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1

NEAL R. GROSS

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U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

CENTERS FOR DISEASE CONTROL

NATIONAL INSTITUTE FOR OCCUPATIONAL

SAFETY AND HEALTH

+ + + + +

ADVISORY BOARD ON RADIATION AND

WORKER HEALTH

+ + + + +

WORK GROUP ON TBD-6000

+ + + + +

MONDAY

JUNE 16, 2014

+ + + + +

The Work Group convened via 

teleconference at 10:30 a.m. Eastern Daylight 

Time, Paul L. Ziemer, Chairman, presiding.

PRESENT:

PAUL L. ZIEMER, Chair

JOSIE BEACH, Member

WANDA I. MUNN, Member

JOHN W. POSTON, SR., Member
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ALSO PRESENT:

TED KATZ, Designated Federal Official

BOB BARTON, SC&A

DeKEELY HARTSFIELD, HHS

JIM NETON, DCAS

JOHN STIVER, SC&A

TOM TOMES, DCAS
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T-A-B-L-E O-F C-O-N-T-E-N-T-S

Page

Welcome and Roll Call ..................... 4

Review of Remaining Simonds Saw and Steel SEC 

Issues for Residual Period

NIOSH response of September 2013

to SC&A Finding 6.................... 5

NIOSH response of February 2014

to SC&A Finding 7................... 10

SC&A position (June 3, 2014) on

NIOSH responses..................... 16

Work Group discussion and

recommendations for Board........... 38

Plans for Presentation at Full Board

Meeting .................................. 40

Adjourn .................................. 53
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1 P-R-O-C-E-E-D-I-N-G-S

2 (10:37 a.m.)

3 (Roll Call.)

4 MR. KATZ: Okay, very good. So, 

5 Paul, it's your meeting.

6 CHAIR ZIEMER: Thank you, we really 

7 appreciate it. I call the meeting to order. 

8 Thank you all for being with us this morning.

9 Our focus is on Simonds Saw. And 

10 Ted Katz, just prior to the official opening of 

11 the meeting, reminded us of the documents that 

12 are before us. And I just repeat again, we have 

13 two documents from NIOSH, one from last 

14 September which is a brief paper dealing with 

15 Finding 6 of the findings matrix dated February 

16 2014, dealing with Finding 7. And then a 

17 document from SC&A, dated June 3rd of this year, 

18 which is the SC&A position on the two NIOSH 

19 responses, that is, responses for Findings 6 

20 and 7.
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1 But all of these papers addressed 

2 clearly -- and what I thought we would do is not 

3 necessarily go through all the details on 

4 Findings 6 and 7. The Work Group and others 

5 have had these on hand for quite some period of 

6 time, but, Tom, give you a chance to add any 

7 comments you want on, first on Finding 6 and 

8 Finding 7. And then we'll go to the SC&A 

9 position paper which basically goes through 

10 these findings, and then give your comments on 

11 those and you can review that for us. That's 

12 just been received within the past week or so.

13 But, Tom, do you want to begin and 

14 then give us any additional comments or remarks

15 on, first on Finding 6 or anything you want to 

16 highlight at this point?

17 MR. TOMES: Okay. Finding 6 

18 concerned the external doses during the 

19 residual period and SC&A had some concerns with 

20 the bases for some of the selected doses in the 
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1 TBD and the justification for those doses as 

2 well as the length of the workday, which we had 

3 discussed previously, and the use of the 

4 distributions in the TBD.

5 Well, we, NIOSH, went through all of 

6 the references. There's various surveys 

7 that's been done over the years starting in, 

8 there was the operational period ending in 

9 1957, which is actually the year they were doing 

10 some cleanups and the surveys were done at that 

11 time and subsequently the surveys were done to 

12 characterize the site, specifically in 1976, 

13 '79-'80 timeframe, 1984 and 1999 and 2007.

14 So we have gone through and -- we=ve 

15 gone and in response to SC&A's finding, we did 

16 have some concerns ourselves with the bases for 

17 some of the values so we went through all that 

18 data again and we're making some 

19 recommendations that we change some of those 

20 values.
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1 We compiled all the data and we have 

2 come up with a bounding dose rate, for 

3 penetrating dose, of 80 micro-R per hour, which 

4 is basically the same value as in the current 

5 TBD as a distribution.

6 But in going through all the data, 

7 we're recommending that dose be retained as a 

8 constant and it should provide a bounding dose 

9 rate based on all the compiled survey data that 

10 we did.

11 And SC&A also commented on the 

12 non-penetrating dose, and the non-penetrating 

13 dose was previously based on an area from the 

14 1957 survey. And there was some data in that 

15 survey that from the 10-inch bar mill it had a 

16 higher beta dose rate.

17 The 1957 survey had 3-foot beta dose 

18 rate readings at the various equipment and the 

19 10-inch bar mill was higher than the other 

20 places, so we simply are deciding that we should 
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1 use that survey data for non-penetrating dose 

2 for all the workers since we cannot tell who 

3 worked at which mill or which area.

4 So we're recommending an increase 

5 in the beta dose rate based on that survey and 

6 there was numerous survey points on that so 

7 we're recommending we just take the midpoint of 

8 that as a constant.

9 And as far as to calculate doses, 

10 we're recommending that we use 2500 hours per 

11 year times the given dose rates to determine the 

12 dose for all the workers. And that is 

13 essentially our proposal for external doses, 

14 and the paper provides some more details and we 

15 have some spreadsheets we've exchanged with 

16 SC&A looking at all the data.

17 They had some observations on some 

18 of the data we did and did not use, but I believe 

19 we came up with a similar number and I believe 

20 they concurred that it should be a bounding dose 
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1 rate.

2 CHAIR ZIEMER: All right, and we'll 

3 get to that in just a moment, but that basically 

4 covers what you discussed in your paper.

5 Let me just stop for a minute and ask 

6 if any of the Work Group Members have any 

7 specific questions on the NIOSH document. 

8 And I'll take the silence as an 

9 absence of questions, apparently.

10 Okay. Then, Tom, let's go on to 

11 Finding 7, give us your comments on that, just 

12 a quick summary.

13 MR. TOMES: Give me one second 

14 here.

15 CHAIR ZIEMER: Okay. And let's 

16 see, I know we have the open meeting, what do 

17 you call it, GoToMeeting, put it online, but 

18 does anyone actually intend to use that today? 

19 Tom, you don't have any --

20 MR. TOMES: I had not planned to. 
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1 I didn't have any presentation to show.

2 CHAIR ZIEMER: Yes, I didn't think 

3 you did, but we're all logged into it so I just 

4 wanted to make sure if you had anything you had 

5 it up. But you don't need to use it. Go ahead.

6 MR. TOMES: I do have it open in 

7 case there's a need to look at anything further 

8 during our discussion.

9 CHAIR ZIEMER: Okay, go ahead.

10 MR. TOMES: Finding 7 concerned the 

11 residual period as well, the internal doses, 

12 and SC&A had a few concerns on how they were 

13 done, one of which was the value we used as the 

14 initial air concentration at the start of the 

15 residual period as well as the value we used at 

16 the end of the residual period.

17 And they also had concerns with the 

18 depletion rate with our TBD as a depletion 

19 ending in 1982 and then the levels remaining 

20 flat rather than the depletion carrying on to 
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1 the end, and we've addressed that.

2 And this was a rather complex 

3 evaluation so we asked the Army Corps of 

4 Engineers for additional data. We had used a 

5 lot of data in their Remedial Investigation 

6 Report, but the Remedial Investigation Report 

7 also referenced that, in some footnotes, that 

8 there was additional data and some appendices 

9 and some spreadsheets.

10 So we got that data from them and we 

11 got the spreadsheets from them, and in looking 

12 at the data we basically decided that we should 

13 probably do a more thorough review of it and 

14 what we had done is come up with distributions 

15 in the contaminated facilities that were there, 

16 inside contaminated facilities where the 

17 operations occurred, and we're recommending 

18 new values based on the evaluation on that data.

19 And the start of the residual period 

20 -- let me go back to the first issue. The start 
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1 of the residual period, we discussed this in a 

2 previous Board meeting and it was determined 

3 that we should probably use the 1954 GA, general 

4 area, air sample data, which is the most recent 

5 data we have.

6 There was GA air samples taken 

7 during the operations and we've taken the 

8 geometric mean of all those results and assumed 

9 that to be the bounding dose rate -- excuse me, 

10 bounding air concentration at the start of the 

11 residual period. And we've connected that to 

12 this new value we got from the Army Corps of 

13 Engineers data from 2007.

14 And we ended up recommending that we 

15 do not stop the depletion in 1982. The TBD we 

16 have made that choice due to the fact that the 

17 facility was roped off and had been idle all 

18 these years. And the data supports that the 

19 facility's basically in the same condition it 

20 was at that time.
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1 However, we found that there is part 

2 of the facility that extends over into the 

3 active warehouse at the facility. The main 

4 area that's isolated is the main processing 

5 area, but there's an area called Building 24, 

6 part of that building is contaminated, which is 

7 the south end of that building. And the 

8 overheads have fixed contamination on them, as 

9 well as some areas on the floor and other places 

10 around there.

11 Most of that building's clean, but 

12 there are areas that are contaminated and 

13 accessible to the people who work there.

14 However, the air concentration is 

15 very low and the Army Corps of Engineers did air 

16 sampling surveys during their work and the 

17 results were low, but we have ended up with the 

18 recommendation that we should take the air 

19 sample results from 1954, assuming it bounds 

20 the air in 1958, and connecting it to the 2007 
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1 air concentrations from the Army's data and 

2 determine a new depletion rate.

3 And that is our -- excuse me, the 

4 last issue was the 2500 hours per year which we 

5 are also recommending. If I did not make that 

6 too confusing, I'd be glad to reiterate any of 

7 those issues that you have questions about.

8 CHAIR ZIEMER: Well, thanks, Tom. 

9 And of course you've given a lot of -- more 

10 detail than that in the paper itself, but let's 

11 again see if anyone has any questions on it.

12 Let me ask you one question, on that 

13 fixed contamination in, was it Building 24 that 

14 was --

15 MR. TOMES: Yes.

16 CHAIR ZIEMER: Yes. On that fixed 

17 contamination is that up in the rafters and so 

18 on as well, was that --

19 MR. TOMES: Yes. The majority of 

20 that contamination is the high levels were in 
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1 the beams in the south end of that facility. 

2 One part of that facility was actually the 

3 loading dock during the early part of the AEC 

4 work and another part of the south end, those 

5 beams were in place, the ceiling beams were in 

6 place during operations.

7 And that part, and that other south 

8 end was actually built during and after the 

9 operations, so there are some areas in there 

10 that they're not contaminated, but there are 

11 some, evidently the ceiling beams had material 

12 sprayed on from furnaces or some other 

13 operations going on in there and they found a 

14 layer of basically just crusted contamination 

15 in the overheads and they did a pretty thorough 

16 survey of it and they were concerned that there 

17 may be high levels of removal and they found 

18 very little and they also pulled air samples for 

19 a few days while they were in there.

20 CHAIR ZIEMER: Are we assuming that 
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1 that remains fixed during the residual period, 

2 then? That's not contributing to the air 

3 activity that's assumed as you go forward in the 

4 residual period.

5 MR. TOMES: That facility is used 

6 in the evaluation -- that data is used in the 

7 evaluation.

8 CHAIR ZIEMER: Yes, okay.

9 MR. TOMES: So we are assuming that 

10 that is one of the data that was used.

11 CHAIR ZIEMER: Okay, thank you. 

12 Other questions? Okay, thank you, Tom. Let's 

13 go ahead then with SC&A's review and analysis 

14 and recommendations. Bob, are you going to 

15 head that up?

16 MR. BARTON: Yes. Thank you, Dr. 

17 Ziemer.

18 CHAIR ZIEMER: Yes.

19 MR. BARTON: This is Bob Barton. I 

20 guess at the outset it's important to remember 
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1 that these new approaches, I guess we'd call 

2 them, are pretty much completely new methods 

3 for reconstructing the doses during the 

4 residual period, so there's a little bit to 

5 digest here.

6 We obviously had some concerns with 

7 the original way things were being done and so 

8 Tom went back and really kind of went through 

9 the weeds on those residual survey reports and 

10 he outlined, you know, they begin in 1957, which 

11 is essentially the final year that was 

12 considered operational and there was some 

13 surveys that were done in the '70s, 1980, '84, 

14 2000, and then a pretty major one in 2007 by the 

15 Army Corps of Engineers.

16 So I guess one of the I guess 

17 overarching issues, which was pretty easy and 

18 kind of a no-brainer to solve was this notion 

19 of whether we're going to consider an 8-hour 

20 workday or a 10-hour workday for the workers.
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1 And originally during the 

2 operational period, NIOSH assumed a 10-hour 

3 workday which is pretty much in line with what 

4 we had heard through claimant interviews and 

5 information such as that, so ten hours makes 

6 sense in their operational period but 

7 originally it was being assumed that once the 

8 residual period started well now the shifts 

9 were down to eight hours.

10 And we said, well, you know, is 

11 there a good reason to justify that. So NIOSH 

12 took a look at it and said, well, you know, for 

13 consistency it's claimant-favorable and much 

14 better just to assume ten hours in both periods 

15 because there's no reason to think that, you 

16 know, the shifts or work schedule changed, so 

17 that was kind of a no-brainer, just increase the 

18 work year from 2000 hours to 2500 hours.

19 Now we sort of get into okay, so the 

20 external component of the dose reconstruction, 
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1 which is Finding 6, and you have essentially two 

2 components to that, you have the penetrating 

3 dose and then you have the non-penetrating 

4 dose.

5 Penetrating dose was essentially 

6 measured in each of the surveys I just 

7 mentioned, you know. So essentially all 

8 throughout the residual period you have some 

9 gamma walkover data.

10 From 1957 or '58, really when the 

11 residual period starts, up until 2000 what you 

12 essentially end up with is about 80 

13 measurements.

14 Now not all of those measurements we 

15 noticed had been used by NIOSH when they 

16 calculated their distribution of gamma 

17 measurements, which is not necessarily a bad 

18 thing, but we said okay, what kind of effect 

19 would it have if we started including some of 

20 these data points which weren't used but 
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1 they're pretty much in the same ballpark.

2 So that sort of brings us to SC&A 

3 Observations 1 through 3 in the memo to the Work 

4 Group sent out about two weeks ago. 

5 Essentially what we did is we said well, what 

6 effect does it have if we start adding in some 

7 of these other measurements into the total of 

8 80 and what it turns out is the chosen value of 

9 80 micro-R per hour, which was essentially the 

10 highest observed result in that 1957 survey 

11 right at the end of the residual period.

12 Out of the 80 measurements, 80-some 

13 measurements, only four ever exceeded that sort 

14 of value of 80 micro-R. So we said okay, well, 

15 what about those, you know, four measurements? 

16 And it turns out that they're pretty well 

17 characterized hot spots.

18 In other words, yes, you could look 

19 at a survey of that and say, wow, the highest 

20 one we observed was 300 micro-R per hour, it was 
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1 under a step, I believe, but then you go ten feet 

2 away and it dropped to a hundred, or if you go 

3 ten feet in the other direction that'll drop to 

4 60, so it was clearly a hot spot.

5 So, you know, it seems very unlikely 

6 to me that any worker would have been exposed 

7 to those higher levels of gamma radiation for 

8 a full year over the entire course of their 

9 employment.

10 And when you fit a distribution to 

11 those 80 measurements what you find out is even 

12 when you add in some of the data points that 

13 weren't used, that 80 micro-R per hour is 

14 bounding the 95th percentile of the full gamma 

15 measurement distribution.

16 Now, this is only considering up to 

17 about 2000. The 2007 survey had over 2000 

18 gamma measurements at three feet and the 

19 highest one I believe was 63 micro-R per hour.

20 So, again, that chosen value of 80 
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1 is certainly going to bound the very highest 

2 measurement observed in 2007 and if you take all 

3 those thousands of measurements and you look at 

4 them and you say, okay, you know, what did it 

5 look like if you put them to a distribution.

6 Well, now your 95th percentile for 

7 2007 was down around, you know, ten micro-R per 

8 hour, and that's at the 95th percentile, and 

9 that's really pretty close to what background 

10 is around Lockport, New York.

11 So, I mean, basically what I'm 

12 getting at is that penetrating value certainly 

13 looks bounding to me. It's even higher than 

14 the 95th percentile of all these gamma 

15 measurements that we have pretty much 

16 throughout the residual period.

17 And, like I said, it represents the 

18 highest measured value right at the start of the 

19 residual period. So, I mean, for those reasons 

20 I feel like that's a good value to choose.
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1 You use it as a constant and it will 

2 certainly bound the doses, from my point of 

3 view. Now that's the penetrating component.

4 When we get to the non-penetrating 

5 component, we have far less data. I believe we 

6 only have maybe five or six values anyway, we 

7 don't exactly know how many measurements 

8 because it doesn't specify how many actual 

9 measurements they have in that 1957 survey 

10 where they found the highest readings in the 

11 10-inch bar mill area.

12 They give you a range it goes from 

13 one to 1.7 millirem and we don't know how many 

14 measurements went into that range so it's kind 

15 of difficult to tell, but essentially that was 

16 an order of magnitude higher than anything else 

17 they measured in the plant and they pretty much 

18 said in that survey report that, you know, aside 

19 from two areas in the main plant area, 

20 everything was below, I believe it was 0.2 
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1 millirems per hour.

2 So that's, you know, an order of 

3 magnitude less essentially than what we're 

4 looking at here and, of course, we're assigning 

5 that for the full day for 2500 hours per year 

6 for however long they worked there.

7 So the data's kind of limited for 

8 beta at three feet, but from what we have we're 

9 pretty much picking the high end of what values 

10 we do have to work with.

11 Now, another way to look at it from 

12 a scientific defensibility standpoint is to 

13 say, okay, what kind of ratio should we see. In 

14 other words, does this beta dose rate and this 

15 gamma dose rate, when you look at them relative 

16 to one another does it make sense, is what we're 

17 seeing scientifically valid? Which brings me, 

18 I believe it's Table 3-10 in TBD-6000 that 

19 essentially gives you a dose rate ratio.

20 If you have this gamma, this is what 
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1 kind of beta dose rate you should see in 

2 relation to it, and that ratio comes out to a 

3 hundred.

4 Now, SC&A also did, I believe in a 

5 review of that methodology, they said, okay, 

6 well, let's run some Monte Carlo and let's see 

7 what ratios we come up with and we found out 

8 that, well, the ratio between the beta and the 

9 gamma is really less than that, it's probably 

10 closer to like 45 or 50.

11 Now, what we're looking at here with 

12 the ratio of these two values is lower than 

13 that. It's around 17, I believe, maybe 17, 18.

14 Now, one would say okay, well, your 

15 ratio is a little bit low there so what's going 

16 on, I mean is the beta component too high, is 

17 the gamma component too low?

18 But what you have to remember about 

19 those two numbers I quoted before, the ratio of 

20 45 and the ratio of a hundred is that 
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1 essentially assumes an infinitely thin slab. 

2 In other words, there's going to be no 

3 self-shielding or attenuation of the beta 

4 component whatsoever.

5 Now, that's not reality. In 

6 reality you're going to have layers of it and, 

7 you know, the beta component will really only 

8 travel through, you know, a fraction of a 

9 millimeter of material.

10 So in reality your ratio is going to 

11 be much lower and the reason I'm bringing this 

12 up is, from our point of view, the fact that 

13 you're in that right range of dose ratios sort 

14 of validates in my mind the values that have 

15 been chosen.

16 Since we don't really have a whole 

17 lot of data, you know, it becomes a weight of 

18 evidence as to whether we find it 

19 scientifically defensible to use the values 

20 that we do have and I think that's one piece of 
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1 evidence in its favor.

2 Now, listen, our ratio is a little 

3 bit low but we're in the same ballpark as what 

4 the model ratio should be and the model ratio 

5 really is a vast overestimate of the beta 

6 component because it doesn't consider any sort 

7 of shielding.

8 So in our mind, from a Finding 6 

9 standpoint, the data has been very well 

10 characterized as to what we have, what we can 

11 use, and I think the values chosen are good 

12 ones, to put it simply.

13 So I guess I'll stop there for now 

14 and ask if there are any questions on the 

15 external component of -- or Finding 6 

16 essentially.

17 CHAIR ZIEMER: But basically SC&A 

18 is saying that they agree that NIOSH's approach 

19 for the external, both the gamma and the beta, 

20 is bounding, would that be a --
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1 MR. BARTON: That's correct. One 

2 of our major concerns going in was that we 

3 didn't feel the original TBD really discussed 

4 what data was out there in the context of, are 

5 we really choosing, first of all, how well was 

6 the site characterized throughout the residual 

7 period. In the case of the gamma walkovers I'd 

8 say it was pretty good.

9 CHAIR ZIEMER: Yes. What was the 

10 basis for it and was it truly scientifically 

11 defensible and I think you're saying yes it, now 

12 you believe it is.

13 MR. BARTON: Yes. I think that in 

14 the latest White Paper provided by NIOSH, I 

15 believe last fall, really kind of laid out what 

16 do we have out there for survey data, you know, 

17 when were the different surveys taking place 

18 and what are the magnitudes we're looking at 

19 that they found throughout the residual period.

20 And I think that we picked a 
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1 scientifically defensible but also bounding 

2 and claimant-favorable value on a value 

3 essentially for the gamma and the beta 

4 component.

5 So that's where SC&A kind of stands. 

6 Again, is there any questions, we can field them 

7 now or we can move on to Finding 7.

8 CHAIR ZIEMER: Well, let's see if 

9 there's questions now, this is on external now.

10 MR. BARTON: Yes.

11 MEMBER MUNN: Not here.

12 CHAIR ZIEMER: Okay. Let's --

13 MEMBER BEACH: Yes, this is Josie. 

14 Bob, that was very clear and good information, 

15 thank you. No questions.

16 CHAIR ZIEMER: Okay, then let's 

17 proceed with the internal, Bob, thanks.

18 MR. BARTON: Sure, okay.

19 MEMBER POSTON: Paul, just for the 

20 record, I don't have any comments, I read, I 
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1 reread all --

2 CHAIR ZIEMER: Oh, John Poston. 

3 Comment, John?

4 MEMBER POSTON: No. Just for the 

5 record, I don't have comments. I reread all 

6 this stuff this morning and the oral 

7 presentations just made it fine for me. I 

8 don't have any questions.

9 CHAIR ZIEMER: Good, thanks. Go 

10 ahead, Bob.

11 MR. BARTON: Okay, great. All 

12 right, so now we're talking about how do you 

13 characterize the internal component, which is 

14 essentially how do you characterize the dust 

15 loading available for inhalation during the 

16 residual period.

17 Now, originally, so essentially 

18 what you need is you need a starting point and 

19 you need an ending point and then you can 

20 interpolate between them to get essentially a 
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1 gradual decline in the dust loading as the 

2 source term is being removed, but if you have 

3 a starting point and an ending point, you 

4 essentially connect the dots and reconstruct 

5 internal doses during the residual period.

6 So the real crux of it is what is 

7 that starting point going to be and what is that 

8 ending point going to be. Now, originally 

9 NIOSH had used a similar, but not quite the same 

10 approach of using general air samples during 

11 the operational period.

12 Specifically, they were using 

13 samples from 1949 to 1953, which is essentially 

14 right in the middle of the operational period 

15 at Simonds.

16 Now, one thing that's important to 

17 understand about Simonds is there's sort of a 

18 sliding scale as to how well they were keeping 

19 dust levels down.

20 When they first started off in 1948, 
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1 the dust levels were pretty enormous. AEC came 

2 in and suggested some industrial controls and 

3 other practices such as, you know, localized 

4 ventilation, you know, use a vacuum, no more 

5 broom sweeping, that kind of thing, to get dust 

6 levels down to where they were pretty good.

7 And, you know, the 1949, now, and 

8 starting in 1953, for whatever reason, maybe 

9 it's that they were doing less work or whatever, 

10 a lot of those industrial controls started 

11 being removed.

12 So we have the situation where 

13 conditions weren't very good. They got better 

14 for a few years and then they kind of degraded 

15 to where they weren't being used anymore.

16 So we said, well, you know, your 

17 general air samples, while we agree it's very 

18 good to use general air samples during the 

19 operational period to establish dust levels at 

20 the residual period, you're kind of looking at 
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1 the period when controls were at their height, 

2 you know, things were probably the best they

3 were at Simonds during that period and it's 

4 always more preferable to use data as close to 

5 the end of the operational period if possible 

6 to characterize conditions at the start of a 

7 residual.

8 So we said all right, we realize we 

9 don't have any air sampling from 1955 to 1957, 

10 essentially the last three years of operations 

11 at Simonds.

12 We do have some air sampling in 

13 1954. That's the closest we can get so that's 

14 the best we can do. So NIOSH compiled the 

15 general air that we have. I believe they came 

16 up, there were 21 total general air samples 

17 taken during operations.

18 They were pretty well 

19 characterized. About, you know, whether in 

20 the vicinity of certain operations going on and 
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1 such, 21 samples, a couple of them were taken 

2 in the same area during the same operation, so 

3 it makes sense to just average those values so 

4 you end up with 16 total samples and you take 

5 the geometric mean of that and you say all 

6 right, that's going to be our dust loading at 

7 the start of the residual period.

8 Now, they're not saying that that 

9 dust loading is going to settle and then get 

10 re-suspended, we're simply saying that is the 

11 dust loading. I mean it's during operations 

12 for rolling uranium.

13 So to me that is kind of an easy way 

14 to say, well, listen, that's got to bound what 

15 the actual re-suspended material was going to 

16 be during steel operations, you know, a number 

17 of years later.

18 We're actually using operational 

19 data that's going to be available for 

20 inhalation. So the starting point to me is the 
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1 good one. It's going to bound it because we're 

2 looking at operational data, not residual.

3 So now we get to the ending point and 

4 originally NIOSH had used essentially the same 

5 report from the Army Corps of Engineers and they 

6 had calculated something, what was it called? 

7 I believe it was called an exposure point 

8 concentration.

9 And, you know, we looked at that we 

10 said, well, we can't really see what was done 

11 here. I mean, we know what the ending value is, 

12 what this exposure point concentration, we 

13 don't know how they arrived at it really. It 

14 was kind of a little muddy, we couldn't really 

15 tell.

16 So we asked NIOSH, you know, can you 

17 give us a little more information on this and 

18 that's where Tom just described they actually 

19 went and got the raw data from the Army Corps 

20 of Engineers and they looked through and they 
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1 said you know what, maybe we should do our own 

2 little bit of analysis here.

3 And so they looked at it and there's 

4 thousands and thousands of data points and a lot 

5 of them were on like clean surfaces like walls 

6 and such.

7 I think Tom, it's very well 

8 described in the report, did a good job of going 

9 through and saying, listen, these one's these 

10 are not in the areas where uranium rolling took 

11 place, or they're on obviously clean surfaces, 

12 so you know what, let's get rid of those.

13 Now let's look at just the buildings 

14 where work was done and it turned out that 

15 Building 24, the southern portion only, because 

16 that's the only portion that was there during 

17 operations, had the highest 95th percentile 

18 contamination value.

19 So we said, all right, that's a good 

20 start because it's, you know, the highest 95th 
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1 percentile out of the four or so buildings where 

2 operations took place.

3 So that's essentially what you're 

4 going to use to be re-suspended, which seems 

5 like a good place, but we wanted to ask one more 

6 question, is, you know, how do the two end 

7 points compare.

8 Because what OTIB-70 says is if you 

9 don't really have data for the residual period, 

10 what you can do is take data from the 

11 operational period as your starting point and 

12 you'll apply what's called a depletion factor.

13 Essentially every day a small 

14 fraction of the source term available for 

15 inhalation is going to decrease and that value, 

16 see if I have it off the top of my head.

17 Okay, here we go. It's 0.00067 per 

18 day. That's the fraction essentially leaving 

19 the site for all intents and purposes. So we 

20 said okay, that's what=s recommended in 
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1 OTIB-700, how do our two, our starting and end 

2 point actually compare if we're going to 

3 calculate that depletion factor, you know, how 

4 do we compare it?

5 Is it in the same ballpark as what 

6 OTIB-70 says? Is it higher? In other words, 

7 are we losing our source term faster? And as 

8 it turns it out that when you connect our 

9 starting and ending point, the depletion factor 

10 is about one-quarter of what is presented in 

11 OTIB-70.

12 So essentially our source term is 

13 hanging around longer, which is obviously going 

14 to be a claimant-favorable assumption. At the 

15 same time, like I said there's about a factor 

16 of four in there which says that the starting 

17 and end point that we've chosen seems 

18 scientifically defensible because we're very 

19 comparable to what OTIB-70, we are prescribed.

20 So I guess that's where we're at 
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1 with Finding 7 and I guess the moral of the story 

2 for both of them is that SC&A feels NIOSH has 

3 really done their homework here and gotten into 

4 the data and explained their position very well 

5 and while also choosing scientifically 

6 defensible and claimant-favorable choices to 

7 reconstruct doses.

8 So I guess that's where SC&A comes 

9 out. If there are any questions.

10 CHAIR ZIEMER: Thank you. Again, 

11 we appreciate the analysis that SC&A has done 

12 to review this latest recommendation from 

13 NIOSH.

14 So I have no further questions, 

15 let's see about the other Work Group Members?

16 MEMBER MUNN: None here. Sounds 

17 thorough to me.

18 MEMBER BEACH: Yes, I don't have 

19 any, either.

20 MEMBER POSTON: No. No questions, 
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the TBD 6000 Work Group for accuracy at this time. The reader should be cautioned that this transcript is 

for information only and is subject to change.

41

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1 Bob.

2 CHAIR ZIEMER: Okay. I guess both 

3 presentations were very clear. We have a final 

4 recommendation from SC&A which is on Page 8 of 

5 the report that Bob Barton prepared.

6 Let me, just for the record, read 

7 the recommendation of SC&A to the Work Group. 

8 Based on the above discussion SC&A believes 

9 that NIOSH has satisfactorily addressed the 

10 original concerns with reconstruction of both 

11 internal and external doses during the residual 

12 period.

13 SC&A's position is that we 

14 currently propose methods representing a 

15 scientifically defensible, sufficiently 

16 accurate and claimant-favorable approach.

17 Therefore SC&A recommends that the 

18 Work Group accept the proposed approaches 

19 outlined in NIOSH 2013(b) and 2013(c) and place 

20 Finding 6 and 7 in abeyance until the TBD is 
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1 revised to reflect the new methodology.

2 And that's the end of the 

3 recommendation and let me just indicate that if 

4 we agree and accept this recommendation, in 

5 essence what we are saying is that we recommend 

6 that the residual period not be included in the 

7 SEC because dose can be reconstructed.

8 MEMBER MUNN: This is Wanda, I 

9 agree with that recommendation.

10 CHAIR ZIEMER: You recommend to the 

11 Board that this be accepted?

12 MEMBER MUNN: That is my 

13 recommendation, yes.

14 CHAIR ZIEMER: Okay, thank you.

15 MEMBER BEACH: I'll second it, this 

16 is Josie.

17 CHAIR ZIEMER: Okay. Now any 

18 discussion on this recommendation, Board 

19 Members? If not, I'll just call for a quick 

20 vote for the record. Let's see, Wanda?
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1 MEMBER MUNN: Yes.

2 CHAIR ZIEMER: Josie?

3 MEMBER BEACH: Yes.

4 CHAIR ZIEMER: John? I hear 

5 somebody clearing their throat, was that a yes?

6 MEMBER BEACH: No, that was Wanda.

7 CHAIR ZIEMER: Oh.

8 MEMBER MUNN: Sorry about that.

9 CHAIR ZIEMER: John, we're not 

10 hearing you, are you on the line yet?

11 (No response.)

12 CHAIR ZIEMER: Okay. And I'll 

13 vote yes. So the Work group is going to 

14 recommend then to the Board that the SC&A 

15 recommendation be accepted, which in turn means 

16 that we are accepting NIOSH's position that 

17 they can reconstruct dose and therefore that 

18 the residual period not be included in the SEC.

19 Now let me just ask Ted here now, for 

20 the full Board Meeting, do we need a formal 
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1 presentation on this or just the 

2 recommendation?

3 MR. KATZ: Well, Paul, I think, and 

4 there are different ways you can do it, I think 

5 it would be helpful to have a presentation 

6 because the full Board, this has sort of been 

7 off the radar for quite a long time and I think 

8 they'll probably appreciate sort of being 

9 reminded of where we left off and then how we've 

10 gotten through this last bit.

11 So, I mean, you may want to have 

12 NIOSH and SC&A sort of give a formal, you know, 

13 presentation of what the remaining issues, 

14 findings were and how they were resolved and 

15 then, I mean, I think the Work Group's, you 

16 know, report could be very brief and oral, even.

17 CHAIR ZIEMER: Right. So perhaps 

18 let me clear this up and perhaps Tom could 

19 summarize NIOSH's approach for Findings 6 and 

20 7, which is the external and internal for the 
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1 residual period.

2 And then Tom could summarize SC&A's 

3 review and their recommendation, and then I 

4 would simply follow up with the Work Group's 

5 recommendation to the Board.

6 MR. KATZ: Yes. I think that would 

7 be good. You said Tom, but you meant Bob for 

8 SC&A.

9 CHAIR ZIEMER: I meant Bob.

10 MR. KATZ: Yes.

11 CHAIR ZIEMER: I meant, Bob, right.

12 MR. KATZ: Of course. And I think 

13 though, also, just to back up a little bit at 

14 the front end you may want to just introduce 

15 this all by reminding the Board that they had 

16 added a Class, you know, back in I think 2011 

17 I think it was.

18 DR. NETON: Hey, Ted, this is Jim.

19 MR. KATZ: Yes?

20 DR. NETON: I've got a question I 
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1 guess on that. Everything we've been doing up 

2 till now has been addressing the TBD review 

3 issues and not necessarily the SEC issues.

4 Is it really the case that we are 

5 closing out the SEC here or are we just closing 

6 out the Site Profile Review?

7 MR. KATZ: Well these were the, I 

8 believe, but you would know better than me, or 

9 Tom would, that these were the issues that were 

10 standing in the way of closing out the SEC, if 

11 I'm incorrect about that --

12 DR. NETON: Well, our 

13 recommendation in the original ER is we could 

14 do dose reconstructions for the entire period. 

15 We didn't leave it open, so it was not an opening 

16 there.

17 MR. KATZ: The original ER, no, the 

18 original ER recommended a class, yes -- No, the 

19 original ER recommended a class for through 

20 '57.
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1 DR. NETON: But we also said in the 

2 original ER that we could do dose 

3 reconstructions for the rest of the period, I'm 

4 pretty sure.

5 MR. KATZ: Right, but then you have 

6 the SC&A TBD review that raised questions about 

7 the residual period, which is why we've done 

8 this work, right?

9 DR. NETON: It's odd though because 

10 we've been conducting this entire review as if 

11 it was a TBD review not an SEC review.

12 MR. KATZ: I understand that, but 

13 this was standing in the way of finishing up the 

14 Board's review of the SEC, right? The Board 

15 was still --

16 (Simultaneous speaking.)

17 CHAIR ZIEMER: Well, we haven=t met 

18 -- the Board did not approve the residual period 

19 yet, did they, and so the --

20 MR. KATZ: They did not and the 
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1 Board did not come up with a determination for 

2 the residual period, which would've had to have 

3 been a determination that the doses can be 

4 reconstructed.

5 DR. NETON: I guess that's a matter 

6 of -- they didn't specifically withhold it, 

7 that's for sure.

8 MR. KATZ: Right.

9 DR. NETON: We recommended that we 

10 could do it, the Board agreed with our 

11 recommended period. I, you know, I can, it 

12 doesn't really matter I guess either way, but 

13 I was going under the assumption this was all 

14 TBD review and not SEC review material.

15 MR. KATZ: Well, and I think it 

16 kills two birds with one stone, but --

17 DR. NETON: I know, but we would've 

18 approached it very differently if it was -- an 

19 SEC evaluation is a somewhat different 

20 threshold than a Site Profile.
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1 I mean, clearly if you cleared a 

2 Site Profile hurdle, the SEC is a non-issue, but 

3 I just didn't, well --

4 MR. KATZ: Well, this was one of 

5 these, I mean, this is one of these SECs where 

6 the Board never articulated a position on the 

7 residual period.

8 So the Board has this as an 

9 outstanding item to close the SEC. But, Jim, 

10 if you're saying, I mean that --

11 DR. NETON: Yes, I don't know.

12 MR. KATZ: Oh, okay.

13 DR. NETON: I really don't know, 

14 I'm just saying that I don't see where the --

15 the Board certainly didn't specifically 

16 withhold judgment. We were very clear in our 

17 ER that we could do the SEC after '57 and so I 

18 saw nothing outstanding commentary-wise that 

19 would indicate that it was an issue.

20 But, you know, if it's the 
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1 requirement that they all formally be addressed 

2 with determinations, if the Board does not 

3 formally address it in the letter then I guess 

4 --

5 MR. KATZ: Yes. Well, I mean, I 

6 the rule we've been running by is unless the 

7 Board formally articulated that it concurs 

8 about the residual period or the period 

9 remaining on an SEC petition, then it needs to 

10 act to do that.

11 Now, I think there have been some

12 SECs where the Board didn't produce a 

13 determination letter saying feasible after 

14 this period, but the Board's discussion of the 

15 SEC made it very clear that the Board concurred 

16 that the SEC shouldn't extend or be considered 

17 beyond the period.

18 DR. NETON: Right. I don't know 

19 what the transcripts say on this, to be honest 

20 with you.
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1 MR. KATZ: Excuse me, can you say 

2 that again?

3 DR. NETON: I don't know what the 

4 transcripts on this --

5 MR. KATZ: Oh, but I can tell you 

6 because LaVon and I went through these 

7 transcripts and this was definitely one of 

8 those transcripts where the Board basically 

9 just ran through the expedient of getting the 

10 SEC added, but did not address the residual 

11 period.

12 DR. NETON: Okay, then that's fine. 

13 That's fine. I just --

14 MR. KATZ: Yes. So that's why 

15 we've had this on our list to close it out.

16 DR. NETON: Okay.

17 MR. KATZ: And I think, I mean, so 

18 I understand what you're saying, Jim, exactly, 

19 but I think things just weren't, this wasn't 

20 left very clear, this issue.
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1 DR. NETON: Yes. Yes. And, 

2 again, it's just a matter of process. I mean 

3 either way it comes out the same.

4 MR. KATZ: Right. And I think, my 

5 impression is you've, you know, you've done the 

6 same work you would have.

7 DR. NETON: But this in effect then 

8 will require a determination letter and such.

9 MR. KATZ: Exactly. It'll require 

10 a determination letter from the Board.

11 DR. NETON: Okay. That's fine. I 

12 just, I guess I was not working under that 

13 impression, but I've got it clear in my mind 

14 now.

15 MR. KATZ: Okay, no problem.

16 DR. NETON: So back to the Board 

17 meeting, then, I guess NIOSH will provide a 

18 summary of what we've done to address these 

19 issues?

20 MR. KATZ: Yes. I mean, I think if 
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1 you folks do that, lead off with the -- and I 

2 think you've more or less done it for the Work 

3 Group anyway --

4 DR. NETON: Yes.

5 MR. KATZ: -- so all you need is a 

6 presentation as opposed to a verbal one, I mean, 

7 a PowerPoint one, and then we would use these 

8 papers, we would provide these to the Board and 

9 SC&A can do their review.

10 And, Bob, I'll just leave it to SC&A 

11 whether you want to actually have a PowerPoint 

12 presentation or deal with it orally as you did 

13 in this Work Group meeting. I think you could 

14 handle it either way.

15 MR. BARTON: Yes, I think a few 

16 slides would probably be useful.

17 Maybe I can coordinate with Tom as 

18 he puts his presentation together so we're not, 

19 you know, overlapping the same information, 

20 but, you know, if some of the SC&A review 
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1 information sort of supplements his 

2 presentation, I think it would helpful for the 

3 Board.

4 MR. KATZ: Yes. I think that would 

5 be great.

6 CHAIR ZIEMER: Tom, also, in your 

7 presentation it would probably be helpful just 

8 to remind the Board of what they've already done 

9 on the active period and why we're looking at 

10 this residual period.

11 MR. TOMES: All right, that's fine.

12 CHAIR ZIEMER: And a very brief 

13 review again, it always helps to remind people 

14 of what they did at the site, what was going on 

15 there and just -- and very brief.

16 MR. TOMES: Okay.

17 CHAIR ZIEMER: Not a full review of 

18 everything, but just a little reminder. So 

19 I'll kick it off by introducing what we're 

20 doing. Tom will talk about how Issues 6 and 7 
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1 for the residual period were addressed.

2 Bob will give the SC&A evaluation 

3 and their recommendation and then I'll finalize 

4 it with the Work Group's recommendation to the 

5 Board. How does that sound, Ted?

6 MR. KATZ: I think that sounds 

7 good. And, Paul, I think given Jim's sort of 

8 uncertainty about this, I think it would be 

9 probably helpful for the rest of the Board to 

10 just note that this was one of these SECs where 

11 the Board, you know, acted to sort of expedite 

12 the SEC and hadn't really addressed the period 

13 outside of what was covered to be added by 

14 NIOSH.

15 CHAIR ZIEMER: Okay, great. Yes. 

16 And, again, that was, I didn't go back and 

17 review that transcript, but I was working under 

18 the impression that that was the case, and you 

19 had reviewed it, Ted?

20 MR. KATZ: Yes. I looked at it and 
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1 Bomber, both of us, we both looked at it and that 

2 was the case.

3 CHAIR ZIEMER: Okay, very good. 

4 The only other comment I will make to you, Ted, 

5 is that I won't physically be at the meeting and 

6 I'll tell you offline why that is the case, but 

7 I'll be on the line and I think I can take care 

8 of it by phone.

9 MR. KATZ: Okay. Okay, thanks, 

10 Paul.

11 CHAIR ZIEMER: Okay, any other 

12 comments or questions? I think that completes 

13 our agenda for the day unless there's further 

14 concerns or comments or issues that anyone 

15 wants to raise.

16 If not, I thank all of you for your 

17 input on this and for your actions and we will 

18 see you either in person or by phone at the full 

19 Board Meeting.

20 Oh, we have a phone meeting coming 
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1 up anyway later this week.

2 MR. KATZ: We do, on Wednesday.

3 MEMBER MUNN: Yes.

4 CHAIR ZIEMER: But we're not going 

5 to act on this till the face-to-face in Idaho, 

6 right?

7 MR. KATZ: That's correct.

8 CHAIR ZIEMER: So the only thing we 

9 need to do at the upcoming meeting is to report 

10 that this is coming.

11 MR. KATZ: Yes. Yes, I think that 

12 would be great.

13 CHAIR ZIEMER: Okay. If there is 

14 no further action before us, I'll declare the 

15 meeting adjourned. Thank you all.

16 MR. KATZ: Thank you everyone.

17 MEMBER MUNN: That's great. 

18 Everybody have a great week.

19 MR. KATZ: You too.

20 (Whereupon, the above-entitled 
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1 matter went off the record at 11:24 a.m.)

2

3

4

5

6