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NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

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

US Department of Health and Human Services

Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

Work Group on Lawrence Berkeley National 

Laboratory

Friday, April 5, 2019

The Work Group convened telephonically at 9:30 

a.m., Paul L. Ziemer, Chair, presiding.
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2 

Members Present: 

Paul L. Ziemer, Chair

Bradley P. Clawson, Member

David B. Richardson, Member

Also Present: 

Ted Katz, Designated Federal Official

Nancy Adams, NIOSH Contractor

Bob Barton, SC&A

Elizabeth Brackett, ORAU Team

Ron Buchanan, SC&A

Joe Fitzgerald, SC&A

Lara Hughes, DCAS

Tom Labone, ORAU Team

Megan Lobaugh, DCAS

Jenny Naylor, HHS

Jim Neton, DCAS

Mutty Sharfi, ORAU Team

Stephen Spanos, ORAU Team

John Stiver, SC&A

Tim Taulbee, DCAS
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3 

Contents

US Department of Health and Human Services 

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Work Group on 

Lawrence Berkeley National Laboratory Friday, April 

5, 2019 1

Welcome and Roll Call 4

SC&A Site Profile Initial Review and Response

9

DCAS Proposed Method to Assess Internal 

Doses 22

Work Group Recommendations/Plans for 

Follow-up 92

Adjourn 108
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4

Proceedings

(9:29 a.m.)

Welcome and Roll Call

Mr. Katz: Welcome, everyone, to the Advisory Board 

on Radiation and Worker Health. It's the Lawrence 

Berkeley National Laboratory Work Group. It's been 

quite a while since we met. And we have quite a bit 

of work to go through, the Site Profile review -- the 

agenda for the Work Group is posted on the website. 

And I have only posted the most recent back and 

forth documents between the Division of 

Compensation Analysis and Support and SC&A 

related to this review.

We'll be talking about more findings and more 

resolutions than are related to these last two reports, 

but they both go back to 2014, 2013 and even before 

that. 

So if anyone on the line needs any documents after 

this meeting and needs help finding them I'll be glad 

to help. But anyway.

We're speaking about a specific site so for agency 

related staff, contractors, and so on, please speak to 

conflict of interest when you do this.

My Board Members don't have conflicts of interest 

which is why they're on this Work Group.

And I have full attendance, so Dr. Paul Ziemer who's 

the chair, he's in attendance as well as Mr. Brad 

Clawson and Dr. David Richardson, they're in 

attendance, so we have the whole Work Group here.

So let's go on to roll call.
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5

(Roll call.)

Mr. Katz: Okay, then let me just remind everyone, 

since we have more than a dozen people on the line, 

to mute your phone except when you're speaking. It 

will help the audio quality for everyone else, and 

please don't put the call on hold at any point. And, 

Paul, it's your meeting.

Chair Ziemer: Very good. Welcome, everybody. I'll 

officially call the meeting to order.

What I'd like to do as we proceed, and you have your 

agenda before you which identifies a number of 

documents that are pertinent for today.

The last time that this Work Group met was several 

years ago actually in the transcript -- was in February 

of 2012.

And if you look at item 1 on the agenda in the related 

documents, it lists the Site Profile called Rev. 1 as the 

first one that was reviewed. But just as I looked at 

my records historically there was what you might call 

a Rev.0 that was dated August 2006.

I don't know that any of us actually saw that. My 

understanding is that that was revised based on 

internal NIOSH reviews, and so the first document 

that I recall seeing was the 2007, April 2007 which is 

officially called Rev. 1.

And that was the one that was reviewed by SC&A 

which is under related documents, the second one, 

January 2010. No, I'm sorry, that was the SC&A 

review of Rev. 1, but Rev. 1 has an official date of 

2007.

Now in January of 2010 we had the SC&A review of 
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6

Rev. 1, and the Work Group met in January of 2010, 

and we went over that SC&A review in quite some 

detail actually mainly to become acquainted with the 

issues of which there were 13, and Joe Fitzgerald led 

us through all of those issues.

The interesting thing was that in January 2010 -- I 

gather that SC&A also had access to Rev. 2. Rev. 2 

officially is dated May of 2010, but at the January 

2010 meeting there was a matrix prepared, that's 

item 5, it's actually Roman numeral V on the 

document report. And that matrix has in it some 

information about Rev. 2 even though Rev. 2 is dated 

later in the year.

As far as I can tell what apparently happened, and 

either Joe Fitzgerald or Jim Neton can correct me if 

I'm wrong, but it appears that just prior to the 

meeting SC&A had seen something in Rev. 2, they 

were able to identify that some changes had been 

made in terms of some of the issues. But SC&A had 

not had an opportunity to actually review the details 

on that, but they noticed that some of the needed 

information had been added in Rev. 2. So I'm a little 

confused about how that occurred.

But in any event when we met at the January 

meeting in 2010 those changes were identified that 

had not yet been reviewed. Well, they were just 

identified.

And then in the document -- Roman numeral VI is 

the transcript, and it would be probably -- if you 

haven't already reviewed that it would be worth 

doing.

We won't go through the SC&A review of Rev. 1 today 

except as it pertains to the actual, and we'll go 

through those issues as revised because there's 
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7

revision 6 then.

But in any event there has been a fairly detailed 

review of what the original issues were. Some -- as 

it turns out of the 13 issues, 8 of those as of our 

meeting were still pertinent which means that the --

even though NIOSH had made some changes those 

changes still needed evaluation.

There were four more that apparently were virtually 

identical between Rev. 1 and Rev. 2, and so those 

issues carry forward.

Another issue that really for the early years that was 

essentially negated by the SEC, and the SEC petition 

was really -- one that was identified by NIOSH. And 

the actual information on that petition is incorporated 

into Rev. 2.

That SEC petition was actually voted on by the full 

Board. It didn't even need to go through the Work 

Group because it was one identified by NIOSH as they 

prepared documents.

So where we really are on this list of documents, as 

I see it, is Roman numeral VII under discussion item 

-- or under -- item 1. And that starts with particular 

issues that we have NIOSH responses to and SC&A 

further reviews on.

So as I see it that's where we would actually start, 

but let me ask either -- well both NIOSH and SC&A if 

I have understood the sequencing correctly on this.

Dr. Neton: This is Jim. I'll have to defer to Megan 

Lobaugh who's POC now and maybe Lara Hughes 

who was the previous POC to verify what you said is 

true.
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8

Dr. Lobaugh: This is Megan Lobaugh. I would agree 

with what you said. So what I tried to do with this 

listing of documents was list everything that I knew 

about. Because I'm new to the site, so I pulled this 

together to kind of come up with the history and see 

where we are today. And so I would agree with what 

you described.

The one thing where you spoke about number 5, that 

matrix was actually issued in January 2012. So I 

think --

Chair Ziemer: Yes, and actually that -- I think that -

- let me see here. Number 5. Yes, that's January 

2012. And let me look here. What was the date of our 

meeting?

Dr. Lobaugh: February of 2012.

Chair Ziemer: Yes, yes, right. I was saying 2010, but 

it was actually 2012. Yes, that's when we met.

So Rev. 2 was available in 2010. I'm sorry, yes. I had 

jotted down the date of the meeting incorrectly. 

And probably -- so it's clear then that SC&A did have 

Rev. 2 and had done the comparisons at that point.

Dr. Lobaugh: Yes, I think it was preliminary. Oh, 

sorry.

Chair Ziemer: Yes, right.

Dr. Neton: -- had a preliminary version.

Chair Ziemer: Yes. And I did look through the matrix, 

and it was pretty clear that SC&A had not had a 

chance to review the 02 except to identify that 

changes had been made from 01.
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9

And of course as part of that the SEC issue had been 

taken care of by the full Board and that in a sense 

negated the one issue. Well, it sort of partially 

negated it. I think it also makes clear that for partial 

dose reconstructions, for example people who didn't 

have the specified cancers or who hadn't worked 250 

days there would have to be some partial dose 

reconstructions possibly in those early days. So some 

of those issues might still have to be addressed, but 

it wasn't clear whether that issue went away or might 

still have some parts dangling as it were.

Anyway, okay, thank you. SC&A, any comments on 

this?

SC&A Site Profile Initial Review and Response

Mr. Fitzgerald: No, I think from a chronological 

standpoint that makes sense. I mean, these are the 

reviews that the Work Group requested by done by 

either NIOSH or SC&A following the last Work Group 

meeting. So that would -- that would certainly be it.

Court Reporter: This is the court reporter. Can the 

speakers identify themselves? Thank you.

Mr. Fitzgerald: Oh, I'm sorry. This is Joe Fitzgerald.

Chair Ziemer: This is Ziemer again. So basically the 

matrix repeated all the original 13 items and just 

commented on which ones appeared to be 

unchanged in Rev. 2 and carry forward and which 

ones appeared to have been changed and needed to 

be reviewed. Anyway, in those cases except for the 

SEC negation of the one, I think in essence the rest 

of them carry forward.

So if it's agreeable we'll begin with issue 3, and issue 

3, we have the NIOSH response to issue 3, and that 
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10

in essence is the response to that original issue. And 

then there's also -- and that is Roman numeral VII. 

Then I think it would be appropriate to skip down to 

Roman numeral X which is the SC&A review of issue 

3, and we can handle that, both of those, I think fairly 

quickly and then move on from there.

So just to handle this in an orderly way and this one 

is fairly straightforward, but I think NIOSH -- and, Dr. 

Hughes, are you going to handle this, or who will 

handle it for NIOSH? Just briefly go over your 

response, and then we'll hear from SC&A.

Dr. Lobaugh: Okay. This is Megan Lobaugh, and I'll 

be speaking --

Chair Ziemer: Oh, Megan, you're going to handle it. 

Okay, yes. Okay, go ahead.

Dr. Lobaugh: So issue 3 has to do with special forms 

of tritium and plutonium that weren't originally 

addressed in the Site Profile.

So in May of 2012 NIOSH put out a response to that 

issue. If you are following along, Work Group 

Members, in the BRS entries, this would be in the BRS 

entries for the LBNL Site Profile PDF if you have that. 

And issue 3 starts on page 11 of that document with 

the NIOSH response starting at the bottom of page 

11, beginning of page 12.

So as I said in -- well, so the May 2012 response is 

where I'll start actually. So we put out a response 

saying that ICRP 66 actually handles the forms of 

plutonium that were being asked about. 

So here we give information about ICRP 66 and the 

clearance half-times that are a part of the ICRP 30 
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11

respiratory tract model and how these combine to 

actually cover the uranium oxides that were asked 

about.

So our response was that the current ICRP models 

cover the uranium question that was asked as far as 

the assignment of insoluble forms of thorium and 

uranium are covered by the ICRP models. That was 

kind of a quick review, but any questions?

Chair Ziemer: Well, right. It seems fairly 

straightforward because SC&A basically said they 

agree with this, but let's see if SC&A has any 

additional comments on this.

Mr. Fitzgerald: No, I think at the time, Paul, we had 

some issues relative to retention times that we 

wanted to go back and look.

And Joyce Lipsztein went and just really compared 

ICRP 30 with 66, and as you noted I think we came 

around to agreeing that there didn't seem to be an 

issue on the retention times, that 66 would be in fact 

conservative and applicable.

So I think that issue went away. It was a question 

between the two.

Chair Ziemer: Okay.

Dr. Lobaugh: And, Paul, one thing I didn't address is 

the tritium. So initially the issue involved tritium as 

well, but Rev. 2 included the tritium questions that 

were asked about the special forms of tritium that 

were used onsite. So the tritium was already included 

with our last revision. 

Chair Ziemer: Right. So let me ask Brad Clawson or 

David whether or not either of you have any 
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12

questions or additional comments.

Member Clawson: Paul, this is Brad. I don't. 

Member Richardson: This is David. I don't either.

Chair Ziemer: Okay. Then I think the statement that 

says SC&A agrees with NIOSH response, I guess --

do I understand this to be a recommendation that the 

issue be closed? Joe, is that your recommendation?

Mr. Fitzgerald: Yes, we no longer have an issue with 

that one.

Chair Ziemer: Okay. So can I take it by consent to 

the two Board Members that they agree the issue 

should be closed?

Member Clawson: This is Brad. Yes.

Member Richardson: Yes.

Chair Ziemer: David, yes. And I'll say yes, and we 

will consider that one closed.

Let me ask Ted as we proceed here. And this will 

come up again at the end, but are we on the agenda 

for the meeting in Pittsburgh?

Mr. Katz: No, you are not.

Chair Ziemer: Okay. So we don't need to report 

anything yet till we get through some more things --

Mr. Katz: Right. Until we finish the entire Site Profile 

review --

(Simultaneous speaking.)

Chair Ziemer: Okay. Just wanted to have in mind 

whether we needed to report anything at this next 
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13

meeting. 

Okay. Let's go next -- I think we can go sequentially 

on these. Next is issue 9 which has to do with medical 

X-rays. This is also, I think, fairly straightforward, but 

let's do the same -- Megan, do you want to quickly 

review the SC&A -- or the NIOSH response, and then 

we'll get comments from SC&A again.

Dr. Lobaugh: So issue 9 is in regards to X-ray 

exposures and the fact that there was not very much 

information on the X-ray exposures for the 

employees at LBNL.

So the main request is that the TBD should be 

expanded in its discussion of the medical dose. So if 

you're following along in the BRS entries PDF this 

would be starting on page 31 of that document.

Member Lockey: Hey, Ted?

Mr. Katz: Yes, I'm here.

Member Lockey: This is Jim Lockey. I'm sorry, for 

some reason my pass code didn't work. I don't know 

why, but I got it now.

Mr. Katz: Okay, but, Jim, this is Lawrence Berkeley 

National Lab. So you don't have to attend this. You're 

welcome to attend this.

Member Lockey: That's all right. I guess I got --

somehow I'm confused. I'm not sure what's going on 

here.

Member Clawson: That's nothing new. We're used to 

it.

Member Lockey: All right. Thank you, guys. Bye bye.
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Mr. Katz: Okay. Megan, you can go ahead.

Dr. Lobaugh: Okay. So we -- NIOSH provided initial 

responses in February 2012 just before the Work 

Group meeting. And what we provided then was that 

these X-ray exams were typically done in private 

physicians' offices before 1964. So those would not 

be covered.

And then while X-rays appeared to be taken from 

1964 to '75 at LBNL, there was limited information 

for this time period. So OTIB-6 would be used. So 

OTIB-6 is the default document that we use for 

assigning medical X-ray exposures for the program.

So the one other question would have been on the 

use of PFG, a specific type of diagnostic X-ray 

machine and whether that was used onsite. There 

was no evidence that a PFG was used onsite, and the 

fact that X-rays were done offsite prior to 1964, 

which PFG was really only used during the early time 

frame. So we found that it was not indicated that 

there was a PFG machine in use at LBNL, so those 

doses would not apply.

So a basic takeaway here is that we would apply the 

OTIB-6 default exposures when we don't have 

specific information. And with Revision 2 we updated 

a lot of the X-ray exposure information that we did 

have for the site.

Chair Ziemer: Okay, thank you. I noticed also at our 

meeting in 2012 that NIOSH or SC&A had 

recommended closure at that time. And I guess that's 

still true. But any comments, Joe?

Mr. Fitzgerald: No. We did get a chance to look at the 

preliminary draft and did see those changes, and 

that's where that recommendation came.
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15

Of course, the TBD wasn't -- the revision hadn't been 

finalized. But that carries forward. We're still satisfied 

with the addition of the information.

Chair Ziemer: Okay. Questions, Brad or David?

Member Clawson: This is Brad. No.

Chair Ziemer: David, okay?

Member Richardson: Yes.

Chair Ziemer: All right. So I think we can go ahead, 

and there's agreement with the recommendation to 

close, so we'll consider this one closed.

Okay. I wish we could move this fast on everything. 

Now we have the IX -- document of issues 6, 7 and 

8 -- a little longer, but let's go ahead and, Megan, if 

you'll walk us through this and make sure we all 

understand the response.

Dr. Lobaugh: Okay. So for finding 6 again if you're 

following along in the BRS entries document. this 

would be starting on page 21. And findings 6, 7 and 

8 all relate to the external dosimetry program. 

Finding 6 specifically is about the insufficiency of the 

internal dosimetry. 

So there were several areas where SC&A was asking 

for some more information. And I'll just talk about 

the main points of those areas. So the first one would 

be the NTA film energy threshold determination. 

So from the review of the TBD there were a few 

different thresholds that we had listed. So at one 

point it was 500 keV, 800 keV, and then other 

sources list 1,000 keV.

So this is kind of a common discussion I think we've 
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16

had at other sites where what is the minimum 

detection of NTA film. That was one question.

The second part was on the failure to adjust recorded 

doses to correct for the lack of response of NTA and 

CR-39 in the intermediate and thermal neutron 

energy range. So again this is low energy neutron 

detection and how we're going to adjust 

measurement for that lack of response basically of 

the dosimeter.

The third part was the minimum detectable dose for 

CR-39 dosimeters. So again this was a question of 

what dose we were listing as the minimum detectable 

dose for these specific neutron dosimeters.

And the fourth was on the use of the neutron/photon 

ratios where neutron data are lacking. So there was 

a seeming inconsistency between the environmental 

and external dose sections of the TBD. So that was 

the initial -- those were the four main points of the 

initial finding.

NIOSH provided preliminary responses just before 

the last Work Group meeting. And what we provided 

was a revision -- our part of the Revision 2. So in 

section 6.3 of Revision 2 of the Site Profile indicated 

that a neutron to photon ratio can be applied to the 

LBNL film era which would be up through 1994. The 

LBNL Site Profile includes neutron to photon ratios 

based on site-specific information.

Also in Revision 2 we provided correction factors to 

account for angular dependence and fast neutron 

energy for the NTA film and CR-39 dosimeters. Our 

peer review research indicated that a limit of 

detection of 15 millirem was appropriate. So the table 

in -- the table 6-4 in Revision 2 was revised.
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17

And then regarding the neutron to photon ratio for 

environmental doses and personnel dosimetry, 

there's a footnote that pointed out that these 

numbers were impacted by skyshine and shielding.

So NIOSH attests that the difference in the 

environmental geometry and shielding scenarios and 

occupational exposure geometry and shielding 

scenarios are why there is a difference between those 

two ratios.

So SC&A in 2012 -- sorry, did somebody have a 

question?

Chair Ziemer: No, I thought maybe you were done 

there, and I was going to move on to SC&A, but go 

ahead and finish what you were saying.

Dr. Lobaugh: So it may be appropriate to move on to 

SC&A at this point because in 2012 SC&A issued a 

review of issues 6, 7, and 8 together. So if they could 

give a summary of what that review was, and then I 

could provide the NIOSH preliminary response to that 

review. There's nothing posted yet.

Chair Ziemer: So we do have the SC&A response, 

but, Joe, why don't you walk us through that. I think 

we're on item 6.

Mr. Fitzgerald: Yes. Joe Fitzgerald. Ron Buchanan 

was the lead author on those three responses, and 

he's on the phone. Ron, can you take us through?

Dr. Buchanan: Yes. This is Ron Buchanan, SC&A. The 

response -- SC&A issued a response in September of 

2012 to this response from NIOSH. And we reviewed 

the revisions in the TBDs and then the last entry in 

the BRS there you see our response in September 

2012.
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18

And what we found is, just to kind of summarize this, 

is that some of the issues that we initially brought up 

and NIOSH addressed in their revision we agreed 

with. However, like in some cases it did also raise 

some application questions or clarifications that 

needed addressed.

And so in that last entry on the BRS we discuss in 

some detail. We don't see that there's any great 

issues, but to actually -- using these in dose 

reconstructions was our concern. And we weren't 

sure of some of the uncertainties and what they 

included and didn't include. And so we asked for 

some clarification on actually using these in dose 

reconstruction, how they would be applied such as 

the correction factor for angular dependency and 

such, what was included and wasn't.

And so I guess at this point rather than just reading 

these I would say that we agreed with some of their 

revisions. It did bring up a couple areas of questions 

that we are still waiting for NIOSH to address, and 

we will then evaluate to see if it does clarify the 

issues.

Dr. Lobaugh: This is Megan Lobaugh again. So I can 

just provide our preliminary response path forward 

on finding 6.

We will revise the external dosimetry discussion to 

provide direct guidance on the use of the neutron to 

photon ratio when it is more favorable than the film 

dosimetry results.

Along those same lines we have since revision of this 

TBD come out with Report 87 which gives information 

about developing a quantile regression method to 

assign neutron dose. So we'll review the data that we 

have for Lawrence Berkeley to see if we can actually 
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19

use our newer method than the neutron to photon 

ratio for this, for neutron dose assignment.

Along the same lines we're going to determine if the 

correction factors are needed to account -- well, we 

know they're needed to account for the low energy 

response, but the higher energy neutron response --

will still be determined based on the specific site, and 

if they're needed then develop them.

(Simultaneous speaking.)

Chair Ziemer: You had a White Paper on that for 

SC&A to review then?

Dr. Lobaugh: What I would suggest is we will provide 

these preliminary responses and path forward in a 

written response, so a BRS entry or a write-up to the 

Work Group. 

And then as we progress through this research, we 

would provide information back to the Work Group 

and SC&A. 

Chair Ziemer: And so SC&A will need to await that 

before they respond -- on that?

Dr. Lobaugh: You broke up a little bit.

Chair Ziemer: Do you have a timetable on preparing 

that written response for SC&A to review?

Dr. Lobaugh: The preliminary response we'll be able 

to get fairly quickly because it will be a summary of 

what we talk about today. As far as the research 

goes, I anticipate that will take a little bit longer. So 

hopefully sometime this summer just depending on 

priorities and what people are working on.

Chair Ziemer: Gotcha.
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20

Dr. Lobaugh: So the last thing I was going to say 

there was that we'll clarify and explicitly state about 

the uncertainties in that table 6-11 that were 

discussed by Ron.

Chair Ziemer: Very good. Okay. Let me see if Brad or 

David have questions or comments to add.

Member Clawson: Paul, this is Brad. Not at this time.

Chair Ziemer: Okay.

Member Richardson: So this issue is going to be held 

while they're investigating alternative approaches 

including quantile regression. Is that what I 

understood?

Chair Ziemer: That would be correct. We would not 

take any action on this other than to understand the 

path forward and add to that any particular additional 

comments.

Ted, we don't have to task this separately, do we?

Mr. Katz: No, absolutely not.

Chair Ziemer: Yes.

Mr. Katz: It's in progress is what the terminology is.

Dr. Lobaugh: This is Megan again. So when I entered 

these into the BRS system, I left the status as open. 

So one thing after we finish the Work Group meeting 

I can go in and update the statuses based on the 

votes that you have already done today or if we're in 

progress still on them.

Mr. Katz: Open -- is before we address it; in progress 

is really the next step which is where we are. So this 

one would get a status change. Okay, Paul. Paul?
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21

Member Richardson: Paul, we're not hearing you.

Chair Ziemer: I had my mute button on. Sorry, I 

thought I took it off. So I wondered if there were any 

additional questions. This will remain open or in 

progress. I think we're ready to move on to issue 7 

then.

Mr. Katz: Megan. Maybe Megan's on mute.

Dr. Lobaugh: I'm here. So finding 7 starts on page 

25 of that BRS entries for the Site Profile PDF. And 

this finding has to do with the failure to justify the 

shallow dose to deep dose assumption.

So again I think just as a quick summary the initial 

finding was asking about the ratio that we are 

assuming within the TBD to assign shallow dose 

because for the time period from 1948 to 1981 no 

shallow dose was measured. And so the TBD did the 

ratio to calculate the shallow dose from the deep dose 

that's measured on the dosimeters.

So, in 2012 NIOSH gave the initial response which 

was that non-uniform exposures are addressed using 

program guidance which would be TIB-10 and TIB13 if necessary. So that's a case by case adjustment 

that we do.

And that the Revision 2 of the Site Profile provides 

guidance on the assignment of shallow dose for the 

historical -- based on historical dose limits used by 

LBNL.

So, and then the other -- well, so I'll be more specific 

about the guidance. So, DCAS-TIB-10 is the external 

dose reconstruction for glove box workers and DCASTIB-13 is selected geometric exposures scenario 

considerations for external dose reconstruction at 
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22

uranium facilities. So those are the two program 

documents that we would suggest using on a case by 

case basis.

And then in 2012 SC&A provided an evaluation, or 

provided the same document that also covered 

finding 7. So if they could speak a little bit about what 

they found and then I can give our preliminary 

response to that.

DCAS Proposed Method to Assess Internal Doses

Dr. Buchanan: Okay. This is Ron Buchanan with 

SC&A again.

On finding 7 we did go back and our initial concern 

was how they derived some of their assumptions.

We did go back and see how they applied these 

various documents, TIB-10 and TIB-13 and OTIB-17. 

And with their explanation we did concur on some of 

these shallow dose assumptions, but did have several 

items that we still would like to have addressed and 

that is that the use of -- lack of shallow dose 

measurements during '48 to '81.

We find that the beta to gamma ratio for the uranium 

slab of 12 inch thickness, some places are quoted as 

5 to 1 instead of 3 to 1 for the recommended ratio of 

3 to 1 may underestimate the claimant's calculated 

dose in close distances. And that was one issue we 

had.

Another one was that if you do a shallow dose from 

the gamma measurements you lack gamma emission 

on P-32 and strontium-90 as listed in table 2-1 and 

6-5 of that TBD. And there wouldn't be any gamma 

dose to derive shallow dose.
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23

And so those were the two issues with the shallow 

dose.

And then we had an issue, I think it's more of a 

wording issue on extremity dose in that it said to use 

three times the whole body dose. However, 

sometimes extremity dose limit is five times the 

whole body dose as quoted there on page 61. 

And so in certain cases using three times could 

underestimate the extremity dose.

And so those were two of the issues that we came up 

with and felt that some of the issues had been 

addressed, but did have these two issues or three 

issues left to be addressed.

Chair Ziemer: So we need to -- well, before I ask this, 

questions or comments from Dave or Brad.

Member Clawson: This is Brad. Not at this time.

Member Richardson: No.

Chair Ziemer: I think, Ron, you mentioned issue 10 

which is the uncertainty issue. I think there was -- I 

can't remember if it was in this document or if we 

discussed it at the last meeting, but there was an 

indication that everyone felt that issue 10 and 

actually issue 11 would both be covered by 

resolutions to issues 2 and 4. 

And at some point -- I'm trying to recall if it was in 

this document that we're looking at or if it occurred 

in our last meeting, but it was essentially 

recommended that we close 10 and 11 because they 

would be already covered once we resolved issues 2 

and 4. I'm trying to remember. Megan? Do you recall 

that?
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24

Dr. Lobaugh: So, for finding 10 from what I gathered 

there was discussion at the February 3, 2012 Work 

Group about the uncertainty. And the fact that it 

sounded like this issue was closed due to the SEC 

period because this was specific to internal dose. 

Finding 10 are specific to the uncertainty of internal 

dose prior to 1961 and the SEC for internal dose goes 

up through 1961.

So, from what I could gather the Work Group -- there 

was discussion on closing finding 10 at that time.

Chair Ziemer: It looked like we may have closed it or 

said that there was a way -- although in the SC&A 

review it mentions that for sections that might have 

to be done, the uncertainty issues would still be 

there.

But in any event if we get 2 and 4 resolved this 

becomes a moot issue because that would handle it.

The same is true of issue 11.

Dr. Lobaugh: So, issues 2 and 4 have to do with 

internal dose as well, but issue 7 that we're 

discussing now is external dose.

Chair Ziemer: Right. But since something was 

mentioned in Ron's discussion about issue 10 it just 

popped into my mind. But yes.

Dr. Lobaugh: And issue 11 from the last Work Group 

meeting it looked like there was discussion of making 

that addressed in the other findings. So how I 

entered that was as a draft in finding 2 and 4. So it 

marks it as closed as in not being counted towards 

our statistics, but that we are addressing it in our 

response to finding 2 and 4.
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25

Chair Ziemer: Right. And that -- my question was to 

take specific action on that. We sort of agreed to it 

already, but maybe we can come back to that when 

we're getting off issue 7. Let's go ahead and finish up 

issue 7.

Dr. Lobaugh: So for issue 7 would you like me to talk 

about our path forward?

Chair Ziemer: Yes, exactly.

Dr. Lobaugh: Okay. So for issue 7 we're planning to 

review the NOCTS claim external dose data to see if 

it supports the shallow to deep dose ratios and any 

extremity dose ratios that we use in the current Site 

Profile.

We're also going to compile a list of the pure beta 

emitters in use at LBNL to determine whether we 

need to make adjustments to our ratios for that or 

have specific facilities where those may be 

applicable.

And we're going to research if there is area 

monitoring data available for these pure beta emitter 

sources and determine if an unmonitored approach is 

needed in response to those pure beta emitter 

questions.

Chair Ziemer: Is this going to require any more onsite 

data gathering or do you have everything you need 

to proceed on this?

Dr. Lobaugh: At this point we have not discussed 

doing additional data captures. I believe there's a lot 

of information captured over the last few years in 

response to the SEC and for other issues.

So I think we'll start with just research of SRDB and 
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26

we will definitely inform the Work Group if we do 

additional data captures.

Chair Ziemer: That sounds good. Ron, are you guys 

okay with that or did you have any other issues you 

think need to be added to that recommendation?

Dr. Buchanan: No.

Chair Ziemer: For the path forward. Will that satisfy 

you? Once you get that information you'll review it. 

But any other issues they should look at in that 

regard?

Dr. Buchanan: This is Ron Buchanan of SC&A.

No, I feel that that's a good path forward and we'll 

look forward to reviewing those results.

I did have one comment that Megan, if you could 

address the five times and the three times issue on 

page 61 also.

Dr. Lobaugh: Okay.

Dr. Buchanan: So that sounds good.

Chair Ziemer: And again I'll ask the Work Group 

Members any other comments or recommendations? 

Are you okay with this path forward?

Member Clawson: This is Brad. I'm good with it.

Chair Ziemer: Okay. David, you still there?

Mr. Katz: Paul, I think David was needing to step out 

to deal with some graduate studies matters. But he'll 

hopefully come back.

Chair Ziemer: Yes. Well, Brad and I are both in 
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27

agreement with it. I think it makes sense. So, we'll 

await the results of that work and have an 

opportunity to visit it again.

Let's see. So the other part of this one.

Member Clawson: Paul, we lost you again.

Mr. Katz: I think Megan's probably scrolling through.

Dr. Lobaugh: So, are we ready to move on to finding 

8?

Mr. Katz: Yes.

Dr. Lobaugh: Okay. So finding 8 starts on page 28 of 

the BRS PDF document. And this has to do with the 

uncertainty in the beta gamma dosimeter response 

to radiation types and energies.

So in the initial Site Profile we discussed that LBNL 

had used electroscopes early on in the program 

there. And we discussed the use of the electroscopes 

and how they may be used in dose reconstruction.

And so there was a comment on the use of that early 

electroscope data for dose reconstruction purposes.

There was also another comment on the dosimeter 

response to very high energy photons and charged 

particles. Because LBNL was a pioneer in the high 

energy physics area there's thought that this would 

be an exposure potential at LBNL.

So, NIOSH provided an initial response in 2012 just 

before the Work Group. And we provided information 

about the revision that we made to the Site Profile 

and the discussion around the electroscope data.

And then there was the meeting in February of 2012 
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28

where SC&A was going to take a look at the response 

in that revision to the TBD and provide additional 

information on where we stood at that time. So if 

SC&A could talk about the response for number 8.

Dr. Buchanan: Okay. This is Ron Buchanan with 

SC&A again.

And again we reviewed the revisions. And it did cover 

some of the issues.

However, external dose is not covered in the SEC 

after 1947. And so there would still be dose 

reconstruction, applied dose qualified for the SEC. So 

we need information on the external dosimetry.

Now, the electroscope issue was evaluated and found 

that they did use film and TLDs after the '47 SEC 

ended for the external dose. And so we feel that that 

issue has been resolved and that part of the finding 

can be closed as no longer an issue.

Now, the thing that remains is the dosimetry 

calibration to the workplace energy, photon energies. 

And this is just very similar to the neutron issue that 

the photon -- generally we have our film, our TLDs 

calibrated using the radial isotope source and that's 

usually acceptable around facilities that are using 

isotope source.

However, as you know Berkeley had a lot of 

accelerators and higher energy possible photons. And 

later on most of these photons were degenerated and 

you could use calibration but in the early to mid years 

there was leakage and that sort of thing around some 

of the experimental accelerators that could create 

higher energy photons than the 1 to 2 MeV.

And so our main issue was was this compensated for. 
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29

If so, how. If not, how can the dosimetry data be 

adjusted just like we adjust the neutron dose for 

potentially missed or lower response to higher energy 

photons which at some point the dosimetry would fall 

off as the photon energy increased above a certain 

point.

And so our question was had NIOSH considered this. 

Was there some reference to back this up in some of 

the references in the attachments or the references 

in the TBD.

So we'd like to see a little more information on how 

this was addressed or if it was addressed and what 

difference it would make in assigning dose, and what 

the high energy photon fields were around the 

accelerators as a function in years and was this 

compensated for in any way either in their original 

dosimetry records or in the dose reconstruction 

records.

Chair Ziemer: Thank you, Ron. Let me ask you a 

question or possibly Megan can answer this.

Do you know if any of the cyclotrons at this facility 

were pulsed units? The reason I ask that is many 

detectors and even dosimeters behave very 

differently in a pulsed field than they do in a steady 

field. Particles of photons. Do you know that or not?

Dr. Buchanan: Yes --

Dr. Lobaugh: This is -- go ahead, Ron.

Dr. Buchanan: This is Ron Buchanan with SC&A. 

Yes, they had pulsed field. And this was an issue 

there and several of the other national labs. And 

myself, I did work on the issue of pulsed field and 
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30

neutron detection because any electronic detector 

will be sensitive to the pulses.

Now, generally the solid state such as the film and 

the TLDs are generally not dose rate dependent at 

the exposure to personnel fields that we would see. 

And so yes, there was pulsed accelerators. And in this 

case we're looking at film or TLDs which would not be 

sensitive to the pulses, whether it was steady state 

or pulses. So that's where we stand on that unless 

Megan can put further light on that.

Chair Ziemer: Well, I'm even questioning whether 

that is actually always true. I think there's data that 

show that some solid state units still behave 

differently in terms of -- could almost look like a 

saturation situation if you look at maybe both pulse 

rates and energy. Are there any papers that support 

that that you're aware of?

Dr. Lobaugh: This is Megan. I'm not aware of 

anything, but we can provide a response on that if 

you're looking for more information.

Chair Ziemer: Well, I'm just wondering if there's any 

publications that would verify one way or the other 

for -- I mean, it's very common for electronic stuff. 

I've seen situations that I think CR-39 even 

sometimes shows this that the pulsing has a different 

response.

But maybe at the dose rates that we're talking about 

which are down at the personnel level, maybe it 

doesn't make a difference. I think that's what you're 

saying, Ron, right? We're not making measurements 

inside the cyclotron. We're making environmental 

type of measurements. 

I was just wondering if there was anything to re-
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31

confirm that we don't have to look at that issue. The 

energy issues are one thing. Pulse rate may -- if it's 

not an issue, if there's some publication that can 

verify that I would just add it in just so it clears up.

Mr. Katz: I think somebody has put us on hold 

maybe. Zaida, are you on the line?

Ms. Adams: Ted, I'll send Zaida an email.

Mr. Katz: Yes, thanks. They can cut that line.

Chair Ziemer: I got cut off for a minute. Are we 

hearing background music or something?

Mr. Katz: We were. There it is.

Chair Ziemer: I'm still hearing it.

Mr. Katz: Yes, it's still there. Zaida is going to cut that 

line but it will take a moment or two.

Chair Ziemer: Yes, okay. We'll just wait a second.

Mr. Katz: I think someone must have put us on hold. 

Chair Ziemer: It's gone. Okay.

Mr. Katz: No, still there.

Chair Ziemer: Well, I don't want to go off on different 

radicals on this issue. I just thought if you could 

maybe -- maybe Ron, maybe you could both just take 

a look and see if there's any literature on that. There 

probably is. I think Ron is probably right that at the 

dose levels we're talking about or dose rate that 

we're talking about it's probably not going to be an 

issue.

Any other questions? So, this will be an issue 8 will 
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32

be like issue 7 I think. You have a path forward, 

right? What is the path forward?

Dr. Lobaugh: So, for issue 8 we're planning to update 

the external TBD with more specific direction not to 

use electroscope data past 1948. So that was one. 

We're in agreement about electroscope data. We 

want to specifically state that in the TBD not to get 

past 1948 because we have film and other dosimetry 

data.

And then for the second part we provided a lot of 

information in attachment A of the current Site Profile 

with regards to the dosimetry calibration and the 

workplace photon energies. So we will include a 

summary of that information within the Site Profile 

discussion itself to support response to that part of 

the finding. 

Chair Ziemer: Okay. Ron, do you have any other 

issues you think need to be included?

Dr. Buchanan: No, I think that covers the issues. I 

guess we'll wait until the revised TBD comes out and 

we'll evaluate that further.

Chair Ziemer: Okay.

Dr. Lobaugh: This is Megan again. I do have a 

question. Would this go into abeyance in the Site 

Profile, or is there something you would like to see 

before revision of the Site Profile?

Chair Ziemer: Ron, from what you're hearing today 

are you satisfied that all we have to do is have it in 

writing?

Dr. Buchanan: Well, I would have to see the --
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Chair Ziemer: You still would want to evaluate it, 

right?

Dr. Buchanan: Yes, right. I'd have to evaluate the 

revisions in the TBD that explain the photon response 

and where they got it and how they applied it before 

I could agree -- whether I agree with it or not.

Chair Ziemer: Right. So, that would then be in 

progress I guess, right?

Mr. Katz: Right. That's right.

Dr. Lobaugh: So you would like to see -- sorry, this 

is Megan. You would like to see our revision before 

the Site Profile revision is put out there. So you'd like 

to see our response before we actually revise the 

TBD.

Dr. Buchanan: Well, that would be helpful. And that 

way you wouldn't have to revise it again if I had 

problems with it. Yes, if you would send me the 

response and how you're going to change the TBD I 

could review it and that way you could -- we could 

agree or disagree on it before you issued it.

Chair Ziemer: Let me ask the process question then. 

On all of the findings do we need to get them all 

closed before you guys -- before NIOSH does Rev. 3? 

Or are you wanting to go ahead and work on it --

well, you're going to be working on it in a sense 

anyway. What is the preferred methodology in terms 

of getting to Rev. 3? Is it to get all these findings 

closed first?

Dr. Lobaugh: I think typically we know -- as long as 

we have a path forward and agreement we will revise 

the TBD and then have another review by SC&A.
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34

But I think it also depends on the Work Group and 

what the Work Group prefers. 

I would suggest us working on revision of the TBD 

concurrently and as we revise things providing them, 

but not necessarily holding up revision of the TBD 

because we have had a lot of data captures and 

information come in for this site that if we hold up 

revision of the TBD then that information isn't getting 

in there for other issues.

Chair Ziemer: Yes, yes.

Dr. Lobaugh: Moving forward with revision, providing 

information as we come up with things that SC&A 

should see or the Work Group should see.

Chair Ziemer: Yes. And so for example, if we get 

everything except one or two things resolved you 

would still want to have the revision out there for the 

dose reconstructors to use, the latest things even if 

every issue is not fully closed at that time.

Dr. Lobaugh: Yes. That's what I think.

Chair Ziemer: Gotcha. Okay. Well, that would make 

sense in a sense. Eventually there might have to be 

a Revision 4 also. Ron, you understand what she's 

saying then? Particularly as we get a number of these 

things resolved not to wait and wait and wait until the 

last -- very last thing is done if there's something 

holding up a particular issue.

Dr. Buchanan: I agree. At this point will we expect 

some response on the BRS paper or a revised TBD? 

What will we see first?

Dr. Lobaugh: I will -- sorry, go ahead.
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35

Mr. Katz: Sorry. Just to be clear about this kind of 

thing it's fine to revise the TBD at whatever point it 

makes sense. We're making sure you're taking care 

of other people's claims as much as you can with 

current information, Megan. So that's all good.

But I mean, you might as well just -- when you're 

mentioning changes that you're inserting into a 

revised TBD just getting those out in either White 

Paper or memo form at the same time that you're 

working them out for the Work Group and SC&A 

makes sense and they can get on it as quickly as 

possible. And then with some luck they can actually 

get their review done before you actually issue the 

revision.

If they don't, that's fine. But that gives you a chance 

of working those in before the TBD actually comes 

out.

Dr. Taulbee: This is Tim Taulbee. If I could weigh in 

here. For issues 6 and 7 we're going to be providing 

written responses. We could do the same thing with 

this issue number 8 here as well so that you guys 

would have something to look at as we're doing those 

revisions for the TBD.

By the way, if there is an issue or something that you 

do have concerns about before that TBD comes out 

we can address it then.

Mr. Katz: Thanks, that's helpful.

Chair Ziemer: Okay. Again I'll ask both Brad and 

David if they have any other concerns on the path 

forward on this one. Or if you do have speak now or 

forever hold your peace I guess.

Member Clawson: If that's what it is then no, I don't 
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36

have anything at this time. This is Brad.

Mr. Katz: That's forever, Brad. That's forever. I think 

David had to go out.

Chair Ziemer: Okay.

Dr. Buchanan: This is Ron Buchanan. Could I ask one 

question of Megan? Megan, when you do do any of 

these things please let me know because -- well, if 

you do a paper or a TBD I'll know it. But if you put it 

on the BRS I don't check BRS for every site every 

day. So please keep SC&A informed of when you do 

provide a response so we can get evaluate it in a 

timely manner. Appreciate it, thank you.

Dr. Lobaugh: Yes, I will do that.

Chair Ziemer: Good, okay. I think we're ready for 

issue -- well, we already did issue 3 in connection 

with the NIOSH response originally. I think we're 

ready for issue 2. So Megan, you want to kick this 

one off again?

Dr. Lobaugh: Yes. So as you mentioned before, Paul, 

issues 2, 4, 11 and 12 are somewhat connected. So 

issues 2, 4, 11 and 12 all have to do with internal 

dose reconstruction. And there are some aspects that 

overlap in these findings.

Issue 11 that we spoke about a little bit before we 

believe was addressed in -- fully addressed in 

findings 2 and 4 given the discussion at the last Work 

Group meeting. So I think that's what we had kind of 

said a little bit earlier today.

But issue 2 is specific to insufficient information for 

internal dose reconstruction especially during the 

early years.
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So this in the BRS document starts on page 3 of that 

BRS entry PDF. This initially was discussing a lot of 

the time period before 1961 which as we discussed 

before the SEC, the Class from before 1961 was 

actually added to the SEC for internal dose 

infeasibility.

So through the discussions since the last Work Group 

meeting or with the last Work Group meeting in mind 

there were some issues that were still open post 

1961.

So there have been several -- it sounds like someone 

may not be muted. If they could mute their phone 

that would be helpful.

So, since the last Work Group there has been several 

documents going back and forth from SC&A and 

NIOSH. Let's just scroll through these.

So we provided our initial response on February of 

2012 just before the last Work Group meeting. And 

these were dealing with table 5-4 which is the MDA 

information in the current Site Profile.

And we have reviewed this MDA information and 

come up with some additional specifics that we can 

add to that table for sure.

And this finding also has to do with use of gross 

counting methods for bioassay samples. So the most 

recent White Paper that we put out kind of falls up 

underneath this issue as well.

So, that's kind of the background on finding 2.

One thing I would like to ask is if SC&A could discuss 

the most recent memo that was put out in 2014, 

February 2014. So this is from what I could gather 
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the most recent information that we have or 

questions that we have from SC&A on this finding. 

Mr. Fitzgerald: Yes, this is Joe Fitzgerald. 

We did prepare two responses. One was right after 

the Work Group meeting which was September 2012. 

That's indicated.

That was in response to the Work Group's request 

that we look at this issue of exposure potential from 

internal emitters in the post '61 period and to get 

back to the Work Group in terms of any significance 

that we would identify, whether the bioassay was 

complete and adequate for that period.

This all stemmed from -- our original comments on 

the Site Profile of course dealt with pre-'61 which has 

since been covered by the SEC as you noted earlier, 

Paul.

So our concern was since the cutoff period for that 

SEC was founded on the standing up of -- essentially 

the standing up establishment of the LBNL routine 

bioassay program and some evidence that they were 

collecting and recording bioassays for LBNL workers.

Our comment was to whether or not that had been 

validated to any degree by actually evaluating the 

bioassay data, looking at the source terms. Of 

course, given this is a very major accelerator lab the 

list is very long as you can imagine, almost the 

periodic table.

And to really ascertain whether in fact the program 

was being implemented in a way where the MDAs 

were in fact adequate for measurement purposes, the 

periodicity of bioassay collection was sufficient and 

would in fact identify and measure the nuclides of 
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concern.

And sort of as a short form whether the program was 

effective to -- in terms of the analysis and monitoring

of workers for the variety of machines and source 

terms that you could find at the facility. 

And this was at the same time, when we were 

reviewing, I think it was 2009-2010. This was roughly 

the same time that we were examining similar issues 

at the other University of California laboratories like 

Los Alamos and Livermore.

And these issues figured very prominently at those 

laboratories in terms of the ability to bioassay, 

particularly in vivo bioassay for some of the shorter 

lived mixed activation products and some of the other 

nuclides.

So, the origin of this question came from one can 

ascribe a major step function in terms of the 

operations, the radiological monitoring operations at 

Berkeley to the establishment of the bioassay 

program at the end of '61.

But there was certainly a need from our standpoint 

for NIOSH to look at the implementation of that 

program to actually be able to validate that the 

program did in fact bioassay workers one would 

expect to have bioassay, the rad workers that were 

doing hands on maintenance, experimentation, 

health physicists, that kind of thing. 

So that was what we had left the Work Group back in 

2012. And we did prepare a report September 5, 

2012 that walked through those issues in a 

preliminary way and looked at the question of 

adequacy and completeness.
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Our conclusion was there was still in our mind some 

questions regarding the mixed activation products, 

some of the alpha emitters, shorter lived alpha 

emitters in terms of how Berkeley would have 

monitored for those.

We still had some questions about the effectiveness 

of the bioassay program from the standpoint of what 

reviews we could identify in that time period after '61 

where there were several instances where they found 

up to 25 percent non-compliance in bioassays. So 

some question about completeness that we felt 

needed to be addressed as well.

So we outlined these issues in that report. And that 

again went back to the Work Group back in that time 

frame.

Jumping ahead to the February 2014 memo that 

Megan mentioned, that came after a NIOSH response 

to our paper. And I think that NIOSH response was 

December 2013. So it was about a year after that 

White Paper I referred to earlier.

And this was kind of a short memo, but what it 

essentially did. We went back because we still felt the 

NIOSH reviews were over-reliant on what Berkeley 

was reporting as their programmatic expectations, 

their policies and guidelines.

But there was little validation and actual identification 

of what the bioassay performance was at Berkeley in 

that time frame, and whether in fact the program 

itself was being implemented as prescribed by its 

procedures and policies.

I mean, this is kind of a basic question. I know we 

raise this almost at every site.
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41

So our memo in February 2014 was saying we were 

still concerned about that. Up to that point the 

responses that we were reading were ascribing the 

effectiveness of the bioassay program pretty much to 

the procedures and SOPs that Berkeley had, but we 

didn't see any evaluation of the actual performance 

or implementation on the ground.

So, we went back and Ron Buchanan worked with me 

on this particular one and actually looked at LBNL 

claimants with job titles that we felt at that time 

would be ones that you would be looking for perhaps 

some internal dosimetry history and these would 

include things like occupations as accelerator 

operators, chemists, nuclear physicists, HPs, 

technicians, maintenance staff who would have 

worked in the sixties, seventies and eighties.

And we just wanted to establish what if any bioassays 

were being recorded. These would be gross alpha, 

beta and gamma for these individuals.

And the files that we searched were for PoCs less 

than -- that would in fact have a probability of 

causation less than 50 percent. And this resulted in 

195 claims that will fall in that category.

And from that 195 we found 25 claimants that 

worked during the period of the sixties to the 

eighties. So that was the base.

And of that 25 only 4 claimants had any bioassay 

records at all. And none of these included any nuclide 

specific information. You know, if the gross gamma, 

beta and alpha were being used to screen and then 

would be followed up by more specific, nuclide 

specific analyses, spectrometry or something, that 

wasn't apparent.
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42

So, based on that sampling we came back with a 

concern that NIOSH needed to do more than look at 

the written procedures, monitoring requirements and 

capabilities for nuclide identification and essentially 

look at the data and to establish whether or not the 

data was sufficient and whether it was adequate and 

complete.

That's similar to what we said earlier in 2012, but in 

this case we actually did some sampling to establish 

whether or not we could find that kind of information.

So the February 2014 memo was just sort of 

underscoring what we had said earlier, but in this 

case with perhaps more data to back it up. That's 

kind of where we left it back at that point. 

So that's kind of where I would call the step off point 

between the issue 2 being sort of a question of 

bioassay data adequacy and completeness to kind of 

where we are now with what we've exchanged in the 

last couple of years regarding some new methods 

that NIOSH has come forward with in terms of air 

sampling.

And I'll turn it back to Megan, but that would be kind 

of where we were going back to the 2012-2014 time 

period.

Chair Ziemer: Let me insert here, ask this question. 

So, February 2014 basically describing where you 

ended, the questions that still remained at that point.

Megan, you've had at NIOSH those questions now 

since then, the past five years. Are you developing a 

response to that or have you already?

Dr. Lobaugh: So, one of the things that we've 

developed in response to not just this memo but the 
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43

finding in general for 2, 4, 11 and 12 is the White 

Paper method that we released in 2017. So that 

method to assess internal dose using gross alpha, 

beta and gamma bioassay and air sampling at LBNL. 

So the White Paper was in response to this finding.

We will provide written responses to this memo 

specifically so that we can evaluate whether this 

White Paper either negates some of these questions 

because the White Paper is a more general approach 

as far as looking at all radionuclides that potentially 

an EE could be exposed to onsite. So it may negate 

some of these questions about what people 

specifically worked with and how we're assigning 

dose for those specific people because we're looking, 

taking a general bounding approach for almost 

everyone onsite.

So, we will provide written responses to that memo 

discussing specifics that maybe we've provided in the 

past that could answer some of these questions and 

how the White Paper methodology affects or does not 

affect these questions.

Chair Ziemer: So you're talking about the October 

2017 document?

Dr. Lobaugh: Yes.

Chair Ziemer: That was more for conflicts right? I 

mean for all sites.

Dr. Lobaugh: The October 2017 paper is specific to 

Lawrence Berkeley, but it's a general approach for all 

workers basically who have had any kind of bioassay 

monitoring there. Because most of the bioassay 

monitoring is gross counting techniques. And then 

there's air sampling added in there that we will 
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44

discuss for an unmonitored worker dose assignment.

Chair Ziemer: Gotcha. Okay. So Joe, the October 

document which is listed under the second main 

discussion item, does that satisfy the questions you 

asked in the February 2014 memo?

Mr. Fitzgerald: Not directly, but I think what we 

interpreted the October 2017 White Paper to be was 

offering a broader, as Megan pointed out, a broader 

and somewhat newer approach to the question of 

how one would assign internal dose after '61 

assuming that you do not have necessarily bioassays 

for all the workers that you'd be concerned about.

The issue is if you're going to do a coworker model, 

you want to base that on air sampling in addition to 

whatever bioassays you do have.

And we have looked at that as will that in fact do the 

job. Will that work. In terms of the hierarchy 

obviously you would prefer bioassay data for the 

workers that were in fact exposed to the internal

emitters.

But if that data isn't necessarily complete or 

adequate could you in fact use air sampling 

information. But that's going a little lower on the 

hierarchy so a lot of our questions, and we did 

respond to that paper, revolve around whether it's 

representative enough and given the fact that it's not 

-- well, we can get into that.

To answer your question no, it's not directly 

responsive to the question of validating whether or 

not the bioassay data is necessarily sufficient and 

complete, but it does get to an issue of if it is not 

could one use air sampling information in the way 

that this paper proposes. And that's how we've 
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45

chosen to look at it.

We kind of have an open door on that. And we can 

get into that if you want, Paul, but I think just before 

we leave this issue the question that we has posed 

on issue 2, or finding 2 for the Work Group back in 

2012 was the adequacy and completeness of the 

bioassay data post '61 and whether or not the end of 

the SEC, the cutoff period was the foreseeable time 

to cut it off, that the bioassay program was 

sufficiently mature, working, being implemented and 

was adequate to the source terms at Berkeley.

And we felt there were some real questions about 

that, whether adequacy and completeness was there 

and whether or not that '61 post -- end of '61 cutoff 

was necessarily appropriate.

And we still feel that way. Now, one can switch gears 

and look at air sampling as an alternative and look at 

the merits of applying that, but I think we still have 

the question of the adequacy and completeness of 

the bioassay as of the end of '61 and whether if in 

fact the premise for pre '61 was inadequacy, whether 

or not into '62 and beyond that now becomes 

adequate.

We think there was a time when the program was 

being ramped up. And it's not clear that after '61 it 

was necessarily adequate to the task of monitoring 

for the variety and diversity of nuclides at Berkeley. 

That's kind of where we came out on that.

Now, given that we have since then examined this 

question of using air sampling results. But as you can 

imagine that itself carries its own issues.

Chair Ziemer: Right. That will also -- those weren't 

breathing zone samples either. They were area 
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46

samples.

Mr. Fitzgerald: Well, we can get into that. But just as 

a broad perspective that's kind of how we have 

arrived where we are now. And that's kind of 

simplistic, but that's why we're talking air sampling 

now as opposed to bioassay because again I think 

NIOSH had considered a number of these comments 

and felt that it wanted to examine air sampling 

information as a basis for dose reconstruction. And 

we have tried to work on those issues.

But again, I don't think we really put the question of 

adequacy and completeness on bioassay 

completeness at that. And I think what Megan is 

saying, there may be a response, will be a response 

to that August memo and the original paper in the 

context of whether or not those issues can be 

addressed fully now or not.

So anyway, that's the backdrop.

Chair Ziemer: And the ramp up is kind of a step 

function. I don't recall, is there any indication that 

the ramp up was starting before 1962? The SEC goes 

through December of '61, does it not?

Mr. Fitzgerald: December of '61. Yes, I think --

Chair Ziemer: And how do you see the ramp up, the 

next day wasn't it a full --

Mr. Fitzgerald: Oh no, no -- and I think NIOSH did a 

good job of painting the history of how there were 

few bioassays before that and that it was very clear 

from documentation that they were putting the 

program in place and they were developing and 

getting it to run through '60 and '61. And that you 

could see evidence of the bioassays being collected 
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47

and the program operating by the beginning of '62.

Our question gets to beyond the programmatic 

documentation and what bioassays may or may not 

have been collected after that can you in any way 

validate the actual implementation after --

Chair Ziemer: Right.

Mr. Fitzgerald: And that's kind of what the Work 

Group charged us with looking at and that's why we 

provided the two documents that are listed, I think 

Megan listed in the BRS. We generated a September 

2012 response as well as that August -- I'm sorry, 

February memo. Both getting to having to look at the 

data and having the data tell you what you can about 

implementation rather than focusing on the 

programmatic stuff, you know, the procedures, the 

guidelines, the guidance.

Chair Ziemer: Right.

Mr. Fitzgerald: -- concern that much of what we're 

reading is what Berkeley had proceduralized as far as 

the bioassay program, but not so much as far as what 

the results seem to be.

Chair Ziemer: Thank you. That's helpful. So, I'm 

trying to look at path forward here on issue 2. Megan, 

do you want to talk to that point?

Dr. Lobaugh: Yes. So, as I mentioned we'll provide a 

written response to that February 2014 memo and

we'll provide within that response specific references 

to where we provided past information on specifically 

the mixed activation products and our responses to 

that 2012 paper as well as how the more recent 

White Paper methodology that we put out in 2017 

would affect these questions or our ability to do dose 
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48

reconstruction with these questions in mind.

Chair Ziemer: Okay, very good.

Mr. Fitzgerald: Excuse me, Paul? While we're on the 

subject of the September 2017 paper since that's 

kind of where we are at right now do you want to 

spend time now -- I think it's actually in the second 

part of the agenda that we get into that. I guess we 

could get --

Chair Ziemer: I think -- this relates to finding 2 

anyway. Is there some -- I see the October one. Did 

you say there was another one in 2017?

Mr. Fitzgerald: I think Megan would want to walk 

through her 2017 White Paper on air sampling. But 

we have since provided a response to that. That came 

--

Chair Ziemer: Is that the May '18?

Mr. Fitzgerald: Right. 2018. And then I know looking 

at the BRS Megan provided some -- I would say some 

reaction to responses within the BRS to that paper. 

So that's where we are right now.

Chair Ziemer: Yes. That was like October of 2018 I 

think. Yes.

Mr. Fitzgerald: Right.

Chair Ziemer: Yes, let's go ahead. That all ties in with 

issue 2.

Dr. Lobaugh: Okay. We'd like to go to the second part 

of the agenda on the White Paper. So this would be 

under -- for the BRS finding it's in a separate PDF. 

It's in the PDF that says Method to Assess Internal 

Dose Using Gross Alpha -- ABG Bioassay and Air 
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Sampling. So that's the BRS entries that we're talking 

about within that PDF. 

So, in October 2017 NIOSH put out this dose 

reconstruction methodology on how we were going 

to analyze gross alpha, beta and gamma bioassay 

samples and air samples for Lawrence Berkeley.

To give you a better summary of that I'm going to 

ask if Stephen Spanos can speak more specifically 

about the document itself since I wasn't actually 

involved in the development of the document. He is 

our ORAU team HP who did develop that document. 

Stephen, would you be willing to speak just generally 

about the White Paper?

Mr. Spanos: Sure. Stephen Spanos, ORAU team. 

The White Paper was -- determine the internal dose 

using gross beta, gross alpha and gross gamma 

bioassay using air sampling and bioassay for 

individuals that were monitored at Berkeley.

How much more specific do you want me to go into 

this other than I'd kind of like to keep it as general 

as I could and maybe get more specific questions 

than bog the Board down in the nitty-gritty detail of 

everything that I did. I assume that's what the Board 

wants to hear.

Chair Ziemer: Well, let's try it that way.

Mr. Spanos: Okay. So, what we did in general was 

we took all -- we compiled a list of all the 

radionuclides that we found at Berkeley, broke them 

up into all the alphas, the betas, the gammas. We 

used 95th percentile air sample concentration. 

Based on the air sampling data we compiled in phase 
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2 you know, data compilation effort that we put 

together. The bioassay program was, we had the 

gross beta, gross alpha, gross gamma bioassay 

program defined as based on the information 

provided in responses and some of the other White 

Papers.

We broke up a list into the longer lived stuff that was

likely to be picked up by the bioassay program based 

on the typical monitoring frequency and the rest were 

lumped into those -- likely picked up by air sampling.

And if an individual was bioassayed we would 

determine their internal dose based on bioassay and 

use the air sampling results to bound their intake 

based on bioassay if the results showed that the air 

sampling results were more limiting. 

That's kind of it in a nutshell.

Dr. Taulbee: Paul, this is Tim. Is that a good enough 

description of the report, or were you looking for 

more?

Chair Ziemer: No, in fact I ask this question. So if an 

individual had bioassay information and you also had 

air sampling information from that location you 

compared the internal dose information calculated 

from each and can see how related they were?

Mr. Spanos: No, we determined intake rates based 

on bioassay.

Chair Ziemer: Right.

Mr. Spanos: The 95th percentile air concentration 

that was an annual average air concentration over all 

samples.
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Chair Ziemer: Okay.

Mr. Spanos: For the site.

Chair Ziemer: Gotcha.

Mr. Spanos: Because the logic would be is if you 

didn't know where a person would work, you know, 

the general -- if the overall average air sample 

results. And we just used those to limit the bioassay. 

And in cases where they've limited the bioassay. In 

case where the bioassay was more limiting we used 

the bioassay. And that was shown in some of the 

examples in the White Paper that we did for this proof 

of concept.

Chair Ziemer: Okay, gotcha. Let me see if -- who 

wants to respond? Joe?

Mr. Fitzgerald: Yes. Actually, Bob Barton's still on the 

phone, he and Ron actually tackled the response to 

this White Paper and I think they can give you a 

summary of our review. Bob?

Mr. Barton: Yes, Joe, I'm here. Well, if you want 

maybe a good way to approach this is we had two 

findings and three observations from that review of 

the 2017 White Paper.

Maybe the best thing to do is sort of go through those 

one by one just like we did the previous issues. Ron, 

if you're on the line I know you were quarterbacking 

the first two findings and that first observation. So I 

don't know if you want to get started there or we can 

work backwards?

Dr. Buchanan: I'm on.

Mr. Barton: Okay, great.
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52

Dr. Buchanan: This is Ron Buchanan of SC&A. 

And the finding, we had -- like Bob said we had two 

findings and three observations. I guess I was the 

one that had the two findings and then Joe and Bob 

had the observations. So I'll cover the two findings.

So the way I understood this was our investigation 

showed that the bioassays perhaps were lacking at 

certain periods which we initially thought there was 

bioassay data after 1961. We found that these were 

sketchy at some times. And so what I understand 

NIOSH proposed using the data air sampling to 

determine what the intake may be and create a 

coworker model from that if there was bioassay data 

of course it would be used.

And so now, there's two issues here and this is finding 

1 and 2. Number one, when you use air sampling 

data, does it represent what the worker actually took 

in. And finding number 2 was the gross counting.

Anytime you do gross counting and then you report 

it as a particular isotope and later on go back and 

extrapolate that to other isotopes it would be limiting 

for dose reconstruction. You get technical issues.

So finding number 1 has to do like so many of the 

sites, this is not a new subject, is air samples may 

not represent concentration for the workers.

And I guess the issues begin by the fact that in the 

White Paper it is stated on page 7 a number of 

references to the fact that air sampling may not 

represent the breathing zone sample or what the 

worker actually took in. 

But then later on we use this data. And so our finding 

number 1 was concern with the fact that -- well, one 
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53

part was that breathing zone and work area and area 

sampling seem to be used interchangeably 

throughout the text. However, that's more of a 

nomenclature thing.

But it does have ramifications in that what were we 

using to derive the air concentrations. And so that 

was of concern to us because if you have an air 

sampler -- and of course it's very tedious to get air 

samples which represent what a worker has -- is 

taking in.

And this is a problem even like where you have 

reduction, like glove boxes, work stations, that sort 

of thing you have problems getting representative air 

samples. And so they used lapel air samplers later on 

and sometimes these were better than area monitors 

obviously. Not necessarily exact, but better than area 

monitors.

And so you really have three types of air monitors. 

One that's sitting over in the corner of the room. One 

that is found at either the intake or exhaust of a work 

area be it enclosed glove box or in a ventilation 

system or something. And then you have -- and that 

can vary depending on the work situation. Then you 

have the ones that are worn on the lapel. And it's to 

represent what the worker is actually taking in.

And so this is always a problem even at production 

facilities, but then at Berkeley it's even probably 

more of a problem because there you had a research 

facility, experimental facility. You had accelerators 

where it's very hard to determine what the air 

concentration is other than just general air.

You might set limits on saying well, we don't have a 

ruptured target or something like that by saying -- or 

spread of contamination by looking at your 
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54

continuous air monitors.

But to say what a worker actually got from an area 

monitor is really difficult especially around such 

things as accelerators, things that are changing all 

the time.

And then of course you combine that with the mixed 

activation products, many of which are short lived 

which you might not detect if you take the filter and 

let it sit awhile and then count it. 

And same way with whole body counting. If you have 

whole body counting it has to be done pretty soon 

after the exposure if it's a short lived isotope.

So these are all issues we have with the breathing 

because we felt that in the paper, the White Paper 

that was issued in 2017 the reverting to using some 

air sampling data to fill in for lack of bioassay 

presented a number of representing patient issues. 

And so that was our finding 1.

There was a response. We issued our response in 

about May of 2018 to their 2017 White Paper and 

brought up some of these issues. And then Megan 

provided a response on the BRS in October 2018 and 

explained some of these things.

However, at this point -- at that point it was said that 

they would change some of the things in the TBD. 

However, we feel that maybe just changing the 

wording is not what we're looking at here. We're 

looking at how representative these air samples 

actually are of the intake.

And so that was issue -- or finding number 1. And so 

I guess before I go to finding number 2 I would let 

NIOSH have any response they have to this issue.
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55

Mr. Spanos: Megan, do you want to --

Dr. Lobaugh: Yes, I'll respond to this, Stephen. Thank 

you. 

So, as Ron said we responded in October of 2018 with 

a response saying that we do understand that the 

interchanging of words needed clarity. 

But in addition to that we also provided justification 

for why the air sampling that we used can be thought 

of as breathing zone sampling.

So according to the implementation guide that we 

used for this program breathing zone samples are air 

samples that are representative of the air that a 

worker breathes. There is no requirement that they 

need to be lapel samples or in any specific location. 

They just need to be representative of the breathing 

zone.

The air samples that we used in this -- is there a 

question? Okay. The air samples results that we used 

in this methodology are marked as breathing zone 

within the LBNL reports that we used.

And LBNL had a policy of air sample placements. So 

LBNL had guidance on the placement of air samplers 

as early as 1951 and in that guidance they said to 

keep the air sampler as close to the scene of 

radioactive operation such as on the face of hoods or 

at the glove box.

So what this ends up resulting in is with an air 

sampler placed closer to the work than the worker is 

which the idea there is that the air sampler would 

capture less diluted air from the work.

We went on to explain how the air sampling 
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56

placement guidance that LBNL used in the 1950s and 

early on in the program, how that is in line with 

current day guidance and standards for air sampling 

placement.

And we also discussed how LBNL used these results. 

So, the limiting MPCs that LBNL used were 0.253 per 

meter cubed alpha and 100 picocuries per meter 

cubed beta gamma. 

And we discussed how this was used in our paper 

here.

So, I think the takeaways here are we have 

committed to updating the White Paper with 

additional justification for why the air samples that 

we're using in this methodology are considered BZ to 

clarify our terms that we're using.

And we just want to ask whether there is additional 

questions or response to what we wrote up.

Chair Ziemer: Well, Ron, you may respond to that. 

Let me again clarify what were labeled as breathing 

zone samples. Clearly they're better than the general 

area samples. And some were even --

Mr. Katz: Can everyone hear me?

(Simultaneous speaking.)

Chair Ziemer: Something broke in there. Are we 

clear?

Mr. Katz: Yes. Are we clear of that line? And is Wade 

Morris an ORAU staff person?

Dr. Taulbee: Yes, he is.

Mr. Katz: Okay. Can you maybe get in touch with him 
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57

so that he knows about phone matters.

Dr. Taulbee: I believe somebody else was trying to 

call him.

Mr. Katz: I see. But there's still something wrong with 

that coming through here.

Chair Ziemer: It kind of broke in all of a sudden. Yes. 

So, then Ron, is SC&A's concern focused on whether 

the breathing zone air samplers or the so-called 

breathing zone air samplers are sufficient? Clarify the 

current concern now on this for clarification.

Dr. Buchanan: This is Ron Buchanan. Yes, so far 

we've seen that mainly the reliance on policy, 

procedures and guidelines. They said they'd do this, 

they'd say they'd do that.

There was only one actual documentation that it was 

done was a 1951 photograph. 

And so as we've found in the past with many other 

things they could have the procedures and policies 

written down, but were they actually being done out 

in the field.

And so we feel at this point there is a question on 

while it was written down in their procedure books 

and such we don't feel that there's been really 

indication that the breathing zone was actually what 

was being monitored.

And this has been a problem at other labs too with 

breathing zone, using air monitoring. Does it equate 

to breathing zone such as Argonne National Lab West 

and Livermore Lab and Los Alamos and a number of 

others.
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58

And so we don't feel at this point that really we can 

okay so to speak the use of air sampling. The air data 

itself might be okay. You didn't really have a problem 

with that. But what about representing what the 

person's actually breathing. And this was especially 

true around experimental facilities.

Some of this is based on production type facility and 

we're looking here at a lot of research type facilities. 

And I know from working accelerators you don't walk 

around with a lapel sampler usually strapped on to 

you.

And so our concern at this time is can again air 

sampling actually be used to assign intake for dose 

reconstruction in a situation for the period we're 

talking about at Berkeley.

Chair Ziemer: Well, the previous -- NIOSH also 

indicated the comparisons for bioassays and the air 

sampling. But that also became a bounding issue, 

didn't it? Can you do bounding with the air sampling?

Dr. Lobaugh: What more specifically do you mean, 

Paul?

Chair Ziemer: Well, was Morris the one who 

presented the discussion there originally on the 

October NIOSH memo? Was that Morris? Who was 

your guy there?

Dr. Lobaugh: Stephen.

Chair Ziemer: Oh, okay. Well, in any event I was 

trying to understand how they were using the air 

samplers. It seemed like they were putting bounding 

values that at least would be claimant favorable. Is 

that correct?
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59

Dr. Lobaugh: Yes. So if there's bioassay data, the 

bioassay intake is calculated and then the air 

sampling data that we have for across the facility, the 

95th percentile across the facility is then compared 

to that bioassay data and the more favorable is 

assigned.

Chair Ziemer: Whichever gives the highest or 

claimant favorable number.

Dr. Lobaugh: Yes. The air sampling results that we're 

using are across the entire facility and it's the 95th 

percentile of all those results we have.

One thing I want to point out -- well, there's two 

things I'd like to point out right now.

This data that we're looking at for Berkeley, if you 

have the White Paper in front of you it would be page 

89 on that White Paper. 

We provide table B-1 and B-2 with all of the results 

for the entire site for this entire time period. So we're 

looking at monthly -- basically what this table gives 

you is the uncensored number of results that we have 

in months, the total months that are monitored, and 

then the number of air sampling locations that are 

out there.

So like if you look in 1964 on this table there's 135 

air sampling locations times 12 gives us this 1,620 

total months.

So we looked at this on a monthly basis so that's how 

we got that 1,620 total months that were monitored.

And of those 1,620 total months only 26 of our 

sample results are uncensored meaning that they're 

greater than 1 percent of the maximum permissible 
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60

concentration onsite.

So we're looking at a very small number of samples 

that are positive and of those samples we're taking 

the 95th percentile. Because the censored results are 

then being censored at the 1 percent. So basically 

being imputed, sorry, at the 1 percent level.

Chair Ziemer: Right.

Dr. Lobaugh: We're even adding additional 

conservatism in there by taking out the zeroes and 

labeling them at the highest number they could have 

been. Highest result they could have been.

So we're not talking about very many positive air 

samples on this site at all. That's the first thing I 

wanted to point out.

And then the second thing I wanted to point out is in 

general for the entire program we're developing 

Report 97 which is a report that's going to discuss 

breathing zone air sampling versus general area air 

sampling. 

And this was originally being developed specific to 

INL and ANL-West, but it is going to be developed for 

a program-wide approach.

Chair Ziemer: And that would go through I guess the 

Procedures Subcommittee wouldn't it for review.

Dr. Lobaugh: Yes. If it's overarching.

Chair Ziemer: Yes. Ron, what does SC&A need to see 

to be -- well, to work toward closing the site 

eventually? What do you need?

Dr. Buchanan: Well, one thing, and this is Ron 

Buchanan with SC&A.
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61

I have a question or a clarification. The reason the air 

samplers data was used was not so much to limit or 

to compare it to the bioassay. I understand it was in 

place of bioassays because there was a lack of 

bioassays during certain periods. Isn't that correct?

Dr. Lobaugh: There is an unmonitored worker 

approach with the air sampling data as well, but there 

is a comparison against bioassay and the finding is 

claimant favorable.

Dr. Buchanan: But if they have bioassay we really 

don't need unless it doesn't show as much as the air 

sampling. But I guess our concern is -- the reason 

we're developing this is there was unmonitored 

workers enough that warranted the coworker model 

of some kind and this was taken from the air 

sampling data.

So I'd just like to clarify if the air sampling data is 

going to be used to assign intakes to a number of 

people that did not have bioassay data. So we are 

concerned it's not just a secondary tool, it's going to 

be primary for a number of dose reconstructions. So 

we're concerned about the representativeness of the 

worker intake.

And so I guess what we'd like to see is something 

besides procedures. I know at some of the other sites 

they have actually showed where the samplers were 

placed in relationship to the ventilation system and 

such.

So far we're not comfortable with the fact that the 

samplers were other than on paper that they should 

be placed in certain places. And so I guess our 

question is have they -- is there any documentation 

that shows that these samplers were placed, I mean 

specific instances, pictures, diagrams, air flow, 
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62

especially around areas that the worker could get 

intakes other than working at a hood.

Now, if you're working at a hood you've got an air 

sampler right there between the Plexiglas and the 

worker. Then that's good. That was that one figure 

showing. What about all the rest of them? Where 

were the samplers placed? How did they represent 

what air was taken in?

I guess that's the unknown at this point.

Mr. Fitzgerald: Hello, this is Joe Fitzgerald again. 

I just want to add to what Ron is saying. What struck 

us is in looking at contrasting how this very question, 

the question of relying on air sampling to develop a 

coworker model was handled at other sites. It doesn't 

seem to us that the degree of scrutiny is being given 

on the Berkeley situation as it has at other sites.

If one is going to go to air sampling versus bioassays 

it ought to be a relatively high bar that one shows 

that the sampling process is representative. Because 

again you're relying on the conservatism of that 

value.

I did hear 95th percentile, but 95th percentile what.

The nature of the operations at Lawrence Berkeley, 

you're talking about fairly large experimental bays 

with accelerators like the bevatron. You can sort of 

look at the scale of those facilities and think about 

technicians, maintenance staff, experimenters 

working on pieces of this huge machine and taking 

targets in and out, looking for contamination, 

checking valves and pumps.

There's just certainly operationally going to be 
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63

instances where you're going to have the potential 

for puff releases, that kind of thing.

So the concern is even though NIOSH and this is how 

it's keyed in their document has a presumption that 

you would have representative BZ sampling by virtue 

of the guidelines and guidance that Berkeley has put 

out. Certainly the concern would be whether in 

reality, given the nature of the operations, how 

workers worked around the accelerator doing the 

work they would do in different parts of the 

accelerator, whether the sampling regime, the 

location of the samplers, the air flow, whether 

anyone had analyzed air flow for that facility, whether 

there were regular evaluations, air sampling 

evaluations of air flow and representativeness. 

That would be important to have confidence that this 

presumption that NIOSH has on the 

representativeness of these samples is in fact the 

case at all of the facilities at Berkeley.

Undoubtedly if you were to lump them all together 

and do a 95th percentile you'd be striving to have a 

degree of conservatism. But if the situation was one 

where it would be difficult to sample whatever that 

technician or experimenter was being exposed to 

doing whatever manipulation they were doing on the 

accelerator by virtue of an air sampler located on the

wall 50 yards away, whatever, then I think that's the 

issue that we need to resolve.

And there was mention of portable air monitors being 

used. That would be helpful, but there's absolutely no 

background or history on how they were 

implemented, applied, and whether in fact they were 

used for these kinds of situations where you were 

doing individual maintenance or monitoring or 
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64

decontamination or target removal from the 

accelerator.

So this is the kind of thing we're after. It really needs 

to be evaluated because you are moving from 

bioassay to relying on something that may or may 

not be a representative air sampling system. 

And there's got to be a way to know one level lower 

whether in fact you're obtaining adequate and 

accurate data, air sampling data so that the coworker 

model in fact would be valid.

So that's kind of the root of our concern goes back to 

I think our original concern that we expressed in the 

preceding documents that something as fundamental 

as a coworker model has got to be founded on 

something more grounded than a presumption based 

on the procedures and the guidelines that the 

laboratory may have issued to one where you're 

actually looking at some hard data. So that's kind of 

in a nutshell what I would say.

Chair Ziemer: Well, that helps clarify what SC&A is 

interested in looking at. Do we have specific 

information on locations of the air sampling devices 

that were in the facility?

Dr. Lobaugh: We have I think rooms and information 

like that. What we used to compile this data would be 

the monthly reports. So it's the information that 

would be available to us in the monthly reports.

Member Clawson: Hey Paul, this is Brad. If I could 

mention something. If we remember what happened 

at Pantex with kind of a similar situation like this 

where when we actually made the tours down there 

and could find out where the air sampler heads were 

at, they were 2 to 3 feet from the exhaust plenum. 
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65

The only thing you would have picked up is a 

catastrophic event.

And that's why this also is so important that we know 

where these heads were at at the time that they were 

done, not down the road but where they were at at 

the time that they were being taken.

Mr. Fitzgerald: This is Joe Fitzgerald again. I'd just 

add to what Brad said. This very question, this is not 

a novel question. This question has come up as Ron 

pointed out earlier at least at Argonne-West and at 

Livermore in those SEC discussions. And both sites 

had plenty of air sampling data available for rooms 

and facilities at those sites.

And the question came up with the lack of bioassays 

could one develop a coworker model, or make use of 

the air sampling data. And the question of BZ versus 

general air sampling has come up at the -- it wasn't 

pursued because the concern was there wasn't 

sufficient evidence that in fact you would have 

representative air sampling information, that it 

wasn't sufficiently BZ in nature, breathing zone in 

nature.

So at the very least I would like to see a crosswalk of 

how that issue has been addressed and the extent to 

which the basis for the air sampling program itself, 

the actual sampling times, the air flow rate, things 

that would bear on whether or not the samplers 

would see the source terms that we're talking about 

and in fact represent BZ for a technician or a 

maintenance person working on the accelerator, for 

example, specifically. That would be useful.

Chair Ziemer: Megan, do we have information where 

you have actual bioassay data and have compared it 

with what you would calculate using the air samplers? 
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66

Do we have any indication of whether bioassay 

samples tend to be higher most of the time or lower 

most of the time? If you do the comparisons.

Dr. Lobaugh: There are examples within -- sorry. 

There is examples within the White Paper, but are 

you meaning have we looked in general at all 

bioassay samples comparing it to this?

Chair Ziemer: Yes. You know what I'm saying? So, 

do the air samples tend to usually exceed what you 

would find in an actual bioassay calculation where 

you have both bioassay and air sampling data? Or 

does it tend to be the other way? I know you can 

have both, but overall. Does one tend to be more 

claimant favorable? Just trying to get a feel.

Dr. Lobaugh: I'm going to ask if Stephen could talk 

about that, the more general, if we looked at general 

--

Chair Ziemer: All the cases where you have both, 

both numbers. The bioassay and the air sample for 

an individual. 

(Simultaneous speaking.)

Dr. Lobaugh: So, any individual that we have a 

bioassay sample for we would use the same air 

sampling result for.

Chair Ziemer: Yes, right.

Dr. Lobaugh: But Stephen, could you speak about the 

more general review, if we've looked at the bioassay 

results in general compared to the air sampling 

results.

Mr. Spanos: Stephen Spanos here. In terms of 
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67

looking at specific bioassay results, no. 

However, the White Paper methodology example that 

we provided was for an individual who received 

missed dose, where he received bioassay and it was 

just below the MDA.

And then if you look at the example calculations that 

we ran through there, most cases the air sampling is 

more limiting. And one of the reasons why the air 

sampling is more limited for Berkeley is Berkeley 

established very low air sampling limits for the 

workplace because they could not stand technical 

contamination. It was documented in one of those 

earlier references maybe around circa 1951.

Technical contamination could ruin weeks of work so 

their air sample limits were several orders of 

magnitude lower.

And as a result, by virtue of the air sampling program 

being so restrictive and the results show that in the 

White Paper if you look at 97 percent of the data was 

censored.

Now, it doesn't mean that they didn't see anything 

below that. They did. It's just the bulk of the data we 

used were these monthly summary reports that were 

an efficiency measure and they showed that they 

only reported results above 1 percent of the MPC. 

(Simultaneous speaking.)

Mr. Spanos: When you drive your air sample results 

down by the fact that you have lower limits that 

you're going to have, most cases you're likely going 

to have the air sampling be limiting for the cases of 

missed dose.
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(Simultaneous speaking.)

Mr. Spanos: -- the example.

Member Clawson: This is Brad speaking, Tim. So, 

you're using air sampling data but they were worried 

about their processes, their technical part of this 

versus this was not set up for the individuals. This is 

not something new. We've run into this at numerous 

sites.

And I just, I don't -- I don't feel good about it. You 

can say whatever you want. You're still taking a 

process and you're saying well, because they did this 

and they did that in these papers, this is good data. 

Here today I don't feel that good about it.

Till you can prove to me where it's at, what it was 

there for, air flows, everything else like that I don't 

think we can really use it.

Dr. Taulbee: Paul and Brad, this is Tim. So if we went 

through and documented better where these air 

samples were taken to give the demonstrations of 

those that were on the hoods that would be between 

the worker and the source material, that type of 

information, would that help you in understanding 

why we believe that these are BZ or breathing zone 

or better than breathing zone as far as protective. 

Would that help?

Member Clawson: I'd like you to be able to prove to 

me that they are better because, Tim, we have been 

through this before and come to find out that when 

we actually put hands on and looked at that it was 

not what it appeared in the papers. 

(Simultaneous speaking.)
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69

Dr. Taulbee: What I was getting at there, Brad, is 

that I mean where we've got an air sampler on a hood 

and the person is working with material in the hood 

and the air flow then was coming from the person 

into the hood, anything that would be potentially 

coming out from that standpoint the sampler is closer 

to the source than the worker is. That's what I'm 

meaning by better than BZ.

Member Clawson: Well, and I understand that, Tim, 

but you're using air samplers throughout the whole 

area. You're using it in areas, large areas to be able 

to basically -- let's just be honest what the sampler 

is for was to catch incidences or any releases.

And the majority of this was, quite truthfully it was 

to catch if we had an event there.

Now, some of them you know -- I'm not saying that 

this is not good data, but what I am saying is that I 

need better clarification of why this is good. And we 

have seen this at numerous sites. This is nothing 

new.

Dr. Taulbee: I understand and that is part of why we 

are developing a special report to help address the 

Argonne-West issue that Joe had brought up as well 

which is not closed yet by no means.

And that's why we're developing a complex-wide type 

of approach of the BZ versus general area air 

sampling in small rooms or confined areas or in this 

type of scenario. And so that's one --

Member Clawson: You just brought up something, a 

small room.

Dr. Taulbee: Yes.
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70

Member Clawson: Okay. That makes, you know --

let's just be honest. We're going to have to see what 

you guys come up with, but right now I'm not 

satisfied with what I'm seeing. 

Dr. Taulbee: And I'm trying to figure out what more 

information we can provide that will help that. That 

was the purpose of my question. 

So if we were to go through and provide more 

information about the location, about the source term 

and these results, air flow, if there are studies, smoke 

studies, that type of thing, a report or a White Paper 

or beefing up this White Paper about that, that would 

help you?

Member Clawson: Yes, that would. This was how we 

had to put it to bed at -- I'm thinking of all the 

different sites that I've been involved with. Even 

Kansas City. Pantex was a big one.

Mr. Fitzgerald: This is Joe again. One thing that would 

be helpful just to be responsive to Tim's question. 

You know, all facilities will run room ventilation air 

flows. If you have an air sampling system that's just 

something that you would periodically do just to 

ascertain whether or not the samplers were effective 

and whether or not you're getting representative 

sampling of the work area.

Tim, certainly one thing that would help is just being 

able to see what Berkeley may have done in that time 

frame. I'm not talking about the two thousands, but 

back in that time frame in the sixties or whenever, 

and that's a rough time frame, what did they do to 

look at placement from the standpoint of air flow and 

representative sampling.
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The placement of the samplers themselves doesn't 

tell you necessarily what you need to know. It's 

whether or not they in fact would capture the -- what 

the workers would be breathing in.

And again I'm concerned because the nature of 

activities. They're episodic and dynamic which is the 

term that was used in the Livermore SEC where it 

was decided not to use general air sampling results 

for that reason.

And I don't see the big difference in terms of the --

whether or not Berkeley wasn't similarly dynamic and 

episodic in terms of what exposures they may have 

had from the accelerators.

To have the analysis at Livermore come out that 

there was insufficient information to link the air 

monitoring results to work areas because of the 

episodic and dynamic work that was associated with 

the laboratory's analysis, that sort of gives me pause.

Okay, that's kind of the same question that we're 

trying to grapple with.

So I would also look at -- you are doing that in your 

general reassessment of GA versus BZ, but just the 

consistency of how that is tested and whether the socalled test is actually consistent across sites would be 

useful in this regard because I think that's part of our 

hiccup is that it doesn't seem like the degree of 

validation on that question is the same. Should it be 

the basis for a coworker model? Certainly the 

validation should be similar and it doesn't appear to 

be.

So that would be where I'd be coming from, that if 

one is going to use air sampling as your fallback for 

the coworker model certainly one would be cautious 
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72

about looking at those issues and try to find some 

validation beyond the guidelines, Berkeley guidelines 

that demonstrate that you have a situation where 

you can rely on those air samples for 

representativeness.

Chair Ziemer: Thanks, Joe. Let me suggest 

something here at this point. We've had a fair amount 

of discussion. Obviously more work needs to be done 

to get both sides lined up here a little better.

I'm wondering if we couldn't ask NIOSH to give some 

additional thought based on the conversations here 

today to address some of these things that have been 

raised. You might need to sort of plan a more specific 

strategy based on what you've heard and see what 

you can do to flesh this out a little more.

And maybe -- might have to have additional give and 

take like we did earlier between NIOSH and SC&A to 

come to some point where there's a better comfort 

level on the use of the air sampling data. 

Looks like it becomes sort of a coworker type model, 

but we need to have some consonance in the 

approach that's being used.

I don't know that we can specify a path forward 

exactly right now, but I think NIOSH, you heard a lot 

of comments here and maybe give some thought on 

how to approach it.

Dr. Taulbee: Right. Thank you, Paul. What I believe 

our approach is, and Megan, correct me if I'm wrong 

here, but we're going to be revising the White Paper. 

And so I think we're going to include some of these 

points that SC&A has raised and provide some --

hopefully be able to provide some more information 
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73

about the placement of the air samplers. And not just 

from the guidance as Joe just pointed out, but actual 

examples of the major areas and try to incorporate 

that into a revision to the White Paper and then 

provide that back to the Work Group.

Chair Ziemer: Okay, thank you. Let's proceed on that 

basis then. 

Now, I need to find out if anybody needs a comfort 

break at this point. I think all we have to really 

address yet is 4. If anyone needs a comfort break I 

can take it, or we can proceed. Anybody? 

(Simultaneous speaking.)

Chair Ziemer: What's that?

Mr. Katz: I think we don't hear anyone crying for a 

comfort break so I think we should just soldier on.

Chair Ziemer: I think -- let's finish up with issue 4 

because 11 and 12 get taken care of if we get 2 and 

4 taken care of. So let's finish up with issue 4 and 

then we'll be ready to call it a day I think.

Dr. Lobaugh: We still have the other finding and 

observations for the White Paper. Do you want to go 

through those or not?

Chair Ziemer: Well, yes, let's see. Yes, let's finish that 

up. So, let's see. Was Ron doing that? Or Joe?

Dr. Buchanan: This is Ron. Finding 2 was mine. And 

that was concerning the White Paper that was issued 

in 2017. And this is for -- there is gross counting data 

for bioassay and for air sampling.

And so at that time they took gross alpha, beta and 

gamma data on a counter and recorded it as a 
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74

microcuries per liter or whatever the results were 

recorded as.

And to do that they had to assume that it was the 

strontium-90 or it was cesium-137 or americium-241 

or whatever because they had their detection unit set 

up for that in the lab.

And so if you take a sample counter you get a count 

rate, you convert that to dpm or microcurie you have 

to assume some efficiency, some isotope and you 

have a certain calibration standard for that detector.

And so our concern in finding 2 was -- so when you 

go dose reconstruction and you have gross counts, 

you don't have specific information on what that 

isotope was. It might have been counted as 

strontium-90 but it could have been some other 

isotope because there was such a wide variety of stuff 

earlier that Berkeley had such a wide variety of 

radionuclides that the worker could have taken in a 

variety of different nuclides other than this 

strontium-90 say that was counted on his record.

And so in dose reconstruction the way they approach 

it is they look at all the possible radionuclides and 

what the cancer is and assign the one that was given 

the highest probability.

And so this gives a lot of possibilities, a lot of 

solubility types and everything in Berkeley.

And the problem is that if -- was a person who was 

exposed to something other -- a beta emitter besides 

the strontium-90 the counting efficiency would be 

different for that, especially if it's lower energy for 

beta and for gamma it works in reverse, the higher 

the energy the less your efficiency. And so there's a 

lot of self-absorption and backscatter, that sort of 
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75

thing that has to be considered.

And so our question was, okay, how can you assign 

an intake to be most favorable to the radionuclide for 

that cancer if you don't know what it was to begin 

with. And if you assign worst case scenario how do 

you know the counting efficiency.

And so that was our question. And then Megan 

provided a short response but I'll let her discuss how 

they plan on addressing that issue.

Dr. Lobaugh: Yes. So the first thing I'll say is this is -

- in our view of it this is a lower priority than the 

response to the first finding. So we are just proposing 

a path forward and we haven't done any work on this 

part yet.

But we're proposing that we would research the sitespecific detector system information and efficiency 

calibration information for LBNL. If we can't find sitespecific we would use a general assumption for the 

time period. 

And we would determine if accounting for the 

efficiency makes a significant difference in the 

assigned doses in the end, and update the DR 

methodology appropriately if that is the case.

So we have a path forward but as I said the higher 

priority as we see it is finding 1. So that's where we 

have put our focus and probably will put our focus 

going forward.

Chair Ziemer: Okay. Let me ask for comments. Is 

Dave back yet?

Mr. Katz: Dave is back. He may not be speaking up, 

but he emailed me that he was back.
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76

Chair Ziemer: Yes. So, there's a proposed path 

forward and let me see if SC&A has any other 

comments on that.

Dr. Buchanan: Is this on finding 2 in general?

Chair Ziemer: Finding 2 I think was what we're 

talking about, right?

Dr. Lobaugh: Finding 2 for the White Paper. 

Dr. Buchanan: The counting efficiency. Yes, that was 

my finding and I feel that that would be a proper way 

to address it and move forward. 

Chair Ziemer: Well, it makes sense to me. I just 

wanted to see if any of the Board Members had 

comments or questions, or if SC&A understood the 

proposed path forward and if that would be suitable 

for making progress on this one. It seems fairly 

straightforward. 

Member Clawson: Paul, this is Brad. I'm good with 

that.

Chair Ziemer: Yes. Good. Okay, we'll proceed on that 

basis on that second finding. You want to say 

anything on the observations, Ron?

Dr. Buchanan: Well, let's see, that was Joe and Bob 

so I'll let them discuss anything.

Chair Ziemer: Oh yes, right.

Mr. Barton: Okay, this is Bob. I think these are fairly 

straightforward, but certainly we need to discuss 

them.

Observation 1 and I think this really just came out of 

we had gone through the Site Profile and sort of 
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77

compared the potential radionuclide lists that were 

developed in this air sampling methodology that 

NIOSH put forth as a coworker method against 

radionuclides of interest that were listed in the TBD. 

And I think there was some discrepancy between the 

two documents and we pointed out two examples of 

that in our observation. 

And I see you've got this response here from NIOSH 

that's specific to radioiodine but also some of the 

other contaminants of interest that we had seen --

again, we had seen them in the TBD but they don't 

appear in the methodology of the air sampling dose 

reconstruction proposed method.

So I guess with that sort of introduction I guess I'd 

hand it off to Megan to sort of update where they are 

on that particular observation.

Dr. Lobaugh: Yes. So we have agreed to include the 

two isotopes that were mentioned in the White Paper 

methodology update that we make and correct the 

typos that were ultimately found through this review 

in the Site Profile. There were two radionuclides listed 

in the Site Profile that don't exist. So we'll correct 

those typos.

And for the radioiodine they weren't included because 

they would not be captured in the air samples 

themselves. They would have been done via charcoal 

method. So that's why the radioiodines weren't 

included. 

So this is again just update of the White Paper.

Chair Ziemer: So you're good on that, right? No need 

on that to take action. They're just observations. You 

want to move on to the second one?
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78

Mr. Barton: Yes, we can move on. I did have a couple 

of questions.

Chair Ziemer: On the first one?

Mr. Barton: -- close those out, yes. On the first one 

the NIOSH response states that radioiodine because 

it can't be detected using essentially these air 

samples it wasn't included. Is there a separate 

method currently available for dose reconstruction 

for those radioiodines?

Dr. Lobaugh: Yes. So the bioassay, there's bioassay 

specific to radioiodines so that's how they would be 

captured there.

Mr. Barton: How would that work for an unmonitored 

worker?

Dr. Lobaugh: For an unmonitored worker that's a 

good question. I'll have to get back to you on that 

one.

Mr. Barton: Okay. And then the other comment I had 

was you noted that two of the elements that were in 

the TBD actually don't exist and you're right. I looked 

them up myself. But I'm guessing -- you mention 

they were a typo. I'm wondering is it appropriate 

simply just to delete them, or are they a typo in that 

they should be representative of a different isotope. 

The typo wasn't putting them in there, but by simply 

deleting them could we be missing what the intended 

contaminant was originally supposed to be in the 

TBD.

Dr. Lobaugh: I will investigate that. I can't say that I 

know for sure that they were typos. And like you're 

suggesting maybe not another nuclide. So I or 

NIOSH, we will investigate that and make sure before 
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79

we delete it that there was not another intended 

radionuclide.

Chair Ziemer: Yes, that's a good point. Okay. Ready 

for observation 2?

Mr. Barton: Sure. And observations 2 and 3 are really 

essentially tied together. And these really come down 

to how this proposed method would actually be 

applied in practice. And it mainly comes out of this 

quote from the NIOSH White Paper which is on page 

6. I'll just read it into the record now.

It says, "Bioassay requests were generally made 

either once or twice per year for each employee in 

the bioassay program. Workers who worked with or 

in areas that contained unsealed radioactive 

materials typically received bioassays. Therefore, 

based on the typical LBNL bioassay monitoring 

frequency a single bioassay result indicate that the 

worker had at most one year of internal exposure 

potential before the date of the bioassay. 

"All other employment period was no bioassay 

indicate a potential exposure to environmental levels 

only."

So this is essentially how are you going to use this 

method if it's approved in an actual DR context. And 

the way it was originally written which it seems may 

not actually be the intended case is that if you were 

a worker and you had at least one bioassay in a given 

year then you were considered a radiological worker 

and you could apply the air sampling methodology.

And if you didn't have a bioassay in a given year you 

were considered not a radiological worker and you 

only get assigned ambient environmental intakes.
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Now, in the examples that were provided in the 

actual White Paper this didn't really appear to be the 

case because in the examples we saw you had 

workers, again these are example workers, who had 

just partial monitoring. In other words a part of the 

covered employment showed bioassay, but not all of 

it. However, even in those cases even if you didn't 

have a bioassay in a given year NIOSH still used the 

air sampling approach as a coworker model.

So the way it's written here it sounds like if you didn't 

have any internal monitoring in a year you would be 

assigned ambient only, but that wasn't the case when 

we actually looked into the examples that were given. 

And in Megan's response she clarifies that the 

examples are representative of what's intended for 

the dose reconstruction process. So that language 

would just have to be updated and the instructions 

clarified that if you were monitored internally 

essentially even once during your entire employment 

that you would be considered a rad worker and the 

air sampling method again if approved would apply 

to that worker.

And if you were never monitored internally 

whatsoever I believe then what would be done, and 

maybe this is a point of clarification, but I guess what 

NIOSH intended if you weren't monitored at all 

internally you're not considered a rad worker and 

thus would not be given unmonitored intakes based 

on the air sampling approach.

Megan, did I sum that part up pretty well?

Dr. Lobaugh: Yes, that's correct.

Mr. Barton: I guess the only question on that would 

be if you run into a situation where you don't have 
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81

bioassay records for an individual, but the job title or 

statements made in the CATI or any other 

information or even just simply positive external 

doses or things of that nature.

I believe your response also says that that would be 

considered evidence that the person was a rad 

worker even if they didn't have a bioassay result. Is 

that also on point?

Dr. Lobaugh: It would be considered, yes. And then 

as you said unmonitored rad worker would be 

assigned the White Paper methodology approach and 

others determined as non-rad workers would receive 

environmental dose only.

So basically it's the decision of a rad worker versus a 

non-rad worker for LBNL. 

Mr. Barton: Okay. So I mean, similar to other sites 

where if you were -- essentially never entered rad 

areas, if you were purely on the administrative side 

then obviously it's appropriate to only assign the 

ambient environmental.

However, if there is a potential to even periodically 

enter rad areas then you would essentially be 

considered a rad worker?

Dr. Lobaugh: Yes. 

Mr. Barton: Okay.

(Simultaneous speaking.)

Mr. Barton: Oh, I'm sorry, go ahead.

Chair Ziemer: Well, I was asking is SC&A suggesting 

that they add some words to clarify that?
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Mr. Barton: Yes, I believe that was part of NIOSH's 

response, that they needed to clarify these different 

points on how -- it's accepted this air sampling 

approach would actually apply to individuals in 

practice. So that's part of their response.

Chair Ziemer: You're just trying to understand what 

it really meant in terms of the present wording.

Mr. Barton: Right, right. Essentially changes, more 

specific instructions are going to be made. I just 

wanted to get a sense of what those specific 

instructions would entail. So yes.

The second part of this is again sort of comes back to 

this which somewhat puts to rest the previous 

discussion, but the bioassay requirement we took a 

look at because obviously that has a high bar for 

validation as use -- to even include somebody in a 

coworker model.

Obviously we just said there's a lot more to it than 

just having a bioassay in a specific year.

What we did is we basically looked through available 

bioassay records that had been captured by NIOSH 

and are available on the SRDB.

And then we went through those records and pulled 

out claimants. Said all right, we see that these 

claimants have bioassay in these captured records. 

Let's go see what we're actually getting from DOE 

when requests are made for an individual's dosimetry 

file.

In other words are the bioassays we're seeing here 

in the captured records being correctly ascribed to 

the claimant and being forwarded so that in a DR 

context these type of decisions can correctly be 
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83

made.

And obviously this sort of goes back to discussion on 

bioassay completeness.

So what we did is we took those claimants we could 

identify, went to the DOE files and basically it was 

either yes, the bioassay record is correctly in the file 

or no, it's not.

I think we found that overall roughly I'd say 20 

percent were missing at least some bioassay records. 

Or I think, yes, somewhere about 37 or 38 total 

workers were missing them. So we said well, that's 

really not good. Even though sort of the criteria of 

how you're going to apply this air sampling model is 

much broader than we originally thought based on 

our reading of the White Paper, is there a problem 

here with correctly getting these bioassay results 

attributed to the claimant for the purposes of dose 

reconstruction.

I guess that sort of sets up the issue. I know that's 

kind of the bulk of the response provided by NIOSH 

so I guess I'll step back and let Megan sort of explain 

the investigations they did into that issue.

Dr. Lobaugh: Okay, thank you. So, the first thing I 

want to just talk about is some history of the LBNL 

claims records and what we know, what we knew 

going into this and what we now know and what 

we've done.

So in 2010 it was found out that the occupational Xray information, so not related to bioassay, but X-ray 

information was not being sent to NIOSH. And we 

need this as part of the exposure assessment. 

And so in 2010 we started receiving the DAR which is 
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84

document acquisition request which is the 

Department of Labor part of these records requests.

And this DAR includes the medical record, industrial 

hygiene information, human resources, a lot more 

information than what NIOSH may receive when they 

make their dosimetry records request.

So in 2010 we started receiving DARs that included 

the medical information so that we could get that 

occupational X-ray information.

What we know also is that in this medical file is 

typically either a copy or sometimes maybe early on 

the bioassay records and that's the only record of the 

bioassay records is within this medical file. 

And this I think is just because of how LBNL had their 

internal dosimetry program set up at one time.

So, in 2010 we began receiving these -- basically the 

medical file, we'll call the medical file within that DAR.

The records that SC&A reviewed were all pre-2010 so 

they didn't necessarily have this medical record 

information which would have contained some of the 

bioassay records. 

So in their review they maybe saw that bioassay 

samples should have been in there based on the 

introductory letter that is attached by LBNL or DOE 

to the dosimetry records where it says there are 

bioassay samples but no bioassay samples are 

included, or from SRDB documents that contain 

internal dosimetry monitoring and then that 

monitoring was not included in the claimant record.

So since 2010 we're receiving the DAR which includes 

the medical record, medical file. So since 2010 we've 
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found that we are receiving all the dosimetry 

information we should be receiving and are expecting 

to receive.

So for this pre-2010 time though we were still lacking 

the medical file for a lot of our cases. So I think there 

were about 120 or so cases, claims that did not have 

the medical record. 

So for pre-2010 we actually did a mass re-request of 

all of these claims to be re-reviewed by LBNL and the 

medical file sent to us. So this began in January. We 

were in talks in the fall with LBNL about how this 

would go.

So in January they actually began sending us these 

re-requests. And so we prioritized them and we've 

already received the first 25 of these about 100 

claims, 120 claims with the medical file now.

And then we will receive the rest, I think there were 

50 or so that were likely tied to visitors so there was 

no medical file. So if you were just a visitor to LBNL 

you likely wouldn't have entered into their 

occupational medical program there so there 

wouldn't necessarily be a medical file.

So, so far we've received technically responses on 

about 75 of these pre-2010 claims. And we'll receive 

the rest over the next few months. This is a big 

undertaking for them, for the site itself to be able to

re-review all of these records and send them to us. 

So we are currently awaiting to hear how they would 

like to proceed with sending the rest of the claims 

that we requested.

So, basically in summary we've re-requested all of 

the pre-2010 records that would be missing the 

medical file so that we could do a revised dose 
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reconstruction and make sure we have all of the 

dosimetry data that we know about.

And with this change that happened in 2010 of 

receiving the medical file and reviewing CATIs and 

information like that we think that we will be able to 

determine rad worker status for these LBNL 

employees.

Mr. Barton: Okay. I guess for SC&A's part I guess the 

only thing I'd see moving forward -- and I think there 

was really some good research to get a handle on 

what we were seeing with sort of these missing 

bioassays in the worker files.

One thing we could do since NIOSH is already rerequesting those pre-2010 records and SC&A has 

found again, we looked at 36 claims we were able to 

identify and 7 of them did not have the bioassay data 

in their file. Another 6, so 13 total had incomplete in 

that we knew that they had more bioassay results but 

we weren't seeing them.

So if those file requests are being made one thing we 

can do is go back and look at those 13 claims where 

we had identified issues and see if those are now 

essentially solved by the new processes.

Requesting the expanded file from DOE so that you're 

getting the medical records along with the standard 

I guess dosimetry response.

The only thing I would propose as far as a path 

forward on it would be to sort of use the previous test 

which found some issues and put it back up against 

the re-requested records and see if that really clears 

up the issue.

Chair Ziemer: That sounds good, doesn't it? You'll be 
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87

okay with that then, Bob, as you proceed?

Member Clawson: This is Brad. I'm good with it.

Chair Ziemer: Okay. So that will take care of that 

final observation. We won't close the -- we have to 

close observation 2, don't we, Ted?

Mr. Katz: Yes, we generally do.

Chair Ziemer: Yes. So that will correct when we see 

the final information.

Mr. Katz: Yes.

Chair Ziemer: Let's then finish up with 4 which also 

deals with bioassay I think completeness and 

adequacy. So let's see. What did we have. I guess we 

can start with NIOSH on that. Megan, do you want 

to?

Dr. Lobaugh: Yes. So one question I have just in 

general here is because of the overlap with 2, 4 and 

11 and the fact that we've provided combined 

responses I don't know how you -- the Work Group 

would like to track these.

Do you want to track them all under one finding or 

separately? If we track them separately then there 

might -- I would need some help to determine what 

is considered with finding 2 and what is considered 

with finding 4. So that would just be my general 

question first off.

Chair Ziemer: Well, what would be most convenient 

for you? Let me ask that. Does it work better -- since 

there's a lot of overlap work better to combine them 

all into one, sort of one finding?

Dr. Lobaugh: I would suggest given the way 
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responses have gone in the past with combining the 

issues together in the responses that the tracking of 

them together would be easier then, just because of 

the past responses that combines them already.

Chair Ziemer: Well, let's do that. Then the question 

is for issue 4 are there additional parts of that that 

need to be raised that haven't already been 

discussed.

Dr. Lobaugh: I would ask for SC&A to speak on that. 

What I would say is NIOSH's understanding of this 

would be that the February 2014 memo is what needs 

to be responded to right now. So the same memo 

that we were discussing before under issue 2. I would 

say that NIOSH sees that we need to respond to that 

memo.

Chair Ziemer: Let me simultaneously ask -- well, let's 

see your answer to that and then I was going to ask 

SC&A the same question.

Mr. Fitzgerald: Yes, I think that's a reasonable 

approach. You really have the fundamental question 

of data completeness and adequacy which were 

raised in that earlier time frame and sort of was 

recapped in the February 2014 memo which I sent.

We had subsequently asked for and received all the 

SRDB citations that NIOSH felt provided a basis in 

terms of bioassay information. And it ended up being 

thousands of pages.

And we actually did screen through those, scanned 

them, and we came up with a series of questions that 

point to the issues of adequacy and completeness of 

that data as reflected in those SRDB citations.

So, yes, there's a fair amount of work in that that is 
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89

actually related to but not the same as where we are 

in terms of considering the air sampling proposal. So 

it would be very useful to go back and try to address 

the basic questions of adequacy and completeness of 

the data post '61 which I think is a very fundamental 

question in addition to looking at air monitoring as a 

coworker approach for the post '61. So I think both 

those need to go in parallel.

And certainly the data completeness and adequacy 

need to be addressed as a condition for even 

considering the coworker. That would certainly move 

us to want to get back to that and answer those 

questions now.

Chair Ziemer: So, what needs to be discussed now? 

What has been left undiscussed in the issue 2 part 

that we have not covered? Is there any new parts of 

this that need to be raised? Well, SC&A and Joe, in 

your mind have we raised all the issues that would 

apply to issue 4 in our earlier discussion of issue 2.

Mr. Fitzgerald: Yes, but -- to answer the question I 

think will take a little bit of effort just to look at the 

bioassay data post '61.

I raised earlier in our conversation today that there's 

a clear basis for deciding that the end of '61 is fine as 

a cutoff.

Chair Ziemer: Yes.

Mr. Fitzgerald: Because of the program being 

implemented. So we really do need to examine 

whether that premise is in fact validated by the data. 

And that's what this is about.

(Simultaneous speaking.)
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Chair Ziemer: We already raised that question 

though.

Mr. Fitzgerald: We haven't answered the question. 

We certainly have looked at the bioassay data. And I 

think there seems to be some convergence that it's 

not as adequate as we'd like it to be and therefore 

that's why air sampling data is being considered as a 

coworker basis.

But it sort of begs the question going back to '61 that 

if the data is not adequate then we need to address 

that head on, how adequate is it, what's missing and 

since that's going to be combined with air sampling 

as the overall dose reconstruction approach what's 

the -- I think Ron raised this earlier.

Is it predominantly going to be air sampling basis 

because there isn't that much usable bioassay 

information or what. We don't really know that, or I 

couldn't glean it from what we've done so far.

I think this is what Megan's talking about in terms of 

responding to our February 2014 memo specifically 

on that question. And that will I think help us 

understand where air sampling is going to fit in and 

if in fact it's going to be the primary basis for dose 

reconstruction of internal doses post '61.

It sort of ties it all together. I think we skipped ahead 

a few years ago to get to this air sampling as a 

method, a proposed method. And it didn't quite cross 

the t's and answer the question about what is the 

completeness and adequacy of the data since we did 

-- or NIOSH did pick the end of '61 for the SEC.

Is it that much better in reality even though the 

program documentation suggests it is? That would be 

the answer I'd like to see. 
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91

Chair Ziemer: Well, that could still be answered in a 

combined fashion with issue 2 I think.

(Simultaneous speaking.)

Mr. Fitzgerald: Although I could say the question of 

adequacy is the hand. 

(Laughter.)

Chair Ziemer: Yes. But putting them together you can 

think of both parts of this. It's still the issue. Each 

one is sort of half of the issue. But they've got to be 

handled in parallel. So we're okay in putting them 

together as far as tracking and so on.

I think the issue, the two issues have to both be 

addressed, but they sort of -- to look forward they 

can be addressed together probably. I'm really 

asking are there any new issues or any parts of them 

that need further discussion today that we haven't 

already covered. I felt like we had raised the issues 

that needed to be covered in both cases. If there's 

other questions that we want to emphasize or speak 

to we should do that now. 

Megan, are you okay -- I mean okay in the sense that 

you have a good feel for what questions have been 

raised here?

Dr. Lobaugh: Yes, I do.

Chair Ziemer: Okay. Any further comments from the 

Work Group Members?

Member Clawson: No. This is Brad.

Chair Ziemer: And David's not back or is back? 

Apparently not back. 
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92

Well, we have proposed paths forward on the items 

that haven't already been closed so I think we're in 

good shape there.

So item 3 which is Work Group recommendation 

comments or follow-up. We've basically done those 

as we went along in terms of the follow-up and the 

path forward. 

So let me ask if there's any other comments or 

questions that any of the staff people, SC&A, NIOSH, 

or Work Group Members have.

Work Group Recommendations/Plans for Follow-up

Dr. Lobaugh: Paul, I do have a question.

Chair Ziemer: Sure.

Dr. Lobaugh: For the observations on the Site Profile 

would you guys like to go through those quickly? 

What I could propose if you don't want to just talk 

about them now is we could -- NIOSH could provide 

a written response to the observations. Because I 

don't know if we've discussed those in the Work 

Group at all.

Chair Ziemer: The observations in the October --

actually, they were in the April 2018 document. 

(Simultaneous speaking.)

Dr. Lobaugh: No, actually for the Site Profile.

Chair Ziemer: Oh, the original. Okay.

Dr. Lobaugh: Yes, the original --

Chair Ziemer: Yes. Yes.
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93

Dr. Lobaugh: -- with the eight observations.

Chair Ziemer: Why don't you speak to those.

Dr. Lobaugh: Okay. Let me pull up the document. The 

observations begin on page 48 of the BRS entries PDF 

document.

And from what I could gather it looks like these 

haven't been discussed before so this will probably 

be the first time we are hearing some of these.

But the first observation has to do with the fact that 

the LBNL Site Profile does not address LBNL staff that 

have been assigned to other DOE or AWE sites like 

the Nevada Test Site.

So, the initial finding is basically just that, that LBNL 

Site Profile doesn't discuss about what to do if an 

employee has a visitor or work at other sites.

And what I would say the NIOSH response to this 

would be is that when any EE, so this is across the 

program. This is how we would handle it for any site. 

When any EE has been identified as working or 

visiting other DOE or AWE sites the monitoring 

records from those sites are requested.

So this is if we see something in a CATI, if we're 

provided records either through that DAR that I 

spoke about before or some other means via the 

SRDB lookup that happens automatically where files 

get attached to the NOCTS claim.

If we see something that shows that that worker 

could have been at another site we request those 

records from that site.

And then the assessment of those monitoring records 
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94

are covered under the applicable site's Site Profile.

So the LBNL Site Profile would not discuss those other 

sites. We would go to that other site's profile to 

actually assess the results.

Chair Ziemer: Doesn't that happen at every location 

anyway?

Dr. Lobaugh: Exactly. This is a program approach. 

This is, yes, exactly how it happens.

Chair Ziemer: I mean, there's nothing different at 

Berkeley than it would be at any other DOE facility. 

Right?

Dr. Lobaugh: Correct. 

Chair Ziemer: So, I think SC&A just wanted that to 

show up. Was that the -- I didn't see anything 

different than what would always occur anywhere.

Mr. Fitzgerald: I just think it was silent in the profile. 

I think just to clarify that was the case. 

Chair Ziemer: So really just to add some words that 

would do that, or clarify that perhaps. Is that what 

we're talking about?

Mr. Fitzgerald: I think it's understood, but it's 

something --

Chair Ziemer: Yes. Okay.

Mr. Fitzgerald: -- file of LBNL workers at other sites. 

It just seemed like something that should be 

mentioned.

Chair Ziemer: Right. Okay. Let's see, go ahead. 

Megan, follow-up and anything else on that one or 
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95

proceed?

Dr. Lobaugh: So, I guess I would just ask -- we can 

provide a written response in the BRS and then 

commit to updating the TBD with some general 

guidance on --

Chair Ziemer: Yes, yes. Shouldn't take but a few 

sentences, right?

Dr. Lobaugh: Yes.

Chair Ziemer: Okay. What else?

Dr. Lobaugh: So observation 2. So this is more 

information needed for internal dose assignment of 

short-lived radionuclides.

So in the initial response there's mention of table 2-

1 the area information and parameters. There were 

some short-lived nuclides and nuclides with little or 

no gamma emissions listed. So the question is how 

are we going to handle those.

And our initial response would be that the White 

Paper, the method to assess internal dose using 

gross alpha, beta and gamma bioassay and air 

sampling at LBNL provides a method for assigning 

internal dose for the short-lived radionuclides. So 

using like we were discussing before the bioassay and 

air sampling results.

Chair Ziemer: Yes. That should take care of it.

Mr. Fitzgerald: We're fine with that, Paul.

Chair Ziemer: Yes. Okay. Go ahead.

Dr. Lobaugh: Okay. Observation 3 is the lack of 

discussion of radiological incidents. So in the initial 
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96

Site Profile there was no discussion of radiological 

incidents even though we knew about them from 

SRDB documents and things like that.

So our response would be to identify and research 

major radiological incidents, revise the Site Profile to 

incorporate those incidents and then our response 

regarding any kind of small incidents such as skin 

contamination that were brought up in the initial 

finding is that this information is typically handled on 

a case by case basis with the information that we're 

provided in the DOE records request.

So when we know a person was involved with say a 

skin contamination incident then we would account 

for it when we have that information. But it's not 

necessary to put that kind of information in a TBD or 

a higher level document like the TBD.

Chair Ziemer: Yes, particularly on small incidents 

which may involve a person or two you wouldn't put 

that in. You have a definition for what constitutes an 

incident? 

(Simultaneous speaking.)

Chair Ziemer: Nobody disagrees with an SL-1 reactor 

meltdown as being an incident. But and there's sort 

of -- does each site decide what constitutes sort of 

an incident? You know, they have -- we have the 

criticality incident at Oak Ridge back in '58 I think 

and things like that. Everybody agrees those are 

incidents. But what's the threshold?

Dr. Lobaugh: Go ahead, Tim.

Dr. Taulbee: I think, Paul, what we're talking about 

is major ones.
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97

Chair Ziemer: Yes, yes.

Dr. Taulbee: -- along the lines that we would include 

it. But what is called an incident now that would be 

reported into like ORPS type of system now, many of 

those we would certainly not include.

Chair Ziemer: No, no. I'm just wondering if there is 

a threshold we would have under a Site Profile -- you 

can't list every case where somebody has to get their 

shoes cleaned or something.

Dr. Taulbee: Right. I don't know that there is a very 

good definition of an incident.

Chair Ziemer: It's sort of intuitive I guess.

Dr. Taulbee: Yes. Major incidents we will include. The

others we won't.

Chair Ziemer: Okay. Well, SC&A, that would satisfy 

what your question was.

Mr. Fitzgerald: Yes, I think the inclusion of major 

incidents would be fine.

Chair Ziemer: Okay. Let's see. I lost my thing here. 

Is there another one?

Dr. Lobaugh: Yes, there is a few more. So 

observation 4 would be the need to provide 

information on the met lab. 

So the met lab provided dosimetry services for LBNL. 

Let me look at the dates. So they provided dosimetry 

services through 1952. So the observation here was 

that we didn't -- we mentioned it, but we didn't 

discuss what kind of services were provided, the 

calibration that they used, the systems that they 

used, anything like that.
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98

So this is kind of an interesting one at least when I 

was thinking about it because the current SEC for 

external dosimetry goes through 1947. So there's a 

five-year period here where the met lab services 

were used that we can look into to find more 

information about the dosimetry services that were 

provided.

So we can do that, provide additional information on 

that.

One thing to mention though is that the internal 

dosimetry SEC goes through 1961. So, any workers 

that would be onsite through '61 for that 250 days 

would be covered under the SEC.

And so these would be -- the workers affected here 

would be the ones that are non-SEC cancers or don't 

meet the time --

Chair Ziemer: Right, right.

Dr. Lobaugh: So, that's just something to keep in 

mind for the effect I guess of this observation.

Chair Ziemer: Okay. And SC&A, you're okay with

that?

Mr. Barton: Yes, that's fine. It's just a matter of going 

beyond just the identity of the lab to more about it.

Chair Ziemer: Sounds good. Okay. Next one.

Dr. Lobaugh: Okay. So, observation 5 is the lack of 

information on isotopes facilities and handling 

methods.

This is again just speaking to the fact that LBNL had 

a wide mission. There were lots of isotopes and 

things that they were using onsite as well as coming 
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99

up with some new elements. 

So, what I would suggest is given finding 1 where 

we're going to be providing more information on the 

facilities, the handling and isotopes that were used 

this observation kind of falls up underneath finding 1. 

So I would suggest that this would actually be 

addressed in that finding.

Chair Ziemer: Right. It would be all inclusive there so 

the finding would basically be handled by the update 

of finding 1.

Mr. Fitzgerald: I think this one speaks to going 

beyond a list of the facilities and a list of the nuclides, 

but actually maybe some mention of what kind of 

work, what kind of interface by the workers there 

were with the accelerators and machines. Just some 

notion about that.

Because obviously it's a pretty diverse operation 

there.

Chair Ziemer: Very diverse, yes.

(Simultaneous speaking.)

Dr. Lobaugh: Yes, so for finding 1 we'll update the 

Site Profile with the additional facility information 

that we've captured since the last revision.

So like I said earlier there's been a lot of information 

that we've found and we're going to be able to beef 

that part up a lot.

Chair Ziemer: So in the record you'll simply say that 

you've included the information in the results of 

finding 1 and that will take care of that hopefully.

Dr. Lobaugh: Yes.
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100

Chair Ziemer: Okay. Let's see. You've got another 

one here.

Dr. Lobaugh: Yes, observation 6 is the extremity 

dosimetry needs revisiting.

So this one is about the fact that the extremity 

monitoring is mentioned and not really discussed. So 

again this is one where I'm going to suggest that we 

think of this as addressed in another finding. 

So we see that we will be responding to this in finding 

7, a finding that we discussed earlier on this failure 

to address the shallow dose to deep dose 

assumption. 

So in response to that we're going to be looking at 

the extremity dosimetry too. So we would be able to 

respond to this observation within that finding.

Chair Ziemer: Right. In a similar way to the previous 

one. Yes, that's good.

Dr. Lobaugh: Okay.

Chair Ziemer: Yes.

Dr. Lobaugh: For observation 7 there is a lack of 

sufficient information for external dose evaluation.

So here there were basically two major sections, or 

two major I guess ideas that SC&A brought forward 

was that we're lacking some information on 

dosimetry program specifics and the site description.

So, as with the previous two findings we kind of see 

that this would be covered under a few of the other 

findings that we had. So the site description part of 

it will be covered under finding 1 earlier and the 

program specifics we'll be discussing in our responses 
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101

to findings 6, 7 and 8 about the external dosimetry 

program.

Mr. Fitzgerald: I would add though I think --

Dr. Lobaugh: Okay.

Mr. Fitzgerald: -- comments going to be reflected in 

the TBD because I think this is more of a finding that 

the treatment of the subject external dosimetry 

wasn't as robust as it could be in terms of the history, 

the milestones in terms of one dosimeter replacing 

another.

I would consider those sort of the basics that you 

typically find in the Site Profile. And I think some of 

the earlier Site Profiles were more abbreviated than 

later ones and I think this is the case here. It could 

be made more robust.

So this is really a reflection of what the TBD would 

end up containing as far as the scope of coverage and 

how robust the treatment is.

Dr. Lobaugh: Okay. So our path forward would be 

improving the details of the external dosimetry 

program and the dosimeters, the historical dosimeter 

usage in the Site Profile. 

Chair Ziemer: And Joe, are you asking for more 

specific time frames for, for example, when they 

started using CR-39?

Mr. Fitzgerald: I think when we look across the Site 

Profiles and particularly the second or third 

generation Site Profiles it's more explicit about some 

of the dosimeter history so that the dose 

reconstructor knows that certain time periods you 

have certain dosimetry that was replaced. A new 
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102

dosimeter came in.

Sometimes there's issues with that new dosimeter as 

we have seen in places like Brookhaven. So that's 

useful for the dose reconstructor to know that yes, 

there was some issues with technology.

Just really to paint the picture more fully as to what 

that history was and what the different technologies 

were. Just sort of --

(Simultaneous speaking.)

Mr. Fitzgerald: -- extremity as well, the extremity 

dosimeter. Just so that the dose reconstructor has a 

pretty good backdrop of how the site handled things.

Chair Ziemer: Yes. You're talking about even detail 

such as the kind of filters used in a particular 

dosimeter?

Mr. Fitzgerald: Again, this goes back --

Chair Ziemer: It goes into -- (Simultaneous 

speaking.)

Mr. Fitzgerald: I wasn't the reviewer 12 years ago on 

this Site Profile. I'm guessing that more granularity 

would help, but I would leave it to NIOSH to judge 

consistent with how other Site Profiles have been 

developed what level of detail makes sense.

I think some of these probably are too detailed and 

others are more pertinent to what the dose 

reconstructor would need.

I think that's the key, what does the dose --

Chair Ziemer: Yes.
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103

Mr. Fitzgerald: -- reconstructor need to have as a 

backdrop to help them make judgments on dose 

reconstruction.

Chair Ziemer: Right. So we'll have a chance to judge 

that when they prepare that response. I don't know, 

Megan, if you're prepared to say now exactly what it 

will contain, but you hear the comment at least and 

you're going to try to address it.

Dr. Lobaugh: Yes. Correct. 

Chair Ziemer: And this is really an observation rather 

than a finding so it I think to most people doesn't 

have quite the thrust for detail as it might have for a 

finding anyway. But at least more granularity as you 

say.

Okay. Let's see, where are we here.

Dr. Lobaugh: There's one more observation.

Chair Ziemer: Yes, one more.

Dr. Lobaugh: So, observation 8 is the overuse of 

generalizations and assumptions.

So this had to do with some of the ratios that we were 

using, so the shallow to deep dose ratio, the IREP 

photon energy fractions that we used and neutron to 

photon dose ratios.

So regarding the site-wide and time encompassing 

correction factors or energy group breakdowns, 

energy range breakdowns these are going to be 

covered in our responses to findings 6, 7 and 8 for 

the external --

Chair Ziemer: Right, right.
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104

Dr. Lobaugh: Regarding like missed dosimetry, so 

there's a discussion of missed dosimetry. So, as in 

the dosimetry results were not included in the claim 

files.

As we discussed with observation 2 and 3 for the 

White Paper there's been some changes since the 

time of this SC&A review to the actual records 

request responses from DOE. So now we're receiving 

all of the medical files as well.

And I just wanted to say a reminder that there is 

always an SRDB document review that automatically 

happens in the background that ties any documents 

found in the SRDB with the employee name or other 

identifiers to that claim.

So -- and the dose reconstructor takes all documents 

into consideration when they're doing the dose 

reconstruction. So that's kind of in response to the 

missed dosimetry. 

And then how their claims process has changed. So I 

would suggest that this would be addressed in 

findings 6, 7 and 8 and then observations 2 and 3 

from the White Paper.

Chair Ziemer: And in your overall response will there 

be I guess documentation for this and some of these 

other observations you'll refer back to the fact that 

they're covered in the findings, in those particular 

findings. Is that how it will happen?

Dr. Lobaugh: Yes.

Chair Ziemer: Okay. Sound okay to you, Joe?

Mr. Fitzgerald: That's fine.
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105

Chair Ziemer: Yes. And Brad, we're okay? On all 

these observations.

Member Clawson: Yes. We're fine, Paul.

Chair Ziemer: Okay. Now, let me ask Ted are there 

any other things that we need to cover today? I think 

we've covered everything.

Mr. Katz: I think we're good. I think we just -- it 

would be helpful to have something -- and I know 

there's like better understanding now about some of 

the SC&A concerns and follow-up that will be needed 

to address these, particularly the primary findings of 

concern.

But so earlier in the meeting, Megan, you had 

mentioned that some material would be ready 

sometime this summer. But I don't know whether all 

the rest of the discussion that comes in sort of gives 

you a different calibration of roughly where in the 

calendar we're talking about possibly meeting again?

Not that I'm going to schedule it now, just it's helpful 

though to have a sense of where we're headed.

Dr. Lobaugh: I think we'll be able to provide some 

preliminary responses this summer. As far as followup to the White Paper I think that's going to take us 

a little while longer because like you said we're going 

to update that White Paper. So I think that's going to 

take a bit of time.

And I would say that's probably from how we see it 

our priority is the follow-up to that White Paper and 

the air sampling questions. 

But as far as preliminary responses to some of these 

TBD findings that we haven't responded to, especially 
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106

the external dosimetry, we expect to provide that 

fairly soon. I would say this summer.

Mr. Fitzgerald: Megan, I had one quick question. 

Dr. Lobaugh: Yes.

Mr. Fitzgerald: You pointed out in one of your updates 

that Lawrence Berkeley declined to I guess send pre2010 medical information. You pointed out that more 

complete medical files are being provided. But that's 

only post 2010, right?

Dr. Lobaugh: So what happened there was when we 

discovered this in 2010, Lawrence Berkeley I would 

say had a lot of pushback on the amount of time that 

would take them to provide the responses.

So as I explained before we actually just started this 

re-request in January. And it is just claims prior to 

2010 because since 2010 they've been sending us 

the entire medical file because they're sending us the 

DAR information.

So, the re-request that we're currently in the process 

of doing or receiving responses for starting in January 

and it's any claim that was received prior to 2010 that 

was not compensated under an SEC or the dose 

reconstruction process already. Yes.

Chair Ziemer: Do they have the full list of that now? 

They have the full list though, right?

Dr. Lobaugh: Yes. They've received the full list of 

claims that we've requested and we've prioritized it 

for them in groups of about 25 or so which we 

received the first 25 so the prioritized group of 25, 

our first 25 we received. 
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107

And then they've already come back with responses 

on an additional 52 that did not have any medical 

files. So we consider those 77 or so claims completed 

of that response.

Chair Ziemer: But that will continue for a while until 

you get all of the ones available.

Dr. Lobaugh: Exactly. So currently LBNL is 

determining the best -- so they've contracted out 

some work to do the copying and some of those 

tasks.

And so the next discussion that we're having with 

them is going to be the best way to receive the final 

responses so that it's not such a burden on them 

because they really do I think only have like one 

person working all of these requests.

So they're working the regular routine requests that 

are coming in as well as these extra ones we've asked 

them to do.

Chair Ziemer: Ted, I'm wondering if maybe sometime 

around July we might want to -- if we have some 

completed documents or White Papers or whatever 

it's going to be that we could have a teleconference 

just to deal with them so that they can move forward. 

We'll just have to see where we are though.

Mr. Katz: Something similar, Paul, that just the staff 

on both sides, SC&A and DCAS. When you feel like it 

would be useful to have a Work Group meeting so 

you can push forward with some of the matters that 

do get responded to. Let the Work Group know and 

we'll schedule accordingly. So we'll leave it in your 

hands to judge when you have material that you'd 

like to move on one way or another and it would be 

helpful to have a Work Group meeting. In this 
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108

summer or after. Does that work?

Mr. Fitzgerald: That sounds good.

Mr. Katz: Okay.

Adjourn

Chair Ziemer: Okay, we'll go on that basis then. 

Sounds good. Okay. Well, thank you, everybody. 

Appreciate the -- I think we made good progress here 

on this today. So we will adjourn.

Mr. Katz: Thank you, Paul. Thank you, everybody, for 

all this work.

Chair Ziemer: Thank you.

(Whereupon, the above-entitled matter went off the 

record at 1:02 p.m.)