THE U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES 

PUBLIC HEALTH SERVICE 

CENTERS FOR DISEASE CONTROL AND PREVENTION 

NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 

convenes the 

THIRTY-THIRD MEETING 

ADVISORY BOARD ON 

RADIATION AND WORKER HEALTH 

VOL. I 

DAY ONE 

SUBCOMMITTEE MEETING
 

The verbatim transcript of the Subcommittee 

Meeting of the Advisory Board on Radiation and 

Worker Health held at the Knoxville Marriott, 

Knoxville, Tennessee, on October 17, 2005. 
 

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C O N T E N T S 

October 17, 2005 

WELCOME AND OPENING COMMENTS 

DR. PAUL ZIEMER, CHAIR

DR. LEW WADE, EXECUTIVE SECRETARY 

CONFLICT OF INTEREST 12 

MS. LIZ HOMOKI-TITUS 

BETHLEHEM SITE PROFILE REVIEW: 15 

SC&A PRESENTATION, DR. JOHN MAURO 15 

NIOSH PRESENTATION, DR. JIM NETON 53 

CONGRESSIONAL ADDRESS 88 

MR. JASON BROEHM 

SRS SITE PROFILE REVIEW 94 

SC&A PRESENTATION, MS. KATHY ROBERTSON-DEMERS 94 

NIOSH PRESENTATION, DR. JIM NETON 110 

Y-12 SITE PROFILE REVIEW 126 

SC&A PRESENTATION, MR. JOE FITZGERALD 126 

NIOSH PRESENTATION, DR. JIM NETON 142 

ROCKY FLATS REVIEW STATUS REPORT 156 

DR. JOHN MAURO, SC&A 

SC&A CONTRACT TASK III REVIEW, NIOSH PRESENTATION 163 

MR. STUART HINNEFELD, NIOSH 

COURT REPORTER’S CERTIFICATE 178 
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TRANSCRIPT LEGEND 

The following transcript contains quoted material. Such 

material is reproduced as read or spoken. 

In the following transcript: a dash (--) indicates 

an unintentional or purposeful interruption of a 

sentence. An ellipsis (. . .) indicates halting speech 

or an unfinished sentence in dialogue or omission(s) of 

word(s) when reading written material. 

-- (sic) denotes an incorrect usage or pronunciation 

of a word which is transcribed in its original form as 

reported. 

-- (phonetically) indicates a phonetic spelling of 

the word if no confirmation of the correct spelling is 

available. 

-- "uh-huh" represents an affirmative response, and 

"uh-uh" represents a negative response. 

-- "*" denotes a spelling based on phonetics, 

without reference available. 

-- (inaudible)/ (unintelligible) signifies speaker 

failure, usually failure to use a microphone. 
 

 

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 P A R T I C I P A N T S 

(By Group, in Alphabetical Order) 

BOARD MEMBERS 

CHAIR 

ZIEMER, Paul L., Ph.D.

Professor Emeritus 

School of Health Sciences 

Purdue University

Lafayette, Indiana 

EXECUTIVE SECRETARY 

WADE, Lewis, Ph.D.

Senior Science Advisor 

National Institute for Occupational Safety and Health

Centers for Disease Control and Prevention 

Washington, DC 

MEMBERSHIP 

ANDERSON, Henry A., M.D.

Chief Medical Officer 

Occupational and Environmental Health

Wisconsin Division of Public Health 

Madison, Wisconsin 

DeHART, Roy Lynch, M.D., M.P.H.

Director 

The Vanderbilt Center for Occupational and Environmental

Medicine 

Professor of Medicine 

Nashville, Tennessee 

GIBSON, Michael H.

President 

Paper, Allied-Industrial, Chemical, and Energy Union

Local 5-4200 

Miamisburg, Ohio 
 

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GRIFFON, Mark A.

President 

Creative Pollution Solutions, Inc.

Salem, New Hampshire 

MUNN, Wanda I.

Senior Nuclear Engineer (Retired)

Richland, Washington 

PRESLEY, Robert W.

Special Projects Engineer

BWXT Y12 National Security Complex

Clinton, Tennessee 

ROESSLER, Genevieve S., Ph.D.

Professor Emeritus 

University of Florida

Elysian, Minnesota 

STAFF/VENDORS 

LASHAWN SHIELDS, Committee Management Specialist, NIOSH

STEVEN RAY GREEN, Certified Merit Court Reporter 
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AUDIENCE PARTICIPANTS 

ADCOCK, DAVID, Y-12

ANDERSON, LYNN, SRS

BEATTY, EVERETT RAY, SR., FERNALD ATOMIC COUNCIL

BEHLING, HANS, SC&A

BEHLING, KATHY, SC&A

BOGARD, RHONDA, Y-12

BROEHM, JASON, CDC WASHINGTON OFFICE

BRYNESTAD, ASTRIS, Y-12

CLELAND, REINA

CROWE, BILL, X-10

CROWE, ED, X-10

DEHART, JULIA

DUNCAN, ASPASCIA, CLAIMANT SPOUSE

DUNCAN, THOMAS N., BWXT Y12

ELLIOTT, CHARLES C.

ELLIOTT, CONNIE, ENERGY RESERVE CENTER

ELLIOTT, LARRY, NIOSH/OCAS

FITZGERALD, JOSEPH, SC&A

HALL, HUBERT T.

HALL, LAWRENCE R., X-10

HENSHAW, RUSS, NIOSH/OCAS

HINNEFELD, STUART, NIOSH

HOMOKI-TITUS, LIZ, HHS

HOWELL, EMILY, HHS

HUMPHREYS, IDA, NIOSH

ISHAK, LAURIE, OCAS

KATZ, TED, NIOSH

KERR, ,GEORGE, KERR CONSULTING

KOTSCH, JEFF, DOL

LAWSON, J.H., BWXT-Y12/ATLC

LAYMAN, RANDY D., CLAIMANT

LIPSZTEIN, JOYCE, SC&A

MAKHIJANI, ARJUN, SC&A

MAURO, JOHN, SC&A

PIERCE, WILLIAM, X10-Y12-K25 K33

PRESLEY, LOUISE S., WIFE OF ROBERT PRESLEY

ROBERTSON-DEMERS, KATHY, SC&A

RYAN, MAXINE, Y-12

SAMPSON, BOB, GAO

SCHAUER, DAVID, NCRP 
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SIMS, JOHN, IGUA

SMITH, KAREN D., Y-12

SNELLINGS, HOWARD

TOOHEY, RICHARD, ORAU

WALKER, ED & JOYCE, BSAG

WOODY, RUTH, CLAIMANT

WORMSBY, PATSY E.

WRIGHT, BETTY R., Y-12

ZIEMER, MARILYN 
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P R O C E E D I N G S 

(10:00 a.m.)

WELCOME AND OPENING COMMENTS 

DR. PAUL ZIEMER, CHAIR

DR. LEW WADE, EXECUTIVE SECRETARY 

DR. ZIEMER: Good morning everyone. I'm going to 

call the meeting to order. This is the subcommittee 

for dose reconstruction and site profile reviews. 

This is not the full Advisory Board committee 

meeting. I hope everyone's aware of that. The 

subcommittee, the way this board is structured all 

members of the board are permitted to participate in 

the subcommittee meetings. So you have a good number 

of board members are actually here this morning 

although it is actually a subcommittee meeting. 

Anyway, we welcome you to Oak Ridge. I feel like 

I can actually welcome people to Oak Ridge since this 

is kind of a homecoming place for me. Marilyn and I 

spent the first year of our marriage -- I say Oak 

Ridge, welcome to Knoxville which is a suburb of Oak 

Ridge. But Marilyn and I spent the first year of our 

marriage in Oak Ridge, so it's kind of homecoming, 

old stomping grounds. We've always loved this area. 

We love coming back here to the general area and 

Smokey Mountains and surrounding lakes and so on. 

We have a rather diverse agenda for the 

subcommittee. It includes things ranging from 

Bethlehem Steel in New York all the way to Rocky 
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Flats, Colorado, and things in between. So a number 

of items that we will be discussing some of which 

will be updates, some of which will help us define 

some of the issues relative to NIOSH's reports and 

the reviews by our contractor. 

Before we get into the main agenda, we do have a 

few business items and things to take care of. Let 

me begin with the usual things, and that is to remind 

everyone to register your attendance with us. 

There's a registration book out in the corridor. If 

you've not already done so, please do that at the 

break. This is everybody, board members, staff 

people, members of the public. 

Also, if you are a member of the public and wish 

to make public comment during the public comment 

session which will be a full board session late this 

afternoon, please register for that as well in the 

appropriate spot there in the corridor. 

Our designated federal official is Dr. Lewis 

Wade, and he's going to make a few remarks at this 

time, Dr. Wade. 

DR. WADE: Thank you, Paul. 

Well first, let me welcome you on behalf of the 

Secretary and the Director of CDC and John Howard, 

the NIOSH Director. We appreciate your service. 
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It's a wonderful time to be alive. It's a wonderful 

time to be here where we are enjoying this beautiful 

weather and doing this most important business. I 

think this board has shown its ability to take on 

unbelievably difficult issues and work them through 

with quality and dignity. And I thank you very much 

for that. It's been a pleasure to be associated with 

the board. 

I will report to you that Secretary Leavitt 

signed the designation of the later years of 

Mallinckrodt on Friday and has sent it on to 

Congress. So a long ordeal I know for you and for 

many, but it's been brought to fruition with the 

Secretary following your recommendation and sending 

that recommendation on to the Congress. 

A couple of things I'd like to talk about, and 

I'll talk about them again tomorrow as we sort of sit 

here now and look forward. We have a board meeting 

scheduled for the end of January. At that board 

meeting we very likely will be looking at SEC 

petitions for Rocky Flats and also for the later 

years of Y-12. 

As I said, we look forward to January. On that 

agenda we're very likely to have SEC petitions in 

front of the board for action for Y-12 and for Rocky 
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Flats. I don't have to remind any of you of the pain 

we went through in terms of Mallinckrodt when we were 

trying to do a site profile review at the same time 

we were trying to do an SEC petition review. 

I think it's critical, therefore, that as the 

subcommittee and then the board looks forward towards 

the end of January that we put in motion everything 

we need to have done to bring us to a position where 

you can make a decision on the SEC petitions for Y-12 

and Rocky Flats at the end of January. We've got 

time between now and then. We have good people doing 

work for us, and I think it’s terribly important that 

we imagine a strategy that will bring you to late 

January and position the information you need to make 

those most important votes. 

We also have in front of us a longstanding issue 

relative to the Bethlehem site profile or Technical 

Basis Document. Again, it's been a long and arduous 

journey that's taken us to this point. We need to 

think hard about those actions both today and 

tomorrow. 

And then we can't forget there are many other 

things that are sort of sitting without direct 

attention, and we need to put our minds to those. 

There are petition, there are reviews of site 
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profiles for Hanford and the Nevada Test site, and 

we'll talk about those through this week. But 

there's much work for the board to be done. 

So I congratulate you on the work you've done to 

this point. We've come through some very difficult 

issues with regard to SEC petitions for Iowa and 

Mallinckrodt, but there's still a great deal to do. 

And I think we need to take the lessons learned, 

particularly from Mallinckrodt, and apply them to the 

things that are in front of us. Thank you. 

DR. ZIEMER: Thank you. 

On the agenda you have an item called approval of 

minutes, and we're going to defer action on those 

since the copies are not to you at this time. We 

will pick that up later in the meeting. 

CONFLICT OF INTEREST 

MS. LIZ HOMOKI-TITUS 

There are a couple of other sort of housekeeping 

items, however. The first has to do with conflict of 

interest, and we're going to call on counsel to give 

us the latest views on that. So Liz is approaching 

the mike now, and Liz, please define what the issue 

is for the group, and what the Department's position 

is. 

MS. HOMOKI-TITUS: Thank you, Dr. Ziemer. 

Good morning. I just wanted to let you know as 
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far as the site profile reviews and recommendations 

that you all will be making to the Secretary, the 

Department has determined that it is very important 

that we have the comments of board members who may 

have expertise at those sites during the discussions. 

But we ask that each board member who has a issue 

with a site or has worked at a site as it's listed in 

your waiver letters, recuse yourselves from approving 

and voting on recommendations that are going to the 

Secretary. So again, we ask that you remain in the 

discussions and provide your expertise, but since 

those site profiles will affect dose reconstructions 

and SEC reviews that could affect you from those 

sites, we ask that you recuse yourselves from voting 

on those issues. 

DR. ZIEMER: Thank you. 

Board members, are there any questions on that? 

And just let me ask one, Liz, for clarification. For 

example, Y-12 as a site, this means that Mr. Presley 

could be involved in all of the discussions on that, 

but if we had a specific action, either on the 

recommendation on the profile itself or on an SEC 

petition dealing with that site, then he would 

recluse himself from a vote. Is that correct? 

MS. HOMOKI-TITUS: That's partially correct. For 
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the site profiles he can participate in the 

discussion but not vote. For an SEC petition, he 

would have to recuse himself from the whole thing. 

DR. ZIEMER: From the whole discussion. 

MS. HOMOKI-TITUS: Right. 

DR. ZIEMER: So site profiles the discussion is a 

different level of concern than -- 

MS. HOMOKI-TITUS: Right. 

DR. ZIEMER: And then we will also at some point 

need to determine what it means, for example, for the 

Chair who officially worked for Union Carbide at X-10 

but spent a week at Y-12, what that means also. And 

you don't have to answer that now, but I will need to 

determine that. 

MS. HOMOKI-TITUS: Right, well, we can discuss 

that. 

Yes, ma'am. 

MS. MUNN: I noticed in observing my own 

documentation that my only listing did not include 

this full site. It only included the portion of the 

site where I had been employed. So rather than the 

Hanford site, my documentation indicates Westinghouse 

Hanford Company which did not come to the site until 

1970 and did not, and I did not come to the site 

until 1977. So... 
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DR. ZIEMER: Perhaps what we need to do as 

individuals, if you have questions as I did and Wanda 

does and maybe others do, we can work these out with 

counsel individually. 

Go ahead if you have an answer. 

MS. HOMOKI-TITUS: No, I don't have an answer. 

We'll have to look at your specific waiver. Again, 

it may be best that you participate in the discussion 

since you have expertise but recuse yourself from 

voting just so there's no kind of outside looking in 

saying she has a conflict there. Why is she voting. 

DR. ZIEMER: Thank you. 

Then we also have another item that we wish to 

bring before the group. It's from the Congressional 

liaison person for NIOSH, but he'll be back a little 

later, and we'll pick that up at that time. 

BETHLEHEM SITE PROFILE REVIEW 

Then we're ready to begin our deliberations on 

Bethlehem Steel, the Bethlehem site profile review. 

And to get us up to date we have two presentations. 

We have the presentation from the board's contractor, 

SC&A, and then we will have a presentation and 

response by NIOSH and Dr. Neton. And so we'll begin 

with John Mauro for SC&A. 

SC&A PRESENTATION, DR. JOHN MAURO 
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Welcome, John. And I think we have, yes, John's 

presentation, board members, is in your booklet, and 

I believe there's copies for the public on the table 

if you need to get a copy for yourself. 

DR. MAURO: Good morning, everyone. I've very 

happy to be here in the sunshine. Those of you who 

live in the northeast, I would say for at least two 

weeks, maybe three weeks, we had six inches of rain 

that didn't stop. It stopped yesterday but flying in 

here today, I looked out at all the green and lush. 

Feels good today. I feel like I came back to life. 

Okay, Bethlehem Steel. Let’s see if we can get 

the next slide going. There's some history here on 

Bethlehem Steel, and I thought it might be a good 

idea to sort of go back very quickly and come up to 

date. As you recall, there was an original NIOSH 

site profile for Bethlehem Steel that goes back to 

about 2003. I'm not sure of the exact date, but it 

was the first one, Rev. zero. 

When that report came out, we performed the 

review, the limited review about a year ago, about 

October 2004. And there are many issues we raised, 

but when all is said and done, our main concern as 

you recall is NIOSH adopted an approach where they 

used what was called a triangular distribution, data 
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that they acquired from Simonds Saw. And it 

basically said well, we're going to use one size fits 

all, so we're going to say that it's a triangular 

distribution, starts at 0 MAC, Maximum Allowable 

Concentration, which is 70 DPM per cubic meter, goes 

to a peak at 2 MAC and then goes all the way out to 

1000 MAC, big triangle. 

We reviewed that, and I guess we walked away with 

the feeling that, you know, we have a problem with 

that approach on several levels. And this came out 

in our critique of the site profile. We felt that 

when you look at the data, the Simonds Saw data, it 

sure looked like, pretty close to a lognormal 

distribution. And when you take the approach that is 

used at triangular distribution, and you sample from 

it, the way we looked at it is by sampling from the 

entire distribution, one could argue well, that's 

really not necessarily claimant favorable. It' sort 

of claimant neutral. 

Claimant favorable would be, okay, you took the 

distribution maybe, and then you pick off the high 

end. So okay, if you're going to have one size fits 

all, you really want to pick the concentrations that 

are more toward the high end, especially if you don't 

know really where a worker worked. So you say, well, 
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we had the full distribution of, going from zero to 

let's say 1000 MAC, but the problem is if you don't 

really know where the worker worked, it's possible 

that he could have worked in a high end location. 

And what we did find out since that is that 

workers did, in fact, work at particular locations 

the whole time. In other words there were workers 

that worked at the rollers, and that's where they 

stayed, and they worked there those ten hours. By 

the way if you recall, they worked on weekends. The 

approach is every one weekend a month for two years 

or perhaps four years. 

So the concern we had was, in essence, with the 

original report. The triangle distribution really 

wasn't the correct distribution to represent the 

data. And second, given that you could construct a 

more realistic distribution, perhaps lognormal, if 

you're going to go with one size fits all, you've 

really got to go with some high end number, maybe a 

95th percentile value as a one size fits all rather 

than sampling from the whole triangle which is really 

claimant neutral. 

Now appropriately NIOSH pointed out, but wait a 

minute, now the Simonds data is very, very 

conservative as applied to Bethlehem Steel because 
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there's lots of reasons, and they're listed in 

detail, of why Simonds was a very, very, I guess, 

conservative representation. And it mainly had to do 

with the salt bath versus the lead bath versus no 

bath. When you have a salt bath which is what 

Bethlehem Steel used at least in the later years or 

later year, you really reduce the potential. 

So the original approach -- now, you've got to 

keep in mind the original approach was use Simonds' 

data, construct triangle distribution and sample from 

it one size fits all. And we gave our criticism on 

that basis. Let's move on now. In fact, let's keep 

going. 

Then Rev. two came out from NIOSH basically 

reacting to some of these comments. And Rev. two did 

something which basically got rid of the triangular 

distribution and went toward the lognormal. It took 

the Simonds' data, took all the data, fit it to a 

lognormal distribution, and plucked off the upper 

end, 95th percentile, which was 550 MAC, okay? That 

was a big change, a very claimant favorable change. 

And they said we're going to use that number. We 

accept SC&A's criticism about the triangle. We 

accept the idea they really should pick a high end. 

So they went ahead and did that. 
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But then they did something else, and this was a 

little bit, this is where things start to get 

interesting. They say well, we're going to use 

Simonds Saw data for 1949-1950 and pluck off the 95th 

percentile, 550 MAC, one size fits all for those two 

years. But for 1951 and 1952 we're going to use 

Bethlehem Steel data. We're not going to use Simonds 

Saw data; we'll use Bethlehem Steel data, and we're 

going to do the same thing. 

We're going to take that data from '51 and '52, 

throw it in the pot, fit it to a lognormal 

distribution, pluck off the upper 95th percentile from 

that, and use that as a one size fits all for 1951 

and 1952. That concentration turned out to be 20 

MAC. So what we have now is as of the Rev. two to 

the TBD was really a two-step process now. We use 

550 MAC for 1951, 1949 and 1950 and 20 MAC for '51 

and '52. 

Now there was a lot about that that troubled us. 

In fact, we submitted a report on September 27th , 

relatively recently, which was our critique of that 

work. It took some time for us to get back and to 

look at that issue. And our concern with that -- 

well, let me go through a process that took place. 

We issued a report on the 27th . Then there was a 
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series of interactions whereby once we issued that 

report, and in effect, the report said the following: 

Our report said when we look at the Bethlehem Steel 

data that's available to us, we've got some problems 

with it. In other words, we're a little concerned 

that you went from using solely the Simonds' data, 

now we're using Simonds' data for two years and 

Bethlehem Steel data. So we took a really close look 

at the Bethlehem Steel data, and we had some problems 

with the data. 

The problems with the data really stemmed from 

the fact that the data for 1951 was illegible. So 

there was a lot of numbers for '51 that we couldn't, 

we didn't know what they were. We also looked at the 

data from the point of view of it looks like the data 

that you do have is heavily general air samples and 

light on breathing zone samples. And we also noticed 

that when you do make, we look at the breathing zone 

samples versus the general air samples, it looks like 

there really isn't much difference between the two. 

Now if you look at the Simonds' data, and you 

look at the breathing zone samples, and you look at 

the general air samples, you consistently see a large 

difference whether you look at the highest values; 

you look at the average values, look at the 50 
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percentile, median values. Whatever values you look 

at the breathing zone samples collected from Simonds 

are always higher than the general air samples at 

Simonds. But that's not what we saw in looking at 

the Bethlehem Steel data. 

So we had two problems with the Bethlehem Steel 

data. The problems being we really couldn't read the 

data for 1951, which was an important year because 

that was the transition year where they were 

installing the new technologies to try to lower the 

dust loading. And so we're missing some data, and 

this ratio just didn't make sense to us. That is, 

why is it that the breathing zone samples are not 

substantially higher than the general air samples? 

Well, so that was our reaction. Well, what 

happened was -- and that was our report on September 

27th . The next thing that happens is October 4th , 

NIOSH was able to track down what they called the 

onion-skin original sheets that really were prepared 

back in 1951 where you could read the numbers. So we 

got a hold of the numbers; NIOSH got the numbers; we 

got the numbers, and you could read the numbers. 

Aha! A big problem with the Bethlehem Steel data 

that we had where we were missing all these 1951 

data, we have them now. That's important. 
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So now we've got to regroup and say, well, wait a 

minute. We've got a lot of data now. Maybe we could 

use it to see what we can do with it. Let's work 

with it. We had a meeting on October 6th . We had a 

working group meeting. Mark was there and others 

were there. I didn't make it. I was out. I had the 

flu. 

But then, and now remember now, we had these data 

as of October 4th . And if you look at one of these 

data sheets, you'll see there's a whole list of 

numbers and right next to each number, the air 

concentration, it gives you the location that it was 

taken from. Our crew sat together and said well, 

what do these locations mean? I mean, let's let the 

data speak to us. What do they tell us? We couldn't 

figure it out, so we don't really know what each of 

these little identifiers mean. 

So Arjun, on Sunday on the -- what date was that, 

the Sunday? The ninth? The ninth -- flew up to 

Buffalo, met with Ed Walker and two of his coworkers 

who worked at the facility for many, many years. And 

they sat down and they talked through each label. 

What do these labels mean, the shearer, a whole bunch 

of different names of, that are given to where the 

sample was taken. So we're starting to get an 
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appreciation what the data say and where they were 

taken. Let's keep going. 

Now so we got to the point now I think we 

understand what the data are. And given that we have 

these data now, and we consider now a complete set of 

data. We understand them, in fact, we actually made 

a drawing. We sent out our report on Friday 

afternoon electronically. 

I realize it was like the eleventh hour, but our 

report, a letter report would go out electronically. 

And we actually had the drawing back there. What was 

done. This is the first time I think, anyone made an 

attempt at trying to sketch out what Bethlehem Steel 

looked like. And that was done, we really have to 

thank the folks that Ed Walker, his buddies, worked 

with us to lay out what does this place look like. 

DR. ZIEMER: Could we identify, is the drawing 

called Bethlehem Steel Ten Inch Bar Mill line 

diagram? 

DR. MAURO: Yes, that's correct. And that's 

Figure 3-1 in the letter report dated October 14th , 

from SC&A to Dr. Ziemer. 

DR. ZIEMER: Right, thank you. 

DR. MAURO: Okay, now where we are with this 

report now. Now it's caught up. There were 
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originally six issues, if you recall, that were on 

the table. One of them has gone away. The one that 

went away is the oronasal breathing issue. And the 

reason that went away is NIOSH made a very compelling 

case that the uncertainty introduced associated with 

having to model mouth breathers as opposed to nasal 

breathers, or oronasal breathing, the uncertainty 

introduced by that and what it means is very, very 

small compared to the uncertainty in the distribution 

of the concentrations in the dose. 

So it's almost like it's not important. It might 

be important at other sites so, in effect, that at 

this site we could sort of put that one on the shelf. 

It's not important. That doesn't mean we don't have 

to revisit it again, but because it becomes a, I 

refer to it as a policy decision. 

There's no doubt -- just as a quick aside, 

there's no doubt if you assume a person's a mouth 

breather and there's a large fraction of the U.S. 

population that are mouth breathers, that you're 

going to get a different dose than if you breathe 

through your nose or breathe through you nose, 

oronasal breathing, when you start to work hard. 

So whether or not mouth breathing is part of a 

model that should be factored in, that's really a 
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policy call. And but there's no doubt, everyone 

would agree, we agree that there's a large segment of 

the U.S. population that are mouth breathers. And we 

also agree if you're a mouth breather, your dose to 

your lungs are going to be somewhat higher, maybe a 

factor of two or so -- we did the numbers -- than if 

you were just a regular breather like everybody else. 

So it becomes a policy decision whether or not that 

should be explicitly included in doing dose 

calculations or not. 

But for this particular issue it becomes a nonissue because it really is not an important 

contributor to the uncertainty in the dose 

calculation. There are other issues that are by far 

dominate or contributes to the uncertainty. 

So we're left with these five issues. I'm going 

to spend most of my time talking about the first 

issue. We'll quickly go into the other four and 

that'll take five minutes. We're not very far apart. 

In fact, we're not very far apart at all on the 

second to the last four bullets there where we have 

come at it a little bit different. We think our 

approach is a little bit more scientifically robust 

and a little bit more claimant favorable. But 

certainly it is not very far away from the position 
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that NIOSH has taken. 

The place that we are still very far away on is 

the first bullet, and that has to do with the 

following: 

As I understand it -- well, let's start where we 

agree. The data that came in where we were able to 

see legible data for 1951, it's clear now that 

there's a very significant difference, perhaps a 

tenfold difference in the concentration distributions 

between the 1951 Bethlehem Steel data and the 1952 

Bethlehem Steel data. I think we have agreement on 

that. I think both NIOSH and SC&A agree, yes, there 

is a difference there. 

So the idea that we have to parse it one more 

time, say, in other words, we started off there was a 

one size fits all. Took the Simonds Saw and at the 

very beginning and applied it across all four years. 

Now we moved into a mode where we say, well, we've 

got the first two years, '49-'50, which is Simonds 

Saw and then in one of the reports then there was a 

second set of data which was the 20 MAC data which is 

'51-'52. 

Well, we've moved away from that I believe. Now 

we're at the point where we're saying, well, we need 

something for '49, '50 Simonds Saw. We need 
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something for 1951, and we need a separate one for 

'52 because there's a big difference in the Bethlehem 

Steel data between 1951 and 1952. So we've got 

agreement there. 

Now here's where we've got -- item number two. 

Here's where the difference of opinion exists. We 

believe that you can't take the 1951-1952 Bethlehem 

Steel data on face value, and we're prepared to 

discuss this with the working board today. 

I'm looking forward to Jim and his position 

because I realize Jim doesn't agree with this. See, 

we say look at the 1951-1952 Bethlehem Steel data, 

and we say there's a paucity of breathing zone 

samples. Unlike the Simonds Saw data where that 

wasn't the case. NIOSH would like to take all of the 

'51-'52 data, put it in a pot, plot it out, semi-log, 

plot it on a lognormal distribution and pick off the 

upper 90 percentile. Or alternatively, take the 1951 

data and take, separately from the 1952 data, and 

plot each on log paper and pluck off the 95 

percentile from 1951 and a separate log for '52. 

That would be an approach that's very compatible 

and consistent with what was done with the Simonds' 

data. The only problem we have is when you look at 

the Bethlehem Steel data, you see a paucity of 
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breathing zone samples which tells us that they 

didn't catch the full range of exposures. 

So we believe that where the action is in terms 

of protecting the workers, where the workers got the 

most exposures, were at the roller locations. This 

is where the dust was generated, okay? So we're 

saying that we need breathing zone samples from the 

roller locations for '51-'52 for us to start to get 

a, to feel confident that we can bound it. 

In an ideal situation if we had lots of breathing 

zone samples from roller locations in '51-'52 from 

Bethlehem Steel, plucked off the 95th percentile for 

those, I think we've got it knocked. But we don't 

have that. We have general air samples for those 

locations. So we think that, yeah, you've got really 

good data for '51-'52, but you don't have enough 

breathing zone samples from the roller locations 

because that's where I think the action is. 

So we came up with the idea that perhaps you can 

take the data, general air sample data from the 

roller location for Bethlehem Steel, '51-'52, and 

apply an adjustment factor. To say, okay, if we were 

to take, if they did, in fact, take breathing zone 

samples when they took the general area samples they 

also took breathing zone samples in '51-'52 from the 
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roller locations, we'd probably see numbers that are 

a little bit higher. 

And we believe that the numbers would be higher 

by about the same factor of the ratio that we saw at 

Simonds Saw because they did have breathing zone 

versus general air. And there was a several-fold 

difference. It turns out the numbers ran from, I 

think, a low of five to a high of twelve-fold 

difference but consistently different. So we're 

saying, okay, let's use the Bethlehem Steel data, but 

I think we need to tweak it a little bit. We've got 

to make an adjustment for the paucity of breathing 

zone samples. 

Finally, this slide, I really told my whole story 

by looking at -- we're going to back up a little to 

reinforce some of the points I've made. This plot 

gives you -- we call it the period one, period two. 

I refer to it as 1951, 1952 data plotted for the air 

sample. You could see that the red line which 

represents period one, '51, is substantially higher, 

especially when you go out toward the higher end of 

the distribution to the right-hand side. So there's 

really two different populations of numbers here. 

These don't come from the same populations. So this 

is the rationale which I believe, NIOSH agrees, we 
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need to make a distinction between those two years. 

This is, again, points out that, the important 

point is we're looking at the breathing zone samples 

from Bethlehem Steel. You'll notice as we go down on 

the right-hand side, it gives you a number of 

samples. Then you look at the right-hand side, 

you'll see no breathing zone samples, no breathing 

zone samples. It's a recurring theme, and that 

troubled us. 

This is another breakout of the data, but in this 

case we show different percentiles. That is, how the 

plots, it's the same way to show there was a 

difference by period between '51 and '52. It gives a 

little bit more richer breakdown of the data, but it 

makes the same point. These two years are different 

years. 

We also know from reading ICRP 75 that we would 

expect to see a substantial difference between 

breathing zone and general air samples. So between 

the Simonds' data where we really see it 

consistently, a difference, and then, of course, 

there's the generic literature ICRP 75 that says 

you're going to see, you should expect to see 

differences, on that order by the way. You know, 

five to ten or perhaps higher differences, not as the 
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literature says. 

So we walk away with the sense that if you're 

going to use the Bethlehem Steel data, you've got to 

do some adjustments in order to correct for what we 

consider to be a paucity of breathing zone samples 

especially in the vicinity of roller stands. But I 

think an important point is that we're zeroing in on 

that population group, the folks who worked at the 

rollers. Those are the people you want to make sure 

you understood and what kind of exposures they 

received. 

The second period, the, it turns out when we -- 

just as an example, if we take the '51 Bethlehem 

Steel data, and we take the general air samples in 

the vicinity of the rollers, and we multiply the 

general air samples by eight which is the ratio that 

we saw at Bethlehem Steel and which is a ratio that's 

not inconsistent with ICRP 75, lo and behold, the 

upper 95th percentile concentration is 540 MAC, 

basically the same 95 percentile concentration that 

we saw as the upper bound at Simonds Saw. 

So in effect what we're seeing here is it looks 

like the dust loadings in '51 in the Bethlehem Steel 

data are really, at the upper end concentrations, are 

really not that different than the concentrations 
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that were seen in Simonds Saw. But then when we do 

the same thing for 1952, we take the same batch of 

data, Bethlehem Steel, take the general air samples, 

multiply by eight, get them, get them up. So now you 

say now we've got something representing free 

breathing zone samples. And we take the upper 95th 

percentile, we come up with 22 MAC. 

So in other words, there is, so where we're 

coming out is -- and we're not saying those are the 

right ratios, but we did that to explore, see what 

would happen if we just went with that. But we do 

think that something has to be done with the data. 

So we come out that we have three different time 

periods; we use Simonds Saw 540 MAC or 550 MAC, 1951 

Bethlehem Steel data where you have a number which is 

probably going to be on the order of hundreds of MAC. 

Maybe not 540 but certainly not 20. 

Then we move to '52 where we're saying sounds 

like about 20 might work which is the number 

originally they wanted to use for '51 and '52. So 

the real difference is I think we're coming down in a 

different place for 1951 Bethlehem Steel data. 

What's the right dust loading to use for that year? 

And I think that we're coming in, if you adjust 

the breathing, the general air samples of '51 by some 
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appropriate factor, you're going to come in with a 

number that might be somewhere in the vicinity of 500 

or 400 or 300, you know, depending on what you 

justify. And we didn't take the analysis that far, 

recognizing we didn't run these numbers until we got 

the data back on October 4th . 

So but I think we have a theme that says I think 

we've got a handle on this problem. We've got a 

tractable problem. And the difference between NIOSH 

and SC&A is that we think some adjustment is needed 

on those data, and we'll hear from Jim about why, 

perhaps, we don't. But right now I haven't heard the 

rationale, the why we don't have to make an 

adjustment factor. The data telling me, yeah, we 

need an adjustment factor, and I haven't heard that 

rationale, but perhaps we'll hear some more about 

that. 

Another point that's important is there is 

actually a generic TIB for AWE facilities. And 

interestingly enough it recommends 100 MAC as your 

default value. In other words, if you're going to do 

an AWE facility, and you don't have any data, go with 

100 MAC. So that's part of the soup, so to speak. 

So we've got all these numbers floating around. 

We're troubled by the 20 MAC that originally, that's 
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proposed in Rev. two of NIOSH's report for the 

reasons we gave. One of the reasons also is that the 

generic TIB itself argues for 100 MAC as being the 

default value when you don't have data. So that's 

sort of part of the play. 

So now -- I'm just about done. Thank you for the 

amount of time you're giving me here. I want to move 

on to the other, a couple of other issues. If you 

remember we made a big fuss over cobbles, you know, 

cutting up cobbles, lots of airborne dust. And we 

learned something. We learned something on our visit 

on the ninth with Ed Walker and his friends. We 

found out that when the rods were going through the 

rollers, and they cobble up into spaghetti, the guys 

working the rollers, they don't get involved in that. 

See, we had this thing in our heads, you make 

these models in your head that the guy is working the 

roller and this dust is coming up. Cobble hits, he 

has to go in there now and cut the cobble making all 

sorts of fumes which the concentration’s going to be 

real high, so he's getting whacked by the dust 

loading from the rollers when things are going well, 

and then when he has to go in and cut the cobbles. 

Well, it turns out it doesn't work that way. 

The way it works is there's a crane that comes, 
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whisks the cobble out, puts it over far away from 

where the roller operation is, puts it on a lay down 

area, and someone else takes care of the cobbles. So 

it's not an additive thing. It's almost like a 

different crowd that's going, he'll get exposed. Now 

we don't know how they cut those cobbles. We still 

don't know. We don't know whether they used some 

kind of shear or snipper, or whether they did cut it 

with an acetylene torch. 

Jim made a great point at our working group 

meeting, they can't cut that stuff with a torch. 

It's, you know, it's pyrophoric. I don't know. We 

made some inquiries. We spoke to Ed Walker and his 

friends if they had any experience, personal 

experience and seen how it was done? The answer is 

no information. 

But you know what? We've sort of put that on the 

margin right now to a certain degree because it's a 

separate crowd of people, and yeah, they'll get their 

exposure from cutting up cobbles however they did it, 

but it's not the same people that are at the rollers. 

And right now it looks like the rollers are the guys 

that we're worrying about. So if you're going to 

have one size fits all, it's the roller guys. 

I need to keep going. I'm almost done. We had a 
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couple of other issues that had to do with ingestion 

scenario, the dust ingestion, and also resuspension 

that goes on all the time. Both those, these are 

different than the air inhalation scenarios where 

that inhalation from direct puff coming up while 

you're rolling or cutting is happening only on the 

days when you're rolling. 

But the ingestion scenario and the resuspension 

scenario in theory could be going on all the time. 

During the week while they're working with steel, you 

still have some uranium dust co-mingled in the steel 

filing dust. So there theoretically was something 

going on that we just can't ignore. Well, we came up 

with, NIOSH came up with their approach, and we came 

up with our approach. 

Ingestion, our approach basically starts with the 

premise that the data compiled by EPA and others is 

sort of accepted 100 milligrams per day as being, in 

a dusty environment one would expect inadvertent 

ingestion of soot on the order of that. Now, the 

numbers could be higher or they could be lower, but 

100 milligrams per day looks like a fairly well 

documented, as good as you can document these things. 

Now our position is okay, so on the day of the 

rolling the guy is working. He eats 100 milligrams 
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of uranium dust inadvertently because that's when the 

rolling is occurring, that's when he's covered. And 

if he's going to ingest 100 milligrams that day 

there's probably going to be predominantly uranium 

dust or filings or oxides, flakes. 

However, as each -- now that's on, let's say 

that's a Sunday. When Monday comes along they're not 

rolling uranium any more, they're rolling steel, and 

Tuesday they're rolling steel and Wednesday. So what 

happens is the approach that NIOSH took was okay, but 

one day out of 30 is uranium and the other 29 days is 

steel. So if you got 100 milligrams a day, we'll 

take 100 milligrams, divide by 30, you come up with 

3.3 milligrams per day as your average ingestion 

rate. 

We took a little bit different tack. We said, 

you know, it doesn't really work that way. On day 

one, it's 100 milligrams of uranium. On day two, 

it's 50-50, 50 milligrams of uranium, the second day 

50 milligrams. On day three it's one to three, on 

day four -- so it's sort of like a summation. 

If you do it that way, I think we come in with a 

number a little bit higher, maybe a factor of two 

higher, maybe, I'm not sure of the exact number. But 

the differences are small. But we felt that approach 
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was more mechanistically true to the process that was 

taking place and it ended up being a little bit more 

claimant favorable. 

Finally -- no, the next item is resuspension. 

The approach that NIOSH adopted regarding 

resuspension, again, now we've got all this dust all 

over the place, iron and uranium co-mingled together 

throughout this facility being resuspended. Now what 

NIOSH did is say okay, let's go figure out how much 

dust might be in the air from resuspension. 

So they went to data from Simonds Saw which is a 

couple of days after they stopped operation at 

Simonds Saw. They stopped operation. Nothing going 

on. They go in two days later. They take out an air 

sample, the position being any air dust loading we 

see must be from resuspension because they weren't 

rolling, and they came up with .5 MAC. 

We've got a problem with that because there was 

nothing going on. No one's kicking around working, 

stirring up dust, so we're not really comfortable 

with that. They also validated that .5 MAC by taking 

what they knew to be measured activity on the 

surfaces, on the floor and the tables and applied a 

resuspension factor approach of ten to the minus six 

per meter, and they came up with a number that wasn't 
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all that far removed from the .5 MAC. 

I've got a problem with ten to the minus six per 

meter as a resuspension factor. You look into the 

literature, that's on the low end. In a dusty 

environment, a place where there's soot, people are 

working, they're kicking up dust, it's a lot higher 

than that, at least a factor of ten, maybe a factor 

of 100 or higher. So right off the bat we're a 

little bit uncomfortable with the strategy taken for 

resuspension. 

So we came up with a different approach which may 

be erring on the other side of conservativism now. 

I'll be the first to admit that. What we did is we 

said let's go into Simonds Saw, find out what the air 

sample level is in the general air, not in the 

breathing zone now, in the general air, and we're 

going to make a very conservative assumption. 

We're going to assume that the levels you 

generally receive in the general air samples are from 

resuspension. Now we know that it's really a mixture 

of resuspension and direct puff, but let's just say 

it's resuspension. And we're saying, okay, so that's 

the amount of dust, milligrams per cubic meter, from 

resuspension. We're going assume that based on 

general air samples from Simonds. Then we're going 
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to say that let's assume that's the amount we're 

going to get from resuspension at Bethlehem Steel. 

That is from resuspension. 

And now we're going to dilute that, that's on the 

day of the rolling, in other words, if you have your 

day, rolling is stopped. There's no rolling. Let's 

assume that at that day the activity that's airborne 

that we measure at Simonds Saw is, in fact, the dust 

loading from resuspension from Simonds, okay? Then 

we're going to say on day two, the next day, you cut 

that in half because now you're doing iron, and you 

cut that in half, and you cut that in half, and you 

keep doing that just like we did with the ingestion. 

And what happens is you come up with a different 

approach. Turns out when you do it that way, that 

approach -- by the way, in our original report we 

used the 95th percentile dust loading from general 

air. That was wrong. We made a mistake. The right 

answer, not the right answer, a better answer would 

have been to go with the average or the median which 

we did. We fixed that. 

When you do it that way, and do our approach that 

way, you come up with a dose from inhalation from 

resuspension which is about four times higher than 

the .5 MAC approach that NIOSH came up with. So 
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we're not that far away. 

Now finally, and I'm done, we have some concerns 

with external exposure contact handling. Jim gave us 

some very compelling arguments why that's not an 

issue, and we agree. 

The only place that's a little residual is that 

we're a little concerned that more explicit 

consideration, not so much for contact where workers 

actually handled the rods, you know, touched them, 

picked them up. And the only other thing that sort 

of stays residual on that last issue is clothing 

contamination. That is, if there's dust embedded in 

the person's clothing and sort of stuck on the 

clothing on non-rolling days, whether or not that's 

an issue or not. But again, that's not an issue 

that's going to be important in terms of 

reconstructing doses, but it's the last place where 

we have some concerns. That wasn't really addressed. 

And I think that's it. And I'd like to thank 

Arjun, Bob Anigstein and Harry Chmelynski. I mean, 

they're the ones who crunched the numbers, who worked 

real hard. I basically sat there listening to the 

story to make it all make sense to me so I could try 

to communicate it to you. So I'd like to thank Arjun 

and the crew for that. 
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DR. ZIEMER: Thank you very much, John. Let me 

start a question here, and you can answer or maybe 

Arjun or maybe Mr. Walker. Do we know where the 

general air samples were collected relative to the 

rolling operations? I can imagine cases where 

general air samples and breathing zone samples might, 

in fact, be quite similar depending on where the 

workers were relative to the mills and where the 

general area samples were collected. Do we know 

where they were there or at Simonds relative to the 

workers? 

DR. MAKHIJANI: At Simonds though all of the data 

points are either labeled on the data sheets and 

where their data points are not labeled either 

general air or breathing zone, we have the AEC 

documentation that indicates that the samples that 

were taken at the rollers that are not labeled either 

general air or breathing zone were considered by HASL 

to be breathing zone samples in their calculations of 

time-averaged data. 

DR. ZIEMER: If they were close to the roller. 

DR. MAKHIJANI: Yeah, and since they were using 

them as breathing zone samples and you had NIOSH 

present some testimony from HASL about that, about 

the Simonds sampling, in this analysis we simply 
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accepted that although with some uncertainty with a 

question mark around it. We accepted that those were 

breathing zone samples. 

For Bethlehem Steel we have four different types 

of samples that were taken. There were breathing 

zone samples that are labeled as such and the table 

of that is in your, in the report. There were 

general air samples that were labeled as such. 

Of the labeled samples, there were only three 

breathing zone samples that appeared to be at the 

rollers. They're all associated with the low dust 

salt bath process it seems to us from September '51. 

There are no breathing zone samples associated with 

the lead baths at the rollers which were clearly the 

dustiest location in the early period. 

The unlabeled samples, there are a number of 

unlabeled samples that are set, taken near the 

rollers. A lot of them are in the second period, but 

because we don't have any descriptive documentation 

or time-averaged calculation, it doesn't appear to be 

claimant favorable to assume that breathing zone. 

This set of samples seems to me, I’ve poured over 

the sample descriptions quite a bit, to have been 

taken in the AEC description itself. At least 

indicates that these samples were taken with the idea 
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of understanding the continuous rolling process at 

Bethlehem Steel which was, you know, experimental. 

It was new so it wasn't taken, so we have the 

difficulties arise in interpreting the data partly 

because they're unlabeled and partly because there's 

very little associated documentation in terms of 

calculations. 

DR. ZIEMER: So the assumption is that if the 

sample was taken close to the operation, it probably 

got labeled as a breathing zone sample. By 

implication the general air samples were away from 

the source of generation of the aerosol. Is that --

DR. MAKHIJANI: Well, we don't know how much 

away. I mean, the general air sample on April 26, 

27, 1951, must have been taken fairly close to the 

rollers because there are quite high dust 

concentrations. But when you look at ICRP 75, there 

was quite explicit disc -- on earlier ICRP documents 

and other documentation. There's quite explicit 

discussion that samples that are fixed samples, taken 

in the general air near the working location, can be 

an order of magnitude or two or there's a magnitude 

less than a lapel breathing zone sample. 

So that's where, it's not that they were taken 

very far away. We don't think that they were. But 
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the problem comes in is what's, is there an order of 

magnitude or more difference or could there have 

been. And since we don't know, this is a kind of... 

DR. ZIEMER: And the ones that were labeled 

breathing zone samples are not likely to be breathing 

zone samples in the way we would do it today as far 

as lapel samplers and so on. 

DR. MAKHIJANI: Well, Jim may address this to 

some extent and we also looked at it. For the 

Simonds' data I think there seems to be no 

controversy or difference of opinion between us and 

NIOSH. In this case we accept the breathing zone 

samples that are labeled as such as breathing zone 

samples. However, when I interviewed this one worker 

who wanted not to be named for privacy reasons, but 

as I said on a conference call of October 11th with 

NIOSH -- I just interviewed him on October 9th . 

He's very clear. He has excellent recall as you 

can see from that drawing that he made. He recalls 

every detail of what went on. I mean, it's really 

quite extraordinary. He worked in that area for a 

very long time which is part of the reason. Part of 

the reason is very clear. He worked at the shears 

during the period of uranium rolling, and he 

remembered, he knew at the time that it was uranium. 
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And he does not remember, he might not have been 

there on the day the nine shear samples were taken in 

the breathing zone. So that's one possibility. But 

he does not remember anybody coming very close to him 

to take what he would consider that he was breathing 

although he remembers people sampling in the area. 

So we have much more uncertainty about Bethlehem 

Steel data. That's the short of it. 

DR. ZIEMER: Wanda Munn. 

MS. MUNN: I think I heard in that but just want 

to be sure that we actually do not know where the 

general air samples were taken. 

DR. MAKHIJANI: Ms. Munn, the samples usually 

have a description of the general area where they 

were taken so it will say roller number three or 

roller number one and so on. Now some of those 

samples are, or shearer, and some of those samples 

will be labeled breathing zone, and we assume that 

they're equivalent to a lapel sampler. The ones that 

are not labeled we assume they are near, but because 

there is a big difference between near and a lapel, 

there's a question of how do you interpret those for 

calculating intake. 

MS. MUNN: In my mind the answer is no, we're not 

sure just exactly where the general air samples were 
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taken. 

DR. MAKHIJANI: Yeah, we don't know how far they 

were taken although we know the vicinity in which 

they were taken. 

MS. MUNN: That's what I thought. 

DR. ZIEMER: Mr. Walker, can you add anything to 

that for us? 

MR. WALKER: Thank you. You had some, in the 

interview and you asked the question, I didn't, I 

know Arjun is very familiar with what we done on that 

conference call, but you asked where the breathing 

zone samples were taken in relation to the rollers. 

I got a set when I asked from Oak Ridge, a breathing 

zone sample. Well, I got samples, air samples, and 

the breathing zone samples are something like nine 

out of ten were taken at the shear. 

And that shear actually from the rollers is 

approximately four to five hundred feet away from the 

rollers. And the rollers are considered the most 

contaminated and dusty area. I got a nice set of 

samples, I believe NIOSH had sent it to me, and I 

looked at those, and most of them were taken at the 

run-off. And I can't remember exactly, but like 

maybe four or five were taken at what they call the 

run-off which was another hundred feet, or 
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approximately a hundred feet, beyond the shears. And 

those were breathing zone samples. 

And it's my understanding that there was only two 

breathing zone samples taken at Simonds Saw. These 

are the issues that trouble me. I hope it clears it 

up on just how far away from the basic rollers and 

the dusted area. I hope that cleared it up a little. 

DR. ZIEMER: Thank you. 

(Whereupon, Mr. Griffon 

joined the meeting after 

which the following 

transpired:) 

DR. ZIEMER: Additional questions or comments? 

Yes, Mr. Presley. 

MR. PRESLEY: Bob Presley. Do we have any data 

that shows that the areas were cleaned up prior to 

the rolling? Knowing how valuable this material was 

in '49, '51, '50, do we have any data at all that 

shows that the areas were cleaned up prior to the 

rolling of the uranium on the weekends and then 

cleaned up again after the rolling was done? 

DR. MAKHIJANI: There are two kinds of residual 

uranium about which there's some pretty clear 

evidence. One is the crop ends that were not useful 

were all packaged and taken away in 55-gallon drums. 
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And then there's the question of scale that fell to 

the floor and so on. The scale from the scale pit 

appears so the steel and uranium scale would have 

been mixed up together, would have been loaded off 

onto flatcars and taken off. The areas do appear to 

have been cleaned from time to time in terms of 

hosing down and so on, the best as we can tell. 

DR. ZIEMER: Yes, Roy -- oh, Ed. Ed's got a 

comment on the --

MR. WALKER: Again, with the information and what 

happened to the scaling, I have witnesses that I 

talked to that worked at the plant. And the scaling 

as it rolled, you can see in the picture from the 

plant, the dust from the floor, three, four inches 

thick. That went down and mixed with the steel dust. 

It was run into a big pit outside and the scale was 

loaded onto a railroad car. 

And one of the claimants, not knowing what I was 

talking about uranium, he was describing what 

happened during that time. He worked there at the 

time. The railroad car took it and dumped it on the 

site. And the reason that we know it was left on the 

site is, that we had good reason to believe, because 

the gondolas that they dumped the scale in, the 

railroad cars had no air lines on them. Without air 
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lines on these vehicles, you could not take them onto 

the main track and out of the plant. So we're sure 

they were dumped on the site, and I forgot the other 

question, Bob. 

MR. PRESLEY: That's fine. 

DR. ZIEMER: Roy DeHart. 

DR. DeHART: In mention of digestive 

calculations, you used a progressive dilution. On 

Sunday, we had 100 milligrams of uranium and then 

progressively did over time. However, you didn't use 

a progressive dilution of the steel that had been 

processed. You're assuming on Sunday that it's full. 

That whole 100 milligrams is uranium. Well, in 

fairness, shouldn't you consider the fact that there 

would have been steel contamination in dilution as 

well? 

DR. MAURO: That's correct. Ideally, we had to 

start at a point. We said, listen, how do we start 

this. The day of the rolling we could say that you 

already have in place some inventory of iron oxide 

scale that you're going to add uranium to. We 

decided that since the uranium during the rolling is 

going to be falling and accumulating on top of that 

while you're working, yes, there would probably be 

some co-mingling and using the 100 milligrams per day 
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on that day all uranium is conservative. 

There's no doubt that there's going to be some 

co-mingling with pre-existing, but for two reasons, 

one, we were not quite sure how best to deal with the 

fact that the stuff is falling on top of it, fresh. 

So we said, listen, let's err on the side of the 

claimant and assume that the, of the 100 milligrams, 

given the 100 milligrams, at least on the day of the 

rolling, the majority of what they inadvertently 

ingest is going to be uranium. 

Granted it's going to be something less than 100, 

but we started at that point not knowing how far down 

to go. What kind of co-mingle you would have. Then 

from then on, then we did a sequential dilution. So 

you're absolutely correct. There's a conservatism 

built in starting at that point that there was 100 

percent -- milligrams of uranium on the day of 

rolling. 

DR. ZIEMER: Because the counter argument, of 

course, is if uranium is 50-50 on the day following, 

then the day following steel, steel should be 50-50. 

So you have a factor of two right at the front end, I 

think, is your argument. 

Henry Anderson. 

DR. ANDERSON: Yeah, the 100 is basically taken 
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from the exposure handbook? 

DR. MAURO: Yeah, two places, Exposure Factors 

Handbook and NCRP both recommend that as being a good 

value, two different places. 

DR. ANDERSON: There isn't any general dust 

measurements made in the facility? 

DR. MAURO: No, the ingestion? The amount 

ingested? 

DR. ANDERSON: Well, I mean a hundred -- 

DR. MAURO: A hundred milligrams a day is a 

generic, an inadvertent dust soot ingestion, soil 

ingestion, used widely. 

DR. ANDERSON: Yeah, no, I understand that. I 

just wanted to know. I mean, that's a starting 

point, and it's as good a guess as any, I guess. 

DR. MAURO: Yeah, there are others. For example, 

in the same report, gardeners, people who, 480 

milligrams a day or so. And other places you hear 

people use 50. So yeah, there's uncertainty there. 

NIOSH PRESENTATION, DR. JIM NETON 

DR. ZIEMER: We do need to move along here. We 

need to hear from Jim Neton from NIOSH. 

Jim, let's go with your presentation. 

DR. NETON: Thank you, I assume I have at least 

15 minutes here. 
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DR. ZIEMER: Oh, yeah. 

DR. NETON: I'd like to commend SC&A for their 

tremendous vigor at which they pursued these 

investigations. I mean, they're paid to turn over a 

lot of issues and discover things, and in fact, they 

do a commendable job at trying to poke holes in some 

of the stuff that we've done. I think though in fact 

in some cases they've gone a little bit too extreme, 

and I'm here to discuss that. 

I'm glad to see that we're coming closer, 

although every time we come closer it seems that a 

couple more issues pop up. But if you recall -- I'll 

go back and do a little historical review of my own. 

If you recall the first review of SC&A, they 

speculated that there may have been as high as 4000 

MAC exposures out there in the plant and people were 

breathing submicron ten nanometer particles possibly. 

People were cutting these cobbles out with a torch in 

the middle of the process. Oronasal breathing could 

have a significant impact on the dose. 

All these issues have sort of gone away at this 

point. So their original estimates, I believe, were 

high-sided. I think we agree that our original 

estimates may potentially be slightly low-sided. 

However, I'd like to point out that if we ended up 
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with even SC&A's assertions as they stand now, this 

500 MAC per year, an allowance for like 20 MAC in the 

fourth year, it is not substantially different than 

the triangular model that we proposed a year ago. 

That model ended up giving a worker about 330 MAC 

effective per year, so 1300 MAC hours, if you will. 

SC&A's model now would say 1500. We're less than 20 

percent apart, I think, on these issues. So the 

differences are not as great as they sound although 

conceptually we still have some issues with what 

they're talking about. 

I'd like to address this TIB-0004 issue a little 

bit as well. TIB-0004 is a profile that is used not 

to make compensation decisions in both directions, 

but it's a profile that is used to, if one can make a 

determination that a hundred MAC is truly a bounding 

estimate at that facility. And which Bethlehem Steel 

is not considered one of the facilities it's 

applicable to, then one can make a determination that 

that probability of causation is less than 50 percent 

for that claim. It's a very different issue, and I'd 

like to separate those two if I could. 

If I can go to the first slide, these are the 

issues that John went over in some detail so I won't 

go through all of them again. But I will point out 
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that this first issue here, of course, is the one 

where we have the most difficulty accepting some of 

their assertions, and I'll get into that in a little 

bit. 

And actually the first two sort of get in there. 

I was encouraged to hear that John is now willing to 

accept the fact that these cobbles are truly, if they 

did happen and were cut in a different location, and 

in fact, the concentrations at the rollers may indeed 

be bounding for the highest exposure or the 95th 

percentile workers. And that's a major step forward 

I believe. 

Oronasal breathing, I think we've agreed, at 

least in this case as John indicated, is not an issue 

for Bethlehem Steel. It's a small contributor, 

albeit not negligible, but a small possible 

contributor, and it is something that we need to take 

up as a policy issue. 

I'll just move on, and I'll go over these as I 

go. The rollings in 1951 and 1952 are indeed 

different. The original review that SC&A did 

asserted that we should use, I think it was 500 MAC 

air at Bethlehem Steel for all four years even though 

it was pretty clear from the data samples that 

Bethlehem Steel was, in '51 and '52 at least, in the 
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business of reviewing or looking at process 

improvements related to salt baths and lead baths to 

reduce worker exposures. 

And in fact, I think I'd like to clarify a little 

misconception. John spoke of, Dr. Mauro spoke of 

1950, two time periods, those early rollings and late 

rollings. In fact, the Simonds Saw and Steel 

rollings that were used from October 27th, 1948, were 

neither salt bath nor lead bath rollings. They were 

furnace-heated uranium. 

That was the only one that we could find had been 

done that way. They realized early on that that was 

an extremely messy process. And in fact, that's 

where the highest air concentration we've seen 

between Simonds and Bethlehem occurred. And that was 

1000 MAC air at roller stand. Well, the first 

roller, there really only was one roller where they 

kind of repetitively moved it through. 

But the first pass through of that furnace-heated 

uranium that had a lot of oxide scale on the outside 

is where we observed these processes, at least this 

high sample. Because of that we think that Simonds 

is certainly a very large bounding estimate or a 

bounding estimate for ‘51 when lead bath was used at 

Simonds, or at Bethlehem Steel. 
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I would also point out that all the rollings at 

Bethlehem were lead and salt baths, and I'd like to 

address a little bit of this issue of BZ versus GA 

samples, breathing zone versus general area samples. 

I’ve had very little time to review their report. 

Their report came out Friday at close of business, 

and I've looked at it, but we've not had time to 

review any of the statistical analyses that were done 

in any detail, but I do have a few comments. 

The first issue that's apparent to me is that 

there were really only two samples at Simonds Saw and 

Steel out of the 41 that were taken that were listed 

as general area samples. The other samples were 

listed as roller stand number one, roller stand this, 

you know, so they were not explicitly called out as 

breathing zone samples. 

SC&A rightfully points out that in their 

analysis, the AEC or HASL went and used these in 

their calculation of total exposures, but they were 

not the traditional sample where it was taken over 

the shoulder. These are very similar in the 

descriptions of the samples that were taken at 

Bethlehem Steel. 

In fact, the ones that are not breathing zone 

samples at Bethlehem Steel are the GA samples that 
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are listed as over roller stand number one, over 

roller stand number three. They were very close to 

the roller stands. At least, they seem in our mind 

very conceptually similar to the process that was 

taken at Simonds Saw and Steel. It would have to be 

a leap of faith to assume that from 1949 to '51, the 

HASL program became more lax and just started taking 

general area samples at the stands that were not as 

representative of the breathing zone that could be 

used for calculations in '51 as they were in '48. 

We have data over seven rollings. There are over 

200 air samples that were taken at Bethlehem Steel. 

We only have 40 samples, 41 taken at Simonds. We 

believe that the data are informative of the bounding 

estimates of exposures at Bethlehem Steel. 

One thing that -- we do agree that we need to 

clarify this issue, the difference between BZ and 

general area samples, and we've gone to some lengths 

to do that. As of last Thursday we've been trying to 

make contact with Al Breslin who was the architect of 

the HASL breathing or the HASL air sampling program. 

Through a series of cold calls around the state of 

New Jersey, we have finally located Mr. Breslin. He 

is alive and well and living in New Jersey, and he 

has agreed to discuss with us exactly where these 
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samples were taken, and what they were intended to 

represent. 

So until we make that contact, we have Federal 

Expressed to Mr. Breslin the air samples that he 

assigned. We've sent him a copy of the revised site 

profile, and we look forward to discussing with him 

in the very near future exactly what HASL’s intent 

was for these samples. This is assuming that he can 

remember. 

We've talked to him briefly. We've not had any 

substantive conversations with him, but he does 

remember Bethlehem Steel. He remembers the process, 

so we're encouraged that we may be able to shed some 

light on this issue and make a determination as to 

how representative or how useful these samples are. 

In fact, it's interesting that the samples that 

Al Breslin took over the salt bath had the same exact 

description as the samples that were taken over the 

lead bath by Mr. Miller. And Breslin labeled the 

sample a process sample. Miller labeled the process 

a GA sample. I believe what we have here is sort of 

a difference in nomenclature for these samples. 

But the fact that at Simonds they took the same 

sample near the roller and used it as representative 

of the breathing zone I think also speaks to the fact 
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61 

that these were either breathing zones that cold be 

used, represented the breathing zone, or in fact, I 

suspect that they may have actually been process 

samples. 

And the other issue that we had with SC&A’s 

review was it's difficult to speculate or postulate a 

mechanism that could sustain continuous air 

concentrations at greater than 500 MAC. This equates 

to about 30 milligrams per cubic meter. SC&A by 

their own calculation in their first review has 

determined that around 500 MAC is an area where 

continuous exposure to that environment would result 

in some adverse health effects to the workers as far 

as respiratory distress and that sort of thing. And 

we buy that. We believe that's probably true. 

So the rolling of these samples were somewhat 

episodic. It took two to five minutes per roll to 

run through. This was a continuous mill, and that 

was the whole point of this was to rapidly process a 

rod through without having to manually feed it. 

So for instance, on the rollings of April 27th 

and 28th, I believe 72 billets were processed. If you 

took about three minutes a billet, that’s 210 minutes 

worth of rolling. Possibly one could get this high. 

We have no air samples. The highest sample we have 
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during that period was around 400, I think, of all 

the 200 and something samples that were taken. So to 

postulate that 500 MAC air existed for a duration of 

20 hours when only 72 billets were rolled, this does 

not seem credible to us. 

The SC&A analysis of the BZ and GA samples is 

sort of interesting. They kind of had a double 

approach here. Up till now we've been fitting 

statistical distributions to the data set and picking 

off the 95th percentile. When SC&A chose to analyze 

the ratio of BZ to GA, they did a rank order test, 

found as close as they could to the 95th percentile, 

and then linearly interpolated between two points 

linearly which, and in the data are lognormally 

distributed which ended up a much higher value than 

if one fits a statistical distribution to -- in fact, 

their most recent report demonstrates that. 

You'll see the ratios are much lower if you fit a 

statistical distribution, in fact, closer to one to 

one than if you do this rank order test, so one can 

do with statistics what one wishes, but it certainly 

alternate interpretations are there for making a case 

that a GA sample at Simonds is very different than a 

GA sample at Bethlehem. 

And in fact, if one, the highest rollings at 
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Simonds of 70,000 DPM, the 1000 MAC, was listed as 

roller stand number one, it was not listed as BZ 

roller stand number one. SC&A has interpreted that 

as a BZ sample. In fact, that has seriously jacked 

up the ratios to make their case. Well, I think 

there are alternative statistical analyses that could 

probably prove almost exactly the opposite of what 

they've come up with. We've not had time to look at 

them. 

This is similar to what Dr. Mauro presented. 

This is the difference in the lognormal distribution 

of the lead/salt bath or the lead bath versus the 

salt bath. And one can clearly see that there are 

very large differences in the airborne concentrations 

in general. 

I don't have it on here, but if one plotted the 

Simonds Saw data, it would be closer to the lead 

bath, but the upper value would be, well, it was 1000 

MAC. The upper value, 95th percentile for the 

Simonds' data would be 550-something MAC. The 95th 

percentile of the lead bath data at Bethlehem Steel 

approaches around 200 MAC, I think. So there is a 

substantial difference in those two operations. 

This is just a depiction of the various locations 

where samples were taken in a box and whisker plot of 
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the distribution of those samples. And you can see 

that there was some very serious interest in the 

shears. These breathing zone samples were taken 

typically when a worker was doing something that 

required some movement, and he was in close proximity 

to the source. So you'll see a lot of breathing zone 

samples when you're taking it out of the salt bath 

and loading it into the first stand or one is 

physically cutting a rod of uranium with a shear 

generating large airborne. 

So there was a lot of interest in BZs where 

workers were in very close proximity with potential 

to generate airborne. The stands which are located 

here, again, they weren't labeled as such as BZ 

samples, but in the early days we know for a fact 

that there were no workers positioned at the stands. 

It wasn't until the cobbles started to become a 

problem, and we've got some documentation on it, that 

they positioned some workers at the different stands. 

And in fact, we don't believe that their face was 

right in over the stand. They were with crowbars 

trying to make sure that these things went into the 

next location. 

Just a little more to finish up here, episodic 

events. Rolling, you know, SC&A has made the issue 
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of these episodic events, and it sounds like that the 

cutting of uranium and the cobbles might not be an 

issue at this point. But we were of the opinion that 

rollings are episodic events in themselves. So to 

take the highest concentration, 95th percentile, at a 

rolling stand and assume a worker breathed that for 

ten hours a day, we believe in our mind, is a fairly, 

is a very claimant favorable assumption. 

This torch cutting of uranium we still believe is 

not, it's a bad idea to cut uranium with a torch. We 

were interested to talk to Mr. Breslin who was 

present during all of these rollings when cobbles 

were taken out to ask his, find out what his opinion 

is of what happened with these cobbles. 

I'd like to talk a little bit about the ingestion 

model. SC&A has recommended, as John talked, this 

100 milligrams ingestion as a starting point. And, 

you know, I spent some time reading literature on 

this. Steve Simon has put out a very large paper on 

this to evaluate ingestion. It is an ingestion 

recommendation for people exposed to soil. It's an 

EPA-type document, and gardeners and such, they can 

ingest soil, you know, a total mass of soil. One 

does need though to make, take account of the 

percentage of the material ingested is the relevant 
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contaminant. 

And SC&A has taken the position that the uranium 

that comes off the process makes this veneer 

contamination of uranium on the ground that is 

available instantaneously for uptake. Our problem 

with this model is that it does not have, take into 

account at all the source term. In other words, if I 

were theoretically rolling five pounds of uranium or 

five tons of uranium, I have the same potential for 

ingestion regardless of how much airborne there was. 

SC&A has made the opinion that these are large 

particles that kind of get deposited locally and that 

doesn't kind of make a case then because these things 

do not distribute and become widely available for 

ingestion. 

We have proposed a model that is based on the 

amount of uranium that is put into the air, and we've 

taken the air concentrations right at the stands so 

that's the material that can drop down to the ground 

in the near location where the workers are. And we 

believe it to be more credible. It's a consistency 

point of view that we're trying to do this. 

I mean, if we have another location, can we 

assume 100 milligrams? For instance, in this model a 

worker would receive 100 milligrams ingestion in 1952 
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when if, as SC&A contends, 20 MAC was the highest air 

concentration than if you were working in 1949 when 

500 MAC was the air concentration. That just doesn't 

make intuitive sense to us. It just does not seem 

proper. 

John talked about this. The SC&A suspension 

model relies on 95th percentile. They backed off on 

that a bit and now have said, well, no, maybe the 

median value of the general area samples are 

relevant. We still have a problem with this since 

these are the samples that were taken during 

rollings. This is going to be, by their own 

admission, an overestimate of the ingestion. And in 

fact, their first model came up, I think it was 13 or 

14 MAC constant air for four years was higher than 

the air samples that were measured in some of the 

rollings, have higher than the median rollings at 

Bethlehem Steel. 

We need to look at this a little closer. This is 

not some place where we're really far apart, but 

we're not convinced that using the median value of 

the general area samples is representative of the 

resuspension. In fact, if one looks at some of the 

samples at Bethlehem Steel where they've taken a 

sample before they're, you know, as the rolls go 
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through, the air samples drop down pretty 

precipitously in between rollings, and they'll take 

another sample, and it'll be very low. That drop in 

itself indicates that something like this is probably 

a very large overestimate. And you just can't 

sustain uranium in the air at the levels that this 

model is predicting. 

Finally, I'll finish up, the external model, we 

see some criticism on our external model. It wasn't 

high enough. We estimated that if a worker were 

continually exposed for a 2000-hour year, it would 

equate to a dose of 133 rem, a fairly large, 

substantial dose is not seen in most DOE facilities. 

I think SC&A has looked at that and agreed that 

that's a very claimant favorable assumption. 

They still maintain that we need to address 

residual contamination on clothing. I think we've 

done that. I would ask them to go back and look at 

our revised site profile, and in fact, we looked at 

some dose rates coming off of contaminated clothing 

at Simonds Saw and Steel and adopted that for our 

use. And I think we ended up assigning about 150 

millirem a year of residual contamination on 

clothing. 

So we need to get together and talk about that, 
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but I think we've addressed that issue. Whether they 

agree with it or not remains to be seen, but we're 

interested in talking with them about it. 

I think that's all I have, open to questions. 

DR. ZIEMER: Thank you very much, Jim. Let's 

open the floor now for questions on Jim's material. 

Henry. 

DR. ANDERSON: I mean, it seems all of this is 

working off, you know, the both groups are using the 

same data, and I guess it was unclear to me and in 

the earlier presentation it seemed there were smaller 

numbers. Is there agreement on what samples 

represent what between the two of you? Are you 

assuming, you know, breathing zone when they're not, 

and --

DR. NETON: Right, I think that's the crux of the 

issue is, you know, we have GA samples at Simonds Saw 

and Steel taken at the rollers that we believe are 

similar, if not the same, as the type of samples that 

were taken at Simonds Saw and Steel. SC&A has made 

the determination that for some reason the Bethlehem 

Steel samples were taken either further away or not 

as representative as the samples taken at the rollers 

at Simonds Saw and Steel. And we have no indication 

they aren't. We believe that the program took the 
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samples in a similar manner between the two 

facilities. 

DR. WADE: Jim, could you restate that? I think 

maybe you were using different Simonds Saw and Steel 

a couple of times. 

DR. NETON: We believe that the GA samples taken 

at Bethlehem Steel can be used to indicate the 

representative exposures, if not bounding exposures, 

for workers at Bethlehem Steel. SC&A's position is 

that those GA samples are not representative or 

cannot be shown to be representative. 

DR. ANDERSON: Because it all seems to stem from 

that and then it's a matter of which model you use. 

And it's all, you know, beyond that how you treat 

that data, it's sort of how reasonable is your 

speculation, and then how do you bound that, and then 

are they, how confident are we that the ultimate 

exposure --

DR. NETON: I think the issue really is pretty 

simple. I mean, if we pick the 95th percentile and 

assume the GA samples are representative, not 

bounding of the exposures at Bethlehem Steel, we 

would suggest then that somewhere in the vicinity of 

200 MAC air was possible at Bethlehem Steel at least 

up through, I think it's October 1st because they only 
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rolled lead bath uranium up to October. After 

October every indication is that it was all salt bath 

rollings. 

SC&A, at least I don't want to speak for them, 

but at least in their original models they suggested 

500 as an upper bound for all four years. Now I 

don't know. I'm not sure where they're going to fall 

now because now they're saying the air samples could 

be eight times higher so that would put them at 1600 

MAC. And then I'm not sure what factor they would 

accept as reducing these by, you know, they come with 

this magic factor of three that all of a sudden makes 

a four, five hundred MAC. I'm not sure. I don't 

want to speak for them, but -- 

DR. ZIEMER: Jim, could you clarify your 

understanding of the differences in the ratios of the 

breathing zone to general at Simonds and breathing 

zone to general at Bethlehem Steel? Do you interpret 

that differently than what we heard from SC&A? 

DR. NETON: One certainly could come to a 

different statistical interpretation depending on 

whether you use a linear fit, a linear fit to the log 

model or use this rank order analysis and interpolate 

between the 90th and 95th percentile. 

DR. ZIEMER: Was that in your mind the source of 
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the difference in the ratios? 

DR. NETON: Yes. 

DR. ZIEMER: The selection of that. 

DR. NETON: The selection of that particular way 

to do the test is what drives that ratio high. Even 

in their last report which I've not had a lot of time 

to look at, I think the ratio’s about one to one if 

you do a linear --

DR. ZIEMER: Has anyone looked at the ratios, for 

example, based on the mean values of those 

distributions or anything like that? 

DR. NETON: SC&A looked at all the parameters, 

the mean and 95th percentile. 

DR. ZIEMER: John, did you want to -- 

DR. MAURO: If I may. 

By way of clarification, in our report we're not 

recommending one method of interpolation or the 

other. In other words we're saying we have a 

collection of data. 

DR. ZIEMER: Yeah, and you've raised a question 

on it. 

DR. MAURO: Right, and now the question becomes 

okay, if you want to pick off the 95 percentile of a 

data set, that's what we're talking about. Okay, now 

let's say we have a data set. Now we basically say 
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in our report we like the idea of picking off what I 

call an upper end. And for want of a better term it 

looks like 95th percentile's the kind of numbers that 

we all agreed represents an upper end. 

Now the question is how do you get there? We 

present both and say listen, you can get there by a 

rank -- if you don't think it's a lognormal 

distribution, and there's some question whether we 

have a lognormal distribution because it does deviate 

quite a bit from lognormal. So one could argue well, 

listen, one statistician would say listen, I don't 

think you really have a lognormal distribution. And 

if you don't have that, what do you do? Well, what 

you do is you do a rank order approach. 

In other words that's non-parametric. You don't 

make any assumption regarding what type of 

distribution it is, and you pick off, and there's an 

interpolation technique. You can get to a 95th 

percentile that way. Or you can get to the 95th 

percentile another way. You can take your data, fit 

it to a lognormal, get your best fit, and pluck off 

parametrically at the 95th percentile. We present 

both. So we do not recommend or adopt, although we 

do make a point though. 

It does look like the fit breaks down on a high 
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end as a pro lognormal. In addition, the ratio of 

this eight to one. We're not recommending that. We 

used that in our conference call mainly as a way to 

discuss the issue. We believe that we have some 

questions related to the definition of what's a 

breathing zone; what's a general air. There's 

ambiguity. If you go with, well, a more conservative 

interpretation, listen, we're going to do the best we 

can to parse it, which one is basically a breathing 

zone, and which one's a general air, which is what we 

did. Then we do see this difference, a robust 

difference, for Simonds Saw. 

And it turns out to be eight-fold at Simonds Saw. 

We're not saying that's the right number. We're 

saying there is a difference. Now and all we're 

really saying is when we move over to Bethlehem 

Steel, it looks like there's a paucity of breathing 

zone, but there are some arguments that perhaps those 

general air are really breathing zone, but we didn't 

see it. But we think there is. 

There's no doubt we're erring more on the side of 

the claimant, and then that means that we do need an 

adjustment factor. What that adjustment factor is, 

you know, we're not in a position to nail that number 

down. All we did is get, for example, the difference 
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is a factor of eight at Simonds, and we sort of 

stopped there. 

DR. ZIEMER: Jim, do you know if Mr. Breslin had 

experience at Simonds as well as Bethlehem Steel? 

DR. NETON: Yes. 

DR. ZIEMER: So he would be in a position to 

address the breathing zone and general air sample 

issues for both sites perhaps? 

DR. NETON: We believe so if his memories can -- 

DR. ZIEMER: But at least he --

DR. NETON: -- over 50 years. He would certainly 

be the one in the best position to represent what 

they did. 

DR. ZIEMER: And Mark, you had a --

MR. GRIFFON: That was my discussion was the 

ratios. 

DR. NETON: I'd like to point, I mean, John keeps 

saying well, it's not eight to one, and then he says 

it is eight to one, and that's their argument. One 

has to buy into this linear interpolation of these 

admitted outliers to begin with. And the other issue 

is that one has to believe that the air samples taken 

at the rollers at Simonds, which were listed as not 

BZ samples, are materially different samples than the 

samples taken at the rollers at Bethlehem Steel. 
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DR. ZIEMER: Yes, Arjun and then Jim. 

DR. MAKHIJANI: Dr. Ziemer, there are a lot of 

issue about these samples. I'd just thought to make 

a few factual clarifications about what's in the data 

sheets, and what SC&A did. 

First of all, the report that you have before 

you, both the rank order and lognormal analyses are 

done on all the data. And if you look, there's one, 

there's only one data set. If you look at Figure 2-

6, you'll see there's really -- 

DR. ZIEMER: This is 2-6 in the letter report? 

DR. MAKHIJANI: In the letter report. 

Where all the lognormal fits in various ways are 

shown in the figures in Attachment Two. If you look 

at those fits, you'll see there's really one data set 

which sticks out which is the general air in period 

two with, where the upper percentiles don't at all 

fit a lognormal, and where a rank order approach is 

more appropriate. 

In the other cases you can go either way, and 

there is a very consistent pattern in the 95 

percentile ratios at Bethlehem Steel, but apart from 

that one that does not have a fit with lognormal. 

That if you take the ratios of breathing zone to 

general air by either method, you do have, the 
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general air is tending to be higher than the 

breathing zones which is not what you expect. 

There's one very important fact in looking at the 

data sheets at Simonds and Bethlehem Steel that it's 

important to note. The highest sample value at 

Simonds Steel, that famous 1000 times MAC, is an 

unlabeled sample as to breathing zone or general air 

which the text of the AC discussion interprets as 

breathing zone. And so it's not entirely claimant 

favorable maybe, but it's reasonable to accept it. 

And the reason we felt comfortable with that is 

that the result is also compatible with this 30 

milligrams. So there's an independent kind of check 

to that. The highest Bethlehem Steel sample of 400 

and odd MAC is labeled as a general air sample so 

that there we do have to, we felt, you have to pay 

some attention to how you interpret that specially 

the general airs are showing higher than breathing 

zone. 

And the last point I'd like to make, Dr. Ziemer, 

is that you have to look at whether the sampling was 

done to be representative of worker intake or whether 

it was done for something else. And Merril Eisenbud 

himself said in 1951, and this is quoted in a TBD, 

quote, dust samples were taken at Bethlehem Steel 
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plant to evaluate continuous rolling of uranium. 

And so from a worker intake point of view, the 

samples are biased. From the point of view of 

evaluating experimental processes, they would be 

appropriate. So now you're faced with the problem of 

how you take this data set that was done to evaluate 

processes and then back fit it into something to a 

different use, to put it to use to evaluate intakes. 

This is a big part of the problem. 

DR. NETON: I would remind Dr. Makhijani that the 

intent of the Bethlehem Steel rollings, one of the 

principal intents, was to develop a more workerprotective process. I mean, so this was not, there 

was some production value to be gained here, but one 

of the major intents was to make the process more 

worker protective. 

DR. ZIEMER: Yes, Dr. Roessler. 

DR. ROESSLER: I have two questions, Jim. You 

mentioned meeting with Al Breslin. I'm wondering 

what the procedure is then. After you meet with him, 

and whether he can or cannot shed some light on the 

samples and what they represented, then do you get 

back with SC&A, and then how does the board or the 

working group get involved? It seems like that could 

be a very important meeting. 
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DR. NETON: Yes, we haven't worked out the 

mechanics of that, and I'm not sure whether we should 

go along; we should go with SC&A and a member of the 

board. I mean, that process needs to be worked out. 

But certainly, we would need, we don't want to 

overwhelm Mr. Breslin either with a large cadre of 

folks. I mean, he is in his eighties, I believe. 

But after that meeting, we let the chips fall where 

they may. If it looks like we can't come to any 

conclusive evidence, that these are as we believe 

they are, or he confirms what SC&A's opinion is, 

we're willing to modify our profile as appropriate. 

DR. ZIEMER: Do you anticipate a number of NIOSH 

people or is it possible that -- 

DR. NETON: No, I think a small -- 

DR. ZIEMER: --someone could represent SC&A at 

that meeting so that it's more efficient and both 

hear the same thing? 

DR. NETON: I don't anticipate a large number of 

NIOSH people, one, maybe two tops. 

DR. MAURO: If it's going to be in New Jersey, 

it's very convenient for me. So I know John is -- 

DR. ZIEMER: Right, we'll work that out. 

John, an additional comment? 

DR. MAURO: I do want to -- we've been talking 
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about our differences here. I think it's very 

important to say let's look at where we're not 

different. We're very close. I think the only thing 

we're saying is this is 1949, 1950, 550 MAC, 

surrogate for 1949, 1950, no problem. Nineteen 

fifty-two, they come up with 20 MAC as being a 

number. I'm sure that's pretty close to where you're 

going to be. So where's the problem, 1951. 

And what I just heard is that if you take all 

your numbers and you come up with, without any 

adjustment factor. See, we're saying we need an 

adjustment factor. You're saying we don't need an 

adjustment factor. And in the end Breslin may be 

able to give us information that says, yes, you need 

an adjustment factor or no, you don't to create, to 

keep parity. 

But either way we're close. I think I heard you 

say for 1951, your 95th percentile value is 200 MAC? 

DR. NETON: I'd guess at that, but it's pretty 

close to that, I mean, in the upper one hundreds. 

DR. MAURO: Now if you go with my, our example 

that we only use for the sake of our conversation 

during our conference call was to take the roller 

breathing zone samples. I'm sorry, the roller 

general air samples. Get the 95th percentile to that. 
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Multiply by eight. So that represents the high-end 

exposure that might be at the breathing zone when 

rolling is going on, and that's going on about 30 

percent of the time. The other 70 percent of the 

time it's general air. 

So what I'm getting at is I don't think we're 

more than a factor of two apart. Even if we go with 

that approach on that order, a factor of two apart on 

1952. That's it. That's our difference. Now if we 

can get some clarification, I think that gap closes. 

DR. ZIEMER: I think Roy gave you the factor of 

two already in his revamping the model, but let me 

get Gen's other question here. 

DR. ROESSLER: I think that might have answered 

my second question, but I'll make it very specific. 

There's so many numbers that have been going around 

and so many multiples and so on, is there any case 

where it's going to be greater than 500 MAC? I mean, 

is that any --

DR. NETON: I really can't speak for -- in our 

opinion, no, but I can't speak for SC&A. 

DR. ROESSLER: -- because it seems like you 

mentioned health effects that would occur at that 

level or higher, and so I'm wondering about if that's 

a possibility, medical records or anything that Mr. 
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Walker could remember about the workers and whether 

they --

DR. ZIEMER: You're talking about general health 

effects from breathing stuff? 

DR. ROESSLER: Something in that, this breathing 

stuff. I think you said that if it were greater than 

500 MAC that the workers would have shown some 

difficulty breathing or some -- 

DR. NETON: This was SC&A's analysis by Dr. Van 

Pelt, but --

DR. MAURO: Yes, one of the things we did look 

into just how many milligrams per cubic meter can a 

person work eight hours, ten hours a day and not 

experience respiratory distress. And based on our 

work, two separate people looking at this question, 

we came in at around 30 milligrams per cubic meter as 

being you're putting this person in -- never mind the 

radioactivity, just the dust loading -- 

DR. ZIEMER: Just the dust loading... 

DR. MAURO: -- as being in a stressful situation. 

So, and that turns out to be around 600 MAC. I mean, 

so that was one of the reasons why we felt that we 

could cap this problem. In other words, given all 

these uncertainties from the radiological 

measurements point of view alone, because we realize 
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that the sampling, how representative it is, these 

are all questions. But one thing where we've come to 

a degree of comfort is based just on the respiratory 

distress aspect, we probably could put a cap on the 

problem, and I think that's very important. 

DR. NETON: But one thing I, a question is one 

would have to get the 1600 MAC if you used this 

adjustment factor of eight for three hours a day or 

for seven hours a day or something like that. 

DR. MAURO: Well, as I said when we worked the 

factor of eight as our example, we took the 95th 

percentile for the general air roller, '52, '51, 

multiplied by eight and said you're going to get that 

concentration for 30 percent of the time. 

DR. NETON: Which was 1600 MAC. 

DR. MAURO: Right. And then the other, right -- 

DR. NETON: But that's higher than any sample 

that has ever been measured in -- 

DR. MAURO: So you're making a counter argument. 

Well, that example isn't too robust because eight may 

get you to a place that doesn't make sense. 

DR. NETON: Right. 

DR. MAURO: And I'm not going to disagree with 

you here. If eight gets you to a place that doesn't 

make sense, you have to acknowledge that. So that's 
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why I keep saying, we used eight only because that's 

the number that we walked away with. So you're 

making a counter argument of well, I hear what you're 

saying, some adjustment factor. Well, I guess I 

haven't heard you say do you think an adjustment 

factor is needed here. You're saying until we talk 

to Dr. Breslin, we really are not sure. 

DR. NETON: Right. 

DR. MAURO: And I think we all agree with that. 

DR. ZIEMER: That sounds like the next step. 

I want to ask, we had a working group that met 

last week -- or last week -- earlier this month and 

also discussed some Bethlehem Steel things. 

And Mark do you have any comments? 

Mark chaired that working group. 

Are there any other issues on Bethlehem Steel 

that you want to bring to this subcommittee that came 

out of the working group at this point? Because this 

will be back on our agenda for the full board 

tomorrow to discuss. 

MR. GRIFFON: I think one thing that struck me 

was, which is where we've had most of this 

discussion, was that was the main item where we had 

some disagreements and questions. And if we can 

figure out what these samples actually represent, I 
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think all of that can go away. 

What I thought we sort of concluded in the work 

group was on a number of the other findings, such as 

oronasal breathing, and I missed the earlier 

discussion. I apologize. But it seems to me that we 

came to a pretty good conclusion that for that it was 

okay for the Bethlehem site profile; however, there's 

still some outstanding stuff that from a programmatic 

side we might want to have NIOSH address the policy 

because it's going to come up again. 

And I think that's true also as I look on the 

ingestion and resuspension, you know, in fact, and 

I'm not sure how far apart these are, but in fact, I 

felt like these numbers were getting pretty close in 

either SC&A's approach or NIOSH's approach. The 

question was also then, well, what's the best method 

to use and maybe for consistency going forward that 

still needs to be worked out. But as far as the 

overall impact on the Bethlehem site profile and the 

doses assigned I don't think it would have major 

impact so. 

But I think where we ended up was that -- and 

Wanda was there as well and Bob. And I think where 

we ended up was that that first issue really was the 

hardest one with the BZs versus the general area and 
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how that was going to be worked out. And that had a 

larger impact on the doses so that was the most 

important one to nail down. 

DR. ZIEMER: Okay, thank you. 

Yes, Ed, did you have an additional comment for 

us, Mr. Walker? 

MR. WALKER: Thank you, Doctor. 

I just wanted to mention to Jim that you 

mentioned that the cobbles weren't cut. That's still 

in question because when those cobbles got into the 

rolling stand, and there were six stands at Bethlehem 

compared to two at Simonds Saw, and they run much 

faster. These cobbles got tangled. Now they were, 

they could not just hook a crane on them from up 

above and pull them out. Somehow, they had to be 

cut, some of them. Maybe some of them they could 

pull out with a crane. 

But somehow when they get tangled around, those 

rods go through that rolling system at that speed, 

and Arjun can testify to this. The crane operator 

that was working 50 feet in the air above a cobble 

was hit, maybe not with uranium. That I didn't 

clarify, but he was hit in the crane when the cobble 

shot 50 feet in the air, red-hot rod an inch and a 

half. So some of those cobbles had to be taken out, 
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in the roll stands, parts of them, maybe not all. 

Some of those cobbles went down into the basement 

area, went around. It was just like a snake when 

they cobble. So I learned that -- 

DR. NETON: I am concerned about the cobbles. We 

have some documentation from HASL AEC talking about 

the cobbles. And the curvature of those cobbles 

doesn't seem to be as great as maybe happened with 

steel. I don't know. They talk about some radiuses 

(sic) of curvature five inches, bends that are not 

that great. But they've taken them back and put them 

in the salt bath and re-ran them through the process. 

I don't know whether -- 

MR. WALKER: Some of them probably -- 

DR. NETON: -- uranium would be a much more dense 

metal, doesn't cobble as much, you know, as steel 

might --

MR. WALKER: I don't know. There was many 

cobbles, and I can testify to that. Some of could 

have been, I think we had talked about that. 

The other one was the men stationed between the 

stands. There is documentation that many times, and 

the fella's name was mentioned, Mr. Harper, had to 

get, he wasn't outside the stands with a long bar, 

had to get between each rolling stand, and again, 
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there were six of them, to open up the jaws to 

receive the rod because they wouldn't hit and go in. 

They had to open up, it was a pressure spring that 

closed down on the rod, and many stands also where 

they had to feed them in with a sledge hammer at 

number one stand. I just wanted to clear that up. 

DR. NETON: But the fact is did he stand at that 

jaw the entire ten hours or was he moved around? The 

air sample standing right here on top of the rolling 

station. 

MR. WALKER: Yeah, that's right. I can't say 

that he was there every minute of the day, right, but 

there had to be people placed there. I wouldn't want 

to be there, and I don't think -- 

DR. NETON: Nor would I. 

MR. WALKER: Thank you. 

DR. ZIEMER: Thank you very much. This will 

conclude our discussion of Bethlehem Steel for this 

morning. We are actually a little behind schedule, 

and we do have one item, well, this kind of relates. 

CONGRESSIONAL ADDRESS 

MR. JASON BROEHM 

We're going to hear from our congressional 

liaison. 

And Lew, why don't you introduce Jason to the 

group and explain what Jason does. 
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And then, Jason, we'll have you read those 

statements. 

DR. WADE: Well, Jason works for CDC, and he 

works in the area of Congressional Relations; and 

therefore, interacts with many of our friends on the 

Hill related to this activity and others. And Jason 

has been in touch with some of the people of the New 

York delegation who have some things they would like 

to be on the record for this meeting. 

Jason, introduce yourself and then go ahead. 

MR. BROEHM: I'm Jason Broehm, and I work in the 

Centers for Disease Control and Preventions, 

Washington office. As Lew said we deal with 

congressional offices on a number of issues, and I 

represent NIOSH in that office. 

I have this morning a statement from Senator 

Charles Schumer from New York that he would like read 

before the board, the subcommittee of the board. And 

I also am expecting a letter that I have not yet 

received from representative Louise Slaughter which I 

anticipate reading tomorrow before the full board as 

well as this letter again. So this is the statement 

of Senator Schumer. 

Mr. Chairman, thank you for allowing me to submit 

testimony to the board regarding Bethlehem Steel. 
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Thousands of New Yorkers labored during the late 

1940s and early 1950s in ultra-hazardous conditions 

at Department of Energy and contractor facilities 

while being unaware of the health risks. Workers at 

these facilities handled high levels of radioactive 

materials and were responsible for helping to create 

the huge nuclear arsenal that served as a deterrent 

to the Soviet Union during the Cold War. 

Although government scientists knew of the 

dangers posed by the radiation, workers were given 

little or no protection, and many have been diagnosed 

with cancer. Despite having one of the greatest 

concentrations of facilities involved in nuclear 

weapons production-related activities in the nation, 

western New York continues to be severely under 

served by the Energy Employees Occupational Illness 

Compensation Program. 

I'm aware that many positive steps have been 

taken in the past few months regarding the Bethlehem 

Steel site profile, but I do not feel that worker 

concerns are being adequately addressed or that 

workers are going to be adequately compensated. 

Eddie Walker has been a tireless advocate for former 

Bethlehem Steel workers, and I share many of his 

concerns. 
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For example, has residual radiation between 

rollings and after rollings been evaluated to the 

fullest? I have a hard time believing that such a 

large steel mill could be completely cleaned of 

uranium dust simply by using a vacuum. Without 

proper decontamination after a rolling, it is likely 

that uranium dust would still be present throughout a 

plant of this size, therefore, making residual 

radiation a hazard for all workers. 

In the latest S. Cohen & Associates report on 

Bethlehem air data released on October 14th, 2005, an 

interview with a former worker states just this. 

Quote, the repair and machine of the rollers which 

would carry residual dust from the rolling area was 

done in the machine shop according to the schedule of 

the shop, which means that it was likely that it was 

done on days which uranium was not being rolled. 

Unquote. In meetings I have had with former workers, 

they tell me that they were surrounded by uranium 

billets and/or dust all day long. Some even told me 

that they had to remove uranium flakes from inside 

their coffee mugs. 

Have site expert information and worker 

interviews truly been taken into account? S. Cohen & 

Associates has repeatedly stated that airborne dust 
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was unlikely to be the main contributor to ingestion 

dose, both in the first interview in October 2004, 

and in the latest document on October 14, 2005. 

Worker interviews done by S. Cohen & Associates also 

state that workers were required to be at the rolling 

stand all day even during lunch. Many workers ate 

their lunch in the rolling area because adjustments 

to rollers were constantly necessary. 

I cannot stress how important it is to speak with 

former workers and site experts to come up with a 

proper ingestion model. The bottom line is this 

latest document from S. Cohen & Associates clearly 

supports what Mr. Walker and other former workers 

have been saying from day one. If an accurate dose 

reconstruction model cannot be formulated from 

Bethlehem Steel information, then these workers 

should be awarded a special exposure cohort plain and 

simple. Using air sample data from Simonds Saw and 

Steel in place of Bethlehem Steel data is based on 

assumptions rather than on sound science. 

On July 27th, 2005, Senator Clinton and I along 

with our colleagues in the House of Representatives 

introduced S-1506 which would amend the Energy 

Employees Occupational Illness Compensation Program 

Act of 2000 to include certain former nuclear weapons 
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program workers in a special exposure cohort under 

the Energy Employees Occupational Illness 

Compensation Program. Our bill would correct years 

of injustice for western New York's nuclear workers 

after the sacrifice these Cold War heroes made for 

our country and have waited far too long. 

Being added to a cohort means that these former 

employees do not have to go through a dose 

reconstruction process. Instead, if a person had an 

eligible cancer and worked at a facility when weapons 

work was performed, their cancer is presumed to have 

been caused by workplace exposure, and the person's 

claim is paid. This bill would finally put the 

former workers on the path to getting the recognition 

and compensation they deserve, and this is how we 

should correct this wrongdoing, not by endless 

bureaucratic red tape. 

Again, I thank the Chairman and the board members 

for allowing me to submit testimony on behalf of the 

former nuclear workers in New York. 

DR. ZIEMER: Thank you, Jason, for bringing that 

to the board this morning. 

We have reached the magic hour of noon, and we 

are going to proceed with our lunch break. What I 

would like to ask is if you're able to try to get 
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back by 1:15 instead of 1:30 so that we can move into 

our afternoon session in a timely way and catch up a 

little bit as it were. So we will recess now then 

till 1:15. 

(Thereupon, a luncheon 

recess was taken and the 

meeting resumed at 1:30 

p.m.) 

DR. ZIEMER: We're ready to proceed with the 

afternoon session. We actually have to carry over 

one item from this morning before we get to the Y-12 

information, and that is the Savannah River site 

material. So we're going to proceed. 

SRS SITE PROFILE REVIEW 

We have two brief presentations on Savannah site 

profile review, and basically this will constitute a 

sort of status report. We'll hear first from SC&A, 

and I guess Kathy DeMers is going to make the 

presentation, and then we'll hear from Jim Neton for 

NIOSH. 

So Kathy, if you want to begin. 

SC&A PRESENTATION, MS. KATHY ROBERTSON-DEMERS 

MS. DeMERS: Good afternoon. As Dr. Ziemer said, 

my name is Kathy Robertson-DeMers, and I work with 

the Task 1 team for Sandy Cohen & Associates. And 
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really this Savannah River review was a team effort, 

so I may call upon some of the team to answer some of 

the questions. It's been awhile since we've 

submitted this report, and we submitted it back in 

March of this year. So we're just going to go over 

some of the basics. 

The Savannah River Site is located on 300 square 

miles of land in the middle of a forest actually 

between Aiken, South Carolina and Augusta, Georgia. 

DuPont originally constructed the plant in 1951. 

They then took over operations of the plant and 

remained the prime contractor until March 31st, 1989, 

at which point Westinghouse Savannah River Company 

took over. 

It had multiple missions. The site had a heavywater plant to produce the heavy water for the five 

production reactors. It had a nuclear fuel and 

target facility. It had two chemical separations 

facilities, tritium processing facilities, test 

reactors, and then, of course, the Savannah River 

Laboratory where a lot of research and development 

occurred. Their primary mission was to produce 

plutonium 239 and tritium. Their current mission is 

remedial action, D&D and storage of fissile material. 

This is kind of an overview of the Savannah River 
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process. Basically, they fabricate the fuel, put it 

into a reactor. Depending upon what the target 

material is, depends upon where it goes at the 

facility. They have F-Canyon which processes the 

plutonium 239 as did H-Canyon through 1960 at which 

point they started to process plutonium 238 for the 

heat source program. 

As you can see, if we have a pointer here, the 

uranium retrieved from the separations facility ended 

up in Oak Ridge, and the plutonium buttons went to 

the Rocky Flats facility. Then the remainder of the 

material went to the tank farms. 

There were several documents that we reviewed in 

the course of this analysis. One of the unique 

things about the Savannah River Site profile was that 

it was a single document rather than six separate 

TBDs, but it included the information that you see up 

on the slide. 

In addition to this there were some supporting 

documents, some technical information bulletins that 

dealt with maximizing of the internal dose for noncompensable cases, assignment of tritium dose, 

interpretation of the external dosimetry records and 

room to assign neutron exposure at the Savannah River 

Site. In addition since we've put out this report, 
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NIOSH has released one additional technical 

information bulletin on the assessment of external 

dose via the coworker method. 

This was one of the first site profiles that 

NIOSH put together and the first site profile that 

SC&A reviewed for a DOE site. The document that was 

reviewed was revision number two. NIOSH is now on 

revision number three which was released in April of 

2005 shortly after we issued our report, and with the 

differences being that they incorporated a model for 

consumption of contaminated food. With that 

completeness and adequacy of data, technical 

accuracy, and the assumptions and methods, 

consistency with other site profiles. Although that 

was fairly limited since we hadn't, at that point, 

done a lot of site profile reviews, and compliance 

with the dose reconstruction requirements. 

The report was divided into strengths, things 

that we thought were good about the document; 

findings, things that represented deficiencies in the 

site profile and that we believe should be corrected; 

and then there were observations, which simply raised 

some questions for which NIOSH should consider it 

would clarify certain things in the TBD and may 

improve it. 
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And prior to me getting into the findings and 

observations, I think it's important that I tell you 

some of the strengths about the Savannah River Site 

profile. As I previously mentioned, they 

supplemented the site profile with technical 

information bulletins which gave additional 

information to the dose reconstructors. The site 

profile was divided into 30 areas, and they made a 

concerted effort to characterize each of those 30 

areas with respect to internal and external dose. 

They did have meetings with trades workers, and 

it appears as though they have incorporated some of 

the suggestions into at least revision three for the 

site profile. Their method for assigning missed dose 

for those with zero dose we concur with, and in the 

case of assigning the dose for internal exposure, 

they used the most conservative solubility class. 

And we'll get into this in a little more detail here. 

We had seven findings, the first of which is 

related to what's called the high five approach, and 

I'm going to kind of explain that to you. Savannah 

River Site had an internal dosimetry registry which 

was put together by Roscoe Hall. In the '90s, Tom 

LaBone of Savannah River went back and calculated the 

dose based upon ICRP 30 methodology which is the 
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requirement that he has to follow. 

It was a best fit analysis. It contained acute 

doses primarily, some chronic doses, and a variety of 

radionuclides, primarily plutoniums and uraniums 

although some fission products. And I need to 

clarify that this methodology would primarily be used 

for someone who would not be compensated. So that's 

kind of a little clarification, but there are some 

issues, technical issues with this method. 

For example, many of the radionuclides, if you 

started with the bioassay data and used the ICRP-60 

methodology versus starting with an intake which was 

calculated by Savannah River, they used the top five 

intakes by radionuclide, averaged them, and then put 

that value into the IMBA code. So if you start with 

the bioassay versus starting with the intake data, 

there are some situations where the methodology 

underestimates the dose. 

Another concern we had was that not all of the 

positive bioassay samples, people with bioassay 

samples, are included in the IDR, or the internal 

dosimetry registry. And in some cases we found 

through data banks and incident files that even the 

highest recorded intakes for a particular 

radionuclide were not included. 
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NIOSH did a comparison of the intake retention 

fractions, and when the intakes are used to calculate 

the organ dose, in general, the solubility type, the 

soluble type is most claimant favorable for a 

systemic organ. When you use bioassay results, many 

times the soluble material represents the higher 

dose. 

So there's kind of a mixing and matching of the 

two methodologies. The most claimant favorable 

approach would be to start out with the bioassay 

samples then apply the ICRP-60 methodology. And 

finally on this issue, we were concerned that the 

intake values were calculated with ICRP 30 rather 

than the most current models, and this seemed 

inconsistent with the requirements for dose 

reconstruction. 

With respect to environmental dose there was 

really no explanation of how they determined the 

significant radionuclides. The analysis for 

environmental dose was limited and did not include 

many of the radionuclides that were also documented 

by the Savannah River Site in public reports as being 

released from the site. 

They applied a resuspension factor for 

calculation of dose of ten to the negative nine per 
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meter. And based upon the studies that we looked at, 

a more appropriate value would have been ten to the 

negative five to ten to the negative six. And those 

values are highly dependent upon the level of 

activity that somebody participates in. 

In this particular TBD they did not address 

recycled uranium which, of course, has impurities in 

it such as fission products and transuranics which 

can add to the dose. And it may not seem that these 

are pertinent in such small concentrations, but they 

do have the potential to concentrate in different 

organs than say the uranium. And in addition to 

this, the impurity concentrations in the recycled 

uranium were somewhat variable because the sites did 

not want to commit to a particular level of 

impurities in their recycled uranium until much later 

in the process. 

With respect to the beta gamma dosimetry, a 

dosimeter calibration was based upon an incident 

angle of zero. This is typically not representative 

of what goes on in the field. The uncertainty value 

that they assigned of 30 percent didn't appear to 

include field radiological conditions and 

environmental uncertainties. And we felt that this 

was too low as a result. 
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The on-phantom correction factor was also too low 

at the lower energies of 30 to 250 keV, and those 

values were taken from calculated values by the 

Savannah River Site shortly after they got their 

DOELAP accreditation and they're primarily laboratory 

errors. 

There was no guidance for how to assign shallow 

dose, and they also did not refer to the TIB which 

tells the dose reconstructor how to assign shallow 

dose. 

With respect to the neutron dosimetry, the 

geometric mean and standard deviation for the post1971 neutron-to-photon ratio are not technically 

defensible or claimant friendly. The TLD recorded 

neutron dose for 1971 to 1995 and pre-1971 neutron 

doses derived from a neutron-to-photon ratio have a 

high level of uncertainty which needs to be taken 

into account. One way to do this would be to use the 

95th percentile value for the thermo luminescent 

neutron dosimeters. 

And as I mentioned to you previously, all the bad 

stuff that they didn't re-collect went to the tank 

farms which had a large number of tanks. With 

respect to the tank farms, the radionuclide lists 

were incomplete for both internal and external 
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radiation. And it was kind of odd because there were 

inconsistencies between the Attachment A, where it 

described the radionuclides in the tank farms, and 

the main text of the document. 

Early workers' incident and contamination 

records, we believe, may be seriously incomplete. 

For example, when you look at the tank farms data 

bank which lists spills, incidents, high radiation 

incidents, and you look at the numbers for the 1950s 

and 1960s, they're very small. And this can be seen 

in our table in the report. And then all of a sudden 

you have a great increase in incidents where they 

really started to document things better. 

Another problem with the tank farms is the 

exposure geometry. In this particular case you may 

have somebody standing on top of a source term rather 

than in front of a source term where their badge 

would more effectively measure their whole body dose. 

There was a potential for internal and external 

exposure to unmonitored workers in unposted areas. 

If they did not go into a radiation zone, they 

weren't badged. However, there was a lot of 

contamination around the tank farms, and they didn't 

always get it posted appropriately. 

The completeness and adequacy of the tank farm 
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data bank we talked about a little bit. What NIOSH 

needs to do is put together a master incident 

database. There are several sources of information 

that can feed into this database. There is, of 

course as I mentioned, the tank farms data bank. 

There is something called a special hazards 

investigation. This is like a field report, 

radiation report, prepared on an incident. And these 

are items that are not being sent to NIOSH by 

Savannah River Site. 

There is also a very complete incident database 

which I'm sure NIOSH knows about which is not 

directly owned by Westinghouse but is owned by one of 

their subcontractors who is responsible for their 

safety analysis program. And site experts indicated 

to me that this is where all the detail is down to 

the minor incidents. 

And that brings us to the last finding. There 

needs to be further investigation on the solubility 

assumptions used to estimate organ dose from urine. 

The most claimant solubility for the radionuclide and 

organ of interest should be considered in the context 

of calculating the dose from this urine. 

With respect to ingestion, I mentioned earlier 

that they had incorporated foodstuff intakes into 
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their latest revision. I really believe that there 

may be some other modes of ingestion, for example, 

during solvent burning, plutonium solvent burning in 

the tank farms area. And then we briefly talked 

about oronasal breathing this morning, so I won't 

bring that up. 

NIOSH along with Savannah River really has 

excused the dose from special tritium compounds. 

These are organically bound compounds or special 

metal tritides which can give a higher dose than the 

standard tritiated water. This is particularly 

pertinent to the tritium production facilities and to 

the D&D workers. This is a subject that is not 

specific to Savannah River and should be looked into. 

Savannah River participated in a number of 

special campaigns. I may have mentioned earlier that 

the reactors produced 14 radionuclides. These 

special campaigns involved the reactors, the 

separations facilities, and of course, the 

laboratories. Some of these radionuclides were 

Californian 252, thorium 244, plutonium 242, and 

americium 243, and then also cobalt. 

What we would like to see, and what we have seen 

in later onsite profiles, there's a list of 

incidents, and then added to that a list of high risk 
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jobs to alert the dose reconstructor to this type of 

situation. For example, with respect to the high 

risk jobs, you have the construction workers, the 

subcontractors, and the D&D workers. And this is 

also mentioned down below in observation seven, and 

really they are, NIOSH is working on this through the 

Center to Protect Worker Rights. The doses to the 

trades workers were not discussed in revision two or 

revision three. And Jim can speak to this better, 

but it is being processed, the investigation. 

There was involvement with uranium 233, with 

beryllium recovery processing and recovery. There 

were also off normal or unauthorized practices. For 

example, there’s a great pond on the Savannah River 

Site, there's lots of tritium and some cesium, but it 

also has great fish. So the workers like to fish in 

this pond. That would be an example of one of the 

unauthorized practices. And then there's significant 

unrecognized or unreported exposures such as opening 

of the tank risers for visual checks. 

The dose to early worker seems to be a recurrent 

problem in these site profiles primarily due to the 

early dosimetry in the early monitoring practices. 

For example, at Savannah River in the early years, 

although they did use neutron monitoring, it was not 
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a routine program as was the beta-gamma program. 

Also, until very recently as a result of an audit, 

the field was responsible for determining who got 

what bioassay including who got follow-up bioassay. 

The, each area on the Savannah River Site was 

like an entity in itself so the rules followed by the 

100 Area or the reactors may be different than the 

rules followed by the 200 Area, or the separations 

facilities may be different from those followed by 

the 300 Area. And that is why it's important to know 

that your field is determining what bioassay you're 

getting. 

There needs to be a review of how comprehensive 

this early data is. For example, if they didn't use 

DR. LIPSZTEIN (telephonically): Hello? Hello? 

DR. ZIEMER: Is this Joyce? Joyce, are you on 

the line? 

DR. LIPSZTEIN This is Joyce Lipsztein. I’m on 

the line. 

DR. ZIEMER: Okay, you're on the speaker phone 

here. Kathy DeMers is still presenting. 

Kathy, go ahead. 

MS. DeMERS: Okay, for example, if you have 

someone who was not routinely monitored for neutron 
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working in a reactor area, you need to ask yourself, 

why and when they could have potentially been exposed 

to neutrons while they were not monitored. 

And finally, I would encourage NIOSH to go back 

to Savannah River and make sure that they're getting 

all the data that they need. For example, there are 

neutron logbooks out there which Savannah River was 

not providing the quarterly data for that you ought 

to be getting your hands on. And the reason that 

they're probably not giving you this data is because 

it's stashed away in the records repository and needs 

to be pulled back. 

Another area that we would like to see NIOSH 

consider that doesn't come in the standard radiation 

personnel file is the multiple dosimetry results. 

They did use multiple dosimetry for especially high 

risk jobs. The dose recorded in the dose record is 

dependent upon the time period. Sometimes they used 

the highest of the multiple dosimeters; sometimes 

they applied correction factors. But you can see if 

they wore a dosimeter on their head, for example, 

when they were in the PIN room, and they have cancer 

on their head, how that might be relevant. 

And that's basically all I have to say. 

DR. ZIEMER: Thank you very much. We have time 
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for a couple of questions. Kathy, on the neutron 

logs that you mentioned, are those individual 

records, are they area surveys or what, both? 

MS. DeMERS: They're listings of neutron dose by 

badge number and --

DR. ZIEMER: But are these logs that don't appear 

in the individual's personal record? 

MS. DeMERS: No, and I don't believe they're 

being provided to NIOSH because they weren't readily 

available to the Savannah River Site records 

organization. 

DR. ZIEMER: Do we know why those were kept 

separate from individual dosimetry records or is that 

not something that --

MS. DeMERS: Well, Savannah River does provide 

information, cycle information to NIOSH out of the 

logbooks. 

DR. ZIEMER: Well, I meant why does Savannah 

River not include those in their own personnel, for 

example, if Dr. Anderson worked at Savannah River, 

would his personnel record not include that or would 

it have been kept --

MS. DeMERS: It would have been like each of you 

have a badge number, and your dose of record would be 

on one page. So they didn't segregate that page into 
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several different people. 

DR. ZIEMER: I see, thank you. 

Other questions right now? 

NIOSH PRESENTATION, DR. JIM NETON 

Okay, if not, let's go to NIOSH and Jim Neton has 

some comments. Jim has told me that their comments 

at this point are still rather brief, so, but we'll 

hear what they have. 

DR. NETON: Thank you, Dr. Ziemer. 

Dr. Ziemer's right. We have not evaluated in 

extreme detail the Savannah River Site profile. We 

acknowledge that we've had this profile since the 

March time frame, but other competing activities such 

SEC petitions and other items have prevented us from 

going into the depth that we really need to at this 

point. I'd like to acknowledge that I think Kathy's 

done an excellent job summarizing the issues that 

were discovered by SC&A in their review, and they, as 

usual, have done an extremely thorough job. 

It does bring one point to mind though, and we've 

been discussing this all along as we go with each of 

these site profiles. They're not intended to be a 

complete compendium of all facts ever known about the 

site. These are not the definitive treatise on 

activities at Savannah River. They are guidelines 
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used by the dose reconstructors to take an 

appropriate path forward, and where there are data 

gaps, to fill those in using claimant favorable 

assumptions. It’s been our experience, in fact, that 

in doing so it ends up that we overestimate doses 

more often than not when we start pulling the thread 

and finding out what the real facts are because we 

tend to be conservative in those assumptions. 

The high five approach is a good example of that. 

I think I'll start with the first slide. I'll just 

summarize the seven findings I think that Kathy has 

gone over so I won't bother to discuss those. What I 

will go over is where we're prepared to make some 

general comments about some of the findings that were 

made by SC&A in their review. 

I think a fairly important one is this issue of 

the high five approach. We've used this to a 

considerable extent in doing dose reconstructions, 

and in particular for workers who, from our 

estimation, appear to have had jobs with low 

potentials for exposures. A good example of that are 

administrative workers, workers who infrequently 

visited the process areas, those types of workers. 

And in fact, it's only used to make a determination 

that even under the, what we consider bounding 
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circumstances, the dose is less, or the probability 

of causation is less than 50 percent. 

The intakes, as I mentioned, are assigned to 

unmonitored workers with low potential for exposure 

or for workers who have bioassay data, and it can be 

demonstrated definitively that the bioassay data 

points themselves are below the values that would be 

predicted based on this large intake. So what we've 

done -- and Kathy's again done a good job summarizing 

this -- is looked at the historical intakes that Tom 

LaBone put together. 

It wasn't our intent that these be exact intakes. 

All we were suggesting, and I think the SC&A review 

itself acknowledges, that for workers for low 

potential for exposure, the intakes that we're 

assigning are bounding values. For example, one 

would assume for an administrative worker or a person 

who infrequently visited a process area, an intake on 

day one, the first day they were at the site, an 

intake of a couple hundred nanocuries of plutonium -- 

I'm not sure if it's a couple hundred nanocuries, but 

it's in the hundred nanocurie range, a very large 

intake that would be very unlikely to be received by 

a person who had a low potential. 

We've done that time and time again in calculated 
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doses for these what we call non-metabolic organs, 

and it's worked to our advantage. So whether or not 

ICRP 30 was involved, we didn't use ICRP 30 to do 

dose reconstructions. All we're portraying here is 

that these intakes are large. They're implausibly, 

not implausibly large, but very large, not likely to 

have been received by these folks. And under those 

conditions we can make a very definitive 

determination of the probability of causation falling 

on which side of the bar. 

I think more has been made of this than needed to 

be, and we need to engage in some conversations with 

SC&A. We have not yet gone to the table and engaged 

in the so-called six step process that needs to be 

undertaken to address these issues. 

The oronasal breathing issue, the more we hear 

about this the more I'm convinced with John Mauro 

that this really is a policy issue that we need to 

come to grips with. It falls in a line of what is 

used. ICRP models, for example, are reference man 

models. They assume a standard adult weighs 70 

kilograms. He has a certain lung size, a certain 

ventilation rate. All those parameters that one 

needs to use to do a calculation. 

Oronasal breathing sort of falls in that 
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category. Is it appropriate that we assume, a 

priori, that all claimants breathe a hundred percent 

of their time through their mouth when, in fact, a 

fraction of the workforce does. We've looked at this 

is some detail. I've commented on this at the St. 

Louis meeting, been to St. Louis so many times. I'm 

sure it was one of the St. Louis meetings -- that 

ICRP has evaluated this. 

And in fact, what their conclusion was that the 

variability among individuals just from normal 

breathing is greater than the variability within an 

individual whether he breathes through his mouth or 

his nose, and it wasn't worth considering in the big 

picture. So again, I'm not going to purport to solve 

this issue here, but these are some discussions that 

I think, us, the board, SC&A, others need to 

undertake to put this issue to bed. 

Another recurring theme in the SC&A analyses of 

profiles, incidents and ingestion is not covered. 

Now we have adopted a policy of primarily, almost 

exclusively, we'll use some type of bioassay data to 

conduct a dose reconstruction for monitored workers. 

In that scenario incidents and ingestion are covered. 

We've gone through this with Mallinckrodt. I thought 

we had demonstrated to SC&A that when one assumed the 
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chronic inhalation model, you cover a large magnitude 

of issues that could have occurred as far as these 

incidents. We're not saying it covers a hundred 

percent, but by and large it is claimant favorable, 

and it addresses incidents. 

Ingestion is also included in there if one is 

ingesting uranium that would be coming out in the 

urine. For the most part we believe for chronic 

exposure models, the inhalation pathway provides the 

highest dose per unit intake. We can discuss a 

little bit about the solubility type F that SC&A has 

raised in the Savannah River profile. That's a 

special circumstance, and in fact, when one evaluates 

that completely, the issue kind of goes away. I mean 

they've kind of focused on one narrow issue. 

So again, you know, the profile gives the dose 

reconstructor an approach to look at detection 

limits, bioassay samples, all that sort of material. 

It doesn't do it in a vacuum. We don't, I think, nor 

could we have every possible incident and addressed 

in these documents. It's just not possible. 

Much was made in the Savannah River as the first 

site profile review done by SC&A, the first DOE 

complex site profile of the uncertainties in external 

dosimetry. I believe that we use the standard 
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uncertainty of plus or minus 30 percent that's 

included in the National Resource Council review, the 

DTRA Program. It's pretty consistent of laboratory 

practice analyses. What can one measure? What type 

of radiation can one measure within a certain 

uncertainty under laboratory conditions? 

And SC&A has made some comments that that 

certainly doesn't include angle of incidents. It 

doesn't include environmental factors that may affect 

these TLDs and film badges. And we agree that we 

need to address that. I mean, there is an analysis 

ongoing as we speak to address another issue related 

to exposure geometries, the locational geometry that 

was brought up in another review. And we're going to 

fold that analysis into one big technical information 

bulletin, and we'll get back to the board with 

further information when that's complete. 

DR. LIPSZTEIN: (Inaudible). 

DR. NETON: Hey Joyce, this is Jim Neton. Did 

you have something to say? 

DR. ZIEMER: Joyce, are you still on the line? 

DR. LIPSZTEIN: Hello? 

DR. ZIEMER: Yes, Joyce, are you still there? 

DR. LIPSZTEIN: Hello? 

DR. ZIEMER: Can you hear us, Joyce? It doesn't 
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sound like she's hearing us. 

DR. LIPSZTEIN: (Inaudible) I can hear, but I 

couldn't hear anything after (inaudible). 

DR. NETON: Sorry you can't hear, Joyce. I'm not 

sure what we can do to rectify that. I can try 

speaking more directly into the microphone. Does 

that help? 

DR. LIPSZTEIN: (no audible response) 

DR. NETON: Apparently not. 

Well, I only have one more bullet here so I'll be 

quick. 

The final issue here is the use of the 95th 

percentile for neutron-photon ratios. Kathy, you 

brought this up, and there's a recurring theme here 

where SC&A consistently recommends the 95th 

percentile. We're a little bit concerned that if one 

keeps compounding 95th percentile, 95th percentile, 

95th percentile, one's add up to at a fairly 

implausible exposure situation which I'm afraid we 

may be reaching. 

In this particular case we constructed the ratio 

of neutrons to photons based on some monitoring data 

that we had and assigned an uncertainty distribution 

about that. So our best estimate was the median 

value and put uncertainties about it. And we 
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proposed and have used that value in reconstructing 

not really missed neutron doses, but what we believe 

to be unmonitored neutron doses. 

SC&A's opinion is that one needs to go out to the 

upper tail, the 95th percentile, multiply all those 

doses by a factor of four, and then one will be 

sufficiently claimant favorable. We're not convinced 

that that's the best approach to take. We certainly, 

again, have not discussed this with SC&A. We need to 

get to the table and work these issues out. But I 

wouldn't say we strongly oppose that, but we'd 

certainly like to have a more detailed discussion of 

where this 95th percentile really needs to be used. 

And I think there's a couple areas that should be 

quick, areas I've called in agreement. We don't 

always disagree, so I thought I'd bring those up. We 

do agree that for consistency in dose reconstructions 

even though the dose reconstructors might include 

recycled uranium in the calculations, we need to have 

additional development in that area so that, again, 

consistency could be reached. 

And we also agree that the exposure conditions at 

the tank farm definitely needs to be fleshed out in 

more detail and portrayed in a better light or better 

detail. 
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And that concludes my remarks. 

DR. ZIEMER: Thank you very much, Jim. 

And Joyce, if you can hear us... 

On the line, for the benefit of those who are in 

the audience, let me tell you Joyce Lipsztein is a 

member of the SC&A team, our contractor. Joyce is on 

the line with us today from Brazil. So I'm not sure 

Joyce if you are hearing this or not at this point, 

but --

DR. LIPSZTEIN: I could hear you, but I couldn't 

hear Jim. 

DR. ZIEMER: Couldn't hear Jim. If you have any 

comments on, I don't know if you heard your 

colleague's presentation, but at least you have a 

copy of it, I guess, and know what she said. Do you 

have anything to add on the Savannah River 

presentation at this point, Joyce? 

DR. LIPSZTEIN: I couldn't hear anything 

(inaudible). 

DR. ZIEMER: Okay, thank you. Hopefully, you'll 

be able to hear the subsequent presentations a little 

better. 

Board members, do you have any comments or 

questions for Jim? 

Yes, Mark. And Mark also while you have the mike 
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if you can report anything from the working group. 

Did the working group -- 

MR. GRIFFON: We really didn't discuss it, so 

that's an easy one. 

DR. ZIEMER: That's easy, okay, thank you. 

Mark Griffon. 

MR. GRIFFON: Yeah, I just have a question as 

we're thinking toward the six step process, Jim, 

that, I mean, I'm wondering if it would be more 

useful to have sort of this how a dose reconstruction 

is going to be done because I don't think that's, you 

know, you said the site profile document is not 

intended to be prescriptive necessarily. 

So I think that's where we've had trouble in the 

past, I think, is that we're pulling some of these 

things apart in the site profile and then we come to 

hear from NIOSH that, well, we're not really using 

that aspect of the site profile to reconstruct doses. 

Well, then why am I wasting my time? You know. I 

think that might be useful for us as we go forward in 

the six step process to -- 

DR. NETON: You raise a very good point, Mark, 

and I think SC&A recognizes in the last meeting where 

we talked about when they do the site profile review, 

they've been doing it without the benefit of having 
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these workbooks available to them and what really 

goes into a dose reconstruction. And I think, I've 

said all along, and I believe more strongly than 

ever, that one can't review a site profile in a 

vacuum without looking how it's applied in a dose 

reconstruction. 

We certainly have many, many Savannah River dose 

reconstructions have been completed. I think it's in 

the hundreds if not a thousand. And so it would 

certainly be good at this point for SC&A and NIOSH to 

jointly look at those and see are we missing major 

issues, we always hear about these incidents, minor 

incidents. We take coworker data. We take bioassay 

data, and we try to give the benefit of the doubt 

where we can and I think to a large degree we address 

these issues by using these coworker databases that 

tend to overestimate on doses. 

MR. GRIFFON: That's what I, I mean, I'm trying 

to understand. I think it would be useful early on 

in the six step process to have that instead of going 

through a lot of this and then at the end of the day, 

the board saying, Jim, can you provide us with a few 

sample cases, right after we've been through four 

meetings of this, you know what I mean? 

DR. NETON: I agree. 
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MR. GRIFFON: I think, and especially maybe not 

only the worst case high five approaches but also 

some best estimate cases. 

DR. NETON: Exactly. 

DR. ZIEMER: John Mauro. 

DR. MAURO: Thank you. 

Yes, we're about to move into what I consider to 

be an extremely important phase of the work we've 

been doing for the board and that is the workbooks. 

It's, in effect, we're about right now, we've just 

begun the Rocky Flats workbook is on the web on the O 

drive, downloading it, we're starting to work on it. 

Now we're engaging in this, some of these are 

extremely sophisticated, complex tools. I think we, 

what I'm going to offer is that the workbook review 

process somehow become part of the working group 

operation. That is, in effect, if I understand the 

workbooks correctly, all of these questions are 

solved. That is, it is a mechanical process where 

all of the lower limits of detection, all of the 

decision points, everything, or as much as humanly 

possible, is built into some of these extremely 

complex workbooks, maybe all of the, many of these 

questions on Rocky Flats which is right before us 

right now. 
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We're concerned that once we dive into these 

workbooks, we're going to find it's going to be an 

enigma. And that it might be something where we're 

going to have to work very closely with your 

spreadsheet workbook people. The degree to which, 

because we've built workbooks that are enormous, and 

the documentation that goes with a workbook to 

understand not only how to use it correctly, but the 

rationale behind every layer and every sheet and 

every link is not always apparent unless it's very 

carefully laid out. 

Now my sense is that a lot of these workbooks 

were put together to help the dose reconstructor get 

through a complex process quickly and efficiently and 

consistently. But perhaps, you could tell me perhaps 

the level of documentation and guidance and training 

is very advanced that you have put in place to make 

sure that these workbooks are being used correctly. 

I'm concerned that we have not been part of that so 

that here we are. We're going to download the Rocky 

Flats workbook and try to dive into it, and we might 

be diving into an ocean that we're going to try to 

swim. 

I think that we need to work more closely with 

the working group and with you. And you're in a 
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position to judge. Some of the workbooks may be very 

straightforward. For example, the 28 radionuclide 

workbook is straightforward, but I'm not sure, for 

example, Rocky Flats is going to be very important. 

And I'm not sure how advanced and how complex that 

workbook is. But if it is like the Savannah River 

one, for example, which is a set of three I believe, 

that are incredibly complex, I think we have to start 

thinking in a different paradigm to use an overused 

word on how we're going to engage. And so I'd like 

to put that before the board as to how we're going to 

proceed with the workbooks. 

DR. ZIEMER: And that's not a discussion we'll 

have right now. I want to return to Savannah River 

and see if there are further questions specifically 

on this presentation. And Savannah River will be 

back on our agenda tomorrow as well so we'll have a 

chance to talk about next steps. 

Yeah, Mark. 

MR. GRIFFON: Just one more thing along the same 

lines that I just mentioned. There's, in the 

procedures review that's coming up later in the 

agenda, there was some -- this is to exemplify some 

of my confusion on this -- some of the NIOSH 

responses, and I think I may have these procedures, 
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technical information bulletin. I think it's TIB 

0007. 

One NIOSH response indicated possibly canceling 

that TIB and including the detailed information in 

the site profile. So I'm wondering if, you know, I 

thought the procedures were going to be more 

prescriptive of what a dose reconstructor would do. 

And now some of that's being put back into a site 

TBD. So I guess, you know, I guess it all does come 

down to these workbooks. But is there any written 

guidelines? 

DR. NETON: I think it's always been our intent 

that as we develop these technical information 

bulletins they get rolled up at some point into the 

site profile because they would tend to be more 

generic. I mean these are generic approaches to 

addressing a varied series of complex details that 

occur. And a lot of thought goes into these TIBs to 

say, well, yes, we acknowledge that SC&A thinks that 

there's all these incidents around these areas and 

solubility's an issue. These TIBs tend to be 

bounding-type calculations that do allow for economy 

of a person's time to do these things. And so --

MR. GRIFFON: So then I guess the notion would be 

that if you had site-specific guidance related to a 
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certain TIB, it would go in the site profile. But 

also if it had certain parameters such as John was 

discussing, it would be built into the workbook -- 

DR. NETON: Right. 

MR. GRIFFON: -- and carried through the... 

DR. NETON: I guess enough said on that. 

DR. ZIEMER: Thank you very much. 

Y-12 SITE PROFILE REVIEW 

We go on now to our next item on the agenda which 

is the Y-12 site profile review. Again, we have two 

presentations. This says John Mauro, but I think 

it's going to be Joe Fitzgerald it appears. So Joe 

Fitzgerald who's here on behalf of SC&A will present 

their review and Jim Neton will have an opportunity 

to respond. 

DR. ZIEMER: Joyce, can you hear now? 

DR. LIPSZTEIN: Yes, I can hear Joe now. 

SC&A PRESENTATION, MR. JOE FITZGERALD 

MR. FITZGERALD: Thank you for the opportunity. 

We discussed this back in July, so I'm going to 

really kind of hone this down to some of the issues I 

think are going to be important over the next couple 

of months that we've already started a dialogue with 

NIOSH a couple of weeks ago. 

I'm going to go over five of the eight or nine 
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findings that we have, and of course, you have the 

handouts. First of all, this is one of the earliest 

site profiles, and as with Savannah River, we 

understand we're looking at a snapshot that's almost 

two years old and there's been a lot of work since 

then in terms of TIBs and workbooks, and you name it. 

So to some extent we're acknowledging the fact that 

there may be some developments that weren't captured 

by looking at the TBD itself. And we're certainly 

open to clarifying that. 

Just off the top, one issue that has continued to 

be of concern is this notion, this worker population 

of maintenance support workers, service workers. A 

plant like Y-12 historically had a large group of 

workers that weren't on the line or assigned to a 

facility per se, but really were available for the 

entire site. And Y-12 being a kind of a selfcontained close-in site, you could, you know, give 

people assignments and move them around the site 

during the work week where they were needed. 

So you had a group that, for want of a better 

word, in fact, they called themselves the outside, 

you know, support staff as opposed to the inside 

support staff. The inside support staff were 

maintenance workers and people like that that were 
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actually assigned to a facility, to an operation, say 

a 92-12 maintenance person would have been certainly 

associated with that particular operation. And in 

those cases, those workers, were effectively badged 

and monitored as were the process workers. 

This group of workers though, these so-called 

outside workers weren't monitored. And again, let me 

tell you, we interviewed something like 40 to 50 

workers split fairly evenly between the maintenance 

and support types and the production folks and with 

vintage -- I guess that's not the right word -- with 

tenure going back into the late '60s and early '70s. 

So I was actually pretty surprised we were able to 

find people that went back that far. 

We really didn't have a whole lot of luck, and 

this was an expedited review. As you recall, the 

board wanted to have this review done relatively 

quick so we started in July and finished probably 

mid-August. But we interviewed these workers, and 

thankfully they certainly corroborated that they 

weren't routinely bioassayed before the mid-'90s, and 

of course, weren't externally monitored before '61. 

And the concern that we have effectively is that 

these workers were given assignments throughout the 

different operations over the different time frames. 
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They supported not only the Y-12 operations but also 

the Oak Ridge National Lab tenant operations that 

were onsite as well. Well effectively, they were 

exposed to just about everything that was going on in 

the plant at some given time. And were, in fact, 

likely exposed. 

There's no way to really know since they weren't 

monitored very effectively and exposed to the 

recycled material. They were exposed to certainly 

the limited PU that was handled at the site and 

certainly thorium operations. They effectively did 

all the cleaning, all the mopping up, and effectively 

some of the dirtier operations because again, they 

were in the maintenance class, and they tended to 

have to do those kind of operations. 

And we were able to get, I think, a number of 

recollections of the types of activities that were 

underway. But they tended to be what I would 

characterize as more dirtier activities from the 

radiological standpoint. 

And the concern certainly is that we couldn't 

find any specific records and the activities these 

workers were involved with, in my view certainly, and 

certainly from their standpoint, were unlike those in 

the production operations. If they came closest to 
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any type of worker, it was probably the maintenance 

workers that were supporting specific line operations 

but only to the extent that they certainly were 

exposed to some of those source terms. 

But these workers, which makes them rather 

unique, were also exposed to source terms elsewhere 

in the plant which the specific inside maintenance 

workers would not be nor would the process operations 

people that were working specific facilities like 92-

12 and 92-06. So we did spend the time we had trying 

to nail down whatever, you know, records would kind 

of stipulate where these people were and where they 

worked and what time frames. 

But as they would attest, those kind of records 

were not kept in any systematic way. I mean, they 

truly were an available resource that was used almost 

on a daily basis for whatever support activities 

would be needed at that time. I make the notation 

that, you know, this is analogous to, I think, your 

transient worker, in a sense outside contractors that 

would have come down to -- 

DR. ZIEMER: Your slide, Joe. I think you're a 

slide behind. 

MR. FITZGERALD: Sorry about that. 

The last bullet sort of acknowledges that this is 
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similar but not identical to the situation you'd have 

with a transient worker. But the difference is, of 

course, the transient and the construction workers 

were outside contractors that would be coming in as 

subcontractors. These were Y-12 employees. And I 

think the notion here is that in addition to being a 

coworker challenge, this is a worker population that 

is kind of a unique group that beyond not being 

monitored, were doing operations that were fairly 

specific and different than the production employees. 

Now finding two is something we did have a chance 

to talk about two weeks ago. And I think Jim was 

beginning to provide some feedback on this. So the 

process of beginning to understand the issues it has 

started. But I would also add to what Mark Griffon 

was saying earlier. We do need to move right into a 

six step process to begin to converge on this. 

But in this case once you get beyond the question 

of the worker category and to what extent you can pin 

down that category and understand what may be a 

potential pathway as far as a coworker assignment, 

you get into this question of whether on the external 

side you can actually assume that the individuals 

that were badged pre-'61 -- and Y-12 is a situation 

where '61 was truly a threshold on the heels of the 
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criticality accident that happened in the late '50s. 

They went from virtually having only a quarter or 

less of the worker group monitored. I think it was 

two to 25 percent to almost everybody being monitored 

after '61. 

And so the question is can you frankly as the TBD 

suggests, use the badged personnel and assume that 

the badged personnel before '61 represented the 

maximally exposed individual, this so-called ten 

percent. And we had a number of questions on that, 

really clarification questions. We didn't see a high 

degree of corroboration in the TBD, couldn't see the 

basis for making that assumption, and this is 

something that we're looking to NIOSH to do. 

And I think Jim has certainly some information on 

that. But that's certainly a concern because on the 

external side for both worker population in general 

and the support workers in specific, that's going to 

be a crucial issue on the external side. On the 

bioassay side, clearly, that's going to be a problem 

in terms of workers that were not bioassayed, and 

there were certainly a large segment that were not. 

Now I might turn to Joyce and as an experiment 

see if we can do this from Brazil. 

Joyce, do you have our slides in front of you? 
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DR. LIPSZTEIN: I couldn't hear you, but I have 

your slides. 

MR. FITZGERALD: Okay, we're going to attempt 

this, and if it doesn't work out, I'll just take 

over. But Joyce was a key author, in fact, the key 

author in this section on internal and certainly had 

a number of concerns that, again, we wanted to 

clarify how these were addressed, what assumptions 

were driving the internal dose TBD. We did have some 

exchanges with ORAU, but I think we still have some 

concerns that have not been resolved. 

And Joyce, I'm going to try this. Can you walk 

down the five or six points beginning with the fact 

that we don't believe Type F as a solubility class 

was addressed adequately. 

DR. ZIEMER: So basically, you want Joyce to go 

finding --

MR. FITZGERALD: Can you go down finding three? 

DR. LIPSZTEIN: I'm sorry, can you repeat again? 

DR. ZIEMER: Finding three, Joyce, can you lead 

us through that page? 

DR. LIPSZTEIN: Oh, okay. 

First of all on the intake model that was used 

for the coworkers, the Type F uranium compounds were 

not considered, and that's, but there's no 
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information why Type F uranium compounds were not 

considered since it is clearly stated as the internal 

dosimetry. (Inaudible), but many workers (inaudible) 

Type F compounds. And when you go (inaudible) the 

dose in the body, in the different organs of the 

body, systemic organs, then Type F many times it's 

more conservative than the other types of compounds 

from Type M and Type S. So there was no explanation 

why Type F uranium compounds were not considered. 

One has to remember that when you go back from 

bioassay results, it's different than analyzing some 

intake. So when you analyze the data from the 

intake, then Type F is less conservative than Type M 

and S. But when you go back from (inaudible) that 

was used in the (inaudible) workers, then type F 

certainly should have been considered. 

The second thing that was a problem is that all 

particle sizes were considered equal to five microns. 

And then again, the TKBS says that there were many 

particle sizes ranging actually (inaudible) 

considered eight microns instead of five. And then 

again, when you go back from bioassay results to 

doses, then the larger the particle size, then the 

doses are higher. 

The third thing that was not considered was the 
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ingestion pathway. Ingestion pathway should be 

considered especially for people that have cancer 

found in their GI tract organs. This should have 

been done at least for the people that have cancer 

from the GI tract. 

Then there's more good analysis on the 

uncertainty in bioassay measurements and the capacity 

to detect intakes from urine samples after exposure 

to Type S uranium compounds. There are some samples 

are saying that we don't know how the bioassay 

measurements were drawn. We don't know how the 

change from microrems to 24-hour intakes. We don't 

know this and don't know that, but then it's not 

addressed in the TBD. 

And then this fourth thing, the fifth thing is 

the 48 hour delay in the routine urine sample. This 

was not addressed, and it says clearly that there was 

-- in two pages at least in the document 005, that 

the samples were taken after 48 hours, and this makes 

a big difference. It could be type F, it can be up 

to four times more, the dose can be four times higher 

if you consider that samples were taken after 48 

hours. 

And then the thing that I consider one of the 

most problematic things is the use of the 50th 
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percentile intake rate for coworker. I think, I 

strongly think that this is not a claimant favorable 

approach. It says clearly that there was a lognormal 

distribution. We didn't analyze the data from where 

it came because we didn't have access to it from the 

(inaudible) database. So we assume that NIOSH was 

right in saying that there was a lognormal, a 

(inaudible) lognormal distribution. 

(Inaudible) lognormal distribution is 

characterized for urine activity results being 

positively skewed each month. So each month 

(inaudible) high urine activities for the workers. 

So there is a group of workers, I don't know if it is 

the same group or not, but there is a group of 

workers that clearly had a high positive urine 

results every month. Which means that there was a 

contamination every month. Then what NIOSH does is 

to use 50th percentile. When it uses the 50th 

percentile, you get tremendous, you assign to all 

workers that were not monitored values that even are 

below the detection limits for natural uranium 

(inaudible). So this is clearly not a claimantfavorable approach. 

DR. ZIEMER: Thank you, Joyce. 

Do you want her to continue on? 
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MR. FITZGERALD: No, no, I can continue. 

DR. ZIEMER: Thank you, Joyce. 

MR. FITZGERALD: The only two things I would add 

is on the ingestion pathway, particularly for a 

uranium plant like Y-12, but for other uranium plans, 

clearly ingestion is, I understand what Jim was 

saying earlier, but in this particular case it's a 

key pathway that we believe needs to be included. It 

won't rival inhalation perhaps, but certainly for 

certain cancers it would be a major contributor. 

The second thing is on the 48 hour delay, clearly 

this was a practice that was changed in the '80s, 

mid-'80s or so according to the interviews with 

workers. I mean, the explanation was there was a 

desire to wash out the soluble uranium before taking 

the measurements, and that practice was reversed 

sometime in the mid-'80s. It wasn't an exact date, 

but so this wouldn't be going into the '90s and 

present but certainly back in that era. 

The fourth finding is again something that I 

don't think is really in contention, frankly. We've 

had this discussion with the ORAU team and also with 

NIOSH. And we acknowledge and recognize that the TBD 

did not originally address nuclides beyond uranium, 

but there's an active effort underway to include 
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thorium, we understand, uranium 233 and recycled as 

well. We would maybe add a couple more to that list, 

but again, we're trying to provide a complete 

assessment of the TBD which is now over two years old 

and at that time certainly it was limited. 

And that has implications again because certainly 

workers were exposed to elements more than uranium. 

And of also concern was, there was a great deal of 

effort by the facility, to its credit, to segregate 

operations like thorium from uranium operations 

because of the higher activities involved with 

thorium. But there were excursions on occasions, and 

they did have track-outs. So again, it would 

certainly be helpful to have that additional 

information in it. 

The next finding, this is kind of an interesting 

issue. I guess we keep coming back to this question 

almost at each site, and it seems like we also have a 

slightly different bent to the NTA film issue. In 

this case the notion is that the NTA film can be 

relied on because the energies involved with the 

neutrons of question were relatively high; and 

therefore, it was felt NTA film would pick up those 

neutrons. 

However, we're concerned that there isn't in our 
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view enough spectral measurements to firm that 

conclusion up enough, but we feel that there's some 

evidence that we do have more some -- I don't want to 

call them soft -- more moderated neutrons, neutrons 

of lower energies that would not be seen by the NTA 

film. And also, again, trying to pin down the 

reliability of NTA film. 

Those of us who were looking at the Iowa site 

profile sort of remember this debate and there's sort 

of the 700 to 1 MeV range that was the area of 

acknowledged value of the NTA film. Even there I 

think there was some desire to not use the NTA film 

and let's go for the neutron-photon as a better way 

to go. Here it's just the reverse that the NTA film 

seems to be the valid way to go. And by the way, we 

can actually see the neutrons down to 500 keV. So 

certainly a question of consistency. 

We're concerned about, you know, exactly where 

does that fall? Are we that confident that the 

energy spectra at Y-12 historically, in fact, would 

have been picked up by the NTA. We have some doubts, 

but certainly if one came up with more energy spectra 

measurements, I suppose you could bracket this and be 

firmer about it. In any case... 

Since we did cover this in July and have had a 
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chance to chew on this a bit, I'm not going to spend 

a lot of time on this. I think the focal point that 

likely the board and we will be faced with were 

amongst those four or five issues. These issues we 

certainly feel are legitimate, but maybe not as 

important to resolving questions before we get to 

January, and in Lew Wade’s words, trying to converge 

on some of the key pathways. But certainly there are 

elements of scope that could be addressed and should 

be addressed but ones that we think are incremental 

and ones that have been raised before. 

With that certainly Joyce and I will take 

questions from the group and certainly welcome any 

questions. 

DR. ZIEMER: Any questions for either Joe or for 

Joyce? 

Joe, do you know if there was any effort on the 

part of the Y-12 health-physics group to take the NTA 

film readings and adjust them according to the 

spectrum in the location of interest? Because 

typically, even in certainly in the late '50s and 

early '60s, facilities did that. I don't know what 

was done there, but... 

MR. FITZGERALD: We certainly didn't see that. 

Again, this was covering a lot of ground in a short 
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time, but no, we didn't see any evidence of that. 

DR. ZIEMER: Other questions or comments? 

Wanda Munn. 

MS. MUNN: Just wondering about the time element 

that we're looking at now, Joe. Have we started our 

six step process? Are we underway yet or just... 

MR. FITZGERALD: You can consider today the 

launching of the process in a sense because we 

certainly have had a couple of very brief verbal 

exchanges of which this is going to be one today. 

But I think what's going to help this is to get into 

a more formal, documented process over the next month 

or so. And I would also add we haven't plowed into, 

as John was saying, the workbooks. 

So to some extent maybe some of these questions 

will be answered by looking through some of the 

guides and workbooks that we have not seen because a 

lot of our questions are ones where the TBD seemed to 

be silent, wasn't clear. And we don't want to jump 

to the conclusion that there isn't a basis, but we 

can't see it in the TBD at this point. 

MS. MUNN: I was heartened by the comments in the 

monthly report and the comments that John just made 

with respect to perhaps having a little experience 

under our belts now and being able to resolve some of 
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these issues which, to the outside observer, would 

appear to be major stumbling blocks but which really 

and truly aren't if we just have the right 

communication. 

MR. FITZGERALD: Right, we have a full 

expectation to converge on a lot of these issues over 

the next month or so and we certainly take that to 

heart. 

MS. MUNN: Thank you. 

NIOSH PRESENTATION, DR. JIM NETON 

DR. ZIEMER: And the SC&A review was dated 

September 19th, and so Jim's folks have had just only 

a few weeks to look at that, and they do have some 

initial responses which we're going to hear next so 

Jim, if you want to take the floor and have at least 

the first round of responses. 

DR. NETON: I knew I should have gotten some 

throat lozenges for this board meeting. I'm going to 

be doing a lot of talking and hopefully you won't get 

tired of hearing me. 

Again, I'd like to commend SC&A for doing a very 

fine job of turning over all the rocks and finding 

the warts that they might perceive in our profile. 

They do a tremendously thorough job. 

As Dr. Ziemer just mentioned though, we only 
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received this profile on September 19th, and typically 

if any of you haven't looked at these in any detail, 

they're generally around 200 pages. That seems to be 

the target number SC&A shoots for and buried within 

them are a lot of individual observations. 

And I'm encouraged from this conversation that 

for NIOSH to go and address literally the tens of 

observations that go into rolling up these findings, 

I'm not convinced is the best use and the way to 

proceed. I was very heartened to hear John Mauro 

suggest that this workbook issue may help us get to 

some closure on these issues because the fact is SC&A 

is eight site profile reviews into this that if 

history holds will be about 1600 total pages of 

material to address and many probably dozens, if not 

hundreds, of points. 

So I will go through and briefly summarize what 

our take and observations have been on the findings 

to date. I've reproduced these here again, I guess 

more for my own edification, and I'll get right into 

our comments. 

This monitored workers prior to '61, SC&A has 

raised some questions, and they were, we haven't 

really corroborated our contention over, the 

profile's contention that these workers were the 
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maximally exposed workers. This is somewhat 

critical. To me it's probably the most critical 

observation made because it speaks to our ability to 

do dose reconstructions. 

And as one knows, we're in the throes right now 

of doing an SEC petition evaluation for workers in 

this time period. So if we look at this, SOL who put 

the profile together, took a sort of a three-part 

tack here and first did interviews with Y-12 staff 

which were primarily the health-physics staff, asking 

them what did you do? Did you really contend the 

monitored workers who were the most significantly 

exposed? 

And the answer was a very resounding yes. They 

felt that yes, we did. We tried to monitor all 

workers with the potential to exceed ten percent of 

radiation protection guidelines. Of course, that in 

and of itself is not proof because as we know, 

health-physicists may be biased trying to cover up 

past sins or practices. But we went in and pulled 

out a few reports. ORAU has -- SC&A has not had an 

opportunity to see these reports yet. 

These are mentioned in the historical dosimetry 

practices document that covers the beta exposures, 

skin doses. And there's a couple documents in there 
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that speak very nicely to this issue. That is, in 

1958, around the same time period ORAU -- SC&A has 

found a Patterson document 57. 

In that same time frame we see a couple reports 

by McLendon and one by Reeves that talk about let's 

get together with management and see does this make 

sense? Among the issues that they discussed with 

line management were what types of exposures were 

expected in these workers, what was the exposure 

potential, what were the typical exposures in the 

last year, the bracketing exposures low and high, 

what were the expected changes in the exposures in 

the near term, and what were the limits of 

detectability could we really see what we were trying 

to measure? And this was all in the context of 

trying to go from a weekly badge exchange to a 

monthly. So they really did try to consider the 

issues relevant with the line management to who 

should be on these monitoring programs. 

The third leg of this analysis was the trend 

analysis of the monitoring data, and I think it 

speaks nicely and completes the little analysis, and 

if I can get the slide. It's very confusing. Don't 

glaze over on me here, but the blue line's what you 

have, the red dots on the very top are the maximally 
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exposed workers per quarters starting in 19, say, ‘48 

or '50, I guess is where we had data here, going 

through 1980. 

Now in 1960, as Joe Fitzgerald accurately pointed 

out, that they went to virtually a hundred percent 

monitoring of workers. What you see here is when 

they went to a hundred percent monitored workers, you 

see no change in the maximally exposed workers. One 

would assume that if the monitoring practices had 

changed, then in this time period the maximally 

exposed workers were not monitored, you'd see them 

starting to, you'd see the trend analysis over here. 

You don't. In fact, what you see is a downward trend 

in the analysis which is this is represented by the 

red line going out past 1960. So that tends to 

corroborate the analysis. 

With a much better analysis of this ongoing, it's 

more straightforward and a little simpler to make the 

point. But I just put this up here as supportive 

evidence of the other two issues, you know, the other 

two areas that were investigated, that is, the 

health-physicists said they were monitored, and 

there's documentation that said they were monitored 

the highest, and here in fact, the data tend to 

support that issue. Again, I can't overemphasize the 
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importance of this. I think we need to be able to 

come to grips with this, and hopefully SC&A and NIOSH 

can discuss this and come to some mutual 

understanding here. 

The other issue is this 50th percentile for 

bioassay data. I'm not sure where Joyce was coming 

from. I don't know whether she maybe misunderstood 

what our approach was, but what we're suggesting here 

is that we would apply the 50th percentile bioassay 

data to workers who were not monitored that in our 

opinion did not need to be monitored. 

Again, these were the administrative-type 

workers, those who infrequently visited the process 

areas. These were not the people, the chemical 

operators with their nose in the operations, 

grinding, cutting, you know, purifying, doing things 

that would have a tendency to generate large airborne 

concentrations. 

We believe that this value is very claimant 

favorable for those who were not monitored. They 

weren't on the program. We know that the program, 

given that they took almost a million air samples 

during this time frame, were very acutely aware of 

what the exposures, potential exposures, were in the 

workplace. We agree that certain maintenance 
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workers, staff, those types of folks, could have had 

exposures, but we don't believe that it's appropriate 

to assign them at the 95th percentile of the monitored 

workforce. 

What you have in effect then, is a situation 

where you're assigning larger doses to 95 percent of 

the unmonitored workers than what the monitored 

workers ever received. So if you have a person with 

a complete bioassay record, 95 times out of a 

hundred, you would assign a larger dose to someone 

who had no monitoring. It just does not make sense 

to us. I went over this we gave the workers with the 

highest potential for exposure were monitored, and we 

need to discuss this with SC&A. 

The other issue is a chronic exposure model was 

assumed here. We've talked about that. How we 

believe that this tends to cover incident-type 

exposures. Many results even among the monitored 

workforce were less than the detection limit. And 

again, I suggest that incident data is included in 

the analysis. 

DR. LIPSZTEIN: Hello? 

DR. NETON: Yes. 

DR. ZIEMER: Joyce, you have a question? 

DR. LIPSZTEIN: No, I couldn't hear. 
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DR. NETON: It must be my voice. I don't think 

I'm talking any more softly than others, but maybe 

Joyce is just being kind. 

I'm getting into some issues I think that Joyce 

might be interested in hearing. We believe that the 

internal dose model adequately addresses chronic 

exposures. One thing that we need to look at, and 

we've taken some look at this. We have roughly, 

after 1952 or ‘3, I believe, about 30,000 urine 

samples per year. I mean, this was a fairly well 

monitored workforce. Well, the workforce that a lot 

of samples were taken on. I don't want to make any 

characterization judgment here. 

But SC&A assumed, or they didn't assume, I think 

they inferred from our analysis that all samples were 

taken on Monday morning, and there is something to 

that effect in the profile. We've gone back and 

looked at the data, and in fact, probably it looks -- 

I can't remember the exact figures, but somewhere in 

the 20 to 30 percent of the samples were not taken on 

Monday morning. This makes a huge difference in the 

chronic exposure model. 

I think that the SC&A review indicated there's a 

factor of three to four difference if you took it on 

Monday. It's sort of a, there's usually sort of a 
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worst case bracketing analysis. You're exposed all 

year to a chronic exposure. You take Saturday and 

Sunday off and you take one sample. That's a pretty 

rare occurrence in this program where most workers 

were monitored at least quarterly, more likely if 

they worked with uranium, weekly. 

But again, the samples, about 30 percent of the, 

20 to 30 percent were taken during the workweek which 

tends to minimize or mitigate that issue with this 

two day layoff. And in fact, a lot of that Type F 

stuff kind of gets smeared into the background when 

one does the analysis. We're still working this. 

It's not nearly as straightforward as the SC&A 

analysis implies. These workers were not exposed 

seven days a week, primarily there were five maybe 

six with a day or two off, sometimes overtime. So 

we're looking at this closely, but we don't believe 

it to be as big an issue as the review seems to 

indicate. 

One issue here is the variability of the bioassay 

techniques. Joyce alluded to the variability of the 

sampling techniques and maybe the urine volumes and 

all that sort of thing. When you have 20,000 or 

30,000 samples, and you generate a coworker 

distribution, it is our opinion that the inherent 
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variability in that distribution encompasses all 

those other sources of variability. In other words, 

you have the same people who maybe worked side by 

side and inhaled the same amount of material, so 

you've got a hundred people, variability is going to 

be inherently included in that analysis of the 

distribution. 

So we need to talk about that with SC&A. We 

believe that this is a very appropriate technique to 

account for uncertainty. It's really the strength of 

large numbers. When you have 20, 30,000 or 

something, you have a pretty good feel for the 

variability of the process. 

The solubility of material, there was some issue 

made about Type F versus Type S. The profile has 

adopted this Type M material. It's based on some 

pretty solid investigations by the Y-12 staff. We 

believe Type M to the greatest extent is 

representative of the typical exposure of the 

workers. We're not suggesting that we would ignore a 

special situation where we knew a person was working 

with uranyl nitrate solution or something like that 

and account for it. 

But by and large the analyses that we've looked 

at -- and we'd be certainly happy to sit down with 
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SC&A and discuss them -- indicate that the Type M at 

Y-12 is a very reasonable approximation of the 

exposures. And again, this chronic exposure model we 

believe tends to bound incidental exposures. 

We get into the issue of neutrons, I think Joe 

had a pretty fair depiction there. I think the 

profile review questioned whether we could see below 

an MeV, an MeV energy. There is a new report out 

ORAU Report 33, which I believe was available at the 

time this profile was evaluated, that addresses these 

issues. I think that we make a strong case that the 

nuclear track emulsion-type A film, that's what NTA 

stands for, is sensitive down to about 500 keV 

although we acknowledge that there are suppression 

factors that need to be applied. 

As you go below one MeV, the film is less 

sensitive and the Report 33, I believe, includes some 

tables that indicate the extent that that correction 

factor needs to be made. And in fact, there are some 

recommendations from ORAU, and I'm sure whether it's 

in this report or not, that actually speak to the 

correction factors that should be applied on a 

exposure-dependent basis, whether it was a cyclotron 

or a californium source or something of that nature. 

So we think we've got a better handle on this. I 
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think ORAU has done a good job with this Report 33. 

I might add SC&A, Y-12 has the most information 

written on it of any of the sites so far. If you add 

up all the pages that NIOSH has written with the site 

profile and all the technical information bulletins 

and the reports, we have amassed about 580 pages of 

written material on this site. If you add the couple 

hundred pages that SC&A has done, you're approaching 

800 pages of written documentation on the Y-12 site. 

So I think it's some site we know quite a bit about 

although sometimes the more you know, the more it 

encourages debate and discussion which is good. 

I think that covered, I know I have a couple 

areas of agreement that Joe talked about. We do 

agree from time to time. We do believe that the 

profile lacked significant discussion of thorium 

activities. There was a, this is what surprised me, 

actually, how much thorium activities there were at 

Y-12 at one point. In fact, I was surprised when we 

found the database that had 90,000 air samples for 

thorium exposure and 10,000 individual lung counts. 

So clearly, it was an operation that they knew had a 

hazard associated with the thorium as a pretty large 

dose per unit intake-type nuclide. And so there is a 

technical bulletin being written right now that 
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fleshes out this issue into much more detail. 

We also agree that additional discussion is 

required for these radiation-generating devices. 

It's sort of a unique situation at Y-12. I mean, 

it's, there's three sites very closely involved, X10, Y-12 and K-25. The resources were shared. It 

appears to us that a lot of the exposures from these 

radiation-generating devices were really under the 

purview of the National Laboratory. They happened to 

be located at Y-12, but it was National Laboratory 

personnel. 

We're rethinking where the exposures need to be 

addressed. Is this really an X-10 issue or is this a 

Y-12 issue? And we agree that that needs to be 

discussed in some better detail. And wherever this 

characterization ends up, we recognize that the 

energy spectra are somewhat different than your 

normal, garden-variety Y-12 spectra with cyclotrons 

and x-ray machines and that sort of thing, and we 

agree that that needs to be fleshed out. 

Now, I think that finishes my formal comments. 

DR. ZIEMER: Thank you, Jim. 

Now again questions from board members. 

MR. GRIFFON: Jim, just one quick one. On the 

50th percentile bioassay distribution. Does that, I 
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mean, is that, I think that's the data I just 

received. 

DR. NETON: Yes, right. 

MR. GRIFFON: Is that done on an annual basis or 

is it all the data put together to get a 50th --

DR. NETON: It's a monthly basis. 

MR. GRIFFON: Monthly basis. 

DR. NETON: We took the distribution of bioassay 

samples every month. 

MR. GRIFFON: And does it include zero values or 

below detectible? 

DR. NETON: Yes. 

MR. GRIFFON: They're included in the 

distribution? 

DR. NETON: Correct. Yeah, that's the only way 

one can do it. I mean, if you fit these lognormal 

distribution curves, you allow, you could take 

advantage of the fact that the first frequency point, 

it may be, and it may actually be in certain cases 

that the distribution, the 50th percentile, is 

actually below the MDA or the (unintelligible), the 

critical level of the analysis. I think that's 

pretty instructive though. I mean it shows that you 

can almost infer what the people are being exposed to 

even though it was below the detection limit because 
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it's a power of numbers. 

If you have 30,000 samples, and your detection 

limit is say one DPM, and you have 80 percent of your 

samples less than one DPM, I think you have a pretty 

good feel of people being exposed to less than one 

DPM. And we can discuss that in some detail. I'd 

like to go over this with SC&A. This is not 

something NIOSH made up. I mean, this is a 

literature-type review stuff that is not commonly 

encountered, but it's a valid technique we believe. 

DR. ZIEMER: Any other comments? 

Okay, thank you very much. 

So we're off to a good start on the Y-12 process 

of getting issues out there and resolving them. 

Hopefully, we'll be able to move along on this at a 

good pace and bring it to closure in a timely 

fashion. 

ROCKY FLATS REVIEW STATUS REPORT 

DR. WADE: I listed Rocky Flats on the agenda for 

this. John Mauro had sent out a note raising a Rocky 

Flats issue that he thought was particularly 

important to get before the subcommittee and the 

board, and that was the high five plutonium issue. 

And John had asked that he be given an opportunity to 

raise that. 
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I think there's been some subsequent 

developments, John, that maybe have tempered that, 

but it is on the agenda. 

DR. ZIEMER: Yeah, and Rocky Flats is simply 

going to be a status report, and I think we have that 

issue from SC&A and probably don't have anything 

specific from NIOSH on Rocky at the moment. 

But, John, you did raise that issue. I think the 

board was e-mailed on that at my request. You 

notified the board members of that issue at the time 

although it's involved a bit, but remind everyone 

what it is, and... 

DR. MAURO: I just wanted to point out as we go 

through this process, and as we identify areas that 

we think are especially important to bring to the 

attention of the working group especially, and of 

course, NIOSH, what I did at that time, I think at 

that time I sent out an e-mail to, as sort of a heads 

up regarding two matters. 

One was Bethlehem Steel and the fact that we had 

this concern about the need for an adjustment factor. 

And the other was to give an update of where we are 

related to some of the things we're seeing regarding 

Rocky Flats. In fact, the person who's actually 

alerted me to it has to do, the issues have to do 
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with lower limits of detection, urinalysis, three 

important points that I think we're going to be 

moving through. As we move through, you'll be 

receiving our Rocky Flats report. Actually, I have 

the full document in my briefcase, and I'm doing a 

read on it right now. And so it's moving through the 

pipeline. 

But there are three areas that I think by way of 

a heads up that are important. And to the extent you 

want to get into at least some introductory aspects 

of it, three areas. One is urinalysis. Namely, in 

the early years of Rocky the main one which you were 

able to evaluate plutonium exposures, which were 

urinalysis. And we're finding that the lower ends of 

detection that you can see using urinalysis is 

associated with fairly high doses, very high doses to 

the lung. And that's going to be an important point. 

The second point has to do with high-fired 

plutonium and its relation to urinalysis. You could 

almost envision if you inhale plutonium, and let's 

say it's a Type S. It has a certain kinetics, a 

certain amount will go to the urine. Now we raise 

the question of well, there are forms plutonium could 

take, and without getting into details where the 

clearance rate might be a lot slower and if it's of a 
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high-fired nature. 

What are the implications of that? Because if 

you take a urine sample, and you see something, or 

you don't see anything, or you see something just 

above the lower limits of detection, how do you 

interpret that in terms of the dose to the lung or 

any other organ? If you're not sure whether it's 

Type S or it's Super S, and there are implications 

there. So that was the second area of inquiry that 

we're right in the middle of working very closely on. 

And the third area has to do with when they, as 

the program matured, they took chest counts whereby 

in addition to urinalysis, which as I mentioned, you 

really can't see very, you have to have fairly high 

exposures, you get very high doses to start to see 

anything in the urine. But with chest counts, you 

see the americium 241 that's coming off. 

And the issue has to do, and that really improves 

your ability to see a body burden, a lung burden. 

But one of the areas we're exploring right now, in 

fact, we discussed in one of our conference calls, 

working group conference calls, is that it's possible 

that you don't always have americium 241, and there 

was (unintelligible) of plutonium depending on the 

campaign. The amount of americium 241 that might be 
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associated with the plutonium 239, I'm sorry, 

associated, the amount of americium 241 that might be 

associated with the plutonium 239 could vary quite a 

bit. 

So how you interpret the lung count where you're 

looking at the americium 241 because you're blind to 

the plutonium 239, so then you have to infer what the 

body burden or chest burden is of the plutonium 239 

from the reading you're getting from americium 241. 

But if there's uncertainty regarding the relative 

amounts of plutonium 239 versus americium 241, then 

there's a lot of uncertainty regarding what the chest 

burden is. 

So these are the three areas that we're looking 

very closely at and I think that at some point a 

working group meeting along these lines is probably 

going to be in order to pursue them a little further. 

And I just gave you a real snapshot of it. The 

people that have been looking extremely closely at 

this issue are Hans Behling and Joyce Lipsztein. So 

I mean, if you want to hear a little bit more about 

that certainly we can call Hans to the microphone and 

tell you a little bit more about where we are on 

making those investigations. 

DR. ZIEMER: Thank you very much. 
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And on the high-fired plutonium issue, 

conceptually, I believe, the assertion is that the 

turnover rate would be so low you may not see it in 

the urine and still have a fairly hefty lung burden. 

In fact, the turnover may be so slow that if somebody 

asserts that, in fact, they, if a claimant says this 

is my issue, a claimant might not come up with it 

that way, but if we said a claimant may be in that 

category, it seemed to me that we ought to ask the 

question whether or not that claimant could not be 

subject to a lung scan and determine, now again, 

depending on the americium issue it may not be even 

determinable in that case. 

But there also is a legal issue, I guess, as to 

whether or not you could require such a scan of a 

claimant. And I asked this question and wondered if 

somebody could at least look into that issue. This 

would be a case where you'd say if such were the case 

the high-fired plutonium should still be there, and 

therefore, be detectible possibly. 

DR. NETON: I'm not sure that NIOSH would go to 

that extreme --

DR. ZIEMER: Well, that's what I was really 

asking. 

DR. NETON: -- exposure. I think, you know, we 
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have taken a very serious look at this high-fired, 

super insoluble plutonium issue, and we need -- 

there's merit to it. I mean, the Rocky Flats 

certainly has situations where the plutonium is very 

insoluble. Our contention is though that if the 

material is so insoluble that it never leaves the 

lung, then the dose to systemic organs would be very 

small. 

And if we assume that it's Type M material using 

a detection of limit for the bioassay meaning it 

leaves more rapidly, we'll be overestimating the 

doses to the systemic organs. If it -- we use Type 

S, right now to this day, I cannot think of any case 

that has not been compensated even just using 

moderately insoluble plutonium. So --

DR. ZIEMER: Well, let me ask, and I don't know 

the biology of this well enough, but could you have 

clearance to the lymph glands through macrophages? 

DR. NETON: Yeah, that's an area we're looking 

into, whether the super insoluble material ends up 

being sequestered in the lymph nodes or remains 

sequestered in the pulmonary compartment. It turns 

out, this is a very, very valid, interesting 

scientific issues. It turns out then for instance in 

the (unintelligible) workers in Russia who were 
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exposed to very large amounts of plutonium, the 

plutonium does not appear to leave the pulmonary 

compartment. Now one does not know whether that's an 

inherent property of the insolubility of the 

plutonium or it may have more to do with the lung 

damage sustained either through the alpha activity in 

the lung itself or the concomitant chemical exposures 

that occurred along with these materials. So the 

short answer is we don't know. 

DR. ZIEMER: Thank you. 

Are there any other questions pertaining to this 

particular issue? 

Okay, thank you. I'm going to ask the board 

members if, do you need a break before we -- I see 

levels of discomfort around the table. Let's take a 

ten minute break and then we'll reconvene. 

(Whereupon, a break was 

taken after which the 

following transpired:) 

SC&A CONTRACT TASK III REVIEW, NIOSH PRESENTATION 

DR. ZIEMER: Our next topic is an item which is 

carried forward for awhile. It's the procedures 

review. One of our early tasks was to ask SC&A to 

review the procedures that NIOSH and ORAU use in dose 

reconstruction. And so we have the, and that was 
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Task 3 of the procedures review. That review has 

been completed for quite some time, but in a sense 

got back-burnered because of more pressing issues, 

dose reconstruction and SEC issues. 

But now in the meantime, NIOSH has had a chance 

to review the findings of SC&A, and they in turn have 

provided responses. And our work group has gone over 

the NIOSH responses and is going to be recommending 

to us, and I think we'll actually do that tomorrow, 

what action the board should take on each of the 

items. 

And board members, although we're not going to 

cover it in detail right now, you should have, there 

are three versions of the so-called findings matrix 

that's called Summary of Task 3 Procedure Findings 

Matrix. The first version of that, I think, was 

distributed, I don't know, a few weeks ago, and it 

had the findings of SC&A, and it cross-referenced the 

finding number and where it was in the report and so 

on. 

Then NIOSH recently generated their response and 

so the matrix has the NIOSH responses included, and 

then Mark Griffon has generated a recommended action 

one. So the final version which, was that 

distributed today? 
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MR. GRIFFON: Yes. 

DR. ZIEMER: Hot off the press, has a column even 

entitled Board Action which is a recommendation which 

comes from our, out of our work group, and we'll have 

a chance to act on that tomorrow. But we'll start 

out with the NIOSH response, as it were, and Stu 

Hinnefeld is going to bring us the presentation for 

NIOSH. Stu, I don't believe, is going to go through 

each individual item, but will -- 

MR. HINNEFELD: I'm not. 

DR. ZIEMER: -- give us an overview of their 

response to the findings. 

So Stu. 

DR. WADE: Just a clarification. We have the 

complete work on the external dosimetry. 

DR. ZIEMER: Oh, yes, right. The portion of the 

matrix that's been completed, by completed I mean 

includes NIOSH response and board action 

recommendation, is only roughly the first half of the 

matrix dealing with external dose reconstructions. 

MR. HINNEFELD: Thank you. 

I started out with just a little history of the 

project that was performed by SC&A. The final draft 

report initially was delivered back in January, and 

this was prior to any of the dose reconstruction 
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review reports, the dose reconstruction review 

reports that SC&A subsequently embarked upon, so they 

got the procedures and read the procedures. 

And I think that they would also tell you, the 

reviewers would also tell you that after having 

reviewed some dose reconstructions, they now have 

probably a better understanding of the structure of 

the procedures and may have written things a little 

differently, which is not to say that necessarily 

anything they wrote is particularly wrong, but they 

may have focused on different things had they done 

the dose reconstruction reviews first then gone on to 

the procedures. 

I've read some of the timeline up here. The 

first compilation or matrix of the findings was 

prepared, I think it was August 22nd . That was the 

date I found in my notes. It was just prior to the 

previous board meeting. And that activity or that 

process was extraordinarily helpful to us to take the 

report and to condense it on to a series of sort of 

cogent statements of the finding. It certainly made 

it much easier for us to provide some evaluation 

response to the finding in a more structured format. 

Now on October 4th, the entire completed matrix 

was distributed and that was just prior, yeah, that 
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was just prior to an October 6th public meeting in 

Cincinnati of the working group where we went through 

the findings on the matrix from where we had our 

initial responses back from the, on the external 

dosimetry findings and discussed potential 

resolutions. And now I've not actually seen the 

recommended board action column, but that was 

generated at that meeting. 

And then there were a few minor edits from the 

matrix that were provided a little bit later, but 

those were just strictly, they were mainly typo kinds 

of things or clarifications. I don't think there's 

any particular substantive change that came out after 

the October 6th meeting. But the version that was 

distributed has those included. 

Our view of this is it was really thorough. It's 

big, and it was a very thorough and thoughtful review 

of procedures. I think it provides valuable feedback 

throughout. There's very little in the report that 

we take issue with, maybe a couple things that we 

think aren't particularly supported well. I think 

there might be some comments that expect more detail 

in a particular document than we had expected to put 

there. So there will be some things like, that might 

fit into that category, but generally, we were, we 
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thought it was a nicely done and well explained piece 

of work. 

We have a number of corrections and 

clarifications and evaluations that we're doing as a 

response to that as well as probably canceling a 

couple documents that have probably been overcome by 

events. And these documents are maybe three years 

old and in the interim, you know, better procedural 

documentation is put out and better organizational 

assignment of responsibilities is identified. And so 

there are probably some things that were obsolete 

that we'll probably just do away with. 

I've gotten on at the end of the distribution or 

in here the list of the procedures that were reviewed 

from the external dosimetry standpoint. I guess from 

our standpoint of, I don't know, there are about 

three pages of these and they are in the handouts, 

but these were the external dosimetry procedures that 

were reviewed as part of the process. 

I guess I would categorize our initial response 

as, of course, we're pretty wordy too, so our initial 

responses are fairly long. But I kind of put them in 

maybe about five categories. There are a few 

comments that we would think are not well enough 

supported that we just don't think that they warrant 
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a revision. We think that we don't necessarily agree 

with the comments, but there are not very many like 

that. 

There's some comments that we believe call for 

more detail in a particular procedure than what we 

intended that document to include. So we also would 

feel like there will be some procedures in that 

category, or comments in that category. Well, we 

wouldn't necessarily take issue with the comment. We 

understand why they would make the comment, but they 

may call for more detail at a specific point in our 

documents. And we would expect our document to have, 

so we would perhaps not propose to do that. 

Plus, there are some findings that we feel point 

out a, they raise a serious technical issue that 

needs at least careful evaluation and quite likely 

modification to the documents we've published and 

then probably a retrospective look at what might be 

affected by this technical change in approach. 

There's a category of comments that we don't 

think requires a technical change to the work 

completed. It doesn't cause us to change our 

technical approach to the work that we're going to do 

in the future. But it does require a much clearer 

description of the technical work we're doing because 
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the document doesn't provide that as it's written 

today. 

And then we have a category of findings that we 

would consider valid findings. You're right; I'm not 

going to dispute the comment you made. But we don't 

know that there's a particularly high priority to go 

change this. If we can make a revision easily that 

corrects this, what gave rise to this finding, we'll 

go ahead and make that correction. Some of the 

revisions may not be that easy, and so we may not 

pursue those corrections, at least not any time in 

the near future. 

Now let me explain a little bit what I meant. 

This would be a finding that the procedure is poorly 

organized, has extraneous information, has a lot of 

fluff in the middle and the important information is 

in the back, and you really ought to reorganize that. 

And reading it and looking at the procedure I'd say, 

yeah, that's probably right. That procedure should 

be, could be, better organized. But that's a fairly 

significant thing to do. That's a fairly difficult 

thing to do is to reorganize a procedure and put it 

in a system, you know, put it back in a format that 

you like better and rewrite the whole thing. 

That's fairly significant and the people who are 
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working on the program, we don't have a lot of 

turnover of people working on the program either on 

our side or the contractor's side. They're familiar 

with how they're structured now. They know how to 

use and the way they're structured now, and so we 

don't know that we gain a lot by making those kinds 

of revisions. 

And then, but there are some procedures that, or 

some comments that would say things like, well, you 

say that this document is giving an illustrative 

example, but it doesn't really seem to say that. It 

seems to be giving definitive guidance and the 

numbers that are there are wrong. And we would be, 

well, we should probably emphasize the illustrative 

example. We've not translated those numbers, and 

it's usually in the implementation guide, the high 

level document. We've not translated those into 

actual practice. 

We're not actually using them anywhere so it's 

not like we've made a technical mistake or a 

technical error from having that document written 

that way. But that's a fairly easy amendment to 

make, edit to make. You insert a little language 

that says, this is included for illustrative purposes 

only and these numbers are not to be utilized as 
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guidance for this site. So that's a fairly easy edit 

to make while it's still in the relatively low 

priority case we think because we've not made 

technical mistakes, and we're not proceeding 

technically in accordance with those numbers. 

So that's sort of a characterization of the types 

of our responses, and unless, I don't think you 

probably want me to read the titles of the 

procedures, and the projector clearly doesn't want me 

to either, so... 

DR. ZIEMER: Thank you very much, Stu. 

Let me ask Mark, do you want to add any comments 

now or just some general things out of the work group 

in preparation for tomorrow's actions on this 

document? 

MR. GRIFFON: Yeah, I think the board actions go 

along those lines that Stu just mentioned with low 

priorities, medium priorities, high priorities. I'm 

not sure in some cases that I distinguished what he 

just said there in the last two examples where you 

might have a low priority but it might require a 

great deal of work as opposed to a low priority, 

fairly easy change. But I think that is reflected in 

the board action. 

I guess the other thing that struck me, and when 
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you review these tonight I think it might be useful 

for the board members to look at this. I think in 

many cases we've sort of pushed the ball down the 

road on a lot of these, and that concerns me a little 

bit that we recommend a certain action which is to 

clarify a document, for instance, but it doesn't say 

exactly how it's going to be clarified. So we don't 

really have an answer to some of the technical 

issues. For example DCF, I think everyone agreed 

that they want to look into it further, but it's not 

clear that we have an answer there yet. So again, 

we've got this issue of tracking these findings over 

time and not losing track of them. 

DR. ZIEMER: Let me make sure I understand. Your 

point is that although NIOSH may have agreed to 

modify or change something, we don't actually know 

what the modification or change would be other than 

saying, yes, we agree that this is an issue and we 

will change our document. 

MR. GRIFFON: Right. 

DR. ZIEMER: Nonetheless that, for the first 

round of doing this, that may be suitable. It may be 

that we will want to have a follow-up with you at 

some point and say, okay, what was actually done? 

think that's what you're saying. 

I 
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MR. GRIFFON: Yeah, yeah. 

DR. ZIEMER: You don't really know what the final 

outcome would be. It could be modified in a way 

which really is unacceptable also is what you're 

suggesting. 

MR. GRIFFON: Right. 

DR. ZIEMER: It seems to me that that probably is 

some kind of a follow-up action on our part otherwise 

this goes on indefinitely. I think if NIOSH agrees 

that there's an issue, the issue's been identified, 

the implication is they will make the modification or 

change to correct or address that issue 

appropriately. Now there's still a possibility that 

you'd say, yeah, but you really missed the mark. 

MR. GRIFFON: Right. 

MR. HINNEFELD: Well, we expect to have an action 

list after this, once we have a board recommendation 

or a board action on these, we expect an action list 

for us. 

DR. ZIEMER: Which would delineate actually what 

you did, and that would be kind of a final step -- 

DR. ANDERSON: Report back to them. 

DR. ZIEMER: Report back with what actually was 

done. And that would be a good closure point, yeah. 

Any other comments, Mark? 
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MR. GRIFFON: Yeah, the only other thing I was 

going to say is just when I put these board actions 

together, and it wasn't really obvious to me in the 

work group meeting, but on page four we break off 

from OCAS-IG-001 to ORAUT-PROC-0006. And basically, 

there's this default line that says that all the 

findings before that sort of apply to PROC-0006 also. 

And I just wanted a clarification in my mind 

because it seems to me that the implementation guide 

is this high level document, but procedure six seems 

to be, at least in my way of thinking, it would be 

more prescriptive, maybe not prescriptive, but more 

prescriptive than the implementation guide. So I'm 

not sure that all the board actions are the same on 

six as they would be on those, on the IG items. And 

maybe Stu can help. 

MR. HINNEFELD: Well, if I may just a little bit, 

procedure six actually repeats a lot of the 

information verbatim out of IG-001. And so to the 

extent that any of those comments in IG-001 are 

reproduced verbatim in procedure six, those would, it 

would be that kind, it would be relevant to procedure 

six as well. Procedure six has additional 

information. Typically, it's oftentimes included on 

an attachment. It gives some specific instruction on 
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how to proceed so, and since barring anything 

specifically on those, then we wouldn't consider 

findings to have been, you know, written against 

those. 

But I believe this was captured this way, and 

perhaps I'm not the person to speak to it, but I 

believe it was captured this way to reflect that a 

great deal of the information in IG-0001 was captured 

verbatim in the procedure six which was copied over. 

And so if you got one, you got a finding in that and 

it's reproduced somewhere else, you got a comment 

that it's a finding on that procedure as well. I 

think that's what happened. 

MR. GRIFFON: Any maybe we need to ask SC&A on 

this one, but I just wasn't sure if we inadvertently 

glossed over something that needed a more -- needed a 

fix in PROC-0006. 

DR. ZIEMER: Hans, do you to --

DR. BEHLING: I will concur with what Stu has 

just said. That procedure six is really an abridged 

version of the implementation guide with the 

exception that there are a series of very, very 

specific attachments which then guide the dose 

reconstructor in terms of what he should do. But for 

the most part the central core of procedure six is a 
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facsimile of the implementation guide, and as Stu has 

already mentioned, what applies there in terms of 

criticism, would also apply to procedure six. 

MR. GRIFFON: So none of the findings were for 

the specific parts that you talked about. 

DR. BEHLING: No, no. 

MR. GRIFFON: Okay, that was my question. 

DR. ZIEMER: Thank you very much. 

Any further comments or questions on this? 

Thank you, Stu. 

We will again return to the detailed comments 

when we deliberate at the, later in the meeting this 

week. 

We're going to move almost immediately to the 

public comment period. In order to do that, I'm 

going to adjourn the subcommittee, and I declare the 

subcommittee adjourned; however, you may not leave. 

(Thereupon, the subcommittee meeting was adjourned at 

3:50 p.m.) 
______________________________ 

178 

1 C E R T I F I C A T E OF COURT REPORTER 

STATE OF GEORGIA 

COUNTY OF FULTON 

 I, Steven Ray Green, Certified Merit Court 

Reporter, do hereby certify that I reported the 

above and foregoing on the day of October 17, 

2005; and it is a true and accurate transcript 

of the testimony captioned herein. 

 I further certify that I am neither kin 

nor counsel to any of the parties herein, nor 

have any interest in the cause named herein. 

 WITNESS my hand and official seal this the 

4th day of December, 2005. 

STEVEN RAY GREEN, CCR 

CERTIFIED MERIT COURT REPORTER 

CERTIFICATE NUMBER: A-2102