NEAL R. GROSS

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Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

132nd Meeting

Wednesday, December 11, 2019 

The meeting convened at 8:15 a.m., Pacific Time, in 

the Hilton Oakland Airport Hotel, One Hegenberger 

Road, Oakland, California, Ted Katz, Designated 

Federal Official, presiding. 
2 

Members Present: 

Ted Katz, Designated Federal Official

Henry Anderson, Member*

Josie Beach, Member

Bradley P. Clawson, Member*

R. William Field, Member

David Kotelchuck, Member

James E. Lockey, Member

David B. Richardson, Member

Genevieve S. Roessler, Member*

Phillip Schofield, Member*

Loretta R. Valerio, Member

Paul L. Ziemer, Member

Registered and/or Public Comment Participants: 

Adams, Nancy, NIOSH Contractor

Barton, Bob, SC&A

Behling, Kathy, SC&A*

Blaze, D'Lanie

Buchanan, Ron, SC&A*

Calhoun, Grady, DCAS

Crawford, Frank, DOL*

Durso, Kelley, NIOSH

Kinman, Josh, DCAS

Lewis, Greg, DOE

Lobaugh, Megan, NIOSH

Marion-moss, Lori, NIOSH

Martz, Amy

Mcfee, Matt, ORAU Team

Montano, Eileen

Porter, Diane, NIOSH

Ringen, Knut*

Taulbee, Tim, DCAS

*Participating via telephone
3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health 132nd Meeting 

Wednesday, December 11, 2019 1

Roll Call/Welcome 4

NIOSH Program Update 6

DOL Program Update 11

DOE Program Update 18

Completed Dose Reconstruction Procedure 

Reviews 29

External Dose Reconstruction 30

External Coworker Dosimetry Data for 

the K-25 Site 35

Dose Reconstruction Method for CLL 47

Board Work Session 64

Draft Report to Secretary, HHS on Dose 

Reconstruction Reviews 69

Board Work Session 78

SEC Petitions Status Update 94

Board Work Session 97

Coworker Modeling Guidelines Review and 

Update on Savannah River Site SEC Petition 

#103 101

Update on Lawrence Berkeley National 

Laboratory Site Profile Review 155

Public Comment 185

Adjourn 185
4

Proceedings

(8:23 a.m.)

Roll Call/Welcome

Mr. Katz: So, welcome, everyone. This is the 

Advisory Board on Radiation and Worker Health. We 

are on our Meeting 132, which is quite a big 

number.

We're here in Oakland and happy to be here. We're 

here in part because Board Members had a tour of 

Lawrence Berkeley National Laboratory, which I 

understand went well and we'll hear more about 

that later today from Dr. Ziemer, who chairs of that 

Work Group.

So, let me get through some preliminaries for the 

agenda today. First of all, for the people on the 

phone, the materials for today, the presentations, 

the background meeting today, those are all posted 

on the NIOSH website for this program under 

Schedule of Meetings, today's date.

You can go there and read all those background 

materials. You can follow along with the 

presentations. They're all posted there.

There is also, as you'll see if you pull up the agenda 

from the website there is a Skype link.

And if you want, you can watch the presentation as 

it's given in the room through Skype. That's all it

does. It doesn't do any more. You can't speak to the 

group through Skype and so on. But if you want to 

do that you can.

Let me also mention that we have a public comment 

session. That comes at the end of the day, 5:30 to 

6:30. So I would encourage people to be ready at 

5:30 for public comments because the way we work 

this is we go right to the public comments and if we 

run through all the public comments at the time, we 

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

could conclude at any point after that once we're 

through the commenters. So please join us at the 

beginning of the public comment session so you are 

assured to have your opportunity there. And we'll 

remind you of this later this afternoon again as well.

Let's see. So, I am going to run through roll call first 

because we need to have a quorum of the Board 

Members. We have a number of Board Members 

that are joining us by phone. So we'll run through 

Board Members.

Let me just speak to conflict of interest while we're 

at it too. We only have one agenda item today that 

relates to a conflict. That is one of the Oak Ridge 

sites and Jim Lockey is conflicted for that.

It's a procedure review, so if you'll just -- since it's 

just a piece of even that session you don't need to 

leave the table, Jim, for that. You just need to 

recuse yourself from that discussion. And that will 

work fine.

But otherwise there are no conflicts to address.

So let me run down the list alphabetically.

(Roll call.)

Mr. Katz: So we have a full house, which is 

wonderful. Thank you. And I think we're running a 

little bit late maybe already. Are we okay? Okay. 

That's great. Okay. Well, we're right on time. That's 

nice.

And with that, with no further ado, let's have a 

NIOSH program update from Grady. And remember, 

please speak right into that mike.

Ms. Adams: Ted, are you going to do people on the 

phone?

Mr. Katz: Oh, wait. Nancy, were you asking 

something?

(No response.)
6

Mr. Katz: Okay, go ahead, Grady.

Mr. Calhoun: Can you hear me? Yeah, I can hear it. 

Okay.

Mr. Katz: People on the phone, can you hear Grady?

Mr. Calhoun: Can you hear Grady on the phone 

right now?

Member Clawson: Yes.

Mr. Calhoun: All right, thank you. Okay.

Mr. Katz: Super. Thanks.

NIOSH Program Update

Mr. Calhoun: Okay. Good to be here this morning. 

Welcome to sunny California. Not so sunny, but. All 

right, here we go with this one.

Okay. Just to go over what we typically have gone 

through in the past: contracts and staffing.

I believe I spoke last time about we've got a new 

dose reconstruction contract in our outreach.

But since that time we did -- there we go. The 

worker outreach contract was awarded to ATL. 

They've had that in the past, done a fine job. So 

that's been awarded which is good.

We're in the process of replacing the health 

physicists who have left. Darn them. But as we 

know, Stu Hinnefeld, Jim Neton left and Pete Darnell 

left. So we have three vacancies.

We've hired one health physicist so far. Still working 

on two more to backfill the people that have gone.

We're well on our way with that, but there's always 

some bumps in the road when it comes to hiring.

As far as upcoming things and things that we've 

completed on workshops, town halls and other 

outreach activities, we held our dose reconstruction 
7

workshop in Cincinnati. That's something that we do 

every year. It consists of advocates and several 

people in here have even attended that.

Pretty detailed two-day presentation about what we 

do and how we do it. And that's organized by ATL 

but most of it is conducted by DCAS staff and 

actually some of the ATL folks as well.

We had a town hall meeting in Bolingbrook, Illinois. 

ANL-East is the closest site to there. And that was 

just an information-providing session.

Upcoming outreach. We're going to -- or we did, it 

happened already. Amarillo. It didn't happen when I 

wrote these but it did now.

We had an outreach in Amarillo close to Pantex. 

That's another information-providing session that 

we had.

And we have an upcoming one here in February in 

Santa Fe. And that one is an authorized 

representative meeting combined with a Joint 

Outreach Task Group meeting. So that's a three-day 

meeting that's going to be held in Santa Fe in 

February. I'll be going to that one.

Some of just the current status reports that we go 

through. 

Since August 14 we have a total of 51,576 cases 

and of those we have forwarded 49,524 to DOL. We 

have 1,000 in-house for DR, 909 have been 

administratively closed.

Of the ones we submitted to Department of Labor 

with dose reconstruction completed, we have 1628 

were pulled by Department of Labor. And then we 

also had 3,535 pulled because they were in some 

way part of a new or existing Special Exposure 

Cohort.

We have 159 requests out to DOE. Outstanding 

doesn't mean they're not being responsive. 
8

Outstanding just means that they're in the process 

of responding to that. And of those only 2 are 

beyond 60 days of our request for documentation.

Probability of Causation summary. Of the cases that 

we've sent for final adjudication, 44,361 total cases, 

12,155 greater than 50 percent, 32,206 less than 

50 percent. 

Active cases with us. We have 1,139 at our shop for 

dose reconstruction: 384 are in the dose 

reconstruction process, 221 initial draft reports are 

with claimants to review and 534 cases we're just 

getting prepped for dose reconstruction, which 

means that we're accumulating data and whatnot.

This is something that I told you last time I was 

going to change up a little bit. And in previous 

meetings we've had reports on the first 10,000 

claims, first 20,000 claims. And that's irrelevant 

now because those are done. They've been done for 

a long, long time.

So basically I just wanted to give you a little 

glimpse of what -- one of the things that's 

important to me in our shop and that's the age of 

cases. Because we always want to make sure that 

we're getting cases through our process as quickly 

as we can.

Some of you have been around long enough to 

remember that that was one of our biggest 

complaints from claimants is that it's just taking too 

darn long.

And so we're really trying hard to track the length of 

time that a case resides with our shop, and try and 

make that as efficient as possible.

You'll see we didn't start tracking this till 2012. But 

even back then that high peak is the six to nine 

months that they've been in our shop. That was in 

2013.

And this is just an overall view of where we've come 
9

from. What we have in 2019 which is a little bit 

more illustrative here is where we are just in the 

last -- since the beginning of the year.

You'll see that the little circles on the bottom, those 

are cases that have been in our shop for greater 

than a year. There's none. 

And 9 to 12 months, it looks like there might be 

about 5 in our shop. And then the six to nine 

months, those are really the cases that are actively 

being worked with dose reconstruction being 

performed. And we've got about 40 of those in our 

shop right now.

So this is something, a report that comes out every 

week, something I like to keep my eye on because I 

want to make sure that we're getting the dose 

reconstructions out to claimants as soon as we can.

And actually we've been doing a pretty good job of 

getting them out in a more timely way. And I think 

that may be it. I think that may be it.

Mr. Katz: Last slide, you mean?

Mr. Calhoun: Yes.

Mr. Katz: Okay. Board Members in the room, do we 

have any questions for Grady?

Member Ziemer: Grady, on the DR workshops that 

you held in Cincinnati, or workshop, about how 

many people attend that and sort of what's the 

breakdown in terms of active dose reconstructors 

versus --

Mr. Calhoun: None of them are active dose 

reconstructors at all. I would say that there's 

probably between -- more than 20 people, probably 

20 to 30 people.

We have a few repeat people that have come to a 

couple of them. They don't come every year. But it's 

a good mix of union representatives.
10

We've got people that are out there just trying to be 

kind of authorized reps for people. And it's really 

just a breakdown.

We go through the process from DOL to DOE to us. 

We actually go through individual dose 

reconstructions on how we do them. We explain 

overestimates, underestimates...

We get really good feedback from the people that 

attend those meetings. So it seems to be well 

appreciated.

Member Ziemer: And as a follow-up, the 

representatives, are a lot of these new people or 

ones that have returned just updating?

Mr. Calhoun: I would say, and I'm guessing here, 

but I would say that at each meeting 75 percent of 

them are new people that haven't been before. 

That's just a guess.

I do them all and so I kind of would recognize them. 

We do this once in Cincinnati every year, and then 

we do a traveling one once every year as well.

And that one is only one day when we're traveling. 

We kind of condense that a little bit to limit travel. 

But we do two a year.

Mr. Katz: Any other questions from Board Members 

in the room? David?

Member Richardson: Just a question. For the group 

that's not represented there which would be zero to 

six months, is it not -- am I understanding the 

picture right? There's another --

Mr. Calhoun: Oh yeah. Yeah.

Member Richardson: That would be way high up on 

the graph?

Mr. Calhoun: Yes, yes, it would be. But those are in 

the process where they can't be done. Most of those 

can't be done at that point because we're in the 
11

process of requesting the information.

Once we get the request from Department of Labor 

then we've got to make the request to DOE for the 

data. We've got to wait on that data.

We've got to do the CATI with the people. So those 

really aren't even available to us to complete. So 

only until we get to the six to nine months is it able 

to be trackable and meaningful.

Member Richardson: Okay.

Mr. Calhoun: Good question though.

Mr. Katz: Any questions from Board Members on the 

line?

Member Clawson: No.

Mr. Katz: All right. Thank you, Grady. And we're on 

to DOL program update. Frank, Chris Crawford, are 

you on the line?

Mr. Calhoun: He is.

Mr. Crawford: Yes, I am.

Mr. Calhoun: I've got to get this going here.

Mr. Katz: Okay. He's setting you up, Chris.

Mr. Crawford: Thanks in advance to Grady for doing 

the slides for me.

Mr. Calhoun: Okay, Chris, I'm at slide number one.

DOL Program Update

Mr. Crawford: Great. Thanks, Grady. My name is 

Frank Crawford. I'm a health physicist with 

Department of Labor. And let's go to slide 2.

In this slide we see that the total compensation paid 

was $17.2 billion so far. That's $6.9 billion from Part 

B compensation, $4.9 billion from Part E 

compensation, and $5.4 billion in medical bills.
12

Also of note, we have over 211,000 cases filed so 

far. Next slide.

We have referred to NIOSH 52,390 cases for dose 

reconstruction. Of those 50,632 cases were 

returned to DOL from NIOSH, 44,150 with a dose 

reconstruction, 6482 were withdrawn from NIOSH 

with no dose reconstruction.

There are various reasons for this, SEC decisions, 

death of the remaining survivor, that sort of thing.

Then the last category here, there are 1758 cases 

currently at NIOSH by our count. I'm sure the 

NIOSH numbers are correct. 

There are 1247 initial or original referrals to NIOSH, 

and 511 reworks or returns to NIOSH. Next slide, 

please.

Okay, here we have Part B cases with dose 

reconstruction and final decision. That would mean 

by implication at least that most of these cases are 

not SEC-accepted cases. A few, maybe.

We have 35,166 cases in this category with final 

approvals of 12,146 and final denials of 23,020. 

Next slide.

Then in Part B cases filed, we see that 35 percent of 

the cases were sent to NIOSH initially, and then 

there were some SEC cases that were referred to 

NIOSH, 12 percent of them.

Then there were SEC cases never sent to NIOSH, 15 

percent of all cases. 

There are 9 percent RECA cases which NIOSH also 

handles.

And then there are 29 percent other, mainly 

beryllium sensitivity, chronic beryllium disease and 

chronic silicosis cases. Next slide, please.

Now, all Part B cases with a final decision, and that 

will include SEC cases as well as cases with dose 
13

reconstructions. We have 104,097 cases with final 

decisions and that includes 55,154 Part B approvals 

and 48,943 Part B denials. Next slide, please.

Our top four work sites are Nevada Test Site. This is 

for the last quarter. Savannah River Site, Hanford 

and the Y-12 Plant. These are more or less the 

usual suspects. Next slide, please.

These are SEC petition sites presumably being 

discussed one way or another today. 

Lawrence Berkeley National Laboratory had 1,016 

cases. And of those, 222 have received a dose 

reconstruction from NIOSH, 472 have gotten a final 

decision. Under Part B, 248 approvals and 247 Part 

E approvals. And the total compensation of medical 

bills paid so far, $67 million.

For the Savannah River Site, 19,882 claims to date, 

5938 were returned by NIOSH with a dose 

reconstruction. 

We have 8387 final decisions, 3619 Part B 

approvals, 4151 Part E approvals. And the 

compensation to date, $1.38 billion including 

medical. Next slide.

We do DEEOIC outreach events regularly. And these 

consist of town hall meetings and traveling resource 

centers. With smaller SECs we just do press 

releases. We also do quarterly medical conference 

calls and authorized representative workshops. Next 

slide, please.

The Joint Outreach Task Group is charged with 

helping with this outreach effort. The members, I 

don't know that we need to go through all of them, 

but I will just for protocol here.

The DEEOIC, the DOL branch, certainly Department 

of Energy, Department of Energy Former Worker 

Medical Screening Program, the National Institute 

for Occupational Safety and Health --NIOSH -- the 

Ombudsman to NIOSH for EEOICPA Part B, Denise 
14

Brock, and DOL's Office of the Ombudsman for 

EEOICPA, Malcolm Nelson.

These include monthly conference calls as part of 

the effort and they conduct all town hall meetings. 

Next slide.

The upcoming outreach events. We have a town hall 

meeting which has already happened in Amarillo, 

Texas on December 5, 2019. Next slide.

We have a Kansas City, Missouri town hall meeting 

coming up January 20. I'm sorry, January 9, 2020. 

Next slide.

And we have another town hall meeting, Santa Fe, 

New Mexico, February 25 through 27, 2020. And 

next slide.

And a final town hall meeting, St. Petersburg, 

Florida for March 2020. Don't have a date yet, exact 

date. And that would be the town hall meetings for 

the fiscal year Q1. Sorry, Q2.

And that concludes the presentation. There's more 

on the NIOSH website containing routine 

information about survivors and benefits and that 

sort of thing. 

Any questions?

Mr. Katz: Thank you, Chris. Those are the meeting 

locations. You always make those cities look so 

beautiful. It's a wonder.

So, Board Members in the room, do we have any 

questions for DOL? David.

Member Richardson: Does DOL do any form of sort 

of actuarial projection about the number of claims 

they're anticipating over the next year, or five 

years, or decade?

Mr. Crawford: Not as far as I'm aware, but I'm not 

sure. May I ask again who's speaking? I'll get back 

to you on that if you wish.
15

Member Richardson: David Richardson.

Mr. Crawford: Thank you, Dr. Richardson. Yes, I'll 

check into it. I'm just unaware personally of any 

such projections.

Member Richardson: I was looking back over the 

presentations that we've had and the ones that I 

can keep track of.

And going back, for example, in 2011 there had 

been a total of $7 billion, $7.5 billion in total 

compensation paid.

One quarter later in January 16, 2012 it was $7.7 

billion, so $200 million in addition. 

Yet it seems to be accelerating now. So if we jump 

forward to today there's been an additional $10 

billion in compensation over the next 28 quarters. 

So the compensation now, it's increasing by about 

$360 million per quarter.

And I'm just wondering if you have projections on 

this and anticipated trends.

Mr. Crawford: As I said I don't have anything at my 

level, but I can ask about it. It does -- just from my 

personal experience with DOL it does seem like the 

Part E part of the Act is ramping up steeply, unlike 

the Part B where we have a probably diminishing 

number of claims, and more importantly a 

diminishing amount of dose for most workers as the 

older workers roll off in a sense because the big 

doses were incurred in the forties and fifties.

So, I hope that helps a little, but I will get back to 

you on any projections that we do have.

Member Richardson: Right. I agree with you, there's 

two components there. There's one is the actuarial 

calculation will tell you about the number just of 

claims coming in. Some consideration of the dose 

would lead you towards compensation for the 

radiologically associated cancers, which is more 
16

difficult. 

But just in terms of even getting a sense of where 

you are in the kind of claims projection itself would 

be useful.

Mr. Crawford: Very good.

Mr. Katz: Good question. And Chris, you can just 

send that response when you have it to Grady's 

group and I'll get it distributed to the Board. 

Mr. Crawford: Great. Will do.

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

question that perhaps is also one you might not be 

able to answer right away.

I believe I'm correct in assuming that Department 

of Labor has a process where final decisions can be 

appealed. I don't think we've ever had a report on 

how often this happens and what the results are. 

Can you give us some idea of how frequently people 

appeal the final decision that they get from the 

Department of Labor and what the success rate is?

Mr. Crawford: That would be difficult to do offhand. 

I see a fair number of those on the Part B side. So it 

does happen and it's not infrequent.

Usually the appeals occur at the recommended 

decision level because a hearing can be held if 

requested by the claimant and at that time we will 

respond to any technical objections and that sort of 

thing.

So after the final decision pretty much there has to 

be new evidence of some kind for a chance, in other 

words, of having the case reworked or accepted. 

The exact numbers I couldn't give you yet.

Member Ziemer: All of those go through Labor. We 

don't ever see that I don't think, but I was just 

curious. 
17

Would it be possible just to give us some idea of the 

frequency and the outcomes? Maybe in the next 

report or in the interim if it's feasible.

Mr. Crawford: Well, I can send this information 

when I can get it to Grady and NIOSH as well for 

posting if that helps.

Member Ziemer: Thank you.

Mr. Katz: Yes, I think that would be very 

interesting. And Chris, if you can break that out I 

think the Board would be particularly interested in 

also breaking out the proportion of those appeals 

that are specifically about the dose reconstruction 

versus other reasons for the denial. That would be

great.

Mr. Crawford: Right. In other words it's the Part B 

radiation cases that are of primary interest.

Mr. Katz: Not just Part B. But I'm saying Part B 

cases where the reason for the appeal is dose 

reconstruction versus other matters that get 

appealed.

Member Ziemer: Yes, exactly.

Mr. Crawford: Oh, of course, of course. Yes, cases 

are reopened for lots of other reasons including new 

cancers.

Mr. Katz: Yes, I don't mean reopened. I mean 

appealed and denied, because we're interested in 

the denials.

Mr. Crawford: Right.

Mr. Katz: You got it? Okay, thanks. And if you have 

any questions about this you can email me and we 

can communicate more about it. Thanks. Thanks so 

much, Chris.

Any other questions from Board Members in the 

room? Good questions. How about from Board 

Members on the line? Okay then.
18

So, DOE is up next. Greg, welcome.

DOE Program Update

Mr. Lewis: All right. Good morning, everyone. I'm 

Greg Lewis with the Department of Energy Office of 

Worker Screening and Compensation Support.

I don't have any particular new news or information 

with respect to my office so I'll get into the 

presentation.

And also I'm going to go through this fairly quickly 

because a lot of these are sort of the usual items. 

But if anyone has specific questions on these items 

please stop me and then I'll also leave plenty of 

time at the end for questions.

Okay. So again, our role within the Department of 

Energy is to provide records. That's what we do for 

the program, both to NIOSH and to DOL.

We do that in primarily three ways. We respond to 

individual requests. We provide support for largescale records research projects like SEC research 

and Site Profile, Technical Basis Document updates, 

things of that nature.

And then we also conduct research into different 

covered facilities if there's concerns that they may 

be inaccurate or need to be updated.

I'll go over some statistics. These are FY2018 

statistics. If this meeting were a couple of weeks 

later I would have had the 2019 statistics, but I'll 

have them for our next meeting.

And our 2019 numbers are more or less pretty 

similar to our 2018 numbers both in terms of 

volume as well as timeliness.

So in 2018 we responded to 16,432 records 

requests for all of our DOE locations. That doesn't 

really represent unique individuals because again 

we're going to get a request from Department of 
19

Labor for the employment verification as well as 

what we call the DAR which has all of -- they want 

everything, anything attached to that individual, 

medical, IH, radiological information.

And then we're also going to get a request from 

NIOSH as well so there might be three different 

requests on any one individual.

We had a 98 percent on-time response rate last 

year or in FY18 I should say which I think was our 

best performance to date.

Many of our sites had a near perfect record, zero 

responses late out of over 1,000 or close to 1,000. 

And again in 2019 that trend continued. We were 

pretty close to that 98 percent. I mean, we'll see 

when the numbers all shake out, but I believe we're 

very close to that number. 

So the large-scale records research projects. We're 

working with NIOSH, ORAU and SC&A on a number 

of requests now.

I think the biggest project we have going on right 

now in terms of the level of effort on the DOE side is 

probably Los Alamos. There's been a number of 

visits and records requests that we're responding to.

But there's also a number of projects ongoing with 

other sites as well.

For all of those and for even some of the individual 

claims depending on the site, there's a need for the 

review of those documents both for classification as 

well as when needed for public release.

The classification review for reports typically takes 

less than 10 working days. The classification review 

for source documents which those documents can 

be 50, 100 or more pages, that can take 

considerably longer, particularly when there's --

after NIOSH or ORAU or SC&A go on a site visit 

there could be a request for hundreds of documents 
20

and many of those can be quite lengthy.

So that can take months or more depending on the 

type of request. But we try to work with the site to 

get those back out to NIOSH and the requestor 

within a reasonable time frame.

We also try to work to prioritize when necessary. So 

if there's a large request we can try to have the 

requestor kind of order them in terms of importance 

and we'll work through it that way.

And we'll also check back so they can be reordered 

if there's follow-up visits or reports or things that 

kind of jump to the top of the list. We'll work it in 

whatever order the requestor would like and we try 

to do that as expediently as possible.

I mentioned the facility research. And there's 

actually quite a few facilities that we're looking at 

right now in concert with DOL and NIOSH.

And then outreach. Everyone has mentioned the 

Amarillo meeting and Chris gave a good update 

about the meetings to come. So we do attend those 

outreach meetings.

And then I always mention our Former Worker 

Medical Screening Program which is, again, not 

directly related to the compensation program, but 

it's -- I kind of consider it a sister program or 

almost a feeder program where former workers are 

eligible for a screening that are provided through 

cooperative agreement holders funded by DOE.

All former federal and contractor and subcontractor 

workers at DOE sites are eligible for this program. 

It's free. We can provide a screening close to their 

home.

And these screenings are evaluated by occupational 

medical physicians that are familiar with the sites 

and the possible exposures that these workers 

might have encountered.
21

And we also in some cases are able to provide a 

letter that helps that individual establish the workrelatedness of their condition and that can be useful 

for an EEOICPA claim.

And there's some information about our former 

worker programs and how you can get in contact 

with them.

And that's all I had for the presentation. I'd be 

happy to take any questions.

Mr. Katz: Thanks, Greg. Questions from Board 

Members in the room.

Member Beach: Greg, I know NIOSH is waiting for 

some documents to be released from LANL. Any 

update on how that's going?

Mr. Lewis: I mean, I don't have a specific update on 

the documents. If you gave me more information 

about them I'd be happy to give you an idea of the 

schedule.

I know that the work there has been fairly 

aggressive in terms of the number of visits and I 

believe there's a deadline of, I think, February. I 

think there's a goal of kind of finishing up the site 

visits and getting most of the information by 

February.

We're doing our best to meet that goal.

I think there was an issue recently where some 

documents were delayed, but my understanding is 

that was more of an issue of personnel and staffing 

at the lab not being -- vacations and different 

people kind of being out. 

But I know that that work is in general progressing. 

So we are working through the different document 

requests for facilitating site visits.

I haven't heard of any sort of major issue that 

would derail that project. 
22

Member Beach: Thank you.

Mr. Katz: Thanks, Josie. David.

Member Richardson: Thank you for the 

presentation. And I agree, it's things that we've 

heard but there continue to be issues that I puzzle 

over and I think it's just my limited background.

DOE frames its responsibilities, one of the key ones 

that was up here was responding for requests for 

information related to claims that might include 

employment verification and exposure records. 

So that would be the type of material that would 

impact on the Board's understanding of how 

decisionmaking happens with respect to the 

program.

That was presented up there as DOE's 

responsibility. When one encounters an instance in 

which there are -- questions might be raised about 

the accuracy or completeness of information which 

is provided to a claimant in terms of either 

employment verification or exposure records is that 

-- legislatively where does that fall when DOE would 

not, let's say a claimant would feel they hadn't met 

those responsibilities?

And does the buck ultimately stop with DOE, or 

does DOE turn to those contractor organizations? 

What is the legislative responsibility or act that 

would cover record-keeping and record provision?

I guess despite the fact that I've been trying to 

understand the program for over a decade, I don't 

quite know where the buck stops.

Mr. Lewis: So, if I'm understanding your question 

correctly, I mean, it can get a little bit tricky with 

the relationship between DOE and the contractor 

and particularly the subcontractor.

So under the legislation as far as I understand DOE 

is responsible for providing the records that DOE 
23

owns and has a right to.

So typically for our prime subcontractors, there's no 

confusion about that. The prime contractor manages 

the records on behalf of DOE, but DOE owns those 

records.

In some cases historically the flow down to the 

subcontractor may not have been there in terms of 

personnel records, or things that DOE kept.

So a sub might have been hired by the prime. They 

would have come on, done their work and in terms 

of the formal employee record that prime contractor 

would not have kept that record and would not have 

had a right to.

The way the contract was set up the record would 

have stayed with the employers, a plumbing or 

construction company or whatever the case may be. 

Those are typically the ones where we run into 

those issues.

Now, that doesn't mean we necessarily have 

nothing on that individual. What we'll do within DOE 

is try to check for any, again, not a typical 

employment record, but any kind of tertiary 

information that we may have on that individual.

So if the person was hurt onsite we're going to look 

for a medical record. They don't always go to the 

site medical clinic, particularly if they're a sub so we 

may or may not have that record. Or the person 

may not have gotten hurt so we may not have that 

record.

If they wore a dosimeter or had any kind of 

radiation monitoring we should have that record. 

But again, particularly with construction, if it was a 

new build or something they may not have been 

badged. So, we may or may not have that record.

So we do go to those secondary sources to try to 

find everything we can.
24

We've also done some things to try to make sure 

that current subcontractors have to maintain those 

records or turn them over to DOE when they leave.

So we have an access to an ownership of records 

clause that's supposed to be included in certain 

contracts, whether it might be a health and safety 

connection.

So we have done some work in the last 10 or 15 

years to try to ensure that DOE has more of a right 

to current subcontractor records in particular.

But essentially the records that we try to obtain are 

those that are currently held at DOE sites by the 

DOE contractors.

And of course for the prime contractors as they turn 

over, those records would remain with the next 

prime contractor because they're DOE-owned 

records.

So those are the records that we're able to go after.

Member Richardson: So DOE for the prime 

contractors and in more recent years for 

subcontractors, views -- it's the ownership of the 

employment -- the records used for employment 

verification and dosimetry, views its status as the 

owner of those records.

It has responsibility for record-keeping and 

reporting of those records. And if there was -- if 

there are problems in the completeness, accuracy of 

those, those -- the buck would stop with DOE 

because those were records which they legally had 

ownership for and responsibility for reporting for the 

keeping and reporting back through this program.

Mr. Lewis: Yes. And I think the key part of that is 

what we had legal ownership of because it can 

depend on the site and the particular contract.

So those contracts are structured based on the work 

that the company is doing. So I'm not going to say 
25

that DOE has legal ownership of all records created 

in relation to a site. There's vendors, there's 

consultants, there's sort of a lot of different 

contractual relationships.

But in that contractual relationship -- I'm going to 

say for all prime contractors and for most of the 

larger subcontractors, the subcontractors that are 

doing work that might encounter any health and 

safety issues, we believe we have it set up where 

we should have ownership rights these days.

But again, going back that's not always the case.

Member Richardson: But in instances where there 

were let's say larger systematic gaps, or failures of 

reporting the football shouldn't be punted back to 

the contractor or historical contractor which may not 

exist anymore.

That would be viewed as those were records which 

DOE had responsibility for record-keeping and for 

currently reporting on.

And it would be the DOE that a claimant or 

Department of Labor or somebody should turn to.

Mr. Lewis: Yes. If I'm understanding you correctly, 

yes.

But again, we can only provide the records that we 

have. So if for whatever reason records were not 

turned over when a contractor left historically, or 

there are gaps in the records, whether records 

weren't created that should have been, or records 

were destroyed that shouldn't have been.

I mean you guys are well aware of those issues 

because they play into a lot of the SEC decisions of 

course. 

What I usually say is within DOE we do the best we 

can to find all of the records we have. If we don't 

have it, we can't recreate it unfortunately. So we do 

the best we can to find the records that are still in 
26

our possession.

Member Richardson: Thank you.

Mr. Katz: Thanks, David. Other questions from 

Board Members in the room? How about -- oh Paul, 

go ahead.

Member Ziemer: Greg, I have one question about 

the medical screening program which we now say 

there are occ med physicians available to all former 

workers close to their homes, I think is the term 

used. Locations close to their residences.

And I'm wondering what that means, how close. 

Let's say they don't retire near where they worked. 

Let's say someone from Oak Ridge decides to retire, 

say, in Corbin, Kentucky or I don't know, some 

little, remote place.

Mr. Lewis: Sure.

Member Ziemer: I hope I'm not insulting people 

from Corbin. It just popped into my mind. But how 

close can we find an occ med physician or someone 

has to go more than x miles to get that care.

Mr. Lewis: So that's a good question and let me 

clarify a little bit. So, occ med physicians will 

evaluate the results of their screenings.

(Simultaneous speaking.)

Member Ziemer: I gotcha. Okay.

Mr. Lewis: So in some cases the occ med physician 

actually will be there for the exam, but for most of 

our programs they're going to go to a clinic and our 

programs will have a relationship with that clinic 

and say here's what we need done, and we need it 

done a certain way.

And a lot of times they'll audit those clinics to make 

sure are they doing things the right way. Are the 

results that they're getting up to par compared to 

the other clinics?
27

So they're going to get the results. And then the 

results are evaluated by that physician.

And of course we have an initial interview somewhat 

similar to the CATI where staff in the former worker 

program are going to talk to that individual, what 

did you do, where did you work, what were you 

exposed to, did you do this, that and the other. And 

they have kind of a list of questions. 

A lot of people say they worked here. Did you do 

that. They have some prompts to kind of help them 

remember. 

So they'll go through that interview so the occ-med 

physician that evaluates it will have that interview 

from the worker, they'll have the results of the 

screening and they'll also have that -- that occ-med 

physician will have a background knowledge of the 

site.

They have something somewhat similar to a Site 

Profile they put together on each site so they kind of 

know the general hazards and what went on at that 

site. They visited the site, talked to people. 

That way they'll be able to look at the interview, the 

results and use their knowledge of the site to kind 

of put those together to try to come up with some 

recommendations or some findings as far as 

possible work-relatedness when they can. But the 

occ-med physician is not necessarily near their 

home. 

But in terms of distance we have relationships with 

clinics. So we have done people most likely in 

Corbin, Kentucky, although I'm not sure.

We've done I think a few folks even in Canada. 

We've kind of gone all over the place because we do 

have relationships with clinics nationwide.

Member Ziemer: Sounds good. So someone can 

retire to Hawaii and still be covered.
28

Mr. Lewis: Yes. You retire, we'll find somewhere 

near you.

Member Ziemer: Thanks.

Mr. Katz: Thanks, Paul. Board Members on the line, 

any questions for Greg?

Member Schofield: Yes, this is Phil Schofield.

Mr. Katz: Hi, Phil.

Member Schofield: I've got a question. What is a 

person who's having difficulty getting their records 

from a site -- who would they appeal that to or 

address?

Mr. Lewis: Well, I mean for starters they can 

contact me. I get contact from individuals or 

authorized representatives or advocates or DOL or 

NIOSH.

So I'd be happy -- you can go directly to me and I 

can work through my contact at the site. I also have 

site contacts so I'd be happy to help troubleshoot if 

there's some issue.

And we do that quite frequently. And we have a 

pretty rigorous process at these sites where they've 

been doing this for 15 years now so they generally 

have a pretty set process and there is some QA/QC. 

Errors -- things are missed on occasion and errors 

are made like in anything else where there's 

16,000. So if an individual thinks, wait a minute, 

this can't be right, or this doesn't look like my 

records, or this isn't the complete record let us 

know and we'll see if -- we'll go back, make sure 

that we followed our process and then make sure is 

there anything else that we think we might be able 

to do to find a record, find any missing records.

So you could go directly to me.

Member Schofield: Okay, thank you.

Mr. Katz: Thanks, fellows, good question for the 
29

public in particular. Other Board Members on the 

line?

(No response.)

Mr. Katz: Okay, then. So we're trotting along pretty 

much on schedule here which is great. Next we 

have three completed dose reconstruction 

procedure reviews from the Procedures 

Subcommittee.

And I have on here John Stiver from SC&A as the 

main presenter. Josie Beach is the chair of that 

Subcommittee. Something came up for John. Things 

happen, as they say. 

So I think we're having Kathy Behling who is the 

lead with SC&A anyhow for these. And Kathy, are 

you on the line?

Ms. Behling: Yes, Ted, I'm on the line.

Completed Dose Reconstruction Procedure Reviews

Mr. Katz: Super. So Kathy, Grady is going to search 

desperately for the presentations. 

Ms. Behling: Will we start with the first one listed on 

the agenda? 

Mr. Katz: It's up to you, it doesn't matter, but I 

have external dose reconstructions as the first one. 

Is that what you're ready to present first?

Ms. Behling: That's fine. If Grady can find the slides, 

I'm ready to present.

Mr. Katz: Okay, okay. 

Ms. Behling: Thank you, Grady.

Mr. Katz: Thanks. We'll let you know when they're 

up.

Mr. Calhoun: Don't thank me until I find them.

Mr. Katz: Can you see the slides? Are you watching 
30

from Skype?

Ms. Behling: Yes, I can.

Mr. Katz: Okay, super.

Ms. Behling: Okay. And hello, everyone. Wish I 

could be there.

Mr. Calhoun: So am I looking for something titled 

External Dose Reconstruction?

Ms. Behling: Correct. It's OTIB-88.

Mr. Calhoun: Okay, OTIB-88. Gotcha, that will help 

me. If you see it, yell stop. There it is. Got it.

External Dose Reconstruction

Ms. Behling: Okay. It's still loading on my screen. 

There we go. All right. Okay.

The first OTIB that we're going to discuss today is 

the external dose reconstruction OTIB. 

And if we go to Slide 2 OTIB-88 is the technical 

information document for external dose 

reconstruction.

And it was issued in September of 2018 in order to 

convert it from what was previously a procedure. It 

was ORAUT-PROC-6.

And that -- it was the desire of NIOSH to convert 

that into an OTIB.

The OTIB also incorporates guidance regarding the 

assignment of onsite ambient dose in order to 

ultimately cancel their PROC-60 which is their 

occupational onsite ambient dose reconstruction for 

DOE sites.

Rev 1 of this OTIB was issued in October of 2019 

and that was to correct an error in Attachment A 

which we'll discuss in more detail a little later, and 

also to add an attachment to provide dates when 

DOE sites incorporated ICRP recommendations for 
31

neutron weighting factors.

SC&A was actually tasked to review Rev 0 and we 

submitted our review in January of 2019. This 

review resulted in no findings, but there were two 

observations.

And if we move onto the next slide, that will give 

you a description of Observation 1. Slide 3.

I'll start to explain it if that's okay. Slide 3 shows 

Observation 1 which states that OTIB-88 does not 

incorporate informative guidance that is included in 

PROC-60 Attachment A which is the external onsite 

ambient dose -- I'm sorry, you okay?

Mr. Calhoun: I'm sorry. There we go.

Ms. Behling: There it is. Okay, thank you. 

So the observation was to state that OTIB-88 

doesn't include the attachments that were part of 

PROC-60. And those attachments are Attachment A 

which is the external onsite ambient dose 

assignment for monitored site employees.

There's an Attachment B, maximizing dose 

summary. And Attachment C, methods for assigning 

site-specific best estimates of external onsite 

ambient doses.

And when SC&A does our reviews and our blinds we 

use these attachments frequently and find them to 

be very useful.

We also think that it helps the dose reconstructor to 

conduct their DRs in a consistent manner. And so 

that became our first observation.

In response to that observation NIOSH indicated 

that the information won't be lost, but it will be 

incorporated into other procedures and likely sitespecific Technical Basis Documents.

But they did state that it might be better to keep it 

all consolidated in one document and asked if they 
32

could give that some thought.

The Procedures Subcommittee found that NIOSH's 

response was acceptable and closed the 

observation. However, they did request that NIOSH 

inform the Committee about their decision as to 

where this information would reside.

Subsequently NIOSH did determine that after PROC60 goes away the attachments and the information 

in those attachments will be incorporated into the 

site-specific Technical Basis Documents.

And then onto Observation 2, Slide 4. Slide 4 shows 

that observation 2 which identified an error in the 

example calculation that was provided in 

Attachment A of OTIB-88.

There are instructions for the dose reconstructor as 

to how to calculate the 95th percentile missed dose. 

And those instructions are correct. However, 

underneath that is an example calculation and the 

instructions state that the 95th percentile should be 

calculated based on multiplying the number of 

zeroes by the LOD value. However, the calculation 

below it actually uses the LOD over 2 value for 

calculating that 95th percentile. We pointed this out 

to NIOSH and they agreed that the sample 

calculation was in error. They subsequently 

published Rev 1 which we discussed earlier and that 

corrected the error in the calculation, the example 

calculation in Attachment A.

And the Procedures Subcommittee agreed with 

NIOSH's corrective action and they closed the 

observation at the February 13, 2019 

teleconference.

And that sums up OTIB-88. Do you have any 

questions?

One other thing I might mention, I'm sorry. I think 

Ron Buchanan is the SC&A person who did this 

review.
33

I believe he's on the line and if he has anything to 

my presentation perhaps we can give him an 

opportunity to do that.

Mr. Katz: Ron, are you on the line?

Mr. Buchanan: Yes. This is Ron Buchanan with 

SC&A.

No, Kathy did a fine job, summarized it well and I 

didn't have any other additions unless there's any 

questions.

Mr. Katz: Super. Thanks, Ron. Any questions from 

Board Members in the room? How about from Board 

Members on the line? Any questions? This is a 

pretty straightforward one.

(No response.)

Mr. Katz: All right. Well, one-by-one we're going to 

take these. The Board has to put these to bed which 

means the Board has to vote on closing the reviews. 

So let's -- if you're ready we'll run down the list.

So the motion of the Board is to close the review. 

And I think at this point there's no need for 

discussion. There no questions, comments about the 

review so I will run the gamut alphabetically.

Anderson?

Member Anderson: Yes.

Mr. Katz: Beach?

Member Beach: Yes.

Mr. Katz: Clawson?

Member Clawson: Yes.

Mr. Katz: Field?

Member Field: Yes.

Mr. Katz: Kotelchuck?
34

Member Kotelchuck: Yes.

Mr. Katz: Lockey?

Member Lockey: Yes.

Mr. Katz: Richardson?

Member Richardson: Yes.

Mr. Katz: Roessler?

Member Roessler: Yes.

Mr. Katz: Schofield?

Member Schofield: Yes.

Mr. Katz: Valerio?

Member Valerio: Yes.

Mr. Katz: And Ziemer.

Member Ziemer: Yes.

Mr. Katz: And all are in favor, it's unanimous so we 

completed this review. And we're on to the next one 

which is external dose for K-25. Grady will be 

hunting to pull that up, Kathy, so just hang in there. 

Oh, it's up. Great.

So Kathy, it's ready for you.

Ms. Behling: Okay. Okay, I'm ready. Okay, this is 

ORAUT-OTIB-0026 and that's the external coworker 

dosimetry data.

Mr. Katz: Kathy, stop. Something is funny with your 

audio. I don't know if something changed, or maybe 

everyone else on the line mute your phones.

I don't know what's going on, but your voice is 

funny. Can you try it again?

Ms. Behling: Okay. Is that any better?

Mr. Katz: There's something odd about your mic. 
35

Has anything changed in your room?

Ms. Behling: No, it hasn't, but if you want I can 

switch phones. Is that better right now?

Mr. Katz: Yes, it is. Thanks.

Ms. Behling: Okay. If that changes let me know and 

I'll try to make an adjustment here.

Mr. Katz: That's good now, thanks.

External Coworker Dosimetry Data for the K-25 Site

Ms. Behling: Okay. Again we are discussing now the 

ORAUT-OTIB-0026 and that's the External Coworker 

Dosimetry Data for the K-25 site.

And slide 2 tells you that the OTIB-0026 is 

obviously an external coworker model for K-25.

And this OTIB provides the dose reconstructors with 

guidance to assign external dose to the K-25 

workers who have limited or no monitoring data. 

And this coworker model is based on data from the 

site and from other monitored workers.

The document was initially issued in May of 2005 

and a page change revision was incorporated to 

modify calculations and use of the coworker doses. 

And that was issued in July of 2005.

A second page change revision was issued in 

November of 2006. And this revision incorporated 

guidance from OTIB-0052 which is the OTIB for 

processing claims for construction trade workers.

SC&A was tasked with reviewing Rev 00 page 

change 2 and submitted its review in October of 

2007. And this review identified three findings. 

If we move onto slide 3, finding 1 has to do with 

professional judgment which comes up routinely.

This finding is concerned that the dose 

reconstructors were required to make too many 

judgments regarding whether a worker should be 
36

assigned doses based on onsite ambient dose, 50th 

percentile coworker dose, or 90th percentile 

coworker dose. SC&A was recommending that the 

OTIB provide more prescriptive approach that 

enables categorizing workers without the need for 

excessive professional judgment.

NIOSH's response was that professional judgment is 

part of the process to categorize a worker's 

potential for exposure and that it would be difficult 

to provide detailed prescriptive guidance due to a 

wide variety of data and information that is 

available to the dose reconstruction staff.

NIOSH also stated that there is another OTIB, a 

more general guidance, OTIB-0020 that provides 

guidance for the application of coworker doses.

And then finally NIOSH stated that any assumptions 

that are made with regard to professional judgment 

should be recorded and documented in the dose 

reconstruction report and they would be subjected 

to both an ORAU and DCAS peer review.

And so based on NIOSH's response SC&A agreed 

with that response and recommended to the 

Subcommittee that this finding be closed.

The Subcommittee also found NIOSH's response to 

be acceptable and they closed the finding at the 

December 9, 2008 teleconference.

If we move on to finding 2, this finding states that 

only a select number of dosimeters prior to 1980 

that were issued at the K-25 site were actually 

processed. And therefore the entire coworker 

database was based on doses from an unknown 

group of presumably higher exposure workers 

coupled with a large component of missed doses.

So NIOSH has responded by stating that they did a 

comparison of the OTIB-0026 data with K-25 data 

and analyzed these data sets using a maximum 

likelihood method that's described in section 7 of 

OTIB-0020. And this comparison shows that OTIB-
37

0026 data was very claimant-favorable. That was 

presented to the Procedures Subcommittee and 

they asked SC&A to look into this comparison a little 

bit further.

And so SC&A analyzed the coworker data in OTIB0026 to evaluate whether the doses reported in the 

1975 through 1980 time frame -- this is the time 

frame when most of the employee records were 

recorded, to determine if there were significant 

differences in the data reported in the earlier 

periods, 1945 through 1975 when only selected 

monitoring results were recorded.

SC&A conducted that analysis and concluded that 

the coworker data recommended in Table 2 of 

OTIB-0026 would provide for reasonable and likely 

claimant-favorable external doses for the K-25 

unmonitored workers. And based on that 

recommendation the Procedures Subcommittee 

closed the finding at the May 16, 2016 

teleconference.

And lastly, finding 3. Finding 3, it identifies that the 

derivation of shallow dose as reported in Table 2 of 

the OTIB resulted in zero values for 19 of the 24 

years that are addressed in that table.

This was considered unimportant because IREP --

by this OTIB because IREP automatically assigns a 

penetrating dose to the non-penetrating input. And 

SC&A questioned if this assumption would change if 

NIOSH modifies IREP in the future.

NIOSH's response to this finding was that -- OTIB0026 states that the approach is technically 

appropriate at this time. And they also stated that 

any future change to the IREP data input method 

would result in a wide-ranging revision to many 

OTIBs and Technical Basis Documents.

Based on that response SC&A agreed and 

recommended closing the finding. And the 

Procedures Subcommittee agreed with SC&A and 

NIOSH's response and closed the finding at the 
38

December 9, 2008 teleconference.

And that's the final finding for OTIB-0026. Any 

questions?

Mr. Katz: Thank you, Kathy. Okay, then. Board 

Members in the room, do we have questions for 

Kathy? Paul?

Member Ziemer: Just to clarify. So there were just 

three findings on this document then.

Ms. Behling: Correct.

Member Ziemer: The three that you covered, that's 

everything that would be open otherwise.

Ms. Behling: Correct.

Member Ziemer: Or that are now recommended for 

closure. Thank you.

Mr. Katz: Bill? Okay. Kathy, we're going back to 

finding 2.

Ms. Behling: If someone's asking a question I don't 

hear it.

Mr. Katz: It's not -- we haven't asked the question 

yet. We're going back to the slide first.

Ms. Behling: Okay.

Mr. Calhoun: Which finding?

Mr. Katz: Finding 2.

Mr. Calhoun: There we go. Finding 2.

Mr. Katz: Bill, bring the mic to your --

Member Field: How's that?

Mr. Katz: I think that's better.

Member Field: Okay. I just had a question about the 

second to last bullet where it says they concluded 

the data -- recommend Table 2 but provide a 
39

reasonable, and likely claimant-favorable.

I'm not sure what reasonable means, but is there 

reason to think it would not be claimant-favorable?

Ms. Behling: No, I don't believe so. Those were the 

words that were put into the report that was done 

or the analysis that was done that it was likely 

claimant-favorable.

NIOSH concluded that it was very claimantfavorable, but based on our analysis we feel it was 

reasonable and likely claimant-favorable. I'm sorry I 

can't answer it better than that.

Mr. Buchanan: This is Ron Buchanan. I think I 

worked on that some. I didn't do the whole --

Mr. Katz: Ron, we can't hear you. Sorry.

Mr. Buchanan: Okay. Can you hear me now?

Mr. Katz: Yes, that's better. Thanks.

Mr. Buchanan: Okay. I worked on that some. I 

didn't work on the whole report. I worked on some 

of the analysis. And what we wanted to distinguish 

there. We did some charting of that information and 

it looked like that the claimant for the previous data 

was covered and we felt that it was claimantfavorable and in some cases more than claimantfavorable. However, we just were distinguishing 

between very claimant-favorable and likely 

claimant-favorable. We didn't feel that it overdid it, 

but it provided a reasonable margin of error.

Mr. Katz: David.

Member Richardson: I'd like to stick on finding 2 

because it seems like a largely conceptual problem. 

The statement is that -- when did K-25 operations 

start, like 1950? Well -- and ceased around 1985.

So and the statement is until approximately 1980. 

So essentially up until very late in the operations 

few dosimeters issued were processed, thus the 
40

entire database for coworkers was based to a great 

extent on an unknown group of presumably higher 

exposure individuals coupled with the large 

component attributable to LOD over 2. So the 

proposed coworker estimation model for the vast 

majority of the period of operations for external 

exposures is based on this sample of a small 

number that were processed.

And then I recognize that in the recent years, and 

there's some discussion about whether the 

dosimetry is essentially complete from perhaps the 

mid to late 1970s forward. And that's where this 

validation is going to happen.

So it's an imputation of the external exposures for 

the workers from the period of the fifties up to at 

least let's say the mid-seventies when it's largely 

incomplete or sporadic and clearly not a random 

sample. And the coworker model here is going to 

use information from the same site, but now 

extrapolating over decades of operation.

So the validation that was done, help me to 

understand. Was there information used on 

department and area or job, or is it just that you're 

looking at whether an imputed value for the 

average worker in the facility in an earlier historic 

period was estimated reliably by this coworker 

model which is derived on later periods? Is it facility 

averaged, or is there additional information on 

location or activity or task or whatever?

Ms. Behling: Ron, can you answer that question?

Mr. Buchanan: It's been awhile since I've looked at 

this. I did it partly. Harry did the original work on 

this and then he wasn't available so I worked on it 

some and we wrote this up. And so I cannot answer 

that question directly today. We would have to 

answer that question -- have to look at that to 

answer that question. However, we did not go back 

and -- I just pulled up some of the write-up. We did

not sort it out by department that I can see. That 

was the overall data. It wasn't sorted by any sort of 
41

department. I can answer that question. However, 

the particulars on it I could not present today.

Member Richardson: So the judgment that it's 

claimant-favorable here means for all workers at the 

facility, the imputed mean value for all average 

workers may be higher than average workers. But 

for an individual who was working in a department 

or task where they had higher probability of 

exposure, imputing the facility-specific mean is 

unlikely to be claimant-favorable would be my --

just the conclusion I might jump to.

If there's nothing else as a basis for imputation 

other than the mean from a future period projected 

back to a mean in an earlier period that seems 

difficult for me to believe that this statement is 

claimant-favorable. Unless we're speaking on 

average for the facility.

(Simultaneous speaking)

Mr. Buchanan: Yes, it's on average. It's not divided 

up by any department because there was not 

enough data. We were looking for data. According 

to what I'm looking at here we did not divide it up 

by department. 

Ms. Behling: And if you'd like we can go back and 

pull this information and pull this evaluation and 

present that, send that to the Board.

Mr. Katz: Well, hold on, Kathy. Let's hear from Tim, 

see if Tim can shed any more light on this. Thanks.

Dr. Taulbee: I can't shed a whole lot more light on 

that. I do agree with what Ron was saying, that we 

didn't -- they didn't go back to the area type of 

information. But I would like to point out that this is 

an SEC during this time period currently. So when 

we're making a coworker model we're trying to 

develop a model that we believe to be claimantfavorable to assign to the workers who are not 

covered under the current SEC. And we're kind of 

doing the best that we can with the data that we 
42

have.

Mr. Katz: That's an important note. Thanks, Tim.

David, do you have any other thoughts before we 

go to other questions?

Member Richardson: No.

Mr. Katz: Other Board Members have questions on 

this or other in the room? How about Board 

Members on the line?

Okay. So, this is a situation where the data is 

limited and it's an SEC. So the data are what they 

are. 

I'm just wondering how the Board Members want to 

handle this. I think that sort of explains why the

Subcommittee closed this finding. 

So I guess there could be discussion about whether 

there's a better way to go at this when you simply 

lack the data to do what Dr. Richardson is 

suggesting. 

Otherwise it seems like --

Member Richardson: I mean, I agree we could just 

go forward. I'm not comfortable with the language 

of saying that this imputation -- unless it's going to 

be clarified that this imputation is claimantfavorable on average or something like that. There's 

a lot of situations where one would impute a very 

low mean to a site and yet there could be areas 

where that's not at all representative.

I guess -- there seems like there is information 

later. There's no possibility of partitioning the K-25 

facility in any way based on a department or other 

administrative thing to have a lower and higher 

mean, for example? 

Dr. Taulbee: Remember that this would be applied 

then to an unmonitored worker. And you don't have 

information of where they would have worked. So 
43

they could have worked in a high area or a low 

area. And so by looking at it all together we can 

look at the 50th percentile and the 95th percentile, 

assign a full distribution to them so in IREP they 

would be given some credit there.

If there's information that perhaps they worked in 

one of these other areas of higher exposure we 

could assign the 95th percentile.

Member Richardson: So there's no employment 

information regarding department or job.

Dr. Taulbee: I don't believe it's generally available. 

Well, self-reported, sure. When the person files the 

claim. But department information if they weren't 

monitored then we don't always have that 

information. It might be in the medical file, but I'm 

not really sure there. Keep in mind we would be 

assigning the full distribution here to these people. 

Member Richardson: I guess it's fine. I'm trying to 

think back to what was done historically with the K25 workers. I feel like there's the health physics 

department, but there's the administrative 

department. It would be based on employment 

records I would think.

Mr. Katz: Paul.

Member Ziemer: Could you clarify, maybe Tim could 

or Ron Buchanan. My understanding is they were 

monitored, but the site elected not to process all the 

monitors. They selected what I understood to be 

representative monitoring devices or badges. I think 

they were using film badges in those days. To 

represent -- rather than read them all out. They 

were not unmonitored in the usual sense. Is that 

correct? Or am I misunderstanding? That we would 

take, or that they would take a certain number of 

the badges and read those out and attribute the 

others, or represent the others by that group.

Dr. Taulbee: Right. That's my understanding, but 

when I was referring to the unmonitored that would 
44

mean they were wearing a badge but it was never 

read so effectively it's unmonitored.

Member Ziemer: So we're calling them 

unmonitored.

Dr. Taulbee: Right. But I believe you're right with 

the representativeness and correct me if I'm wrong 

on that one.

Member Ziemer: There's a sense in which the ones 

they did read out are representative of the others 

more so than you might get from a truly 

unmonitored group that maybe had different jobs 

than the ones they read out.

Member Richardson: Yes. My sort of vague 

recollection of this is historically at that period the 

dosimeter was incorporated into the badge. So at 

Oak Ridge everybody had a dosimeter because it 

was incorporated into the badge that was required 

for entry.

I believe -- I was reading the question about the 

presumption of which dosimeters were read. It was 

that not it was representative, it was presumably 

they were oversampled on people with higher 

probability of exposure.

Member Ziemer: Which might be more bounding, 

but not necessarily --

Member Richardson: And so that's the question. But 

it's apparently not clear what this sub-sample of 

dosimeters that were monitored was because it's 

not documented. So we're using our recollection, 

our intuition to understand what these numerical 

values are for this period where most of the 

dosimeters were not evaluated. 

Mr. Katz: David.

Member Kotelchuck: Yes, Dave Kotelchuck. I do feel 

a little uncomfortable using the word "likely" when it 

is not likely. It is on average. And I would be 
45

comfortable if we were to change "likely" to "and on 

average claimant-favorable." That is a correct 

statement and one can disagree with it. Others 

might disagree with it, but at least we would be 

speaking what we understand to be the most factual 

thing. So I'd like to just suggest that.

Mr. Katz: Okay. And keep in mind that the 

methodology is what it is. So it will produce the 

results it does. What we're talking about here is 

simply really the Board's characterization of what 

we're delivering here. And maybe it also can be 

reflected in NIOSH documents too, which I think 

makes sense.

Member Kotelchuck: I just don't want to 

characterize it beyond what we really feel we can 

fairly characterize it to be. The process is the 

process.

Mr. Katz: Absolutely. Absolutely. Thank you. I think 

these have been excellent questions, discussion.

Are we ready to close on this? Just looking around 

the room I think we've sorted this out pretty nicely. 

All right, then.

So the motion again of course is to close the review. 

And Paul, do we want more discussion?

Member Ziemer: Just for clarity, is there any more 

that's going to -- any follow-up on Finding 2, or it is 

what it is?

Mr. Katz: Well, I think the one follow-up could be 

just reflecting in the NIOSH documentation that 

perspective on what claimant-favorability degree we 

have here. That on average, I think. That's what the 

public, if they do look at the documents, that's what 

they see in terms of the methods used for their 

dose reconstruction. But Tim?

Dr. Taulbee: And we can add that language, on 

average claimant-favorable to OTIB-0026.
46

Mr. Katz: Yes. I mean, I think that's nice and 

transparent.

Member Ziemer: But that doesn't really change 

anything.

Mr. Katz: It doesn't change the number that the 

person gets, no, it doesn't. But I think it was agreed 

that there's really not a better way to handle this 

limitation of data. 

All right. So, I'll run down the roll call. Again, the 

motion is to close the review for external for K-25. 

Anderson?

Member Anderson: Yes.

Mr. Katz: Beach?

Member Beach: Yes.

Mr. Katz: Clawson?

Member Clawson: Yes.

Mr. Katz: Field?

Member Field: Yes.

Mr. Katz: Kotelchuck?

Member Kotelchuck: Yes.

Mr. Katz: Dr. Lockey is recused from this one. Dr. 

Richardson?

Member Richardson: Yes.

Mr. Katz: Dr. Roessler?

Member Roessler: Yes.

Mr. Katz: Mr. Schofield?

Member Schofield: Yes.

Mr. Katz: Ms. Valerio?
47

Member Valerio: Yes.

Mr. Katz: And Dr. Ziemer.

Member Ziemer: Yes.

Mr. Katz: And all who could voted in favor. The 

motion passes and that review is closed. Thank you 

very much. That was excellent.

Onto the third presentation. Kathy, the presentation 

is up on the screen.

Dose Reconstruction Method for CLL

Ms. Behling: Okay. The next presentation is OTIB0082. Can you hear me?

Mr. Katz: Yes, thanks.

Ms. Behling: Okay. And this one is a little bit 

different. This is the Dose Reconstruction Method for 

Chronic Lymphocytic Leukemia, CLL.

On slide 2 we give a description of the CLL model. 

And the OTIB-0082 describes the CLL model and 

provides guidance on its application.

Now, this OTIB was initially published on December 

4, 2012. There was a page change revision a few 

days later and this page change was issued to 

clarify the use of OTIB-0017 which provides 

guidance on the assignment of shallow dose and to 

add a description of the blended electron DCF which 

I will be discussing in greater detail later in this 

presentation.

SC&A submitted its review of OTIB-0082 in October 

of 2014. The risk model which was developed by 

SENES Oak Ridge entitled Review, Synthesis and 

Application of Information on the Human 

Lymphocytic System to Radiation Dosimetry for CLL 

is the basis for OTIB-0082.

That review of that risk model was not included in 

this review since it had been extensively peer 
48

reviewed prior to its publication in 2012.

SC&A actually had no findings with our review. 

However, we're presenting this material in hopes of 

providing a better understanding of the complexity 

of the CLL model.

Okay, we can move onto slide 2. Estimating 

radiation dose to cells suspected of giving rise to 

CLL is very complex and challenging for the 

following reasons.

CLL originates in B lymphocytes which are 

distributed throughout the lymph system. And these 

B lymphocytes can travel through various 

compartments of the body. Therefore they affect 

numerous organs of interest.

In addition, their inventories can significantly differ 

based on factors such as age, gender, health status, 

et cetera.

So estimating dose to these cancer sites for CLL 

cases requires calculating dose to this population of 

CLL precursor cells and this becomes complex 

because as stated above CLL precursor cells can be 

present in different compartments of the lymph 

system. And since the B cell population in a given 

compartment is not constant the affected organs 

can receive substantially different doses. So to 

develop the CLL dosimetric model compartmentspecific weights were derived based on the relative 

size of B lymphocyte pools to estimate the weighted 

average radiation dose. Due to the variability and 

uncertainty in these distributions probability 

distribution functions were assigned to the number 

of lymphocytes and to the fraction that represent 

the B cells for each of the organs of interest.

Moving onto slide 4, in the final CLL model an 

average dose and associated uncertainty was 

derived for a total of 30 compartments.

For external dose B lymphocyte compartments 

correspond to 15 organs for which dose must be 
49

assessed.

For internal dose calculations there are a total of 28 

organs that are impacted by the B lymphocyte 

compartments.

And for medical X-ray dose calculations the B 

lymphocyte compartments correspond to 18 organs.

And the ICRP-modeled organs that correspond to 

each of these compartments of the CLL model are 

shown in Table 3-1 of OTIB-0082 and that has been 

reproduced in slide 5.

And I apologize because it's difficult to read, but I 

thought it was important to include this particular 

table.

So in order to calculate external dose as we see on 

slide 6 we -- to calculate the external dose using 

dosimeter measurements -- we can move on to 

slide 6 -- okay, thank you.

To calculate the internal dose using dosimeter 

measurements for the individual organs listed in 

Table 3-1 required the derivation of a special dose 

conversion factor which is used to estimate dose to 

the appropriate CLL compartments.

For external dose calculations this what we'll call 

blended CLL DCF is the sum of B cell fractions for 

each of the 15 organs of interest times the DCF for 

each organ.

And a complete description of this derivation of 

these blended CLL DCFs is provided in a separate 

report. It's the DCAS-RPT-004, Chronic Lymphocytic 

Leukemia Dose Conversion Factors is the name of 

that report.

It should also be noted that the blended DCFs are 

based on DCF values that are cited in the 

implementation guide, the External Dose 

Reconstruction Implementation Guide, IG-001 for 

selected radiation types, energies and exposure 
50

geometries.

And they were calculated using Monte Carlo 

methods.

And onto slide 7. For each CLL DCF NIOSH 

employed a total of 5,000 iterations which were 

fitted to 5 standard probability distributions.

And those distributions included normal, lognormal3, lognormal-2, Weibull-3, and Weibull-2. And a 

detailed description of the derivations of these 

distributions is provided in RPT-004.

A best fit of the data associated with these five 

distributions was determined using the Akaike 

information criterion, AIC, and selecting the fit with 

the lowest AIC score.

To ensure that the proper blended DCF values were 

applied in dose reconstruction NIOSH created a CLL 

tab which contains the CLL DCFs. And that was 

added to all of the site-specific external dose 

calculation workbooks.

SC&A's review of the external dose methodology for 

CLL cases included critically reviewing the statistical 

approach that was used in RPT-004 and also 

verifying that the site-specific external dose 

calculation workbook had been updated with the 

appropriate CLL DCFs as provided in RPT-004.

This resulted in SC&A concurring with the 

methodologies by NIOSH to derive these blended 

CLL DCFs.

Now, onto internal dose. Internal dose which 

requires a calculation of dose to 28 organs or 

tissues.

NIOSH needed to develop -- NIOSH developed a 

CLL Simulator Tool. And this tool allows files that 

are generated by the IMBA software program and 

the Chronic Annual Dose Workbook, CADW, to be 

imported and for internal doses to be calculated for 
51

all CLL organs simultaneously.

The CADW was also modified to create separate files 

for each of the 28 organs and tissues which can 

subsequently be used in the CLL Simulator Tool.

Onto slide 9. And that lists all of the other -- not all 

of the other, I'm sure there's more than this, other 

guidance documents at this point at least, and sitespecific tools that needed to be modified to address 

applicable aspects of the CLL risk model.

Things like OTIB-0054 which is the fission and 

activation product assignment, and the Super S 

OTIB-0049, site-specific radionuclide chooser tools 

and internal environmental tools that are sitespecific.

Continuing on with internal dose on slide 10, SC&A 

evaluated the accuracy of the internal dose 

methodology for CLL cases.

First, SC&A was given training on running the CLL 

Simulator Tool. We generated IMBA files and CADW 

files for a CLL case. We imported those files into the 

CLL Simulator Tool and we assessed the internal 

dose generated by the tool. SC&A also reviewed 

site-specific tools and the dose reconstruction 

guidance to perform -- for performing the internal 

dose estimates to ensure that the accuracy of the 

updates, to ensure the accuracy of the updates for 

the CLL cases.

SC&A determined that the appropriate changes 

were incorporated into the applicable tools and the 

tools generated internal doses that included 

weighted organs and tissues as specified in OTIB0082.

SC&A also verified that appropriate changes were 

made to the applicable technical guidance 

documents for performing best estimates for CLL 

cases.

Now, medical X-ray dose. To calculate medical X-
52

ray -- occupational medical X-ray dose from chest 

or lumbar spine exams, dose estimates to each CLL 

compartment were defined by the product of the 

incident air kerma and the compartment-specific 

DCF associated with each of the organs. That's 

shown in the second column of Table 3-1.

For the CLL compartments involving skin, the 

entrance and exit skin doses defined as well as the 

fraction of skin exposed with it varying from 0.19 

for a properly collimated beam to 0.38 for poorly 

collimated beam.

The effective dose to the CLL precursor cells from 

occupational medical exposure is the sum of the 

weighed organ doses with consideration of 

uncertainty associated with each organ-specific DCF 

value and the weighted fraction of the CLL cells.

Moving onto slide 12. To assist the dose 

reconstruction for CLL medical X-rays NIOSH, 

developed CLL X-ray doses that were facilityspecific, view-specific, PA or lateral, and facilityspecific to a given time period. Variables included 

assigned organ dose and whether the beams were 

properly or poorly collimated. And then NIOSH 

updated each of the site-specific external dose 

calculation workbooks to include a CLL X-ray data 

tab which contains a lookup table of occupational 

medical X-ray doses.

Slide 13. SC&A's review included NIOSH's 

methodology and guidance for assigning 

occupational medical X-ray dose to CLL 

compartments.

This review determined that NIOSH properly 

adjusted existing models to comply with the CLL 

risk model. And SC&A also reviewed each of the 

site-specific external dose calculation workbooks 

and was able to verify that the CLL X-ray data tab 

was included and that these values were consistent 

with the TBD guidance. 

Lastly, SC&A -- in order to validate the guidance 
53

provided in OTIB-0082, SC&A conducted a 

preliminary review of a CLL case that was assigned 

under our audit of the 19th set of dose 

reconstruction reviews. The case that was reviewed 

included photon and neutron doses, occupational 

medical exposures, bioassay data, IMBA inputs and 

results, and the CLL Simulator Tool.

And this evaluation and spot check of calculations 

and doses resulted in SC&A concluding that for this 

case the dose reconstructor followed appropriate 

procedures and assigned correct doses. And it 

appeared that the guidance in OTIB-0082 was 

appropriate for the dose reconstruction process. 

That sums up our review of OTIB-0082. And as I 

said there were no findings, but I just thought it 

might be beneficial for the Board to get a better 

understanding of the complexity of this model.

Mr. Katz: Thank you very much, Kathy.

Ms. Behling: Thank you. And if there are any 

questions I hope they're directed at NIOSH. 

Mr. Katz: I'm just giving them a chance to digest. 

David.

Member Richardson: Thank you. Could we go back 

to the medical doses because that seemed to me 

the one that I thought I understood the best.

So for the medical doses the body is viewed as 

partitioned into compartments. There's an estimate 

of the dose to each compartment and the estimate 

for the CLL overall, the CLL quote unquote "organ 

dose" is the sum of the weighted compartmental 

doses. Or the weighted doses to target organs 

where the weight is a weight which is derived based 

on an estimate of the fraction of all B cells which are 

within that compartment.

Am I saying that back to you correctly?

Mr. Katz: Tim.
54

Dr. Taulbee: Yes. Yes, you are. It is derived based 

upon the probability of where the B cells are in the 

various organs with the various views associated 

with the medical X-rays.

Member Richardson: So, I guess a first question is 

what's the basis for the weights? Is that something 

that NIOSH has derived? At least here I didn't see a 

documentation of that.

Dr. Taulbee: If you look in RPT-004 where we 

developed this for the external doses in there it 

gives that probability distribution of where those B 

cells are in the various organs over time, or actually 

at time. And so that same distribution was used for 

the medical X-rays. 

Member Richardson: But was that something that 

NIOSH derived, or is there a literature on the 

distribution of B cells in the body?

Dr. Taulbee: I believe it was a literature search is 

how we came up with that distribution. I'd have to 

go back and look closely at RPT-004 to verify that, 

but --

Member Richardson: Did SC&A review that, that 

component of this?

Dr. Taulbee: That I don't know. 

Member Richardson: Does SC&A know if they 

reviewed that?

Mr. Katz: Tim, was that part of the original peer 

review when developing the CLL model?

Dr. Taulbee: I don't remember what SC&A 

reviewed. 

Mr. Katz: No, I'm talking about the original peer 

review by external experts.

Dr. Taulbee: Yes.

Mr. Katz: Was it part of that?
55

Dr. Taulbee: Well, wait a minute. No, the external 

peer review was about whether CLL was radiogenic 

or not and whether we should be including it. That 

was the external peer review.

Mr. Katz: Okay, that was limited to that.

Dr. Taulbee: Yes.

Member Richardson: So I think I understand. So 

there's weights which were -- are based on a model 

for where B cells are distributed in the body and 

that's something which we could or could not 

consider. 

I was wondering about like the compartment of the 

skin, but I'm not a B cell expert.

And then there's an estimate of the dose to each of 

those organs. And the final dose which is going to 

be the quote unquote "organ dose" for the CLL is 

the sum of those weighted doses to those target 

organs. And again with the weights are the fraction 

of the B cells that are in that organ.

Dr. Taulbee: That is correct.

Member Richardson: So, now when we move to the 

external dose model which was the first one we 

went through maybe SC&A could talk me through 

because I didn't understand the rationale for the 

different approach. And this is the slide here. To 

account for the correlation of dose between 

dosimeter measurements and individual organs a 

special dose conversion factor was derived.

I was trying to understand why there was 

correlation between dosimeter measurements and 

organs. 

Dr. Taulbee: We treated the B cells as a distribution 

throughout the various components, various organs.

And so they're all correlated together because we're 

taking this population -- some of the B cells can't be 

greater than 1. So as we're varying that because 
56

there is some uncertainty which is why I'm thinking 

we didn't use a set number, we used a distribution 

for each of those organs. So as we're going through 

and doing the Monte Carlo simulation to come up 

with the dose conversion factor we're making sure 

the B cells are all coming up to 1. So there is a 

correlation with that as we're assigning that dose 

conversion factor from IG-001. And so as we're 

summing them up it all has to come up to 1. Are 

you following my discussion there?

Member Richardson: But I guess going back, there's 

no Monte Carlo calculation for the medical dose? 

There it's a single weight which is assigned to each. 

There's no draw from a distribution?

Dr. Taulbee: I believe there's a draw.

Dr. Lobaugh: So what I was going to say, the main 

difference -- sorry, this is Megan Lobaugh for people 

on the phone.

The main difference between medical dose and the 

external dose would be that medical dose we know 

the way of exposure based on the PA or LAT of the 

diagnostic that was actually done. So we know that 

the radiation was coming from the front, or the 

back, or the side.

When you have an external dose on a dosimeter we 

don't know which way they were irradiated. So we 

have DCFs for all different irradiation schemes, 

right. So, isotropic, from the front, from the back, 

from the side. So we have to look at all those DCFs 

when we do the external dose. If that makes sense.

Member Richardson: You have different geometries 

and energies of exposure that you want to calculate 

dose conversion factors for.

Dr. Lobaugh: So the reason we can use the single 

weight, the known weight, of where the B 

lymphocytes are distributed within the body for the 

medical dose is because we know the geometry of 

irradiation.
57

Member Richardson: It's not a single weight though 

I don't think. It's a probability distribution on there 

as well.

Dr. Lobaugh: Yes. Yes, but the reason why it 

doesn't need to be combined with the DCF there is 

because the DCF is based on that irradiation scheme 

as well. And it's just one number.

Dr. Taulbee: To answer your question earlier about 

those B cell probability distributions, those were 

developed by SENES. And so we do have them for 

each of the organs. So each of those organs have a 

B cell probability distribution associated with them.

Member Richardson: Okay. I need to think. But I'd 

like to at some point get to the internal doses as 

well.

Mr. Katz: Okay. Well, do we have other questions? 

Paul?

Member Ziemer: Just to follow up on the medical. 

So on the medical presumably -- typically it's a 

chest X-ray, but other organs, you'll have to remind 

me. Are we considering scatter into other organs? 

So you have some dose delivered to other organs 

combined with their B cell population to --

Dr. Taulbee: We do.

Member Ziemer: -- get probabilities for all different 

organs.

Dr. Taulbee: Yes, we do.

Member Ziemer: Yes, thanks.

Mr. Katz: Other questions from Board Members 

before we go back to David? David.

Member Richardson: So, for the internal doses it 

wasn't clear to me whether this -- the description 

here, you're running a calculation. You're deriving 

simultaneously estimates to 28 target organs, 

deriving a final value. Is that a weighted sum of the 
58

target organs specific estimates, or is there a 

selection of a maximal organ? I wasn't clear what 

was happening there.

Dr. Taulbee: And this is where I'm going to ask if 

Dave Allen is on the line? You haven't heard 

anything back? Okay.

I really don't know the answer to that. I believe 

they're doing the same thing that external did from 

the probability distributions, but I can't -- I don't 

know that off the top of my head.

Member Richardson: Yes, the algorithm didn't seem 

to suggest that. It seemed like you're running the 

whole simulator, its outputting 28 target organspecific values after which there would have to be 

another MCNP layered on top of that which -- I 

appreciate that's like a nightmare. But I wasn't clear 

what the decision is at the end once you've got 

these 28 values.

Dr. Taulbee: And I'm sorry, I don't know that for 

sure. But we can get back to you on that.

Mr. Katz: Do I have any questions from Board 

Members on the line?

Member Anderson: That was a question I had. 

Thank you.

Mr. Katz: Okay. That was Andy, by the way. Henry 

Anderson.

Member Anderson: It seems like a full scale 

operation.

Mr. Katz: I'm sorry, Andy can you just speak up a 

little bit? It's a little hard to hear you.

Member Anderson: Okay. My question was I think 

was previously answered so I'm good.

Mr. Katz: Okay, thank you. Other Members on the 

phone? Questions? 
59

Member Clawson: I'm good with it, Ted. I will let 

you know though, you guys are getting more 

garbled as we go on during the day. It's a little bit 

harder to hear you. It's kind of garbled up.

Mr. Katz: And you're a little bit garbled too, Brad.

Member Clawson: I see. No, I just watched it 

progressively get worse.

Mr. Katz: You always see right through me. Am I 

clear even speaking to you, Brad?

Member Clawson: Yes. It's --

Mr. Katz: Okay. So just endeavor, everybody, to 

speak close to your mics. But thank you. Thanks for 

that. We need to know that as that happens. We 

tend to drift as a Board, as times goes on, from the 

mics.

So I guess my question, David, is: is this an issue? 

Do you want to know more before you sort of 

adjudicate on closing this review? Because it sounds 

like we're not ready to completely answer your 

questions.

Member Richardson: It would be great if those few 

questions could be answered. How are internal 

doses being -- how is the final decision being made 

on that. I think that's a big one.

I think I'm understanding about what was called a 

blended DCF. I appreciate more what that's about.

Mr. Katz: Okay. So, that's fine, that's fine. My 

suggestion then to the Board is that we not act on 

this at this meeting, but just keep it on the agenda. 

We can have it on the next Board meeting for 

follow-up. 

Member Ziemer: I have a question though.

Mr. Katz: Sure. Paul, go ahead.

Member Ziemer: I want to clarify, I think this 
60

question is probably for Kathy.

My understanding of what SC&A actually reviewed 

was whether or not the methodology worked in the 

way that NIOSH said it would work as opposed to 

the underlying assumptions, the correctness of the 

distribution of B cells, for example.

Kathy, could you clarify what exactly SC&A did? I 

think you were just saying that the workbooks and 

the model worked the way NIOSH said it would 

work. Am I not understanding that correctly?

Ms. Behling: Yes, you are correct in that. And I 

think up front I indicated that we were -- when we 

were tasked with looking at OTIB-0082 we were 

specifically told that we were not supposed to look 

at the underlying model, that that was something 

that was extensively peer reviewed.

It was used to generate the OTIB-0082. So we 

looked at the RPT-004 which was how the DCFs, the 

blended DCFs were calculated.

We also looked at the new tools that were 

generated such as the CLL Simulator Tool.

And we went into the site-specific external dose 

calculation workbooks and made sure that when 

they indicated that there was a new tab that was 

incorporated to assist in the dose reconstruction 

process that that had been done for all of the sites 

and that all the information in there was correct.

Member Ziemer: Thank you, Kathy. So my thought 

on this was that perhaps we could approve that 

action.

I think the underlying issues, clarity on those would 

still be helpful, but it may not affect what SC&A did 

here. If I understand it correctly.

Mr. Katz: Right. I mean, I guess just my one 

thought about this is. So, to the extent that we're 

talking about diving into what was peer reviewed, I 
61

mean the original models were put up at the same 

time we did the rulemaking. We had to have the 

models before we could do the rulemaking. And the 

rulemaking and the models came before the Board 

at that point and the Board approved the rule and in 

effect approved the models with them. But, 

nevertheless. 

And so yes, so SC&A's review is a review on the 

mechanical level, absolutely. And where these 

questions of David's fall is not totally clear to me at 

least whether they go beyond how things were put 

into effect, or whether they back up to the model 

that was approved at the time the rulemaking was 

done.

But what I was going to say before -- and you can 

respond, is I do think it's important that the Board 

is settled and has its opinion on the work anyway, 

however, wherever that falls, because again, this is 

the DR process for a whole lot of claimants and it's 

important that the Board be supportive of the final 

product.

So then it works either way for me, Paul. We can 

hold it open, or we can close SC&A's review, but 

keep this as an item to get follow-up on at the next 

Board meeting. Whatever the sentiments of the 

Board are, that's fine.

Member Ziemer: I would certainly yield to David's 

desire on this. I think either way, whether we act on 

this now or later we still need some clarity on the 

underlying assumptions if that is needed.

Member Richardson: Could I ask just for a 

clarification? Who tasked SC&A with this review?

Mr. Katz: The Board. 

Member Richardson: When?

Mr. Katz: This would be the Procedures 

Subcommittee, but approved by the Board quite a 

long time ago. I don't know, Kathy, what the date, 
62

original date for the tasking was. I don't know. 

Ms. Behling: Somewhere around 2014.

Mr. Katz: Okay.

Member Richardson: So five years ago the Board 

asked you to evaluate whether you could go 

through implementation of the written procedure 

and see whether it worked with clarity and you 

could come up with the numbers that NIOSH had 

said.

Ms. Behling: Correct.

Member Richardson: Okay. Thank you. In terms of 

whether the Board approved all of this before, 

again, your recollection is probably better than mine 

because I feel like I must be forgetful of a lot of 

things.

I don't believe I ever saw this detail of discussion or 

presentation about what was happening with this 

dose reconstruction.

I believe even as reflected by the answers to the 

questions where it's uncertain how it's being 

implemented, even the people who have been 

involved in it are not quite clear about what was 

going on. So I don't think that we sort of at this 

level of detail discussed this.

Mr. Katz: I can be clear about that. We didn't 

because SC&A didn't do this mechanical review at 

that point. I'm talking about at the point where the 

Board cleared the model and the rulemaking which 

would have preceded that. So of course it wasn't 

done. There wasn't an SC&A review as part of that. 

It was not a component of that.

Member Richardson: But the model must have been 

expressed in some higher level of abstraction than 

this.

Mr. Katz: I don't recall how the release exactly 

worked.
63

Dr. Taulbee: I don't recall all of it from that. I was 

involved in the external part of that and we did 

release Report 4 which does do the details for how 

the external DCFs were developed.

It's 300 pages long, that particular report is. 

So in the rollout of that I'd have to go back to the 

transcripts and look and see were there separate 

presentations on each of those.

Mr. Katz: I mean, I'm sure there wasn't -- I recall 

the presentations on the model were more abstract 

than this discussion. So, yes. There were 

presentations to the Board on the model, how this 

was going to be handled. That's for certain and the 

Board gave a thumbs up on that. And that's what 

I'm saying. But I have no problem whatsoever with 

digging into details at this point. That's fine.

Member Richardson: Thank you. And thank you for 

reassuring me that my memory is not horrible. I 

know it's not good.

Mr. Katz: I have the worst memory of everyone. So 

no, I would never.

Okay. So then let's -- so David, are you fine with 

putting this SC&A review to bed and keeping this on 

the agenda for the Board to address your questions? 

It sounds like yes. Okay. All right.

So then, again. So the motion is to close this SC&A 

review and Subcommittee Procedures review. And 

I'll run down the list. Anderson?

Member Anderson: Yes.

Mr. Katz: Beach?

Member Beach: Yes.

Mr. Katz: Clawson?

Member Clawson: Yes.
64

Mr. Katz: Field?

Member Field: Yes.

Mr. Katz: Kotelchuck?

Member Kotelchuck: Yes.

Mr. Katz: Lockey?

Member Lockey: Yes.

Mr. Katz: Richardson?

Member Richardson: Yes.

Mr. Katz: Roessler?

Member Roessler: Yes.

Mr. Katz: Schofield?

Member Schofield: Yes.

Mr. Katz: Valerio?

Member Valerio: Yes.

Mr. Katz: And Ziemer?

Member Ziemer: Yes.

Board Work Session

Mr. Katz: And all in favor. It's done, it's closed. 

Thank you very much. And thanks for this 

discussion as well.

Okay. We are at -- subtract three hours. 10:25. 

Let's see where we're supposed to be. We have a 

break at 10:45. We do have 20 minutes. 

If you want to get some Board work session out of 

the way, we could talk about a few things before we 

break. If that's okay? Are you good with hanging in 

a little bit more?

Okay. So, for now we are -- Board work session. We 
65

usually try to knock out the scheduling. Let's get 

that at least out of the way. 

So, the next meetings to schedule, we have a 

location issue for April and then we have the year 

out scheduling for Board meetings for both the 

teleconference and the face to face.

And for locations, so here is what I would suggest 

as possibilities we have here coming up. And of 

course I'm open to all of your input, other ideas.

But Hanford we have several documents that will be 

out in this time frame before that Board meeting, 

which is mid-April. I don't have the date right at 

hand but I could tell you in a second.

We have several that are related to the SEC that are 

coming out. So that would be an opportunity to get 

input from Hanford community on those sort of 

newly released documents related to the SEC. And 

Hanford is a pretty manageable location. I think for 

late April it should be okay.

And the other location that I think might make 

sense for either April or summer which is August is 

INL. We have a burial grounds paper that should be 

released fairly soon, the burial grounds follow-up 

which is relevant. And I believe there will be work 

done related to the INL reactors also, right? Is that 

correct, Tim? Yes. So there's a reactors-related 

report. You all recall that's a complicated business. 

But that should be coming out before then too. So 

INL again, we'd have fresh documents that are 

relevant to the community there. Tim?

Dr. Taulbee: That reactor report is probably more 

into late spring. So that would be like coming out 

just before that Board meeting. So it might make 

more sense to push Idaho.

Mr. Katz: Oh, right. I'm sorry. So I meant to clarify 

that. Yes, so that's really -- exactly. I was thinking -

- I was thinking exactly along those lines, that 

Hanford might make sense for April and INL for the 
66

summer. It's been our tradition to go visit Brad in 

the summer. But let's hear from other Board 

Members about this or other thoughts.

Member Beach: So Ted, we also have Metals and 

Controls Work Group scheduled for January that 

might be ready at that time also. Unless you think 

that's going to happen ahead of that.

Mr. Katz: We do. That what would happen?

Member Beach: At like a Board call.

Mr. Katz: Oh no, we're not going to do an SEC at a 

Board call.

Member Beach: Okay. So that might be --

Mr. Katz: So we do have that, but then that would 

be an action and then it doesn't make as much 

sense to go to Massachusetts for the Board to make 

its decision as it does to when we're rolling out new 

documents and want input on those, I think.

Member Beach: Okay.

Mr. Katz: Massachusetts. Very iffy weather in April. 

No, that's -- anyway, but that's one suggestion. 

Others? Board Members? On the line? What would 

you like? Does that make sense, Hanford?

Member Anderson: How long of a meeting are you 

expecting?

Mr. Katz: Andy? Sorry?

Member Anderson: How many days?

Mr. Katz: Well, this one might be pretty busy 

because we have a number of sites with petitions 

that could be ready.

We have SRS which we are working towards that. 

That's our hope. And that's a lot of material too. So 

that's a busy session.

We potentially have the Santa Susana sites. There 
67

are two of those. And those might be ready.

And we also have Metals and Controls, as Josie just 

said. There's a chance that could be ready also for 

April.

So that's three SECs that I can think of off the top 

of the head.

Member Anderson: I'm just --

Mr. Katz: Sorry?

Member Anderson: My only point -- we can get to 

Hanford. And it is a little longer trip back and forth 

for those in the Midwest and East. So if it's a 

multiple day meeting it makes it more practical to 

do two days of travel for --

Mr. Katz: For two days of meeting.

Member Anderson: Two days of meetings would be 

good.

Mr. Katz: Right, right. So anyway, I mean it's 

always hard for us to -- fortune-telling about the 

next Board meeting in terms of the agenda. But it 

looks like it could be a busy one, in which case --

Member Anderson: Then are we going to have a 

party for you?

Mr. Katz: Sorry?

Member Anderson: Are we going to have a day of 

party for you in April? 

Mr. Katz: No, no parties.

Member Anderson: That will be the last face to face. 

Is that going to be it for you?

Mr. Katz: Oh, sorry. So, yes. April will be it for me,

so to speak. Yes. That sounds a little bit fatal.

Member Richardson: I was thinking Santa Fe.
68

Mr. Katz: Oh, so I mean that's another suggestion. 

We do have -- Tim, I guess, or Bomber? Let's just 

talk about the New Mexico situation since that's 

another possibility, absolutely.

Mr. Rutherford: Are you talking about Los Alamos or 

Sandia?

Mr. Katz: We are. We're just talking about April, in 

the twenties I think, is the meeting.

Mr. Rutherford: April, we're definitely not going to 

be ready with Los Alamos. We've got a lot of 

documents to be released and we haven't got our 

sampling plan together yet.

Sandia, we have a tour scheduled in early part. 

SC&A's reviewing Sandia so I really don't think that 

we'll be ready in April for that unless SC&A gets 

their report out early and then -- and there's not 

much to that report that we have to respond to.

Mr. Katz: Joe, it's all on you. Concise. Okay. So that 

sounds iffy. That sounds like it's more likely, then, a 

prospect for the summer when it's nice and warm in 

Santa Fe.

Other thoughts? Okay. I think that's probably all the 

prospects there could be.

So, some -- are we going to Hanford?

Member Beach: We can go to Hanford. That's 

perfect, I don't have to travel.

Mr. Katz: Are we all right with that? 

Member Beach: It's April 22 right now.

Mr. Katz: Sorry, Brad, I can't hear you. Go ahead.

Member Clawson: Do we have anything from NIOSH 

yet on Hanford?

Mr. Katz: No, but they're rolling out fairly soon. 

That's what's happening.
69

Member Clawson: I've been waiting for a while for 

that opening. Thank you.

Mr. Katz: I know you have. Ultimate patience, Brad, 

I know, you do. Let me find the dates. Twentysecond and twenty-third. Okay, that sounds right.

I mean, everyone else has these dates. If someone 

else has it on their calendar.

Member Clawson: I blocked a whole week.

Mr. Katz: Sorry? That's right. That's fine.

Member Anderson: We need a travel day which 

would either be Monday or Tuesday.

Mr. Katz: Yes. So it's the 22nd and 23rd, Andy. 

Okay. All right. Well, I'm not hearing a great 

movement anywhere else other than Hanford so 

let's say that's where we'll go.

All right. And it's -- we can just take our break now 

I think and rejoin at 11 o'clock. And we'll be dealing 

with the Secretary's report on dose reconstruction 

case reviews. Thanks, everyone.

(Whereupon, the above-entitled matter went off the 

record at 10:35 a.m. and resumed at 11:04 a.m.)

Draft Report to Secretary, HHS on Dose 

Reconstruction Reviews

Mr. Katz: All right, so I think we can get started. 

I'm sure Andy will join us shortly. And we have a 

session on dose reconstruction case reviews report 

for the Secretary which has been long in the 

making, but I think it's gone along well. David.

Member Kotelchuck: Thank you. This as you see, 

this report as you remember is dedicated to the 

memory of Jim Melius who was a Member of this 

Board from 2001 to 2018, was Chair from 2009 to 

2018.

And I'm going to take a moment to just read the 
70

dedication.

For us on the Advisory Board on Radiation and 

Worker Health, Jim Melius was a consummate 

bridge-builder between all three perspectives 

represented on this Board: scientific, medical and 

worker. In this pursuit he was patient, humorous, 

attentive, and insightful in doing his part to bring us 

as closely into consensus as possible for a given 

decision. Throughout our activities he was caring of 

his fellow Board Members, of the program and the 

Board staff, as well as the claimants, their families 

and advocates. 

Dr. Ziemer said that on behalf of the Advisory Board 

and I'm just repeating it now.

The report that we are submitting has been -- this is 

the third report to the Secretary. We the DRRSC has 

reviewed this and is submitting it to you.

Since our 2016 report -- I'm going to go over some 

of the conclusions. Since our 2016 report we have 

examined 166 more cases for a total of 498 cases 

reviewed since the inception of this program.

During this period up through the Sets 21 which 

were completed for this report there were 48,089 

cases which had dose reconstruction. Therefore we 

have kept up with our goal of reviewing 1 percent of 

all cases as you see: 498 over 48,089. It is a 1.04 

percent rate of dose reconstruction cases reviewed.

In addition, in this report, we have 18 more blinds 

for a total of 32 blinds again since the program was 

developed. In 31 of the 32 cases, 97 percent, both 

the NIOSH and OSHA conclusions with respect to 

compensation were the same.

This is particularly notable since 87 percent of the 

cases selected for the blinds were best estimate 

cases with a Probability of Causation between 45 

and 52 percent, a range of PoCs whose 

compensation decisions are especially sensitive to 

any difference in this complex process.
71

So, and these results give us confidence in the 

instruction and the procedures given to the dose 

reconstructors and their results are therefore -- we 

have confidence that the results are reliable and 

consistent among the dose reconstructors who have 

evaluated them.

By the way, for the single case of the difference in 

compensation, case number 3 in the table, there 

had been no working group that looked over it. So 

the case was referred to the Surrogate Data 

Working Group for consideration. The Working 

Group concluded that the NIOSH approach in which 

the claimant's compensation decision was made was 

an appropriate one and they, if you will, passed that 

that was an appropriate procedure.

In format as you will note this report is quite similar 

to that of the 2016, the last report to the Secretary, 

the 2016 report. But let me mention that there are 

a number of changes in the text seeking greater 

precision in discussing and describing the dose 

reconstruction process and results.

For example, in the 2016 report we describe three 

basic types of dose reconstructions. In this text, the 

one that we're submitting, and I should add with 

the help and suggestions from Ted Katz and the 

OGC, Jenny Lin Naylor, the text describes correctly 

one single process, the so-called best estimate 

process for getting the -- for determining the dose 

reconstruction. And the other two processes, the 

overestimates and underestimates, are in fact 

efficiency measures and they're called that here 

because -- to help -- they are there to assist the 

dose reconstructors in completing their tasks to deal 

with so many claims through this process.

Before closing my remarks I do want to note that 

reviewing this there was a typo that I found in the 

data on page 16, Figure 3, page 16. And maybe I'll 

go there for you to look at.

Figure 3, page 16. And I made a comment in the 

text that for the cases above 45 percent, that is the 
72

best estimate cases on this graph are between 45 

and 50 percent, and between 50 and 52 percent. 

That's how we've been selecting best estimate cases 

for our review recently.

So, that's the error is 25 percent and the PoC 

greater than 50 is 14. That sums to 39 percent. And 

I apparently, it escaped -- I noticed that we said on 

page 17 line 1 both PoC segments at or above 45 

percent have declined since last report from 51 to 

39 percent, not 49 percent. And we'll make that 

correction.

Everything else that I said here is correct. That was 

just a typographical error, and I went back and 

checked the earlier report and confirmed that 

everything that was said about the report was 

correct except for that number which should be 39 

percent. 

With that I'd just like to open it up for comments, 

suggestions, questions.

Mr. Katz: So, about half the Board, a little more 

than half the Board is actually on the Dose 

Reconstruction Reviews Subcommittee. 

So those members, if you want to add anything.

Member Kotelchuck: Yes, and I thank you very 

much for reminding me to mention the folks who 

are on the Board. And I'm the Chair. Josie is on it, 

Josie Beach, Loretta Valerio, Dave Richardson and 

Jim Lockey. Have I left someone out? I didn't do my 

counting, but I think --

(Simultaneous speaking.)

Member Kotelchuck: Okay. That was -- that's not 

Henry.

Mr. Katz: That's Brad Clawson.

Member Kotelchuck: Brad. Excuse me, Brad. Oh, 

yes, sir. Brad, you're -- I went around and looked in 

the group here. Of course, Brad. So all of you. And 
73

this has been a very active group. And you know, 

we had a large backlog to deal with in the past for 

the previous report. And I think we're moving along, 

we're moving along at a reasonable pace keeping up 

with -- having our reviews keep up with the pace of 

claims, at least 1 percent of the pace of claims that 

are coming in to the program. Thanks, Ted.

Comments and suggestions? Are there any?

Mr. Katz: None in the room. How about on the 

phone? 

Member Ziemer: If you're asking for comments I'd 

just like to say that I think the report -- thanks for 

the report. I appreciate the work the Subcommittee 

did.

In particular, we're charged with a couple of things 

for the Secretary. One is to confirm that we believe 

the process is scientifically sound and you've done 

that in the cover letter.

And also I think the recommendations are 

important, particularly the third one that you've

developed here. I appreciate the work you did on 

that.

Member Kotelchuck: Very good. Thank you and 

thank all on behalf of the Subcommittee.

Mr. Katz: Okay. So I don't hear any suggestions, 

comments, concerns, questions from the Board 

Members on the phone.

Member Ziemer: Do you need a motion to approve?

Mr. Katz: We do.

Member Ziemer: I'd like to move that we approve 

the report to the Secretary with the change noted 

on the number.

Member Kotelchuck: Yes, yes.

Mr. Katz: Second?
74

Member Beach: I'll second it.

Member Valerio: I'll second.

Mr. Katz: Okay. No more discussion. Let's run the 

vote and then we'll get to cover letter and so on 

issues. Anderson?

Member Anderson: Yes.

Mr. Katz: Beach?

Member Beach: Yes.

Mr. Katz: Clawson?

Member Clawson: Yes.

Mr. Katz: Field?

Member Field: Yes.

Mr. Katz: Kotelchuck?

Member Kotelchuck: Yes.

Mr. Katz: Lockey?

Member Lockey: Yes.

Mr. Katz: Richardson?

Member Richardson: Yes.

Mr. Katz: Roessler?

Member Roessler: Yes.

Mr. Katz: Schofield?

(No response.)

Mr. Katz: Phil?

(No response.)

Mr. Katz: Okay, Phil's playing hooky. Loretta 

Valerio?
75

Member Valerio: Yes.

Mr. Katz: And Ziemer.

Member Ziemer: Yes.

Mr. Katz: Okay. Phil, do you need to mash your 

mute button maybe? Okay, well I can catch -- I 

think I can catch his vote during a work session or 

whenever he pops back up. 

It's in any event unanimous with all the Members 

who could vote. There's one outstanding vote. The 

measure passes. So the report is approved.

I drafted a cover letter to accompany and transmit 

the report to the Secretary. And I'll wait till Dave 

gets back to the phone. I think I should read it into 

the record. The cover letter includes a very brief 

summary that reflects the report summary. And 

then I think Dave has some edits, suggestions to 

edit that, which we can capture too. And anyone 

else. And you should all have copies of this with 

your materials.

So...

Dear Mr. Secretary. Enclosed for your information is 

a report prepared for you by the Advisory Board on 

Radiation Worker Health. 

The Board conducts independent reviews of selected 

radiation dose reconstructions completed by the 

National Institute for Occupational Safety and 

Health in accordance with the requirements of the 

EEOICPA.

The purpose of the Board's review process as 

mandated by EEOICPA is to advise you on the 

scientific validity and quality of radiation dose 

estimation and reconstruction efforts being 

performed for the purposes of the compensation 

program.

This report was prepared by the Board's 

Subcommittee for Dose Reconstruction Reviews with 
76

input from the full Board. It was approved by the 

full Board on December 11, 2019.

The report covers the Board's review of 166 

individual dose reconstructions conducted since the 

Board's last report to the Secretary in 2016. The 

three reviews represent over 1 percent of the total 

number of radiation dose reconstructions performed 

by NIOSH since the start of the program in 

2002.These reviews are generally representative of 

the overall worker population and work locations 

covered by the EEOICPA program.

The reviews were prioritized to focus on radiation 

dose reconstructions that involve more 

comprehensive dose reconstruction procedures, and 

on those dose reconstructions for which errors in 

the dose reconstruction could have a greater impact 

on claimant compensation decisions.

The Board's review of the 166 dose reconstructions 

identified 243 findings, approximately half the rate 

of findings since the 2016 report representing a 

marked improvement which has now been a 

continuing trend over these three reviews.

The current report also summarizes 32 blind case 

reviews in which the Board oversaw independently 

conducted dose reconstructions which it compared 

to the final dose reconstructions conducted by 

NIOSH.

The comparison allows the Board to ascertain 

whether independently performed dose 

reconstructions would produce similar results for 

claimants and to further examine the scientific 

quality and validity of the methods being applied.

The findings from these comparisons further 

validate that NIOSH dose reconstructions are being 

performed consistently and with appropriate quality 

and validity.

Our review of these 166 dose reconstructions as 

well as the 32 blind case reviews and our ongoing 

review of the NIOSH procedures used for dose 
77

reconstruction provide the Board with a high level of 

confidence that the radiation dose reconstruction 

process is scientifically sound.

Finally, the Board has made several 

recommendations to modify and improve its review 

process.

We hope that you will find this information useful 

and informative. And Dr. Kotelchuck would sign for 

the Board.

Member Kotelchuck: If I may just first in the 

attribution just to get the Subcommittee's name it's 

the Subcommittee on Dose Reconstruction Reviews, 

of course. 

And also in the second paragraph, the Board's 

review of 166, I would like to just cite the -- since 

the Board's previous reports to the Secretary in 

2009 and 2016.

These combined cases reviewed in all three reports 

consist of over 1 percent of the total number of -- in 

other words just cite the two reports. And I have it 

written up rather than just citing the previous 

report.

If I may read again since I was having -- the 

combined cases reviewed in all three reports 

constitute over 1 percent of the total number of 

radiation. I might suggest that. I will of course -- if 

others think.

Mr. Katz: So are you elaborating on what I just 

said, the three reviews represent?

Member Kotelchuck: Yes. Citing the 2009 and '16 in 

the previous sentence and then say the three 

reviews. You know what? You do -- why don't we 

just drop that because you do mention three 

reviews. And the previous reports to the Secretary 

in 2009 and 2016 establishes the first two. This is 

the second. So let's -- you're right. What the 

sentence, the three reviews represent are perfectly 
78

-- it's perfectly adequate as it is.

Mr. Katz: Okay.

Member Kotelchuck: So I would just say in the 

previous sentence let's just add reports to the 

Secretary in 2009 and '16.

Mr. Katz: Okay. If you just send me an email with 

that, that would be great. Yes. It's good to try to 

keep things as simple as possible for these kind of 

letters to the Secretary because they're read by 

very high-level people.

Member Kotelchuck: All right.

Mr. Katz: But thank you for that. Any other 

comments about the cover letter? Okay. So thanks, 

everybody, and thanks to SC&A for a really terrific 

effort they put into this, Rose Gogliotti in particular, 

but others with her into getting this report in shape 

with the Subcommittee. We really appreciate that.

Member Kotelchuck: Thank you.

Board Work Session

Mr. Katz: We have time. It's -- we didn't use up 

much of our time here. So why don't we do a little 

bit more Board work session before we break for 

lunch?

So we had gotten through scheduling a place and 

we acquitted that which is good. So let's just sort 

out dates for the next teleconference that hasn't 

been scheduled as well as the next face-to-face 

meeting.

So I have as approximately the right timing an 

October 26 of next year teleconference date. That 

week. And that week means, so it's probably -- the 

28th is probably the Wednesday if we stick to 

tradition when we can. But of October of next year.

Member Richardson: You said the 28th of October?
79

Mr. Katz: So that would be I think a Wednesday, 

right? Anyone have any problems with that date? 

Same on the phone, no problems?

Member Anderson: No.

Mr. Katz: Okay, that was easy. October 28 it is. 

Teleconference. It will be 11 a.m. as usual. 

Okay, then a meeting. Grady suggested -- I had on 

here in my notes the week of December 14, but 

there's a longer -- Thanksgiving isn't jammed up 

against December as it is this year so we could back 

up a week, the week of December 7 if you want to 

look at that week and see how that would be for 

your schedules.

So again, Tuesday and Wednesday, or Wednesday 

and Thursday. Tuesday and Wednesday in this case 

would be a little better for staff if we can 

accommodate that.

Member Lockey: The eighth and ninth?

Mr. Katz: That sounds right. How is that for 

everyone's schedules? Eighth and ninth of 

December. How about on the phone? I'm sorry, I 

can't hear you. Say it again?

Member Anderson: Eight and nine of December, 

you're saying?

Mr. Katz: Correct. Correct. 

Member Anderson: Okay.

Member Roessler: Okay.

Mr. Katz: Okay, sounds like it's good with Gen. Phil, 

that's okay with you? Brad?

Member Clawson: I'll -- that one's good with me.

Mr. Katz: Brad, I couldn't understand you.

Member Clawson: I'm having trouble with you guys 

on there, too. I said it was good for me.
80

Mr. Katz: Great, okay. Yeah, you still sound like 

you're in a fish tank. Phil, are you there?

Member Schofield: I have no conflict there either.

Mr. Katz: Okay, great. Okay, so then there it is. 

December 8 through 9. That's Tuesday, Wednesday. 

Well, that was too easy too.

Member Anderson: Do we have a location?

Mr. Katz: We're good to get a location for the next 

meeting. I could suggest any number of locations. I 

won't be here.

Member Anderson: The reason is my birthday is on 

the 10th.

Mr. Katz: Oh, right, of course, of course. It should 

be near your house.

Member Anderson: That's why I had travel trouble 

this time. So if I can get home on the night of the 

ninth I will have a home, and if I don't I'm in 

trouble.

Mr. Katz: Right, right. It's a day meeting. It will be 

easy because your travel day would be the eighth or 

the ninth.

Member Anderson: Right.

Mr. Katz: Okay. All right. So, what we have left for 

the Board work session -- if you'd like to get started 

we could get started on some of those; why don't 

we at least run for 15 minutes, say, with those and 

then we can pick up the rest of them after lunch --

is the Work Group reports. We do also have public 

comments. Why don't I do that after lunch. The font 

is very small. It will be a struggle for me.

So let's do Work Groups. And I will just skip Work 

Groups, where I'm quite sure there is nothing to 

say. But you do have the Board coordination report 

which gives you updates on when you're being 

delivered reports either from SC&A or the DCAS 
81

group, NIOSH. So you may have -- want to address 

any of that as well as we go through.

Brad, do you have anything on Argonne East?

Member Clawson: No, it's just -- the report it is just 

shortly -- and I believe that we're reviewing that as 

we speak so that's about all I have.

Mr. Katz: Okay. I knew there was a report out. 

Thanks, Brad. So, it looks like then a little ways 

down the road we might even have an Argonne East 

Work Group meeting.

Blockson Chemical, there's nothing there. 

Brookhaven, there's nothing there. Carborundum, 

there's nothing there. The Carborundum Work 

Group is essentially finished.

Dose Reconstruction Review Methods. There's 

nothing there. 

Then we get to Hanford. Hanford. And I mentioned 

already that there will be some reports coming out 

from NIOSH relevant to the SEC in the next few 

months. But Brad, do you have any -- Brad's the 

chair for Hanford. Any other comments about 

Hanford?

Member Clawson: No, not at this time. But I have 

not heard an official date. Does NIOSH have 

anything?

Mr. Rutherford: Actually our report, it's a White 

Paper. It addresses the remaining issues.

It is in final review now. It should be out sometime 

this month, within the next week or two.

Member Clawson: Okay. Thank you, Grady.

Mr. Katz: Yes, thanks. No, that was Bomber.

Member Clawson: You know, you need to forgive 

me.
82

Mr. Katz: I know. You're paying the price, Brad, for 

not being here with us. Okay. 

INL. Phil. We may still have lost Phil, but I did note 

for you all we do have some work coming out on the 

burial grounds and some work related to the 

reactors. So there will be some action on INL over 

these months ahead.

Lawrence Berkeley. We're going to have an update 

from Paul later today about the work and also about 

their tour which I hear was great. 

And much thanks to the site for that, for hosting 

them so well. It's really appreciated.

LANL, Josie.

Member Beach: So, we did hear a little bit from 

Greg. We are waiting on documents from LANL to 

complete the exotics report and the sampling plan.

I know it was due in I believe September. It was 

pushed off till now just about, February or 

December. So I guess LaVon's kind of got the ball 

on that one.

Mr. Rutherford: Yes, we actually identified -- we 

ended up doing an additional data capture and we 

identified roughly 70,000 pages of RWPs, associated 

with RWPs for LANL.

And the site's reviewing those now. And as Greg 

had mentioned we have prioritized those over the 

exotics because the way it works out we can 

complete the exotics report up to the point of 

analyzing some of that data. But we need that RWP 

data first. And so that's pretty much the status on 

that.

Mr. Katz: Great. Thanks. Metals and Controls, Josie.

Member Beach: I can report the next meeting is 

scheduled for January 9. We're going to go over a 

White Paper, the thorium and welding exposure 

models as well as petitioner's concerns.
83

I think SC&A is working on that paper now. But 

anyway, our meeting will be January 9.

Mr. Katz: Right. That paper should be out quite 

soon, within weeks I think, a week or two.

Member Anderson: That's going to be a phone call, 

right?

Mr. Katz: I'm sorry, Andy?

Member Beach: Yes, phone call.

Mr. Katz: Yes, it's a teleconference.

Member Anderson: Okay.

Mr. Katz: Yes. Okay. Mound. Mound.

Member Beach: We're just still waiting on that 

external TBD report. And I didn't see when the date 

was scheduled for now. It's been pushed back a 

couple of -- oh wait, no, it's in review I believe. Isn't 

it? It is. So we should see that shortly. I forgot that 

part.

Mr. Katz: That's great. Nevada Test Site is Brad. 

Brad, I didn't look at the coordination report on that 

one. Do we have something coming from 

somewhere?

Member Clawson: I'm sorry, I couldn't hear what 

you were saying, Ted.

Mr. Katz: Nevada Test Site.

Member Clawson: No --

(Simultaneous speaking.)

Member Clawson: You're not coming through. Hello?

Mr. Katz: Brad?

Member Clawson: Not at this time.

Mr. Katz: Do you have something?
84

Mr. Rutherford: Yes, I was going to mention that we 

are working on a response to SC&A for health 

physics review actually and it's due in January.

Mr. Katz: Okay. So I thought there was something 

that should be coming. Right, great. And it's been a 

while so it will be great to be able to put Nevada 

Test Site to bed.

ORNL. That's Gen.

Member Roessler: I have heard nothing. Maybe 

somebody there can bring us up to date.

Mr. Rutherford: Sure, yes. We've done a number of 

actually captures and stuff. We do anticipate that 

we will complete this effort in May of next year.

Mr. Katz: Okay. May of next year, Gen. Okay. 

Next we have -- I'm not sure if Phil has rejoined us. 

Phil, are you on the line? Okay.

Member Schofield: I'm sorry, I had it on mute.

Mr. Katz: Okay, Phil. Well, the first thing I'm going 

to do is get your vote for the dose reconstruction 

report. Everyone voted in favor, it passed. Are you 

in support or opposed? Phil, could you understand 

me?

Member Schofield: You're --

Mr. Katz: The dose reconstruction report. The 

Secretary's report. You missed the vote on that. 

From the Dose Reconstruction Review 

Subcommittee. 

Member Schofield: Yes.

Member Clawson: Phil, we voted on it.

Mr. Katz: So Phil, do you have a vote?

Member Schofield: Yes. Voting for it.

Mr. Katz: Okay, thank you. Thank you. That takes 
85

care of that. All right.

So then we're on Portsmouth, Paducah, K-25 Work 

Group. Do you have any update?

Member Schofield: I don't think we have. We just 

had all that information from K-25. That was in --

we were just looking at this last week and there was 

a paper presented this morning on it. I don't think 

we're ready for a vote on that yet.

Mr. Rutherford: Actually, we are providing 

responses to the Work Group sometime this month.

Mr. Katz: This month.

Mr. Rutherford: Yes.

Mr. Katz: So, do you hear that, Phil? So we'll get 

the DCAS responses this month. Thank you. Thank 

you, LaVon. Okay, Rocky Flats. Dr. Kotelchuck.

Member Kotelchuck: Nothing new.

Mr. Katz: Right.

Mr. Rutherford: I will provide a little update. We 

actually had completed -- we had identified four 

interviews of individuals that may have information 

on neptunium work post 1983.

We have completed those -- we completed three out 

of the four interviews. The fourth one we could not 

come up with a place where the individual, where 

we could do it in a setting, a classified setting.

But we have three individuals that have completed 

the interview. We will provide those interviews once 

they have been reviewed by the interviewees. We 

will provide that to the Work Group for their review.

Mr. Katz: And cleared by DOE, right?

Mr. Rutherford: Yes.

Mr. Katz: Yes. So just roughly what time frame is 

that?
86

Mr. Rutherford: You know, we should have our part 

done and back to the interviewees within the next 

few weeks. It's just how quickly they get them back 

to us.

Mr. Katz: Sure. Okay. And then DOE.

Mr. Rutherford: Yes.

Mr. Katz: Okay. All right. So maybe, yes, within the 

next month or two we might have that. That's 

great.

Sandia. Andy.

Member Anderson: I don't think we have anything. 

We have a site visit.

Mr. Katz: Andy, we can't really make you out.

Member Anderson: I can't hear you. It's garbled.

Mr. Katz: Seems like we're having audio problems 

both ways. So again, where are you with this?

Member Anderson: I can't -- you probably know 

better. Why don't you say this? You aren't going to 

be able to understand me here. I can't understand 

you.

Mr. Katz: Okay. Well, we'll work on this because you 

need to be able to hear us. Improve the audio 

quality on their end. Before it was easy for them to 

hear.

But Bomber, do you want to just give an update for 

Andy for this?

Mr. Rutherford: Yes. Right now the addendum that 

we completed is in review with SC&A.

However, there is a tour scheduled in January that 

will be a tour set up with the security guards and 

forces there. That is I think January 15, if I 

remember correctly.

Mr. Katz: Yes. Early January. Right.
87

Member Anderson: That's right.

Mr. Katz: Right. And several Board Members will be 

there. I'll be there, SC&A and NIOSH. Okay. Santa 

Susana. Phil. Phil, you've heard.

Member Schofield: Yes. NIOSH is working on the 

information that has been submitted. I haven't seen 

anything from them yet.

I don't know if they have a date for when that's 

going to be ready. It's supposed to be before the 

April Board meeting, but I'd like to have a Work 

Group meeting before that.

Mr. Rutherford: We're scheduled -- we're going to 

try to push to have it done in time before the Board 

meeting and to allow for a Work Group meeting.

However, it's -- right now it's scheduled the first of 

April. First of April.

Mr. Katz: Well, this is actually just to sort this out. 

This is not for a Work Group meeting, this is on the 

Board's plate still. So it would be for the Board 

meeting that it has to be done.

And we also have an SC&A report that's just 

recently completed that's available that addresses 

the documents that were submitted. 

But they'll be addressing -- yes, the documents that 

were submitted at the August Board meeting by the 

petitioner. And immediately following that.

And I will note that the petitioner also has a FOIA in 

to DOE still that hasn't been fulfilled. And she's 

awaiting those documents.

Okay, that's fine. So we'll hear more about those 

then from the petitioner. 

Okay. Savannah River Site, Brad. All right. We don't 

need to go into it now. We have two hours of this 

this afternoon.
88

Member Clawson: We're going to have a lightning 

session on that so I figured I'll just pass it off to 

NIOSH and Joe in a little while.

Mr. Katz: Yes, unless you want to summarize it all 

right now. Okay.

Member Clawson: I can do it.

Mr. Katz: Science issues, David.

Member Richardson: I have an outstanding action 

item for myself which was to move forward with a 

list of things to do. And I humbly apologize for not 

having made action on my action item.

Mr. Katz: Okay. Thanks. SEC issues. They are 

entangled with the SRS Work Group on this same 

work. So they're in effect covered this afternoon.

And then we have Subcommittee on Dose 

Reconstruction. Is there anything more you want to 

talk about there?

Member Kotelchuck: Well, we still, we don't have --

this is one of those rare times that we don't have a 

meeting set up right now.

I think we're awaiting some determination maybe 

from you.

Mr. Katz: We're waiting for work to get done.

Member Kotelchuck: Pardon?

Mr. Katz: Yes. We're waiting for work to get done. 

Some work to get done. So we're sort of between 

horses right now. We do have a full new set of dose 

reconstruction case reviews that were completed by 

SC&A in draft and are -- all of you know better than 

I, the two-member Board teams are working 

through those so we can get those finalized.

We also have an assignment of a new set of blinds 

which is in the works at NIOSH. I think it's on 

NIOSH's plate to come up with the cases. And they 
89

haven't come in yet.

They should be coming in any day because it's been 

a little while for that. Josie?

Member Beach: Yes, I just had a question and 

perhaps a comment on the way the blind reviews 

are being set up.

Typically in the past, two of us have reviewed a 

series of five or six. This time around we are split up 

into different pairs and it seems the scheduling is a 

lot more difficult. 

I was curious as to why that changed.

Mr. Katz: Yes, I did that. So I take credit for that.

It's not the blinds you're reviewing though, it's the 

full set actually. It's the full set. And I did that 

because I wanted Board Members to have the 

experience of working with different team members 

on some of these different cases. We always have 

this issue anyway in part because of conflicts. The 

same team can't work on them all because one or 

the other might be conflicted with one site or 

another. So that's always been a piece of the issue.

I just made it a more difficult scheduling process, 

but I did think at this point given what's going on 

with me leaving soon and so on, I did want to get 

Board Members on different teams for different --

and the other issue that had gone on previously is 

that you would have these tremendously long 

sessions to get through all your cases together as a 

team. And Board Members were sorry for the 

experience and this is breaking it up so that you can 

take it in small bites instead of --

Member Beach: It might be nice to have a review of 

how it went and what people's thoughts are, only 

because on the scheduling end of it I know, I think 

Rose and Kathy are doing a lot of that. Just to 

determine if we should move forward in that 

direction.
90

Mr. Katz: Yes. I'm really interested in the Board 

Members. I mean, SC&A, all due respect is paid to 

do whatever, go through whatever misery we put 

them through. No offense intended, but it's just, it's 

more important to me that the Board Members have 

a good -- the kind of experience that's valuable to 

them. So yes, absolutely, I think it's a good idea to 

review and see whether you liked or disliked having 

different dance partners for the reviews.

Member Beach: One more thing. It just ties up 

several days instead of one day. So for me it would 

be nice to review it. Thanks.

Mr. Katz: Okay. I know where Josie comes out on 

this.

Member Beach: I'm done.

Mr. Katz: Okay. So then moving on to Procedure 

Reviews. Josie.

Member Beach: I don't have anything in addition. 

There is not a date scheduled for Procedures 

Review. If there's anything from NIOSH on what 

work is coming out maybe. Other than to thank 

Kathy for the review on the last three reports this 

morning.

Mr. Katz: Right. We don't have much of a plate of 

work is the reality.

Member Beach: Okay. Maybe just keep working on 

getting some of these reviews caught up before the 

Board potentially.

Mr. Katz: TBD-6000. Paul.

Member Ziemer: Currently we have Superior Steel. 

We reviewed this I think in June of this past year. 

Are we scheduled now, Ted?

Mr. Katz: We're in the middle of it. We're almost 

scheduled.

Member Ziemer: Yes. We've solicited the dates. Ted 
91

determined when the Chair was available and 

determining when we can meet. I believe it's going 

to be in January.

Mr. Katz: January or early February.

Member Ziemer: End of January, early February. So 

we have that to do.

And while we're talking about TBD-6000, we 

actually have a little carryover. We have Joslyn still 

to close on and that will have to be done later. It's 

been sitting for a while. 

But the next thing on the docket will be Superior 

Steel and hopefully be ready to clear that out in 

about a month.

Mr. Katz: Right. And that's a priority because that's 

an SEC.

Member Ziemer: Yes.

Mr. Katz: Thank you. Okay, Andy, the Uranium 

Refining AWEs Work Group. 

Member Anderson: Yes. We have a meeting coming 

up January 30 to go over NIOSH's response to 

SC&A's review on a Site Profile review.

Mr. Katz: And that's the Site Profile for?

Member Anderson: WR Grace.

Mr. Katz: WR Grace. Thanks.

Member Anderson: And while I've got you, if you 

can understand me, what was the teleconference 

date in October?

Mr. Katz: The October teleconference date was the 

28th. That's a Wednesday.

Member Anderson: Yes.

Mr. Katz: Okay. Okay, thank you, Andy.
92

Member Anderson: Well, I don't know. I think that's 

when I -- meeting. So earlier in the week or 

Tuesday would have been better.

Mr. Katz: That doesn't work for you. Is that what 

you're saying?

Member Anderson: Well, it might. It's usually the 

day I travel. I can see it being travel.

Mr. Katz: Why don't we just push it up till -- if we 

can shift that back to Tuesday.

Member Anderson: Tuesday, Wednesday is ideal.

Mr. Katz: This is October. So instead of the 28th it 

would be the 27th.

Member Anderson: Right.

Mr. Katz: Is that good? I don't hear any complaints 

yet. Let's give people a second. October 27.

Member Anderson: Thank you very much.

Member Clawson: It's all about Andy.

Mr. Katz: It is. It is, Brad. Just reconcile yourself 

with that. 

Member Clawson: At least it's not because --

Mr. Katz: Okay. I haven't heard any complaints. The 

27th is okay, 11 a.m. still. Thanks, Andy, for 

catching that.

All right. And I think the last but not least is the Use 

of Surrogate Data. And there is no report there. No 

action there.

So we just got through all of the work session 

business and we're close enough to a lunch break. 

So we can be adjourned. But please be back. So, at 

1:30 we'll be back for the SEC petitions update from 

LaVon. Lunchtime. Take care.

(Whereupon, the above-entitled matter went off the 
93

record at 11:50 a.m. and resumed at 1:32 p.m.)

Mr. Katz: Okay, so welcome back. We just finished 

our lunch break and this is the Advisory Board on 

Radiation and Worker Health and we're on to 

afternoon sessions.

Before we get going with that let me check on the 

line for my Board Members. So, let's run down the 

list. 

Brad, are you there?

Member Clawson: Yes, I am.

Mr. Katz: Oh, you sound much better in terms of 

clarity, audio clarity. That's great.

Member Clawson: You don't sound any better.

Mr. Katz: I don't sound any -- you know, you'd 

probably say that no matter what. But, okay.

Let's go on, someone else on the Board. Gen, are 

you there?

Member Roessler: I'm here. You sound a little 

better, but you were starting to get a little fuzzy.

Mr. Katz: Fuzzy, okay.

Member Anderson: Hi, it's Andy. I'm here too.

Mr. Katz: Andy.

Member Anderson: Yes.

Mr. Katz: Okay.

Member Schofield: I'm here, Ted.

Mr. Katz: And there's you, Phil. Okay, that's all four 

of them. And we have everyone back at the table as 

well.

So, keep giving us feedback as you have issues with 

understanding what we're saying here. 
94

But we have now a session on the SEC petition 

update from LaVon Rutherford.

Mr. Rutherford: As soon as we can figure out how to 

advance the slides.

Mr. Katz: Larry, Joe, Louis or whoever, figure out 

the slides.

Oh, and also I guess let me just give you all a 

heads-up. This is going to be a little bit odd because 

we got through a lot of our work session before the 

lunch break.

So we have -- we had 45 minutes set aside for 

Board work session following LaVon's presentation. 

We are surely not going to need that because we 

only have one item left, the public comments to 

address from the last meeting and that's it.

Unfortunately the next session after that is 

coworker modeling guidelines review and then the 

SRS update. And that really needs to be time 

certain at 2:30. We can't -- so what we're going to 

end up with is another break after I do the public 

comments. And I don't know, that's not terrible but 

that's what we're with. And then we'll come back at 

2:30. Anyway, so LaVon.

SEC Petitions Status Update

Mr. Rutherford: All right. I'm going to give the SEC 

update. We give this update at every Advisory 

Board meeting. This allows the Advisory Board 

Members, Work Groups and such to prepare and 

schedule for future meetings, whether those be 

Work Group meetings or Advisory Board meetings.

Also I'm going to talk about petitions that are in 

qualification, under evaluation, currently under 

Board review, and potential 83.14s.

Okay. This is a summary slide. To date we've had 

255 petitions. We have three petitions that are in 

the qualification phase.
95

One petition evaluation that's currently in progress -

- actually there's two, that is wrong, I apologize --

and I'll get to that in a second.

And we have 10 reports with the Advisory Board. 

Petitions in qualification. Reduction Pilot Plant. 

Those who may remember at the last Board 

meeting we talked about this one. We had this 

petition. However, the period that the petitioner was 

looking at, 1976 to 1978, actually was not fully a 

covered period. We had identified information that 

we felt may support expanding that covered period. 

We provided that to Department of Labor. The 

Department of Labor returned in mid-November a 

letter back to us agreeing with us and they 

extended that covered period. So, I indicated that 

the qualification would be this month. We actually 

qualified that petition today. So that is an 

evaluation that will take place and a report will 

come to the Advisory Board.

ANL-East. This is another petition that is in the 

qualification phase, 1975 to 1981. It's for all 

employees. And we anticipate making that 

qualification determination sometime in January.

BWXT. This is a petition for the residual period, 

1973 to 1984. I think some Board Members will 

remember that we actually have added Classes for 

both ends of the operational period at this one. So 

this is the residual period again, 1973 to 1984. We 

expect to make a qualification determination in 

January.

Lawrence Livermore National Lab. This is a petition 

evaluation that's underway. This actually addresses 

the remaining years of an existing petition, the 

1990 to 2014. We've been working on this one for 

some time. We have got all the information in.

However, there are a couple of issues we are 

working on. We anticipate having this report out in 

April. I don't think it will be in time for the meeting 

though, in April.
96

Y-12 Plant. Again this addresses the remaining 

years of an existing petition. If you remember last 

Board meeting we actually recommended adding a 

Class at Y-12. And we indicated at that time we had 

a reserve period. We knew there was data at the 

site. We were waiting to get that data. We are still 

working on getting that data. However, we 

anticipate completing that report in June of next 

year.

Okay, these are petition evaluations that are with 

the Advisory Board and have some period that 

needs to be addressed. I'm not going to get into too 

much detail since we've already talked about the 

Work Groups associated with these just earlier this 

morning.

Hanford. Again, we've got a White Paper coming out 

this month to the Work Group. Savannah River Site, 

an update this afternoon.

Los Alamos National Lab. We're waiting on a 

number of documents and we're working to get our 

sampling plan together for that one.

Sandia National Lab. Again, there's a tour in 

January and an SC&A report due to us, so that one's 

moving along.

INL we discussed earlier, working -- some issues 

there. ANL-West as well. 

Santa Susana, we expect to have a presentation at 

the April Board meeting, our review of the additional 

documents provided by the petitioner as well as a 

chronology of the things that we've addressed to 

date.

Metals and Controls Work Group meeting in 

January. 

De Soto Avenue goes along with Santa Susana. 

And Superior Steel, I think Dr. Ziemer mentioned a 

Work Group meeting I think in February for that 
97

one. So we have actions there, we have a path 

forward for everything to move forward.

Again, these are the time periods that are 

remaining. All these are petitions that had a broader 

time period. However, these are years that are 

remaining that are left to be addressed. And all 

those I've spoke to already.

Potential 83.14s. Everyone will remember we added 

a Class at West Valley Demonstration Project. It was 

the 1969 through a period. However, we held off on 

the '66 through '68 period because we had 

identified a significant amount of data that we 

wasn't sure it was warranted. We're continuing that 

evaluation and I don't have a good date for that. 

However, we will report back to the Board once we 

have that.

And that's all I've got. Questions?

Mr. Katz: So then it seems De Soto will be ready for 

April.

Mr. Rutherford: Well I think that, you know, 

depending how the back and forth goes. But I think 

yes.

Board Work Session

Mr. Katz: Okay. So, Board Members, questions for 

LaVon? I don't see any in the room. Any Board 

Members on the phone have questions for LaVon? 

Okay, thanks. That's helpful.

You didn't have anyone make fun of you this time. 

You miss it, I'm sure. I'm just not as mean as Jim 

Melius.

All right then. So, we have Board work session. All I 

have left for the Board work session though is to 

run through the public comments, responses to the 

August public comments. So I'll do that.

And you have to bear with me. The material I have 

is in a font 4 or something my children can read, 
98

but I have a hard time with.

And so we had a set of comments from -- on West 

Valley from one of the petitioners, the petitioner 

representative, petitioner/petitioner. And these 

were all sort of process questions in a sense, or let's 

see. I'll be careful about this. But, they're about 

understanding why was a particular claimant 

selected for the 83.14 to sign the petition in effect. 

Because 83.14s, as people know, are cases where 

NIOSH is deciding to add a Class and just needs to 

establish a dose reconstruction case that it cannot 

complete. So that's the origin, that's how that 

comes about. It's when we hit a dose reconstruction 

we can't complete, that -- so that is how someone 

gets selected to be the petitioner in those cases.

And then there were questions about the process, 

like changing the time frame. These are questions 

that come up frequently about the time frame in 

any given site, why it's been changed by NIOSH. 

And NIOSH has responded on the matter to --

explaining what the variables are that were relevant 

there.

And then the petitioner also had procedural 

concerns about communications with the 

petitioners, whether the petitioners are being kept 

abreast appropriately, or with this 83.14 case 

whether the authorized representative was 

informed. Again, this is just -- these are process 

questions. I think they're all responded to 

appropriately. I don't think there's anything to 

address here. And that's it for West Valley.

The next -- okay. So, and then the next site for 

which we had comments was Santa Susana.

Well, I think the simplest way to deal with these -- I 

mean, a lot of this is commentary and related to, as 

we've discussed already today, submitting new 

documents that were submitted for the petition for 

Santa Susana. This is Area IV we're talking about 

here, not De Soto. And those are being addressed in 

reports. So there is an SC&A report and there will 
99

be a NIOSH report which will cover the documents 

submitted, what they are, what they aren't, and 

how they're relevant or not relevant for the petition.

And the report will also address petitioner concerns 

that were raised, that was discussed by Dr. 

Richardson. He thought that would be good to have 

those addressed directly in a report. So that's all 

coming. I don't think I need to -- there's anything to 

cover here. It's a reiteration of all that.

Then we have Y-12. So, these were questions about 

-- there's some question about particulars covered 

in the statement, in the Evaluation Report by NIOSH 

and that's been responded to by the lead.

There's a comment about concerns about the extent 

of exposure monitoring of a certain sort, particularly 

related to fecal sampling, and explanation of why 

that is not of concern for the evaluation again by 

the lead, Lara Hughes.

There's a very general statement that the petitioner 

consulted the statistician who couldn't reproduce 

NIOSH calculations. And the NIOSH response there, 

as I think it can only be, is that it's really difficult for 

them to respond to that kind of general concern.

And then there was a concern about paying 

attention to the document from DOE that was 

submitted. And in response, that document was 

reviewed as part of the evaluation review.

Okay. Let's see. There's some comments that don't 

require a response, just comments. That covers Y12.

Okay, Rocky Flats. Okay, so these Rocky Flats 

comments are really comments, not questions, that 

don't really require a response.

Then we have the Oak Ridge sites. We have a 

comment in favor of expanding the SEC Class. That 

doesn't require a response.
100

Another comment on the Oak Ridge sites, again not 

requiring a response, about the difficulty of finding 

records for people who worked in a certain division 

there.

And there was -- okay. And then the rest also 

doesn't require responses. For example, we have a 

Rocky Flats comment, someone offering themselves 

up for expert information. I think their contact 

information was collected at that meeting for that 

purpose. Likewise for someone who was a radiation 

safety officer at Santa Susana, same situation.

And that's it, that gets through the comments. Any 

questions from Board Members about these 

responses? Yes, Paul. 

Member Ziemer: Just for clarity, do these 

comments, do these show up in the table? I didn't 

see them there.

Mr. Katz: No, because they have personal 

information.

Member Ziemer: Personal information.

Mr. Katz: Yes.

Member Ziemer: But all of these are from the 

transcript. The comments are in the transcript.

Mr. Katz: Yes. Just the same, yes.

Member Ziemer: Are the responses necessarily sent 

to the commenter, or only if --

Mr. Katz: There's a lot of different issues. So, the 

ones that don't require a response aren't responded 

to. Often staff get on the phone with the individual

and have a conversation about these and that's the 

way they respond. It's not that frequent that it's 

done in writing I don't think, but it could be back 

and forth in emails.

Member Ziemer: I was trying to get some clarity in 

my own mind as to sort of the affirmation that the 
101

loop is closed, not just with the Board but with the 

commenter. Thank you.

Mr. Katz: Sure. Okay, then. Then we are on break 

until we have our coworker modeling Santa Susana 

discussion which begins at 2:30 local time here.

(Whereupon, the above-entitled matter went off the 

record at 1:51 p.m. and resumed at 2:31 p.m.)

Mr. Katz: Okay, yes, we're here. We're live.

All right, before we get started let me just check on 

the line and make sure I have my Board Members. 

Gen, are you there?

Member Roessler: I'm here.

Mr. Katz: And Phil, are you there?

Member Schofield: Here.

Mr. Katz: And Brad?

Member Clawson: Yes, I'm here.

Mr. Katz: And Andy.

Member Anderson: I'm here.

Coworker Modeling Guidelines Review and Update 

on Savannah River Site SEC Petition #103

Mr. Katz: Super. Okay. Now we have a session, it's 

sort of a two-part session. It's doing two things.

The Board has draft guidelines on the use of 

coworker data, or co-exposure data is the 

terminology we're using now, which actually is a 

much better term.

And the Board has tentatively approved those 

guidelines and wanted to see how they would work 

in the real world, and the real world in this case is 

Savannah River Site co-exposure data.

So, the first part of this session is to address that 
102

question and we'll have presentations from Tim 

Taulbee and Bob Barton as well. And they have 

coordinated a bit last week, Thursday and Friday, as

this is very fresh. We had a day and a half meeting 

on this and on the second part of this, just mirroring 

the session today.

But where they were into a lot of details, you're 

going to get today a more summary version,

including an update because there were some 

things accomplished in that meeting, and you'll hear 

about those. And following then this part A which is 

again this coworker, co-exposure data guidelines, 

then we'll get into an update on the Savannah River 

Site petition.

And that is as we discussed last week, and the

petitioners were on the line and representatives of 

the folks there in Savannah were on the line, so I 

think they're well apprised. But it's just an update. 

We're not going to have action on that SEC petition 

today.

We are aiming working towards having action on 

that petition in April. So there will be Work Group 

meetings following this meeting, this winter, late 

winter, spring, to hopefully bring us to the point 

where in April we can take action and put to bed 

part or all, however it works out, of the remaining 

part of the petition that's still with us.

So I think that takes care of all I want to say.

So, following this piece on the coworker exposure 

we'll have the SRS update and I think Tim will have 

some words for that, but part of your presentation 

will address that too, right?

Dr. Taulbee: Yes.

Mr. Katz: And then I think Joe Fitzgerald from SC&A 

will follow with some comments too, is that correct? 

Oh, answer questions. I see, I get it. Okay. So Joe 

will be available for discussion on that.
103

And with no further ado then Tim, take it away. 

Thanks.

Dr. Taulbee: Okay. Thank you, Ted. Ted just gave a 

really good background so that's going to take care 

of a lot of my slides here at the beginning, but 

that's good.

One thing that I wanted to say before I got going 

here in talking about the Co-exposure Model 

Implementation Guide and using the SRS coexposure model as an example is I wanted to thank 

the ORAU team who developed this particular 

method for co-exposure modeling. 

And the team was led by Chris Tornes and Liz 

Brackett, and Matt Arno did the intake modeling, 

and Nancy Chalmers was statistical support. 

Mr. Katz: Tim, given the noise coming through the 

wall too just --

(Simultaneous speaking.)

Dr. Taulbee: Is that better?

Mr. Katz: For the folks on the phone. I don't know 

what they're hearing, but it couldn't be that great.

Dr. Taulbee: Can people on the phone hear me 

okay?

Member Schofield: Yes.

Member Roessler: Ted, you have an echo.

Member Anderson: It sounds like you're out on the 

street, but that's okay.

Mr. Katz: That's where I belong. Exactly. So I'll stop 

talking.

Member Anderson: It's not overwhelming.

Mr. Katz: That will take care of my echo. Go ahead, 

Tim.
104

Dr. Taulbee: Okay. All right, thank you. So a little 

bit of an overview of what we're going to go through 

here today.

And Ted hit on this at the beginning. We did a name 

change here. We've referred to coworker in the 

past. And really this is a co-exposure model instead 

of a coworker model. This was a discussion within 

the respective Work Groups, the SEC Issues Work 

Group as well as the SRS Work Group. And we 

decided on a name change to be more specific and 

improve the communication for clarity. So, I'll use 

these interchangeably kind of by accident because 

I'm used to saying coworker, but hopefully in the 

future we'll be referring more to co-exposure model 

instead of coworker model.

I'm going to go through a little bit of the 

background leading to the development of the coexposure model criteria and the draft criteria for the 

evaluation and use of coworker datasets. You see I 

switched back there, but that's because that's the 

title of the original draft document. And then go 

through the Savannah River co-exposure model 

example and wrap up here with a summary.

At that point I'm going to turn it over to Bob Barton 

who's going to go through SC&A's comments on this 

particular model, and then the Work Group 

deliberations that happened last Thursday and 

Friday.

So this is, as Ted indicated, fresh off the press.

So leading with a little bit of background. Back in 

2010 which is almost 10 years ago there was some 

concern that the co-exposure models using raw 

bioassay data could be dominated by a few 

individuals. And this would be a case where 

somebody was involved in an incident and left 50 to 

100 bioassay samples. And when you looked at that 

across the entire collection of bioassay sampling, 

that could really dominate the model. And so it's 

really not a co-exposure model, it would be a oneperson model. And so RPRT-53 was written back 
105

then and developed what we call one person, one 

statistic. 

Following that particular methodology there were 

multiple SEC Issues Work Group meetings 

discussing what we called OPOS at the time, 

stratification, statistical comparison methodologies.

And what ended up coming out of a lot of those 

discussions was a Time-Weighted One Person, One 

Statistic, what we call TWOPOS. But also coming out 

of those discussions were this is what promulgated 

the development of the draft criteria for the 

evaluation and use of coworker datasets. And this 

was drafted by Jim Neton, my predecessor who 

came up with this criteria of things that we needed 

to evaluate. And that's what Ted was talking about 

that the Board had previously looked at and had 

agreed with in principle but wanted to see an 

example.

So the general timeline of this implementation guide 

was starting in June of 2014. And you can see the 

dates there going through. And the final version was 

July 6, 2015. And you'll see the rev was 4.1.1 

because that last revision was really just some 

wording changes that took place. But at that time is 

when the SEC Issues Work Group requested a 

demonstration or a pilot example showing how we 

would actually implement this guide.

And so that's what I'm going to go through here. 

I'm going to start out with the draft criteria that was 

put out by Dr. Neton, and then at that point we'll go

into the SRS example.

So some of the things that we needed to evaluate 

the elements of the Co-exposure Model 

Implementation Guide are in evaluation 

stratification, data adequacy, data completeness 

and validation, the applicability of the model to 

unmonitored workers, and then the analysis and 

application which is kind of the -- similar to the step 

above, but slightly different to the unmonitored 

population.
106

So I'll start here with data adequacy first. And this 

was to be a review of the sampling methods, the 

laboratory analysis. And in doing so consideration 

should be given to the representativeness of the 

bioassay collection methods, the radiochemical 

recoveries, the counting efficiencies, the reliability 

of the measurement methods.

For data completeness we were to evaluate whether 

the data are either sufficiently representative or 

bounding of the exposure potential. And there was 

recommendations in there of using a minimum 30 

person-measurements per year and we are to 

assess temporal trends, gap analysis, assess the 

data quality, the accuracy of data transcription, and 

then the evaluation of potentially missing data such 

as comparing this to the claimant files.

In the applicability to unmonitored workers there 

was a hierarchy that Dr. Neton put into this criteria 

and that was threefold here.

The first was to use routine representative sampling 

for the co-exposure model.

The second was to use routine measurements of the 

highest exposure-potential workers. So these would 

be workers who are identified as having that 

greatest potential for exposure. And if you could 

develop the co-exposure model with them that 

would be a bounding scenario.

And finally from the hierarchy was the collection of 

samples after the identification of incidents. So this 

would be an incident-based model, a co-exposure 

model.

And the whole goal here was to either get a 

representative sample of the exposed population, or 

workers with the highest potential for exposure. So 

it was one or the other would be the criteria here.

The next step was the analysis and application to 

the unmonitored population. And this was, was 

there sufficient data to construct a representative 
107

co-exposure model or a bounding model. And again 

the recommendation was to use 30 workers per 

time interval. However, less data could be used if 

the data fit a distribution reasonably well. And this 

was left up to the judgment of the statistician. The 

statistician looks at each one of these fits. So this 

isn't being done by a health physicist. This is 

somebody who is professionally trained to really 

look at data intently and determine if the data can 

be reasonably represented by a statistical 

distribution. 

This is where the Time-Weighted One Person, One 

Statistic comes into play. And this is when multiple 

bioassay samples are present during a monitoring 

period for a given individual.

It's appropriate to average the values so that a 

single statistic can be computed for that individual. 

So one individual isn't dominating the whole model.

And then the next, the final stage which really 

becomes the first stage which I'll get into in a 

minute here is -- there should be an evaluation of 

stratification, or it should be evaluated when there's 

accurate job titles and descriptions can be obtained 

for all workers, there's a reason to believe that one 

job category is more highly exposed, and there is 

unmonitored workers in this job category.

And a couple of examples I would give you here is 

there are times when we look at a dataset, even 

I've seen this in external dose already, where we're 

looking for -- there's one population that has higher 

neutron exposures, let's say. And you go in and you 

look at everybody in that particular work group was 

monitored for the neutron exposures including the 

secretaries and the clerks that were in that work 

group. So from that standpoint that particular group 

doesn't really need to be stratified out. They can be 

stratified out, but they're not really part of -- there's 

no unmonitored workers that would be needing that 

particular exposure.

The stratification by individual job categories was 
108

never really our intention from the standpoint of coexposure models. It was more general groups of 

workers.

In the case of Savannah River that I'll give you here 

in a minute it comes down to construction trades 

versus non-construction trades. But it could be 

other strata that we would look at.

So, when talking about the Savannah River coexposure model and the pilot that we did we initially 

came out with a pilot example for what we call 

OTIB-81 Revision 3, and that was in November of 

2016. And it had three radionuclides in it. It was 

the trivalents which is americium, curium and 

californium. So that's three, but it's really one 

count. Tritium and thorium. And subsequent 

discussions on the stratification and applicability of 

subcontractor construction trades workers in this 

group led to a general Work Group consensus that 

they wanted to see the full models to evaluate all 

aspects.

So we had initially intended to provide these three 

that we could work out all of these details, but it 

turns out that folks wanted to see the whole thing 

which is perfectly reasonable, so no problems there.

The difficulty was is this took us another couple of 

years to develop, to go through. And I think at the 

end of this presentation or by the time we get 

through it you'll see why that occurred with all of 

the details that we had to go through with the 

datasets. So, the final one was OTIB-81 Rev 4. And 

this was released in March of this year. And this 

contained models for all radionuclides.

So the first thing within the co-exposure modeling 

was the stratification decision. And we went back 

and forth internally a lot on this and reviewing some 

of the transcripts and input from the discussions 

that the Work Groups had had.

And we decided a priori to stratify based on 

differences of exposure potential between routine 

and non-routine operations. Because we found it 
109

difficult to make the argument that the exposure 

potential was similar for these two types of workers.

For example, consider when a glovebox is purposely 

breached. You have the loss of engineering control 

that is used to protect the operations workers.

Whenever they're doing their work there's a 

glovebox face in front of them, they've got their 

hands in it, they're making their product. But then 

you take the face of the glovebox off for 

construction trades to come in and do their work. 

Now they're wearing respirators. That's the 

protection that they have. So we stratified based 

upon this routine and non-routine type of work 

scenario.

And in reality how it gets stratified is something that 

we will continue to work with the SRS and SEC 

Issues Work Groups to nail down. But for us the 

reality was in the initial construction trades versus 

non-construction trades stratification, that was the 

hard part. Going through with all of the data and 

figuring out for this particular person's bioassay at 

that time, were they a construction trades worker or 

were they an operations worker.

We've demonstrated in this model Rev 4 that we 

have sufficient data to stratify the workforce. The 

question is how we should stratify it. We picked a 

priori to go routine and non-routine operations 

which translates to construction trades and nonconstruction trades. What remains unclear to us is, 

is that the right strata and those will be further 

discussions we'll be having with the Work Group 

when we reconvene. Because is stratification 

completely needed? Is construction trades, nonconstruction trades okay? Should we be stratifying 

on subcontractors versus non-subcontractors? 

Those are discussions that are to take place. But for 

this purpose of the demonstration we've shown that 

we can stratify here and that's what we'll go 

through for this example here.

So for Savannah River co-exposure models, which 
110

ones are needed? ORAU-OTIB-18 which is a 

bounding approach using air monitoring actually 

takes care of a large number of claimants who 

would need a co-exposure model. And this is 

because a lot of the claimants that we have that are 

not monitored don't have metabolic cancers. And so 

this bounding approach ends up resulting in an 

overestimate of their dose and we can process the 

claim.

The goal of the co-exposure model is to supplement 

ORAU-OTIB-18 with a best estimate co-exposure 

model. For those cases where the decision rides on 

-- not an overestimate or an underestimate, but we 

can use -- we need a best estimate.

So from this we decided that we needed a coexposure model for all the major radionuclides at 

Savannah River because these are the ones that we 

could potentially get claims for. So there's nine of 

them. There's the trivalents which is americium, 

curium and californium. At some sites these are 

called exotic radionuclides. At Savannah River 

they're not as exotic because they actually produce 

this material.There's tritium, plutonium, uranium, 

fission products which includes strontium, cobalt-60, 

cesium-137, neptunium and thorium. Those are the 

nine co-exposure models that we developed.

Now with that a priori stratification that we did 

there's actually 18 models here. So there's each of 

those nine radionuclides, one for construction trades 

and one for non-construction trades. So there's a lot 

of work that went into this particular effort. So how 

OTIB-81 is organized is based upon the radionuclide 

that we are presenting and modeling here.

And the format for the discussion closely follows 

that implementation guide. It starts with data 

adequacy, goes on to data validation. The data 

adequacy discusses personal monitoring, the 

applicability, the bioassay analysis techniques, and 

then the data validation goes through completeness 

and interpretation and exclusion. We get to the 
111

statistical analysis, the development of the TWOPOS 

values and then the intake model. 

So these four methods is what you will see within 

the OTIB-81 as far as following the discussion. So I 

want to walk you through the plutonium coexposure model for Savannah River for nonconstruction trades workers to give the example 

here. Keep in mind there's a lot of data that we 

could be going through. I'm trying to give an 

abbreviated version here.

So in walking through this we'll start with data 

adequacy. And we looked at the personal 

monitoring, who was monitored. And there are 

bioassay control procedures starting in 1968 -- this 

is in Attachment C of the report -- that identify the 

types of workers, the frequency of monitoring within 

specific areas.

One of the things with construction trades workers, 

they were monitored every three years for 

plutonium.

The applicability to unmonitored workers. And this 

would be the number of workers monitored was 

relatively constant over time. So there were no 

temporal gaps.

Workers with the highest exposure potential were 

monitored more frequently. 

How do we know that? Well, if you look at this 

particular table in Attachment C. And I know you 

can't read it there because last week when I put it 

up on the screen I realized nobody could read it 

either so I'll summarize the plutonium one in the 

next slide. But across the columns that you see is 

plutonium, enriched uranium, uranium, induced 

activity or fission products, the americium, curium, 

californium, strontium, tritium. And so for each area 

which is the far left column there's different 

frequencies associated with these radionuclides. 

So let's just look here at the plutonium one. And 
112

they separated the workers in this time period --

that was 1976 by the way, the example that I'm 

giving here -- into workers with a low potential for 

exposure, a medium potential for exposure, and a 

high potential for exposure.

The low potential exposure was workers in the 

tritium facilities, the 100 areas which would be the 

reactors. 305-M was a reactor. 773-A, select 

personnel which would be supervisors and clerical 

people as well as reactor engineering from 773-A, 

all people who really don't work directly with

plutonium. And so their sampling frequency was 

once every three years.

The people with the medium potential that I would 

call for an exposure to plutonium were those in the 

221-F and H canyons. The A-Line was the uranium 

line. 235-F, people who worked in the non-process 

areas of that building, and people in 772-F who 

worked in the non-process areas, and those in 321-

M.

The sampling frequency for those workers was once 

per year. They would leave one plutonium sample 

per year.

People with a high potential for exposure would be 

those who worked in the HB line, FB line, and JB 

line.

These were the three plutonium production lines. 

This is where they took the plutonium solutions 

coming out of the canyons and turned them into 

plutonium metal.

Also 235-F, the process area and 772-F, and then 

select personnel in 773 which were part of the 

analytical chemistry division, the high-level caves, 

et cetera. They were sampled for plutonium four 

times a year.

So you can see that their monitoring frequency that 

we would see in the bioassays follows their 

exposure potential. So we know the highest 
113

exposed workers were sampled more frequently.

So next we looked at the analysis method. These 

would be the bioassay techniques. 1954, there was 

a bismuth phosphate method and lanthanum 

fluoride co-precipitation.

Fifty-nine was a nitric acid/hydrogen peroxide 

dissolution. 1966, TIOA, liquid extraction, and '81 

was a co-precipitation technique with alpha 

spectrometry.

Another part of the analysis method that we looked 

at is the censoring level or the reporting level.

And for plutonium it was 0.1 disintegrations per 

minute per day. This is a reporting level, not 

necessarily a limit of detection, or a minimum 

detectable activity.

And to give an example of that, if you look at the 

plutonium logbooks you'll see in here the dpm per 

1.5 liters, this is a dpm per day. And you can see 

the very top result is 0.029 dpm per 1.5 liter. What 

appears in the worker's record is less than 0.1.

So most of the workers' records have this less than 

value. That was an action level where they would 

begin to do follow-up at the site. But there is the 

uncensored values that are available. However, 

most of our models were using the 0.1, less than 

0.1.

So with plutonium and data interpretation, most of 

the measurements were gross alpha after chemical 

extraction or chemical separations. 

During the 1980s, plutonium-238 and 239 were 

reported separately. We merged these into a gross 

alpha result in order to be consistent and we made 

a claimant-favorable assumption and assumed 12 

percent of 10-year aged plutonium.

There were some data that we excluded from this. 

The draft criteria indicated that we should identify 
114

what data we were excluding.

Some of the data we excluded were those chelation 

samples, or indication of DTPA use. And the primary 

reason for this was that the -- when you chelate an 

individual to remove the plutonium faster you're 

interrupting the biokinetic model which is what we 

use to estimate the intake rate based upon 

urinalysis. So those samples were removed.

As well as there were some samples who had lost in 

process where something happened in the lab and 

they would do a re-sample. If it had an LIP next to 

it, we removed those values.

Also, some had insufficient identifying information. 

And then there were some samples that were given 

per unit mass which are likely fecal samples and 

again that's a different biokinetic model than the 

urine model that we were using.

The next phase that we went through was looking at 

the data validation. And this was, for the plutonium 

model we used the NOCTS in vitro dataset.

I showed you earlier logbooks. There's a lot more 

plutonium data that ares available. However, we are 

using NOCTS as a representative sample.

We had sufficient data there that were already 

coded that we could use. This particular in vitro 

dataset contained plutonium, uranium, enriched 

uranium, and fission products.

We separated the acceptance criteria of the dataset 

into two categories, critical fields and all other 

fields.

The critical fields we felt were the isotope and the 

result. And the result included that less-than value.

And so to get to 1 percent from this data set -- and 

by the way, this data set n was equal to 303,000 

entries. Yes, 303,000 entries.

So we checked -- 4,386 entries were checked. And 
115

there were 11 errors. So our error rate was 0.25 

percent with a 95th percent confidence interval of 

0.13 to 0.45 percent.

Then we checked all of the other fields which 

included last name, first name, middle name, 

payroll ID, date, units, and then the area.

Because we had a higher acceptance criteria rate of 

5 percent we didn't have to check as many fields. 

Eight hundred and seventy-four fields were checked 

and there were four errors in this dataset, so 0.46 

percent was our error rate within that dataset with a 

confidence interval from 0.13 to 1.17.

So we did this for each of the datasets that we were 

using here. So this took a lot of time to go through, 

develop, clean the datasets, and then go through 

and do the checking.

The next part of the analysis was the time-weighted 

one person one statistic methodology. Again, we 

used RPRT-53 which was an analysis of stratified 

co-exposure coworker data sets. The title is a little 

misleading from what ended up coming out of that.

The TWOPOS data are fit to a log-normal 

distribution during the statistical analysis. 

I want to reemphasize that most of the bioassay 

data is censored, reported as less than some value. 

And in fact generally the datasets are censored 

more than 75 percent. To fill in for that censored 

data what we used was a multiple imputation 

technique. And this is outlined in RPRT-96, Multiple 

Imputation Applied to Bioassay Co-exposure 

Models. And this will be discussed more by Bob and 

the Work Group and there's more work to be done 

here as to what method we use here. But this is 

what we propose to use. This is what we think is 

right. And what we do for the multiple imputation 

methodology is we fit the bioassay data, the upper 

tail of it, and assume that it extrapolates down as a 

log-normal distribution.

The example I'm giving here is 1969. And so based 
116

upon this particular fit, the left-hand graph that I've 

got, we then calculate the TWOPOS value.

And some people, they have no censored values, 

and so from that standpoint those would be the 

black dots on the graph on the right.

Some people, less than 50 percent of their values 

are censored. When they do have a censored value 

we'll go to the chart on the left and we will grab --

randomly grab a value between the censoring level 

of 0.1 and down to nearly zero, but following that 

log-normal distribution. 

So we'll pick a sample out of there, calculate their 

TWOPOS value.

We do the same thing for people who have multiple 

samples that are censored. We might pull two 

samples out of there, or three. However many 

censored values they have we will go and grab them 

from that graph on the left and then impute, 

calculate their TWOPOS values.

The graph on the right is the first run of the multiple 

imputation. So this is our first simulation of going 

through and doing this. We do this multiple times, 

over and over, to end up with this particular type of 

a graph in data.

And you can see that the spread toward the left end 

of the log-normal distribution begins to widen out as 

one would expect.

From this TWOPOS plot for each year -- and actually 

each year and each strata; this is the 1969 nonconstruction trades worker strata -- we will extract 

the 50th percentile and the 84th percentile from 

along that red line that's on there. This is assuming 

a log-normal distribution. And from that we develop 

what we call the TWOPOS data table here. And I've 

listed here the results from 1967 through 1970. And 

you can see the 50th and the 84th percentile. 

We do calculate the GSD from that and then the 
117

next column over lists the number of workers that 

were involved in that TWOPOS model or log-normal 

model that we use.

And here we've got construction trades workers in 

the first, or the second through fifth columns, and 

then non-construction trades workers -- I'm sorry, 

construction trades workers on the next set.

So now from this TWOPOS data, again we're using 

the 50th percentile and the 84th percentile. Using 

that data for each solubility type now we do the 

intake model. So now we've got each radionuclide 

separated by non-construction trades and 

construction trades workers and each solubility type 

that we could possibly end up applying to a worker 

which can vary as far as what their organ dose 

comes out to be.

And here's where the internal dosimetrist earns 

their money. This is a difficult task of selecting the 

time intervals of similar results, but this is what 

they do in real life as far as figuring out how to 

model bioassay data.

What they do is they assume a chronic intake 

scenario for each time interval to determine the 

intake. So we're looking at the bioassay data and 

trying to model what intake would give an output of 

bioassay that looks like that. And so I'm going to 

walk you through this example pretty quick here.

But in this case the first intake interval is those first 

six blue data points. So this would be from 1955 to 

1960. The internal dosimetrist came up with a 

chronic intake of a particular value that would give, 

bioassay that would follow that black line that I'm 

showing, if they were only exposed during those 

first six years.

Then they look at the next time interval, and this 

will be '61 to '66. And again it happened to be six.

Then you see the data jump up, at least from the 

bioassay standpoint. And so these will be the 
118

TWOPOS data by the way that I'm looking at, the 

50th percentile.

And so the intake increases during this particular 

time interval. And this would be four years, before it 

begins to fall back down.

And so the fourth interval would be '71 to '81 and 

this would be the intake value. And then the final 

data set would be '82 to '90 that's modeled here.

So these are the five periods that I just walked 

through that the internal dosimetrist comes up with 

and what they come up with is a 50th percentile 

intake rate. So this is in dpm per day.

They repeat that exact process I just showed you 

for the 84th percentile. So they take the 84th 

percentile data and do it again.

From that we calculate the geometric standard 

deviation, this column right here. And you'll notice 

here that the next column is an adjusted GSD.

If any of these geometric standard deviations in this 

first one are less than three we increase them to 

three because that's the minimum that we use for 

uncertainty in internal dose calculations. So that's 

why that changed from 2.98 to 3.

Then from the 50th percentile and this adjusted 

geometric standard deviation, we calculate the 95th 

percentile of this distribution. 

This would be the intake distribution that if a worker 

was exposed or we are assigning this particular 

dose we would look at their employment dates of 

when we are going to start that particular exposure 

and then assign these particular values into their 

intake model that we would do to calculate dose for 

their particular cancer.

If a worker worked for all these years, 1955 through 

1989, and we assigned all of those intake values 

over that whole time period, their urine excretion 
119

would follow this green line.

And you can see that this cumulative model is overpredicting what we see in the actual bioassay. And 

this would be the 50th percentile. And this would be 

the 84th percentile.

And so what I've superimposed on here is a blue 

line indicating what that censoring level is. 

And what you'll see here is that if a worker that we 

were assigning this data to that was not monitored, 

if they had been given a bioassay sample in the 

latter years, it would have shown up positive with 

this type of an intake.

So we feel that this is claimant-favorable, but it's 

reasonable and sufficiently accurate for a coworker 

model.

This is just another version of that previous graph 

that I've got. The box and whisker plots are the 

distributions of the TWOPOS data with the red being 

the geometric mean or the 50th percentile and the 

blue dots being the 84th percentile of what would 

be predicted in the urine if somebody was exposed 

over this whole time interval.

So we did this for plutonium that I just showed you. 

We did it for americium. Here's those particular 

results. And then tritium.

Tritium is a little different because we could use 

dose. We didn't have to go to intake.

And one thing to note here with the tritium is post 

1980 time period, these models are all less than 

100 millirem for the Savannah River Site here.

We did it for uranium, for Type F, Type M, Type S. 

The plutonium by the way example I gave you was 

Type M. We also did Type S from that. But here this 

is to demonstrate that we've got multiple different 

solubility types and you have to do this for each 

solubility type that you're going to assume.
120

Also for cesium. And then neptunium is a little 

different, a little interesting. We had to break this 

into two parts because we have two different 

monitoring methods. The first part was urinalysis. 

That's the graph over here off to the right at the 

top.

And then we switched to whole body count data. 

And the sum of the two is what you see in the large 

graph here with the step function change here 

around 1970.

And the reason we had to do that is you see that 

the urinalysis data is quite sparse in that time 

period. But we do have the whole body count data 

that we could use and develop a co-exposure 

model.

What we superimposed here in the 1980s time 

frame, we did have a significant amount of actual 

urinalysis data and we wanted to see how does this 

model fall with the data that we do have. And 

clearly from this example here we are bounding in 

this particular scenario for neptunium.

So the next step would be the application of the coexposure model to the unmonitored workers.

Normally the 50th percentile with a full log-normal 

distribution will be assigned to workers who may 

have been exposed to greater than environmental 

levels, but less than a typical operations worker.

So, this would be somebody who intermittently 

went into an area. And in this case because I'm 

looking at non-construction trades workers here, 

this would be a clerk or somebody who goes into an 

area and was not monitored.

Workers considered to have a high potential for 

exposure may be assigned something higher like 

the 95th percentile of the co-exposure model 

distribution on a case-by-case basis as determined 

by the dose reconstructor.
121

But this would be something the dose reconstructor 

would look at and then make that judgment based 

upon a lot of other data that could be available 

within the claimant file.

So, this example of the co-exposure model 

demonstrates how the draft criteria for evaluation 

and use of coworker datasets would be 

implemented.

We believe the intent of the draft criteria for 

evaluation and use of co-exposure datasets has 

been met. Some of these words here got jumbled 

here. I apologize for that.

NIOSH believes the co-exposure models presented 

are claimant-favorable, reasonable, best estimate 

and adequately bound the potential doses for 

compensation purposes.

So, our next steps is that now that the Work Groups 

have approved this methodology is we're going to 

go and take that draft guidance and turn it into 

finalized guidance and post it on our web. We will 

be changing the name to co-exposure model so you 

might see that within the report, but that will be the 

only change. And then we'll start implementing this 

method across all the sites where co-exposure 

models are needed.

Just to let you know, this implementation of this 

methodology is going to take some significant time. 

It's going to take years to get these updated.

So as we get new models updated and start using 

them we will of course be doing a PER looking at 

past dose reconstructions in all cases to make sure 

that nobody's claim would change, or if they do 

change, to notify the Department of Labor and redo 

those dose reconstructions.

And with that I'll turn this over to Bob Barton where 

SC&A reviewed the co-exposure model.

Mr. Barton: Thank you, Tim. I guess just to start off 
122

I'd like to recognize the SC&A team that worked 

very hard on this review. That's Ron Buchanan, 

Harry Chmelynski, Rose Gogliotti, and Joyce 

Lipzstein.

Our review identified six findings and seven 

observations which I'd like to give sort of a bird's 

eye view of now, not to get down into a lot of the 

details but to update the Board as to what was 

discussed and any resolution and our path forward 

that resulted from last week's joint meeting. So 

Finding 1. This has to do with what we call bioassay 

variability, but really what we're talking about is 

data adequacy.

And just to give a little bit of background so this 

finding makes sense, what they were doing at SRS 

for those trivalent actinide samples. Again, that's 

americium, curium, and californium is they take an 

individual urine sample, a single voiding, and they 

would split it out onto different discs or planchettes 

if you want to think about it that way so that they 

could measure it multiple times.

Now, what we recognize, and this discussion 

actually goes back a number of years, is that even 

at the high levels, levels much larger than a 

censoring level, we were seeing significant variation 

between measurements of what is the same exact 

urine sample, just measured on a different disc.

And so that certainly gave us concern from a data 

adequacy standpoint which the implementation 

guide really describes as does the data we're 

looking at sufficiently reflect the exposures with 

which we're trying to reconstruct here. And when 

we saw that kind of variation it certainly gave us 

pause.

A discussion with the SEC Issues Work Group and 

the Savannah River Site Work Group, the tasking 

really came back to us on that, that we really need 

to go in and look at the actual analytical methods 

that were employed and the documentation behind 

those methods to see if there's anything in there 
123

that troubles us.

So that would be things like the chemical extraction 

method, the detectors that were used, the detector 

efficiencies, anything in there that might explain

this variability which really gave us concern. So that 

was Finding 1 which is SC&A's action item.

Finding 2, and this has to do -- Finding 2, Finding 3 

and Observations number 1 and 2 all really have to 

do with this multiple imputation method which Tim 

described.

And really what we're talking about is when you 

have a dataset with all these bioassay results that 

are less than the detection limit or the censoring 

level and you don't really know what the true 

number is below that less than result what do you 

do with that data.

NIOSH has developed the multiple imputation 

method. This method has been actually used in 

some external dosimetry applications, but this is 

really the first time it's been used in a coworker 

model.

And as Tim mentioned, RPRT-0096 details that 

method and how it was developed. And RPRT-0096 

was issued earlier this year in January I believe.

So again, Finding 2, 3 and Observations 1 and 2 

really all have to do with this multiple imputation 

method. And really they have the same status.

So Finding 2 was the use of imputed values that are 

less than one-half of the MDA raises a fundamental 

fairness issue in that monitored workers who have 

bioassay results that are less than the MDA are 

assigned a missed dose.

This is in accordance with ORAU-OTIB-0060, the 

internal dose reconstruction. 

Per that guidance if you are a monitored worker and 

you have a result that is less than the detection 
124

limit it's evaluated at essentially one-half of that 

detection limit.

So we looked at that and then we compared it to 

some of the coworker values that were developed 

using the multiple imputation method.

And we noticed that the results, the resulting 

coworker representative bioassay results were often 

much less than the MDA, and often much less than 

one-half of the MDA. So that certainly gave us 

pause.

So what we did in our review was to perform some 

scoping calculations. Let's come up with a 

hypothetical worker who has a result that is less 

than the MDA. 

Let's evaluate their dose, their intake, their dose, 

and then let's calculate a theoretical Probability of 

Causation.

Then let's take that same worker and assume that 

hypothetical again, hypothetical worker, and 

assume that they were assigned the coworker 

values. 

And again, go through the exercise, calculate their 

assigned dose and then follow it through to the end 

result of a Probability of Causation.

And I'd just like to note one finding and one of the 

observations is about those results, that these 

scoping calculations are purely illustrative. They 

certainly don't encompass all the different scenarios 

and factors that really go into these internal dose 

calculations.

So that was Finding 2 and the status of that is again 

SC&A was tasked to go and review the actual 

underlying report, RPRT-0096 where this multiple 

imputation method was developed and first 

implemented really in this SRS coworker model.

Observation 1, again related to the multiple 
125

imputation method reads while the multiple 

imputation method is mathematically correct it has 

the potential to result in biasing the simulated 

bioassay results unnecessarily low.

Alternate approaches such as the maximum possible 

mean method which replaces censored data with 

the actual censoring limit, or alternatively one-half 

the censoring limit, would solve the issues 

associated with datasets containing a large number 

of censored values in a claimant-favorable manner.

So again this goes to what do we do when we have 

all of these bioassay results that are less than some 

limit and we really don't know what the true value 

is. 

So that has the same status as the previous Finding 

2 in that we're going to go and we're going to take 

a critical look at RPRT-0096 and how it fits in with 

the whole coworker modeling process.

Before I get to Finding 3 I realized just this morning 

that during all the hustle and bustle I somehow 

omitted Observation 2 from any of these slides. 

So I'll just briefly tell that Observation 2 was also 

about the scoping calculations.

And what was interesting about it is when we 

calculated the dose considering a missed dose. So in 

other words if the worker had a result it was less 

than the detection limit and we evaluated it as a 

missed dose the dose was always higher, in many of 

the scenarios we modeled the dose was higher than 

what the coworker model would assign.

And you say well, that might seem problematic. 

However, when you take the next step and you 

assign uncertainty to that dose the situation 

changes drastically for the Probability of Causation.

So for example, where we might have two 

scenarios, one coworker, one missed dose where 

the missed dose was actually two to five times 
126

higher than the coworker dose the fact that the 

coworker dose has an uncertainty distribution based 

on a lognormal with a minimum GSD whereas the 

missed dose is a triangular distribution, the 

Probability of Causations actually came out quite 

similar. 

So that was Observation 2, essentially pointing out 

that based on these scoping calculations it's 

apparent that the Probability of Causation is really 

driven by the statistical uncertainty that you place 

around the dose and not necessarily the magnitude 

of the dose itself. So that was Observation 2.

And again I apologize that that slide didn't make it 

in here. However, the presentation that's on the 

website for SC&A's review of OTIB-0081 has that 

slide as well as some additional information on that.

Finding 3, again about multiple imputation. This 

reads the sample comparison of coworker intakes to 

missed dose method for uranium specifically showed 

that the coworker model actually derived intakes 

that were a factor of four higher than the missed 

dose approach.

This was in comparison to the other contaminants 

that we evaluated such as plutonium, and mixed 

fission products.

And this illustrates the potential for inequity 

between the treatment of an unmonitored worker 

who's assigned coworker intakes and the monitored 

workers who have results less than the detection 

limit.

And again this all falls under the open SC&A action 

item to actually go back and take a hard look at this 

multiple imputation method as presented in RPRT0096 released earlier this year.

Finding 4 moves on to data completeness. As Tim 

mentioned, the coworker model for SRS is largely 

based on available NOCTS data, that is the claimant 

data available to us.
127

And there was a cutoff point. It was somewhere 

around August of 2011 which is obviously necessary 

because you have to make a cutoff somewhere to 

start your data evaluation. Otherwise you'd be 

constantly revising.

So at that date in August of 2011 there were about 

4,000 claims available for analysis to create this 

coworker model.

Since that time there have been about another 

2,000 claims that have been submitted. So 

essentially another 50 percent.

Inclusion of this data would be especially important 

for the two contaminants that required a 

combination of multiple years for analysis because 

you simply didn't have a sufficient number of data 

points to do it on a year by year basis. And that was 

for uranium and cesium.

This was discussed in depth with the Work Group. 

And while everyone agrees that it's always better to 

have more data as it improves your counting 

statistics and precision the amount of effort 

including pulling that additional data for those 

additional claims, stratifying that data into 

construction workers and non-construction workers, 

essentially the benefit to the level of resources and 

effort was deemed to be outweighed.

So the Work Group decided not to pursue the 

inclusion of this additional data and that finding was 

closed.

More on data completeness. Observation 3. This is 

again looking at those trivalents, the americium, 

curium, californium.

And we noticed that in particular in 1980 and 1982 

the number of samples that we have available for 

coworker analysis was less than what was reported 

by the site as actually having been analyzed in that 

year. We're talking around 70 percent roughly.
128

So the site reported a certain number of samples for 

that year and we're only seeing roughly 70 percent 

in those two years in the nineteen eighties.

This observation notes that any changes in 

operations are not discussed. If you have what 

could be considered a data gap you really want to 

take a hard look at the operations and what they 

were doing to assure that there was nothing going 

on during that period that could be potentially 

missed or underestimated by any dose assignments.

Now during that discussion it was actually brought 

up I believe by a member of ORAU that there's 

actually documentation that during that time frame 

there was a whole backlog piling up of bioassay 

analyses.

So those samples, even though they might have 

been distributed in those years and the sample was 

given in those years they might have been actually 

analyzed years later which is actually somewhat 

shown by the data in those later years in the 

nineteen eighties. 

So the action item is really to NIOSH there is to 

provide that reference or references to really 

document that the reason we're seeing this sort of 

lull in comparison between the number of samples 

the site was reporting as having either distributed or 

received is actually consistent with that backlog that 

was taking place during that time.

Observation 4. This is actually really just a 

carryover. This observation appeared even in 

Revision 3 of the co-exposure model from back in 

2016.

And that is OTIB-0081 does not provide a statistical 

comparison of the two stratified groups as described 

in the Coworker Implementation Guide. 

The various coworker models were stratified based 

on the a priori assumption that exposure potential 

between construction trade workers and non-
129

construction trade workers was different.

Now again, we added this observation in because it 

was SC&A's mandate not only to review the SRS 

coworker model specific to issues related to SRS, 

but also how it followed the coworker guidelines. 

So obviously as Tim had mentioned before there's a 

lot of history to this in that -- we were never really 

able to develop a proper statistical test that would 

have the power to differentiate between the two 

groups.

However, logic really tells us that the non-routinely 

exposed workers are likely in a different exposure 

category than those who were exposed more 

routinely. 

And so the status of this is there's really no action 

required. It's just, it's there to note the fact that the 

coworker guidelines say that you should perform a 

statistical analysis after you stratify the groups to 

see if they're truly different.

And in this case the two groups were stratified a 

priori.

Observation 5. And this again is about stratification. 

SC&A believes a quantitative assessment of 

available job plans rather than a qualitative basis is 

appropriate to determine that prime contractor and 

subcontractor CTWs are part of the same exposure 

strata.

Such an assessment has been performed by NIOSH. 

A report of their findings has recently been issued.

So essentially this whole issue is about within the 

OTIB-0081 coworker model there were some 

anecdotal examples of construction workers on work 

permits that concluded that prime contractor 

construction workers were really working side by 

side with subcontract construction workers and 

therefore could be considered part of the same 

strata.
130

And again that was sort of a qualitative evaluation 

of it.

Since that time NIOSH has put together an actual 

quantitative comparison of prime contractors and 

subcontractors regarding plutonium up till about I 

believe 1990. That report is SRS Construction Trade 

Worker Plutonium Stratification Refinement. It's on 

the website.

So, obviously the status of that is it's getting 

transferred and being subsumed under the review of 

that White Paper that I just mentioned. So there's 

really no action required with regard to OTIB-0081.

Finding 5. This is specific to the classification of the 

job machinist which we note that in PER-014 was 

considered a construction trade worker while in 

OTIB-0081 in the listing of job titles that would be 

considered construction trades versus nonconstruction trades, a machinist was considered a 

non-construction trade.

What NIOSH did in response to this is they actually 

went through and pulled NOCTS claims that had 

machinist in the title.

As it turned out a lot of them actually were -- even 

though in the table it shows machinist as a nonconstruction worker, when it came to the actual 

coworker model they were categorized correctly as 

construction workers because the title machinist 

was also associated with other titles such as a 

maintenance mechanic.

And for the remaining cases where it's possible that 

the machinist might have been misclassified it's a 

very, very low percentage so it likely would not 

affect any resulting coworker distributions.

And also noted by NIOSH that the misclassification 

rate, this is the quality assurance they performed 

after they developed the coworker model and 

whether the workers were correctly classified as 

construction trade workers or non-construction 
131

trade workers was less than 5 percent. So it met 

their quality assurance criteria.

Again, it was determined that would have a minor 

impact on the co-exposure models in any case.

This is a little bit more that SC&A did about sort of 

the difficulty in correctly classifying some groups of 

workers as either construction trade worker or a 

non-construction trade worker.

And Finding 6 and Observation 6 as you see are sort 

of --

Mr. Katz: Bob, I'm sorry, let me break in. Someone 

on the phone line has -- someone has their phone 

line open and there's a bunch of chatter and it's 

probably especially difficult for people on the phone 

to hear what's going on in the room.

So please, everyone on the phone should have your 

phone muted. If you don't have a mute button for 

your phone press *6 on your phone and that will 

mute your phone for this conference line. But please 

don't have an open line with discussion. Thanks. Go 

ahead, Bob.

Mr. Barton: Again, this is about sort of the difficulty 

in classifying workers as either construction worker 

or non-construction worker.

And as Tim indicated, and what we're really talking 

about is the non-routinely exposed worker versus 

the routinely exposed worker.

I'm not saying that they're non-routinely exposed. 

It's that their exposure potential is not of a routine 

nature. They're doing different jobs. They're 

breaking down glove boxes. They're doing 

modification, that sort of thing, versus a routinely 

exposed worker who might work at the same glove 

box for their entire career. And there are more 

permanent sort of engineering controls and such 

associated with that.
132

So what we did, and this is the subject of Finding 6 

and again, Observation 6 on the next slide.

Targeted sampling compared the OTIB-0081 strata 

designation -- again, that's CTW or non-CTW --

against two alternate sources for identifying worker 

job classification.

And it indicated that just over 9 percent of those 

entries appeared to be in conflict when you 

compared the NIOSH designation in OTIB-0081 and 

what SC&A did with these two alternate sources of 

information.

Now, just a note on that 9 percent. Again, this was 

a very targeted sampling. We looked specifically at 

job titles that might pose a problem with 

determining whether they should be included in the 

construction trade worker or non-construction trade 

worker.

Examples would be the job category such as 

foreman. Was the foreman in an office most of the 

day and would periodically visit his crew out in the 

field doing the actual radiological work? Were they 

up in the gallery just observing the work from sort 

of a distance?

Or were they actually hands on with a small crew 

down there doing the exact same work? It's difficult 

to tell unless you really get down into the case.

Another example was the assistant or helper 

category. If your job title is simply given as an 

assistant, well, were you a laboratory assistant 

where your exposure could be considered more of a 

routine nature, or were you a carpenter's assistant 

out there doing the non-routine construction type 

job work.

And the last one we really took a hard look at was a 

job title known as the general service operator.

Operator obviously is going to be considered with a 

more routine exposure category, but what we found 
133

was that the general service operator sometimes 

was more akin to a laborer or a truck driver, 

something that would be considered construction 

trade worker rather than a non-construction trade 

worker.

So this targeted sampling really looked at those 

jobs which could be considered in a gray area.

And so that 9 percent really just reflects a subset of 

the entire worker population. This 9 percent does 

not reflect the entire co-exposure population.

And so the Work Group discussed that issue and 

decided not to pursue a sensitivity analysis which 

this will make more sense when we get to 

Observation 6 on the next slide so let me just head 

there.

Observation 6 reads SC&A acknowledges that there 

are inherent difficulties in correctly associating 

individual workers with the correct CTW/non-CTW 

strata. 

This is particularly true for job titles that could 

potentially be included in either strata.

SC&A suggests a scoping analysis in which the 

borderline job titles are removed to ascertain the 

effect on the resulting distributions.

Such an analysis would help determine whether 

current strata designations are sufficient, or a more 

rigorous approach to individual job classification is 

warranted.

After lengthy discussion similar to the finding 

regarding the extra claims that have been filed 

since the coworker model essentially cut off back in 

2011 it's really the amount of resources that would 

have to be expended for such an analysis really 

outweighs the potential benefit.

And again, we were looking at a very small subset 

of the population so it's not clear that it would really 
134

even have a discernible effect on the resulting 

distributions.

Observation 7, and this is the last one. This has to 

do with the quality assurance assessment that 

NIOSH performed on their own dataset. 

Again, going in and pulling random samples, 

predetermined set of random samples to see if they 

hit either the 5 percent criteria for what's called a 

non-critical field, or 1 percent criteria for critical 

fields. Critical fields are obviously going to be the

actual sample result and things of that nature.

And observation 7 reads the results shown in 

Attachment A -- that's where the quality assurance 

assessment was detailed -- demonstrate a high 

degree of confidence that the acceptable error rates 

are within the goals established for each test.

However, this conclusion is dependent on the 

assumption that payroll ID issues identified would 

not affect the resulting coworker distribution.

Now that last sentence, the payroll ID issues. 

Essentially payroll ID was often used as a way to 

identify who was a construction worker and who 

was a non-construction worker.

And I believe, and I don't want to botch this so Tim 

interrupt me if I'm wrong, but I believe what came 

out of that discussion is that through this quality 

assurance assessment NIOSH was able to actually 

identify what was a systemic problem with one 

particular format in these payroll IDs.

And so the QA assessment uncovered that. And 

once it was figured out that that might have been a 

systemic problem all of those affected results were 

targeted and corrected. That's basically what it was. 

And so that observation was closed.

So that ends my summary of the SC&A review of 

OTIB-0081.
135

Dr. Taulbee: We would be happy to answer any 

questions on OTIB-0081 now.

Mr. Katz: Thanks, Tim. Thanks, Bob. Very nice 

summary. Very long day of discussions. Go ahead, 

Jim.

Member Lockey: Bob, I'd make one suggestion on 

that SC&A Finding 6, the finding and the conclusion.

I understand what you meant there, but a year from 

now if somebody goes back and pulls this out and 

looks at it it's not going to be clear, 9 percent 

versus 5 percent.

So maybe you can put some clarification in that for 

the record.

Mr. Barton: Sure, absolutely.

Member Lockey: What we mean by 9 percent. It 

was a very targeted population. Okay, thank you.

Mr. Barton: Yes, I agree. That was certainly a 

source of confusion during Work Group discussions 

last week so that needs to be clarified.

Member Lockey: That confusion will carry forward 

as our memory fades.

Mr. Katz: Thanks, Jim. Thanks, Bob. Other 

questions from Board Members in the room? How 

about Board Members on the phone?

Member Roessler: This is Gen.

Mr. Katz: Hi Gen.

Member Roessler: Can you hear me okay?

Mr. Katz: Yes, perfectly. Thanks.

Member Roessler: Okay. Since we had the Work 

Group meetings last week there's been this change 

in the name of the model from the coworker model 

to the co-exposure model.
136

And since SC&A used it or NIOSH used it, SC&A 

used it I assume that everyone agrees that this is 

an appropriate change in the title.

Mr. Katz: I think everyone in the NIOSH program 

folks thought that was actually a great clarification. 

And SC&A folks I think agreed as well. The Board 

Members that were involved in the mix there 

thought that made a lot of sense.

It's such a sensitive issue. It's just one phrase, but 

it's a phrase that actually resonates for the claimant 

population too. So as a clarification it seems like a 

good one.

Member Ziemer: Can I add to that?

Mr. Katz: Yes, Paul, go ahead.

Member Ziemer: Hi Gen, this is Paul. Also, it should 

be noted that it wasn't really a formal action to 

change this. I'm not sure it's required.

But I think we all were aware and have been aware 

for actually years that the claimants frequently, 

almost always misunderstand what coworker model 

means.

They believe that it's the dose of somebody they 

specifically worked with. Another individual from 

their lab.

We had often gotten comments such as they did my 

dose reconstruction based on coworker data and 

I've checked with my coworker and no one ever 

talked to them about it. So it can't be true.

So the word is certainly misunderstood and we all 

felt this more generic word was perhaps better.

But I don't think the Board officially adopted new 

terminology, or if it's even needed.

Dr. Taulbee: I guess I would leave that to the Board 

as to whether they wanted to formally adopt it.
137

Mr. Katz: I don't think the Board has to adopt the 

language itself. That's how the idea was generated,

anyway, from that meeting.

Dr. Taulbee: We will certainly start using coexposure model going forward.

Member Ziemer: As long as it's clear what we're 

talking about it should be fine.

Member Roessler: Well, I certainly agree it's much 

of an improvement. 

Dr. Taulbee: Thank you.

Mr. Katz: Any other comments from Board Members 

on the phone? Oh, David, sorry.

Member Richardson: Could you start by describing 

the situations in which the model will be used?

Dr. Taulbee: Okay. When an individual has or does 

not have any bioassay data at the site. Let's say 

that they have no bioassay data and they have 

external monitoring data.

And so we look at the external monitoring data and 

it identifies certain areas that they went into. 

This would be an application where we could apply 

the co-exposure model to estimate their internal 

dose.

Member Richardson: And you had -- so this would 

be people -- is it only used when there's a complete 

absence --

Dr. Taulbee: No.

Member Richardson: -- of bioassay. Or is it for any 

given year of employment where there's an 

absence? Or how does it work?

Dr. Taulbee: Well, it depends upon the individual's 

case. I mean, if you look at their bioassay. Let's say 

they have some bioassay in latter years for let's say 
138

plutonium, for example. And in the earlier years 

they didn't, but they were in an area that was not --

that had a low potential for plutonium exposure. We 

might use the coworker model for those initial 

years, and then use their bioassay for the latter 

years. But we would be making sure that that 

bioassay in the latter years was bounded to where 

we would not be applying this coworker model if 

those bioassay in those latter years would be 

showing positive. So we would be using some 

variation between the two, but we would always use 

the worker's bioassay as the primary source for 

dose reconstruction.

If you were to invert those to where they had 

bioassay in the early years we would use that data. 

And then in the latter years where they didn't, and 

say they were in an area that required monitoring 

once every three years and they left after two years 

we would apply this co-exposure model for those 

last two years.

Member Richardson: One of the radionuclides that's 

on the list for co-exposure modeling is tritium. 

Could you discuss that because that's been 

problematic at SRS?

Dr. Taulbee: Okay. Give me a little bit more about 

what you're referring to as problematic.

Member Richardson: There are years -- if my 

recollection is correct there are years in which the 

external dosimetry record has the tritium 

component summed into it. And there are years

where it does not. So one can't partition out the 

component of dose which is from the tritium intake 

I would think. So is it viewed then as the 

assumption is it's all external? How does that work?

Dr. Taulbee: In the cases where -- it actually 

doesn't really matter from that standpoint because 

we have the tritium bioassay. We use that to 

estimate that worker's dose. Whether they included 

it in the external or whether they didn't doesn't 

really matter. We will use that person's tritium 
139

dose.

And what you're talking about is where it was a 

record-keeping scenario at the site where they took 

that bioassay, converted it to dose and added it to 

the external dose. In this case we have both the 

external dose and we have the tritium bioassay. We 

will do the dose calculation based upon the tritium 

bioassay regardless whether it made it into that 

final external dose or not. We will calculate their 

tritium dose based upon their bioassay. We get 

those results for every worker. Or not every worker, 

but every worker who left tritium samples. We get 

their individual bioassay.

Member Richardson: And then do you subtract it out 

from the external dosimetry record?

Dr. Taulbee: I would have to look at the Technical 

Basis Document to see. I don't know if there's 

certain years that we subtract it out and certain 

years when we can't determine and we just assume 

that this is all external dose and then add on an 

additional --

Member Richardson: Yes, I guess that's what I was 

asking. 

Dr. Taulbee: That's how I believe we handle it. But 

again we get the individual tritium bioassay dose. 

Member Richardson: And for the SC&A, one of the 

things that you had noted was you have a couple of 

open questions. One of them was this puzzle about 

the bioassay variability and what's causing parallel 

analyses of the same urine sample to give different 

results. 

Another one was could you describe -- you had a 

question about the use of multiple imputation for 

values that are less than one-half of the MDA. 

Mr. Barton: Yes. Multiple imputation, like I said it's 

been used for external coworker modeling in the 

past. This is the first time that it's been used for any 
140

sort of internal coworker modeling. And that is --

RPRT-0096 really describes that new method for 

internal coworker modeling.Now, what we noticed is 

as it was applied in this case often, for example, say 

for plutonium or something like that the multiple 

imputation method results in 50th percentile 

estimates of the bioassay value that are much less 

than one-half of the detection limit, of the censoring 

level.

So in other words let's just say for example you had 

a result that was less than one and that result was 

an individual's. That individual would be assigned a 

missed dose based on half that value assigned a 

triangular distribution. The imputation method takes 

that less than one and imputes a different value 

essentially and that goes into the coworker 

distribution. And what we noticed is that the end 

result after the imputation method is you could 

have coworker bioassay assignments that again are 

part of a distribution.

We're not assigning an individual imputed value, but 

you could have coworker values at the 50th 

percentile that are 10 percent of the censoring level, 

or even sometimes a little bit less than that.

Member Richardson: And over a large number --

because it's a lognormal distribution, and over large 

numbers of imputations the expectation of the value 

below the detection limit is -- it's the detection limit 

over the square root of two, isn't it?

So I believe that it would be -- it would not equal 

the detection limit divided by two. It would be the 

detection limit over the square root of two. So 

divided by 1.4. I think that's how that works.

Mr. Barton: I'm really not sure. Again, the -- what 

gave us the greatest concern was seeing coworker 

values that were so much less than one-half. And 

that's what drove us to do some of these scoping 

calculations.

Member Richardson: I would think that it would be -
141

- that you would get -- it should drive to something. 

You probably played with us.

Dr. Taulbee: Yes, and this is where SC&A has the 

action to review RPRT-0096 which actually looks at 

several datasets where we artificially create a 

censoring value and then do a comparison of the 

multiple imputation method with the real values 

within those datasets. And that's what SC&A is 

currently tasked to look at.

Just a bit of clarification from what Bob was saying. 

This is the first time this method has been used in 

coworker models. That is a true statement. This is 

the first time we've done a coworker model in this 

particular method and going through all of these 

steps of data verification and completeness and so 

forth. So this is how we're proposing to go forward. 

But again SC&A has the task to look at RPRT-0096.

Member Richardson: Okay, thank you.

Mr. Katz: Any other questions for Tim and Bob? 

Okay, then. We have actually -- Tim, do you want 

to say something?

Dr. Taulbee: Yes. RPRT-0092 now.

Mr. Katz: I don't know where we want to divide this 

in terms of the coworker model action versus --

Dr. Taulbee: Oh, okay. I'm sorry. Go ahead.

Mr. Katz: Okay, thank you. So we have two Work 

Groups that both voted in support of making the coexposure criteria guidelines final so that NIOSH 

could go forward with not just here, but coworker --

co-exposure modeling for other sites as well.

So, as with all cases with a Work Group motion it 

doesn't need a second. It's there. We've had I think 

all the discussion that there will be unless any of 

you want to discuss the fact that -- of moving 

forward on this and putting it to bed. I don't see 

anybody looking for that. So we can take a vote if 
142

you're ready for that. Dave?

Member Kotelchuck: Please be clear, what are we 

voting on?

Mr. Katz: So, what we would be voting is to agree 

that the co- as we want to call it now - coexposure criteria for modeling --

Member Kotelchuck: Jim Neton's.

Mr. Katz: Yes. Are made final and put into effect 

across the board. Clear, everyone?

Member Anderson: This is Andy. What our 

Committee looked at is kind of the 30,000 foot level 

of criteria that were set out, were they sufficiently 

comprehensive, did they cover all the areas that 

would need to be looked at when developing a coexposure model as opposed to what you really 

heard in the last two hours is the application of 

those criteria to the Savannah River Site and the 

development of a co-exposure model.

Our Committee really didn't look at decisions that 

NIOSH made, were they appropriate, was the data 

adequate through the whole time, all of that. It was 

just were there other areas that were missed, could 

it be done. 

And that's really what we're asking is we just 

couldn't identify any areas that would need to be 

worked on. Mostly it's a decision from the various 

Work Groups on site-specific things is we didn't 

really talk anything here much about stratification 

other than the construction and worker, nonconstruction worker kind of things.

But the issue of is that lumping everybody together 

and using all the data, is that an appropriate and is 

there adequate data for all the years, trying to fill 

in. That's really a site-specific set of discussions that 

our group really haven't been involved with at the 

Savannah River Site.
143

It was a very data rich site compared to others so a 

lot of the criteria about having 30 workers or 

whatever really wasn't an issue. So that's really 

what we're looking at is when you look over that set 

of criteria is there something missing, is there 

something that's not adequately spelled out.

We're not looking at has it been appropriately 

interpreted because that's always open to 

discussion and that I think is where the Savannah 

River study group is looking at a number of these 

issues.

So, we really felt that it's -- this set of criteria has 

been around since 2012 I think if not earlier. And 

drafts for so long and it really has not been altered. 

And we didn't think -- come up with anything that 

we thought ought to be changed in it or added to it. 

So that's what we're basically saying, trying to take 

the draft off it, make it a formal set of criteria.

And the only change that we're supportive of really 

is changing -- not calling it coworker, calling it coexposure because really that's what it's set out to 

do is looking at exposures doesn't matter so much 

what the job title was if we believe the people had 

the same exposure, were working in the same 

environment as other workers.

Mr. Katz: Thank you, Andy. Thanks for that 

elaboration.

Member Anderson: We're not suggesting that you 

were -- at this time we're adopting what Tim 

presented as the way forward for Savannah River. 

That's really up to the Savannah River group to 

decide and come back to the Board.

Mr. Katz: Right. Okay. Do we have other questions 

about what we're doing here?

Member Ziemer: Would it help for those that 

weren't involved in the double Work Group meeting 

to differentiate the action of Andy's Subcommittee 

versus I think it was Brad's Subcommittee which is 
144

the Savannah River.

I know we took specific action as two different 

Subcommittees at that meeting. And would it help 

for someone who has a better memory than I to 

summarize the two actions? Josie was there.

Member Lockey: I think the co-exposure model, I 

think we at the Subcommittee level thought it 

should be finalized and approved.

The appropriate thing is to do that at this meeting 

today, at least get that off the table from my 

perspective.

Member Ziemer: And basically the other part was 

the data adequacy in applying this model to 

Savannah River Site. And that was also I think is 

what --

Mr. Katz: Well, there's no motion for action there. 

There's no action to take there.

Member Ziemer: No, I'm just saying what the 

Subcommittee.

Mr. Katz: Oh, sure.

Member Ziemer: Well, both Work Groups.

Member Beach: And just a correction, it's a Work 

Group meeting.

Member Ziemer: They're both Work Groups.

Member Beach: Not Subcommittee.

Member Ziemer: Two Work Groups.

Mr. Katz: So anyway, yes. So the Work Groups have 

different charges although we did discuss in that 

meeting, or I did discuss I think it actually was very 

productive to have the Work Groups together for 

Savannah River even though again the SEC Issues 

Work Group, that's not their main charge. It was 

the guidelines.
145

It was useful having both because having more 

perspectives at the table for something as 

complicated as Savannah River Site is very handy, 

obviously very handy from the discussion that we 

had.

It was a fuller discussion by route of those 

perspectives. So I had suggested that we continue 

to have joint Work Group meetings to work through 

the Savannah River issues, even though SRS, I 

mean the Coworker Model Work Group doesn't have 

to be there for that.

Member Beach: So we're just doing an action on the 

criteria --

Mr. Katz: The only action here is to put to bed the 

criteria.

Member Beach: The coworker -- so it's not going to 

be a draft. It's actually going to be a coworker 

criteria.

Mr. Katz: Right. And both Work Groups actually 

voted on this even though it's really in the domain 

of the SEC Issues Work Group.

Dr. Taulbee: Yes, I just wanted to echo what Josie 

just said of making it from a draft criteria to a final 

criteria so we can start implementing it across the 

board.

Member Lockey: After 10 years.

Mr. Katz: No, no, 2015.

Dr. Taulbee: We will start implementing it now. It 

just takes a long time to finalize.

Mr. Katz: Five years. Don't double 5 to 10. Okay. So 

we're ready for a vote. Dave?

Member Kotelchuck: Well, I'm ready for a vote if 

you'd like to vote.

Mr. Katz: Okay. I like to vote.
146

Member Kotelchuck: I have a comment.

Mr. Katz: Oh, a comment first.

Member Kotelchuck: I wish as an example of the 

application of the coworker criteria that an example 

was chosen that was a little more simple, a little bit 

simpler than SRS.

However, we're voting on the criteria and to me 

those are clear, clear and understandable.

Mr. Katz: Yes. That sentiment, I think others 

probably hold that sentiment too. Although SRS on 

the other hand is a very good flogging --

Member Lockey: I second the motion.

Mr. Katz: I was trying to look for what might be 

missing. It's probably a good one in that respect 

because it raises so many issues.

Member Lockey: Ted, I'll second the motion.

Mr. Katz: So, let's run down the vote. Anderson?

Member Anderson: Yes.

Mr. Katz: Beach?

Member Beach: Yes.

Mr. Katz: Clawson?

Member Clawson: Yes.

Mr. Katz: Field?

Member Field: Yes.

Mr. Katz: Kotelchuck?

Member Kotelchuck: Yes.

Mr. Katz: Lockey?

Member Lockey: Yes.
147

Mr. Katz: Richardson?

Member Richardson: Yes.

Mr. Katz: Roessler?

Member Roessler: Yes.

Mr. Katz: Schofield?

Member Schofield: Yes.

Mr. Katz: Valerio?

Member Valerio: Yes.

Mr. Katz: And Ziemer.

Member Ziemer: Yes.

Mr. Katz: All in favor, unanimous, it passes. So 

that's done. Thank you. It's good to get that behind 

us. You guys are very unanimous today. That's the 

last of our votes. Go ahead, Tim.

Dr. Taulbee: Thank you very much. That does help 

us a great deal to be moving forward with coexposure models across multiple sites.

Next I want to give a status update on RPRT-0092 

which is the evaluation of subcontractor monitoring 

at the Savannah River Site.

And the first thing I'll say is this is an ongoing 

discussion between the Work Group, NIOSH as well 

as SC&A.

To give a little bit of an update of where we are with 

this particular review is in June of this year we 

released RPRT-0092 which is the evaluation of 

bioassay data for subcontracted construction trades 

workers at the Savannah River Site. This was 

submitted to the Work Group. 

In November, SC&A provided comments to us on 

this report. Last week, last Thursday and Friday 

both NIOSH, SC&A and they -- presented our 
148

respective views to the SRS and SEC Issues Work 

Groups.

Currently NIOSH is working to provide responses to 

SC&A's comments with regards to that report, 

RPRT-0092. We received a number of comments 

from SC&A and we are working through those to 

address each of them and then we will be meeting 

again on that particular issue.

Some of the major topics still needing further 

discussion to resolve will be the stratification issue 

that was pointed out earlier of non-construction 

trades workers, DuPont construction trades 

workers, subcontractor construction trades workers.

In June of this year we also submitted a White 

Paper entitled Savannah River Site Plutonium 

Construction Trades Worker Stratification 

Refinement.

And also in November SC&A provided comments on 

that White Paper. And we are going to be providing 

responses to them in early 2020.

And at that time I think it's appropriate for the Work 

Groups to obviously get back together and we will 

go through and discuss those -- that White Paper 

and SC&A's comments and our responses to them 

much like we did with the coworker model.

There's another report, Americium Monitoring at the 

Savannah River Site that we released in June of this 

year. This would be RPRT-0091, Evaluation of 

Savannah River Site Americium-241 Source Terms 

Between 1971 and 1999 Using Bioassay Frequency 

Tables. And SC&A is to provide comments on this 

particular report as well.

So those are some of the major topics that we have 

ongoing within these Work Groups, particularly the 

Savannah River Site Work Group, but the SEC 

Issues Work Group certainly are interested in their 

views of the stratification issue as well.
149

So that's a very short abbreviated update of where 

we are with Savannah River from the subcontractor 

construction trades worker evaluations.

All these reports are out on the web so if you want 

to read RPRT-0092 or RPRT-0091 they are out 

there. I will warn you they're a little lengthy. I think 

RPRT-0092 is about 181 pages. So it's an in-depth 

analysis and SC&A's comments I think is about 70 

pages. So it's some good light reading for everyone.

With that I'll be happy to answer any questions.

Member Beach: You might have just talked too fast 

there.

Mr. Katz: What's that? He stopped too fast?

Dr. Taulbee: I talked too fast.

Mr. Katz: Oh, talked too fast. Do we have any 

questions in the room? How about on the phone? Do 

I have any questions from Board Members on the 

phone? Joe, anything you want to say? Okay.

All right. We're at 4 o'clock and we have till 4:30. I 

had explained to petitioner/folks who represent 

folks at Savannah River Site that they could 

comment during the public comment session.

However, because I didn't know whether we would 

have time during this session for them to comment. 

We do have a half an hour though. And I don't know 

whether they're on the line and listening right now, 

but if they are and they would prefer to comment 

now instead of the public comment session that's 

most welcome.

If they'd rather wait till the public comment session 

or they can't hear me then that would happen 

anyway, that's fine too.

But do I have anyone from -- representing folks 

from Savannah River on the line who might want to 

say some words?
150

Mr. Ringen: Knut Ringen, I'm speaking on behalf of 

the building trades.

Mr. Katz: Knut, I don't know if you're using a 

speaker phone, but your voice is cutting out.

Mr. Ringen: Let me try something different. Is that 

better?

Mr. Katz: Give it a little try, let's see.

Mr. Ringen: Okay. How does that sound?

Mr. Katz: I think that's good. Thank you.

Mr. Ringen: Okay. I just wanted to make a couple of 

comments both about the coworker modeling and 

also about whether it can be applied to Savannah 

River in the way that NIOSH has proposed.

And I mentioned some of this when the Work Group 

meetings took place.

And I continue to ask this Board and I'd like to ask 

you again to determine what you mean by sufficient 

accuracy.

Because until you can do that then you really have 

no way of saying whether these models are valid or 

not.

There's no doubt there will be a significant number 

of workers who should get compensation who will 

not get compensation if you apply a coworker 

model.

How many that is is very hard to say. Is it 5 percent 

of all workers, 15 percent, I don't know.

But I do know this for sure. If you don't do 

stratification within these cohorts there is no way 

that you can accurately determine who's going to 

get compensation and not get compensation the fair 

way.

I don't see how you can do that without 
151

stratification. And I just want to make that point 

very emphatically.

I also want to make the point that NIOSH is 

increasingly moving towards imputation of data 

which is a very tricky thing.

It's obviously the statistics of last resort that you 

need to use. And it involves applying a huge 

amount of assumptions that may or may not be 

expressed correctly and may or may not be valid. 

That's certainly very hard for anybody who's not 

involved to confirm or validate.

I also want to warn about the excess use of the 

work permit to establish whether somebody was 

onsite, or whether somebody could have had --

(Simultaneous speaking.)

Mr. Katz: I don't know what happened. Try again.

Mr. Ringen: That happens frequently, Ted. Sorry.

Mr. Katz: Go ahead. Go ahead.

Mr. Ringen: I want to warn about the excessive use 

--

Mr. Katz: The further you're getting away from your 

mic, but it's happening again. We can't hear you.

Mr. Ringen: I tell you what. I'll send some 

comments in writing.

Mr. Katz: We can't hear you. I don't know.

Member Anderson: We can hear him on the phone.

Mr. Katz: You can hear him. That doesn't help us in 

the room. 

Mr. Ringen: Can you hear me now?

Member Clawson: You're clear to us, Knut, it's just 

that everybody in the room can't hear you. It's what 

we've been suffering with all day.
152

Mr. Ringen: Okay.

Mr. Katz: Something must be going on on our side 

here.

Mr. Ringen: I think it's your problem.

Mr. Katz: Hold on.

Mr. Ringen: That is frequently the case.

Mr. Katz: Okay, why don't you try now again, Knut.

Mr. Ringen: How does that help?

Mr. Katz: You were way better when we started. I 

don't know what happened. 

Mr. Ringen: But now I can't remember what I said.

Member Clawson: You were talking about the data 

and the use of it.

Mr. Ringen: I was kidding. I was kidding. Sorry.

(Simultaneous speaking.)

Mr. Katz: -- just keep talking randomly until we'll 

see if we can hear you.

Mr. Ringen: I don't want to waste anybody's time.

Mr. Katz: Knut, that's better right now. If the phone 

-- you can hold it where you have it that might 

work. Try again, Knut.

Mr. Ringen: Let me just very quickly, the points.

The Board and NIOSH has not defined what it 

means by sufficient accuracy. That's the first point. 

And until you do that you cannot really know 

whether what comes out of this modeling is going to 

be adequate.

The second point that I made is that I don't see how 

you can do co-exposure modeling without stratifying 

these populations because they're so 
153

heterogeneous. And I warn very much about 

jumping to conclusions that maybe you can do this 

without stratification. 

The third thing that I want to warn about is the 

increasing use and reliance by NIOSH on 

imputation.

As you know, in statistics that's a measure of last 

resort and it involves establishment of a huge 

amount of assumptions that are very hard for 

anybody who's not directly involved in the modeling 

to establish whether these things are going to be 

valid or not.

The fourth point I want to make is that NIOSH is 

also increasingly relying on work permits, whether 

site permits or job-specific permits to establish 

whether somebody has been at work in a particular 

location, task, or whatnot, and whether they could 

have had radiological exposures as a result of that.

I would not rely very much on work permits 

because they are very inaccurate. We know for sure 

frequently that construction workers worked outside 

their permits, are linked to other contractors for 

something or another.

And a variety of other things that workers have told 

NIOSH about down there.

I noticed in one of the slides that NIOSH presented, 

slide 53 in one of the presentations they reported 

that 7 out of 136 construction trade workers in a 

particular work permit were laborers.

That means that less than 5 percent of all 

construction trade workers in this particular job 

were laborers. That's inconceivable. That would be 

like having an operating room with only surgeons 

and no assistants.

In any work crew of construction trade workers the 

laborers constitute between 20 and 30 percent. So 

how one can say that a crew with 5 percent of 
154

laborers is indicative or representative of anything 

suggests to me that whoever decided also doesn't 

know very much about construction workers.

Based on all of these things together I think it's 

very unfortunate that NIOSH has spent so much 

time on doing all of this, particularly for the 

Savannah River workers.

I'm calling you now because the lead petitioner is 

dead. The two other petitioners are not capacity 

worthy or willing to participate in this.

The lawyer for the workers is in hospice and is no 

longer able to represent them, Bob Warren.

And all of this is a result of a period of 10 years of 

churning and churning data with very little gain to 

be shown for it. And it's incredibly unfair to the 

workers at Savannah River.

Moreover in general the co-exposure modeling that 

is being proposed is going to be unfair to somebody 

and we don't know who that is, and we don't know 

how many it is, or how significant that is, or 

whether that exceeds whatever looks to be 

significant in NIOSH's eyes at any given time.

But one thing is for sure, it's not going to be fair. 

Thank you.

Mr. Katz: Thank you, Knut. Knut, if -- if you have 

thumbnail notes of what you just said it might be 

helpful for the court reporter. If you don't mind. You 

could email that to me, or you could email that to 

the program and they'll send it to me. Whatever.

Mr. Ringen: I will, Ted.

Mr. Katz: Thank you so much, Knut.

Mr. Ringen: Sure.

Mr. Katz: Thanks, Paul, for that suggestion. Okay, 

very good. Do I have anyone else from the site on 

the phone who wants to say anything? All right 
155

then.

Our next session is -- well, we have a break 

between this and our next session, and the next 

session has to wait anyway because it's the update 

on Lawrence Berkeley. We don't want those people 

if they were expecting to call in for that to call in at 

the wrong time.

So we are on break and that break ends at 5 p.m. 

local time. So please be here at 5 p.m. for Lawrence 

Berkeley update.

(Whereupon, the above-entitled matter went off the 

record at 4:08 p.m. and resumed at 5:00 p.m.)

Mr. Katz: Let me check on the line to see if I have 

my Board Members on the line. Brad, are you 

there?

Member Clawson: I'm on, Ted.

Mr. Katz: Thanks. Gen, you there?

Member Roessler: I'm here.

Mr. Katz: Great. You guys are loud and clear right 

now, at the end of the day. How about Phil, are you 

on there? Phil?

(No response.)

Mr. Katz: And how about Andy, Henry Anderson?

Member Anderson: Here.

Update on Lawrence Berkeley National Laboratory 

Site Profile Review

Mr. Katz: Okay, great. Okay, so we might be 

missing Phil for the moment. And in the room we 

have all our Board Members, but for David 

Richardson's gone and Bill Field I think is 

somewhere. He's not in the room right now. But 

why don't we get started I think.

David is gone. Bill, I don't know where Bill is. He's 
156

missing. Oh, Bill's conflicted. He's not conflicted for 

this session because this session is just 

informational, but it's okay that he's not in the 

room. It's fine. He can't be active with this Work 

Group.

But otherwise the slides are up and Paul, I think if 

you're ready, we're ready.

Member Ziemer: Okay. I was sort of hoping there 

might even be some Berkeley folks in the room. So 

we'll be speaking to the choir as it were, Megan.

I'm like many old guys. I have to start with a story 

which is not in the slides. But I want to tell you the 

extent to which the Lawrence Berkeley National Lab 

impacted on me going way back.

In the mid-'50s when the Health Physics Society 

started -- and this is before I was around, by the 

way -- but the national meetings of the Health 

Physics Society were held in universities, not in 

hotels during the early years. The first one was held 

in 1955 at Ohio State University and the second one 

in '56 at the University of Michigan, the third one in 

'57 at University of Pittsburgh. And the fourth one 

was held in 1958 at the University of California 

Berkeley.

Now, the other thing that was going on in 1958 is 

that I had just received an Atomic Energy 

Commission fellowship which included a summer 

internship at the Oak Ridge National Laboratory, 

summer of '58. The contract for the fellows on the 

program, and there were 30 of them at Oak Ridge 

at the time, 30 young mostly whippersnappers who 

were taking their courses at Vanderbilt and their 

internship at Oak Ridge. And the program was 

administered for the Atomic Energy Commission by 

what was then called the Oak Ridge Institute of 

Nuclear Studies, now ORAU.

It turned out for some odd reason Oak Ridge 

Institute of Nuclear Studies had extra funds that 

they needed to spend on the fellowship program.
157

And they decided that all 30 fellows should come to

Berkeley for the annual meeting of the Health 

Physics Society. So they flew 30 of us out from Oak 

Ridge to Berkeley for that meeting. That was my 

first professional contact with the larger health 

physics community. And it was exciting to be part of 

that.

It was not realized by me at the time, but two years 

later, I would be at Purdue University working on 

my Ph.D. and it turns out that my mentor, my 

major professor John Christian had started a 

program involving the use of radio tracers, a 

program whose techniques he had perfected as it 

were by coming to Lawrence Berkeley and working 

with a group from the cyclotron group including 

Ernest Lawrence and his colleagues who had started 

to make radioisotopes for medical research 

purposes.

So John Christian learned his techniques from 

Ernest Lawrence, brought them back to Purdue and 

started the radioisotope program there which 

required them to bring in a health physicist which is 

how I got there.

So Berkeley has double-kicked my career into 

existence. 

And it seems not ironic, but at least curious that 

here we are as chairing the Berkeley Work Group. 

I'm pleased to have that opportunity.

I'm mainly going to introduce the person who's 

really going to talk about Lawrence Berkeley, but let 

me just give a couple of pieces of background 

information.

And this magic button doesn't work very well, this 

up button, the down button. How about left or 

right? Here we go, how's this? Press enough buttons 

and something works.

Just to tell you who the Work Group Members are: 

Brad Clawson, David Richardson and I'm serving as 
158

Chair. So, a small Work Group.

So here's what has gone on and you'll get more 

details in a moment, but activities relating to the 

laboratory.

There have been mass record requests. Records 

retrievals have been carried out by NIOSH. There's 

been interviews with some of the past workers, 

particularly the health physics group, radiation 

safety employees.

There's been extensive Site Profile reviews by the 

Board's contractor, SC&A. And we've had several 

Work Group meetings. I'll just enumerate them 

because there hasn't been a lot. Most of what's 

gone on has been retrieval of data and preparation 

of Site Profile-related documents.

Our first meeting was in 2012 as indicated on the 

slide, February 3. We met again in April of 2019 and 

again just a few weeks ago in November of 2019.

The Site Profile goes back to August 2006, at least 

what I'll call the initial Site Profile or Rev 0. But 

during the internal review of its own document, 

internal review by NIOSH they made changes. So 

Rev 1 came out very shortly thereafter in April of 

2007. There now is a Rev 2 which was issued in May 

of 2010. That really occurred because of the review 

that NIOSH was doing related to the initial SEC 

petition for this site. So in doing the -- gathering 

the information for the SEC review a number of 

changes were made in the Site Profile itself. So Rev 

2 is the one that's basically in effect now. And 

although SC&A began their review of the Site Profile 

prior to Rev 2 most of what we have today relates 

to Rev 2 issues.

I also put a note on this slide that NIOSH 

recommended an SEC for the lab for the period of 

August 13, 1942 to the December 31, 1961 era.

And that was approved by this Board in March of 

2010. So there is an SEC for those early years.
159

Currently there are 21 issues that have been 

identified by our contractor SC&A. By issues we're 

talking about -- that's a broad name for both 

findings and observations.

There are 13 findings and 8 observations. And in 

working through some of those findings, additional 

findings have arisen on specific issues. You'll learn 

of those in a few moments.

So let me now introduce Dr. Megan Lobaugh of 

NIOSH. She is going to give you a lot of information 

about the findings and where they stand as well as 

the observations.

Megan, we're pleased to have you do this. She's 

done a terrific job of putting together all that has 

happened before. So we're pleased to have her 

make the presentation. And I'm glad not to have to 

tell any more stories.

Dr. Lobaugh: Thank you, Dr. Ziemer. So before we 

get into the Site Profile issues, I'll talk a little bit 

about the site too just to give kind of a background 

on the type of work that they do.

So, just a quick overview of what I'm going to talk 

about. The site itself, then I'll go through a 

summary of the Site Profile issues and I'll talk more 

specifically about the issues that are in progress. So 

I won't touch on the ones that are currently closed.

Then I'll do an overview of what we've done 

recently, so that research and the interviews that 

we've done. And then I'll speak more specifically on 

kind of our most recent focus which is a White Paper 

that we issued in 2017 called the Method to Assess 

Internal Dose Using Gross Alpha, Beta and Gamma 

Bioassay and Air Sampling at Lawrence Berkeley 

National Lab.

And this document as Dr. Ziemer said, kind of came 

out of the review of the Site Profile. So it's kind of 

been one of those issues that came out of reviewing 

other issues.
160

So just first a little bit about the lab. It was founded 

by E.O. Lawrence in 1931 as the radiation lab. You'll 

see that the covered period really doesn't start till 

'42. That's because in '42 is when they actually 

received their contract with the AEC at the time. 

Well, really Manhattan Project before that. 

So the EEOICPA covered period really starts August 

13, 1942 and it goes through present because this 

lab is still currently working as some of us saw 

yesterday.

It's a multi-program science lab. So that means 

they do pretty much everything under the sun when 

it comes to basic research.

Some of the facilities are things that you may have 

heard of, are the 88-inch cyclotron. This is one of 

the big user facilities onsite.

There's also the advanced light source, the 

molecular foundry, biosciences, and then in 

particular one of the facilities we saw, the 

biomedical isotope facility. And kind of along the 

lines of what Dr. Ziemer was talking about in his 

story.

There is also the DOE Joint Genome Institute and 

then research, just other research on energy and 

environment.

I think this is a pretty cool site and a lot of us were 

impressed by the number of awards that the 

scientists have received. And in particular there's 13 

Nobel Prizes that have been awarded to scientists 

that have worked at Berkeley.

On the right-hand side here I have a map. I thought 

maybe it would be kind of helpful to point out like 

where we are in relation to it.

So the lab itself is up the hill from the city of 

Berkeley, from the campus of UC Berkeley. But then 

we're I think down here right by the airport. So I 

don't know if you can see my mouse or not. I 
161

probably can't make a pointer out of it.

But we're not far from it at all. It took us about 35 

minutes to get there the other day.

So more specifics on LBNL and Part B. So, as Dr. 

Ziemer said, there's been a Special Exposure Cohort 

Class that's been added and it's all employees from 

that start of the covered period, August 13, 1942 

through December 31, 1961. And the time period is 

based on two different infeasibilities. So external 

dose we have an infeasibility prior to 1948 and 

internal dose prior to 1962.

For just number of claims that we've had there's 

been 217 completed claims. Of those 43 had a PoC 

of greater than 50 percent and 174 had a PoC less 

than 50 percent. PoC being Probability of Causation.

There are currently -- or at the time I made this 

presentation there were currently 8 active dose 

reconstruction claims and 36 pooled. The pooled 

could be pooled by DOL for some reason or for the 

SEC.

So now I'm going to go into the Site Profile issues. 

As Dr. Ziemer said, there are 13 findings and 8 

observations that we were initially reviewing.

For the findings first, there are three that are 

currently closed, two that are considered addressed 

in finding. 

Addressed in finding is a status in the Board Review

System. That means the issue is completely covered 

by another issue.

So, basically what happens is our response to the 

other issue really is going to cover that finding. So 

I'll talk about those when I go through each of the 

in-progress findings and how they're related.

And there then are eight in-progress findings.

For the observations we have eight observations. 

Two of them are closed. Three are considered 
162

addressed in another finding, and three are 

currently in progress.

So next we'll talk about just those in-progress 

issues.

So Finding 1 has to do with inadequate 

documentation of historical operations and sources 

of radiological exposures.

So this is specific to facility information that we 

have in our Site Profile really asking for more 

information broken down by facility and by time 

period.

There's a related issue, so Observation 5 is 

addressed by Finding 1. And Observation 5 is 

entitled Lack of Information on Isotopes, Facilities 

and Handling Methods. So again just requesting 

additional facility information.

So the last thing I'm going to talk about with each 

of these findings is the action items. What's left to 

do or what's currently on the plate.

So for this one NIOSH needs to update the Site 

Profile with additional information that has been 

captured since the last revision of the TBD.

So we're in the process of still capturing 

information. So that's why this finding remains open 

or in progress.

Next is Finding 2 and it's on insufficient information 

for internal dose, especially during the early years.

So this was kind of a focus area of the SEC Class, 

but we found even after the Class was added for 

that prior-to-1962 time period that there really is 

still some more information that we need to talk 

about even post 1962.

So again it's focusing specifically on internal dose. 

And we have two related issues, or two issues that 

are addressed by this finding and that's Finding 4 

which is bioassay data, completeness and adequacy 
163

not verified, and Finding 11, inadequacy of bioassay 

analyses presentation. So just really about how 

we're talking about the bioassay analyses.

So for this again NIOSH has the action item and we 

currently need to respond to the SC&A February 

2014 memo with more specific references to where 

we have provided the information that they're 

requesting as well as how this internal dose 

methodology White Paper I mentioned before, how 

that will really affect the answers, or the questions 

that they're asking.

So, currently this is one of the findings that we're 

targeting in our most recent interviews and the data 

capture that will be upcoming. I'll talk more about 

that later.

Finding 5 is -- so you'll see I skipped a few findings 

there. We went from Finding 2 to Finding 5 because 

Finding 3 I believe is closed and Finding 4 was 

addressed in the other finding.

So Finding 5 is insufficient justification for selection 

of IREP energy range fractions for photon 

exposures. This is specific to external dose.

And again we have a related issue. So Observation 

8 is addressed by this finding. And Observation 8 is 

with regards to the overuse of generalizations and 

assumptions. And the specific area within 

Observation 8 that appears to be too general would 

be the IREP photon energy fractions. So that's why 

that is addressed by this finding.

So the action items that we have are to update 

Table 6-5 in the TBD for all years and all major 

accelerator operations. 

And again this is something we're targeting with our 

data capture and current interviews.

Finding 6 is insufficiency of neutron dosimetry 

treatment again focusing on external dose. And 

again the same related issue as prior. Observation 8 
164

is addressed by this finding. And the specific area 

would really be the neutron-to-gamma ratios.

You'll see that NIOSH has a lot of action items.

For this one we will revise the external dose 

discussion to direct the use of the neutron-tophoton ratios. 

So one of the questions that came up with this 

finding was we have a neutron-to-photon ratio, but 

we don't explicitly say to use it during certain time 

periods.

So really be a bit more explicit in the TBD about 

that.

And then one thing that we're currently really 

investigating is NTA correction factors for energy 

response, angular dependence and fading.

Again, something that we just need to clarify in the 

TBD is that the discussion around the low-energy 

NTA correction factors and uncertainties that are 

listed in Table 6-11.

Finding 7 is a failure to justify the shallow dose to 

deep dose assumption. Again focusing on external 

dose.

And here we have three related issues. So 

Observation 5 is a lack of information on isotopes, 

facilities and handling methods.

Here specifically what will be covered by this finding 

is the additional information specific to shallow and 

extremity doses.

Observation 6 focuses specifically on extremity 

dosimetry and the need to provide more information 

there.

And Observation 8 specifically will cover the shallow 

to deep dose ratios by this finding.

Here we have a long list of action items. We're 
165

planning to review the NOCTS claim data to 

determine if the claim data that we have supports 

the shallow to deep dose ratios and extremity dose 

ratios that are in the TBD.

We're going to compile a list of the pure beta 

emitters in use because the pure beta emitters 

would be ones that are affecting the shallow dose 

and would not have a deep dose component to 

actually make any estimate of the shallow dose 

from.

We're going to research whether there is area 

monitoring available for those pure beta emitters 

and determine if an unmonitored approach is 

needed for those pure beta emitters.

We also need to review the extremity dose ratio and 

provide some specific responses to SC&A on their 

comment of our choice of three times, where 

they're proposing five times.

Again, the interviews and data capture we're doing 

currently are really going to help us answer these 

questions.

Finding 8 is on uncertainty in beta gamma 

dosimeter response to radiation types and energies, 

again focusing on the external dose.

And our action items here are to update the 

external dose discussion in the Site Profile with 

specific direction regarding not using electroscope 

data. So one of the things that we discuss in the 

TBD is the use of electroscope data for the time 

period prior to 1948.

So just again clarifying that, after 1948, we 

wouldn't use this data because we have other 

dosimetry data available. We have film and other 

dosimetry data available for that time period. So 

electroscope data really isn't the most reliable and 

shouldn't be used when we have other data 

available.
166

We also need to review Attachment A of the Site 

Profile and provide a summary back to the Work 

Group and SC&A on what was specifically included 

to address this finding.

Finding 12 is a failure to provide sufficient guidance 

for unmonitored workers. And this is a little different 

than the other ones because we're focusing on 

internal dose.

It seemed like I was saying external dose a lot 

there.

So our action items here are really similar to what 

we talked about for Finding 2 in that we need to 

respond to the February 2014 memo from SC&A 

with specific information again on how we can 

answer their questions, or how we have answered 

their questions in our previous documentation, and 

how this most recent methodology that we've put 

forward would really affect those answers to those 

questions.

This is the last finding, Finding 13 was inadequate 

coverage of occupational environmental dose.

So, it focuses on environmental dose. And we need 

to provide or add information to the Site Profile 

about the cobalt-60 accelerator and flesh out really 

accelerator background data, or background 

exposures for people onsite, and change the 

guidance for radionuclide assignment for internal 

dose from beta contributors.

Now, stepping through the observations. 

Observation 3 is a lack of discussion of radiological 

incidents. 

Really what we need to do here is identify and 

provide information about any major radiological 

incidents that we know of at LBNL and incorporate 

those into the Site Profile.

I should say Observation 1 and 2 are closed. And 

we actually just closed them at the most recent 
167

Work Group meeting.

Observation 4 is the need to provide information on 

metallurgical lab. And it's really specific to 

dosimetry services.

So during a certain time period, the Met Lab 

provided dosimetry services for LBNL. So we're 

looking to provide more information in the Site 

Profile about what those services entailed and 

additional information about those services.

We kind of discussed in the Work Group that this is 

going to be hard because Met Lab is an SEC for the 

entire time period. So it's turned out to be difficult 

so far to find additional information, but we're still 

working on that.

Observation 7 is a lack of sufficient information for 

external dose evaluation. Again focusing on external 

dose.

Here we've committed to improving the discussion 

of the post 1947 external dosimetry program.

So this is really just kind of beefing up our section 

discussing the dosimeter information and the 

program in general. 

Now the fun stuff. So this is what we've been doing 

recently. As Dr. Ziemer said we've really been 

focusing on the research efforts and data captures 

and interviews.

So this is just a quick timeline. I won't go through 

everything on here. I'll just give you a bit of 

summary.

But starting over the summer we sent a data 

request to the site with lots of questions about -- in 

line with our -- I'll talk about it on the next slide, 

but in line with our current efforts for the inprogress findings and issues.

Shortly after that we requested interviews through 

the LBNL point of contact. And then in August we 
168

actually began reaching out to our list of potential 

interviewees.

Then in September we had two back to back 

interviews. Those are documented in SRDB with the 

rough IDs I give above, or give in the presentation.

So, the first interviewee actually provided us several 

additional names. We sent out requests for 

additional interviews and didn't hear back. 

So there is still potential that we could have 

additional interviews, but it's a little bit removed 

from when we made that request so we're not really 

waiting on that.

Then the site in November actually provided us with 

some selected technical documents that we 

requested. So they're numbered documents, or 

UCRL-numbered. So we actually were able to ask 

for some specific documents there and receive 

them.

And then in January we have a data capture 

scheduled for January 13, the week of January 13.

So what did we specifically request? Specific to the 

Site Profile issues we asked about whole body 

counter peak searches and calibration information.

And this covers Findings 2, 4, and 11 which are 

internal dose findings. 

We requested information on neutron and other 

radiation energy spectra for the cyclotron and 

accelerators. And this is helping us with Findings 1, 

5, 6, and 8.

We requested information on extremity dosimetry. 

This is helping us with Finding 7, Observations 5, 6, 

and 8.

Neutron exposures measured by NTA film. And this 

would be help for Finding 6 and Observation 8.

And then the last one we requested information on 
169

shallow and beta dose.

So we requested this information, but I should also 

say that we had questions that we ask the 

interviewees in line with all of these topics as well.

To kind of jump ahead a little bit. So the next topic 

that I was going to talk about after going through 

this is the internal dose methodology.

So in that data request we asked about the Site 

Profile issues that we were following up on, but also 

internal dose methodology issues that we were 

following up on.

So you'll learn more about these findings in the next 

section. But I wanted to point out that the internal 

dose methodology was really written in response to 

Site Profile Findings 2, 4, 11, and 12, and 

Observation 2. And those are the findings that are 

specific to internal dose.

So the information that we requested was really 

about their in-house detector systems. So some of 

the questions that we had from SC&A were about 

the energy response of the detectors and how we're 

converting from a count data from a detector to 

actual air concentration data.

So you'll see that the first two items that we 

requested are related to Finding 2 and that's 

because that was really about the efficiency and 

energy response of those detectors for gross alpha, 

gross beta, gross gamma bioassay and breathing 

zone alpha and beta, gamma in-house detector 

systems.

Then lastly we requested additional information to 

help us with Finding 1 which is about the 

representativeness of the air sampling.

So one part of this internal dose methodology has to 

do with air sampling that was done onsite. And so 

we were asking more questions -- or asking for 

more information on policies and procedures and 
170

practices including specific information on breathing 

zone samples.

So in the tour yesterday we actually saw some 

examples of their air sampling in picture form 

because we had to stand outside that lab. We saw 

some pictures of air sampling in use at LBNL now.

So, the last thing I wanted to talk about was more 

specifics on this internal dose methodology.

So, like I said this was a White Paper that we put 

out in 2017, I believe. And it was -- it's a method to 

help us assess dose from samples that are counted 

using a gross technique, meaning counting all of the 

alpha, or all the beta, or all the gamma from the 

bioassay, or all of the alpha, beta -- or all of the 

alpha or beta, gamma for air sampling.

So, SC&A reviewed our methodology and issued two 

findings and three observations.

Currently both findings are still in progress and the 

three observations, one is closed, one is in 

abeyance and one is in progress. And I'll actually go 

through all of these observations because this has 

kind of been the focus -- the biggest focus of our 

most recent work.

So finding 1 as I mentioned before is about the air 

samples may not represent concentrations breathed 

by the workers.

So, in October 2018 we provided our initial response 

to the Work Group. And this really focused on why 

NIOSH believes that, given current day standards 

for breathing zone samples and the LBNL policies 

and documentation that are available, why these 

samples that we used in the methodology we 

consider representative of the air concentration.

Then in April 2019 we had a Work Group meeting 

and we discussed the issue. And at that meeting 

additional information was requested such as air 

flow studies, pictures documenting placement of the 
171

air samplers and more information really relating to 

the implementation of these policies.

So this is one of the things that we were targeting 

in our interviews and data capture. So really we 

asked questions and made a request for additional 

information on the air sampling programs' policies 

and procedures as well as in the interviews asking 

questions about the implementation itself.

So Finding 2 is as I mentioned before has to do with 

the technical issues and uncertainties with the gross 

counting data conversion from basically counts to 

an air concentration which is then used for an intake 

calculation to use for internal dose reconstruction.

So in October 2018 we provided a response 

committing to research and review the detector 

technical information, basically the efficiency 

calibrations for the detectors to determine if for 

specific radionuclides we may be underestimating 

using these gross measurement methods.

Again we targeted interviews and data capture for 

this to ask for more specific information on in-house 

detector systems or for people we can talk to who 

maybe worked with the systems and could give us 

more information.

So again this is in progress and we hope to capture 

some information in January.

So now onto observations. Observation 1 is about 

potentially missed radionuclides.

So SC&A provided a list of several radionuclides that 

were not included in the initial methodology. So 

here I'll just go through our response for each of the 

radionuclides.

So one of the things they mentioned was 

radioiodines. And these were not included because 

they would not have been measured by these 

samples. They were actually measured by separate 

charcoal samples onsite.
172

During the Work Group meeting we were asked to 

provide additional information on the radioiodine 

sampling and if we see a need for providing a 

separate methodology for radioiodines for 

unmonitored workers.

So we have committed to provide a written 

response on that.

One of the other radionuclides was erbium-165. This 

was not included because it's below the short halflife cut-off that we used for this document.

Again this was something that was discussed in the 

most recent Work Group meeting and we've 

committed to provide a written response on this 

short half-life cut-off and what it's for, why we did 

it. We provided some information in the 

methodology so I think this document would just be 

to clarify that and provide the information again.

The next one is erbium-169. This was something 

that just got left off the list. So it will be added to 

the final DR methodology implementation.

The next one is fermium-237. And we believe that 

this is a typo in the SC&A methodology review. And 

we think that the intent was likely fermium-257 

which is in the Site Profile but not included in our 

methodology.

So fermium-257 will be added to the final DR 

methodology implementation.

LBNL is kind of an interesting site because they're 

one of the sites that actually creates new 

radionuclides. 

So some of our discussions in the past were well, 

how do we know for sure it's a typo and not a 

radionuclide none of us have heard of, right.

So it took some research to kind of pull the string a 

little bit on this one and another one of the 

radionuclides.
173

So the next one is rhodium-102. And again this was 

inadvertently left out and will be added to the final 

implementation.

Scandium-93 is one of those interesting ones where 

we believe it was a typo. And we actually found 

where the typo came from. We believe it's a typo in 

the site environmental reports.

So we're still confirming with the site themselves to 

make sure that, again, this isn't something that we 

just don't know about.

But we definitely were able to track it back to how it 

got into our TBD through the site environmental 

reports. So we'll be reporting back on that one.

So this is observation that remains in progress.

Observation 2 and 3 are very closely related 

because they both have to do with information that 

is in the claimant DOE files.

So Observation 2 is specific to the bioassays in 

claimant DOE files that may not be indicative of 

exposure potential.

So what happened was in the methodology we said 

that bioassay would be an indicator of exposure 

potential. 

And what was found when SC&A did a review of the 

DOE files was that sometimes it was marked that 

there would be bioassay, that the person was 

bioassayed on the form that they complete for 

NIOSH.

So it's yes, I've included internal dosimetry 

monitoring, external monitoring. So sometimes it 

was seen that this form was completed as there was 

internal dosimetry monitoring, but then it wasn't 

provided.

I'm going to take a step back. So what happened 

was that was one way that maybe they saw that it 

was inconsistent for the site that the DOE files may 
174

not have bioassay data in it.

Well, what happened was SC&A reviewed all claims 

prior to 2010 and in 2010 actually NIOSH began 

receiving the entire medical file.

And what we found was that the medical file could 

have had copies of the bioassay data that weren't 

transferred over to dosimetry which was providing 

the dose records.

So in 2010 we actually started receiving the entire 

medical file for another reason, for actually X-ray 

information for the occupational medical X-ray dose.

So we received it for a completely different reason, 

but basically we found that some of this bioassay 

information was also in there.

So with this observation we actually made a mass 

re-request of the site to receive the complete 

medical file for all claims that we received prior to 

2010, because like I said since 2010 we've received 

it.

So this totaled 168 claims that we received prior to 

2010 that were not compensated in an SEC or 

compensated under the dose reconstruction 

process.

So of these 168 claims, 53 of them had no medical 

records. These were likely visitors to the site 

because we made a broad request. It was anybody 

who had LBNL listed. So they could have been 

visitors to the site who would likely not have 

medical records.

There was one claim we inadvertently submitted 

that actually had a PoC over 50 percent. So that 

one didn't require any additional review.

Of those remaining claims, 109 of them had no new 

bioassay information. So everything had already 

been provided via the DOE request. 

There were three claims with new bioassay 
175

information from DOE itself, but we actually had 

access to it from other documents.

And then there were two claims with new bioassay 

information. 

So because this observation was really specific to 

our ability to ascribe exposure potential to a 

claimant, I wanted to take the next step and review 

really those five claims that had new bioassay 

information and see how maybe our decision of the 

application of this methodology could or potentially 

would have changed.

So for two of the claims that the bioassay results 

were not available at the time of the DR at all, so 

there were no bioassay results, there were new 

bioassay results provided during the re-request. So 

this is the first row.

So what was the effect as far as the application of 

the internal dose methodology. It was a definite 

yes.

For a strict -- so I should say this. A strict 

application of that exposure potential. So if the only 

thing we were thinking about was, are bioassay 

results in the DOE record or in the DOE request that 

we received back, is that the only thing we're 

thinking about in terms of exposure potential which 

I'll talk a little bit later that's not really what we did 

in our example that we provided the methodology.

So in a strict review of it, yes, those two claims 

would have been affected.

For the next two claims they actually had bioassay 

results available at the time of the DR. So the 

internal dose methodology would have been applied 

at the time of the DR.

There were new bioassay results available after the 

mass re-request. So again the potential effect is yes 

because it could have extended the time that the 

application of the internal dose methodology was 
176

applied.

Again, it's potential here because the DR-ist could 

have made the decision that because they had 

bioassay data they had an exposure potential their 

entire employment and not just the time of the 

bioassay results.

For the last claim there were bioassay results at the 

time of the DR. There was actually no new results 

provided, only additional details for the results that 

we already had.

So this would have had no effect on the application 

of the methodology.

So in the end we had four claims that potentially 

could have been affected by a strict review of claim 

information for exposure potential.

So my note here at the top is kind of along the lines 

of that potential. Again, because the unmonitored 

approach that we provided in the methodology 

which uses the air sampling results doesn't 

necessarily rely on the existence of bioassay data.

So the DR-ist could make the decision to assign the 

unmonitored approach even if the bioassay results 

weren't in the file.

So like I said before, 4 of the 168 claims or 2.4 

percent could have been potentially affected by the 

existence of the bioassay data.

This observation was placed in abeyance by the 

Work Group at our teleconference on the 25th.

And what we're awaiting is a NIOSH update to the 

methodology to include more clear and explicit 

guidance on the application. 

Because like I said, even though we said that there 

had to be bioassay data in the files, in our example 

we actually did not require the use of -- we did not 

require bioassay samples in order to apply the 

method.
177

We would -- what we will include is like what we 

actually do in practice is review CATI information, 

other claim information and job title along with the 

existence of bioassay data to really determine the 

exposure potential.

Like I said before, Observation 3 is also related to 

that information in the DOE claim files and is the 

same but really only focuses on the fact that the 

files may not be complete.

Again, SC&A reviewed claims that we received prior 

to 2010 and as I said before in 2010 we began 

receiving the entire medical file.

So we made this mass re-request not only for 

Observation 2 but for Observation 3.

But here we look at a different subset of claims 

when we really think about this. In the end there 

were really only just those two claims with new 

bioassay information that we did not have before. 

So only 1.2 percent of the claims really had any 

information that we didn't know about.

So this observation was closed by the Work Group 

at the November 25 teleconference. And I think 

that's it. I hope I didn't speak too fast.

Mr. Katz: Great. Thank you, Megan. Do I have 

questions? Jim.

Member Lockey: Thanks for your presentation. How 

representative were those two claims in relationship 

to their results when compared to the other data 

that you had available?

Dr. Lobaugh: What do you mean as far as --

Member Lockey: When they retrieved the bioassay 

data how did it compare to what was retrieved 

previously for other claims? Was it in the same 

ballpark?

Dr. Lobaugh: As far as the order -- like the 

magnitude of the results? 
178

So I didn't mention this, but actually all of these 

results, the PoC remained under 50 percent. I don't 

remember the exact magnitude of those bioassay 

results, but basically what that means is the new 

information didn't change the end outcome of the 

claim as far as the compensation decision goes.

Mr. Katz: Questions from other Board Members? 

David.

Member Kotelchuck: Back in Finding 7, slide 11.

Mr. Katz: Dave, you'll have to speak into a mike.

Member Kotelchuck: Of course I should.

Mr. Katz: Thanks.

Member Kotelchuck: Sorry. Finding 7, slide 11. 

There was just one down near the bottom, NIOSH 

review extremity dose ratio and provide specific 

response to SC&A comment of three versus five 

times. Three versus five times, what?

Dr. Lobaugh: So this is specific to the ratio of 

extremity dose to whole body dose ratios.

And so the three times is what we propose in the --

or what we have in the TBD, and the five times is 

actually based on from what I remember SC&A said 

was actual regulations, or you know, what's allowed 

dose to the extremity versus whole body.

Member Kotelchuck: Okay, good. Thank you.

Dr. Lobaugh: You're welcome.

Mr. Katz: Other questions. Board Members on the 

line, any questions for Megan?

Member Clawson: No.

Member Kotelchuck: If I may.

Mr. Katz: Yes, of course.

Member Kotelchuck: One more comment. That was 
179

a very nice clear report. Thank you.

Dr. Lobaugh: You're welcome.

Mr. Katz: Yes, I agree, I agree.

Dr. Lobaugh: Thank you.

Member Beach: One of the best I've seen for a 

while.

Mr. Katz: Oh wow. That's good. We need a 

competitive spirit among the NIOSH staff about 

these presentations. Brad? Okay, then. That 

concludes the session.

And I can see from the room that we don't have any 

folks from the lab here in the room. 

But let me just check because I know people don't 

get in their car around here. Traffic is difficult 

especially at this hour. And check on the line and 

see if we have any folks from the lab on the phone.

Because if we do we'd want to hear from them first. 

Okay, not hearing from them I don't have the signup sheet for people who want to comment but I 

only notice one person who might have comments 

for the Board in the room.

I'm sure she did sign, I'm sure she did. I just don't 

have the sheet. But I don't need it either.

So you're welcome to come. I think now would be 

good for you and then we'll go to any other folks on 

the phone related to any sites whatsoever.

So let's hear first from D'Lanie Blaze who is the 

petitioner for Santa Susana sites.

Ms. Blaze: And De Soto.

Mr. Katz: Right. Yes. I throw those together. I 

shouldn't.

Ms. Blaze: Well, we have to refer to them as 

separate sites, right?
180

Mr. Katz: Absolutely, absolutely.

Ms. Blaze: For the time being anyway. As the 

petitioner for SECs 235 and 246, Santa Susana and 

De Soto facility we submitted some additional 

information at the Oak Ridge Work Group meeting 

in August. So I have some brief observations on 

SC&A's recent evaluation of that information and an 

update for the Advisory Board.

We've been talking about the presence of 

americium, thorium and associated progeny at 

Santa Susana and De Soto outside of the current 

SEC periods at both work sites.

And we have also acknowledged, NIOSH has 

confirmed, that we cannot track worker movement 

between work areas or even between the work sites 

themselves, and that we cannot tell which work site 

a worker was at while monitored or exposed to 

radiation.

This alone has been accepted as a standalone 

reason to accept an SEC at other work sites.

Recently we also discussed the inadequate 

monitoring of site remediation workers after 1988. 

That was something that was addressed by SC&A in 

the recent review of information.

In its review, SC&A mentioned the Boeing 

Company's efforts to be exempted from the DOELAP 

requirements to monitor workers.

SC&A briefly mentioned a loophole the Department 

of Energy gave to the contractor. But SC&A did not 

describe what the loophole was or why it might be 

important to dose reconstruction.

The loophole relieved Boeing from its responsibility 

to monitor employees. And it has two important 

parts that I hope the Advisory Board will consider. 

First, workers who are administratively affiliated 

with a non-radiological location do not have to be 

monitored. That means that employees who are 
181

assigned time clocks outside Area 4 are not required 

to be monitored.

And we already know that workers routinely went 

into Area 4 to do work for DOE after clocking in in 

Areas 1, 2 or 3.

What the Board should also know is that site 

remediation subcontractors operate their dispatch 

locations, their administrative locations, out of Area 

2.

So site remediation subcontract employees are not 

administratively affiliated with Area 4. They are not 

readily considered to be radiation workers based on 

that alone.

The second part of the loophole has to do with the 

job title. Any employee with a job title that is 

inconsistent with radiation work does not have to be 

monitored for radiation exposure.

This would help to explain why we routinely see 

workers like propulsion mechanics administratively 

affiliated with Areas 1, 2, or 3 just by virtue of their 

time clock location, and their employment records 

when we were actually able to get them from 

Boeing show that they participated in site 

remediation work even the D&D of Area 4 nuclear 

facilities with no radiation monitoring badge, no 

radiation data.

This common scenario calls into question the 

adequacy of the worker monitoring program and it 

is also considered to be a reason to accept an SEC.

There's strong and compelling indications that 

workers who should have been monitored for 

radiation simply were not monitored.

Current site remediation subcontractors require that 

Area 4 waste be surveyed for radioactivity. But the 

employees who are tasked with the related job 

duties are not monitored for radiation exposure 

because they either have a different job title or 
182

they're administratively affiliated with a dispatch 

location in Area 2.

So while the waste is essentially monitored, the 

workers are not. And I ask that the Board take this 

into consideration when weighing the need for an 

SEC because I do not believe that we can count on 

the reliability or the adequacy of the monitoring 

program or existing worker radiation records.

Now on the americium, thorium issue and the 

possibility that TRUMP-S operations occurred at 

Santa Susana I do not believe we can rule it out 

quite yet.

SC&A referenced the technical progress report that 

was issued by Boeing in 1998, but they left out the 

part of the report where Boeing specifies 

Rocketdyne's involvement in step 6 of the process 

which is the separation of the actinides that include 

americium. I think we need some more information.

While NIOSH and SC&A have essentially advised the 

Advisory Board that there is nothing of real 

significance in the documentation that we have 

submitted, they have yet to fully explain their own 

documentation that confirms the presence of 

americium, thorium and associated progeny at both 

work sites until 1999.

The site description confirms that americium and 

thorium existed in stack emissions data and 

presented an inhalation risk for workers.

That information can be found in the site description 

on page 9, Table 4.1 and page 12, Table 4.3.

Now if these isotopes were not used in an 

operational capacity, what are they doing in stack 

emissions data?

SC&A also identified americium contamination in a 

drain line at the De Soto facility, further suggesting 

an operational use of americium at that work site.
183

Lastly, we have discussed 1,463 boxes of records 

that are located at the DOE EMCBC. SC&A indicated 

that these boxes were made available to them and 

to NIOSH, but they did not provide much detail 

about what was found.

The Board meanwhile has patiently given us more 

time to obtain additional information pending the 

fulfillment of an outstanding Freedom of Information 

Act or FOIA request. 

So, I want the Board to know that this FOIA was 

based on Boeing's inventory detail of what's in the 

1,463 boxes. According to Boeing several of those 

boxes contain documentation of DOE transuranic 

operations at Santa Susana to 2011. According to 

DOE the reason we don't have our FOIA request yet 

is because the responsive documents are, quote, so 

voluminous.

In closing, when NIOSH acknowledged that it 

cannot conduct dose reconstruction with sufficient 

accuracy for americium and thorium, NIOSH did not 

hinge its assertion on whether these isotopes were 

present in large or small amounts, or whether a 

worker could expect to encounter these isotopes.

Whether an employee encounters americium or 

thorium during fuel fabrication or site remediation, 

the fact remains that a DOE contractor employee 

has encountered an isotope that NIOSH has 

acknowledged cannot be dose-reconstructed with 

sufficient accuracy.

Further we have no way to tell whether a worker 

who encounters these isotopes is administratively 

affiliated with Santa Susana or with De Soto facility. 

Using the radiation data we can't tell which site they 

were at and we cannot track their movements 

between the work sites, or between work areas at 

Santa Susana.

The site description verifies americium and thorium 

present until 1999. That should be enough. But the 

current update on the worker records issue which 
184

we were discussing earlier today is we're now 

seeing with more frequency that the DOE and 

Boeing cannot verify employment for Santa Susana 

workers.

We used to get very detailed records and 

employment verification. Now we're routinely seeing 

just no records exist.

A lot of these workers with no records exist as their 

response are able to provide documentation 

addressed to them from Boeing that identify them 

as retirees, confirming their hire date and their 

retire date.

It is highly unlikely that Boeing could not provide 

simple employment verification for these guys. 

They're getting retirement benefits.

They're also able to provide copies of their work 

badges, very detailed EE-4 coworker affidavits, 

company-issued photographs. We have clear 

indications that there's obstruction and we cannot 

obtain complete or cohesive employment data.

This is a reason to consider an expansive SEC for 

DOE contractor personnel at Santa Susana on the 

basis that we cannot rule out Area 4 employment 

for anyone.

Thank you for your continued efforts on these SEC 

petitions. As always, it's a privilege to represent the 

workers and to address the Board. Thank you.

Mr. Katz: Thank you, D'Lanie.

Ms. Blaze: Do you guys have any questions for me 

at all? Thank you.

Mr. Katz: Thank you. Wait, we do.

Member Kotelchuck: I do have one question. You 

asserted that the GE contract had no requirements 

for monitoring outside of Area 4. Have you provided 

-- do you have documentation for it and have you 

provided it to the staff at NIOSH?
185

Ms. Blaze: I don't have documentation of it. 

However, it's understood that Department of Energy 

operated in Area 4 and that radioactive operations 

were confined to Area 4.

So typically no one in Areas 1, 2, and 3 would be 

expected to be issued a badge unless they entered 

Area 4.

However, the loophole document that I was talking 

about, there are several letters from Department of 

Energy to Boeing. SC&A has them. It's the 1200 

page FOIA request that I submitted to you guys 

wherein DOE states if a worker is administratively 

affiliated elsewhere they don't have to be monitored 

for radiation.

Member Kotelchuck: Okay. SC&A has them.

Ms. Blaze: Yes. Sorry, yes.

Public Comment

Mr. Katz: Thank you. Thank you, D'Lanie. Okay. On 

the phone, do we have any folks from any site or no 

site at all who have public comments for the Board?

Going once. Okay, then. That sounds like that's it. 

D'Lanie, this is unique. I think we've only had one --

this is the only Board meeting where we've only had 

one public commenter, but you're most welcome.

And with that, with no further ado, we are 

adjourned. Thank you, everybody, for a good 

meeting.

Adjourn

(Whereupon, the above-entitled matter went off the 

record at 6:03 p.m.)