, 

there's a reason for the uptick of subcontractors in 

the late '90s. 

You were shutting down production, tritium 

production, at Savannah River. The K Reactor went 

down. This was post-Chernobyl, and you had pretty 

much all production cut off, and you had an influx of 

subcontractors to work on restart of the production 

reactor because, again, the tritium source was cut 

from the nuclear weapons program. 

So this was a extremely, as you can imagine, high 

priority influx of thousands of subcontractors to 
.

110

Savannah River to work on that. But you don't have 

production anymore. Basically, you have access 

requirements for the subs to, you know, work at K 

Reactor. Anywhere in the K Reactor fence line you'd 

have to be bioassayed for tritium, even though you're 

being exposed to residual levels that existed in and 

around. 

I mean, tritium contamination was pretty prevalent 

around the reactors, but you didn't have production 

sources that were, you know, high sources. You just 

had these contamination levels that anybody who 

worked anywhere near a K Reactor had to be 

sampled.

So you have two trends. You have a lot more 

subcontractors coming on site, thousands in the late 

'80s into the early '90s, and you had certainly a lot 

of tritium bioassays. 

But they're, you know, predominantly going to be 

lower level just simply because you're dealing with 

the residual levels of tritium that existed in the 

environment and around the reactor. 

So this just goes back to, I think, what Brad 

mentioned and what Bob mentioned earlier. You got 

to be careful about trying to draw these conclusions 

about comparisons and what the tritium exposure 

levels may suggest because, you know, again, the 

operational sources of exposure behind that, the 

source terms, may be much different over time and 

much different between classes of workers. 

So I would just make that comment on tritium in 

particular because that was a big deal in the late '80s, 

into the early '90s, because of the cut off of 

production -- tritium production at Savannah River, 

probably the biggest thing that happened in that 

timeframe. 

Member Ziemer: This is Ziemer again. Joe's quite 

right. The K Reactor shut down and never did restart 
.

111

even though they spent a lot of time and effort 

getting it back to operational conditions. 

It never was allowed to restart. That was -- I guess, 

Joe, I know it was going -- the effort to get it 

restarted ended about '92 and they declared it ready 

to restart but it never was allowed to. So late '80s, 

early '90s. 

Mr. Fitzgerald: Yeah, it turned out that, of course, the 

end of the Cold War made it unnecessary. 

(Laughter.)

Mr. Fitzgerald: But between about '88 and '90 -- I 

think it was '92, there was a fierce amount of effort 

to get that restarted, and that's why I'm saying when 

you look at these bar graphs, just a tremendous 

uptake on subcontractors, a tremendous uptake on 

bioassays. None of it surprises me. It's skewed 

everything at Savannah River for at least three or 

four years. 

But again, I wouldn't expect the actual doses to be 

that high because there wasn't any production. It was 

just simply whatever, you know, may have been 

leaking or existing in the environment. 

That was pretty much it. And with the half-life, you 

know, you just wouldn't have a whole lot to worry 

about. 

Chair Clawson: Well, that being said, is there 

anybody else that wants to ask any questions? And I 

appreciate that because, you know, this is something 

that's really been interesting to me is if you don't 

have a lot of the real history of what was going on at 

the time, a lot of this stuff can really look -- to me 

look skewed. They really do. 

And you know, I found a lot of this very interesting, 

but I think we need to take a look at where we're 

going to go with this. But we have got decisions as a 

Board. 
.

112

We have got a table motion right now until we could 

get through this information of being able to go 

forward, and I want to make sure that everybody that 

I've got, you know, can weigh in and express their 

feelings on this because this is going to come down 

to the Board and making these decisions on this. 

Well, I guess what I would look at, and I'm looking 

mainly at the Savannah River Work Group, but Paul, 

it's also your group because this is kind of the test 

run, as they said earlier, of what we're looking at on 

this for the co-exposure model. 

And so I just -- I guess what I'm looking for is 

people's inputs on this. Phil, do you have anything 

that you want to say or concerns or issues? 

(No response.)

Member Lockey: Hey, Brad?

Chair Clawson: Yeah.

Member Lockey: This is Jim Lockey. I agree with you. 

I think this really is a co-exposure modeling issue 

that, Paul, your group's going to have to write --

provide some guidance or at least some input on this 

because it would be helpful. 

Chair Clawson: Well, also, too, I agree with you, Jim. 

But also, too, we have got two different valuations of 

what the co-exposure model is saying, too. We have 

got two different opinions on that, too. 

Member Lockey: That's right, and we have two 

groups that are well qualified that have come to 

completely two different opinions, which I find 

troublesome. 

It's sort of like the CDC in conflict with the National 

Academy of Allergy and Immunology in relationship 

to COVID. 

Chair Clawson: Well, I think we see a lot of different 
.

113

opinions on that, to tell you the truth. 

To tell you the truth, Jim, see it. I don't see anything 

new with this. We both have our sides that we're 

looking at at it. The thing is that we have got to look 

at what I always want to make sure that we 

represent, and that's the claimants. 

Both of us are here to be able to do a job and the 

number-one thing with me, period, is the claimants. 

I'm not -- I'm not out here doing this for the fun and 

games and stuff like this. I'm trying to be able to 

represent the claimants the best that I can, and this 

program should be doing the same, too. And I'm not 

saying that it isn't but it is -- it is important. 

Member Lockey: So the question is, is the process 

typically defensible, which NIE says it is? Is it 

claimant favorable, which NIE says it is? 

And SC&A is saying the process is not scientifically 

defensible, and I'm not sure what they're saying 

about claimant favorable. But they're saying it's not 

scientifically dependable. 

Chair Clawson: No. And you know what? This comes 

down to the Board. This is the Board -- the Board has 

got to be the ones that adjudicate this. This comes 

down to us as a Board, bottom line.

Member Lockey: Yeah, so it's --

Chair Clawson: And basically, it comes down to what 

SC&A says or NIOSH. It comes -- it comes down to 

us. 

Member Lockey: I agree, but what I'm saying, Brad, 

is you have two well-qualified scientific groups that 

come to different opinions, right, and that -- and that 

is not helpful. Okay. 

Chair Clawson: No. No. No, it's not. But are you really 

surprised? Because to tell you the truth, I sit in a lot 
.

114

of scientific discussions, and everybody has their own 

opinion on it. 

But the problem that I have, and maybe this is what 

you're having, too, is that these are -- you know, 

people are involved. It's not a theory or a thought, 

but people's compensation is at stake here. 

Member Lockey: If we go to the compensation issue, 

is it based on the current model? Is the current dose 

reconstruction claimant-favorable? The answer is 

yes. You know, we're dealing with 95 and 99 percent 

comp intervals. 

In some of the dose reconstructions I've seen skin 

cancers to compensate for one rem exposure. So it is 

a claimable process even when NIOSH is going 

through, and I'm in agreement with that and we push 

that. It's a very claimant-favorable process based on 

the current available data. 

So the question is, is -- you know, if I look at NIOSH's 

data and I look in SC&A's data, you know, I can -- I 

can see positions that are taken that really are 

skewed and presented in a one-sided fashion, and 

that bothers me because it almost is like the two 

groups are taking advocacy positions, and that's not 

what our Board needs, and that's why we're in the 

position we're in.

Chair Clawson: Well, the other thing, though, is --

and I know that you wanted to punt off to Paul's 

group, but this really comes down to the Savannah 

River Work Group, and scientifically, under the 

program and stuff like this, it can all be put out to us. 

But ultimately it comes to us as a Work Group to put 

out a decision. Once we have put out a decision, if 

the powers to be say that, you know, they don't 

agree with it or whatever, they -- that makes it so we 

can do it. 

Member Lockey: I agree with that. No, I wasn't trying 

to leave it on Paul's group. Eventually his group is 
.

115

going to have to address the issue. It may not be in 

relationship to Savannah River, but --

Member Ziemer: Yeah, this is Paul. Let me insert a 

couple of comments here, and that is to start with --

my clock is chiming now. Can you hear me against 

the chime?

Chair Clawson: Yeah. 

Member Ziemer: Okay. So the SEC Work Group is 

mainly functioning to assure that as we approach SEC 

petitions for a variety of sites which have very 

different situations that we are addressing the issues 

of, for example, data adequacy and all of those 

related issues that we have been talking about.

It's not -- there's not a simple answer that our SEC 

Work Group can say well this -- this group has met 

the data adequacy thing so they're okay and this 

group hasn't.

I think originally Jim Melius asked us to sit in on this 

sort of to help monitor the complexity of the 

Savannah River and to lend our comments where 

necessary. 

I don't know that we have been asked to make a 

separate decision on the adequacy per se. Although 

we could do that, then we haven't met the goal to 

consider whether inference is an important part or 

inference is part of the discussion, as Joe Fitzgerald 

was talking about earlier today. 

I think we have tried to be here to help address some 

of these issues insofar as we can then expand the 

Work Group as they consider it a very complex issue. 

But ultimately Brad is right that the recommendation 

to the full Board is a recommendation from the 

Savannah River Site. The full Board may ask what 

does the SEC issues Work Group think about this, and 

for example, right now I would say the -- or the 

Savannah River Site has looked at these specific 
.

116

issues that we look at with respect to SEC. 

They've struggled with it. They've listened to the 

arguments of NIOSH. They've listened to the 

arguments of SC&A. They've considered it fully, and 

they've made their decision. 

But I would like -- I'm glad to hear from the other 

SEC Work Group Members if they think that we 

should go further and make the official decisions on 

the adequacy ourselves of this data and so on. But I 

just --

Chair Clawson: And I appreciate what you've said 

there, Paul. But I want to be clear on something, 

Lockey. If you think about this back four years we 

have been one-sided on this for four years. 

And then all of a sudden NIOSH comes out with 0092, 

and they walked away from it and went to 94, and 

now the bootstrap theory, everything else like that. 

We have been at the same position of this and none 

of these -- none of these have changed the issue. 

And the bottom line is, too, is that NIOSH and SC&A 

are reading 006 differently. 

I think that's -- you know, that's -- the guidance says 

what it says, but NIOSH is interpreting the criteria. 

That is where I'm having my problem right now and 

that, number one, I don't want to -- I don't want 

NIOSH to think that I'm belittling them in any way or 

anything else like that. 

But I don't read it that way, and I think this is what 

our biggest issue is, is the interpretation. And we --

because you said that we're kind of changing the --

we haven't changed our stance for four years. It's 

just been one more thing after another thing after 

another thing. 

Well, if this one won't work, we could try this, and if 

that won't work we can try this. And I get in trouble 

for always saying that, you know, time is an issue. 
.

117

Time really doesn't matter. You're 100 percent right 

on that. 

But to me, I think we're going on 14 years now. At 

some point, we got to be able to bring this, you know, 

to an end. But the guidance says what it says, period, 

to me, and I think --

Chair Anderson: I would just add to that in here as 

well as what Paul said. I think what I've seen, and 

that's why at one point for the metals and control 

group, we want to look at other sites that we have 

made decisions on. 

And I think what's happened here is as we get into 

some of these sites with difficulty of having enough 

data, we have really moved to the now co-exposure 

model -- it used to be co-worker -- and have kind of 

loosened up the interpret -- at least I would do, as 

we're kind of on the edge of when is what used to be 

the fallback of last resort when you don't have 

adequate data to look at. 

Is there adequate data if you develop a co-exposure 

model, and then we got into what goes -- how much 

do you need to have a reliable co-exposure model to 

replace actual exposure of individuals or the Work 

Group that you're looking at.

So we're really starting to stray out to the edges and 

I think that's where it really gets to be somewhat --

or not somewhat but definitely subjective on, well do 

you think it's sufficient and then we get into the 

reliability in the -- is it adequately protective of 

bounding. 

Well, bounding also has to be reasonable. So, you 

know, when we talk about some of these other like 

the wording of the skin cancer things and you look at 

what was that dose, then you almost get to the point, 

well, maybe that has strayed over into the -- being 

unrealistic. 

So I think we're sort of at a point where, and listening 
.

118

to NIOSH's presentation on this data and then some 

of the other data that they're looking at, is this seems 

to be the direction now is to move towards these 

subgroups like the construction workers that are 

being filed as supplemental petitions to look at 

relying on more and more as kind of the primary, a 

co-exposure model.

And I think that becomes where we really have to 

decide what initially was a fall back to, you know, last 

chance is we'll take a look at those. Now it becomes 

the lead to look at -- use co-exposure models 

combining all of the various groups, looking to other 

sites to see if we can use those data because their 

work is similar to what's done at these. So I think we 

have to be cautious to kind of not overreach on the 

use of co-exposure models.

Chair Clawson: Well, and Henry, I appreciate that 

and I think that's really good. But, you know, that 

being said, completeness and representation is first. 

Chair Anderson: Yes, I would agree. 

Chair Clawson: And the other thing, too, is is if you 

remember, right, how long we worked on this coexposure model or co-worker data, whatever it was, 

it took a long time and it finally got put out there.

And I don't like to see the goal posts once we have 

then agreed to something because I did not agree 

with this co-exposure model, and you know that as 

well as I do. I did not vote for it. I do not like it and 

I think it's got a lot of holes.

But that is what's been given to me as a Work Group 

Chair to be able to work with and that's what I'm 

going to work with, and that's the rules of the game 

there. 

But I also don't want those goal posts because you 

can't meet this criteria, let's move the goal posts five 

feet and then we can shoot it on through. That I --

that I do not agree with and that's a little bit to be 
.

119

put there. 

Member Beach: This is Josie. It sounds like you and 

Henry are agreeing with each other, and I wanted to 

make one correction. 

Chair Anderson: I'm just too wordy. 

Member Beach: Well, Henry's the Chair of that Work 

Group, the SEC Work Group. We keep saying it's 

Paul's but -- Paul is a Member but Henry's actually 

the Chair. Just a correction.

Chair Clawson: Thank you, Josie. It's just because 

Paul is such a pillar of the community.

Chair Anderson: And Henry relies upon Paul. You 

know, I don't have the work experience at the 

facilities.

Chair Clawson: Let's be honest. We rely on 

everybody here and that's what it comes down to, 

you know, and each one of us has our area of 

expertise or that we think is a expertise in some 

place. 

But I think that we need to be able to address this 

and this, myself, lies with the SRS Work Group. And 

I guess, you know -- I guess my question to the SRS 

Work Group is at the next Board meeting do we want 

to untable this and discuss it as a full Board, because 

that's where it goes. 

It's already came from the Work Group. We have 

done all of our due diligence on all the information 

that's put out there and everything else like that. 

So that being said, as we move forward, and I'm 

speaking just to the SRS Work Group, I'd like to know 

your feelings of opening it up to the Board because I 

think that we have done everything. I haven't seen 

anything that's changed anything, really. But I'm 

open to discussion. So Jim?
.

120

Member Lockey: Well, Brad, I concurred with you 

that I don't think we're going to gather any more data 

that's going to be helpful for us. 

We have to deal with the data we have, and this has 

been a useful process for me. I spent a lot of time at 

their -- our last few meetings to get a better 

understanding and clarity as well as insight into this 

and, you know, I feel -- my position is I feel NIOSH 

has presented significant enough data that they can 

do a very good dose reconstruction. 

But I wanted it to go to the Board because I think we 

have to have the Board make a decision and finalize 

this because I don't think it's worth pursuing any 

further than that. 

But if I had this as a database, I would be glad to use 

this data in a dose reconstruction to look at mortality, 

and I don't think there would be very few holes in 

that study. 

This is the database I'd love to have. You know, we 

have an abundance of data in the modern period. 

Exposures were decreasing. A lot of the exposures 

were at least under 100 millirems. 

We really run -- I know we're not supposed to talk 

about biological plausibility but we run into a 

biological plausibility issue in this modern day and 

age. Do these low type of exposures really present a 

risk at all, and is that risk measurable?

They're most likely not but that is reality. That is 

reality. This is not the 1940s and 1950s and 1960s 

and early 1970s. It's really not. 

And I think dose reconstruction can be done based 

on the data that's available in a very claimantfriendly manner, particularly when we put in place 

the 95 and 99 percent competence intervals. I mean, 

that is all encompassing of this data.

And I have not seen SC&A present anything 
.

121

otherwise that says it's not. They say there's holes in 

the data and there are certain percentages that 

aren't monitored. But they actually did not present 

objective data that says that's the case.

Chair Anderson: Okay. Thank you.

Member Ziemer: Brad, could I make another 

comment even though I'm not the Chairman of the 

SEC?

(Laughter.)

Chair Clawson: Sure. Sure. 

Member Ziemer: If the Board does choose to proceed 

with this, it's got to be very clear in the letter that 

NIOSH doesn't agree with the recommendation. 

It's got to be clear that SC&A does support the 

recommendation, and keep in mind that neither 

NIOSH nor SC&A nor the Board decides whether it's 

an SEC. 

We make a recommendation which can be ignored. 

It's Congress that makes the ultimate decision based 

on the recommendation of the Secretary of HHS. 

So we're not making the ultimate decision on this, 

and I think it's quite fair to have opposing views --

it's almost like the Supreme Court, I suppose -- but 

to have opposing views. 

Science is very much that way where -- and 

particularly in complex things. This is not --

Savannah River Site is just a great example of the 

complexity of what we have been asked to do, which 

I suppose the Congress originally thought it was fairly 

straightforward to look at the -- look at this, A, B, C, 

and they didn't -- they didn't make it easy for us 

because they required some very specific things, 

which NIOSH has done a great job of carrying out and 

which are -- the Board's contractor has done a great 

job of reviewing. 
.

122

So, you know, we have, in essence, been asked to 

have our science looked at critically, and we have 

both views in this case, and that's fine.

We had this before, at least in one case I remember, 

Bethlehem Steel. The Board was very split on that 

and NIOSH and SC&A were split on that. And, 

ultimately, the Secretary had to make the decision. 

So we need to keep that in mind. Don't feel badly if 

you're defending a particular view. I think that's 

healthy and it's good. We don't have to agree on 

everything. 

Chair Clawson: And I appreciate that, Paul, because 

I believe totally that this is why the Board is set up 

the way it is, to look at these different views, and the 

more different views that we have the better product 

that we're going to get out. 

And I'm glad you brought up Bethlehem Steel 

because I was trying to remember which one. It's not 

-- it doesn't matter. You know, this is the Board's 

decision to be able to make. The Work Group is just 

making a recommendation. And Rocky Flats. On both 

of them we had split decisions on them. It was a 

totally different thing. But we've got to kind of move 

forward on this. We have spent enough due diligence 

on this and everything else like that. 

So, Phil, if you're still on, what is your feelings about 

moving this forward to the Board? 

Member Roessler: Brad, could I make a comment 

first?

Chair Clawson: Sure, Gen.

Member Roessler: Okay. I don't know if this little 

hand here shows up. But, anyway, this is a troubling 

decision. And I'm on the SEC group, not the SRS. But 

I think one of the things that as Board Members we 

need to think about is, what is our responsibility? And 

you mentioned as a Board Member of feeling 
.

123

responsible to the claimants. 

And, actually, our responsibility is broader than that. 

And it seems to me that maybe we need to kind of 

look at the whole picture and get someone to remind 

us of what that responsibility is. And I'll just end that 

statement there. 

The other comment I'd make on this particular 

discussion today, and I think the SRS group may 

want to vote, when we get to the Board vote I will 

definitely vote for -- I guess when we talk about 

sides, NIOSH's approach, I'm totally convinced it can 

do dose reconstruction. I have not been convinced by 

SC&A that completeness and representativeness has 

not been addressed. I think we're using some 

different words here, but I feel that if there were a 

vote I would say yes, I think NIOSH could do a dose 

reconstruction. So, you wanted some opinions and I 

thought I would just give you those now.

Chair Clawson: And I appreciate that, Gen. I really 

do. You know, it's neither the position of NIOSH or, 

you know, the petitioners or NIOSH. You know, we 

do -- and I agree with you 100 percent. I always keep 

thinking about the petitioners and so forth because 

they're the ones that are passing away and dying 

from a lot of this stuff. And so that's where it's at. 

But, you know what? We have got a responsibility to 

the American people, too, and I understand that.

But, back to that, Phil, I want to give you an 

opportunity. Are you still on, Phil? Mute.

(No response.)

Chair Clawson: I guess not. So I'm going to -- I'm 

going to ask if Richard or -- if anybody else is out 

there.

Member Lockey: Brad?

Chair Clawson: Yeah.
.

124

Member Lockey: We need to bring it to the Board. I 

don't think it -- we're going to do that today, right?

Chair Clawson: Yeah, we're going to bring it to the 

Board. I don't think -- I haven't seen anything else 

that's going in there or anything else like that. 

And so, Rashaun, you know, this is coming to the end 

of the Board meeting here, so I'd like to take in from 

the Board that we move for the upcoming Board 

meeting, that we bring Savannah River on to the 

agenda and --

Member Ziemer: Brad, I think Rashaun's trying to 

speak but it's not coming through. 

Chair Clawson: Hello?

Dr. Roberts: Hi, Brad. Can you hear me?

Chair Clawson: Yes. 

Dr. Roberts: Okay, great. I actually had a question 

for you. I'm not sure that the group has the quorum 

if Phil -- I haven't heard anything from Phil. He was 

on earlier, but I don't know that he's here. 

Member Lockey: How many do you need, Rashaun?

Dr. Roberts: Three. And Richardson was not on at all 

today, I don't believe. The other thing I just wanted 

to point out is that there is an item on the agenda to 

allow the petitioner or the public to speak, and so I 

would like to honor that and give them the 

opportunity because, you know, they were cut off in 

December. 

So I just want to bring your attention back to the 

agenda and note there's also correspondence as well. 

Chair Clawson: Okay. I'll let you take care of that.

Dr. Roberts: Okay. Is it okay if we have the -- with 

you, Brad, if the -- if I open it up to petitioners or 

public at the --
.

125

Chair Clawson: Yes. Yes. I'll turn the meeting over to 

you now and then at the very end we'll go from there.

Dr. Roberts: Yes. Let's try to come back around. And 

I don't know if, Nancy, if you can hear me or if you 

could try to contact Phil. I'm not sure --

Member Beach: Hey, Rashaun, this is Josie.

Dr. Roberts: Yes?

Member Beach: Oh, bad feedback. Hang on a just a 

sec, Phil. Phil's on the line. But I think he's having a 

hard time getting through. But he's there. I just 

called him. 

Dr. Roberts: Okay. Well, he will need to somehow 

weigh in to this and it may very well be the case that 

he's connected. But if we can't hear him, then that's 

problematic. 

Chair Anderson: Could he use the chat? Tell him to 

use the chat. 

Member Lockey: Josie, tell him -- tell him to call in 

by phone. Tell him to call in by phone.

Dr. Roberts: Okay. Well, while she's trying to talk 

with him, is it okay if we go ahead and have --

although he's -- I wonder -- Josie --

Chair Clawson: Rashaun, we can't hear you.

Dr. Roberts: Josie, do you know -- can you hear me 

now? 

Member Beach: Yeah. Rashaun, he said he's been 

listening the whole time and he's trying to call in. So 

I told -- I told him to get off the phone with me and 

try to do that.

Dr. Roberts: Okay, because technically --

Member Beach: There's some interference, though. 
.

126

Dr. Roberts: Okay. Because, technically, if we don't 

have the quorum the meeting really needs to stop. 

Chair Clawson: Right. He's here and I'm glad that he 

made that announcement there. But I would 

appreciate if you're not talking or whatever that you 

mute your phone because we're getting a lot of 

feedback.

And I'll turn it over to you, Rashaun.

Petitioner Comments

Dr. Roberts: Okay. Well, assuming that he's here and 

he's listening, I'm thinking that we can go ahead and 

have the petitioners, invite them to speak at this 

point. 

So are there any petitioners that would like to make 

statements or comments or would like to talk at this 

time? 

Mr. Johnson: Yes, ma'am. This is Warren Johnson, 

one of the petitioners. Given the late time of the day 

and past experience, I'll be very brief. I have to say 

I am once again -- well, even more concerned. 

We're now 20 years into this process. For the last 

several years I've been listening to these meetings. 

It's my understanding that NIOSH was pushing that 

they could actually prove the data completeness 

through the RWPs. Then November 17th of last year, 

Mr. Cardarelli conceded that critical data is missing. 

Is bootstrapping a newly created technique for dose 

reconstructions? If not, why wasn't it used a decade 

ago? The obvious answer is that it's not appropriate 

when claimant favorability is the applicable standard. 

It's also concerning to me that NIOSH routinely 

references worker interviews when it supports its 

position, but then goes on to disregard them when it 

points out deficiencies in monitoring, even when this 

is -- these deficiencies are backed up by enforcement 
.

127

actions from Department of Energy, the Tiger Team 

report and the 1997 enforcement action. 

I feel like bootstrapping is the appropriate term here. 

As I understand it, that term refers to trying to lift 

one's self up by their bootstraps, something that 

simply cannot be done. 

Feasibly reconstructing a dose in a claimantfavorable manner is something that cannot be done 

here. NIOSH has been trying for 20 years and they 

just came up with this idea of bootstrapping for a 

reason. 

In regards to the job-specific bioassays, it's well 

documented that job-specific bioassays are for 

people who have been on a routine from other areas 

and now have new radionuclides of concern. The 

purpose of routine was never to assign a dose.

It was simply to check on the system. And so now to 

try and pull in this additional data and use it for 

something that was never intended just so we have 

enough data points to try and satisfy these statistics 

is never going to get to claimant favorable. 

As to the reference to the 40 percent that wasn't 

monitored, Mr. Cardarelli's answer was that that 

probably means they didn't need it. 

In this context, it's not appropriate to speculate that 

they didn't need monitors as there's no evidence to 

support that. That is yet another anti-claimant 

favorable assumption. 

The fact that we needed 92 to prove -- 092 to prove 

data completeness and then rejected that because 

there wasn't enough data just doesn't get us there. 

And so in order to get enough data, NIOSH has 

redefined the monitors to include effectively 

monitored, which essentially this is a guess that has 

turned into a co-worker model to get to a co-worker 

model. 
.

128

And now adding bootstrap analysis to that guess, as 

I understand it, we're basically going to average 

guesses until we get an exact measure. There's no 

way to get sufficiently accurate to ensure claimant 

favorability here, and as such, the SEC is appropriate. 

With that, I'll yield the rest of my time and I hope 

that you all have the opportunity to bring this to vote. 

Dr. Roberts: Okay, thank you. Thank you so much. 

I'm going to ask if there are any other petitioners or 

members of the public that would like to speak at this 

time. 

Ms. Barrie: This is Terrie Barrie. 

Dr. Roberts: Hi. Welcome. 

Ms. Barrie: Hi. Thank you. I wasn't really prepared 

for comments. I just have a few, and I appreciate Mr. 

-- Warren's comments that he just made and I totally 

agree with his analysis, and the SEC does need to be 

brought to the full Board and passed. 

I have an issue with using the NOCTS database, and 

I want to give you an example to -- so you would 

understand it easier. 

Let's assume that only the NOCTS database was used 

for Rocky Flats dose reconstruction. There was a 

gentleman who was a strong advocate for the Rocky 

Flats workers who had a very high body burden and 

exposures over the years at Rocky Flats and he was 

never ever sick. He never ever made a claim. 

So his exposures would not have been used to do the 

co-worker model or whatever you're calling it now. 

So I just have a -- that is -- to me that -- you're 

missing a whole lot of information if you're only using 

the records from people who have filed claims. 

And the last thing that I want to briefly mention is 

Mr. Calhoun had offered assistance to the Work 

Group to draft the language for the Class Definition if 
.

129

they decide to go forward with presenting it, and I 

have a problem with that. 

First, it's the Work Group's responsibility, and the 

Board's, to define the Class. It's in -- you can find it 

under 83.15(e) of the final rule. 

And NIOSH opposes granting the SEC status. So I 

think -- there's kind of a -- I'm having an echo here. 

Dr. Roberts: Hello. If the person with the phone 

number ending in 229, could please mute?

Ms. Barrie: Okay, thank you. So there's like -- to me, 

there's some kind of conflict of interest with NIOSH 

working on -- with the Work Group to define the 

Class. 

The Work Group, in December, had a very simple 

Class description and, basically, it was all 

subcontractor employees employed at Savannah 

River Site who were employed between October 1st, 

1972, and December 31st, 1990. I think that's all 

that's needed, but I could be wrong. 

So I kind of urge the Work Group to decline this 

invitation, and you have enough experience to do it 

yourself. So, thank you for allowing me to comment. 

Dr. Roberts: Okay. Thank you, Terrie. Are there 

others that have come --

Member Schofield: Rashaun, can you hear me? 

Dr. Roberts: Yes. Who is this, please?

Member Schofield: This is Philip. This is Phil.

Dr. Roberts: Hi, Phil. Okay. Great. Yeah, if you could 

mute for now, and I'm hearing an echo as well. 

Member Schofield: Okay. 

Dr. Roberts: Okay. So, glad that you're back. Okay. 

Any other petitioners or members of the public that 
.

130

would like the floor at this time? 

Mr. Fester: Yes, this is Josh Fester, also attorney for 

petitioner. I'll keep it brief. 

As Warren noted a lot of our concerns here, but 

piggybacking off of what Terrie said, NOCTS data is 

just absolutely inadequate sample to base this coworker model off of.

It's only -- to my understanding, that could -- correct 

me if I'm wrong, this is only folks that have filed for 

cancers under the Act and, you know, this -- Warren 

and my small plaintiffs firm in Hardeeville, we have 

hundreds of claimants, many of whom never have 

cancer but have very large amounts of dose.

And I know that's anecdotal, but I think you're 

missing -- by using NOCTS, you know, as the -- as 

the sample, I think you're missing a lot. One, for 

example, I know of -- one of my clients is on the top 

10 list for assimilations of plutonium in the history of 

the Savannah River Site. Never gotten cancer.

So I think you're missing a lot of data by relying on 

NOCTS and it's just simply -- relying on NOCTS is just 

simply inadequate. But I will certainly yield, you 

know, to the Board, and I hope you all can get to a 

vote this afternoon. 

Dr. Roberts: Sorry. It went off mute. Thank you so 

much. Are there any other comments from the public 

or the petitioners? 

(No response.)

Dr. Roberts: Okay. Well, hearing none, there is 

another item that concerns a letter that was sent to 

DCAS and because it was requested that DCAS 

forward that to the Chair of the SRS Work Group, 

Brad, and I wanted to see, first of all, if those folks 

may actually be here. 

There was a request that the letter be read at --
.

131

actually, it was the February teleconference which we 

actually -- that's where we -- we didn't bring up SRS 

at particular teleconference. 

We decided to delay discussion until today. But let 

me reach out and see if Ms. Deborah Dunlap or Mr. 

Robert Dunlap are on the line and would like to speak 

about the letter directly. 

(No response.)

Board Correspondence

Dr. Roberts: Hearing none. Okay. So, Brad, I just 

wanted to ask you, do you prefer to read the 

comments? These are lengthy comments, and I can 

certainly read through but I wanted to check with you 

first.

Chair Clawson: No. If you'd go ahead and read with 

it. I'm pretty sure of it.

Dr. Roberts: Okay. Very good. And bear with me 

because these are lengthy comments. So it may take 

a moment to get through them.

So it says, I would appreciate Mr. Bradley Clawson, 

the Chairman of the Savannah River Site Advisory 

Board, receive a copy of this letter. We appreciate 

the opportunity to provide information concerning 

the date extension of Petition 103, Savannah River 

Site. 

As we communicated with you in previous emails, the 

Class will more than likely be awarded to construction 

workers at SRS. The SEM does not include 

supervision or management for the same hazards as 

their employees. This is not an accurate assumption. 

First-line managers as a whole are exposed to the 

same hazards as their employees. 

Some of their offices are located in the contaminated 

areas and they constantly are out monitoring their

employees and looking for hazards in the field. 
.

132

The following is a summation of why it is of our 

opinion more thought should be given to operations, 

RadCon, maintenance, E&I, and laboratory workers 

as well as the supervision providing job performance 

oversight to all Work Groups mentioned above.

I, Deborah Dunlap, have attended several 

community information meetings in North Augusta, 

South Carolina. During these meetings, I'm amazed 

at the lack of knowledge the employees have 

concerning their radiological and contamination 

exposure at the site. 

As you will see in the paragraphs below, as a RadCon 

inspector I felt inadequately trained and lack of 

knowledge provided to perform my duties. 

It is disturbing that in the community outreach 

meetings there are career RadCon personnel stating 

they don't know what they were exposed to. It is 

reprehensible that construction, operations, 

mechanics, lab technicians, and E&I personnel 

depended on these grossly undertrained RadCon 

personnel to protect them from radiation and 

contamination hazards. 

This is the same department that was responsible for 

maintaining but, ultimately, losing or destroying 

pertinent exposure records. 

One, very little training during the '80s and '90s was 

provided to employees before being sent out into the 

workplace. During this timeframe, the site was hiring 

a large number of employees due to attrition of 

employees retiring and expected new missions.

Most of the training was basic industrial practices 

with no radiological or chemical training. The 

majority of training was taught by co-workers in the 

facilities assigned.

This on-the-job training was task specific with no 

explanation of the associated hazards or knowledge 

of facility conditions past and present. 
.

133

With this being said, the majority of this class of 

workers did not have any radiological knowledge at 

all. We were employees hired off the street, glad to 

have a job with great benefits. 

We were often told we were the cream of the crop. 

Safety was emphasized. We were taught about 

seatbelts, holding hand rails, driving vehicles, and 

not leaning back in chairs. 

This was great information but not adequate for us to 

understand and protect ourselves from radiological 

and chemical hazards. The personnel that were 

retiring were also people hired with no radiological or 

chemical background. 

Most of these employees worked off the 'good old 

boy' system, did not ask questions, trusted what they 

were being asked to do was safe, and did whatever it 

took to get the job done with little or no regard to

radiological or chemical hazards they were being 

exposed to. 

Putting our nation first, this class of personnel had no 

understanding of what an impact being exposed to 

these hazards had to their health. They performed 

their jobs with little knowledge of the whole process, 

which is the turnover we received as well in the '80s 

and '90s.

Two, I, Deborah Dunlap, was employed as a clerk in 

1982. In less than a year of employment, I took an 

aptitude test to determine if I could be trained for a 

position as a lab technician or RadCon inspector. 

Before going into the lab, I was offered a job as a 

RadCon inspector. 

I accepted the position with no knowledge of what 

the job requirements were. I did have six months 

training period which consisted of touring the 

operation facilities including the canyons and reactor 

areas. 

During the training, I was trained on the instruments 
.

134

used for surveying, which included instruments for 

surveying for contamination and radiation. 

Training was provided for wearing protective clothing 

including respirators, plastic suits, how to dress out 

with coveralls, hand/foot protection, and plastic 

suits. 

All of this was taught by a RadCon senior supervisor. 

Rad worker training and testing was taught before 

entering the facilities. 

Yes, we were trained but with no real understanding 

of the job duties or hazards. We were always told at 

the site that we were safe with the best safety record. 

I was assigned to L reactor as an inspector. The 

inspectors were mostly older men, very complacent 

with their job duties, and did not appreciate the fact 

that females were taking the jobs that were typically 

a man's job. 

They did not want to share knowledge with new 

inspectors. L reactor was being refurbished to restart 

during my time at the reactor. I worked alongside 

construction, maintenance, E&I, and operations. We 

were all exposed to the same hazards. 

A RadCon inspector assigned to the reactors covered 

other reactors that were still operating at that time 

during their outage and over time. 

We also covered D Area and N Area for overtime as 

well. No additional dosimeters were provided or 

acknowledged for working in different facilities. 

I had several incidents while working in the RadCon 

position. I worked one eight-hour day and eight 

hours OT to cover a spill that happened on the 

railroad tracks. 

I was not told what the spill was. My job was to 

survey the soil at the contamination until no more 

contamination was detected. 
.

135

To be honest, I had no clue what I was doing and 

expressed that concern to my supervisor. He did not 

take my concerns seriously. 

I covered a job one night for a line break. The 

operations supervisor gave briefing at the -- at job 

site. The operators were in plastic suits. The other 

participants were in lab coats, standing behind the 

roped off area to be worked in. 

Per procedure, a standby person has to be suited up 

in case something unexpected happens. He can go 

into the roped off area. 

I asked the supervisor in charge who the standby 

person was. He indicated he was the standby person. 

I told him he needed to suit up. He called my 

manager and had me pulled off the job and have 

someone that would cover the job with him not 

having to suit up.

The next night the senior supervisor apologized to me 

and told me he looked up procedure and I was 

absolutely right. It is sad that this practice was 

acceptable and this was the normal way the facilities 

were run. 

Later, the same operations supervisor stuck his 

hands in some material that he needed added 

protection. When the RadCon personnel -- person 

told him he could not do that there was a 

confrontation. 

I covered a fire in D Area one night, again, right there 

with construction workers. Again, no special 

dosimeter. Again, not really knowing what I was 

doing. 

I was sent to a reactor to help and gain a good 

learning experience of working in a shutdown facility. 

The RadCon supervisor thought it would be a good 

learning experience to cover a job with a fellow 

RadCon inspector to measure radiation rates while 

pulling fuel rods. 
.

136

I was told to watch the inspector for a while, then I 

would cover the job. This job consisted of standing 

on a bridge to monitor for radiation in a plastic suit 

while the operators did their task. 

My fellow co-worker braced himself on the bridge 

while they moved the bridge to different locations. No 

hand rails on bridge, just braced feet close to the little 

ridge on the sides.

When it was my turn, I did exactly as he did. The 

supervisor was in an area above the reactor called

the Fish Bowl. They could observe the job being done. 

When he saw what I was doing, he panicked and had 

me pulled off the job. 

As I stated earlier, this is how we were trained. This 

activity is an example of how operations were ran in 

all areas. I asked to return to clerical. 

I felt the job was not for me and, to be honest, for 

most women. Lots of climbing on scaffolding, put on 

jobs not trained for, too many rules not being 

followed, not enough questions if what has been done 

for years is correct. And while it is not recognized by 

NIOSH and the Advisory Board, we did a lot of work 

with construction with same radiological concerns. 

I later transferred from clerical to become a lab 

technician in F Area, 772F, around 1992. I was 

knowledgeable of the instruments from being a 

RadCon inspector, which was good -- which was a 

good thing.

With this job there were several concerns. I was 

assigned to co-workers to help train me on the 

different methods performed in the lab and lab 

practices of coming in and out of hoods and glove 

box. 

We were told that the procedures were written so 

that any person coming off the street could run the 

radioactive samples. This was not true for me and, I 

would suspect, for others. 
.

137

I had to learn how to perform the method to 

understand the procedure. At that time, we had 

many procedures to run the method. You were 

supposed to have the procedure open to the proper 

step while performing the method. So many 

procedures helped with that. 

Later, they did away with many procedures. It was 

impractical to expect a technician run a method by 

following a five-page procedure while working in 

containment. Buffing floors was a common practice 

in contamination areas with no additional monitoring 

of any kind and no additional protective clothing. 

You have to realize that the lab floor had several 

years of contamination being stirred up by the buffer. 

Later, this practice was discontinued. The drain 

system was not working in the lab, radio benches, 

hoods, and glove boxes. 

We would take two-liter bottles out of containment 

when full and stored them in glove boxes. Once the 

glove boxes were full of bottles, we were tasked to 

gather all of the waste bottles, bag each bottle, and 

dump the liquid waste in the area that samples were 

entered into the cell. 

With this being said, there are bottles from all the 

labs with different radiological materials and 

chemicals all being poured down the drain one after 

another, often with fumes caused by the 

incompatible chemicals mixing together. 

We wore coveralls, plastic apron, and face shields for 

protection. No additional RadCon coverage was 

provided for this job. The same method was used for 

dumping unused samples. 

Sample dumping was done when sample bins were 

full. Cell waste is waste from cells that were used to 

run samples that are too high in radiation to be run 

in a regular glove box or hood. Once the cells are full 

of waste, a team of technicians are tasked with 
.

138

removing the waste. 

We wore two pair of coveralls, respirator, and lead 

apron and pencil dosimeter. The LTD and pencil 

monitors were worn under lead apron. We did not 

wear finger rings until later years. 

No head nor extremity monitoring was performed 

except for those finger rings in later years. The 

thought by NIOSH that a dose can determine by coworkers' dose is not accurate. 

We were all in the same area performing different 

tasks with different exposure rates. As a lab tech, 

when we got a heavy rain the basement would flood. 

It was the technicians' responsibility to mop the 

water up. No additional protective clothing or 

monitoring were required. 

The dirty protective clothing worn from all crafts were 

stored in the basement for the laundry to pick up --

was stored in the basement as well as the clean 

laundry. The worn laundry would often get wet and

had to be moved around to clean the water up. 

Construction did perform a lot of work in the 

basement. 

The area was roped off but personnel could walk 

around the work area without being monitored. When 

the elevator was broken, we had to take dirty laundry

down the stairs and bring up clean laundry. 

This task was performed in street clothes. At times, 

technicians would put on clean coveralls and discover 

contamination on coveralls. Plain coveralls were from 

all areas -- were from all areas were not sorted by 

area. It was cleaned and bagged up for delivery to 

the facilities. 

In the later years, laundry was contracted out to 

facilities off site. In the early years, SRS had a 

laundry facility, which was a known -- which was 

known as a very hazardous area to work. 
.

139

The respirators were also decontaminated for reuse, 

again, not always properly decontaminated. The 

ceiling tiles in the lab would leak from condensation 

from the tile above. 

No solution was ever made for the leaks. Buckets 

were put -- placed around the lab to catch the drip. 

One of my fellow co-workers had one fall on her head 

while running a sample. 

TRU waste barrels were stored in an area that was 

normally transfers for technicians to go to the 

individual labs. The TRU waste barrels were not 

removed in a timely manner. 

Number three, I, Robert Dunlap, was employed by 

DuPont at SRS in 1984. My training to be an operator 

consisted of respirator use, forklift operation, and 

CPR. I have previously been employed in commercial 

nuclear reprocessing as done in F and H Areas.

After the rigorous training I received in the 

commercial world, I was shocked at what passed for 

training at SRS. I would like to address the issues 

related to my time in 221-SA-line. 

This facility concentrated uranyl nitrate-depleted 

uranium. Heated it to drive off all the liquid, the 

vacuumed and drummed -- the uranium powder, 

sometimes called yellow cake. Half-face respirators 

were used only when handling the powder but the 

entire building was always covered in yellow dust. 

Even the control room and offices were covered. 

Given these circumstances, I was constantly inhaling 

and probably ingesting this uranium powder. 

Bioassay samples were a monthly schedule, which I 

believe to be insufficient. 

The concept was to fill the bottle as the month 

progressed. Because there is such a disgusting odor 

to open a bioassay bottle, once you started it the top 

practice was to fill in in one shift. This does not 

provide the level of monitoring necessary to track a 
.

140

slow constant intake of uranium dust.

Based on my personal experience, NIOSH does not 

recognize this when performing dose reconstruction. 

The irony there is that in the last five years uranium 

miners have been added to the people eligible to 

participate in the compensation program.

Uranium miners' exposure is identical to that of those 

who worked in 221-FA-line. And, yet, NIOSH refused 

to consider this as a factor in my dose reconstruction. 

So how can uranium miners be added while 221-FAline workers are being discredited? It's because 

NIOSH contends that the DuPont area program was 

adequate. 

As I listened to the recent Advisory Board meeting on 

December 9th, 2020, it was clear that Mr. Bradley 

Clawson adamantly believed same way, but the 

NIOSH representative constantly pushed back. 

It appears to me that NIOSH's involvement in 

approving this petition to extend the inclusion date is 

a conflict of interest. If the inclusion date is moved 

out, NIOSH would receive less work and, 

subsequently, less funding.

Thank you for your effort in pursuing extending the 

SEC inclusion period in Class determination. Also, we 

appreciate your consideration of our information and 

hope that it provides some insight into the work and 

monitoring formerly practiced at SRS during the 

DuPont era and early Westinghouse operation of 

SRS. 

Obviously, the early '90s Tiger Team uncovered these 

same issues, which validates the proposed extension 

of the SEC inclusion date and expansion of the class 

of workers. Debra Dunlap and Robert Dunlap, who 

have signed that.

So, that's the letter.
.

141

Chair Clawson: Thank you, Rashaun.

Dr. Roberts: Sure.

Work Group Discussion

Chair Clawson: That being said, Phil, I need -- if --

Rashaun, is it okay if I take back the meeting for a 

minute now that we have got Phil?

Dr. Roberts: Sure. Absolutely. 

Chair Clawson: Okay. That being said, Phil, I've --

you've been listening to everything. What is your 

feeling about moving the SEC to the full Board? 

Member Schofield: Hey, Brad?

Chair Clawson: Yes.

Member Schofield: Can you hear me again? 

Chair Clawson: Yeah.

Member Schofield: Okay. My feeling is let's go forth, 

put it before the whole Board. I have great concern 

because, you know, a lot of these subcontractors 

worked for -- well, one of the guys even said he had 

worked for six different subcontractors out at 

Savannah River. 

So where they were a lot of these guys didn't know. 

All they knew is they were assigned. You know, 

someone take them over to this area and drop them 

off and you do what you're told over there. 

They're not going to know for a CATI report which 

buildings they were in necessarily, what they did on 

one day or one week or even one month. 

So I'm all in favor of putting them before the whole 

Board. 

Chair Clawson: Okay, thank you, Phil. I appreciate 

that. That being said, we have all voted that we're 
.

142

going to move it ahead to the full Board.

Rashaun, I'd like to have plenty of time to be able to 

discuss that. But I'm going to ask a very big question 

and this is a view --

Dr. Roberts: Actually --

Chair Clawson: What?

Dr. Roberts: Brad, can I just ask a question --

Chair Clawson: Sure.

Dr. Roberts: -- for what you're bringing to the Board? 

So let's see. So are we bringing the same thing that 

was brought before? Is that --

Chair Clawson: Yeah. We are untabling the SRS SEC 

and bringing it to the full Board because there's too 

much information that they kind of run out of time. 

And --

Dr. Roberts: Okay. And is there agreement among 

the Work Group for the description of the proposed 

Class that you are untabling?

Chair Clawson: We don't have to come up with that 

description until the Board votes one way or the other 

because if the Board votes now then there's no 

reason for a description. 

Member Beach: Can you ask that 229 to mute so we 

can hear, Brad? Because I can't hardly hear him.

Dr. Roberts: Okay, but let me mute then. And, Brad, 

if you would --

Chair Clawson: Yes, it's already been proposed to the 

Board. What the Board takes from that, what they 

decide one way or the other, then the description 

would come out on that. If they vote that this is 

adequate data, then we don't need a Class for it. 

But if they decide that there is insufficient data, then 
.

143

we'll make the Class then. Is that what you needed 

to know, Rashaun?

Dr. Roberts: So you want to ask the Board -- the 

question to the Board is that whether or not people 

believe that there's sufficient data for dose to be --

so you want to just bring that for discussion?

Chair Clawson: We're going to bring this to the Board 

for a vote and so there's going to be a small 

presentation. And we can discuss it and revise it if 

the Board feels, you know, strongly about it. 

But it's already put before the Board. We're just 

untabling it. I would like to have a small presentation, 

and Tim and Joe or Bob or John, I guess, I'm going 

to be honest with you. I don't want to see more than 

four or five slides. 

Just to give a background of where we're at, because 

the last time when we dumped 71 slides onto the 

Board where they hadn't seen hardly anything, it's 

information overload. 

And so we're just untabling this and proceeding 

forward. But there'll probably be some questions 

there. I'd like to be able to make sure that we have 

got the information that the rest of the Board 

Members want to ask and go from there. 

So we'll move this to the Board meeting. That being 

said, as Lockey and Gen mentioned of why they felt 

that there was sufficient data, I want to mention why 

I feel there is not. 

I feel it is inadequate for many areas. Number one, 

we're looking at 773-A. We're looking at one area. 

Three hundred areas in the Savannah River Site. We 

have got partial information. 

I do not feel good about where it's at. It seems like 

the last four years there has been more information, 

more information to try to make the last information 

that didn't work. 
.

144

And if you look at the whole process, we have gone 

through all of this and we're back to where we were 

at when we started four years ago. 

Now, if this data would have been all that good and 

all that wonderful right then, I would have felt like 

that we should have done it clear back then. 

But that's my opinion, and all of us have opinions and 

it is -- there is no problem with us voting this and 

going ahead without NIOSH's concurrence. That's 

their position on it. 

Because this is just a recommendation, as Paul said, 

from us as a Board to HHS, and they're going to be 

the ones that ultimately say yes or no. 

So I just wanted to go on record of saying that and 

just go from there. 

Dr. Roberts: Okay. 

Member Lockey: This is Jim Lockey. I agree that, and 

with the Board. I think it should be reflected that I 

think there is adequate data. 

Brad thinks there's not. And that we're bringing it to 

the Board for a thorough discussion and a final vote, 

I don't think any additional data is going to add to 

this. 

I will disagree with Brad. I thought the analysis that 

we just recently performed was data -- really 

convinced me that this data is strong enough for dose 

reconstruction and that informed me in relationship 

with my change in position. 

But, you know, it's my opinion as looking at the data 

over a period of time. But I think it has to go to the 

Board. I don't think any more delay is necessary 

here, and the Board will make the final decision.

Dr. Roberts: Okay. I do see a couple of hands raised. 

I see Jenny had her hand raised and also Tim. 
.

145

Member Lockey: Okay.

Dr. Roberts: Jenny, did you have a question? 

Ms. Naylor: So I have a couple comments. One, in 

the past, the Board has taken one definitive vote on 

the recommendation to the Secretary. And when that 

recommendation is voted on, it has certain clarity in 

terms of the Class Definition, the finding, that the 

dose that cannot be reconstructed costs -- you know, 

endanger the health of the class of worker. 

So, you know, you should be ready to clarify for the 

Board the dose that cannot be reconstructed, and 

that is part one of your statutory responsibility. 

And part two of your responsibility is to justify why 

that dose could cause harm to that class of workers. 

And as we know through the program's 

implementation, DOL has to be able to implement the 

Class. 

So I think what's sort of missing from this 

conversation is who are precisely those subcontractor 

CTWs? How would DOL go about identifying them and 

putting them in the Class?

So that will be something that the Board would also 

need to clarify either through Brad's presentation or 

through the Board's discussion. But that part of the 

conversation needs to be fleshed out. 

Chair Clawson: Well, Jenny, that sounds real 

wonderful. I'm glad you brought all that up. But 

guess what? We will have to be able to -- first of all, 

we have got to be able to get the Board one way or 

another and make the decision. 

The Board will consider with DOL as appropriate to 

be able to implement this as we have always done 

and we have always brought up opinions of do we 

think that we can do this, do you see any issues for 

it, and I know that you've been involved with them.
.

146

And any dose -- you know, when it comes down to it, 

the Board should not have to clarify Class Definition 

endangerment with NIOSH. So that isn't the biggest 

issue. 

We'll work through that and we'll go from there if --

and I know that we have got plenty of legal counsel 

there to be able to help us. So, first of all, we have 

got to get this to the Board a make the decision one 

way or the other. 

Dr. Roberts: Okay. So just for my kind of -- just so 

that I'm really clear, so it almost seems like talking 

to the Board is going to be a two-part conversation 

almost, like, there's going to be a piece that focuses 

on, you know, whether or not data is adequate or 

whatever to construct the dose. 

And then there's the question about the SEC Class. 

So it feels to me like those are two separate -- kind 

of a two-step conversation. Am I interpreting this 

correctly? 

Chair Clawson: Well, a little. First of all, we have to 

take -- and we have to bring this before the Board. 

Given that NIOSH contests the -- you know, we 

accept NIOSH will disagree with the Class. It's not an 

issue. 

But first things first is we have got to bring this before 

the Board. We have got to tell them where we feel at 

it. This was already brought to them once before. We 

had an awful lot of data that came in on that, and 

now it's going to be up for a vote. 

Once the vote is taken, that is when we'd either 

decide their -- what the Class Definition is and 

everything else like that or we don't have to make 

the definition of the Class because it didn't pass. 

So it's coming before the Board for the vote. I just 

want to make sure that if there are questions there 

that people are able to ask these questions and get 

clarifying questions answered. 
.

147

There's an awful lot of data out there and a lot of 

Board Members may have to go through it and make 

up -- read before the presentation and go from there. 

But they've got all the data before them. Nothing's 

really changed except for what was discussed in this 

meeting. 

Dr. Roberts: Okay. So I know Tim is --

Member Ziemer: A question, Brad or Rashaun. 

Dr. Roberts: Yes.

Member Ziemer: Do we have a copy of the issue that 

was tabled? That's what's going to come up. The 

wording of what was tabled? Because the Board's 

going to need to know what years it covers and the 

exact subgroups. 

You know, it's not everybody that worked at 

Savannah River during that year. So what is exactly 

in the motion that is coming off the table? Brad, that's 

what we'll -- we will be voting on, right?

Chair Clawson: Right, it's the -- right. Yeah, and it's 

the subcontractors, not --

Member Ziemer: And the years --

Chair Clawson: It's the subcontractor SP from 1972 

to 1990. I believe it was December of 1990. Just 

CTWs -- subcontractor CTWs from 1972 to 1990. 

Member Ziemer: And at this point, no one has 

clarified whether Department of Labor could --if this 

passed if Department of Labor could actually 

administer it with that description, that we have --

that remains to be the determined?

Chair Clawson: Well, that -- Paul, that would remain 

to be determined afterwards. 

Member Ziemer: Okay.

Chair Clawson: But, you know, you've already looked 
.

148

at -- NIOSH has already said, you know, that they're 

able to take all these CTWs and separate them out. 

So that really shouldn't be a, you know, an issue right 

there. 

Dr. Roberts: Okay. I know that --

Member Ziemer: I just wanted to make sure that the 

Board knew what they would be voting on.

Chair Clawson: Right. 

Dr. Roberts: Right. And I know Tim has had his hand 

raised for a bit. Tim?

(No response.)

Dr. Roberts: Tim, I think you're on mute.

Dr. Taulbee: Thank you very much. Sorry. This is a 

question for you, Brad, as to what your expectations 

are for us as to whether you want us to do a -- I 

heard a short four-slide type of presentation, which 

we can certainly do if you would like. 

I'm just trying to figure out your expectations of a 

presentation for the full Board. Is a four-slide 

summary acceptable to you? Is that what you want? 

Or do you want us to just give it to you all?

Chair Clawson: You know, I'm going to be -- if you 

take a look at the last four years of the information 

that we have gone through on this, I wanted to make 

sure that you, as NIOSH, have the opportunity, too. 

But we really did this last time. My whole thing is I'm 

just untabling the motion that was put before the 

Board. 

But I feel that you need to be prepared to be able to 

-- if there is discussion to be able to discuss it, and I 

was thinking four-page -- four slides to be able to just 

bring them back to speed of where we're at and why 

you feel the way that you do and why SC&A feels the 

way they do. 
.

149

Dr. Taulbee: Okay.

Chair Clawson: And I know that there's a lot of data 

out there, but a lot of this is we get data overload 

and I just want the main pitch.

Dr. Taulbee: Understood. We can certainly try and 

summarize it in four slides and then SC&A can do 

theirs and to the Board, then.

Chair Clawson: Right, and, like anything, we need to 

have this well before the Board meeting so that the 

Board Members that are reviewing this have the 

opportunity to be able to review it and make 

questions to be able to ask and go forth from here. 

We have been privileged to be able to have the 

opportunity to go through all these discussions that 

they have not, and I just want to make sure that they 

deal with it the best that they can.

Dr. Taulbee: Understood.

Member Lockey: You're going to have your four 

slides, but I would have backup slides and then I 

would get all the backup information that those two 

slides rely on to the Board Members so they had a 

chance to review it before the meeting, because we 

don't want them to say, well, I don't have all the 

data. 

I'd like to have them have the data that your slides 

are relying on ahead of time so they have something 

to refer back to. That'll save us a lot of time. 

Dr. Taulbee: Understood. What I wanted to know if 

this would be acceptable. I mean, most of this is --

in fact, all of this has been presented before. 

So we will pull a compendium together of all of the 

slides that we have been presenting and then I will 

just do a quick four-slide summary of pointing to the 

key points that you could find within all that 

background material.
.

150

Member Lockey: And they should have that 

background material --

Dr. Taulbee: Yes.

Member Lockey: -- so that they can refer to it. And -

-

Member Ziemer: Quick question.

Chair Clawson: Go ahead, Paul.

Member Ziemer: Brad, is somebody making sure that 

David has been brought up to speed on all the 

different issues? I don't think he was at the last 

meeting either. 

Chair Clawson: He wasn't -- he was to part of it and 

he was part into the Board meeting. I'll touch base 

with him. I'll reach out and touch base with him and 

let him know where we're going. 

The biggest thing is, and Rashaun, this is going to 

come down to you, is to make sure that the Board 

has all this. Well, they've gotten it several times. 

I just want to make sure that they have the data that 

they have been presented and gone forth from there.

Dr. Roberts: Right. And that's why, you know, I do 

want to just touch base both with NIOSH and SC&A 

just to make sure because the Board meeting is not 

that far away. 

So do you have sufficient time to pull together what's 

being requested including the compendium of data 

that's more like reference material for the Board so 

we have adequate time to get everything together?

Dr. Taulbee: This is Tim. From my standpoint, we can 

certainly get a four-slide presentation together. 

That's not a problem from our standpoint. 

Pulling everything together, we'll get with our team 

tomorrow and go through to make sure of that. But I 
.

151

don't really foresee any issues from that either 

because everything is actually out on the web 

already. 

All of the key documents are. It's more of us pointing 

folks to those key documents that are all out there at 

this time. So --

Dr. Roberts: Okay. Great. SC&A?

Mr. Barton: Yeah. Right along the lines of what Tim 

just said, I mean, the information is already out 

there. The reports are -- I think all of them are posted 

online at this point, and it's just a question of putting 

together some summary slides, again, pointing back 

to those reference documents or previous 

presentations, what have you. I don't think -- I don't 

foresee that being a big issue.

Dr. Roberts: Okay.

Chair Clawson: Yeah, Rashaun. I just -- Rashaun, this 

is Brad. I didn't see the information being that big of 

a deal because it's already been presented to 

everybody. 

It's just this last time was data overload. And so I 

would suggest that maybe we send out that they 

review this, that this is going to be coming up for a 

vote and that all this information is in the last couple 

of Board meetings. 

Plus, they're able to go into our Work Group meeting 

and pull what has been discussed there, too. So I 

don't see that as a real big issue. I just want to --

Dr. Roberts: Sure. But considering -- but considering 

the packet with the -- I just wanted confirmation that 

it is reasonable to expect that everybody get that 

together, given the short turn around, and it sounds 

like both are able to do that. 

My next question is then how much time are we 

talking on the agenda? Because we, certainly, don't 
.

152

want to be cut off. You know, we want to be able to 

have a full discussion this time around. So how much 

time, roughly, do we need to carve out? 

Member Lockey: Rashaun, what's on the schedule 

now? 

Dr. Roberts: I'm sorry? How much time is on it now? 

Member Lockey: Yes.

Dr. Roberts: I actually don't have it in front of me. 

I'd have to pull it to see how much time is now. But, 

you know, that was an estimate, you know, just kind 

of based on my best guess. 

So I don't think that that's necessarily something to 

go by. But yeah, how much time do we think we need 

for the --

Chair Clawson: Personally, me -- here's kind of what 

I would like to have. I'd like to be able to have it --

I'd like to be able to have at least a minimum of two 

to two and a half hours. 

I'd like it at the beginning of our Board meeting 

instead of at the end so that if anything comes up 

we'll go from there. I think, myself, I think two and a 

half hours is ample time.

Dr. Roberts: Okay. And in terms of your presentation 

to NIOSH and SC&A, you know, how much time are 

you looking at? It sounds like a very brief 

presentation that's being requested and --

Dr. Taulbee: Yes, very brief. 

Dr. Roberts: -- I just think --

Dr. Taulbee: It's -- like I said, it's more just stating 

our position and pointing to the documents of how 

we formed that basis. That's it. 

Dr. Roberts: Okay. So right now, it's -- SRS is right 

after the DOE program update on the first day, and 
.

153

you said, Brad, at least two and a half hours, two and 

a half to maybe three hours for that. And I can, 

certainly, try to find time for that. 

Chair Clawson: Okay. 

Dr. Roberts: Okay. Very good.

Chair Clawson: I'll get Dave Richardson caught up 

with it. He wanted me to let him know where we were 

at and so forth. So I'll bring him up to speed on where 

we're going and what we're doing. 

Dr. Roberts: Okay. That sounds good. And I'm trying 

to think if there's anything else. Brad, is there 

anything else that you wanted to cover? I think that 

kind of brings us to the end. 

Chair Clawson: No, that's all I wanted to cover and 

all we're going to do is what was put before the Board 

at the last one. I'll make sure that we have got the 

same verbiage that we presented to them before and 

we'll still overview and then be able to have 

discussion on it. 

But I would like, Rashaun, that we make sure that 

before the Board knows this is coming to a vote and 

this information in these areas of the Work Group, 

the last presentations of NIOSH and SC&A at the last 

couple of Board meetings. 

Dr. Roberts: Okay. But we're relying on SC&A and 

NIOSH to actually pull together those materials, 

correct? 

Chair Clawson: For the presentation or for review?

Dr. Roberts: And the background materials, et 

cetera.

Chair Clawson: Well, it's our -- I don't know if we 

really have to. It's out there already for them. 

They've already seen -- it's already been presented 

to them. 
.

154

So I've just looked at the last Savannah River 

presentations that we have got. It's there for them to 

be able to get clarifying questions answered. 

Member Lockey: And I would -- this is Jim Lockey. 

(Audio interference) need you to reference the 

documents that it's based on. 

Dr. Taulbee: Could you say that again, Dr. Lockey? 

You're breaking up.

Member Lockey: If you're making references on your 

four slides, you have to back it up with the documents 

you referring to and where they're located so people 

can find them.

Dr. Taulbee: That's correct, and my plan, hoping we 

can execute this, is to actually make sure those are 

copied under the supporting materials for the Board 

meeting. So that we'll get another link there on the 

website that people can click on to get those 

documents. 

Member Lockey: Okay.

Chair Clawson: Okay.

Dr. Roberts: Okay. 

Chair Clawson: Rashaun, anything else? 

Dr. Roberts: No, I don't believe so. I don't believe so. 

Adjourn

Chair Clawson: Okay. That sounds good. With that 

being said, I'd like to tell everyone I appreciate their 

time today. Been a long time coming and everything 

else. 

We are always going to have opportunities to 

disagree with one another. And guess what? That's 

why this Board is set up the way it is. 

I appreciate Dr. Ziemer's comment on that because I 
.

155

think of -- over the years of some of the discussions 

that we have really had, and I will be truthful, there's 

been a lot of times that I've been swayed different 

ways than what I was thinking and sometimes not. 

But the thing is, is this is why this Board was set forth 

the way it was, and I feel that it's very important that 

we do have these discussions.

With that being said, I call this meeting adjourned. I 

have a beach to go see.

(Whereupon, the above-entitled matter went off the 

record at 4:10 p.m.)