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has been reviewed for concerns under the Privacy Act (5 U.S.C. § 552a) and personally identifiable 

information has been redacted as necessary. The transcript, however, has not been reviewed and 

certified by the Chair of the Santa Susana Work Group for accuracy at this time. The reader should 

be cautioned that this transcript is for information only and is subject to change. 

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

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

US Department of Health and Human Services

Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

Santa Susana Field Laboratory Work Group

Monday, December 3, 2018

The Work Group met telephonically at 10:30 a.m. 

Eastern Time, Phillip Schofield, Chair, presiding.
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2 

Members Present: 

Phillip Schofield, Chair

Henry Anderson, Member

Josie Beach, Member

Bill Field, Member

Also Present: 

Ted Katz, Designated Federal Official

Nancy Adams, NIOSH Contractor

Bob Barton, SC&A

Terrie Barrie

D'lanie Blaze

Rose Gogliotti, SC&A

Milton Gorden, SC&A

Monica Harrison-Maples, ORAU Team

Lara Hughes, DCAS

Jim Neton, DCAS 

Dennis Strenge, ORAU Team
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be cautioned that this transcript is for information only and is subject to change. 

3 

Contents

US Department of Health and Human Services 

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Santa Susana Field 

Laboratory Work Group Monday, December 3, 2018

1

Welcome and Roll Call 4

Area IV SSFL SEC petition 5

DCAS White Papers & SC&A review 5

Petitioner Questions/Comments 42

ABRWH December meeting plans/other 

follow-up 45

De Soto Avenue SEC petition 48

SC&A review of DCAS De Soto 

Evaluation Report 48

Petitioner Questions/comments 71

ABRWH December meeting plans/other 

follow-up 72

Adjourn 75
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4

Proceedings

(10:32 a.m.)

Welcome and Roll Call

Mr. Katz: Welcome, everyone. It's the Advisory Board 

on Radiation and Worker Health, the Santa Susana 

Work Group teleconference. And this Work Group is 

addressing both, two petitions, both for Area IV 

Santa Susana first and also for De Soto Avenue, two 

separate petitions so I'll get to those, I think, in that 

order.

The materials that are available for the public and 

petitioner and others are posted on the NIOSH 

website, for one. They should have been sent to the 

petitioner as well. Under missed programs section of 

the website, schedule of the meetings, today's date 

filled in, you can find those in the agenda, which is 

pretty much what I just told you with a little more 

detail.

There is an SC&A report that just was at the last 

minute cleared by DOE, so that is not on the website 

yet but it will get posted as soon as it can. It will also 

be sent to the petitioner as soon as we can get that 

out to the petitioner. And there's a presentation 

based on that. That presentation is also not on the 

website yet but we'll get it on the website. The Work 

Group Members had it and I sent it to the petitioner. 

I'll check in with her when I get to her on the roll call. 

Make sure that she got it, I sent it to her right after 

it was cleared. 

Let's get on with the roll call. We're talking about a 

specific site, so please speak to conflict of interest, it 

doesn't apply with respect to the Board Members 

because they all are, sort of by definition they don't 

have conflicts of interest to be on this Work Group. 

The Work Group is chaired by Phil Schofield, who's 
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5

present, and the Members of the Work Group are 

Henry Anderson and Josie Beach and Bill Field and 

again, they have no conflicts of interest. They're all 

present, so we have the full Work Group on the line. 

(Roll call.)

Mr. Katz: I want to just remind everyone to please 

keep your phones on mute except when you're 

speaking and press *6 if you don't have a mute 

button to put your phone on mute. *6 to come off of 

mute, and please don't put the call on hold. And with 

that, so, it's your meeting.

Chair Schofield: Good morning, everybody. I guess 

we'll just start off with DCAS and their White Paper, 

their Air Data Summary paper they issued.

I don't think that's been cleared yet, has it?

Mr. Katz: Yeah, that's public, that's on the website.

Chair Schofield: Okay.

Mr. Katz: So that's Lara.

Area IV SSFL SEC petition

DCAS White Papers & SC&A review

Dr. Hughes: Yes, hi, good morning everybody. I do 

have a presentation and it's up under the 

presentation link of this meeting. Unfortunately, this 

presentation has not been finalized on the NIOSH 

website, it's still undergoing final accessibility review. 

It's the same presentation I will present next week at 

the Board meeting. 

If you don't have it, I don't think it's a big deal. I'm 

just going to go over the content of the two White 

Papers that we recently sent to the Santa Susana 

Work Group, and all this information will be 
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6

presented again next week. 

This is regarding Area IV of the Santa Susana field 

lab. This is a site in Ventura County, California. You 

all are pretty familiar with it, I suppose, at this point. 

The DOE-covered period for Area IV is 1955 through 

1988, and there's a remediation period from 1989 to 

the present.

There are several existing SEC classes for Area IV 

that have been added to the SEC. Three of those 

encompass the entire operational period, so the 

entire operational period from 1955 through 1988 are 

SEC classes at this point. The latest SEC-234 was 

added to the SEC based on insufficient data to assess 

intakes from thorium and americium radionuclides.

There was SEC-235 that was evaluated last year. This 

qualified for evaluation from August 1, 1991 to June 

30, 1993, based on the issue with the bioassay 

contractor, Controls for Environmental Pollution. This 

NIOSH evaluation, SEC evaluation, was presented to 

the Board in August, 2017, and no class was 

recommended. 

This was followed up by a more detailed discussion 

off this evaluation with the Area IV Work Group on 

December 4, 2017. From that meeting, the Work 

Group requested that some additional work to be 

done on NIOSH on two specific issues. 

One was the, what was the status of thorium and 

americium operations in the post-1988 period in light 

of SEC-234, which we added the cost based on those 

two radionuclides, and also to shore up the CEP 

period, as we call it, this period where we don't use 

bioassay by looking at what the available air sample 

data during that period looked like.

NIOSH issued two White Papers on November 1, 

2018, so about a month ago, and they have finally 
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7

been cleared and they are available on the NIOSH 

website. Unfortunately, a redacted version, but I 

think that the Work Group has received the full 

unredacted version. We had to take a lot of personal 

identifiable information out.

Let's look at the remediation period for Area IV. What 

was the status of the site after 1988? There were 

three facilities that were from a radionuclide 

exposure standpoint the major players, and that was 

the hot lab, Building 20, the radioactive material 

handling or disposal facility, which was an active 

facility, and the SNAP reactor facility.

The hot lab and the SNAP reactor facility were two, 

one was a formal reactor facility, the hot lab was a 

hot cell facility, just being dismantled. The main 

radionuclides of concern during this D&D period were 

fission products, mostly cesium-137 and strontium90. The hot lab had to deal with the residual alpha 

activity in the form of plutonium-239.

In the SNAP reactor facility the major issue was 

activation product, cobalt-60. This was based on the 

nature of the operation of these facilities, not the only 

radionuclides present, obviously, but the main 

drivers of the radioactive protection, the health 

physics protection program.

We looked at the status of the operations for thorium 

and americium after 1988. All reactor facilities had 

ceased operation and reactor operations ended by 

1980, so several years before. The nuclear support 

operations ended by 1988. 

Pre-1988 during the operational period, the thorium 

source term consisted of reactor fuel components, 

thorium was a component of the reactor fuel of the 

SRE and the AETR reactors and there was also a 

thorium exposure potential based on the nuclear 
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8

support operations of the fuel assembly and the fuel 

handling and storage or disassembly after it was 

taken out of the reactor.

The americium source term pre-1988 consisted of the 

transuranic in all of the used reactor fuel and the 

several fuel sources that were present at the site. I'd 

like to add that the issue with the americium source 

term during the operational period is not so much the 

quantity, that was a huge quantity, it's more so that 

we can't quantify the source term. 

We looked into some detail of the thorium operations, 

where they were done, and what was the status of 

those facilities during the remediation period. The 

thorium fuel for the SRE was present in what they 

called Core II, they had three different cores for this 

reactor, I think the last one was not being used but 

this core was in operation from 1960 to 1964 and 

consisted of thorium-232 and enriched uranium alloy.

This core fuel was assembled in the engineering test 

building. The Core II fuel was stored in the 

radioactive material handling facility or disposal 

facility after it was removed from the reactor in 1964. 

Starting in 1974, ten years later, this Core II fuel was 

disassembled in the hot lab and it was shipped offsite 

in 1977 with pretty detailed reports on this, where 

the fuel came from, where it went. The engineering 

test building, the building where the fuel was 

assembled, was released for unrestricted use in 

1985.

Then the other reactor, the TR -- AETR, the Advanced 

Epithermal Thorium Reactor operated from 1960 to 

1974. This also had thorium-containing fuel. The fuel 

was fabricated at the reactor building in 1959 and 

this building was released for unrestricted use in 

1980.
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9

We looked through the incident database and other 

records that are available to NIOSH and we found no 

incidents involving thorium listed in the remediation 

period. 

For americium, again, all reactor fuel was removed 

from the site by 1988. The Transuranic Management 

by Pyropartitioning - Separation Program used

americium and other isotopes. This was a program 

that was supposed to be done but it never got off the 

ground. At least that's what the records indicate. 

There are some americium materials that were 

received at Area IV and were kept in storage and 

were later shipped offsite without being actually 

handled or used. Any incidents that are listed 

mention americium use only before 1988 and the 

only two facilities were some residual contamination 

from americium or the transuranics is possible is the 

hot lab and the radioactive material handling facility. 

We reviewed the records of, the decommissioning 

records and quarterly review reports on those two 

facilities during the remediation period and they do 

not indicate any evidence that americium or thorium 

were encountered at these facilities or that they were 

in any way were the drivers of the radiation safety 

program. 

In conclusion on the thorium/americium status, the 

major source term for americium/thorium first terms 

for americium/ thorium had been removed from the 

site by 1988, which is the nuclear reactor fuel. A 

detailed review of facilities during the remediation 

period does not indicate a sustained radiation 

exposure similar to the operational period. 

The D&D operations could produce unpredictable 

exposures but the site had an internal exposure 

monitoring program that was driven by air sampling 
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10

and NIOSH does not find that the exposure potential 

from the operational period continued into the 

remediation period. 

This was the White Paper I that was sent to the Work 

Group. I do not have my presentation broken up in 

two separate ones. If you have any questions, if you 

want me to stop and discuss White Paper I right now, 

or I can continue with the presentation, with the air 

data, and then we do questions and discussion 

afterwards. Which one do you prefer?

Mr. Gorden: This is Milton Gorden from SC&A. I think 

we're good to go paper by paper if that's okay.

Dr. Hughes: That's fine.

Member Beach: I agree. I was going to say that too.

Dr. Hughes: Okay.

Mr. Barton: This is Bob. As I said, we don't have an 

official review on these White Papers yet but we have 

been going through them. Milton Gorden's on the line 

and he's really taken a lead on them and looked at 

some of the underlying documentation and we 

certainly have some questions, clarifying questions 

really about what NIOSH's intended approach is 

based on these White Papers, so I'll turn it over to 

Milton.

Mr. Gorden: Okay. I guess my first question would be 

about the SNAP reactor, if it was undergoing D&D. 

But the paper didn't really address that at all. Is that 

because of what source term there was is related 

more to activation products that you found, or do you 

have any other reasons why you didn't address 

SNAP, really?

Dr. Hughes: The SNAP reactor did not have thorium 

fuel. We mostly, this was mostly focusing on the 
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11

thorium and americium.

(Simultaneous speaking.) 

Dr. Hughes: The SNAP reactor facility was 

undergoing D&D, yes, but it was, you know, this was 

the building, the activated concrete and steel 

structure. There was no, the reactor itself was not 

there anymore. It was just the building that was 

undergoing D&D. I guess I didn't make that clear. I'm 

sorry.

Mr. Gorden: That's okay. They did do a lot of 

surveying. I was looking at one of your references, 

had all kinds of surveys from that period and then '91 

paper I was looking at. They did have, what localized 

they, in case you want to give them a pass, high 

alpha contamination they had removed. Mostly, I 

guess, from the hot pads but do you come across 

anything at all that would, I guess, characterize the 

alpha contamination? I know occasionally they would 

say, Pu-239 and strontium-90 in a couple of places 

but ---

(Simultaneous speaking.) 

Dr. Hughes: Right. They did smear surveys as well as 

they did stacks, well, it's mostly the hot lab but the 

general survey was based on, they did the gross 

alpha, gross beta and then they use the limit of what 

they call the radionuclide of concern, which they used 

plutonium-239 just because it's, I think it's the most 

limiting radionuclide. Generally their survey 

information is presented in gross measurements and 

then is compared to what they're using after limit to 

compare it to to see if any kind of action is required. 

I think with, this is mostly with regard to the air data, 

if they saw an elevated, if they saw a sample that 

was, I think, within 25 percent or 25 percent of the 

limit, they would do a special analysis for 
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12

radionuclides, for specific radionuclides. I mean, we 

have not seen any indication that they saw thorium 

or americium during that time.

Mr. Gorden: Okay. In regards to the incident reports 

you looked at, can you tell us where they are, I guess 

on the CDC drive? We were having trouble finding 

them.

Dr. Hughes: They're on the site research database. 

Do you have access to that?

Mr. Barton: This is Bob. I actually, yeah, I think it's 

page 5 of the White Paper, it says, "There are no 

listings of incidents involving thorium or americium 

during the post-1988 period, but not all incidents list 

the nuclide of concern," and then there are three 

references provided.

We could find the last two, I guess, cited as Incidents 

1980 and Incidents 1990. We went through that. It's 

something like 500 pages of documentation but we 

only saw about 33 incidents that were actually 

related to this post-1988 period, and only two 

instances actually mentioned the contamination or 

even survey results for alpha. 

One was a wound incident involving a plutonium 

glovebox and the other one was sort of, the infamous 

lost TRUMP-S material which wasn't really lost, but I 

think we'll get into that a little bit with the DeSoto 

discussion. Everything else was basically incidents 

related to beta gamma they found with a GM probe 

or some other external radiation monitoring device. 

Now the third reference, which is cited as SSFL 2007, 

when we went to the SRDB for that, it said that that 

information cannot be indexed but can be found at a 

location on the internal CDC O drive. However, we 

couldn't follow that link to really find where that, I 

guess, incident database was actually located. In 
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13

other words, the address given in the SRDB 

document, we couldn't really see that. 

Mr. Katz: Bob?

Mr. Barton: Yes?

Mr. Katz: This is Ted. For items like this, where you're 

just trying to track down where's the reference, I 

think you can just shoot Lara an email and that would 

be much more efficient than anything else. That's 

just a mechanical issue of getting you to references 

that you can't find or whatever.

Mr. Barton: Sure. I understand.

Dr. Hughes: Yes, because ---

Mr. Barton: What I really wanted to point out was 

that we say that, or at least one thing that would 

concern me, is we're saying that there are no 

incidents involving thorium or americium but in 

looking through the incidents that we have in front of 

us, there are basically, they found external 

contamination and they cleaned it up, and they didn't 

really talk about what the contamination was except 

for those two incidents I just discussed. One was a 

puncture wound in a glove box and one was the 

TRUMP-S material that arrived and was briefly 

unaccounted for.

So I, you know, when we say that there's no evidence 

that the thorium or americium is there, that's true 

but I would also point out that there's not a whole lot 

of information about what the alpha contamination 

was. I think that's something that Milton was trying 

to point out as well, and there are incidences of alpha 

contamination. 

We can say that the driver's really the plutonium, but 

I'm not sure, well, at least from our side, if we're 
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14

comfortable saying that the americium and thorium 

source term was simply not there anymore. I mean, 

it was there in 1988, that's why there was an SEC 

there for americium and thorium, and then they 

started carrying out all this equipment that, you 

know, what about all that contaminated equipment? 

We have evidence of alpha contamination but they 

don't necessarily identify what it is, so it's at least 

difficult from my view to say that it couldn't be 

americium or thorium. That kind of leads me to what 

my main question is, in the conclusion of this White 

Paper, is it NIOSH's intention that we're not going to 

be assigning any sort of dose to these potential 

contaminants, or are we saying that after 1988 if it's 

there it certainly doesn't rise to the level that 

warranted the SEC in the first place up to 1988?

In other words, is there a plan for a dose 

reconstruction approach in the future, or are we 

saying that that source term simply didn't exist 

anymore and therefore it doesn't have to be 

accounted for?

Dr. Hughes: Well, we do have a dose reconstruction 

approach and we're not planning on developing a new 

one in the sense that the remediation period is not 

currently an SEC because we found no infeasibility so 

we will continue to do dose reconstruction for this 

period based on available, largely bioassay data.

Mr. Barton: Specific to thorium and americium, 

though? Or ---

Dr. Hughes: Typically we assign, I don't know, dose 

reconstruction, it will assign, any internal dose 

reconstruction we usually assign based on a limiting 

radionuclide, whichever was most claimantfavorable, and I don't think that's currently 

americium. I don't know, we have our, we have some 
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15

support staff that's more familiar with dose 

reconstruction. Dennis, if you're on the line, could 

you weigh in on what, do we typically use thorium or 

americium?

Mr. Strenge: Well, when we do the dose 

reconstructions we usually go with the bioassay data 

that we have but of course for some, up to '88 we 

have the internal dose reconstruction coworker study 

that we would apply also. The exposures after 1988 

are typically very small and we don't usually have 

very much bioassay data.

Member Beach: And this is Josie. Bob's correct, 

though, that one line in your conclusion says that the 

facilities were undergoing D&D and the exposures 

were unpredictable. If you weren't looking for it or if 

they weren't looking for it, certainly you wouldn't see 

it. So you have to account for that thorium and 

americium somehow.

Dr. Hughes: Well, based on our review of the air data, 

they were only, they were surveying with gross 

measurements but once they identified an elevated 

reading they would go ahead and identify. But I have 

not seen any evidence that they did identify 

americium or thorium, but that may also be we have 

not looked at the raw data. We only looked at 

quarterly summary reports. 

Member Beach: Lara, could you remind me why you 

cut off the SEC at '88? What did you find in '88 that 

concluded that it was ---

Dr. Hughes: It was the end of the operational period.

Member Beach: Okay. So it was just simply the 

operational period.

Dr. Hughes: Yes, as you can see from the, there's a 

graph in the White Paper that kind of shows the 
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16

reactor operation actually ended in 1980 and then 

there was a period where they removed the fuel from 

the site. So we made it out all the way to 1988. That's 

not saying that there was a huge exposure of 

thorium/americium in 1987, in fact I don't think there 

was. But we just kind of extended the class out 

because it's really an unknown source term but we 

felt like 1988 was rather conservative. 

Chair Schofield: Do any of these incident reports or 

surveys break it down into fixed versus renewable 

contamination in the levels?

Mr. Barton: We have not surveyed that. I mean, I 

looked it over but I have not, I don't have a detailed 

summary of that right now. We typically, when we do 

data capture for the site and this period, we did not 

focus on this level of data. We mostly look at air data 

and bioassay data. 

The smear samples will be reported, they will be 

reported in dpm, so I think they most likely went with 

the same operational, the same procedure if they're, 

if they pick something up they'll probably go ahead 

and do isotope analysis but I have not seen it.

Mr. Barton: Could we again go back to sort of the 

mechanism that NIOSH has plans to use? Again, I 

just wanted to clarify that this White Paper is 

essentially establishing NIOSH's position that dose 

reconstruction to this particular source, there's no 

infeasibility, that's the conclusion of the White Paper, 

I think, but I guess I'm still not quite clear on what 

NIOSH would plan to do in an actual dose 

reconstruction.

The coworker model was mentioned, which I believe 

is TIB-80, but I don't recall that being specific to 

americium or thorium, so I'm wondering how that 

would actually work. 
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17

Dr. Hughes: We get bioassay data from a worker. 

We're not using bioassay during the CEP period but 

bioassay data will be reported as a reading from the 

bioassay contractor and they analyzed for, I think 

what we get is various forms of uranium, mixed 

fission product, plutonium, let's see, so we will take 

the urinalysis result and do a --- What we do in our 

dose reconstruction process, we have this program 

that will take the bioassay result and then we kind of 

interpolate what the workers, what period this 

bioassay sample represents and we calculate an 

intake of this radionuclide in question and then from 

this intake we calculate the dose that this worker may 

have received.

If it's not clear what radionuclide it was we'll usually, 

like if say it's plutonium, we will assign the most 

claimant-favorable radionuclide, whichever will result 

in the highest dose.

Mr. Barton: And I agree that that's true if you have, 

I guess, gross alpha urinalysis, you could do that sort 

of comparative where you select the most claimantfavorable radionuclide, but I guess I'm more asking 

towards the worker with limited or no internal 

monitoring data. Again, there's a coworker model 

and like you said, the coworker model was developed 

for fission products and uranium and maybe 

plutonium as well. 

How would you account for the potential for someone 

who's out there ripping out this equipment that had 

been used potentially for any sort of research with 

americium or thorium, how would that be accounted 

for? I understand the position that the same 

exposure potential did not necessarily exist or it 

would be different in the operational period versus 

the residual period to some extent, but again, and 

perhaps this is down the road, a discussion for down 

the road, but I'm still not sure if you have an 
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18

unmonitored worker who is involved in these D&D 

activities, how would those be accounted for?

Dr. Hughes: Right. We have not seen, either we have 

the coworker model and we would have a worker's 

own either air data or bioassay data. I don't, at this 

point from my detailed review I do not think there 

are a lot of workers that were unmonitored that were 

in the thick of the D&D operation. 

There were workers onsite that weren't monitored, 

that is true, but the people that were breaking out 

the drain line from the hot lab, they wore respirators 

and they were monitored based on all accounts that 

we have seen in the reports from the site. So any 

kind of dose reconstructions will be based on 

available worker dosimetry data which I actually did 

have thorium available during that time period.

Mr. Barton: So there are actual thorium bioassay 

results?

Dr. Hughes: Yes, there are. We did not, they're not 

sufficiently abundant to be put in the coworker 

model, but yeah, we do have some. I can't speak to 

americium, I'm not sure right now but they did 

monitor for thorium. We might have one or two 

results total. I mean, it was not, we're not talking 

about a large group of workers here.

Mr. Barton: I guess that leads me to say we're 

actually monitoring a couple of workers. Clearly there 

was some concern.

Dr. Neton: Lara, this is Jim. Are you speaking of the 

monitoring in the cover period, not the residual 

period?

Dr. Hughes: I'm speaking of the residual period, but 

I'm not exactly sure because we have not really 

focused on the bioassay data at this point. Let me 
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19

phrase it that way. I know they had a contract with 

the bioassay vendor that came in after CEP, and that 

contractor had the capability of monitoring for 

thorium. I'm not sure we actually have the data at 

this point. I thought I saw it at some point but I'm 

not sure what time period we're looking at.

Mr. Barton: Okay. So I guess just to sort of 

summarize this discussion, it's NIOSH's position that 

if the workers during the residual period have data 

that that can be interpreted to potentially account for 

thorium exposure and that if you have an 

unmonitored worker then it's going to be assumed 

that that person just was not exposed. 

Dr. Hughes: That's correct. Keep in mind the 

infeasibility for thorium and americium, especially 

towards the end of the operational period. It's not so 

much that we found that there was a huge concern 

of the quantity of the source term, it's more like that 

we couldn't really quantify the source term. It was 

one of those things we just based on the available 

data. 

We couldn't quantify it so, but the most of the source 

term being removed after the operational period 

which did not see that there was, there's not the 

same material available on the site. So whereas the 

D&D could open up something, it just doesn't look 

like there's the same type of source term available 

during the remediation period that we felt this was 

infeasible. We have not seen that in any of the claims 

or dose reconstructions, as far as I know. At least not 

the ones that I have reviewed.

Mr. Barton: Okay. And then, again, these, we just 

wanted to really understand what NIOSH's position 

was and that is that there's no infeasibility. Now you 

mentioned that the workers involved in D&D, they all 

wore respirators and had, I guess, lapel breathing 
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20

zone samplers, that kind of thing, and that that data 

is available in the DOE-supplied files for all these 

claimants?

Dr. Hughes: The breathing zone data is not and the 

DOE-supplied files, no. We have to go look for that.

Mr. Barton: I guess that's kind of leading into the 

next White Paper so maybe we can discuss that with 

the air sampling issue White Paper. I guess I clarified 

NIOSH's position of, for me. Milton, do you have any 

other questions for DCAS?

Mr. Gorden: No, I think that pretty thoroughly covers 

it.

Mr. Barton: Okay. Unless the, certainly if the Work 

Group has more questions, otherwise I suppose we 

can move on to the next White Paper.

Member Beach: Yes, I'm good with that. This is Josie.

Chair Schofield: I don't have any additional 

questions.

Member Field: This is Bill. My only question is is SC&A 

going to do a formal review, to take a formal review 

in findings, look for findings?

Mr. Katz: Yes. This is Ted. Yes. I just, the NIOSH 

reports weren't ready until November, so it's just a 

timing issue.

Member Field: Okay. 

Mr. Barton: That's obviously correct. We wanted to 

be able to sort of ask some of these clarifying 

questions so we understand what the real intention 

is behind these White Papers and the process going 

forward, and we will submit an official review on 

these matters as soon as we can.
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21

Mr. Katz: Thanks.

Dr. Hughes: Okay. Let's move on to the air sampling 

White Paper. Again, to reiterate, these White Papers 

were produced by request of the Board and the Work 

Group to clarify some items from the SEC-235 

evaluation.

The second question that was raised during the Work 

Group discussion about a year ago was since we're 

not using the bioassay data controlled for 

environmental pollution, that we should shore up this 

gap. It's roughly a two-year period that we should 

shore up with available air data. Air data is not, it's 

something we generally look into however we don't 

typically collect all of it during data capture because 

often it just represents a huge quantity of 

information.

So we don't have any raw general air of breathing 

zone data from Area IV, but we do have quarterly 

summary reports that summarize the available air 

data and this is what was used to develop this White 

Paper.

During this 1991 to 1993 period and several quarters 

before and after this period, we looked at general air 

sampling results. Those are fixed location air 

samplers. They report weekly results and then the 

quarterly reports, they report one quarterly result 

which represent about 13 weekly results. 

Breathing zone air sampling is what's worn by a 

worker during our entries into high air contamination 

areas. This worker may or may not wear a respirator, 

depending on the expected contamination. The 

results from breathing zone and general air data are 

compared to a maximum permitted air concentration, 

or MPC for the radionuclides of concern at the time. 

During the D&D period the radionuclides of concern 
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22

were stronium-90, for presenting beta emitters with 

a limit of one times ten to the minus nine microcuries 

per milliliters and plutonium-239 for alpha with an 

MPC of two times ten to the minus 12 microcuries per 

milliliter.

For breathing zones, those were compared to the 

maximum permitted air concentration, our limit of 

2000 per year or 520 per quarter and until 1992, 

actually the site stipulated that air sampling was the 

primary exposure assessment method and bioassay 

was used as backup. So when it was expected 

somebody would have an intake based on breathing 

zone or air data they would order bioassay.

I've prepared a little operational summary. I probably 

should have given that at the beginning of this, but 

this is how the White Papers are structured. What 

was going on during 1990 to 1993 at the site with the 

D&D, the SNAP reactor, the T059 building, we have 

air data available for 1991 for four quarters. 

The facility is undergoing D&D and the main 

contaminant encountered there is cobalt-60. The 

main operations that were going on this period is that 

the structural steel of the facility and the irradiated 

concrete are cut to smaller pieces and sent to the 

radioactive material disposal facility for interim 

storage until the material is shipped offsite.

Again, to reiterate, the reactor, the actual reactor, 

the fuel and the reactor parts have been removed 

from the site at this point. We're dealing with the 

building itself that's being dismantled. 

There were some airborne radionuclides observed 

during the removal of old sodium potassium coolant 

lines. The workers were breathing zone samples 

during operations causing airborne contaminations. 

There was no general air data in the SNAP building. 
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23

They were relying on breathing zone only. 

For the hot lab, we have air data available for 1990 

to 1993 for 15 quarters. This facility had 28 general 

air samplers that recorded air data for every quarter. 

Workers with potential for intakes were breathing 

zone and respirators if needed. This was the facility 

with the largest number of breathing zone data 

available. 

The D&D operations during this period mainly 

consisted of the removal of cell liners and drain pipes. 

Some incident reports indicate small events of 

contamination. 

When we looked at the general air data points, there 

was a period in 1993 where we saw some quite 

elevated general air data. We looked at this in some 

more detail trying to figure out what was going on, 

and I'll talk to that in a little bit. We found any 

potential intakes could be assessed based on 

available whole body counts and bioassay data.

The radioactive material disposal facility was an 

operational facility in this time. It was not undergoing 

D&D. We have air data available for 1990 to 1991 

with one quarter missing. There were seven fixed 

general air samplers at this facility and there's 

breathing zone data for up to ten workers per quarter 

available. 

The site, operations at this site consisted of receiving 

material from other areas at Area IV. They did sitereduction packaging, storing and shipment of 

materials offsite. 

Do most of you have the presentation in front of you? 

Well, anyway, if you have the White Paper in front of 

you, there is a figure that actually goes back to the 

operational period. We looked at some annual 

summary reports and pulled out the annual average 
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24

air concentration for the hot lab during operational 

period, and we plotted that. 

For years, we have years 1975 through 1988 

available and we compared that to the maximum 

permissible concentration at the site and there's only 

one year, 1985, where they reported an average 

above the limit that they set or that they had. There's 

no indication of why this limit was exceeded or what 

the operations were. At least we didn't do any 

research into what that was. It was mostly collecting 

this data just to compare it to what we saw during 

the remediation period. 

Also what this shows is that from 1986 through 1988 

the annual average went way down, which probably 

related to operations winding down. However, once 

we get into the D&D period we see the air data 

picking up a little more.

So when we looked at the, what is the maximum 

quarterly average, so these are the, an average of 28 

air sample locations in the hot lab. They're averaged 

together per quarter and they used the maximum 

reading at every location, as I understand, and then 

they reported on these, someone did an alpha 

reading and there was a reading for alpha and a 

reading for beta emitters on this. 

Then this was compared to the respective alpha MPC 

and the respective beta MPC. We plotted this for all 

the quarters from the first quarter in 1990 to the 

fourth quarter in 1993 and it all looks fine, so all the 

data are below their respective MPC with the 

exception of three quarters in 1993 where we see 

some really, really high air data. We did not expect 

that.

Of course we tried to figure out what the matter was 

with this, why did they report these high air data? We 
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25

couldn't find any information there so these results 

are reported in the quarterly reports but they're not 

discussed in any way. They just kind of didn't seem 

like, it didn't trigger an incident report or any kind of 

detailed analysis, so we're not quite sure what to 

make of this but I'll try to explain it a little more in a 

minute.

We also looked at the breathing zone data for the 

remediation period. In a nutshell, there's a graph, 

well, it's actually presented in a Table. In the White 

Paper and my presentation it's a graph so if you don't 

see it now you can see it next week when I present 

it to the Board.

The same, we used the maximum average, actually I 

used the maximum breathing zone per quarter and 

during the remediation period that was reported for 

individual workers and then I compared it to the MPC 

hour limit of 520, and I showed that none of the 

workers that were monitored by breathing zone 

approached this limit. 

For the hot lab elevated data, we had quarters one to 

three in 1993 had elevated quarterly results in three 

locations. The service gallery, which was the staging 

area behind the hot cells and the basement, which is 

not generally occupied except when work is done. 

The worker breathing zone data remained below the 

regulation level and we also reviewed workers' whole 

body count data and some had small readings of 

cesium-137.

Again, when we looked at this, you know, if we had 

any workers that may have had potential intakes 

from this air data and the hot lab, we reviewed 

workers' whole body count data and we also reviewed 

workers' bioassay data because they had in the third 

quarter of '93, they had the new bioassay contractor 

on line so any kind of intake would have been picked 
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26

up by these elevated results.

Now I'd like to add that we're not quite sure if these 

results are real. They're extremely high and they're 

only reported in those two quarters. We did some 

research into what they did during this time and yes, 

some of the D&D work could have produced some 

airborne contamination. 

However, this was quite a high reading so we're not 

even sure if those are spurious results, if there's 

some kind of interference with the detectors, if these 

are faulty. However we would assume that if they 

were faulty they might not report them so we're not 

quite sure what's going on with this. This is kind of 

an open-ended question here, because we would 

have to go and find any kind of raw data if that is 

decided that it's necessary. 

We've come to the conclusion that general air and 

breathing zone data are available, but that we can, 

even though that we can reconstruct doses based on 

either available whole body count or bioassay data 

that was coming on after, right after these several 

quarters of elevated data. 

So in conclusion for the general air and breathing 

zone data, they are available but some quarters, 

some facilities are not currently available. Some 

quarter reports are not available or don't exist. Raw 

data log books are potentially available. We have not 

looked for them yet. It's not clear how easily they 

could be collected. 

The hot lab air data is the most complete data set 

and it's believed to be bounding. Some elevated 

samples that are unusually high but generally 

elevated samples would be in line with disruptive 

operations during D&D. Despite these type of 

operations, there is no significant worker intakes 
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27

observed and NIOSH believes that the available 

information is sufficient to band doses from D&D 

operations during the CEP period.

That's my summary of the air data for the CEP period.

Mr. Barton: Okay. This is Bob. I guess just to sort of 

tee this off since it's been on a while, I think we really 

discussed this about a year ago. The purpose of this 

air sampling review exercise, and please correct me 

if I'm mistaken, but I believe the intention at least 

when we met last was that you have this period 

where the bioassay contractor is suspect so you can't 

trust the bioassay data for this couple year period in 

the early '90s. 

I think the intention was, at least back then, was that 

what we would do is we would take the bioassay data 

and the derived intakes from the operational period 

and extend them as essentially coworker intakes 

through this period into remediation. Am I correct so 

far?

Dr. Hughes: Yeah, I think that's true.

Mr. Barton: Okay. So, then the question was well, 

can we sort of build this weight of evidence that 

based on the air sampling data that we do have, 

which we have no reason to believe is necessarily 

suspect, can we make a comparison between what 

the radiological conditions were during the operations 

period which we're going to use as coworker data, 

can we make a comparison of sort of the exposure 

potential that we're seeing based on these air 

samples that we have.

And that was the original intent of this, was really to 

sort of bridge that gap to say listen, we can't trust 

the data in the early '90s because the bioassay 

contractor was not up to snuff, but can we confidently 

say that the conditions during the operational period 
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28

are going to bound what was experienced by workers 

who were performing these D&D activities? 

So that was really the intent of this. So just to sort of 

set the stage of why we're going through this because 

as Lara said, you normally don't rely on air sampling 

data for dose reconstruction if you have bioassay 

data. In this case we have bioassay data prior to this 

period that we're going to apply to the early '90s to 

sort of cover up this two-year period where we can't 

trust the bioassay data and therefore we can't use it 

to develop any sort of unmonitored intakes. 

So that's sort of the story. I will, I'll pass it off to 

Milton Gorden because as I said before he's sort of 

been taking the lead on looking at a lot of the 

underlying documentation in this. So Milton, if you're 

on the line I'll give it to you. 

Mr. Gorden: I'm kind of relying on some of the stuff 

that you had done too.

Mr. Barton: I can keep going, that's no problem.

Mr. Gorden: It's probably going to be easiest, 

otherwise you'll just probably end up trying to explain 

more what I'll laugh to.

Mr. Barton: Okay. No problem. We did have some 

questions that we developed. I'll try to reference the 

report that's posted online so people can follow 

along.

One of them was, on page 7 it states, "A recent 

request for additional quarterly reports to DOE-EM 

Consolidated Business Center in Cincinnati where 

DOE records and SSFL operations were sent has not 

yielded additional quarterly review reports. It is not 

known at this time if additional reports or potentially 

raw data could be located."
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29

So I guess our question, right off the bat, is is this 

request still ongoing to this records center, or have 

they exhausted their document holdings and there's 

simply nothing else there? And are there any other

locations where there are Santa Susana documents 

held that could be of use?

Dr. Hughes: The request is not currently ongoing. It 

mainly consisted of me requesting some of their 

findings, and looking through, see if they had 

anything listed quarterly reports, and they said we 

haven't identified anything additional.

The quarterly reports were kind of driven by 

regulatory agency requirements so they may have 

not. They may have stopped writing them if they 

weren't required to do it. I think that's my 

understanding. 

So if the quarterly reports aren't available, the raw 

data is, some of it is certainly available. I'm not sure 

what is available where. We know that a lot of the 

accords have been sent to this location in Cincinnati. 

I would think that most of the records that are of 

interest to us are available there. 

Now when we do dose reconstruction, this is not at 

the level of where we necessarily collect, where we 

collect quarterly reports. We collect air sample 

summaries, we have not targeted detailed air 

sampling during this period. 

I guess what I'm saying is we don't know what level 

of effort would be necessary. I feel somewhat 

confident that we would find something if we were 

looking for it but I have not done that. That would 

take quite a long time and a lot of resources. 

There are other locations, we know there are some 

Iron Mountain locations that may have records, or 

that do have records, but I think those are more of a 
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30

general nature and not related to radiation protection 

records. I think it's mostly like human resource 

records and things like that.

Mr. Barton: Okay. I understand that. Moving on, on 

page 8, figure 1, it states, "Annual maximum 

averages," and I'm just looking for a little bit of 

clarification on what that actually represents. Would 

this be the highest average among the approximately 

30 air samplers for this, or is it the average of the 

maximum readings of all the air samplers? I wasn't 

quite clear on that.

Dr. Hughes: I'm not, that's how it's reported and I do 

believe it's, you know, they take the maximum for 

each location for each quarter or, these are annual 

so they take the annual maximum for each year and 

average it over all the locations and that's what the 

number they report there. At least that's what I 

understand on that estimate.

Mr. Barton: Okay. So the average, and so this doesn't 

represent really the highest air sampler, it's the 

maximum ---

Dr. Hughes: No, it's an average microtron average. 

That's, it's in those annual summary reports so again, 

this may be available in much more detail, value 

pulled out from the summary reports.

Mr. Barton: Okay. That clarifies at least what we're 

looking at. And it looks like this, I mean, these are all 

just from the operational period though, right?

Dr. Hughes: Yes.

Mr. Barton: Okay. I notice it's for the beta samplings. 

Do we have similar comparisons, because again the 

whole point of this exercise was to compare what the 

air sampling was during the operational period where 

we're going to use the bioassay data to assign intakes 
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31

to this other period in the '90s. 

Was there something done for alpha, and do we plan 

to compare --- I mean, I'm looking at figure 1, it 

stops in 1988 but it doesn't really show how that 

would compare to the period that we're trying to 

apply this bioassay to, and it's only for beta.

Dr. Hughes: Yeah, they did not report alpha for, this 

was for the hot lab so they did not report alpha for 

the hot lab. I think their main contamination concern 

was fission products. They went with the beta that 

they reported in these reports.

Mr. Barton: Okay. Moving along, page 9, it's 

indicated that breathing zone data, so these are the 

lapel samplers for the workers who were in there 

doing the D&D work, I guess they were compiled into 

an electronic database but we don't have that data?

Dr. Hughes: That's correct.

Mr. Barton: Have there been any attempts to get that 

database, or, you know, look at it?

Dr. Hughes: Yes, I have talked to an individual who 

was in charge of the health physics program and I 

was told that this database from the d-base, I think 

it was later converted into something else and it's 

available on a five inch floppy disk somewhere so no, 

it's not available to us. 

Mr. Barton: Is there any plan at this time to go get 

that and ---

Dr. Hughes: I don't know where it is. I mean, we can 

certainly put, an avenue I would say is probably 

available to us is looking at log book entries if we 

needed the raw breathing zone data, that we would 

go for log books, health physics log books-type 

information that would be in the records.
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32

Mr. Barton: When you say in the records, I guess that 

goes back to my original question. If we're looking at 

an individual claim from this period and presumably 

if they were doing this work that would be riskier as 

far as airborne contamination, are those records 

available to the dose reconstructor to be able to 

evaluate what the exposure to an individual was, at 

least, during this period? 

Are those actually in the files? I mean, do we have, 

we don't have the complete database but is that, are 

those breathing zone results being supplied with an 

individual claimant's monitoring record?

Dr. Hughes: They occasionally are but it's not a 

given. I mean, they're not supplied in the same way 

that we receive external and bioassay data, so it 

might be in the records if it was filed in the records 

or if there's some kind of, let's say there was an 

incident report that was written in some cases. 

However, we do have name lists, so these quarterly 

reports contain, they have usually in the form of an 

appendix, have a list of the workers that were 

involved in these D&D operations for the hot lab with 

their names and what their breathing zone 

information was for that quarter. We do have, we do 

believe we do have information for most of the 

workers involved in this D&D operation during this 

period of questionable bioassay data, that we do 

have that available, and that can be used for dose 

reconstruction if needed.

Mr. Barton: Okay. So essentially what you're saying 

is in the quarterly reports that we do have, it lists all 

of the workers who at least wore breathing zone ---

(Simultaneous speaking.) 

Mr. Barton: And that's a complete list of all the 

workers involved?
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33

Dr. Hughes: Well, you know, there will be a summary 

statement saying, you know, we had 11 workers 

wore breathing zone during this quarter and then 

they would have the names and then they would 

have, say, if Joe Smith had, I don't know, 25 entries, 

what they call entries, which is the number of times 

this worker geared up with this breathing zone 

apparatus and went in and did a certain amount of 

work. 

We do have quite some detail available. It is, 

however, in the form of summary output so it's not 

more detailed than that, so it will be like a quarterly 

summary result for that given worker and it will 

report the number of entries that were made during 

that quarter.

Mr. Barton: Is there necessarily a position right now, 

I mean, being so confident that we have all the 

records? It's a completeness question, really. Do we 

have all the breathing zones, even if they're in the 

form of a quarterly summary, for listed workers, or is 

that still in question as to whether we actually have 

all these results of the workers doing the D&D 

operations?

Because as you said, at least my understanding is 

that they used those air samples to control exposures 

rather than, and the bioassay was a check. So, how 

confident are we that we have all those breathing 

zone samples to really know who was in there, who 

was doing what work and what the airborne levels 

were? That could be, I mean it's D&D work, so it's by 

its very nature it's a little off-normal, it's not routine 

stuff, and so you could have these localized events. 

I'm not saying there were or were not, but how 

confident are we that we had access to all that data 

to be able to confidently say, or we're applying the 

bioassay data from operations that were really bound 
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34

in the exposures to these workers in there doing D&D 

work? 

Dr. Hughes: We do have the breathing zone for the 

workers at the hot lab for this CEP period. We also 

have, keep in mind we also have whole body cam 

data for workers in the hot lab, so we would see 

exposures to, like, cesium. They actually did detect 

some of that during this period. 

So for the hot lab, yes we do, we do have a breathing 

zone, which I assume it's a comprehensive list and 

they're available by name. We assume that the hot 

lab was probably the bounding operation here, 

because they really were doing some higher level 

work when they were taking out the drain lines from 

some of the hot cells in the basement, so yeah, we 

do have that available.

Am I confident? Well, I'm as confident, I mean, you 

could look at the records and where they list the 

workers by name, and it's fairly detailed information 

available. That being said, we don't have the raw

data available at this point, and anything like in the 

form of log books or anything. We have not looked 

for this type information.

Mr. Gorden: I guess like follow-up then, excuse me, 

because that is in your opinion, do you think it's 

worthwhile, do you think what you've uncovered so 

far is probably going to be sufficient in doing, 

supporting the dose reconstruction?

Dr. Hughes: From the need-to-file program, I would 

say yes, it's sufficient to assess intakes for workers 

during this period, yes.

Mr. Barton: I'm looking at Table 1, it's on page 10 of 

the White Paper, and I guess it's the second quarter 

from 1992. It's giving alpha results significantly 

higher, at least by a factor of two, than all other 
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35

entries for alpha air sampling. Do we have any idea 

of what was going on there? These are also, I guess, 

maximum averages?

Dr. Hughes: I'm sorry, which one was it again?

Mr. Barton: I'm looking at Table 1, in the second 

quarter of 1992, you have an alpha result that's on 

the order of minus 13. I notice that's a factor of two 

higher than every other reported result for this table. 

Do we have any idea what was happening then? It 

just caught my eye.

Dr. Hughes: Right. No, I don't. I mean, every 

quarterly report has a summary available of what the 

specific work was but it doesn't necessarily specify 

this is why these values were elevated. Keep in mind 

this was below the maximum permittable 

concentration for alpha, so they did not really 

discuss. Actually, they didn't discuss the incidences 

where they were above, so no, we don't know 

specifically what was going on.

Mr. Barton: And it says maximum reported value so 

that would be, I mean, I think these things were 

going on essentially a weekly basis, you'd have a 

sampling for seven days so this would be the 

maximum ---

Dr. Hughes: These are maximum reported value for 

the quarter. I just, they're, I went through all these 

quarterly reports and they report the different 

locations and I pulled out whatever, what was the 

highest location that was reported and in this case, 

the hot lab, so between the 28 different locations 

reported I would report the highest.

Mr. Barton: I guess my question is does that 

represent the average over the entire quarter?

Dr. Hughes: It represents a quarterly average, yes.
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36

Mr. Barton: Okay. This kind of leads me just to my 

last question here, it's on Table 2. You discuss this 

sort of in the presentation. These values are huge.

Dr. Hughes: Yeah. I know.

Mr. Barton: We're talking about 10 to 12 orders of 

magnitude higher than the DAC.

Dr. Hughes: Yes, right, they're very large and we 

don't know what to make out of it so that's why we 

went, you know, look at worker records to see did 

they have any kind of significant intake or anything, 

or are these even real, you know? We'd like to not 

say oh, they're not real, because we tend not to do 

that.

Mr. Barton: Of course.

Dr. Hughes: But they seem very high. They're very 

high so we don't quite know what to do with them. 

Short of looking for log books and trying to figure out 

is this real, what's this, what's going on here? But 

then again, we were like well, you know, to what 

extent do we want to pursue this, I guess, is the 

question. 

Mr. Barton: It's surprising that if these were being 

reported and even in a quarterly summary that they 

wouldn't ---

Dr. Hughes: Right, and they don't discuss it, it's not 

being discussed at all so it's kind of strange.

Mr. Barton: And to sort of follow up without getting 

into any obviously specifics that would skirt the 

Privacy Act line, you went and evaluated a couple of 

workers?

Dr. Hughes: Yes, I looked at a small number of 

workers whose names were listed.
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37

Mr. Barton: So these would have been in the 

appendix that showed they were wearing lapel 

samplers during those quarters.

Dr. Hughes: Yes, and not necessarily claimants but 

we received the worker dosimetry scans from Boeing 

years ago so we can by name matching, we can look 

at these workers' files and see what is in their health 

from a bioassay standpoint, from a whole body count 

standpoint, if there are incident reports in there, 

anything like that.

Mr. Barton: I mean, these Table 2 values are so high. 

Do we have any comparisons to say that, I mean, it's 

simply a unit that got ---

Dr. Hughes: I don't know. It might be a short circuit 

and, but then why would they include it, you know? 

I'm not sure.

Mr. Barton: Okay. That's a little disturbing, just 

seeing how high they are. Like I said, it's 12 times 

the MPC.

Dr. Hughes: I did talk to the person that was in 

charge at the time or one of the health physics 

managers that was in charge of this facility at the 

time and he basically looked at the records like, well, 

I don't think those can possibly be real. He recalls 

seeing elevated general air data, but not to this 

magnitude. It's not uncommon to see something, but 

not this much, and so he didn't have an answer for 

me either and so we kind of don't know what to do 

with it at this point.

Mr. Barton: Well, that's all the questions I had to sort 

of clarify NIOSH's position. I don't have anything 

more. Milton, do you have anything you want to ask 

or obviously the Work Group probably has questions 

as well.
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38

Mr. Gorden: No, that's fine. Work group can go 

ahead.

Chair Schofield: Lara, I got a question for you, this is 

Phil. Do you have the criteria for incident reports? I 

mean, like does alpha count has to be a certain level, 

or do you know what these levels are?

Dr. Hughes: I do not know, no. 

Chair Schofield: Okay, thanks.

Member Beach: Lara, this is Josie. You mentioned a 

couple of different times during your presentation 

about getting more log books or reviewing more log 

books. What kind of a possibility is that? And you 

talked about that floppy, that someone mentioned 

that those records were put on the floppy. Is there 

any follow-up to trying to figure out where that went 

or it just is in somebody's file and it's not obtainable?

Dr. Hughes: Yeah, so I talked to the person who was 

in charge of the health physics manager at the time, 

and I asked him about this database, and he basically 

said that this was converted from database format, 

whatever d-base, into something else. He basically 

said it was on storage files that were not, that are out 

of date now and he does not think it's available but 

at the same time, we haven't actually looked for it. 

And the other though I can report, and that's for log 

books. You know, any of the summary data that is 

reported in the quarterly reports, it would be 

somewhere else. Especially with these elevator 

reports, the thinking goes that there would be some 

log book entries of some sort. Because somebody 

pulled these samples off and wrote a number down 

that was really extraordinarily high. They must have 

had something to say with regard to that although it 

is not reported in the quarterly reports.
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39

Now, what kind of time and effort would be needed 

to find this type of information, I don't know if it's 

needed for the purpose of this program or not. I'm 

not quite sure.

Chair Schofield: Other Work Group Members?

Member Field: This is Bill. I just have a question 

about your conclusions or data conclusions. Your 

third bullet, you say it is not clear if this data is 

available and how easily it could be collected. When 

you're talking about this data, are you talking about 

the log books? Because it's a different bullet, or the 

quarterly information for air monitoring?

Dr. Hughes: For both. I mean, there's some, you 

know, we don't have all quarterly reports and I'm not 

sure if those were written, because they may have 

followed some kind of regulatory requirement. And 

again, the same with the raw data. For any kind of 

quarterly report there is raw data somewhere, or 

used to be. So yeah, it's not clear. 

I haven't actually seen it, I haven't seen a finding aid 

that says, you know, HP logbooks for this time 

period, so it's not quite clear to me if this data is 

available. I would think that it is, but until I see it I 

can't speak to it. And also, how easily it could be 

collected. I mean, the collection part may not be the 

hard part but how easily it is to decipher and to 

catalog and to uncode and all that sort of thing.

Member Field: Okay. It may be helpful just to state 

what you meant by this in the bullet. And in the first 

bullet point, instead of the data are available, but 

they're not currently available, that makes it sound 

like they may be available in the future. 

Dr. Hughes: It's the same thing. This is regarding the 

Table 1 of the White Paper, you know, we have 
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40

quarterly, we have some quarterly reports. We have 

quarterly reports available for the SNAP facility, for 

the radioactive material disposal facility, and for the 

hot lab, but not for all the quarters that we were 

focusing on so I guess my statement is, well, we do 

have some but we don't have all quarters and we 

don't have all facilities. 

They're not currently available because there may or 

not be some more quarterly reports out there, but we 

just haven't located them. I did a cursory search at 

the local, Cincinnati local records facility where most 

of the records were sent, and they did a keyword 

search for me and they have not located any 

additional one. That's not to say that there aren't 

somewhere, but we may just have to search in a 

different manner.

Member Field: And this isn't, you're going to be 

putting a lot of effort into, in the near future locating, 

correct?

Dr. Hughes: I'm sorry?

Member Field: And this isn't something you're going 

to be putting a lot of effort into to try to locate.

Dr. Hughes: Well, if it's the desire of the Board or the 

Work Group that we need to clarify or shed more light 

on the nature of the air data or the exposure 

scenarios, then we will do this but we feel like for the 

current dose reconstruction program we don't feel 

like we need to do a tremendous additional effort to 

be able to do dose reconstruction, I guess is what I'm 

trying to say.

Member Field: I understand. I was just trying to 

interpret it by not currently available as they may be 

available next ---

Dr. Hughes: We don't have them, we don't have 
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41

them in our database, I guess.

Member Field: I understand. That helps clarify it. 

Thank you.

MR. MARCH: But they are available somewhere, you 

think?

Dr. Hughes: They may be. It's quite possible that we 

could find, well, I'm not the one to speak to the 

quarterly reports, I really don't know. The raw data, 

some of it is probably available somewhere, yes. We 

have not looked for this type. We don't usually go to 

that level of searching, or we haven't for this facility. 

MR. MARCH: Okay. 

Mr. Barton: So I guess just to summarize, what we're 

really saying here is based on the conclusions of this 

White Paper on what air sampling data we do have 

that it's NIOSH's position of intention that applying 

the operational coworker model to this period is 

sufficient and the available data that we do have 

shows a radiological environment that is bounded, 

essentially, by that operational data. 

So we can use the operational bioassay or if we're 

not using the air samples to reconstruct dose, we're 

going to assign doses based on the coworker model 

in place currently. Is that correct? 

Dr. Hughes: The coworker model would be used, 

yes, for an unmonitored worker. For the monitored 

workers we would use whatever is available. 

Mr. Barton: Well, during this period, this is ---

(Simultaneous speaking.) 

Dr. Hughes: Well, if you have this, if you have a 

worker who was working in the hot lab, if we have 
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42

breathing zone available it probably would be the, 

they would probably do a check and see which one 

was more bounding.

Mr. Barton: I see. Okay. I don't have any other 

questions.

Chair Schofield: Anybody else have any questions?

Ms. Blaze: I do. This is D'Lanie, SEC petitioner.

Chair Schofield: Go ahead.

Petitioner Questions/Comments

Ms. Blaze: Thank you. SEC-235 was initially based on 

an inability to identify work locations or effectively 

rule out Area IV employment. We've established that 

Boeing's record responses are unreliable and 

incomplete.

In April of 2018, we found that Boeing has omitted 

radiation and bioassay data for a hot lab employee 

who was also employed at the DeSoto facility. His 

record indicated a notation from a contractor that 

whole body counts were never reported for workers 

at Santa Susana and the DeSoto facility, so my 

question is has the Work Group and SC&A and NIOSH 

reviewed the clean studies comparison that I 

submitted for this employee? It's dated April 30, 

2018. 

We found that Boeing had also redacted all of that 

employee's incident reports that were supplied to 

DOE, which were easily retrieved from the Boeing 

incident report database, and that they had omitted 

pages where that worker was shown in diagrams to 

be involved in extraordinary events. This really calls 

into question the integrity of their records responses 

with respect to radiation data, and establishing your 

processing. Have you guys received and reviewed the 
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43

case study?

Dr. Hughes: This is Lara. I have it and I have 

reviewed it and we have actually, DOE is actually 

working on this with Boeing at the moment, so 

there's actually a contingent going out and trying to 

figure out what the issue is with Boeing and why, you 

know, there was certainly a disconnect between what 

you sent in for this worker and what I think Boeing 

provided to DOE or DOL, because this is not a claim 

that is with NIOSH. 

I was instructed to look at it, and what I did is I pulled 

the worker dosimetry files that we have from this 

Boeing data dump that we received in 2014, I 

believe, and we do have a lot more than what Boeing 

has supplied at this time. So I think what DOE's trying 

to sort out what the issue is. 

This may have something to do with the Boeing 

responses. I think they're coming from headquarters 

now instead of coming from the site directly and the 

people that are working there may or may not know 

how to search properly so I think they're trying to 

resolve it, and I'm trying to help them if they, as 

much as I can based on what we have so hopefully 

they will get this resolved.

Ms. Blaze: I don't know that it's a question of 

knowing how to search properly when they turn in 

incident reports that have been actively redacted, 

with pages missing, but obviously we're awaiting 

resolution of that issue. It's just calling into question 

the ability for claimants who are eligible for existing 

SEC to even establish that they were employed at the 

site because of contractor interference. That by itself 

is the basis for an SEC class. That's all from the 

summary until I see the White Papers.

Dr. Hughes: Right. Again, this is Lara. I can't speak 
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44

to, I mean the SEC class is based on certain 

guidelines that we have to follow, so we'd like to 

brush this off as is this an issue for DOE and this is 

an issue for DOL to establish employment at the site, 

but we'd certainly try to help with whatever resources 

we have if the question is posed to us.

Ms. Blaze: Thank you. The study, and is the Work 

Group, do I need to send that out? Again, could 

someone just advise me on that?

Mr. Katz: D'Lanie, can you just repeat what you 

asked just now?

Ms. Blaze: Sure. Has SC&A and the Work Group 

received a copy of the case study on those missing 

records? If you guys will let me know. I can send it 

out again if I need to.

Mr. Barton: This is Bob at SC&A. To my knowledge, 

it certainly hasn't come across my desk, and so I 

don't think we've necessarily been I guess formally 

tasked with looking at it, and I don't think we have 

done anything on it. It sounds like from what Lara 

said that the matter is being pursued by the agencies 

involved, which is really DOE and DOL, I guess, at 

this point. We can look at it if that's what the Work 

Group wants us to do. That's all I can really say. And 

I, to my knowledge SC&A has not done any work 

specific to the issue you're talking about, which is 

obviously important and needs to be run to ground.

Ms. Blaze: I would just respectfully submit to the 

advisory Board, there's documentation suggesting 

that whole body counts were not reported for these 

employees, so if it pleases the Work Group I'll send 

that case study out again, if they think it's relevant.

Mr. Katz: D'Lanie, you don't need to send it again, 

because I think DCAS can share that again with SC&A 

but there's not going to be a tasking at this point.
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45

Ms. Blaze: Okay.

Member Beach: And I see, and I have it right in front 

of me, D'Lanie. Is it April 30, 2018?

Mr. Katz: Yes.

Member Beach: Okay. Thank you.

Ms. Blaze: Thank you.

Mr. Katz: So, path forward, I think, is where we're at, 

Phil, right?

Chair Schofield: Yes. 

ABRWH December meeting plans/other follow-up

Mr. Katz: So the immediate issue with path forward, 

to tell whoever this is what we want to do at the 

Board meeting. This is clearly not ready yet for any 

kind of Board action, because we haven't even had a 

chance, SC&A hasn't had a chance to respond 

formally and review it formally. 

So it's more sort of sorting out presentations. We 

have Lara's presentations, and I don't think they 

would take much adaption for the full Board. My 

thinking is that there's not any other presentations to 

be made at this point, because SC&A is not really 

ready to make a presentation on this, they've just got 

these clarifying questions so I think for Lara to 

present and then the Work Group Members, of 

course, can pipe up with any observations or

questions again that they want to raise at the Board 

meeting, and of course the petitioner will have an 

opportunity to comment at the Board meeting, but 

I'm thinking there's not more to be done. I'm open to 

whatever the Work Group thinks.

Chair Schofield: I have to agree with you, I don't 
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46

think we're ready for a possible vote on this. We still 

have to wait for SC&A's paper to come out.

Mr. Katz: Right. So it may be that we can, we need 

to leave enough time for D'Lanie to comment as soon 

as she wants to at the Board meeting, but it may be 

that we don't the whole hour and a half for this. Lara, 

how much time do you think you need for your 

presentation?

Dr. Hughes: It's about the same, so what was it, 20 

minutes. It's the exact same presentation because I 

have to submit it way in advance so it's exactly, the 

title slide's different, so yeah.

Mr. Katz: Yeah, I wasn't really tracking how much 

time you took and that's why ---

(Simultaneous speaking.) 

Dr. Hughes: Well, I think, you know, I should get 

through it in at the most 20 minutes.

Mr. Katz: 20, 25 minutes.

Dr. Hughes: Yeah.

Mr. Katz: Okay, okay, and then if D'Lanie, do you 

think you need 15 minutes? How much time do you 

think you might need?

Ms. Blaze: If we can allot for about 20 minutes.

Mr. Katz: Okay. And then time for questions. So my 

thought is then this session could really be about an 

hour. For this portion of the session, of course, 20, 

40 minutes, because we also have DeSoto to talk 

through as well. 

Ms. Blaze: I'm sorry, Ted, I just want to clarify. Are 

we going to be discussing both of the petitions, 235 

and 246?
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47

Mr. Katz: Sure. Sure. We just haven't gotten to that 

for this Work Group yet. But yeah, they'll both be on 

the plate for discussion at the Board level, yeah. All 

right, so we can go on from here now to the next 

portion.

Mr. Barton: Okay. Let me just quick get my 

presentation up here on the Skype for everybody. I 

forget how you present it as a slide presentation. 

Okay.

To those of you that have the Skype up, can you see 

the presentation slides?

Chair Schofield: Not yet.

Mr. Barton: Okay.

Mr. Katz: Yes, not yet, Bob.

Mr. Barton: Okay, sorry about this. Let me see -- try 

it again.

Mr. Katz: It's loading now, Bob. Yes, there it is. You 

just need to expand it.

Mr. Barton: Okay, how does that look to everybody?

Mr. Katz: Small.

Mr. Barton: Small.

Mr. Katz: You need to make it a little bigger.

Mr. Barton: It's showing it as a slide show on my 

screen.

Mr. Katz: Yes.

Mr. Barton: Let me try that again. Did that go full 

screen?

Mr. Katz: I don't know how other people -- it's 
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48

definitely legible. So you can carry on.

De Soto Avenue SEC petition

SC&A review of DCAS De Soto Evaluation Report

Mr. Barton: Okay, very good. Very good.

Okay, we're going to be talking about SEC-246 now. 

And that was submitted on December 13th of 2017. 

The proposed definition in the petition was all 

workers who worked at the De Soto Avenue Facility 

in Los Angeles County, California during the period 

from January 1, 1965 through December 31, 1995.

The rationale provided in the original submission read 

as follows: NIOSH has determined it cannot 

reconstruct radiation dose for americium, thorium, or 

associated progeny at SSFL Area IV, 1965-1988 -- it 

says 988, unfortunately, but I'll fix that. Based on 

shared contractor and operational history, shared 

data limitations between SSFL Area IV/De Soto 

Facility, and the established presence of americium, 

thorium, and associated progeny at De Soto Facility 

until at least 1995, the following petition is 

submitted.

So just to give a little more background, the SEC 

petition qualified on March 1, 2018. The proposed 

class essentially will remain the same, just the 

standard language about DOE and its subcontractors 

was added in but essentially it remained unchanged.

In July of this year, NIOSH released the SEC Petition 

Evaluation Report and that was presented in August 

of this year at Meeting 124 of the Advisory Board, 

which was in Providence, Rhode Island.

After discussions at that Board meeting, SC&A was 

tasked with reviewing the main conclusions of the ER, 

Evaluation Report. So that's where we are today.
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49

Now, the two central conclusions of the Evaluation 

Report and, again, I'll just -- I'll read these into the 

record. Again, these are based on americium and 

thorium potential.

For americium, neither the documents available to 

NIOSH nor interviews with former workers revealed 

any history of fabrication of americium sources, or 

work with uncontained americium at the De Soto 

Avenue Facility. Contrasting previous NIOSH 

evaluations of radiological work at Area IV of SSFL, 

NIOSH has found no indication that De Soto had 

sources of americium associated with work 

processes.

Now the conclusion for americium in the NIOSH ER, 

that was released in July.

And for thorium, NIOSH has identified detailed 

documentation of thorium work episodes in 1970 and 

1979, providing source term, operational procedures, 

radiological protection protocols, names of individual 

operators, and dates of work. NIOSH has concluded 

that the thorium-grinding operations in 1979 

represent the bounding thorium internal exposures at 

the De Soto Avenue Facility during the operational 

period, which is January 1, 1965 through December 

31, 1995.

As presented in Section 7.2.3.1, NIOSH had sufficient 

personnel bioassay data, including pre-work and 

post-work urinalysis, and job performance data to 

allow it to develop a bounding dose estimate for 

workers with potential thorium exposures during the 

period from January 1965 through the end of 1995.

So our review approach at SC&A was, obviously, 

we're going to start with what available 

documentation is in the Site Research Database, as 

available to both NIOSH, SC&A, and the Advisory 
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50

Board, as well as the documents that were supplied 

by CORE Advocacy for Nuclear and Aerospace 

Workers.

We also went through and found what documented 

interviews there were with former workers at the De 

Soto facility and there was also a signed affidavit 

supplied by a former health physicist who worked at 

De Soto.

The third thing we did is we went and we looked at a 

very substantial portion of the claimant population. 

We focused in on job classifications that would likely 

at least have a potential for involvement in these 

radiological operations. 

And we specifically looked at what's known as a CATI 

report, which is a Computer-Aided Telephone 

Interview, in which to see if there were statements 

made about what type of work was being done, what 

exposure there was, especially to americium and 

thorium, and really anything else that would be of 

interest going on at De Soto during this time.

Also for several of the claims often led by what was 

contained in the CATI, we would go into the 

Department of Labor case files, which are essentially 

the initial submissions that often contain other 

information and statements made by the claimants 

that might be relevant to the potential for exposure, 

particularly to americium and thorium.

As far as the available documentation we have, really 

there are four really important primary document 

types that we focused on. That's not to say these are 

the only things we looked at but if we were going to 

find evidence of what the exposure situation was at 

De Soto during this time, it was really the health 

physics log books, which these would be handwritten logs, what the HPs were doing out at the site 
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51

on a daily basis. 

There is also something called a tagged area entry 

permit. These are essentially radiation work permits. 

If there was something that was going to be done 

that required potential for exposure, there was a 

standard form that would be filled out that would

specify what types of radiological protection were 

going to be required, what types of monitoring, 

whether it be personnel monitoring, whether a 

bioassay was going to be needed, that sort of thing. 

So that would give us an indication what type of work 

might have gone on with thorium materials or 

americium.

We also have the routine contamination surveys. 

These are pretty standard across all these sites, 

where an HP would enter a specific room, would take 

swipe samples of that area and then go and count 

them for activity.

Now these are usually only provide gross alpha and 

gross beta but there is also a comment section where 

they can indicate whether -- what was going on in 

that room, if they found some contamination, what 

sort of operations were. So that is just another clue.

And the fourth item of great importance, the area air 

sampling results and also the personal air sampling 

results, which we just spent a lot of time this morning 

talking about those, breathing zone, and lapel air 

samplers which, again, oftentimes will include what 

the material was, what they were doing, what the 

operation was.

So these are really the primary sources that would 

really characterize what was going on radiologically 

at De Soto.

Now our first finding was that when we were looking 

through all these different types of documents that 
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52

really there's a sampling of them throughout the 

period. And we'll see in the next couple of slides what 

I mean here.

So what we're looking at, this first one is health 

physics logbooks. And as you can see, it's probably 

hard to see the actual numbers in here but what we 

have here is a chart -- a bar chart that shows from 

1965 to 1995 and what percentage of the months in 

each year in which we have at least some health 

physics logbooks from De Soto. Now, this doesn't say 

exactly if an entire month is covered or whether it 

covers all relevant buildings. In this case, we're 

mainly talking about Building 1, where they did the 

fuel fabrication, and Building 4, which was the 

radiological laboratories.

So as you can see, there is a very large gap if you'll 

notice, from 1968 to about 1980 in which we couldn't 

really find any of those health physics logbooks to 

really know what was going on at the site.

This next one is, again, these essentially radiation 

work permits. They call them tagged area entry 

permits. And again, some years you have the entry 

permits for all months. Now again, you can't really 

know if that represents all of the tagged area entry 

permits in the year but at least we know that 

temporally we have some for each of the months, at 

least in the 1969-1970 and then in 1980 and 1981.

But also, again, during the full scope of this evaluated 

period for SEC-246, for a lot of years we could not 

find any of them.

Routine contamination survey reports, those were 

the third source that I mentioned. Again, we have 

gaps. I mean there were temporal gaps. This is not 

necessarily surprising as you go and -- any sort of 

these data capture trips, oftentimes, you only get a 
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53

sampling of all the different things going on but you 

don't necessarily have the wherewithal to capture 

every single document.

So there are these temporal gaps, which does add 

some uncertainty as to being able to make 

conclusions about all of the activities that might have 

happened at De Soto. 

And this last one is the area air sampling. Note that 

this does not include personal lapel samplers. I was 

working towards trying to get that data compiled in 

time for this meeting but the clock was ticking and I 

just ran out of time. But these are going to be your 

general area air sampling results which, again, will 

oftentimes include notes about what was going on in 

a particular location where an air sample was taken, 

even if the results are simply given in gross alpha or 

gross beta.

So specific to americium, essentially we see four 

potential sources where this -- you could have 

exposure to americium specific to De Soto. The first 

one and probably one of the more important ones 

would be any spent nuclear fuel that had been 

decladded and handled at De Soto. We know that this 

operation did occur at Area IV. So the question 

becomes because of the shared radiological health 

program and the shared goals of De Soto and Area 

IV, did they receive decladded spent fuel or do the 

decladding themselves, in which case you would be 

expected to encounter transuranic material, which 

would include americium.

They also had a license to fabricate sealed americium 

sources. So they did receive americium material and, 

under their license, they had the ability to basically 

expose that material and create sources for other 

offsite parties that were interested and wanted that 

sort of material. And I believe that they had a license 
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54

for up to I think it was 10 millicuries of americium at 

any given time for that program.

So that's the second real source of potential 

exposure.

There is also this program known as the Transuranic 

Management by Pyropartitioning-Separation or the 

TRUMP-S program. It is basically a program to try to 

figure out how to dispose of spent fuel in the 

transuranics that are contained in there. So that 

material could have included americium that was not 

sealed, which obviously if you have an unsealed 

source of americium, you might have an exposure 

potential.

And the last one which was interesting was smoke 

detectors that were at the De Soto facility, which 

actually used americium for at least a certain period 

of time. We're going to talk about that.

So the first one, the first source of exposure was the 

decladded spent fuel. Today, we have not identified 

evidence of actual or direct evidence of decladding 

activities of any spent nuclear fuel occurring 

specifically at the De Soto site or, as it's pretty well 

documented, as occurring at Area IV. We just have 

not found the evidence to date.

We did identify examples of the spent fuel arriving 

and, at the very least, being stored at the De Soto 

site. But again, any documentation indicating the 

handling or processing of the actual decladded fuel, 

which is where the transuranic material would have 

been, again, to date we have not identified that sort 

of evidence.

We did find one example where one of those area 

surveys an HP found a contaminated tray and this 

was in Building 4, which is the radiological laboratory. 

Essentially, they found a contaminated tray that had 
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55

been used to clean sodium from decladded fuel 

elements. It doesn't go into much more detail than 

that.

We're not sure if the fuel has been decladded actually 

at De Soto or if that occurred possibly at Area IV. But 

obviously, we assume that the fuel element was 

actually irradiated. That's not necessarily indicated 

but you would assume that if they were going to take 

apart the cladding on a fuel element, that they 

probably spent some time in a reactor.

So that incident was the subject of SC&A Finding 2. 

Again, it was a tray that was contaminated and the 

logbook entry, or actually it was, I believe it was a 

survey report, indicated that that tray had been used 

to clean off decladded fuel. So that's about the extent 

of what we found so far related to that first exposure 

source.

Now we talked about the fact that De Soto had in its 

license to be able to use unencapsulated americium 

for the purpose of fabricating other sources to be 

shipped offsite. In fact, there was even a notice of 

violation in 1994 that the required six-month leak 

check -- essentially they had americium sources that 

were encapsulated -- and by their license 

requirements, every six months if they were in use, 

they had to be leak checked to make sure that the 

material was being contained and not lose 

contamination that could potentially be ingested or 

inhaled.

But the notice of violation, honestly, the six-month 

violation was -- they were late by between one and 

eight days. So, it wasn't necessarily that serious. 

Obviously, they were in violation of it.

There was actually a repeat violation. Again, they had 

been noted that in 1991, the same problem that they 
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56

weren't specifically on that six-month schedule. But 

at the same time, the notice of violations did not 

actually indicate any of the sources leaked. So they 

were -- they violated their license by not doing it 

every six months but, again, we don't have evidence 

that those sources were compromised and could have 

resulted in any internal exposures at De Soto.

The TRUMP-S program, we found some 

documentation from 1989 and I kind of alluded to this 

before, where some TRUMP-S materials arrived at De 

Soto, which was the headquarters, essentially, for 

the entire site and it was lost. 

Basically what happened is the material arrived at the 

loading dock. The workers there put it in the standard 

radiological source locker to keep it secure. What 

failed was the paperwork associated with it in that 

health and safety and the radiation control people 

were not notified that this stuff had arrived. And so 

they didn't go and inspect it and swipe it in the timely 

manner required by NRC.

They eventually did find it and the packaging of the 

material was intact. There was no external 

contamination, so no indication that that material 

posed an internal source of exposure.

And also the investigation documents actually 

indicated it was just depleted uranium and some 

plutonium. Americium is not specifically mentioned 

with this incident.

And beyond that, we did not identify any evidence or 

documentation of these TRUMP-S materials actually 

ever being used at De Soto. Our current 

understanding is the material arrived and it was 

eventually transferred over to Area IV. And then they 

didn't actually do any work with it and then, 

eventually, it was shipped offsite to another location 
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57

where they actually did that research.

And lastly, we have the smoke detectors. Based on 

what we've seen in the documents, they didn't 

actually use those until about April 1985 but the 

worry is that if you have americium in a smoke 

detector, if that source becomes exposed, then it 

could become an internal exposure source.

They did the preventative maintenance on these 

smoke detectors right where they were. So that work 

was definitely being done at De Soto. But if the 

smoke detector was malfunctioning and actually had 

to be repaired, it was sent over to the electrical shop 

at Area IV to have the repairs done.

So essentially what we'll be talking about with 

preventative maintenance is going in with rags and 

cleaning solutions and just cleaning them up some.

In the late '80s, they actually had a radiological study 

of this specific potential pathway, that is the workers 

going out and doing the preventative maintenance on 

these americium smoke detectors, what is their 

actual exposure potential. And what was indicated is 

that there is little to no potential really from that 

source. They measured all the cleaning materials that 

were used and they were below the NRC levels for 

release to uncontrolled areas. And the workers who 

were actually involved, directly involved in that 

maintenance activity submitted bioassays afterwards 

and there was no potential activity in those samples.

Continuing on with americium, we did find one 

document of a survey that occurred in the late '80s 

in the Mass Spectrometry Lab, which is in Building 4 

at De Soto. We're going to take a quick look at that 

in the next couple slides but, essentially, it looks like 

the document was edited internally by site personnel 

because what you see is you have these red 
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58

strikethrough marks through certain sentences, 

sentence additions, edits. You'll see what I mean in a 

second.

But what the document does indicate is that when 

they went to go survey these industrial waste drains 

in Building 4, they did find americium in the drain. So 

the question is what was going on that put that 

material there and does that represent an activity 

that could be source of exposure.

The edit notes that there was no documented release 

of americium or plutonium but also it also sort of 

indicates that they couldn't explain it at the time they 

found it, which again was in the late '80s as to how 

it got there. So we're going to take a look at that right 

now.

And you can see what I mean about the editing, 

which clearly went on with this. And what we're really 

looking at, and I'm going to blow it up on the next 

slide, is down towards the bottom right corner you 

see the presence of americium-241 within a drain 

sample and there is sort of -- it's sort of difficult to 

follow.

What I will say is that since we put this presentation 

together you know I kept digging and did find the 

actual source document which talks about this and 

it's exactly what it says. The americium that was 

found in the drain was unexplained but that no 

documented release of plutonium or americium 

occurred.

And this is kind of blowing up that section. You can 

see here it looks like 48 picocurie but I think based 

on the source document that I identified it was 

actually 400 picocurie that was in about 49 grams of 

a sample of -- I don't remember if they referred it to 

slag or what it was but they say soil here.
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59

But again, when they went to go survey some of the 

drains in Building 4, they found americium in the 

drain. So that begs the question how did it get there 

and what operation could have gone on to put it 

there. And does that represent a source of exposure 

that needs to be accounted for?

Moving on to thorium, the NIOSH SEC evaluation had 

identified three distinct thorium operations, which 

are discussed extensively in that report.

The first one was some thorium fuel simulant discs 

which occurred in June 1970. Another one included 

post-test analysis of some thorium that had 

undergone destructive testing. I believe that 

occurred at Sandia and they got the material back 

and then they essentially analyzed it. And the third 

one was the grinding of over 500 thorium plates, 

which occurred in late -- or 1979.

That 1979 grinding operation actually included 

bioassay sampling directly for the workers that were 

involved in it. And NIOSH used that, analyzed that to 

essentially come up with a thorium intake rate, which 

it states in the ER could be used to bound thorium 

exposures to workers in general at De Soto, not just 

the ones that are named with this operation.

Some other activities that we identified with thorium, 

there appeared to be some sort of source program 

going on in what we understand to be Buildings 4 and 

5, which occurred in 1969. We have some personal 

air sampling results from thorium operations, 

including in a room in Building 1. That was also in 

1969.

We have one of those tagged area entry permits that 

talks about inspecting dimensionally, I believe it was, 

of thorium fuel simulant discs that occurred in March 

1970.
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60

We identified personal air sampling with a thorium 

cutting operation. That was in 1971. So again, these 

area activities that we identified in those sort of four 

document types, the HP logbooks, the air sampling 

reports, entry permits, that sort of thing.

And there were several references, including many 

provided by CORE Advocacy that talk about the SRE 

fuel and other materials associated with it that 

arrived at De Soto. But unfortunately, our review of 

that material didn't indicate what the future use was 

Plan B, other than possibly storage, or any 

information about what they were going to do with it 

other than storage.

One confounding thing, and I can probably work with 

Lara offline about this, is that the personal air 

sampling results that we have for a lot of these 

activities are in the units of microcurie hour per cubic 

centimeter. And our understanding, at least at this 

time, and again I can work like I said with Lara 

offline, you need to know how long the operation 

happened to actually convert that into a meaningful 

air concentration for comparison. That would 

important to be able to establish to really know that 

the intakes derived from that thorium grinding 

operation in 1979 are going to be bounding for any 

of these additional activities that we identified.

Moving on to the interviews, in the Evaluation Report 

there's actually just two individuals that were 

interviewed after the submission of SEC-246. One of 

them didn't work at De Soto until the 1990s and so 

they even admit that their knowledge on the subject 

is based on retrospective documentation, things 

exactly like the NIOSH TBDs and Evaluation Report. 

The other one didn't necessarily work in radiological 

areas. In fact, they say they didn't but they were in 

a position where they would have likely had 

knowledge about what was going on but they didn't 
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61

begin work until the late 1970s. 

So again, those were the two documented interviews 

in the SEC Evaluation Report. 

There were seven additional reports that were in the 

SRDB that had been performed prior to the 

evaluation of this petition and were involved in work 

at De Soto but three of them didn't appear to actually 

work during the period of interest, so didn't really 

have relevant information and the remaining didn't 

specifically discuss americium or thorium. Often, they 

were more focused on work that occurred at Area IV, 

not necessarily what was going on De Soto and not 

necessarily what was specific to americium or 

thorium.

There are some more interviews, though, that were 

performed by DOE and EPA sometimes in 

conjunction. These occurred in 2010 and 2011. 

Again, they were mainly focused on former Santa 

Susana Field Lab workers, so Area IV, but that's 

going to include a significant population of those who 

were at De Soto. The document we looked at had a 

total of 121 interview summaries that had been 

cleared for release; 41 of those reported work at the 

De Soto site; and 13 had information that could be 

relevant to SEC-246. Now when I say information 

relevant, what I really mean is based on the 

interview, these people were in a position to know 

about the radiological operations during this period 

we're talking about. But none of these actually 

mentioned specifically work with americium or 

thorium. But again, I guess down the line some of 

these workers might be able to be contacted if it's 

warranted to see what they know specifically about 

the potential exposure at De Soto. 

So again, this was really trying to go through and see 

who is out there and what they have to say about the 
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62

exposure potential there. And this is what we came 

up with. So I mean these are obviously interview 

candidates if we decide to go that route. Now, I don't 

know necessarily their availability at this time. In 

fact, I don't even know their names. They were 

assigned an arbitrary number in the document that 

I'm talking about here but that might be something 

that could be pursued again, if it is deemed 

necessary.

And the last thing we talked about was the claimant 

population. There was about 257 total claims that 

have covered employment at De Soto at the time we 

put this review together. So we looked at the 

Computer-Aided Telephone Interviews for these. For 

a sizeable portion, about 73 percent, and again that 

was based on the job titles and the likelihood that 

that job title would of potentially be involved in 

radiological operations, and we'll see what they have 

to say. Only a small fraction indicated, and again I 

can't give the actual numbers or we don't want to 

give the actual numbers for Privacy Act reasons, but 

it was a small fraction that indicated any exposure to 

thorium and/or americium. But again, at least six 

were conducted directly with an energy employee 

that could possibly be followed up with and talked to 

again to see what specifically they remember and 

what they're talking about. Because again, it's a 

generic sort of interview form and there's a checklist 

of contaminants where you say yes, I was exposed 

to this, no I was not, or I don't know. And oftentimes, 

at least in these cases, americium or thorium might 

have been checked but further information was not 

present at that time. So again, if it's deemed 

necessary, we might be able to talk to these 

individuals further.

And then petitioner-supplied documents. This was 

supplied by CORE Advocacy for Nuclear and 

Aerospace Workers. There were at least 20 primary 
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63

reference documents that were provided that are 

specific to De Soto and also a White Paper that had 

59 individual items identified. And a lot of the 

documents were actually already contained in the 

SRDB but some of them, I believe, were new. And so 

we went through those.

There was also a signed affidavit from a former 

worker. Direct evidence in that affidavit did not 

indicate necessarily potential to americium that was 

unencapsulated, or decladded spent nuclear fuel, or 

actual fabrication operations in thorium. We also --

we did re-interview that worker earlier last month in 

November but the results have not been finalized on 

that interview. So we can't really report back on it 

because, obviously, the interviewee needs to see our 

summary of the interview and correct anything that 

is not correct or add anything that they maybe didn't 

state during that interview.

For the documents provided by the petitioner, SC&A 

went through and reviewed each one but, again, we 

didn't find the evidence necessarily of an internal 

exposure hazard to the americium. A lot of the 

documents indicate spent fuel possibly arriving at De 

Soto but did not directly indicate that that material 

was going to be processed, per se, at De Soto, other 

than possibly stored. We didn't find any evidence of 

the decladding of spent fuel elements, other than 

that one incident I mentioned earlier about the tray. 

And again, we're not sure where that decladding took 

place but we do know there was that contaminated 

tray that had been used on decladded fuel.

And we did not identify evidence of direct processing 

of the SRE fuel rods which contain thorium or other 

thorium activities necessarily in these additional 

documents which would not, to us, indicate a greater 

hazard than the plate-grinding operation in 1979, 

which NIOSH currently proposes for coworker 
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64

assignment.

So to summarize our findings, once again, we noted 

temporal gaps in the available primary 

documentation which is the health physics logbooks, 

tagged area entry permits, contamination smear 

surveys, and the general air sample reports. The 

disposition of any additional documentation we don't 

necessarily know at this time.

Like I just said, we found that logbook entry about a 

contaminated tray that had been used to clean 

decladded fuel. It was in the hood of -- well, I guess 

did I say the chem lab? I guess it was in the fuel 

fabrication area. So it was Building 1, not Building 4. 

And again, if it's decladded fuel, the usual 

assumption is that it was irradiated. And if it was 

irradiated, it could contain transuranic contaminants 

which would include americium and, again, it was 

just called decladded fuel but if it was fuel that had 

thorium as part of its makeup, then it could have also 

represented an exposure source to thorium, as well 

as the transuranic americium-241.

There is that 1997 document, which refers back to a 

1988 document about finding the americium in the 

industrial waste drains and that was in the chemical 

-- or radiological laboratories. And again, we don't 

know where that americium came from. And like I 

said, since the issuance of I guess the preliminary 

report in this presentation, I was able to track down 

the 1988 survey and that's exactly what it says: we 

found americium-241 and we don't know where it 

came from.

And then Finding 4, again, only two individuals were 

interviewed about this specific petition after it was 

submitted. But as I noted, based on the DOE and EPA 

interviews, as well as the claimant population, if it's 

deemed necessary, there are potential interview 
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65

candidates out there that might have more 

information.

And that is the end of my presentation. Oh, no. One 

more slide here. I'll just read this into the record.

Although SC&A did not find evidence of operational 

processes involving unencapsulated americium at De 

Soto, at least one incident of material potentially 

contaminated with transuranic material associated 

with decladded fuel was identified. Furthermore, it 

appears that americium was detected in the Mass 

Spectrometry Lab drain samples in 1988 whose 

provenance is unknown.

SC&A has not identified direct evidence of thorium 

operations occurring at De Soto during the period 

under evaluation that would not be bounded by the 

calculated intake rates derived from the 1979 

grinding operations that is being proposed for 

coworker application.

However, we noted significant temporal deficiencies 

in the available primary documentation of health 

physics activities at De Soto. Again, those are the 

logbooks, area surveys, entry permits, and air 

sampling. 

And the available documented interviews directly 

associated with radiological conditions at De Soto 

under evaluation are currently -- clearly limited at the 

current time. Again, essentially just those two 

individuals who were interviewed directly about 

potential americium and thorium exposure at De 

Soto.

So the next slide is just a place holder based on what 

discussions we have today for the Board meeting 

going forward.

So with that, I'm going to get a quick drink of water 
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66

and would be happy to answer any questions.

Member Beach: Thanks, Bob. This is Josie. First of 

all, thanks for numbering your slides. That's always 

helpful when you want to go back and refer to a slide. 

I'm actually not going to do that but I do have a 

question for you or for Lara.

Operational information for De Soto, is there 

something out there that says that this was the 

mission -- I mean it's a 30-year timespan and I'm 

sure it changed numerous times over the years, but 

is there anything that we can grab onto that might 

give us some indication of why there was americium 

in the drain line or that tray you kept mentioning that 

they found with thorium?

Mr. Barton: This is Bob. I can take a crack at it. Again 

with the americium in the drain, when they found it 

they didn't know where it came from. And we haven't 

identified anything from that area or from previous 

time periods. I mean it might even be possible that 

it's been there since the start of the Mass Spec Lab. 

I don't know and we haven't found any timely 

documentation on that.

Again, a lot of this information comes from your daily 

logbooks, and area smear surveys, things like that, 

air samples for specific individuals that indicated 

either thorium work, for example, the 1971 worker 

who was cutting thorium oxide but that's based on 

an air sample. We don't have a planning document 

necessarily saying you know this operation is going 

to occur on this day for this worker, like we do have 

for those three documented thorium campaigns 

which are presented in NIOSH's Evaluation Report.

Member Beach: Okay. It seems to me like it would 

be a good idea to go and interview more workers that 

may have specific information for that time period. 
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67

So that was a -- I know you didn't throw it out as a 

suggestion, just a possibility, but it might be 

something to look at.

Mr. Barton: You're correct. My main intent with that 

discussion was to say if that's something we want to 

pursue, there are certainly some avenues and 

individuals that we identified through our review that 

might be helpful but I don't know of their necessary 

availability or even what knowledge they might have. 

But based on -- if it's the claimant population based 

on the CATI interviews or Department of Labor 

statements, they certainly seem to be in a position 

where they would have knowledge if it was out there.

Mr. Katz: Are there other questions from Work Group 

Members or from Lara?

Chair Schofield: I don't have any questions at this 

time.

Dr. Hughes: This is Lara. I don't have any questions 

at this time.

Member Field: This is Bill. I agree with Josie's 

suggestion about additional interviews. I think it 

would be helpful.

Mr. Katz: Andy, any thoughts?

Member Anderson: No, I think that's probably the 

next step is if there are some individuals who might 

have been there and been involved in operations that 

would have had some information on that, that would 

be certainly helpful. I mean there seems to be an 

indication that you know it's been identified but we 

don't have detail on how frequently or where it may 

have came from and that's -- that's something if we 

can track that down would be very helpful.

Chair Schofield: I've got just one question. When 
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68

we're talking about the amount of americium that 

went through the soil through there, are we talking 

about a matter of grams or kilograms?

Mr. Barton: Lara, please correct me if I'm wrong. I 

think the quantity they generally used was activity. 

And I think they were licensed to have up to 10 

millicuries, again, and that was for the purposes of 

fabricating other sources for offsite parties. What we 

did not necessarily find was them actually necessarily 

ever doing that. We know they had the sources there. 

We know they had to be leak-checked. I noted the 

notice of violation and that they were a little bit late 

in doing it every six months but we know that they 

had americium sources there. I guess the question is 

whether they actually handled unencapsulated 

material.

And then, obviously, the other sources of potential 

exposure would have been if they're handling or 

processing decladded spent fuel. When you put the 

fuel in the reactor, it creates all sorts of transuranics, 

which include americium. And that was a source of 

exposure for workers at Area IV. Again, we're trying 

to figure out whether a similar situation also existed 

at De Soto, where you're handling and processing 

spent fuel that doesn't have its cladding on it and 

that's exposing that transuranic material to where it 

could be possibly inhaled or ingested.

Mr. Katz: Phil, do you have other questions?

Chair Schofield: No, I was just thinking that -- I mean 

there's nothing here that indicates really what they 

did. What they possibly did is an open question that 

we need answered.

Mr. Katz: Well I think that's why Bob, and Josie, and 

Bill Fields suggesting maybe at least one way to 

follow-up on that question might be to interview 
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69

some people who were present at the time periods of 

interest.

Chair Schofield: Yes, I agree with that. I was just 

curious about the kind of like this is actually a fairly 

small operation and as far as quantities go.

Mr. Katz: Right.

Member Anderson: Well, it says it's limited to the 

laboratory, where they maintained these basically as 

QA/QC.

Ms. Blaze: This is D'Lanie.

Mr. Katz: Before you get there, D'Lanie, wait. Can we 

just finish up?

Ms. Blaze: Yes, let me know.

Mr. Katz: So, Lara or Bob, I mean is there any way 

of figuring -- is there data information on what the 

quantity was in the drain, if that's at all indicative of 

how much of an operation there could been, whether 

it's a lab-scale thing or something more substantial?

Mr. Barton: I believe the quantity was 400 picocurie 

that they had found in the industrial drain. And again, 

even when they found it, the site people didn't know 

how it got there.

Mr. Katz: No, I'm not interested in how it got there. 

I'm just -- what -- for the rest of us, you have no idea 

what that means, 400 picocuries in terms of what 

kind of quantity of material they're talking about. You

or Lara, can you sort of shed light on how significant 

that is?

Mr. Barton: Not with any confidence. I mean that's 

what they found at that time. We don't know when it 

got there. We don't know what the operation was. We 
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70

don't know -- we know that's what was in the drain 

but I mean is that the quantity used in whatever 

operation that got it there? I can't in good conscience 

try to guess at that.

Dr. Neton: Ted, this is Jim. I think -- Bob, did you say 

it was 400 picocuries of 40 grams of material?

Mr. Barton:: Yes, I think it was 400 picocuries --

Dr. Neton: That's 40 picocuries of americium per 

gram of material, which is a fairly low specific amount 

of activity. It would be -- that would not, in my mind, 

represent a very huge exposure potential. You'd have 

to generate a large airborne concentration of that 

material to get any kind of dose.

But Bob, I think what Bob is alluding to is what 

actually got the material in the drain in the first place.

Mr. Katz: Right, we don't know that. We don't know 

that.

Dr. Neton: That's more of the issue, I think, not 

necessarily that there's material in the drain, 

although that is an issue as well, but that's a minor 

issue related to what might have generated that 

contamination.

Mr. Katz: Right.

Dr. Neton: It's suspicious to me that it is americium 

only. I did some calculations based on ingrowth. I 

don't think it would be that from like plutonium-241 

source term. This is the first I've seen this, well, since 

I read about it in the report. 

We need to take a look at it and evaluate it. I think 

that's in general what we need in the path forward is 

NIOSH needs to react to SC&A's review.
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71

Petitioner Questions/comments

Mr. Katz: Yes.

If there aren't any other questions, then it's time I 

think for D'Lanie to have her comments and

questions. Yes, D'Lanie.

Ms. Blaze: All right, thank you, Ted.

Mr. Katz: Sure.

Ms. Blaze: Of course I'll address all of this in more 

detail at the Work Group meeting but I want to just 

touch on the fact that since the beginning of the dose 

reconstruction project, it's been accepted that Santa 

Susana, and Canoga, and De Soto's missions and 

goals were the same, that their workers were the 

same, their contract and contractors were the same 

during the same time period. They shared materials. 

They shared fuel. They shared record-keeping 

programs and, as a result, they share the same data 

limitations.

And so NIOSH considers these sites to be the same 

operationally and contractually, and they always 

have, since the beginning. 

The Site Profile, the NIOSH Technical Basis 

Document, I just wanted to touch on briefly. The 

occupational and environmental PDF, there's two 

tables that apparently confirm the presence of 

americium and thorium at the De Soto facility 

between 1959 and 1999. And those can be found on 

page 9, Table 4.1 and page 12, Table 4.3.

And then we also had the DHS verification survey of 

the Mass Spec Lab at Building 104, which confirmed 

the presence of americium and thorium. And that 

further supports SC&A's Finding 2 of the 

contaminated tray and also their reference to the 
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72

contaminated waste streams.

So given the fact that NIOSH has always accepted 

that these sites represent the same entity 

operationally and contractually, we have seen SECs 

accepted in past together before because of the 

shared similarities and the undocumented worker 

rotation. And now there is no evidence that there was 

any effort whatsoever to confine americium and 

thorium to Santa Susana or to restrict those 

materials from existing at the De Soto facility.

It seems to me that SEC-246 should be a pretty easy 

thing to accept because I think in passing SEC-234, 

most of the work really here has been done.

I just want to thank everybody for their hard work 

and their attention to detail. And I look forward to 

seeing you guys in Redondo. And I hope that you'll 

take a look at those Technical Basis Documents that 

reference americium and thorium at the De Soto 

facility between now and then. Thanks.

ABRWH December meeting plans/other follow-up

Mr. Katz: Thank you, D'Lanie.

Path forward for the Board meeting, we have the 

SC&A presentation which Bob can update, just to 

cover what's been discussed at the Work Groups and 

you talked about a possible path forward to talk 

about with the full Board in terms of pursuing more 

interviews.

Is there anything else you want -- Board Members 

want to add about that presentation? So we don't 

have NIOSH presenting, just SC&A, which I think is 

fine and appropriate. And of course, we'll have 

D'Lanie commenting at that time formally in however 

way you would wish on this one.
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73

But Work Group Members, do we have anything else 

we want to address for a path forward to the Board 

meeting?

Member Beach: The only thing I would suggest is the 

document that D'Lanie mentioned and I don't know 

offhand if that's something we might want SC&A to 

look at or comment. I'm just posing that for the Work 

Group.

Mr. Katz: Yes and I mean keep in mind that Lara's 

already covered that, really, work --

Member Beach: The case study? Yes.

Mr. Katz: Yes and the issue is with DOE and DOL.

Member Beach: Okay.

Mr. Katz: It's sort of an indirect matter for what you 

guys are trying to in evaluating the petitions.

Member Beach: Right. I just didn't know if there was 

anything else in it besides what is out of our purview. 

So thank you.

Ms. Blaze: Was that Josie that just asked that 

question?

Member Beach: Yes, it was Josie.

Ms. Blaze: It's me, D'Lanie. Were you asking about 

the case study or were you asking about the NIOSH 

Site Profile document?

Member Beach: No, I was asking if it was something 

we would want SC&A to pursue. I was asking that of 

the Work Group Members.

Ms. Blaze: Of the case study or of the Site Profile?

Member Beach: No, the case study.
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74

Mr. Katz: The case study.

Ms. Blaze: Okay, thanks.

Member Beach: Okay and no, I understand that's 

probably not appropriate at this time.

Mr. Katz: Work Group Members, anything else for 

path forward for the Board meeting, for work that 

must be tasked after we discuss this with the Board?

Okay. Okay, well, then I think it's pretty clear what 

we need to do to be ready for the Board meeting. And 

also I'll just say, D'Lanie, since you're on the line, I 

mean we will get these SC&A reports to you before 

the Board meeting, I certainly hope. They were just 

cleared by DOE but they should be -- so they should 

be ready pretty soon to get to you and also the parts 

for the Board meeting.

Ms. Blaze: I sure appreciate it, Ted. Thank you.

Mr. Katz: Yes, sure.

And I think then, I think we've covered the waterfront 

for today's meeting, unless anyone has anything else 

to add before we close.

Chair Schofield: Not at this time.

Mr. Katz: So thank you, everybody. And I think, 

based on this discussion again, we probably can 

shrink the time a bit for this session. It's also not an 

actionable item for the upcoming Board meeting and 

we probably allotted more time than we need for this. 

I mean I'll check it on the -- what I have on the 

agenda but I believe that we have probably an hour 

and a half for this and we probably don't need an 

hour and a half.

Chair Schofield: No.
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75

Adjourn

Mr. Katz: We can probably shrink it down, yes.

Okay, so thank you so much, everybody. And thank 

you, D'Lanie for joining us for this meeting. And we 

will see you next week. 

(Whereupon, the above-entitled matter went off the 

record at 12:14 p.m.)