1 

United States of America

Centers for Disease Control

National Institute for Occupational

Safety and Health

Advisory Board on Radiation and

Worker Health

128th Meeting

Wednesday

April 17, 2019

The meeting convened at 8:30 a.m., Eastern Daylight 

Time, in the Pittsburgh Marriott City Center, 112 

Washington Place, Pittsburgh, Pennsylvania, Ted 

Katz, Designated Federal Official, presiding.

Present: 

Ted Katz, Designated Federal Official

Henry Anderson, Member

Josie Beach, Member

Bradley P. Clawson, Member

R. William Field, Member*

David Kotelchuck, Member

James E. Lockey, Member

David B. Richardson, Member

Genevieve S. Roessler, Member*

Phillip Schofield, Member

Loretta R. Valerio, Member*

Paul L. Ziemer, Member*

Registered And/or Public Comment Participants: 

Nancy Adams, NIOSH Contractor

D'Lanie Blaze

Zaida Burgos, NIOSH

Grady Calhoun, DCAS

Kirk Domina

Eloy Giron*

Rose Gogliotti, SC&A*

Kirk Grimes*

Stu Hinnefeld, DCAS

Lara Hughes, DCAS
2 

Michele Jacquez-Ortiz*

Deb Jerison

Josh Kinman, DCAS

Greg Lewis, DOE

Mark Lewis, ATL

Megan Lobaugh, NIOSH

Vernon McDougall, ATL

Matt McFee, ORAU Team

Jenny Naylor, HHS

Charles Nelson, DCAS

Jim Neton, DCAS

John Palastro*

Rich Palastro*

Rick Reefer

LaVon Rutherford, DCAS

Hugh Stephens

Tim Taulbee, DCAS

Marissa Thomas, CDC

*Participating via telephone
3 

Contents

United States of America Centers for Disease 

Control National Institute for Occupational Safety 

and Health Advisory Board on Radiation and Worker 

Health 128th Meeting Wednesday April 17, 2019 1

Welcome and Roll Call 4

NIOSH Program Update 9

DOL Program Update 16

DOE Program Update 20

Sandia National Laboratory, SEC Petition No. 

188 Evaluation Report Addendum 23

Santa Susana Area IV, SEC Petition No. 235

49

Idaho National Laboratory, SEC Petition No. 

219 96

SEC Petitions Status Update 110

Board Work Session 113

Public Comment 129

Superior Steel Company, SEC Petition No. 247

132

Adjourn 158
4 

Proceedings

(8:35 a.m.) 

Welcome and Roll Call

Mr. Katz: We have a lot to do this morning, so I'm going 

to get started, first with some preliminaries. For 

everyone, particularly for folks on the line, welcome 

everyone. This is the Advisory Board on Radiation and 

Worker Health. This is our 128th meeting, and this is our 

first time in Pittsburgh, so we're glad to be here.

We're here in Pittsburgh because later, at the end of the 

day, we're going to be talking about Superior Steel, which 

is here in the area, and it's an opportunity for people who 

have some relationship with that facility, whether they 

worked there or are survivors or what have you, to see 

the Board, hear the Board, and also comment to the 

Board if they want, because we're doing an evaluation of 

a Special Exposure Cohort petition from that site, which 

is underway and you'll hear about that in the end of the 

day.

So also for everyone on the line, the agenda and the 

materials for this meeting are posted on the NIOSH 

website for this program, and that includes all the 

presentations that are going to be given are there posted, 

and the background papers for those presentations too 

for more context.

We do have also, and it's listed on the agenda, a Skype 

connection, and that would allow you, for folks on the line, 

to be able to follow the presentations as they're being 

given in real time. But at the present time, we're 

struggling with that Skype system. 

So I'm not sure whether it will be ready first thing or not, 

but again just to remind you folks on the line, the 

presentations are all posted on the website, so you could 

pull up those presentations as they're being given and 

follow along even if Skype, we don't get the Skype 

working. So that shouldn't be a calamity.

Let's see. So I mentioned we're here in part because 

Superior Steel is here and that we have a petition from 

there that we're evaluating. So there will be a public 
5 

comment session and that will begin at, let's see, at 6:00 

p.m. 

So people who are listening in and want to -- are 

particularly interested in Superior Steel or another 

petition or just want to comment, 6:00 p.m. Please be on 

the line at that point, because we never know how long 

the comment period will go. It just depends on how many 

commenters we have.

All right. We have -- let me just speak to conflict of 

interest for the Board Members, instead of having them 

deal with that directly. We don't have a lot of conflicts for 

this meeting. 

We do have for a session on Sandia National Lab SEC 

petition we have two Board Members who have conflicts 

and will recuse themselves for that session, and for that, 

for Sandia it's Phil Schofield, who's here in the room, and 

Loretta Valerio who will be on the line, or she's probably 

already on the line. But we'll go through that, go through 

roll call for that.

And otherwise, Idaho National Laboratory in the 

afternoon. We have Brad Clawson here. He'll recuse 

himself from that discussion, and that takes care of all the 

conflicts for the day, so pretty simple. 

So, roll call. 

(Roll call.)

Mr. Katz: Right. So welcome all of you, and that's a full 

Board, so we have our quorum and more, which is great. 

Okay. At this point, before we get onto -- we have a 

NIOSH Program Update that starts at 8:45, we've got 

some minutes before and we have something to do 

beforehand.

We have two members of the NIOSH team, the Director, 

Stu Hinnefeld, and the Associate Director for Science, Jim 

Neton, who are -- this is their last meeting in person. It's 

the last meeting period for Jim, and I think Stu will still 

be here for the teleconference?

Okay. So we don't even get him for that. Okay. So we're, 

all right. So Jim has been with the program since the 

beginning of time of the program, and Stu came not long 
6 

afterwards. This is a big body blow to lose them. They've 

been dear to us. They've done enormous things with this 

program, in developing this program. 

So we have some sentiments from the Board to start with, 

and more to do. So Paul and Gen, if you want to take it 

up at this point. 

Member Roessler: Okay, I turned off my mute.

Mr. Katz: It's okay. I think maybe Paul starts with Stu or 

either way. The order doesn't really matter but --

Member Ziemer: Yeah, Ted. I need to pull up and maybe 

Gen can go ahead and go first.

Mr. Katz: Oh that's fine, yeah.

Member Roessler: Okay, I'm ready. Can you hear me?

Mr. Katz: You're a little faint. I don't know if we can 

increase the gain on you or -- why don't you say 

something more Gen so we can hear.

Member Roessler: Okay. Well let me move the phone a 

little bit. Does that get better?

Mr. Katz: That is better, yeah.

Member Roessler: Okay. I'll try and hold it still. So if 

you're ready, I'll begin.

Mr. Katz: Yeah, thank you Gen. 

Member Roessler: Okay. This is a salute to Dr. James 

Neton. The Advisory Board on Radiation and Worker 

Health extends its congratulations and best wishes to Dr. 

James W. Neton upon his retirement as Associate Director 

for Science, Office of Compensation Analysis and Support, 

National Institute for Occupational Safety and Health, 

NIOSH.

For the past 19 years at NIOSH, Dr. Neton, Jim has 

provided scientific excellence, integrity and leadership as 

the principal scientist, author and mentor of the many 

technical strategies used by NIOSH to reconstruct the 

radiation dose history of workers in the U.S. nuclear 

weapons complex.
7

During his years of service at NIOSH, Jim's responsibilities 

in the Office of Compensation, Analysis and Support 

included health physicist in the health-related energy 

research branch, where he conducted retrospective 

external and internal radiation exposure assessments for 

use in epidemiologic research study.

Technical program manager involved with supervising a 

multidisciplinary team of technical, administrative and 

contract personnel to support NIOSH's activities related 

to the Energy Employees Occupational Illness 

Compensation Program Act of 2000, EEOICPA. Associate 

Director for Science with responsibility for the overall 

scientific development of dose reconstruction methods 

and risk models under the EEOICPA provision.

In all of these activities, the Advisory Board Members 

have observed Jim Neton's devotion to his work, his care 

in dealing with claimants and his fairness considering all 

aspects of the science and technology involved. He has 

been an effective communicator of dose reconstruction 

concepts and issues not only to the Board and the support 

staff, but also to members of the general public.

Throughout his time at NIOSH, Jim Neton made sure that 

the dose reconstruction program was developed on a 

sound scientific basis. He carried out his responsibilities 

in what was often a politically charged environment, and 

he did it very well.

As Jim Neton retires from his years at NIOSH, the 

Advisory Board on Radiation and Worker Health offers him 

its gratitude for what he has done in developing and 

advancing dose reconstruction methods. We wish him and 

his family the best in all he does as he enters the next 

phase of his life.

Mr. Katz: Thank you, Gen. And Paul, are you ready?

Member Ziemer: Yeah, and I'm pleased to present this 

salute to Stuart Hinnefeld. The Advisory Board on 

Radiation and Worker Health extends its best wishes to 

Stuart L. Hinnefeld upon his retirement as Director of the 

Division of Compensation Analysis and Support, DCAS, of 

the National Institute for Occupational Safety and Health, 

NIOSH. 

For the past 16 years at NIOSH, Stuart Hinnefeld, Stu, 
8

has provided strong and steadfast leadership in building 

the NIOSH portion of the Energy Employees Occupational 

Illness Program Act, on a solid, scientific and technical 

basis. He has always administered the program fairly and 

with compassion, and he's shown dedication to the 

claimants that are the program's -- or the claimants that 

the program served.

During his years of service at NIOSH, Stu's 

responsibilities have included dose reconstruction team 

leader who provided leadership and technical guidance to 

a team of health physicists in preparation and review of 

radiation dose reconstruction reports, including the 

development of strategies and techniques for performing 

dose reconstruction, technical program manager and 

responsibility for all health physics activities.

This included the technical solutions team that developed 

and utilized database systems and computer applications 

used to support claims tracking and dose reconstruction 

efforts. Interim director and subsequently Director of the 

Division of Compensation Analysis and Support, with the 

responsibility of providing leadership and guidance to 

scientific, professional, administrative, technical and 

support staff.

This included program planning and policymaking 

activities. In all of these activities, the Advisory Board 

Members have observed Stuart Hinnefeld's dedication to 

the program, his sensitivity in dealing with Members of 

the Advisory Board, his courtesy and fairness towards 

claimants, and his respect for the science and technology 

involved.

He and his staff have been effective communicators of 

dose reconstruction concepts and issues to all of the 

program's stakeholders. Throughout his time at NIOSH, 

Stuart Hinnefeld performed his duties with the highest 

level of integrity and ethics.

As Stu retires from his years at NIOSH, the Advisory 

Board on Radiation and Worker Health offers him its 

gratitude for all of his contributions in developing and 

leading the efforts at NIOSH for the dose reconstruction 

program. We wish him and his family the best in their 

future endeavors.
9

Mr. Katz: Thank you, Paul. We also have some 

commemorative objects to present to Stu and Jim. If you 

want to come up and Josie and Andy will take care of that. 

(Applause.)

Mr. Katz: Okay then. We're on to a NIOSH Program 

Update from -- Stu has to follow that. Yes thank you, and 

thanks so much Paul and Gen for doing the honors.

NIOSH Program Update

Mr. Hinnefeld: Okay. Well thank you all for that. I guess 

it's a little bittersweet because I feel that because of the 

affection and respect I feel for all the Board Members, it's 

something -- it's one thing to do this as your job. It's quite 

another thing to be a member, a special government 

employee, a member of the Board who participates in this 

because of dedication to the program.

So I just wanted to say thank you to all of you for your 

continued service. I know some of you have served very 

long. I'll also comment that it was particularly nice to have 

Dr. Ziemer read my acknowledgment. He may not want 

me to admit this, but we met each other in 1977 when I 

showed up at Purdue as a graduate student in Health 

Physics and I was lucky enough to have Paul as my major 

professor.

So before I'm sure some of my staff were born, that's 

when I met Paul. So anyway, thank you all for that. One 

last time I'm going to do this, this presentation. So you 

said hit enter. Well, that's worked. Okay. Do I have to go 

back? 

Okay, well the first line is just what we talked about. The 

first line I skipped right past is about Jim's and my 

retirement. Jim's last day of employment is next Friday. 

My last day of employment is June 21st. 

I was going to say it was the last day I was going to work, 

but it's a little questionable about how much work I'll 

actually be doing on June 21st. But my last day of 

employment is June 21st.

There was -- there were competitive promotions for 

opportunities for our understudy positions, and we 

decided I think I mentioned in December that we would 
10

be pursuing understudies for our two positions, based on 

the competitive hiring process, Grady Calhoun is now 

serving as my understudy. His term started Monday I 

believe as my understudy.

Tim, for a little bit longer than that, has been the 

understudy for Jim. You both know them very well. 

They're both very familiar with the program, and I don't 

envision a lot of hiccups or a lot of need for phone calls 

back to me because I think Grady knows everything I do 

anyway. So that's the news on the personnel front. 

In terms of upcoming events, outreach, we've had a slow 

period through the winter. We haven't really done any 

outreach since December, but we're making up for it this 

spring with several things coming up. 

In May, we have the Department of Labor sponsoring an 

outreach meeting that they've asked us to attend with 

them for Brookhaven National Lab. That's in the Middle 

Island, New York.

So one of us, some of us will be -- somebody will be there 

mainly to answer questions probably. In June, the DOL is 

sponsoring the fourth of their authorized representative 

workshops, which they've done around the country. 

They've done one in Jacksonville, Florida, one in 

Kennewick, Washington. We hosted one at our facility in 

Cincinnati, and this one will be in Las Vegas in June.

We go and present a couple of -- a module multiple times 

because they do breakout sessions for that workshop, so 

we will be attending that. The DOL Ombudsman has told 

us that they intend to sponsor outreach meetings at the 

Fernald site, which is right by Cincinnati, and also at 

Columbus, I guess for Battelle.

So we will also attend those. Those will be relatively 

straightforward for us to get to. Those are in June, and 

we're going to Oak Ridge for a couple of different reasons. 

There is a town hall meeting that DOL sponsors 

associated with the expansion of the Class there.

You recall that action was taken last Board meeting. That 

Class was effective at the end of March, and the Board --

DOL typically does outreach town hall meetings when a 

good-sized Class is added. This is probably a pretty good 

size Class that's added at Y-12.
11

And then finally with our outreach contractor, ATL, we are 

conducting a one day DR and SEC workshop in June in 

Oak Ridge as well. ATL puts on a portion of that workshop 

and we have a speaker who puts on a portion also.

Now I actually have some other news this time. I guess, 

I don't know if everyone knows. Most of you probably 

know that one, I think it was January 22nd, the Tuesday 

after Martin Luther King three-day holiday, we came into 

our offices and found that the sprinkler line had frozen 

and broken right above our B1 conference room.

So I think most of you have been to our facility and you 

probably, if you may have a vague memory of the 

conference room where we did our briefing. That's the 

conference room. The sprinkler line was right above the 

fake ceiling there, and there's a lot of water in a fire line.

When it started running, it actually smelled like fire. The 

water, since it sat in the pipe so long. And so when the 

engineering staff, NIOSH maintenance staff got there said 

it smells like fire, they didn't turn the sprinkler off and 

waited for the fire department to show up to turn the 

sprinkler off. So the water flowed for a while as well. It 

flowed all through our offices, out the hall, into the 

hallway. That was in our B1 area. 

Now directly below that is our B2 area which we also 

occupy, where we have our claimant communication staff 

and where we used to have -- thank goodness we don't 

anymore -- tons and tons of paper records. Now we have 

digitized all those records, so the paper's all thrown away. 

So fortunately there was no paper down there.

There was some penetrations in the floor, and certain 

spots in B1 also got soaked. So we were out of our offices 

until last week, right? So from January 22nd until last 

week, we didn't have use of those offices as they took out 

the flooring, took out some of the drywall, repaired the 

ceilings and they moved us back in last week.

We were on what we call emergency telework. All of our 

people were teleworking full time, and we do have some 

offices that people could come in. If they needed to come 

in, there were offices we could find for them to use. So 

but people were on emergency telework for almost three 

months because of that. But things seemed to keep 
12

moving, so I guess the credit to people's ability to work 

at home I guess.

Also since December, the RFP has gone out. Proposals 

have been received and we're in the evaluation process 

for our dose reconstruction contract. ORAU is the current 

holder of that contract. They have been since the start of 

the project, but every five years, we recompete it.

And so it's in the recompetition stage. The contract was 

scheduled to end at the end of March, right? But the 

award wasn't going to be made and so the contract has 

been extended through June. So ORAU is the contractor 

through June, and we believe we are late in the selection 

process.

We have done a lot of our portion, maybe all of our portion 

of the selection process, and we believe we're late in that 

and we believe a selection can be made by June, but it's 

really in the hands of our programs and grants office. It's 

not in our hands. So chances are there will be a new --

well, we are hoping there will be a new contract in place 

on July 1st. It may be a new contractor, it may be the 

existing contractor.

Now this next item is a technical change that affects what 

we do, a few things quite difficulty, most stuff not very 

much or it can be addressed very simply. ICD is the 

International Classification for Diseases. It's a way to put 

a number on a diagnosis, and number nine, ICD-9 was 

the ninth version of that, and that was the version that 

was in effect when this program started.

So we've written into our regulations references to ICD-9 

and ICD-9 codes. In the dose reconstruction rule, there's 

a table of ICD-9 codes and possible primaries, if you've 

got a secondary and you don't know the primary. Well 

that all has to be changed to ICD-10.

Now this is strictly a technical change. We're not really 

changing anybody's requirements except us. The reason 

that it had to change is because the world -- by the way 

when I say the world, I mean the Center for Medicare and 

Medicaid Services who kind of sets the rules, because 

everybody goes along with Medicare.

They adopted ICD-10 a couple of years ago and for a 

couple of years they have maintained this crosswalk that 
13

they would translate them, and DOL has relied on that 

translation of ICD-9 and ICD-10 to keep using ICD-9 and 

sending us ICD-9 codes, which is what we've been using.

Well CMS, the Center for Medicare and Medicaid Services, 

is going to stop doing that in October. And so that 

prompted us, well now we have to change. We have to 

get all our paperwork up to date to ICD-10. We're writing 

our internal procedures to do that and making sure we 

can do it that way, and we are revising our regulation

through an interim final rule.

That's what it's called right, interim final rule. It's strictly 

a technical change and that process is in place as well. As 

far as I know, there are no difficulties and that's going to 

happen.

And then one final item, I've been talking a lot about low 

dose radiation research, which is kind of funny because 

through most of my career, let's see, it was just kind of 

accepted. I mean it was going on and didn't really seem 

to affect much. Now all of a sudden there's a lot of interest 

in whether low-dose dose models are really being 

appropriately determined and our rules based on those, 

are those the right regulations we should have.

So there's a certain amount of debate about that, but and 

so there have been a number of discussions at national 

meetings, and this next one is sponsored by the National 

Academies of Science in Washington in May. It's on the 

future of low dose radiation research, and it's a 

symposium at the National Academies of Science, and we 

will have people attending that as well.

So we're trying to -- we want to keep our ear to the 

ground. We don't really do radiation research in our 

program. We want to make sure that we're 

knowledgeable of what's going on. It could in fact affect 

what is done in this program in terms of the risk model 

and modifications to the risk model, so we will be 

attending that as well.

Member Anderson: What's the date on that?

Mr. Hinnefeld: The dates of that symposium are May 7th 

and 8th I think, 7th and 8th. It's the Wednesday and 

Thursday of that week of May, the first full week of May. 

So and I believe it might be webcast or something, is that 
14

right? 

There may be a way to watch it remotely as well. But it's 

in D.C. at the National Academies, right there right on the 

Mall essentially. Okay. I am already over time. I -- well, I 

did something wrong. 

Okay, okay. So the case statistics are in the handout. I 

would propose that I not run through them since I've 

taken so much time with announcements and things. If 

there are questions about them I'll be glad to answer, or 

questions about any of the other things, anything I 

commented on or anything I didn't comment on. I'll be 

glad to try and answer those.

Mr. Katz: Right. So any questions from Board Members? 

(No response.)

Mr. Katz: Not in the room. How about on the line?

(No response.)

Mr. Katz: Okay. Then thank you Stu. We should zip -- oh, 

go ahead.

Member Richardson: I'm sorry. I knew there was a 

question that was in my head and I was searching for it 

to come back. The issue of the ICD codes --

Mr. Hinnefeld: Uh-huh.

Member Richardson: And you had mentioned previously 

you had been receiving codes from Center for 

Medicare/Medicaid?

Mr. Hinnefeld: Labor. Labor got them. 

Member Richardson: Labor was receiving those.

Mr. Hinnefeld: Labor got the translation and sent them to 

us.

Member Richardson: The other way that a claim could 

come in would be for a deceased claimant, and how -- I'm 

trying to think. I mean when that transition happened 

with the coding, with different organizations have taken 

up using ICD-10 going back to around 2000 I think was 

actually the date of the transition.
15

Mr. Hinnefeld: Right.

Member Richardson: And in fact, I'm just thinking about 

this process, that's always seemed a little confusing to me 

that there was a cite to an ICD-9 when you could have 

claimants filing who had deceased under the ICD-6, 7, 8, 

9 and 10. Is there -- and the cross-walk gets more and 

more complicated as you span all those revisions of the 

ICD. So how has that -- how has that been 

operationalized?

Mr. Hinnefeld: Well, I think that might be a question for 

the Department of Labor, because they send us an ICD 

number associated with the diagnosis, you know, because 

they verify the diagnosis and things like that. So they 

send us an ICD and up to now they've sent us ICD-9 

codes, and they will be sending us ICD-10 codes.

So whatever translation has been occurring from earlier 

diagnoses, Labor has done that up to now anyway.

Member Richardson: And they're going to continue to do 

that, but they're not going to go from 10 to 9? Is that the 

issue? Because you are -- you still could be getting 6's, 

7's and 8's?

Mr. Hinnefeld: Yes. Presumably, they will take those to 

10's now, and they will send everything as 10's.

Member Richardson: Well that seems -- it's actually 

impossible to do that. So I don't know what they'll do.

Mr. Hinnefeld: Okay. Well, I really don't know how, what 

they're planning to do.

Member Richardson: Okay.

Mr. Katz: Yeah, and because the Board advises NIOSH on 

rulemaking, EEOICPA rulemakings, we'll have this in 

August I think, right? In August, right, we'll have this 

because of the interim final rule. 

So it is effective immediately so that we can put it to 

work, but it also allows opportunity for comment and the 

Board, we will be getting the Board's comment, such as 

we have for all rulemaking we've done in this program, 

even though this is just a technical change, maybe that's 

another opportunity to get some information from DOL 
16

about this.

Mr. Hinnefeld: Yeah. I'm just not very familiar with their 

part of the operation and how they do it.

Mr. Katz: Okay. We should go on. We're quite behind, and 

we have an SEC petition to discuss this morning. So I 

would just -- I hate to do this, but I would ask -- DOL's 

up next I believe on the line.

Mr. Hinnefeld: I'm not sure I can get their presentation 

up. I'm not --

Mr. Katz: Okay. Why don't we switch? Why don't we then 

have DOE come up.

Mr. Hinnefeld: Labor's is up now.

Mr. Katz: Oh Labor's up. Okay. So Frank, are you on the 

line?

Mr. Hinnefeld: Or was.

Mr. Katz: Crawford?

Mr. Crawford: Yes sir, I'm here.

Mr. Katz: Okay. So I'm going to ask you -- I hate to do 

this, but given the time constraints that we have an SEC 

petition, to just try to be very efficient in this 

presentation, and leave the Board time for questions. 

They have the materials of the presentation. 

So details they could probably ask you about if they have 

questions about from having the report. So go right 

ahead.

Mr. Crawford: I'll be happy to do that.

Mr. Katz: Thanks. It's Chris Crawford from DOL.

DOL Program Update

Mr. Crawford: Good morning. I understand from Stu that 

Mr. Grady Calhoun will be changing the slides, so let me 

know if they're ready to go?

Mr. Calhoun: I might try something completely different 

here, because this isn't working. Let's do that.
17 

Mr. Crawford: Couldn't quite hear that.

Mr. Katz: He's just -- he's almost ready, but not quite 

ready.

Mr. Calhoun: Okay, yeah. Now I'm there.

Mr. Crawford: Great.

Mr. Katz: Okay, he's there. Okay.

Mr. Calhoun: You may not be able to see this via Skype 

though.

Mr. Crawford: Okay. Thanks for doing that for us as usual. 

All right. Let's go right to the second slide. It's a very 

short slide. I think the gist of it is we have just over $16 

billion in total compensation and medical bills paid in the 

history of the program, with 206,526 cases filed to date. 

Next slide, please. 

Mr. Calhoun: There. Go ahead.

Mr. Crawford: Some information here. We have 51,000 

plus cases referred to NIOSH for dose reconstruction, of 

which 49,500 roughly have been returned to DOL from 

NIOSH. The differences are in cases that were withdrawn 

without a dose reconstruction. There's only 1,744 cases 

currently at NIOSH by our count, 500 of which roughly 

are reworks. Next slide, please.

Mr. Calhoun: Okay.

Mr. Crawford: This one shows the number of cases with 

dose reconstructions completed and final decisions. We 

see that there's about a 35 percent acceptance rate with 

final approvals of almost 12,000 and final denials of about 

22,500. Next slide, please.

Mr. Calhoun: All right.

Mr. Crawford: We show this slide each time also. This is 

Part B cases filed. I think the most interesting thing here 

is -- the thing that needs explanation is other includes the 

beryllium sensitivity cases, chronic beryllium disease, 

chronic silicosis. 

Of the rest, 15 percent of the cases were SEC cases never 

sent to NIOSH. NIOSH got 35 percent of the cases 
18

referred to it, and another 12 percent of the cases were 

sent to NIOSH that were SEC cases, but with usually 

multiple cancers that required a dose reconstruction. We 

have a small amount, RECA cases, at nine percent. Next 

slide, please.

Mr. Calhoun: All right. 

Mr. Crawford: Top four work sites. Nevada Test Site, Y12 Plant, Hanford and Savannah River Site generating the 

greatest number of cases for the last quarter. Next slide 

please.

Mr. Calhoun: I think we went out of order there, Chris. 

Which slide are you looking for?

Mr. Crawford: Out of order?

Mr. Calhoun: Yeah.

Mr. Crawford: Which slide are we showing?

Mr. Calhoun: Well, the last one was Part B cases with a 

final decision, and the top four sites were after that so --

Mr. Crawford: Yes, yes. Sorry. Perhaps I didn't tell you to 

switch. But we've now finished Slide 7. Let's move on to 

Slide 8, which is the SEC petition sites.

Mr. Calhoun: Okay, there you go.

Mr. Crawford: So we'll be dealing with these sites today. 

Sandia National Laboratory has 4,000 cases filed at 

present, of which almost 700 have been returned already. 

We have final decisions on almost 1,900, with approvals 

on 1,262. That's Part B approvals. We have 1,162 Part E 

approvals. Often those are joint approvals.

The Area 4 Santa Susana Field Laboratory, we have about 

1,100 cases filed. 265 have been returned by NIOSH with 

a dose reconstruction. We have 536 final decisions, 259 

Part B approvals and 247 Part E approvals. 

The Idaho National Laboratory, another large site, 6,325 

cases, of which NIOSH completed a DR for almost 2,000. 

We have 2,800 final decisions, 1,000 Part B approvals, 

1,300 Part E approvals.

And finally later today, Superior Steel in Carnegie, 
19

Pennsylvania. We have 52 cases. This is an AWE of 

course. NIOSH has done a DR on 35 cases. We've had 

final decisions on 48 cases, with 19 Part B approvals and 

no Part E approvals because it's an AWE.

Next slide, please. These are standard slides, the next 

two, on DEEOIC outreach events and the Joint Outreach 

Task Group. I won't go through this in any detail because 

I think most people are quite familiar with it and it doesn't 

change.

So next slide is the Joint Outreach Task Group, and then 

let's move along to the next slide, which is the upcoming 

outreach event. We have a town hall meeting in Oak 

Ridge, Tennessee April 24th of this year. 

Next slide, please. We have another town hall meeting in 

Middle Island, New York, May 2nd, 2019. 

Next slide, and the next outreach event is the town hall 

meeting in Las Vegas, Nevada June 4th and 5th, 2019. 

That completes the presentation as such. There are more 

informative slides which will be found on the website.

I just want to say it's been a pleasure working with Stu 

and Jim since 2004 in different capacities, and I'm happy 

to see them going off to a very well-earned retirement. 

Thanks to you both. Any questions?

Mr. Katz: Thank you, Chris. Questions from Board 

Members?

Member Ziemer: Ted, this is Paul. I have a question for 

Frank and maybe I could also ask a similar question of 

Stu. But as you look back, did the government shutdown 

have any noticeable impact on the output of your 

program?

Mr. Crawford: Answering for DOL, I don't believe so. But 

DOL was fully funded, one of the agencies that were fully 

funded. We, as far as I know, didn't experience any 

slowdown.

Mr. Katz: It's the same Paul for the entire EEOICPA 

program continued to have funding. It was all -- there 

were actual appropriations for HHS and Labor.

Member Ziemer: So it didn't impact our contractors then 
20

either?

Mr. Katz: Neither contractors nor employees, right. 

Everyone was funded.

Member Ziemer: Great, okay. Thank you.

Mr. Katz: You're welcome. David.

Member Kotelchuck: Hi. My question has to do with the 

top four work sites. Maybe my memory is not good. I was 

surprised to see Nevada Test Site appearing as the top on 

this list in this iteration of these slides. Has that been the 

case and I've missed that for a while?

Mr. Crawford: Actually, I'm trying to recall myself. It is a 

very large site. I know there's a tremendous amount of 

data out there and over the years. So it doesn't surprise 

me, but I don't know if there's been a sudden surge at 

the site in cases filed.

Mr. Katz: Greg's coming up to help with this, I think.

Mr. Lewis: Yeah. This is Greg from DOE. We have noticed, 

you know, I don't know if I want to characterize it as a 

huge surge, but you know, Nevada is typically one of our 

larger sites. I'm not sure if they're always in the top four 

of claims, but they're a large site.

For whatever reason, they have seen a bit of an influx of 

claims recently. We're not really sure what to attribute 

that to, but we're adapting and fulfilling those claims. I 

don't know that I would consider it a huge surge. They 

are a large site. It's not uncommon to see them in this 

top four.

Mr. Katz: Other questions?

(No response.)

Mr. Katz: Okay then, Greg. You're already halfway up 

here. Greg Lewis from DOE, welcome. 

DOE Program Update

Mr. Lewis: While Grady's getting my presentation up, first 

I just want to echo what everyone else has said and 

congratulate Stu and Jim on their retirement, and also on 

Grady and Tim on their new roles. We look forward to 
21

working with them and we look forward to hearing from 

Stu and Jim how it is on the other side. Sounds very nice. 

I'm sure their golf game will improve, or get worse. But 

they'll be having fun either way, yeah.

And I'm going to keep this very short, but I'd be happy to 

take, you know, as many questions as you have. I know 

we're running a little behind schedule and there's a full 

agenda today. I think the one thing I was going to note, 

I'll go over our stats just a little bit, but we did see slightly 

fewer overall records requests last year compared to the 

--

Sure. So again, I'll skip through our role. I think everyone 

knows our role is to provide records to NIOSH and to the 

Department of Labor so they can adjudicate claims and 

work on projects like Special Exposure Cohorts or Site 

Exposure Matrix, things like that.

Looking at our -- so our stats. Again, we did about 16,849 

records requests last year. That's from NIOSH and DOL. 

That's down slightly. I think we were at 17,500 I think in 

the previous fiscal year, somewhere around there. So we 

are down slightly. We're not sure if that's a long-term 

trend or just a blip, but something to note.

And our on time rate was 98 percent, and we consider on 

time anything returned in under 60 days. So last year, 

last fiscal year our response rate was 98 percent on time, 

which I think is a new high for us. In fact, the previous 

fiscal year we had been much lower than usual because 

of some funding issues and a record center move over at 

Y-12, which it had a significant impact on us.

But this fiscal year, we were back up around 98 percent. 

We're very proud of that and we work very hard to get 

those claims back in under 60 days. You'll see. I just sort 

of noted a few sites that were, you know, with a 98 

percent on time rate. Most of the sites looked similar, but 

I just picked out a couple that had a particularly good 

record.

Legacy Management, zero late out of 1,300; Savannah 

River, no late claims out of 1,200 and Nevada, zero late 

out of 950 requests. And then with -- of course we're 

supporting the records research projects from NIOSH, as 

well as DOL but primarily NIOSH.
22

The one thing I wanted to note was the Savannah River 

Site. We had, you know, we talked about this probably 

the last couple of Board meetings. There had been some 

difficulty, you know, ORAU and the Board and SC&A and 

the various groups had been requesting documents and 

Savannah River had sort of been falling further and 

further behind on the classification review as the, you 

know, the volume of documents requested kind of stayed 

steady and we were falling behind.

It was becoming a problem for NIOSH and we were trying 

to figure out how to deal with it. We were able to work 

with Savannah River. They had hired a few new 

Classification reviewers. They came up with a project plan 

and started working, you know, trying to reduce this 

backlog.

I think as of a couple of months ago, we pretty much 

completely eliminated the backlog. Obviously there's new 

documents coming in, but we are -- we believe we're 

keeping up with those documents. We've eliminated that 

backlog and, you know, we hope you all have the 

documents you need to do the work you need to and 

make the decision on the SEC.

I think, you know, most of this is my standard slides. Of 

course both Chris and Stu have mentioned the upcoming 

outreach events. We'll be attending those as well. I'll just 

mention the Former Worker Medical Screening Program 

which is the other program that's run out of my office. 

I encourage anyone who is applying to the program or 

has worked at a DOE site, you know, if you haven't 

already looked into the former worker screening program, 

please do. You can also feel free to tell other folks that 

worked at the site or people you may come in contact 

with.

So with that, I think that was a very quick review. But 

again, I'd be happy to take any questions you have and 

hopefully this is getting you guys back on track a little bit.

Mr. Katz: Thanks so much. I feel a little sheepish for 

having asked you guys to cut it so short, but it's working. 

Questions from Board Members.

(No response.)
23

Mr. Katz: Or Board Members on the line for Greg?

(No response.)

Mr. Katz: All right then. So now thank you very much 

Greg, and now we have an SEC petition to address. This 

is Sandia, and we will not have a petitioner commenting 

after the presentation. But we do have a statement from, 

we expect from Senator Udall. So his staffer, after the 

presentation and discussion of the presentation, will make 

-- provide those comments. 

Mr. Giron: Excuse me Chairman?

Mr. Katz: Yes.

Mr. Giron: This is Eloy Giron. I am the petitioner from 

Sandia.

Mr. Katz: Oh okay. I was informed that you wouldn't be 

attending, but I'm happy that you are. So after the 

presentation then, you will have the opportunity to 

comment. Okay, thank you.

Mr. Giron: Thank you, yes. I'm also here with Kirk Grimes 

and [identifying information redacted].

Mr. Katz: Okay. So anyway, we'll register you in right 

after -- first NIOSH is making a presentation, and then 

they'll be some discussion from the Board, and you'll be 

up next. Thank you so much.

Mr. Giron: Thank you.

Sandia National Laboratory, SEC Petition No. 188 

Evaluation Report Addendum

Mr. Nelson: Okay, good morning everybody. My name is 

Charles Nelson. I'm going to be presenting the Sandia 

National Lab. This is Addendum No. 2 to SEC-00188. 

Okay. Originally, the Petition SEC-00188 qualified for 

evaluation on October 21st, 2011, and the petitioner 

proposed a Class for security inspectors and many other 

security folks for the period of January 1, '63 through May 

21st, 2011.

And NIOSH proposed a Class to be added based on that 

SEC Evaluation. What it doesn't say here it was actually 
24 

both SEC-00188 and 00162 where we added Classes and 

there for the -- hold on. I think we skipped a slide here. 

Okay. I didn't touch a button but it went a slide forward.

Okay. So it was a Class added for all personnel that 

worked in any area of Sandia National Lab in 

Albuquerque, New Mexico for the period of January 1, '49 

through December 31st, 1994. 

We'll go to the third slide now. Okay. The basis for this 

Class from '49 to '94 was due to insufficient monitoring 

data and information to reconstruct the internal doses for 

that period of time. We were lacking some program 

monitoring documentation, some monitoring data and we 

did in those Evaluation Reports conclude that we could 

reconstruct external doses including medical X-rays 

during the period of '49 through 2011.

So that was covered in SEC-00188. We've looked at our 

portions of the external dose evaluations and we have the 

same conclusions that we can reconstruct dose. So we 

haven't found anything that contradicts that. 

Okay, Slide 4. Summary of the SEC-00188 addendum. So 

we had an addendum last year July 26, 2018, whereas we 

added a couple of years onto the SEC. Again, it was all 

personnel that worked at Sandia National Lab 

Albuquerque from January 1, '95 to December 31st, 

1996. 

And again, the basis here, they were developing an 

internal monitoring program. There was many changes. 

They were going from bioassays over to breathing zone 

air sampling, and we recognized that and we also saw a 

lot of procedures being developed and changes being 

made.

It appeared to us that a lot of these things didn't get 

totally formalized until '96 or '97, so we did add those two 

years, '95 and 1996. So the focus of this presentation 

then is SEC-00188 Addendum 2. So that's the remaining 

years that we're evaluating, from January 1, 1997 

through May 21st, 2011.

And again, we're going to look at the suitability of the 

monitoring program. We did look at it, and the data 

deficiency and if you read the Evaluation Report, we did 

a pretty good write-up, I believe, on the security guard's 
25

concerns.

Okay. So yeah, we looked at several data sources during 

this evaluation. There were 21 people or actually 17 

people interviewed, with 21 interviews themselves. Since 

the last addendum, we did do a site data capture to 

capture some additional breathing zone or personal air 

samples.

We had four written data capture requests and since SEC00188 in 2012, we've also captured over 900 more 

documents relevant to this period. So that gives us a total 

of about 5,500 total documents in our Site Research 

Database. We look at internal procedures and memos, 10 

CFR 835 compliance and self-assessments. We looked at 

facility and process information, radiation work permits, 

incident reports, air monitoring and some 

internal/external audits.

We also looked at the site's reporting system that they 

used for reporting dose. It is called WebDose, and they 

created us an extract from that and we went through all 

of that as well. Looked at internal/external monitoring 

records and really the focus of this presentation, we really 

focused on breathing zone monitoring and air sample 

records, and a mechanism for tracking DAC hours.

So what do we have? We have available internal urine 

bioassays. This is straight out of WebDose. So from '97 

to 2011, we're talking about a 15 year period. There were 

2,020 non-tritium urines, and if you look at the next 

column over it's persons sampled. If you add those up, 

they're not going to total 317 because some people were 

sampled year after year. The tritium sample results were 

7,209 with 362 people. 

Okay. Also, internal monitoring data. We had whole body 

counts and thyroid counts, 1,115 on 207 people. 

Breathing zone samples. We captured these. Most of 

these came from the internal dosimetry group. Any time 

they wanted the internal dosimetry group to evaluate a 

breathing zone air sample, determine if there was any 

actions and perhaps maybe even a need for bioassay, 

they were sent over to the internal monitoring group.

So we believe this to be a good catch, because we believe 

these to be the highest results. If you look at the number, 
26

it actually says -- the title of the slides is "data sheets," 

and over there it says "results." It's really BZ sheets. So 

it's sheets of data and we'll see later that that total 

number of BZs is actually about 4,400 that we have, our 

breathing zone samples.

Okay. So as an overview of their monitoring program, as 

I've mentioned before, they shifted their internal 

monitoring program from reliance of the use of bioassay 

to the use of breathing zone sampling. So that was the 

primary method of monitoring internal exposures to 

individuals.

It was the Sandia's position that no individual was likely 

to receive internal exposures of 100 millirem. Having 

stated that in their Technical Basis Document and it was 

also concluded in some external assessments performed 

in 1996 and 1999 by a pretty renowned health physicist.

They used a confirmatory bioassay monitoring program, 

meaning that was their mechanism to see if the controls 

in place were adequate. But the primary method again is 

breathing zone air sampling.

Okay. In that change, like I mentioned before, they were 

doing bioassays. They moved to personal air sampling, 

and that was a change to the program. They had methods 

for dose tracking that and they also had requirements for 

recordkeeping and retention on those.

We looked at some evidence of the implementation of 

this. There's a couple of memos I wanted to highlight, 

because they kind of give you a good discussion or 

indication of what was going on in the field. The first one 

was that on February 3rd, 1998, at the Rad and Mixed 

Waste Management Facility, they had a safety committee 

discussion and the discussion surrounded the need for 

routine bioassay.

The discussion was well, rad techs are all on routine 

bioassay. If there's any trends that indicate internal 

doses, those people at the job site would be asked to 

submit special bioassays to determine the scope of the 

problem. In other words, if they see trends and there's an 

upset condition, then they would require some bioassays. 

Those things such as elevated air concentrations increase 

surface contamination. Then they also went on to discuss 
27

that specific job-specific RWPs [radiation work permits]

are going to require some bioassays for other individuals. 

A lot of times the waste handlers, not only the RCTs but 

they were also required to leave bioassay. Certainly, if 

they were working with tritium they would leave bioassay.

Another memo a couple of years after that, really three 

years on May 30th, 2001. It was documentation on the 

routine bioassays for RCTs in Technical Area V. 

It went on to say that the current schedule calls for annual 

whole body counts and semi-annual urine for uranium, 

thorium, americium and plutonium, and again they said 

the bioassay program is confirmatory in nature. In other 

words, it confirms that the results and effectiveness of the 

contamination control and other protection activities are 

adequate. 

Then they went on to say, you know, they were discussing 

the fact that RCTs were on the routine monitoring 

program, and they said because they were present at all 

work activities there's a possibility -- where there was a 

possibility of meaningful intakes, their bioassays serves 

as a good proxy indicator for other personnel.

We looked at captured RWPs in planning documents, and 

we looked for -- we wanted to see what the airborne 

levels were in the areas, whether they required 

respiratory protection and BZ monitoring and bioassay. 

What we found in those RWPs, we saw many of the areas 

that required respiratory protection, and we found 

breathing zone sampling results tied to those RWPs.

Okay. So this next slide is an example of an upset 

condition that might lead to bioassay. So we, for instance, 

there was a puncture wound that led to a bioassay 

sample, unusual odor and you'll notice later down there 

was a -- later down in the slide, there was a few instances 

of elevated breathing zone air samplers that resulted in 

bioassays and in one instance a whole body count. So we 

found some indications of that.

So what did we do? We looked at the breathing zone data 

that we had on hand, and we looked at the activities on 

the filter, and from that activity we calculated committed 

dose equivalent based on the stochastic ALI [annual limits 

on intake] for each of the limiting radionuclides. 
28

We took that data then and we'll go to the next slide here, 

and we looked at the individual work activities and the 

work days, and so if you're looking at this slide, these 

were focusing on this one on the gross alpha activity. So 

the total for those years is 4,400 BZ results that we do 

have.

And based on that data there, we developed a graph and 

determined what the median dose for an event, an event 

characterized by a work activity or working in a day. What 

we found out was that about a half a millirem per event. 

Just to note, this right here is the actually the breathing 

zone, the lapel samplers, the filter activity outside, if an 

individual is wearing a respirator or in many cases in 

some of the activities they wear bubble suits.

These results aren't corrected for, you know, that 

respiratory protection or any other PPE provided. This is 

the gross data as if somebody were standing right beside 

them, and they weren't in all this PPE. 

Member Richardson: But let me confirm. These are -- this 

is -- these are the results for a calendar year that you 

plotted?

Mr. Nelson: Those are the total results, the 4,400 data 

results that we do have.

Member Richardson: So for example the -- this is the 

distribution over all time, all workers, all breathing 

samples and this is what you're plotting?

Mr. Nelson: Yes, correct.

Member Richardson: Okay.

Mr. Nelson: All right. We did the same thing for gross beta 

and gamma, and in this case there was the same 4,400 

samples, the same work activities and we got a median 

dose of .001 millirems. So very low, and again this is with 

no respiratory protection, as if somebody were working 

alongside of these other individuals. In which case most 

of these people were in respiratory protection for this data 

that we do have. Certainly all the upper tail.

Then we did the same thing on some tritium BZ results. 

So this is particulate. So we assume that to be insoluble 

stable metal tritides for that, and the results of that was 
29

0.007 millirem as a median dose, so quite low.

So I mentioned before WebDose. That's their reporting 

mechanism to say how much dose that the site received 

over this 15 years. I'll draw your attention to the far right 

column, the total. There was a total of 77 millirem 

assigned for all individuals for all years, internal dose.

I do have a couple of typos there under urine and thyroid. 

We had to put zeros in this and somehow zeros got down 

there. The urine should have been, it looks like 42 and 

the thyroid should have been five millirem. So that's the 

dose of record.

So feasibility of dose reconstruction. Now based on our 

review of the radioactive material use at Sandia and the 

associated radiation protection plan, NIOSH has 

concluded that intakes for unmonitored workers who have 

access to the controlled area were unlikely to have 

resulted in a committed effective dose equivalent of 0.1 

rem or 100 millirem per year.

And that's not based on a 10 CFR 835 requirement, but 

it's based on a review of our exposure monitoring records, 

with employees involved in radiological activities we feel 

with the highest risk at the site during the period that we 

evaluated.

So as I mentioned before, the internal monitoring records 

for individuals are available within WebDose. And internal 

doses for unmonitored workers or individuals monitored 

solely by breathing zone sample can be bounded using 

this 100 millirem presumptive exposure.

So as mentioned before, and this is kind of a wrap-up 

conclusion summary for feasibility. The dose, assigned 

dose, the total assigned dose committed effective dose 

equivalent for all employees for the 15 year period, as I 

mentioned earlier, is 77 millirem.

Looking at all the breathing zone, bioassay data that we 

do have, the median quantity of radioactive material 

available for uptake to individuals, as I mentioned before, 

are located alongside personnel performing high risk 

activities would correspond to an internal dose of 0.5 

millirem per work event.

And again, that's assuming they're working right next to 
30

the workers. They have all this type of personal protective 

equipment and in most cases respiratory protection. And 

if you look at that 0.5 millirem, it would take 200 events 

in a year to get to 100 millirem in a year.

Then as previously -- as I mentioned earlier, as previously 

identified in SEC-00188 Evaluation Report in 2012, and 

with SEC-00162 in 2011, NIOSH finds it feasible to 

reconstruct medical and principal external doses, 

including exposures to beta, gamma and neutron 

radiation at Sandia National Lab Albuquerque with 

sufficient accuracy.

And as previously identified in SEC-00188 Evaluation 

Report, the principal sources for this internal radiation for 

members of the proposed Class included exposures to 

plutonium, tritium, uranium, americium, and fission and 

activation products. So based upon the analysis of the 

available resources, NIOSH finds no part of this Class 

under evaluation which it cannot estimate radiation doses 

with sufficient accuracy. 

So in conclusion, for internal all radionuclides, we feel 

dose reconstruction is feasible and the external dose beta, 

gamma, neutron and occupational medical X-rays, we feel 

radiation dose reconstruction is feasible and we see no 

health endangerment.

Mr. Katz: Thank you Chuck for a nice, clear presentation. 

Public Participant: Hello Ted.

Mr. Katz: Hello. That's Michele?

Public Participant: It's really difficult to hear. During the 

presentation, it was cutting in and out.

Mr. Katz: Is that Michele or Loretta or who am I speaking 

with?

Public Participant: I'm a member of the public.

Mr. Katz: Okay, okay. Because you are super-clear, so 

I'm glad we can hear you well. But okay. So people, 

everyone please speak with your mouths close to the mic 

to help with that audio issue. So now I have questions 

from the Board Members. Josie.
31

Member Beach: I have a couple of questions. First one on 

your Slide 14. You talk about the RCTs being on a routine 

bioassay program. My understanding with RCTs, with my 

work experience, is they generally stand back while the 

workers are kind of hands-on. Any other routine 

bioassays besides the RCTs?

Mr. Nelson: Yes. A lot of the material handlers were also 

on the routine bioassays.

Mr. Katz: Chuck, can you speak into the mic for us?

Mr. Nelson: Yeah. Also, a lot, many of the material 

handlers are on routine bioassays, and at many times the 

radiation work permit would specify certain workers to do 

it based on the hazards present.

Member Beach: Okay, and I have two other questions. 

Can I ask those?

Mr. Katz: Yes, of course.

Member Beach: Okay. On talking about the mixed waste 

handling facility, it's my understanding that in '88, looking 

at the Evaluation Report, that they -- it took them from 

'88 to '95 to build the new facility?

Mr. Nelson: Correct.

Member Beach: Where was waste being stored in the 

interim?

Mr. Nelson: I'm not really sure about that, to be honest 

with you. That facility was made to repackage waste and 

get it ready for burial or shipment. 

Member Beach: It wasn't until '95 that it went online --

Mr. Nelson: Right, that's correct.

Member Beach: So that's why I was kind of wondering 

where all that stuff was.

Mr. Nelson: Yeah. There was a landfill, so I don't know if 

material was stored there. I don't have that knowledge.

Member Beach: Okay, then lastly --

Mr. Katz: Tim, were you trying to respond? One sec.
32

Dr. Taulbee: Yeah. I just wanted to point out that '88 to 

'95 is part of the current SEC.

Member Beach: Right, okay.

Mr. Nelson: Okay, thanks Tim.

Member Beach: I guess this is after. Thank you, yeah. So 

then the other one, it talks about the internal 

dosimetrists, that the program participation was by 

individual department managers. It doesn't really give a 

time frame of what type, what time frame that might have 

been. That was also in the Evaluation Report under 7.1. I 

don't -- right here.

I was just wondering. It said it changed at some point, 

but it didn't really say when.

Mr. Nelson: Okay. What you're referring to is prior to 

about 1995, that individual managers would determine 

who were assigned bioassay and so forth. I think some of 

that still did happen, and my understanding is that, you 

know, there was consultation with the radiological 

program leads at the facilities.

Member Beach: So in the '97 to 2011 time frame, you 

think that was still potentially going on or --

Mr. Nelson: I would perhaps. I'm not 100 percent sure 

about that, other than I know that radiological program, 

they all had radiological experts in their areas, and they 

oversaw the program when they communicated with the 

internal dosimetry group. It was much more formalized 

as time went forth, and we saw a ton more procedures 

beginning in 1995 as they were trying to implement 10 

CFR 835 requirements and really beefing up their 

program.

Mr. Katz: Brad.

Member Clawson: I was just looking at your sampling. In 

2003 and 2011, you have zeros.

Mr. Nelson: We have no breathing zone samples for those 

years. That's not to say they didn't occur. This is just what 

we have captured ourselves. So we have captured 4,400 

breathing zone samples and the majority of those are the 

ones that were sent over to the internal dosimetry group.
33

Member Clawson: But so you're not saying that there 

weren't --

Mr. Nelson: No. This isn't inclusive of all breathing zone 

samples, absolutely not.

Member Clawson: Okay, thank you.

Mr. Katz: Other Board Member questions in the room? 

David.

Member Richardson: Thank you for the presentation, and 

it's really interesting. The part that got me thinking was 

this description of a philosophical change in the internal 

dosimetry program, from a program that was aimed at 

estimating intakes, internal doses to what they describe 

as a program which is with an emphasis on radiation 

protection.

And the bioassay program really serving in a confirmatory 

role that they were in compliance with their radiation 

protection objectives. That makes complete sense from a 

worker protection standpoint. But I think it poses 

challenges for a dose reconstruction program, because 

it's not targeting the same, let's say, latent variable 

anymore, the unknown construct, the dose which actually 

the worker had intake.

You pointed to some of the challenges there. They may 

be wearing a respirator. They may have -- it may have 

worked correctly, it may not. There's many more 

uncertainties at that point.

Mr. Nelson: Yeah. The use of breathing zone air samplers 

though actually is a great mechanism for monitoring dose 

in a work area. It would have indicated an upset 

condition. It would show any activity on the filter outside 

of that, and it would be actually a really good indicator.

Some radionuclides that you really do need to use 

breathing zone samplers because you will not see at the 

level that you need to see with bioassay.

Member Richardson: Again, I'm not questioning that.

Mr. Nelson: Okay.

Member Richardson: I'm talking about this philosophical 
34

change from what they were trying to estimate, the 

implications for a compensation program which wants to 

estimate the dose that was taken in for a subject. It 

seems like I'm a little bit hung up on that, just on that 

change.

You could -- you sort of -- you're receiving a signal which 

is indicating compliance, and they've got some action 

level that they would like to comply with. 

One other question was you described what they called 

"field implementation," which were triggers for them to 

conduct bioassays. Those were described in terms of 

trends. I'm having a hard time reading, I'm sorry. But 

they say a trending contamination, I think it's like a trend 

over time or other sorts of trend indications.

They don't really describe what those are, and the 

examples which are provided don't look to me like trends. 

They seem like incident reports basically, where there 

was a puncture wound. 

Mr. Nelson: Yeah that --

Member Richardson: So it doesn't suggest a trend overall, 

over time in a work area or how you would -- how that 

signal would be flagged. It's not clear if it's a trend within 

subject or over the workforce. Could you clarify how that's 

happening?

Mr. Nelson: Yeah. I think what you're referring to as a 

trend was identified on Slide 14, am I correct?

Member Richardson: Yep.

Mr. Nelson: Okay. That was actually quotes from the site 

facility in a safety committee discussion. They were 

basically saying if there were trends that developed such 

as elevated airborne levels, increasing contamination 

levels, then special bioassay would be requested.

So we were just quoting that as something that we saw 

that provided us some evidence that, you know, what we 

were reading we were finding in some memos that were 

documenting, you know, the internal dose monitoring 

program and how it worked.

Member Richardson: So are there written procedures 
35

other than incidents for, that would target or activate a 

bioassay program?

Mr. Nelson: Yes.

Member Richardson: And those are different than these, 

a trend developing indicating internal doses?

Mr. Nelson: It would be a similar type wording to that. 

That's not out of a procedure. That's out of a memo from 

a meeting minutes.

Member Richardson: And are those procedures, are they 

within subject trends or are they workforce trends?

Mr. Nelson: They're more programmatic documentation 

provided by the rad protection program. 

Member Richardson: So on the aggregate level, not on 

the individual levels.

Mr. Nelson: I'm not 100 percent sure I'm following you at 

this point then. 

Member Richardson: I mean you could, you could have -

- you could have repeated samples on a person and you 

could say oh, it looks like levels are going up for that 

person. Or you could say over time, you're seeing more 

evidence of contamination in an area. Those would --

Mr. Nelson: I guess an example might be, you see a work 

area and actually I think you might have mentioned it 

there. You're seeing increased contamination levels. 

Certainly if they're not expecting that something they 

might do is say okay, we're seeing these increased levels. 

We didn't really anticipate them, and so one of the 

indicators that we saw that sometimes had happened and 

they sent somebody for bioassay or maybe the work crew 

for bioassay.

Member Richardson: Okay.

Mr. Katz: Other questions from Board Members and Board 

Members on the line as well?

Member Roessler: Ted, this is Gen.

Mr. Katz: Hi Gen. Yeah, you're perfectly clear, thanks.
36

Member Roessler: The audio on my phone and I actually 

switched phones, is actually okay, I can hear people on 

the line but I agree with the member of the public. It's 

difficult, was difficult to hear the person at the podium. I 

could hear Josie and Brad. I think the person at the 

podium could speak into the mic and be consistent about 

it.

Mr. Nelson: How's this Josie? Is that any better? Oh Gen, 

sorry.

Member Roessler: A little better.

Mr. Nelson: A little better? I'm pretty close right now so -

-

Member Roessler: Yeah, I don't know. The mic seems 

different than the others in the room.

Mr. Nelson: Maybe we need some work on this mic then. 

I wonder if we can move that one up here.

Member Roessler: Okay, thanks. I don't have any 

questions though.

Mr. Katz: Oh okay, okay. Thanks Gen. Other questions 

from Board Members on the line? 

Member Richardson: Could I just ask one last question? 

What's the decision currently for using what looks like the 

median of a log normal distribution, as opposed to some 

other quantile of the distribution?

Mr. Nelson: I'm going to let Mr. Taulbee answer that one, 

because I know he's worked with that quite a bit with 

coworker studies.

Dr. Taulbee: I'm going to turn this on. Is it on? Okay. At 

this time, I mean we -- as far as using geometric mean 

or the 95th percentile, in this particular case this is a low 

dose facility. So what we're trying to demonstrate is that 

we can bound the dose here. So we're just putting out the 

median for that purpose.

So median would be something you would assign to 

people who are not routinely exposed, whereas people 

who are routinely or have a potential for exposure, that's 

where we tend to go to the 95th percentile. So these data 
37

were just to show that this really is a very low dose 

facility, compared to some of the other sites we deal with.

Mr. Katz: Other questions from Board Members? Jim.

Member Lockey: David, I wanted to pursue what you 

were asking about exposure reconstruction and dose. If 

you have rigorous exposure data, breathing zone data, 

can you not use that to inform what a person's dose is? I 

mean, I do that routinely in the studies I do, so I wasn't 

sure I understood where you were going with that.

Member Richardson: I -- and, again, I said I just think 

that there was a change and it makes it more difficult to 

estimate the dose, than if you actually have a biological 

sample of an intake. So they went from a program of 

sampling to taking bioassays, to ambient monitoring, you 

know, near the breathing zone.

Member Lockey: Yeah, but if you have good ambient 

monitoring data.

Member Richardson: It doesn't make it impossible, I 

agree. You just, there's a whole other set of things that 

are related, right, related to breathing rates, lung 

capacity, the use of respiratory protection between the 

sampler and the mouth and nose. All those become --

Member Lockey: All that you'd have to take under 

advisement. Yeah, I would agree with that.

Member Richardson: Those are large factors for some of 

those respiratory protection factors.

Member Lockey: Then your dose would be even reduced 

in relationship to the exposure levels.

Member Richardson: Yeah.

Member Lockey: Right, so it would --

Member Richardson: Assuming that the person's wearing 

the respiratory protection. So we have --

Member Lockey: If they weren't, you would have an 

exposure level that would be reflective of what most likely 

that dose would be. So in anything, if they're wearing 

respiratory protection their doses would be less rather 
38

than higher.

Mr. Katz: LaVon.

Mr. Rutherford: I think the key here is that if we are 

assuming --

Mr. Katz: Is that mic on? Wait, hold on. Your mic's not on.

Mr. Rutherford: Yeah. I think the key here is we assume 

no respiratory protection at all.

Member Richardson: Yeah, well I understand that. Again, 

all I was saying is there was a change, and the change is 

towards trying to estimate something like compliance, 

and now we're going to try and back calculate from that 

to get to what we would have had had we had a bioassay 

program.

Mr. Katz: Other questions from Board Members?

Sure, Brad. I think your mic's not on yet.

Member Clawson: Okay, I would just -- when you're 

calling these BZ zones, these are actually breathing 

zones. This is lapel samplers --

Mr. Nelson: Yeah. For the most part it's lapel samples. 

Now there may be some air samplers in the area that they 

call the breathing zone, but to my knowledge, from what 

we saw, they were lapel samples.

Member Clawson: Okay, thank you.

Mr. Katz: Thanks, Brad. Other questions from Board 

Members?

(No response.)

Mr. Katz: Okay. Well so I heard we do have the SEC 

petitioner on the line, and this is an opportunity now for 

you. If you'd please introduce yourself before you get 

started clearly, so that we get your name and all, and 

then you have ten minutes to summarize your comments.

Mr. Giron: Chairman, good morning. My name is Eloy 

Giron. Can you hear me?

Mr. Katz: Yes. You're pretty clear, thank you.
39

Mr. Giron: I'm also here with Kirk Grimes and 

[identifying information redacted]. Good 

morning Members of the Board, and I had something 

summarized here to write up right away, but the first 

thing I want to say is those questions from the Board were 

spot on right now. So you guys have been able to read 

that report, and I really thank you for those questions. 

I have to disagree with this report. We just received this 

report last Thursday. I haven't had --

Male Participant: Friday.

Mr. Giron: Friday. We haven't had that much time to go 

over this. I feel real bad. I wish we had been able to work 

a lot closer with Chuck Nelson on this. I had no -- no 

interactions at all on this. We can beat this horse to death, 

but I'll just go straight to some of the bullets on this.

On your Addendum No. 2, on your third bullet, it says 

address security guard's monitoring concerns. This report 

does not address bullet number three. Nowhere in the 

report does it mention our concerns. We expressly told 

NIOSH that none of our officers were ever put on internal 

or personal air monitoring program.

Mr. Nelson just a little bit ago reported that all workers 

wear PPE, bubble suits, respirators, and this data was 

provided to the Advisory Board. With our security 

posture, nowhere -- with our security -- nowhere and at 

no times were we ever -- wore bubble suits or respirators. 

Mr. Nelson reported that it would take 200 events in a 

year to receive a certain dose, I don't remember that. But 

that was an attainable goal within six months, within four, 

five, six months with most of our officers. So we dispute 

-- I can go through this report line by line and dispute a 

bunch of it, just because the way our security posture was 

set up, and it appears the reporting from Sandia to Chuck 

Nelson was -- the reporting from Sandia to Chuck Nelson 

under 853, we were all doing work a certain way with PPE, 

respirators, bubble suits. But none of our officers were 

working in that capacity. Some of the information from 

2003 and another year were not provided. So I mean how 

can we do honest and credible dose reconstruction?

Again, I want to thank those Members of the Board that 
40

went over this report. It means a lot to me because I was 

running out of steam, banging my head against the wall. 

When you guys asked those questions, it put wind back 

in my sails. So thank you guys for asking those questions. 

I know I'm all over the map right now, but we've 

requested to be involved in this process with all the 

players, and we have not -- I mean none of us, not --

none of us in this room have been involved. Again, we 

received this report last week. 

I mean I don't know how many pages it is, it's a bunch of 

them, but we barely had enough time to go over this, and 

it makes us look like we're not doing or being involved, 

engaged in this, but we really want to be engaged in this. 

That's about as much as I have right now. Thank you, 

Chairman.

Mr. Katz: Thank you for your comments and --

Mr. Giron: Also, I think there may be some more in this 

room. I haven't looked at it, but they might want to 

engage also in this. Kirk Grimes and [identifying 

information redacted] are in here also. 

Mr. Grimes: Mr. Chairman?

Mr. Katz: Yes. Please, are you Kirk Grimes?

Mr. Grimes: Yes. Kirk Grimes. I'm president of the 

Security Police Association. Okay, a couple of things. It 

was stated -- I believe I heard Chuck say a while ago --

it was stated the new philosophical change that took place 

that was implemented in 1997. I think there's an 

assumption that's being made that because of a 

philosophical change there that the program became 

robust overnight.

We actually have -- it took us a month -- it took us a 

month to get it, but we actually have information that we 

got earlier this week, sir, where we know for sure that in 

1997, '98 and '99, there were still incidences going on 

here at the labs, at least in those three years, where 835 

was not being followed.

Sandia was actually being cited and receiving penalties 

because of not -- for being out of compliance with 835, 

okay. That information, the information we do have is 
41

public record information we're willing to -- we'll check, 

but we should be able to be willing to share, okay.

There's some information we can't because it's protected 

information the Laboratory is protecting. But the vast 

majority of the information we do have now. We received 

it Monday of this week, and the reason we were asking 

for that information is because those are the time frames 

that we knew for sure that there had been some 

incidences that took place, where Sandia had been cited 

and fined for.

Like I said, it took us a month to be able to get it. We 

were trying to get it earlier. That's part of it right there.

The second thing is it's taken a long time for this report 

to be put together, and we would like to have ample time 

to be able to respond to it. So what we would like -- we 

would like to know who we need to contact in writing, how 

to contact them so that we can submit our response in 

writing, because we would like to have time to go through 

this report and respond to it appropriately, 

comprehensively, and also concisely, sir.

Mr. Katz: Okay. So are you finished, Kirk?

Mr. Grimes: Yes. The reason we want to send it to the 

Board because we'd like for the Board Members to be able 

to see that --

Mr. Katz: No, absolutely. We understand. This report 

came out very late, but this was on the agenda, and we 

wanted to get this presentation out. This is the beginning 

of our process at this point with the Board, since they've 

just received this report not much before you.

But so in terms of contacting NIOSH, I think you have an 

SEC petitioner, Josh Kinman. Your petitioner will have 

contact information for him and certainly any information 

you have that you want to provide in response to this 

report absolutely provide to Josh. He can direct you.

If you need conversations with the HPs involved, Chuck 

or other, I think Josh can make arrangements for that as 

well. So we're happy for you to be engaged absolutely, 

and please you can follow through that way. You're 

welcome.
42

Mr. Grimes: Appreciate it. Thank you, sir.

Mr. Katz: Sure thing, sure thing. Before -- well unless 

Board Members have questions for the petitioner, we 

need to go on to -- we have comments from Senator 

Udall's staff person. So if you have questions for the 

petitioner, go ahead. But -- no. Josie? Okay, all right.

Member Clawson: I do.

Mr. Katz: Oh wait. Brad, go ahead.

Member Clawson: I just want to make sure the petitioners 

realize that many of the Board Members also have 

security clearances. So any of those that can't be 

discussed in public, if we know about it then we can take 

care of that.

Mr. Katz: Yeah, absolutely. All right then. So --

Mr. Giron: Chairman, this is Eloy Giron again. We could 

not hear that question.

Mr. Katz: Okay. So let me just summarize what Brad's 

just said. Our Board Members, a number of our Board 

Members have security clearances, as well as the staff, 

the staff that support the Board independently of the 

NIOSH program also have clearances.

So it's not an issue with them being able to see Classified 

information and so on, that might be germane to this 

evaluation. So just -- just wanted to reassure you of that. 

Thanks, Brad.

Mr. Giron: Thank you.

Mr. Katz: So now Senator Udall has a statement, I 

believe. Senator's staff person Michele, are you on the 

line?

Ms. Jacquez-Ortiz: Yes, yes. Thank you. Can you hear me 

okay, Ted?

Mr. Katz: Yeah. You're very clear, and if you would just 

introduce yourself, and then take it away.

Ms. Jacquez-Ortiz: Well first, Ted, I want to thank you for 

all of your information and your really focused efforts to 

make sure that we're in the loop and the questions that -
43

- the many questions you've had to answer from our 

office. You've been extraordinarily helpful, so thank you 

for that.

I do want to reiterate, there are significant -- almost to 

the point where I think the public is a bit at a 

disadvantage. There are significant audio issues 

associated with this call. That last question from Brad is 

a beautiful example. 

There wasn't even one word that came out just from our 

end that we could hear, and that's been happening 

throughout Chuck's presentation. It's almost as if their 

microphone is muffled and every fifth word goes into 

silence for about three or four seconds, and it's literally 

impossible to make heads or tails out of what's stated.

So I don't know if that can be corrected for the rest of the 

call. But just on behalf of the public that's engaging by 

telephone, certainly out here in New Mexico the 

petitioners, I think, this information, this type of a 

presentation is so important for them to be able to hear. 

There are not resources to go out to the East Coast for 

this meeting. So I do hope that there is something that 

can be done to address that. And I apologize for having 

to point that out, but it's significant audio problems. 

I am grateful that you all can hear me. I'm going to very 

quickly read a statement into the record on behalf of 

United States Senator Tom Udall.

Thank you, Members of the Advisory Board on Radiation 

and Worker Health, for the opportunity to submit a 

statement into the record. In addition to some of the 

concerns the petitioner just shared, I note that petitioners 

and my office are still waiting for information that NIOSH 

agreed to provide us during the December 2017 Advisory 

Board meeting, information necessary to Sandia National 

Laboratory's SEC petition.

It's difficult for petitioners to adequately make its case 

before the Advisory Board if NIOSH does not provide 

relevant information and under-communicates. Last fall, 

NIOSH recommended and the Advisory Board approved 

an addendum to the SEC through December 31st, 1996. 

A number of questions were raised by petitioners and in 

Work Group meetings, and NIOSH was tasked with 
44

responding to these questions.

The report presented today attempts to answer some of 

the questions, but also firmly concludes that the petition 

should not be extended past the 1996 date. However, 

petitioners have shared with my office SNL's noncompliance and federal oversight reports with dates well 

past 1996.

A May 2005 report by the U.S. Department of Energy 

Office of Independent Oversight identified systemic safety 

deficiencies at SNL and pointed out that for many 

deficiencies, limited progress has been made or corrective 

actions have not been effective in addressing the root 

causes and preventing recurrences of deficiencies.

As a result, a number of aspects of worker safety are still 

not adequate to provide a level of assurance consistent 

with DOE expectations. The injury and illness rates at SNL 

are among the highest of the 27 DOE contractors 

performing research-related activities. That's a direct 

quote from that 2005 report.

It's not clear how NIOSH can conclude that it's able to 

accurately reconstruct dose past 1996, given the 

systemic problems identified by the DOE in 2005. 

Petitioners just received the NIOSH report a week ago, 

and they deserve the right to sufficiently review and 

respond to it, and for the Advisory Board to consider 

petitioners' response before reaching a final decision on 

the SNL SEC petition. 

Thank you for your service on the Advisory Board and for 

considering my statement. Tom Udall, United States 

Senator.

That's it, Ted.

Mr. Katz: Thank you very much, Michele for those 

comments from the Senator and also -- and if you would 

email those to me, that would be great, so I can make 

sure that they get recorded correctly.

Ms. Jacquez-Ortiz: Yes, yes and I apologize for not getting 

it to you. We were -- it was being edited up until last 

night, but I will email it to you.

Mr. Katz: No, no. It's no trouble, no trouble. There's 
45

plenty of time for that. So no trouble. And thank you 

about the audio issue. We've heard of that a couple of 

times this morning. It is the mic, and I think it is just a 

matter of the speaker being close to the mic in all these 

cases. But so I think the machinery actually is okay. But 

we'll check on that with the next presentation.

But so at this point, Board Members, we have a petition 

that's been presented, an evaluation that's been 

presented, and we've had some dialogue about the 

comments and where do we go from here?

Member Beach: Can we task SC&A to review this 

Evaluation Report and --

Mr. Katz: Yes, yeah, and I already asked Joe Fitzgerald 

from SC&A to familiarize himself, so that we'd be -- have 

a good head start in getting to that, so because I expected 

we would want to have that as a next step. 

We do also have a Work Group, and I would just mention 

also with the Work Group, if we have -- if we have 

Classified issues and we need an additional Board Member 

to help with reviewing Classified, we can take care of that 

in real time as we see what we're dealing with in terms of 

information. But SC&A can consider itself so tasked.

I don't know if there are any specifics you want to put 

together with just the general tasking to evaluate the 

supplement, the addendum, but if there aren't, then go 

ahead. Andy.

Member Anderson: Well, I would -- I guess the only thing 

I would add would be if they could specifically focus on -

- I would have the focus or at least some mention on the 

group of the security guards issue, specifically where the 

data here is really generically for everybody, and again 

looking at the initial document review I see there's 

internal data was only four percent on some of the 

claimants. So I think it would be useful to take a look at 

some of that.

Member Beach: Can I add one thing? It might be useful 

for us to pick out some interviewees as well. That may be 

helpful. Just to keep that in mind.

Mr. Katz: Okay. Any other comments? How about the 

Board --
46

Public Participant: Hello, Ted? Hello, Ted?

Mr. Katz: Yes.

Public Participant: This is a member of the public. I think 

it is a mechanical issue. It keeps, like Michele said, it 

keeps going in and out, and it's -- can't hear a thing.

Mr. Katz: So you mean you can't hear me or --

Public Participant: I can hear you, but I can't hear anyone 

else in the room. I can hear them, and then it blocks out.

Mr. Katz: Did you -- so Andy, who just spoke, Henry 

Anderson, did you have a problem hearing him?

Public Participant: Yes. He was in and out.

Mr. Katz: Okay. So I'm just -- we have a technician in the 

room, and he's going to work on that then. Thank you. 

Thanks for telling us. Okay. Do we have more comments 

from Board Members?

Member Kotelchuck: Yeah, Dave Kotelchuck. Did you, can 

you --

Male Participant: Ted.

Member Kotelchuck: Can you report to them what Henry 

asked because it was an important question.

Mr. Katz: Yeah. So Dr. Anderson requested that there be 

a specific focus on the petitioner group, the security folks, 

their experience since they have sort of a unique role and 

experiences at the site compared to other workers, and 

SC&A will do that. We'll look with a focus as they would 

normally, I think, on that group.

Member Ziemer: Ted, this is Paul. I didn't have any 

problem hearing Henry's remarks. I'm wondering if some 

of this is generally transmission of phone calls anyway 

because I didn't have any breakup in what I heard Henry 

saying.

Mr. Katz: Okay. Did you earlier though? Did you have 

difficulty also? Well Gen did with hearing Chuck, or was 

that also --

Member Ziemer: I didn't have any trouble hearing Chuck, 
47

although his volume was down from what others were in 

there. I think that's a closeness to the mic issue.

Mr. Katz: Okay, yeah.

Member Ziemer: The breaking up of things, that may be 

-- and I'm on a cell phone. It may be the carrier issue. 

Sometimes we have that, sometimes we don't just on 

regular calls. But so far I haven't had any problems this 

morning.

Mr. Katz: Right. Thanks for raising that point. For 

everyone who is on the line, I mean do recognize as well 

it's a sort of two-to-tango issue with audio and connecting 

by phone. So sometimes people are on speaker phone 

and that doesn't work so well, or some people's cell 

phones aren't so great.

So, but we will do the best we can here to make sure that 

we're improving the quality and certainly having people 

speak closer to the mic. Thank you. 

Member Field: Ted, this is Bill. I agree with what Paul said. 

I'm hearing things fairly well.

Mr. Katz: Okay, thank you, Bill, and you're clear too, 

super.

Member Ziemer: Ted, this is Paul again. Can you give us 

the status on Skype? I have Skype up, but I'm not seeing 

anything except a list of people who are on it. 

Mr. Katz: Okay. So we had Skype working earlier. I don't 

know if it has broken. But we'll work on getting that back 

online, I guess. We'll work on that, okay.

Member Ziemer: Thank you.

Mr. Katz: Sure. Thanks for telling us.

Okay. So if Board Members --

Member Ziemer: I have another question.

Mr. Katz: Oh, go ahead, Paul.

Member Ziemer: Can we assume that the petitioners, 

after they have a chance to review this report in detail, 

will provide their comments to the Work Group before the 
48

Work Group meets next?

Mr. Katz: Right. So SC&A is going to take a while to review 

this addendum, and in that interim, absolutely we've 

asked the petitioners if they would submit comments. 

They can do that through Josh Kinman, and they know 

Josh, I think they already have a line with Josh, and they'll 

get that done.

Certainly that will -- whatever comes in from the 

petitioners will come to the Work Group as well as to 

SC&A to look at, and NIOSH will be looking at that as well.

Member Ziemer: Thank you.

Mr. Katz: Sure. 

Mr. Giron: Excuse me, Chairman, this is the petitioner 

again. 

Mr. Katz: Yes.

Mr. Giron: I want to be clear on this. So after we review 

this report, you want us to forward everything to Josh 

Kinman?

Mr. Katz: Well get in touch with Josh. Josh will let you 

know who to communicate with, with whatever it is that 

you might have to communicate. So I think it depends on 

what you want and who you want to speak to and so on. 

But Josh is sort of your portal for speaking with NIOSH 

about issues, okay? All right.

Mr. Giron: Thank you, Chairman.

Mr. Katz: You're welcome, you're welcome. Okay then. So 

SC&A has been tasked, and they have some specific 

instructions as well, and I think that takes care of this 

session. So I have 10:20. 

We have a break until 11:00 a.m., so we're on break. 

Please get here five minutes early or so for the next 

session, which is also an SEC petition, so we can start on 

time for that. Thank you.

(Whereupon, the above-entitled matter went off the 

record at 10:20 a.m. and resumed at 11:00 a.m.) 

Mr. Katz: Okay, all right. We're about ready to get started 
49 

again here in the room. I heard a little earlier, Loretta, 

you were on the line and ready way ahead of us, and, 

Paul and Gen and Bill, you're on the line still?

Member Roessler: I'm on.

Member Ziemer: Yeah. This is Paul, I'm here.

Member Field: Yes, I'm on.

Mr. Katz: Super, super, thank you. And so without further 

ado, we have the Santa Susana Area IV SEC petition, No. 

235, and we have had out an Evaluation Report since I 

think November from NIOSH, and at this point we're 

having the evaluation review, review of the Evaluation 

Report by SC&A, and Bob Barton's going to do that.

Bob, please speak very close to the mic so that everyone 

has good audio quality, and off we go.

Mr. Barton: Great. Thank you, Ted. Can the people on the 

phone hear me okay?

Member Ziemer: I can hear you just fine. This is Paul.

Mr. Barton: Okay, great. 

Member Roessler: Yes, I can hear you well, Bob. Keep 

going.

Member Valerio: This is Loretta. I can hear you as well.

Santa Susana Area IV, SEC Petition No. 235

Mr. Barton: Wonderful. Well good morning, everybody. 

My name is Bob Barton. I'm with SC&A, and I'm going to 

be presenting the Santa Susana Field Laboratory, SEC 

Petition 235. Before I get started, I just wanted to point 

out the significant efforts of Milton Gordon, who worked 

with me on this and really did a lot of the heavy lifting as 

far as research, and was also co-author of our report, 

which is available on the NIOSH website.

So a little bit of background on Santa Susana. There are 

actually three SECs already in place for Area IV, all for 

periods prior to 1989. There is SEC 93, which covers 

January 1955 through 1958, and that was based on the 

inability to reconstruct both internal and external 

exposures.
50

Now a quick note on that is the recommendation to the 

Secretary said both internal and external, but in actuality 

NIOSH had determined that external dose was feasible 

during that period. So it was really just for the internal 

doses.

SEC-00156 extends from January 1959 through 

December 1964, and that was also based on the inability 

to reconstruct internal doses. And then SEC-00234 

extends up through 1988, and this got a little bit more 

specific in it was the inability to reconstruct internal 

exposures to americium and thorium specifically.

The original petitioner requested definition for SEC-00235 

was all employees of North American Aviation, to include 

corporate successors and subcontractors who work at 

Area IV, the Santa Susana Field Laboratory, SSFL, from 

December 31st, 1964 through the present.

The Class evaluated by NIOSH was all employees of the 

Department of Energy, its predecessor agencies and their 

contractors and subcontractors, who worked at Area IV of 

the Santa Susana Field Laboratory in Ventura County, 

California from August 1st, 1991 through June 30th, 

1993. We'll see in a second why that Class definition is 

very different than what was requested by the petitioner. 

One note on SEC 234. That was the SEC that was 

accepted up through 1988. In that Evaluation Report, 

NIOSH had stated NIOSH has not identified any data that 

suggests the possibility for significant operational thorium 

or americium exposures after 1988. They cannot be 

bounded. Therefore, NIOSH has established an end date 

of December 31st, 1988 for this SEC Class.

So recall that that SEC was based solely on the inability 

to reconstruct americium and thorium, and during that 

evaluation NIOSH determined that that exposure source 

did not continue as an infeasibility after December of 

1988.

NIOSH evaluation for SEC-00235, as I pointed out on the 

last slide, is for approximately a two-year period from 

mid-1991 into mid-1993, and it's really based on the 

bioassay contractor at the time, which was called Controls 

for Environmental Pollution, which I'll refer to as CEP 

during this presentation.
51

CEP had been implicated in data falsification with their 

bioassay results. This is actually, I believe, related to 

Sandia National Laboratory. But obviously if bioassay 

data is invalid there, it's going to be invalid for any site. 

So all that bioassay data for that two year period can't be 

used either in an individual dose reconstruction or to 

formulate any coworker intakes.

NIOSH released its original Petition 235 evaluation in May 

of 2017, and just to summarize what those feasibility 

conclusions were in that report, no issues had been 

identified with the reconstruction of external exposures or 

medically-related exposures. Those would be 

occupational X-rays.

External dose to unmonitored workers can be 

reconstructed using coworker doses, and those were 

detailed in the document OTIB-0077. As I said, the in 

vitro or bioassay data was disqualified for that CEP period, 

that two-year period in the '90s.

However, they also had a whole body count program that 

was valid, and it was in use during that time. Also, once 

it was discovered that the CEP data for that two-year 

period couldn't be used and the contract with that vendor 

was cancelled, they performed follow-up bioassay to see 

if they could measure any intakes that might have 

occurred during that two year period, and it showed no 

measurable internal exposures.

Finally, the internal coworker intakes have been 

developed for bioassay results that were during the 

operational period which ended in 1988. So coworker 

intakes have been developed for uranium, plutonium, and 

fission products, and those are proposed to be used not 

only for the CEP period, that period in the '90s, but for all 

periods after 1988 for which there's no SEC coverage 

currently.

So the ER was discussed back in December of 2017, so 

roughly a year and a half ago, and really there were two 

items that came out of that discussion as issues that 

really needed to be vetted further before any action could 

be taken. 

The first item was really to go and look at so me of the 

air sampling data during that two year window when we 
52

can't use the bioassay data. 

The reason you want to do that is you can take that air 

sampling data, compare it to the operational period for 

which we have coworker intakes, to try to get a feeling 

for whether those operationally derived intakes would be 

either representative or sufficiently bounding of any 

intakes that might have been experienced after 1998 

during that CEP period, when the bioassay data is invalid.

So that's the first item. The second item is related to the 

americium and thorium. As I said SEC 234, which ends in 

1988, was based on the inability to reconstruct americium 

and thorium. That was also the end of the operational 

period, but the question obviously remains what 

happened after that, you know. Is there -- they're doing 

remediation activities and D&D activities and things of 

that nature.

Is some of that material still there in process piping, glove 

boxes, and things of that nature, and how will that be 

accounted for? So NIOSH delivered two White Papers 

addressing each of these issues back this past November, 

and they were discussed a month later in December with 

the Work Group.

At that time, SC&A was tasked with reviewing those two 

new White Papers and the new information. We delivered 

our review of the two White Papers in a single document 

titled Review of Remaining Internal Dose Topics Related 

to the Evaluation of SEC-00235 at the Santa Susana Field 

Laboratory. That was delivered at the end of February.

So SC&A's review approach with those two White Papers. 

Obviously, where we always start is the Site Research 

Database, which is pretty much the compendium of all 

related EEOICPA documentation that NIOSH has to make 

these determinations. There are over 2,700 total 

documents just for Area IV, but only a subset of that 

would obviously be related to activities occurring after 

1988.

The second facet of the review is the Boeing incident 

database. This was provided by the petitioner, CORE 

Advocacy for Nuclear and Aerospace Workers, back at the 

December meeting in Redondo Beach. So we were going 

to go through that and look for incidents that were 
53

occurring after 1988 that would be relevant to this 

discussion.

The last thing was to evaluate, as I said before, the air 

sampling data. Again, for purposes to be able to make a 

meaningful connection between this two year period when 

the bioassay data is invalid and the operational period for 

which we have coworker intakes developed.

So starting with the SRDB review, again the purpose 

we're looking at those two facets. One, is there any 

reason to think that there's an exposure potential to 

americium or thorium that can't be feasibly 

reconstructed, that would represent an SEC issue.

The second one is, again, look specifically at that two year 

window when there's invalid bioassay data. What sort of 

activities were being done and how would that affect the 

use of coworker intakes that were developed during the 

operational period.

That's just some of the document types that we reviewed 

that are contained on the SRDB. These are pretty 

standard, but you have your air sampling, general area, 

and breathing zone. There are contamination surveys 

because this is part of a general remediation period and 

D&D. There are significant environmental monitoring 

evaluations and reports.

There's also the accident incident reports that were 

already on the SRDB. Some of them are contained in the 

Boeing database as well. The D&D evaluations, because 

that's the type of work they were doing, and any other 

planning or occurrence reports. 

In addition to those documents, there were two 

interviews that were performed as part of this SEC 

review, with workers who certainly had knowledge of the 

type of radiological operations that were occurring after 

1988, and these are two significant quotes we felt. I'd like 

to read them into the record.

As the various ETEC activities were terminated, the 

potential exposures to alpha emitters reduced 

significantly. As mentioned above, the primary isotopes 

of concern became cesium-137 and cobalt-60. While 

alpha emitters were also part of the source terms in 

Building 20 and the RMHF, these were at very low levels 
54

and were not routinely found in the contamination 

surveys of these locations.

So that was the first interviewee, and the second one 

states it is my opinion that americium-241 and thorium 

would have been minor contributors, if any, to internal 

dose. It is likely that this rationale is why there are 

relatively few bioassay requests made historically for 

these radionuclides. If americium-241 and thorium had 

been a significant internal dose contributor in the 

workplace of SSFL or De Soto, then it would logically have 

also been a potential environmental contaminant.

This is not the case as demonstrated by the U.S. EPA. The 

U.S. EPA Area IV Radiological Study which occurred from 

2009 through 2012. So neither americium nor thorium 

are or were an environmental issue. 

One could arguably extrapolate back and imply that it was 

also not a workplace issue at SSFL or at De Soto, or at 

least less so than uranium, plutonium, and mixed fission 

products, for which we had more than adequate bioassay 

data.

I'd just add that uranium, plutonium, and mixed fission 

products are all part of the operational coworker model. 

So SC&A concluded, based on this SRDB documentation 

review, while we do not find any significant events or 

operations that involve thorium or americium, these 

might have been potentially if, for example, they were 

ripping down a glove box or some ventilation lines and 

they found a significant amount of americium or thorium, 

but we simply did not find any evidence of that.

And then the second facet is we didn't find evidence that 

operations, and when I say operations I really mean 

remediation activities and D&D, during that two year 

window when we don't have valid bioassay data, that they 

were decidedly different in a way that would preclude the 

use of coworker intakes that were developed as part of 

operations.

Moving on to the review of the Boeing incident database. 

Again, the purpose is the same. We're looking for 

incidents possibly involving americium or thorium after 

that 1988 period. And then also again looking specifically 

at that two year window with invalid bioassay data, 
55

identify radiological incidents and see how they compare 

to incidents that occurred during operations and also 

before and after that two year window.

In the review of that database, there are 71 incident files 

that were related to Area IV after 1988. That's roughly 

ten percent of the entire incident database provided. 

Nineteen of those involved the detectable spread of 

contamination. Specific to that two-year window, there 

are ten incident files in that Boeing database, and only 

one of those involve detectable spread of contamination. 

Most of the incidents were generally related to things like 

radiography, operations that were done in the field and 

maybe a worker wandered into the wrong zone, that sort 

of thing, which would obviously be an external dose issue.

So conclusions, based on that review of the incident 

database, we did not find any incidents involving thorium, 

though we did find one single incident involving 

americium in that post-1988 period, it involved the 

cleaning of a smoke detector, which as many of you 

probably know radiological smoke detectors are often 

used, as they're a little more efficient than any sort of 

heat-based smoke detector.

A worker was cleaning one with an alcohol solution, and 

low level contamination was spread to the worker's 

hands, which was detected immediately and immediately 

removed. They performed a contamination survey of the 

area and did not find any contamination as a result of this 

cleaning operation, and nasal smears were also taken on 

the affected worker, and they were negative.

With regards to that CEP period, we didn't find any 

incidents that would lead us to believe that there was a 

significantly different exposure potential during that two 

year window, that again would preclude the use of 

coworker intakes that were developed as part of the 

operational period.

The third facet of our investigation was the air sampling 

data, and this was something that NIOSH also looked at. 

So what we wanted to do is take a look at what we had 

was general area summary values, by quarter for the 

operational period, where we're using the bioassay data 

to assign coworker intakes to that later period.
56

If we can compare those two data sets, the operational 

and the CEP period, and see how they compare, we can 

make some determinations as to how representative the 

radiological environment was for the two periods. 

So this first graph we're looking at, these are the 

maximum gross beta air sampling results, and again 

they're by quarter. This is really more of a sort of a visual 

element, but as we get further into the presentation, 

there will be some more quantitative numbers here. But 

as you can see, I've circled on the left vertical axes the 

maximum permissible concentration, which is one times 

ten to the minus nine microcurie per cubic centimeter.

And what -- the real takeaway here is if you look at that 

operational period, which is on the left side of the graph, 

in general those values are higher at the maximum levels 

than what you see during the CEP period, which is that 

small period bounded by the two red lines.

So that's the maximum gross beta. Looking at the 

average gross beta, once again just a visual inspection 

sort of shows that during that operational period, 

particularly in the earlier years of the operational period, 

it appears that the average values were bounding 

compared to the CEP period.

Moving on to the maximum gross alpha, again these are 

general area samples, and once again visual inspection 

you have from roughly 1982 to 1987 or 1986, you have 

higher values at the maximum, and this sort of drops 

down a little bit. I think that just sort of is reflective of the 

changing site mission and sort of the closure of actual 

operations, and then moving towards a more D&D and 

remediation style activities. So that's the maximum.

And then here's on average, and as you see, I love the 

earlier values. They're all right at one times ten to the 

minus fourteen. But again, a visual inspection shows that 

for most years during operations are bounding compared 

to the CEP period. And also what's noticeable is how much 

lower they are than the maximum permissible 

concentration.

So just looking at some numbers based off those graphs, 

if we're looking at the average of the average essentially. 

So we have these quarterly average values. If we were to 
57

average them over the operational period and then 

average them over the CEP period, how do they compare?

So as we show here, gross beta, you have your maximum 

permissible concentration of ten to the minus nine. The 

operational period was three orders of magnitude less 

than that, compared to the CEP period which was another 

two orders of magnitude less than the operational period. 

So clearly bounded in that metric.

Gross alpha was a little bit closer. But again, both 

operational and CEP were three orders of magnitude less 

than the max permissible concentration, with the 

operational period being about a factor of three to four 

higher than the CEP period. 

That was the average of the average. This is the average 

of the maximum quarterly air samples. Once again, 

during the operational period the maximum samples were 

actually quite a bit higher than the maximum permissible 

concentration, but again these are the maximum over the 

entire quarter.

And again, the operational period was about three orders 

of magnitude higher than the CEP period, that two year 

window in the '90s. And similar for alpha, once again the 

operational period is three orders of magnitude higher 

than the CEP period. 

So conclusions based on this air sampling evaluation, at 

both the maximum and average quarterly levels, it seems 

to corroborate the notion that the operational, general 

operational radiological conditions are bounding when 

compared to the CEP period when remediation and D&D 

activities were occurring. Also of note is that when you 

look at both the maximum and the average for the CEP 

period, they're all less than the maximum permissible 

concentration.

So SC&A did not identify any evidence in the air sampling 

data that suggests that internal exposure potential for the 

radionuclides of concern would not be bounded by the 

operational data. Again, that would be for uranium, 

plutonium, and fission products.

So to summarize SC&A's review, again it's the two facets. 

There's the thorium and americium, and then there's this 

two year window when the bioassay data is invalid. For 
58

thorium and americium after 1988, we did not find any 

evidence that there were thorium exposures or exposure 

potential or americium exposure potential that couldn't be 

feasibly bounded.

In other words, we do not see the same situation post1988 during this remediation period as was found prior to 

-- well, 1988 and before, when there's a SEC in place 

because of an infeasibility to reconstruct americium and 

thorium. But what does this really mean for dose 

reconstructions? 

Well, current methods assign what's known as an ambient 

or environmental intake, and these are actually based on 

stack emissions. Now, what is an ambient or 

environmental intake? These are really developed for 

workers who never really entered radiological areas. 

They'd be office workers or other administrative-type 

workers, not rad workers. But, since they were onsite, 

there is the chance for an elevated exposure above 

background.

So that's what those are used for, but they are not really 

appropriate for operations workers. So what SC&A 

suggests is that NIOSH go back and try to develop an 

occupational model, and you could do it a couple of 

different ways. But, generally, you could use either 

available breathing zone data or administrative limits on 

what was allowed, the max permissible concentration, or 

some fraction of that as appropriate.

So NIOSH has agreed to go back and investigate whether 

such a potential model could be put together to account 

for occupationally exposed workers, rather than, like I 

said, those who fall under the ambient or environmental 

category, which are really the non-rad workers.

With regard to the CEP period, again, August 1991 to June 

1993, we did not find any evidence in the air sampling 

data, the SRDB, or the Boeing database to suggest that 

internal dose reconstruction would be infeasible using the 

current coworker approach, which, again, utilized 

operational bioassay data to develop intakes.

So the Work Group for Santa Susana and DeSoto met at 

the end of this past March, and the Work Group 

determined at that time that the Advisory Board -- or they 
59

recommended that the Advisory Board accept NIOSH's 

evaluation and recommendation not to designate an 

additional Class for SSFL under SEC-235. As you can see 

there, that was the evaluated Class Definition.

There have been some additional developments since 

SC&A put out its report and the Work Group met. CORE 

Advocacy provided two additional documents right at the 

Work Group meeting on March 25th of this year. And so 

I'm going to go over those two documents briefly, 

because it's important that we look at those and vet 

those.

The first document was a list of buildings at Santa Susana 

that were associated with thorium, americium, and some 

other nuclides. The underlying references here are 

historical site assessments. So they're retrospective looks 

at what was done in the different facilities.

The reason they did this is for remediation reasons. They 

wanted to be able to know what they should be testing 

for in the soil, what radionuclides should they look for to 

see if they need to be cleaned up. 

But we point out that dose reconstructions are not 

building-specific at this site. So, if you have covered 

employment at this site, it doesn't quite matter which 

building you necessarily worked; it doesn't affect a dose 

reconstruction. However, the Site Profile should be 

updated to reflect this information so that it's 

comprehensive and accurate.

The second document certainly caught our interest. It was 

another historical site assessment, from 2011, but it 

indicated the potential for TRUMP-S operations, which 

stands for Transuranic Management by Pyropartitioning 

Separation. I think I got that right. I had to practice that 

one in my hotel room a couple of times.

But there were some indications that there might be some 

operations involving that material, which can be 

plutonium/americium, obviously a big one, uranium and 

neptunium, and there were some indications that that 

might have occurred even in 1989, which would obviously 

represent an operational type activity and not simply 

remediation or D&D.

So we went to that document, and also the underlying 
60

documents that supported it, and did some additional 

research. What it looks like, from what we could gather, 

is there were definitely preplanning activity, lots of 

meetings designating who would do what kinds of work, 

starting to develop procedures before the actual activity 

might have taken place.

In February 1990 they were still trying to get their license 

modified with the NRC to actually do the work with the 

TRUMP-S material. We found a newspaper article in 1990 

that noted that the operation had actually been moved to 

the University of Missouri, and it was due to "the heat of 

public challenges to the company getting the project 

licensed by NRC." The TRUMP-S material was eventually 

shipped from where it was being stored at Santa Susana 

to the University of Missouri in September of 1990. 

So, basically, what it looks like is they were trying to get 

the project licensed to be performed at SSFL, but it just 

didn't work out and they ended up sourcing that project 

out to the University of Missouri. So we just -- we did not 

find any evidence that TRUMP-S activities actually ever 

occurred after 1988.

In addition to those two documents, the petitioner, CORE 

Advocacy, had notified NIOSH at the end of January of 

this year that nearly 1,500 boxes of DOE records with 

potential relevance to SSFL and other sites there, like 

DeSoto, had been identified.

The exact contents and relevancy of the boxes, 

specifically to this petition, but in general, are not 

currently known, at least by me. But, per information 

supplied by CORE Advocacy, the boxes were supposed to 

be made available no later than the fall of 2019. But, even 

at the most recent Work Group meeting, it appeared that 

maybe those boxes already were available and possibly 

at a DOE facility in Cincinnati. 

So, what about these boxes? Well, the first thing that I 

guess we'd note, and this was discussed during the Work 

Group meeting, is that NIOSH is routinely notified of any 

new and relevant information made available, and they 

evaluate it accordingly. This is just their standard process. 

Also the petitioner can separately request the records via 

the Freedom of Information Act. 
61

This last bullet, I just wanted to point out that the SEC 

evaluation can always be reopened by NIOSH via the 

83.14 process. That's when they determine their own 

infeasibility, and so start the SEC process on their own. 

Or the submission of a new 83.13 petition, which would 

be externally generated by a petitioner.

The only reason I mention this is, if there are actions 

taken today, it's important to remember that it's not 

closed and gone forever. Any time there's new 

information, it can be evaluated and the discussion 

reopened. 

That concludes my presentation. I would be happy to 

answer any questions.

Mr. Katz: Thank you, Bob. That was very nice and clear 

and extensive. Board Members in the room, do we have 

questions for Bob?

Member Lockey: I have one, Jim Lockey, one question. 

That means that you will go through the boxes no matter 

what, is that correct?

Mr. Barton: I guess I'd defer to NIOSH on that question. 

At this time, I don't believe SC&A has any tasking.

Member Lockey: That's what I meant, NIOSH.

Mr. Katz: Lara's coming up to the mic. I don't know if that 

mic is live yet. It should be on. There you go.

Dr. Hughes: Yeah, it was not on. So what typically 

happens is, if we have an open investigation, an open SEC 

petition, and there's issues to be resolved, there will --

we will get notified if they get new information at the 

records facility in Cincinnati, and then a data capture 

team will go out and look through the boxes and collect 

what they -- what we think is needed.

So, with regards to those boxes, we contacted them with 

this box list to see what was available. And they were kind 

of bogged down in cataloguing and they weren't really 

giving us the information, saying, oh yeah, we have all 

those, but they were going through the numbers and 

were saying, oh yeah, it looks like we have this 

information here.
62

So, and as they catalogue the stuff they get from Boeing, 

they notify us if they see any of those key words that we 

typically look for, such as bioassay, air data. 

Recently, that's been a lot of investigation into DeSoto 

records, and in this case they will be collected. We just 

collected like something on the order of 4,000 documents

in the early part of this year. I hope this answers your 

question.

Member Lockey: Well, no, it partially answers the 

question. So, suppose this SEC is closed off today. Will 

you still go through the information, the boxes? It could 

be reopened. That's what my question is.

Dr. Hughes: Yes, we do. We would not necessarily go out 

and look for evidence of -- evidence of thorium/americium 

operations during this CEP period, because that would be 

a closed issue. However, if we came across something, 

we would certainly, you know, take it into account and 

say, how does this affect our previous decision? Does that 

answer your question?

I mean, nothing is ever closed. However, you know, if 

something is closed, we will not actively work on it until 

we find something.

Mr. Katz: Tim, is there something you want to add?

Dr. Taulbee: Yeah. Let me give a shot at trying to answer 

the question here. What's going on is DOE has received 

these records and they're currently inventorying them. 

We've given them a list of key words for them to look 

against. And so, as they run into something, they notify 

us and we go over and we send a team and we look at it.

And, just like we do with all of the other sites, if there's 

something that comes relevant that we didn't know about 

at, not just SSFL or some other site, we would consider 

that and does this impact any of our previous decisions. 

And if we have to, then we will open up a new petition if 

we run into some kind of infeasibility.

But, right now, all that is happening is they're being 

inventoried, we're being notified and then we're sending 

teams out to look at it. So it's an ongoing process until 

we get the entire set inventoried, and then we will look at 

the final listing across all the sites, really. Does that help?
63

Member Lockey: It does. I guess, would there be a 

difference in the -- if the SEC is closed, would your 

approach in relationship to this additional information be 

different than if the SEC remains open?

Dr. Taulbee: No. 

Mr. Katz: Right. So, in other words, your key words would 

capture something anyway, irrespective, that would be 

relevant for this topic. 

Dr. Taulbee: That's correct.

Mr. Katz: That's what Jim was trying to get at, I'm sure.

Member Lockey: That's what I was trying to get at. 

Mr. Katz: Yeah, thanks.

Member Lockey: Sorry. I wasn't quite clear on that, but I 

was --

Mr. Katz: No, that's okay. But it's clear now, which is 

what's important. Yeah, thanks. Other Board Members 

with questions? Josie.

Member Beach: I mostly just want to thank Bob and SC&A 

for jumping on those two documents that we got on the 

25th and giving us a report on them today. I appreciate 

that. I want to ask Tim, is the key list for those 

documents, is that word list already given to them? You 

did indicate that?

Mr. Katz: Lara's coming back to the microphone.

Member Beach: Sorry, Lara.

Mr. Katz: It's okay.

Dr. Hughes: I'm sorry? 

Member Beach: The list of key words, has that been given 

for that box of documents, the set?

Dr. Hughes: Yes.

Member Beach: Okay. Are thorium and americium on that 

list of key words?
64

Dr. Hughes: Yes.

Member Beach: Okay.

Mr. Katz: Good. Other Board Member questions? 

Member Roessler: Ted, this is Gen.

Mr. Katz: I'm sorry, we can't -- is that Gen?

Member Roessler: Gen, yes.

Mr. Katz: Yeah, go ahead.

Member Roessler: I have a question on Slide 9. I don't 

have any question about your conclusions, but you 

interviewed two people. Were they radiation workers, or 

who were the interviewees?

Mr. Barton: I'm not sure how much information we can 

give in a public forum. I will say that they were in a 

position to have knowledge of what was going on there at 

the site, to the point that I think their statements certainly 

have merit.

Mr. Katz: Thank you, Bob. Thanks --

Member Roessler: They were workers?

Mr. Katz: Yeah. They were, right.

Member Roessler: Yeah, okay. That was supportive of 

your other information. I just wondered. Thank you.

Mr. Katz: Other Board Member questions?

Member Kotelchuck: Yes here.

Mr. Katz: Yeah, so David, Dave Kotelchuck.

Member Kotelchuck: On that same slide, I didn't have a 

chance to look back at the SRDB, but roughly how many 

people were interviewed? Are these selected quotes from 

a large group? 

Mr. Barton: Well, I believe there are a number of 

interviews that were conducted as a part of the previous 

SEC investigations, which have bearing here. These two, 

I believe, occurred after the submission or the acceptance 
65

or the evaluation of SEC 235. 

So, specific to this one, they were interviewed after that 

petition was received. But there are a number of 

interviews on the SRDB related to SSFL that were done 

as part of the previous SEC investigations, but obviously 

are relevant to the full onsite operations.

Member Kotelchuck: Are they? I mean, are they relevant 

in terms of -- do they cover, are they trying to cover -- in 

the earlier SECs, are they trying to cover that period, this 

period of time?

Mr. Barton: A lot of them are not directly relevant, 

because these guys obviously wouldn't be asking 

questions directly relevant to SEC-235. So I would say 

that those two workers had questions directly related to 

this, whereas the other workers would be more incidental 

information provided.

Member Kotelchuck: Yeah.

Mr. Barton: So, really, those two are main interviews for 

this SEC.

Member Kotelchuck: Right. I mean, there can be -- they 

may well be many different perspectives. Can I ask, are 

they part of the petitioners? Are they among the 

petitioners?

Mr. Katz: We can't really get into identifying people so --

Member Kotelchuck: Okay. Well, petitioners are a larger 

Class I thought.

Mr. Katz: Well, no. There is one petitioner. Are they --

you mean are they members of the petitioning Class?

Member Kotelchuck: Yeah.

Mr. Katz: Oh, I don't know if -- we probably don't even -

- couldn't tell you that off the bat. Can he?

Mr. Barton: I don't know that.

Mr. Katz: Lara, do you know?

Dr. Hughes: So you're asking if the persons that were 

interviewed for SEC-235 are members of the --
66

Member Kotelchuck: Of the Class that's petitioning, in 

effect.

Dr. Hughes: Petition Class. 

Mr. Katz: Do you know that?

Dr. Hughes: I would think so. They were individuals who 

worked at the site for a long period of time and who are 

very knowledgeable about the radiation safety program.

Mr. Katz: At that time period?

Dr. Hughes: Yes.

Mr. Katz: That makes sense.

Member Kotelchuck: Okay.

Mr. Katz: That makes sense, right? I mean, they are 

speaking to the period that's being petitioned for.

Member Kotelchuck: That's the best. That's the best we 

can get. That's not -- there are other questions, but since 

we can't identify people, I'll stop, leave it at that.

Mr. Katz: Other Board Member questions? Dave. David 

Richardson.

Member Richardson: Thank you. And thank you for the 

presentation. So, I'm trying to put together the, let's say, 

threads or lines of evidence that are being used to make 

the argument. There's one which we just had a discussion 

about, which is unattributed quotes of opinion, and that's 

one category of information.

The second set that you put forward were incident 

reports, which were very small in number, and in fact you 

said N equaled one case report. Typically, I've set those 

aside sort of like case observations or something. Again, 

it's going to be very hard to make a determination based 

on the incident reports.

The third category seemed to be the one where you were 

providing some quantitative evidence, and I wanted to try 

and better understand that. The White Paper that was 

provided, this third line of evidence had to do with air 

sampling data. And it describes that -- I mean, here we're 

talking, I believe, the periods 1991 to 1993, and the 
67

White Paper points to a partially overlapping, but not 

completely overlapping, time period of 1988 to 1992, 

during which it says air sampling was the primary 

assessment method for worker exposure.

And it goes on to say that this is predominantly general 

air sampling, with breathing zone samples in localized 

areas for very specific tasks. So those seem to be the 

exception. 

So, first, I guess my first question is just to understand 

what is on the slides as the presentation of, for example, 

average values.

These are average values over a year of general air 

sampling results? Or are you averaging breathing zone 

and general air sampling?

Mr. Barton: It would just be general air.

Member Richardson: So, pretty much the presentation, 

this third line of evidence, is hanging on either maximum 

or average value of general air sampling results?

Mr. Barton: That's correct.

Member Richardson: Okay. And that's the basis for us to 

understand the comparability of worker exposures during 

that period to the other periods?

Mr. Barton: Yes. I'd say it's one piece of evidence. Again, 

when we first started discussing this, the NIOSH 

Evaluation Report, we had noticed that there was some 

air sampling data that had already been captured. So we 

said if we're trying to make this connection between the 

operational exposures and this two-year window, and we 

have some air sampling data to make that comparison, I 

think that we should go in and use it and that's what we 

did.

Is it an absolutely conclusive piece of evidence? No. But 

it is one piece of evidence in, I guess, what you would call 

a weight of evidence argument.

Member Richardson: Yeah. And the thing that particularly 

got me hung up was the average of the averages, which 

I think suffers what's called, you know, regression to the 

mean. It's not at all surprising that, you know, as you 
68

average averages, you pull closer and closer to not seeing 

an any signal at all.

And so it's almost -- I would discount that line of evidence 

as well. So I'm not left, so far, with very much with which 

to understand this issue.

Mr. Katz: Tim.

Dr. Taulbee: May I elaborate a little bit, and hopefully help 

clarify some of this, Dr. Richardson? Keep in mind that 

we're not using that air sample data for dose 

reconstruction. It was simply for a comparison type of 

purpose. We've got a coworker model that's based on 

bioassay. So what we were looking for is during that time 

period where we can't use the bioassay, where we're 

relying on the coworker, do we see an increase in airborne 

activity at the site? Do we see something that is out of 

place?

The information that Bob just presented, even though it 

is averages of averages, which would go toward a mean, 

it's several orders of magnitudes difference that's not 

showing this huge increase in airborne activity that would 

tend to point to the invalidity of a coworker model that 

was developed during the operational period.

So the coworker model is what we're using 

from a dose reconstruction standpoint. This was a 

comparison of does it continue to carry through that time 

period.

Member Richardson: Yeah. I appreciate that. I'm just sort 

of thinking about it's almost as though you have a tool 

which, you know, a flashlight that doesn't have batteries 

and you don't see anything, so how reassured are you? I 

mean I feel like, you know, average values from general 

air sampling, I'm not even sure how sensitive that would 

be to the detection of whether there was a problem during 

some of the activities that they describe, like this SNAP, 

pulling apart the SNAP building.

You know, what information have we been given that 

potential problems that somebody might have 

encountered there? That's an aside. I mean that was just 

in general, what, how helpful is that evidence? I'm not 

sure it's very helpful.
69

Mr. Katz: Do you have other questions David?

Member Richardson: No.

Mr. Katz: Board Members on the phone, do you have 

questions?

Member Ziemer: This is Paul. I do have a question. 

(Pause.)

Mr. Katz: He's there. He's just formulating I think but --

there he is. Paul?

Member Ziemer: Yeah. Can you hear me?

Mr. Katz: Yeah. I guess you're -- just whether some other 

-- your phone must have broken up, because we didn't 

hear you.

Member Ziemer: Okay. Let me try again. So I'm going to 

-- I have it on speaker. I'm going to take it off speaker. 

Maybe it was echoing or something. If we vote to accept 

the recommendation, it would be to vote not to have an 

SEC for this period. If we voted not to accept the 

recommendation, does that carry with it the fact that or 

the implication that it therefore becomes an SEC? That's 

one part of my question.

The other part is if we don't vote at all, doesn't that have 

the same effect for now of voting to accept?

Mr. Katz: Okay. So let me take that in parts. So if you 

vote to not accept, it does not result in a Class, because 

you have to formulate a Class and you need a justification 

for adding a Class, and you still don't have that.

Member Ziemer: Right so --

Mr. Katz: Yeah.

Member Ziemer: So not, not voting in favor of the 

recommendation leaves things at the status quo, which 

has the same effect of not voting at all?

Mr. Katz: Yeah. I mean that's true. I am not encouraging 

of that, because I don't think the Board should just table 

things basically on the shelf. 
70

So I think the Board has a duty to act on a petition once 

it's done its homework. So either in favor or there needs 

to be more research, or against. But I don't think we 

should just sort of pocket veto or whatever an action as 

you might describe it.

Member Ziemer: Well, I wouldn't suggest that we do that. 

I was trying to determine the effect of it, and also we 

certainly are expecting to take a look at these new boxes 

and determine what impact they have.

Mr. Katz: Right.

Member Ziemer: Either way, I guess.

Mr. Katz: Right. There are these boxes. I mean it hasn't 

been typical for the Board to, because of a floor request 

for records or records that are undescribed when we've 

already done our analyses, it's not typical for the Board 

to wait on additional records.

I mean there are additional records at all of these sites 

that we haven't gone through. Every single site that the 

Board can cover for every petition, and we would --

frankly, the program, you know, will take years and years 

to get through reviewing every record at every site that 

could be germane for something related to dose 

reconstruction. But so that's my suggestion to the Board 

about that. 

Member Ziemer: Thank you. 

Mr. Katz: Sure. Gen or Bill or Loretta, do you have 

questions?

Member Roessler: No further questions.

Member Field: No questions, Ted.

Mr. Katz: Okay, okay, let's go on then.

Member Valerio: Ted, Ted?

Mr. Katz: Yes, Loretta.

Member Valerio: Ted, this is Loretta.

Mr. Katz: Yeah.
71

Member Valerio: I have a question. In the White Paper 

that was issued in February of 2019, the review of 

Remaining Internal Dose Topics, on page 17 the last 

incident report, if I'm reading it correctly, that incident 

overlaps the previous SEC period and the SEC period 

we're looking or considering now.

I'm just wondering the air samples that were found in a 

file cabinet, were those alpha or beta? Do we know?

Mr. Barton: I don't -- this is Bob. I don't recall necessarily 

whether they were designated as a specific gross alpha or 

gross beta. I know that, I believe that incident in 

particular spawned a whole operation to search the entire 

facility, to make sure that wasn't happening and it wasn't 

a widespread problem.

So they actually went through essentially every drawer to 

see if there were more air samples there. I believe with 

that incident, while there were air samples that were in a 

drawer, there was no associated contamination, if I 

remember correctly, on the outside of the packets 

essentially that these samples were in.

Mr. Katz: Thanks Bob.

Member Valerio: Thank you.

Mr. Katz: Loretta, is that it? Okay. David, Dave 

Richardson.

Member Richardson: I had one related question. There's 

something which was sort of punted, which was the 

evaluation was going to allow for the use of an available 

coworker value, and that's what NIOSH is proposing to 

do. Are there in fact two, two coworker models on the 

table right now? 

There's the ambient environmental coworker model and 

the one which you are proposing, which is based on 

breathing zone data perhaps, albeit limited, or what is 

that coworker model?

Dr. Hughes: There's currently an occupational coworker 

model that is based on bioassay data. That was developed 

several years ago based on, yeah, based on urine data. 

There is also an environmental approach that is used to 

assign ambient doses for workers on the site. It's not so 
72

much a coworker model; it's just the ambient model that 

we use in the Technical Basis Document.

Member Richardson: So what's SC&A's proposal about 

that, and how does it relate to the proposal which is here, 

because it was raised as a recommendation at the end of 

this presentation?

Mr. Barton: Right. This is Bob again. I think, so there's a 

couple of different facets to this. When we talk about the 

traditional coworker model, which was developed based 

on the production values, that's for plutonium, uranium 

and fission products.

When we talk about maybe developing occupational 

intakes using breathing zone, that would be for assigning 

americium and thorium occupational values, rather than 

the uranium, plutonium and fission products. So there's 

essentially in this remediation D&D period, there are two 

occupational models.

There's the urine-based one for uranium, plutonium, 

fission products and then there's -- NIOSH is going to look 

into developing an air sampling based one for americium 

and thorium, which is currently on treated with the 

environmental intake model.

Member Richardson: I see. Thank you.

Mr. Katz: Thanks, Bob. Other questions? Okay. D'Lanie, 

we have now the petitioner for this petition for her 

comments. Thank you D'Lanie for joining us again. 

Ms. Blaze: Is this one? Are we live?

Mr. Katz: Are we live? Can you hear D'Lanie on the 

phone?

Ms. Blaze: Hello? Can you guys hear me out there?

Mr. Katz: I think so.

Member Roessler: Just barely.

Mr. Katz: Yeah, okay. Oh just barely.

Public Participant: We have background noise from 

maybe a TV in the background I think.
73

Mr. Katz: So let me just before you get started, for people 

on the phone, everyone except for -- well everyone for 

that matter, please mute your phone. If you don't have a 

mute button, press *6. That will mute your phone for this 

line, so that we have good audio. 

This will help you hear the petitioner as well, so as well 

as our Board Members who are on the line who need to 

be able to hear this. But please mute your phone, mute 

button or *6 to mute your phone. All right. Why don't you 

give it a shot D'Lanie?

Ms. Blaze: Okay. I'm D'Lanie Blaze, the SEC petitioner. 

I'd like to thank the Board, NIOSH and SC&A for the 

ongoing efforts on the SEC petitions at Santa Susana and 

the DeSoto facility. As we are aware, Santa Susana, 

Canoga and the DeSoto facility are considered to be the 

same entity operationally and contractually. 

NIOSH uses the same Site Profile to conduct dose 

reconstruction for workers that are affiliated with all three 

of the work sites. 1988 is the beginning the site 

remediation period, and remediation workers are covered 

under this program. So today, I want to talk a little about 

some documentation that has been submitted by CORE 

Advocacy that I believe it's relevant to both work sites.

I don't think it's been adequately reviewed, and I also 

think it's being selectively interpreted and applied. In 

2016, CORE Advocacy provided NIOSH and SC&A and the 

Board with proposed corrections for the Site Profile, and 

remember that's used for all three work sites, Santa 

Susana, Canoga and DeSoto.

That submission was based on EPA's 2011 Area IV 

radiological characterization study, which is the study that 

SC&A has been referencing. From here on, I'll just call it 

the EPA study. In their study, EPA identified at least 50 

additional radiological facilities at Santa Susana Area IV 

that had operated over the course of 50 years.

They had all been excluded from the Site Profile, along 

with all corresponding environmental data. This has 

resulted in a Site Profile that does not provide an accurate 

depiction of site operations or worker exposure risk. To 

date, NIOSH has not incorporated any of the suggested 

additions or corrections and it does not appear that the 
74

EPA study has been adequately reviewed amidst this SEC 

evaluation process.

This is actually apparent, since it appears that the 

interviewees of Boeing misquoted the EPA study and 

NIOSH appears to have taken these assertions at face 

value, rather than fact check the statements against the 

actual EPA study. So basically EPA identified americium 

and thorium to be among the radionuclides of concern 

that were associated with all 50 of those locations.

The majority of those locations were considered to be 

Class 1 under the Multi-Agency Radiation Survey and Site 

Investigation Manual or MARSSIM, which is a manual that 

defines the reasonable potential for residual radioactive 

contamination. A Class 1 MARSSIM rating refers to an 

area that's found to have to have had prior to remediation 

a high potential for radioactive contamination based on 

the site's operational history, or known contamination 

that's based on previous radiation investigations.

So EPA identified the 50 radiological locations that never 

made it into the NIOSH Site Profile. NIOSH has not added 

the information after it was provided. EPA identified 

americium and thorium at all 50 of those locations, which 

were mostly Class 1 MARSSIM areas, indicating high 

radioactivity potential that was based on established site 

history and previous investigations.

EPA reviewed over a million historical facility documents 

to reach their conclusions, and to date it does not appear 

that NIOSH has made any effort to rely on the EPA study 

or to acquire the same documents to conduct their own 

review. It should be noted that most of those locations 

where EPA identified americium and thorium were not 

torn down until 1995 or after, which is well after this 

proposed SEC period.

And again, site remediation workers who are covered 

under this program are likely to encounter these materials 

during their site remediation processes. But moreover, if 

NIOSH and SC&A are going to use that EPA study to find 

reasons to limit this SEC, shouldn't NIOSH be using it to 

update the Site Profile by adding all those 50 sites that 

are missing?

I continue to be impressed by the thorough work that is 
75

performed by SC&A, but I'm frustrated because it does 

not appear that they are being given all of the relevant 

information. It seems that NIOSH only provides SC&A 

with enough information to result in an unavoidable 

conclusion that meets with NIOSH's desired outcome.

Case in point, NIOSH has been in possession of the Boeing 

incident report database since at least 2008. So why did 

CORE Advocacy have to provide SC&A with a copy of that 

database at the last Work Group meeting? Further, with 

respect to the TRUMP-S program, if the EPA study had 

been adequately reviewed, it seems that their 

assessment of Building 4023 would have been noted.

This is where EPA describes TRUMP-S research taking 

place, and that location is among those where EPA 

identified americium and thorium among the 

radionuclides of concern. I've provided EPA's excerpt of 

Building 4023 gosh, I think a year ago, but I also provided 

it at the last Work Group teleconference. 

Further underscoring the need for an SEC Class is 

Boeing's response to the Santa Susana SEC expansion to 

1988. The contractor has countered by now withholding 

personnel and radiation records, often making it 

impossible for workers to establish their work locations 

and their exposures.

In 2018, we verified that Boeing withheld and altered 

radiation data and incident reports for an employee of 

Santa Susana and the DeSoto facility. That alone is a 

basis for an SEC. As usual, we've covered a lot of ground 

in a short period of time, but I believe we have 

established the presence of americium and thorium in 

Area IV after 1988.

We've also demonstrated that the current Site Profile is 

so deficient that we cannot conduct dose reconstruction 

with sufficient accuracy, and as such dose reconstructions 

based on that Site Profile are likely to have been 

dramatically underestimated, based on a downplayed 

depiction of site operations and exposure risk.

I respectfully urge the Board to find that SEC-235 is 

necessary for Santa Susana, and as always it's a privilege 

to address the Board. Thank you.

Mr. Katz: Thank you, D'Lanie. Do we have questions from 
76

Board Members? Josie.

Member Beach: Not for you D'Lanie, but for SC&A, refresh 

my memory, Bob. Has SC&A reviewed the EPA study that 

D'Lanie's discussing?

Mr. Barton: Yes. That's available on the SRDB, and also 

with regard to the comments with the TRUMP-S, that was 

specifically part of the presentation. What happened is as 

they were going back and looking at these different 

buildings, including Building 4023, they were looking for 

historical evidence of what operations were going on 

there.

They found documentation that there were plans to have 

TRUMP-S activities performed in that building in 1989. So 

we obviously took that very seriously, and but in digging 

further on, they were having problems obtaining a license 

to actually perform the work, and eventually that project 

was scrapped and sent to the University of Missouri.

Member Beach: Oh okay. So not regarding TRUMP-S. I 

understand that, but the EPA study in light of the two 

individuals that commented, have you looked at it for that 

aspect of --

Mr. Barton: Well certainly americium and thorium would 

be part of the list of contaminants of concern, just given 

the site history out there. So they would obviously be part 

of any analysis there. We didn't see anything in that EPA 

report that would lead us to believe there was an 

exposure source that was comparable to what was 

happening during the operational period that prompted 

SEC-234.

So we agree that americium and thorium could be out 

there, especially in things like drain lines and HVAC 

systems, which is really why we proposed that NIOSH go 

back and determine an occupational dose assignment or 

at least see if that's feasible to do beyond just the 

environmental ambient exposures that are currently 

assigned.

So we agree that americium and thorium are there, but 

we have not to date found evidence that it was to the 

level as the previous period that prompted the SEC.

Member Beach: Thank you.
77

Mr. Katz: Other Board Members' questions? 

(No response.)

Mr. Katz: And Board Members on the line, questions? Yes, 

Andy.

Member Anderson: This is more of a process question for 

NIOSH. I mean you raised the issue that there's a lot of -

- or the EPA report information that's out there that isn't 

summarized or part of the current Site Profile. The 

question would be if we now end the SEC portion here, 

will that update or can we have a commitment about an 

update of that, or is that in the works or what's the status 

of that? If we're not working on something, then my 

concern would be it's going to drop off the --

Ms. Blaze: Can I just interject? I didn't get a chance to 

respond to the question that Josie raised, and this could 

be relevant too. It is true that the TRUMP-S program was 

scrapped and sent offsite to some, I guess, site in the 

Midwest. But EPA does provide the documentation 

showing that the research began at Building 4023 and the 

materials were used there.

We're continuing to find documentation of the TRUMP-S 

program. In 1990, Rockwell International was still 

interested in making the TRUMP-S program the only 

continuing to function program at the site. Those 1,463 

boxes, there are several of those boxes that contain 

information that's specific to the TRUMP program, and 

that's listed in the box inventory that I provided.

Mr. Rutherford: As for our processes, as soon as the close 

out of an SEC, our standard process is that Site Profile 

revisions take place. All new information that, information 

that we've brought forth in an SEC evaluation through the 

Board, petitioner and such is all evaluated and updated in 

our Site Profile.

Mr. Katz: Can I clarify though LaVon, because you only 

add to the Site Profile information germane to doing dose 

reconstructions. Isn't that right or not?

Mr. Rutherford: Well that's true, but what we're doing is 

-- I mean everything we've learned from our dose 

reconstruction process is updated in the Site Profile. So 

you know, not only if we -- you know, our infeasibilities 
78

that we define, but if we've learned that possibly that, you 

know, not in this case that we needed to update a dose 

reconstruction method based on what we learned, we 

would update that.

So everything as part of the evaluation process is taking 

into consideration do we need to update it in the Site 

Profile.

Mr. Katz: Right. No, I just wanted to be specific to 

D'Lanie's issue, I think, because it doesn't mean 

necessarily, you're not committing to putting anything 

about the EPA report in the Site Profile unless there's 

something there that's germane for doing dose 

reconstructions; is that correct?

Mr. Rutherford: That's correct.

Mr. Katz: Okay. I just want clarity on that.

Ms. Blaze: Could I respond?

Mr. Katz: Yes.

Ms. Blaze: It's my understanding that a Site Profile's 

purpose is to provide an accurate portrait of a site's 

operational history, and that is to also include 

environmental data of releases and incidents, the types 

of materials and operations that took place, the amount 

of materials that were kept onsite.

This is the type of information affiliated, associated with 

these 50 missing locations that have been excluded from 

the Site Profile. I think that would be germane to 

completing an accurate dose reconstruction, is 

understanding what the workers faced when they were at 

the site every day.

We had 50 additional radiological facilities that functioned 

for up to 50 years, including a radioactive waste 

incinerator.

Mr. Katz: Yeah. I just wanted to be clear for you D'Lanie. 

Ms. Blaze: I got it.

Mr. Katz: It may be, it may be that it characterizes stuff 

that goes on on the site, but if it's only if it's relevant and 
79

germane to dose reconstruction that they would include 

it. That's all with any information, but so it's not a total 

picture of operations at a site or even what materials may 

be residing there. Board Members? Any other questions? 

Or on the line? Any questions?

Member Ziemer: This is Paul. I'm trying to resolve the 

difference on whether or not the NRC license was required 

for the TRUMP-S program? It sounds like D'Lanie said 

they had actually started it, and I think -- I think the SC&A 

report said they never did get the license. 

Ms. Blaze: We've got difficulty --

Member Ziemer: Can we clarify that issue?

Mr. Katz: Bob.

Mr. Barton: Yeah. Hi Paul, this is Bob. Based on our 

research into that, they were certainly gearing up for the 

operation. They were having pre-planning meetings. They 

even had outfitted a glove box for it. But yes, they were 

having trouble getting their license amended to perform 

that work with NRC, and as I gather they were under 

immense public pressure about actually doing that 

program out there at SSFL.

Based on what we know, we did not find the evidence that 

they actually started it up there. Again, they were gearing 

up for it. There's plenty of pre-planning meetings. There 

were even procedures written. But we didn't find any 

evidence that it actually got off the ground, and that they 

actually got the license amended to do that work.

In fact, if that evidence is out there, then that certainly 

would be a game-changer.

Mr. Katz: Jim.

Member Ziemer: I think D'Lanie mentioned this particular 

building where they had actually started. Did I 

misunderstand that?

Ms. Blaze: No, you didn't. It's Building No. 4023 or 

Building 23 they call it.

Mr. Barton: That's correct.
80

Member Ziemer: And so you're saying that they actually 

started it? I mean they were handling the materials at the 

building?

Ms. Blaze: According to my understanding of the EPA's 

review of Building 4023, TRUMP-S research and materials 

were underway, actually took place at Building 23.

Member Ziemer: Hmm.

Mr. Katz: Well so Paul, I mean, I guess part of the 

question is can you actually handle the radiological 

materials without an NRC license to do so?

Member Ziemer: Well under NRC, you can't even possess 

the material until you have a license.

Ms. Blaze: I guess that was one --

Member Ziemer: So if a license is required to possess it, 

unless there's different rules on that.

(Simultaneous speaking.)

Ms. Blaze: We have records of shipments of materials for 

TRUMP-S. 

Mr. Katz: Jim, did you have a question?

Member Lockey: That was my question.

Mr. Katz: Okay, you covered it. Okay. Paul, do you have 

other questions?

Member Ziemer: No. That was the issue concerning, that 

there's a conflict between the SC&A report and what the 

petitioners reported on that TRUMP-S material.

Mr. Barton: Dr. Ziemer, I'd just -- I'd add that this 

particular issue with Building 4023 wasn't actually part of 

our report. This kind of came to light at the last Work 

Group meeting. So SC&A really did sort of an ad hoc 

review of that issue, both that document, on the EPA 

document that identifies Building 4023, but also the 

reference documents that they were using to determine 

whether TRUMP-S activities happened there. 

And again, there seems to be some conflicting evidence 

as to whether the project actually got started, or whether 
81

it never really got off the ground. Ms. Blaze is correct, 

that they did receive shipments of TRUMP-S material. We 

have records of that, and we have the records of them 

then shipping it to the University of Missouri in 1990.

Ms. Blaze: Can I ask you a question?

Mr. Katz: Yes.

Ms. Blaze: Is it possible to task a review of the TRUMP-S 

documents that are in the boxes at DOE?

Mr. Katz: Yes. It's possible to task just about anything, 

yes.

Member Beach: I have a question related to the 

shipments. How long was it onsite Bob, if it was shipped 

to Savannah or Santa Susana and then shipped out? Do 

you know how long it was there?

Mr. Barton: I don't know the exact dates off the top of my 

head. I believe it got shipped there in the late 1980's, and 

I know it was shipped out in September of 1990.

Ms. Blaze: Those shipments arrived to the DeSoto facility, 

and they were transported to Santa Susana.

Mr. Barton: I'm just not sure of the date.

Mr. Katz: So 1990 you said to 1990 shipped out?

Mr. Barton: No. I believe, I believe it came some time in 

the late 1980's, and then was shipped back offsite to the 

University of Missouri in September 1990.

Mr. Katz: September 1990. 

Member Beach: It seems like there's some questions that 

still need to be resolved on this issue. 

Mr. Katz: Jim?

Member Lockey: Did SC&A look at the EPA document?

Mr. Barton: Yes.

Mr. Katz: SC&A looked at the EPA document and the 

underlying documents that the EPA document sort of 

referenced. So again, you've heard it, that the -- well, I'm 
82 

not going to summarize, because it's been summarized 

for you. Tim.

Dr. Taulbee: May I make one additional comment, or one 

small comment here, is that you know, Bob was talking 

about the material being, the TRUMP-S material being 

shipped out in September 1990. The time period of 

question from the CEP bioassay is 1991 to 1993. That was 

what we were initially focusing on here.

Mr. Katz: Prior, you mean prior -- it was shipped out prior 

to the SEC period?

Dr. Taulbee: That's correct.

Mr. Katz: Well that, okay. That seems like an important 

fact, but --

Ms. Blaze: Although we'll -- I mean we were talking about 

operations after 1988, so I guess it would probably be 

relevant.

Mr. Barton: This is Bob. Yeah, the question came up in 

the Work Group back in December of 2017 as to well, we 

have this SEC here for americium and thorium, and then 

we have a cutoff date and then there's nothing. So that 

was one of the things we were tasked -- 

Originally NIOSH was tasked with looking at, is there 

significant potential for exposure to those two 

contaminants after that SEC period? So while SEC-235 is 

concentrated on that two year window in the early 90's, 

as part of NIOSH's and eventually SC&A's tasking we were 

looking at basically americium and thorium potential after 

1988.

Mr. Katz: I see. That's not a helpful clarification. Thank 

you, Bob. Phil.

Member Schofield: Yeah. What level of new evidence 

would it take for you guys just to reopen it instead of just 

adding it to the site database? 

Mr. Katz: So these, the documents that are relevant are 

going to the Site Research Database, right, that whatever 

they capture that's new, because there has been some --

a number of these documents that are at the Cincinnati 

facility they already have. Even though they're part of this 
83

boxload, they've received it previously. Is that what 

you're asking about?

Member Schofield: Well, kind of. I'm really wondering at 

what point it triggers that no, we need to maybe reopen 

that SEC petition because of this additional data?

Mr. Katz: Oh, oh. I mean at whatever point that NIOSH 

receives new information that raises an issue about the 

ability to reconstruct doses is when they would pursue an 

83.14. Yes, Jim.

Member Lockey: Yeah. One question, Bob. So TRUMP-S 

would have been americium and thorium, is that right, or 

something other?

Mr. Barton: I don't believe thorium is usually part of those 

programs, but americium certainly.

Member Lockey: Okay. So I thought I heard you say that 

when they did sampling, when they did in the residual 

period they didn't -- they found little americium or 

thorium; is that correct or have I --

Mr. Barton: Some of the measurements, again soil 

samples, did find small amounts slightly above 

background. So it's out -- it is out there, which is to be 

expected since they handled transuranic materials 

throughout its operational period. So it would still be 

there onsite. The question really is what is the exposure 

potential to it during this period after 1988, and can we 

come up with a reasonable method to bound that dose?

Member Lockey: And how about Building 23? Do you 

remember anything about that?

Mr. Barton: Yes. That's -- it's towards the end of my 

presentation. That was the second document provided by 

CORE Advocacy at the last Work Group meeting, and 

again looking at the references that were supplied and 

also the underlying references and we did a little bit more 

research on top of that, even digging up that newspaper 

article that indicated it never really happened, but it 

might have. We just simply don't --

Member Lockey: Was there any EPA sampling, residual 

sampling in Building 23? 
84

Mr. Barton: That I do not recall offhand.

Member Lockey: Okay. 

Ms. Blaze: I think EPA sampled at Building 23.

Member Lockey: They did?

Ms. Blaze: Yeah. I submitted the excerpt of Building 23 to 

our Work Group. 

Member Lockey: And was the background levels of 

americium different than what they're finding in the rest 

of the site?

Ms. Blaze: I don't know.

Mr. Barton: It's also a question of when those potential 

activities would have occurred. If the TRUMP-S program, 

they were doing those activities prior to 1989, that 

exposes -- is already covered by an SEC. So it's really a 

question of what were they doing after 1988, and if they 

were still doing TRUMP-S activities that would obviously 

be a very important operation that we would have to get 

our head around.

And like I said, we looked into it and I guess based on our 

evaluation, again since the last Work Group meeting, it 

looks to us like they tried to get the licensing for it. They 

tried to have, be their really last experiment, the last 

hurrah so to speak, and they just couldn't get it done 

between public pressure and the NRC license issue. So 

eventually, I guess they found more fertile ground in 

Missouri.

Mr. Katz: But you also said just a moment ago in clarifying 

that the materials that they had for TRUMP-S were 

shipped out before --?

Mr. Barton: That's correct. They were shipped out in 

1990. The evaluated period is from August 1991 through 

June 1993. But again as part of this whole evaluation, we 

were tasked with looking at specifically americium and 

thorium after 1988, which will include any TRUMP-S 

activities that might have taken place.

Member Lockey: So Ted, what I was trying to get at is if 

they were doing TRUMP-S activities in Building 23, 
85

perhaps the americium contamination in that area would 

have been different than the rest of the site in the early 

90's. That's what I was trying to get at.

But we don't, you don't have that data, or you don't --

you're not aware of what that was.

Mr. Barton: Well, I'm not aware of it, but again we're not 

trying to claim that americium exposure potential didn't 

exist. In fact, that's our recommendation, is that we need 

to have some sort of framework in place to be able to 

assign occupational exposures to americium, because 

americium projects did occur at that site, but maybe not 

in this post-'88 period, which is an important distinction.

Mr. Katz: Tim.

Dr. Taulbee: Again, this petition is from 1991 to 1993. If 

during this document review we find that they did do 

TRUMP-S material there in Building 23, that would require 

a new petition. So we would open that under an 83.14 

type of purpose.

So it's not like this is going to completely go away. These 

1,400 boxes are still being reviewed. They're being 

indexed. We are looking at them from that standpoint. 

But this particular petition is from 1991 to 1993. 

Mr. Katz: Well further, they can't do the TRUMP-S 

activities in '91 to '93. If they shipped the materials off in 

'90 but --

Dr. Taulbee: That is correct. But if they did, then we 

would open a new petition from the 1988 period forward.

Mr. Katz: Right.

Member Richardson: But I'm back to these three lines of 

evidence. We had an SEC which went through 1988 and 

was premised on the argument that that was the end of 

operations. Now there's a suggestion, I guess it's an open 

question, were there activities going on after 1988, 

because we have this vacuum here or this gap in the 

information for the period which is, I agree, we all agree, 

we're discussing.

And the argument is that based on anecdotal evidence, 

incident reports and area sampling of area air sampling, 
86

we can make an informed decision about whether the 

activities during that period were comparable to 

neighboring activities.

But if there's uncertainty about what was happening, then 

I think now we have -- because I find those three lines of 

evidence weak for making that determination, and it's all 

sort of premised on that there was nothing, that there 

were no operations going on.

So I think it is -- there's some relevance to it, because 

we're trying to build some argument about what 

happened in a period where we have very little 

information about what happened.

Mr. Katz: Brad.

Member Clawson: Is this on?

Mr. Katz: It's not on. No, there's a button up there. Yeah. 

Josie's mic.

Member Clawson: I'm broke. My question is as this 

information comes out on the 1,400 boxes, is that only 

being sent to you, NIOSH, or is it being -- because you 

know we look at information a little bit different. My 

question is SC&A available to see any of the printout that 

they get?

Dr. Taulbee: Absolutely, absolutely, yes.

Member Clawson: I was wondering if it was updated to 

them?

Dr. Taulbee: Everything that we've been getting from the 

Department of Energy, based upon those key word 

searches, is uploaded to the DSRB. So SC&A has full 

access to that.

Member Clawson: Okay. That's what I wanted. Thank 

you.

Mr. Katz: Okay. Paul or anyone on the line, other 

questions? 

(No response.)

Mr. Katz: If we don't have other questions, so thank you 

D'Lanie.
87

Ms. Blaze: Thank you again everyone.

Mr. Katz: So we have from the Work Group a motion on 

the table to agree with NIOSH that dose reconstruction 

can be completed. So we don't need to have that put 

forward, but let's have some discussion then, of where we 

want to go from here. 

Member Schofield: Right now --

Male Participant: You have to speak in the mic.

Member Schofield: After what I'm just hearing right now, 

I'm kind of inclined to say let's not take a vote today. I'd 

like to have a little more information before we put a vote 

out on it, just because there's, you know, there's some 

question in my mind that I'll admit at the last Work Group 

meeting I did not have, but now I do. 

I'm a little, and get it reopened or getting it to the point 

it's an 83.14 I think is a higher hurdle. If we can just keep 

it open at this time.

Mr. Katz: Other Board Members, comments, discussion.

Member Beach: I guess in light of what you just said --

Member Ziemer: Well, this is Ziemer.

Mr. Katz: Go ahead, Paul or --

Member Ziemer: Just as a matter of procedure, I think a 

recommendation from a Work Group automatically is a 

motion that requires no second. So we actually have a 

motion on the floor, isn't that correct?

Mr. Katz: That's correct. That's what I, that's how I put 

it. We have a motion on the floor, and we're just 

discussing that motion now.

Member Ziemer: So if we don't want to act on the motion, 

we would need a motion to table or to postpone the vote, 

and that's not a debatable motion once that's made.

Mr. Katz: Correct.

Member Beach: Okay, and in light of that, what I wanted 

to direct to Phil is what exactly we need to accomplish in 

order to move forward or I just want it more defined. 
88

Member Schofield: Well, my big concern right now is the 

whole question of the recent rule. We've got people 

coming up from DeSoto too, so at what level do we know 

who was in and out of that particular building? Were there 

any hot spots around there? I mean I did look at some of 

the EPA stuff, several years, a couple of years back and I 

realized a lot of that is low background.

But I'm still a little nervous about the americium, just 

because it's really nasty stuff if, you know, people get into 

it. That may just be me. I mean maybe I'm just being a 

little over-worried about it, which you know, in that case 

I would go ahead and say let's go ahead and take the 

vote, and we could always, if we have to, task them.

If there's more information comes up, to take a deeper 

look at the question about the americium.

Mr. Katz: Okay. So I need another -- this so from -- if I'm 

understanding you correctly Phil, we don't really have a -

- you're not putting on the table a focused review of 

anything in particular. I mean the hot spots and so on 

don't really relate to this per se, this petition evaluation.

But maybe other Board Members want to direct this in 

one way or another, because we absolutely need an 

action.

Member Lockey: Ted, can I ask one more question? Bob, 

where are you?

Mr. Katz: Bob.

Member Lockey: So this is following up on David. I think 

as -- really what David was asking, from '89 to '91, there's 

no data; correct?

Mr. Barton: No. It's actually from August of 1991 through 

June of 1993 when the data is invalid, the bioassay data's 

invalid.

Member Lockey: No, I understand that. But looking at 

your air sampling data, the air sampling data stops at '89. 

Mr. Barton: Right. We used basically what had been 

captured. So it was already available for analysis, so we 

used it as one tool.
89

Member Lockey: And so what about '90? Was there any 

air sampling data for '90?

Mr. Barton: Not currently captured. That's not to say it's 

not out there somewhere, but it was not available to us.

Member Lockey: And '91 early, same there I guess?

Mr. Barton: Yeah.

Member Lockey: There is some?

Mr. Barton: I used what we could find on the Site 

Research Database, which again is not necessarily 

exhaustive of what's out there possibly in these records 

in Cincinnati or elsewhere. 

But again, sort of the idea there was that well, we're 

trying to use this coworker model for a different period. 

How do we try to get a way to match the two periods, to 

see if it's actually going to be representative or even 

better bounding?

Member Lockey: I understand that.

Mr. Barton: They said well, we have this air sampling 

data. Let's see what we can do with it.

Member Lockey: Okay, thank you. 

Member Schofield: Do we have any data from the stacks? 

The building would have to have had ventilation and stuff. 

I assume, and this may be a bad assumption, that they 

had to monitor the stacks and report those numbers. Do 

we have any of that data available?

Mr. Barton: Yes. There's certainly periodic environmental 

release reports that SED was require to do. In fact, I 

believe those documents were what formed the basis for 

the current ambient environmental model, which is again 

for non-rad workers.

So they use the stack emission data to develop intakes of 

americium and thorium. But again, that sort of approach 

is not really appropriate for a rad worker, which is why 

SC&A recommended that NIOSH look into developing an 

alternate dose reconstruction method specific to 

americium and thorium. 
90

Member Schofield: My only question about is if you're 

saying this, if any of that data is showing release, then 

you know it's got to be in the building getting out. If those 

numbers look good, that gives me a little better feeling 

about potentially what may be inside.

I mean like you said, they're going with the breathing, 

you know, the breath analysis and things like that and 

bioassays. But if they're showing that coming out of 

there, then I don't think you can say coworker data is 

going to work on that, if you take some coworker that 

hasn't been working in that building and try to apply their 

data.

Mr. Barton: Well I guess we run into that problem really 

at a lot of sites where try to create a coworker model to 

encompass everybody, and use a sufficiently high percent 

value from that cover that sort of uncertainty. As I said 

earlier, the dose reconstruction method at Santa Susana 

is not building-specific. 

In other words, we're not looking at a claim and say they 

work in this building, this building and this building, 

therefore they get A, B and C dose assigned. It's a single 

sort of one-fits-all model for all the buildings at Area IV.

Ms. Blaze: Since we're on the topic of Building 23, I just 

went ahead and pulled it up, the EPA. That building was 

also used for the Rocky Flats Plutonium Recovery Project 

in 1987, and in 1989 reports appear to indicate that 

Building 23 served as a support facility for the transuranic 

management by pyropartitioning separation operations or 

TRUMP-S in Building 4020, which was the hot lab.

Atomics International requested DOE's approval to utilize 

the facilities for a two year period that began in July 1988 

for the Kawasaki Heavy Industries, KHI and the Central 

Research Institute. I can -- I've sent this excerpt before 

on TRUMP-S, but if you want it sent, I can just send it to 

you. You can disperse it to the Board.

Mr. Katz: You're welcome to send it. I'm not sure whether 

that's on -- but wait. But we need some suggestion from 

the Board as to if we're going to continue to evaluate, 

about what we're going to evaluate. 

Member Clawson: I'll tell you what. Dealing with Santa 

Susana for all these years maybe is a -- it is a mess. But 
91

what I would like to do, and I know that SC&A has done 

some of this, but they just got these reports. I'd like them 

to evaluate the EPA process of this.

I just don't feel comfortable with it, Bob. I'm not saying 

that you guys didn't do diligence. It's just too short a time 

period for you to be able to evaluate it. I really hesitate 

about trying to make a decision on this.

Mr. Katz: So, do you want them to evaluate the EPA 

report information?

Member Clawson: Right, a little bit more in-depth, and 

also the TRUMP-S part of this is something that's -- it's 

just convoluted, and I'm just not feeling very good.

Mr. Katz: Okay. So the EPA report information and 

whatever information we have on the TRUMP-S attempt 

or whatever they did something, whatever it might be.

Member Clawson: Right, and also, you know, we're 

coming up with new stuff in these boxes and stuff. I would 

like you to just kind of monitor that as that comes out in 

these -- you guys do get that information, right, that 

they're talking about, that 1,400 boxes that Tim just 

talked about?

Mr. Barton: Well, I think it's maybe a little more nuanced 

than that. We certainly have access to everything that 

NIOSH receives and uploads to the SRDB, which can be 

accessed by the Board Members. 

For example, I don't know that we're necessarily in the 

loop as far as communication between the DOE records 

facility and NIOSH, and when new documents come in 

and when new documents are posted. I mean we can 

check periodically, do something like that. 

Mr. Katz: Well, I think they could do better than that 

because I think in this case NIOSH can affirmatively 

inform SC&A if any documents come in that are germane 

on these topics. That's easy to do. I know you're not in 

the process, but... D'Lanie, we're really -- we're trying to 

at this point, we're trying to get the path forward.

Ms. Blaze: The last thing. The location wasn't remediated 

until 1993, and all the materials were taken to the RMHF 

at Santa Susana. So we might expand our view beyond 
92

Building 23, to include the waste handling site.

Mr. Katz: Thank you.

Ms. Blaze: Thanks.

Member Richardson: Can I ask about the process of that? 

I'm wondering whether there would be the opportunity 

for SC&A to add to the list of words, so that it's not just 

NIOSH notifying SC&A when something germane 

happens, but that they could have, make some 

contributions to the definition of what is germane.

Mr. Katz: We do that all the time with documents 

searches and so on. So certainly SC&A can be made 

aware of the key words and so on, and you can add to 

them. Thank you, David. That's an "as might be needed." 

Member Richardson: Yes.

Mr. Katz: Thank you.

Member Field: Ted, this is Bill. In regards to Dave's 

concerns about them using means of means for the air 

monitoring, is the data in such a form that it could be 

looked at in other ways, rather than taking the means of 

means?

Mr. Barton: This is Bob. I believe what we have are just 

the quarterly summary reports that provide the average 

and the maximum for each quarter. I don't believe that 

we have necessarily the raw data underpinning all of 

those reports. That's not to say it's not out there.

Member Field: But it's something that may be -- it may 

give you a little bit more information. You could actually 

get some information on what the max is for. 

Mr. Katz: You have the maxes actually, right?

Mr. Barton: We have the maximum per quarter. I don't 

believe we have maybe location data or how many other 

samples there were that were close to the maximum. 

Again, we have a maximum and then an average value 

for gross beta and alpha by quarter.

Mr. Katz: Right. 

Member Lockey: So I need -- I'm not sure what we're 
93

assigning to be done here. You've gone through the EPA 

report; is that correct?

Mr. Barton: Yes. 

Member Lockey: And so --

Mr. Barton: What we haven't really done is a specific 

write-up to address concerns about it, which includes the 

TRUMP-S documentation, which we've had discussion on 

today. Again, we saw that, petitioner provided that to us 

at the end of March at that meeting.

And so I sort of rushed around and tried to pull together 

what I could. And again, our read at this time was that 

we don't believe it actually got off the ground, but there 

could certainly be more work done on that to flush out 

that position, and if it's deemed not enough information 

at this time, then obviously the option always is to go and 

specifically look for, I guess, TRUMP-S documentation in 

the remaining boxes and perhaps at other records 

locations.

Member Lockey: So if we assign, if we assign SC&A to 

focus on the EPA document and the TRUMP-S documents, 

and then answer questions that have been raised today, 

is that doable in a relatively short period of time?

Mr. Barton: I believe so. I think we've already done a lot 

of the leg work on that. Other questions might arise as 

we write it up, but I think it's really a question of just 

documenting what we found in that EPA study. The 

TRUMP-S part of that is really an extension of that same 

report. 

It's really a whole series of reports developed for site 

remediation and their historical site assessment. So 

they're looking back at what products were done in 

different buildings. But again I remind you, it doesn't 

necessarily mean those projects were done after 1988.

Member Lockey: Right, yeah.

Mr. Katz: Andy first. Andy had --

Member Anderson: We've had an interesting set of 

discussions here, and what I would propose is that we 

make a motion to table the motion that we already have, 
94

and that will just keep it open. But it also keep the current 

review of the committee.

Member Beach: And I'll second that. Does it need a 

second?

Mr. Katz: Yes.

Mr. Katz: Okay, so and, but David, Dave was trying to get 

in a word too.

Member Kotelchuck: Yeah. No, no. I feel very comfortable 

with that choice, and what I would also add is that for 

myself as one Board Member, there were a number of 

issues raised today that I did not understand so well, and 

I would like some time just to look at the record and look 

more carefully again at some of those issues.

I feel like I could personally make a much more informed 

decision. So if there's an appropriate task to be carried 

out, and that will delay and allow us also as individuals to 

look things over, that would be very good. So I support 

the motion.

Mr. Katz: Well that's -- yeah, and that's always fine, Dave. 

I mean whenever you feel like you are not ready to take 

action, you should voice that because we want the Board 

Members to be prepared to act whenever they act, so 

absolutely. 

Member Kotelchuck: Okay, yeah.

Mr. Katz: That's perfectly valid. All right. So we have a 

motion on -- that's been seconded, and it's -- I don't think 

we need, although there's the option of course for 

discussion since we have this motion, and it's been 

seconded. I think we've had a lot of discussion. Is there 

any more discussion about this before we take a vote?

Member Ziemer: A motion to table is not debatable.

Mr. Katz: Okay, it's not -- okay, good. Thank you.

Member Ziemer: Under Robert's Rules. You can't debate 

whether the --

Mr. Katz: Bless you Paul for keeping me on Robert's 

Rules. So we have a vote, and I'll run down the line for 
95

the vote to table this and to pursue the further evaluation 

that we just discussed. I think it's very clear to SC&A at 

this point. So Anderson.

Member Anderson: Yes.

Mr. Katz: Beach.

Member Beach: Yes.

Mr. Katz: Clawson.

Member Clawson: Yes.

Mr. Katz: Field, Bill?

Member Field: Yes.

Mr. Katz: Kotelchuck?

Member Kotelchuck: Yes.

Mr. Katz: Lockey.

Member Lockey: Yes.

Mr. Katz: Richardson.

Member Richardson: Yes.

Mr. Katz: Roessler.

Member Roessler: Yes.

Mr. Katz: I think I heard a yes. It's very quiet.

Member Roessler: Yes.

Mr. Katz: Phil?

Member Schofield: Yes.

Mr. Katz: Loretta?

Member Valerio: Yes.

Mr. Katz: And Ziemer?

Member Ziemer: Yes.

Mr. Katz: Okay unanimous, and it passes, and a very good 
96

discussion. Thank you all for the thoughtfulness that went 

into this, and I think that takes care of this session, and 

we are on break. We'll take this up, I'm expecting we'll be 

taking this up then in August, when we meet in August to 

complete our considerations. 

Thanks, and you can take the mics off of line. Thank you 

Board Members, and we'll be back at -- after lunch, two 

o'clock.

(Whereupon, the above-entitled matter went off the 

record at 12:36 p.m. and resumed at 2:01 p.m.) 

Mr. Katz: Okay, then. We are just back from lunch break. 

Let me check on the line first, and see if I have my Board 

members on the line. Paul, are you there, Dr. Ziemer?

Member Ziemer: Yes, I'm here.

Mr. Katz: Yep, and thanks. And Gen Roessler?

Member Roessler: I'm here.

Mr. Katz: Super. Bill Field?

Member Field: Online.

Mr. Katz: Great, and Loretta Valerio?

Member Valerio: Yes, I'm here.

Mr. Katz: Super, okay. So we have our whole Board. 

David Richardson's not here at the table yet, but we have 

a quorum, and Jim Lockey is also not in his seat yet, but 

he's on his way. Good, and so now we have an SEC 

petition again. 

This time Idaho National Lab, Petition No. 219 for the 

period of '63 to '70, and this is a petition that was taken

up quite some time ago and has gone through a lot of 

deliberation by and work from NIOSH, SC&A and the 

Board. SC&A is reporting out now. Bob, welcome.

Idaho National Laboratory, SEC Petition No. 219

Mr. Barton: Thank you, Ted. Like I said, my name is Bob 

Barton. I'm with SC&A and we'll be talking about SEC00219, which is for the chemical processing plant at Idaho 

National Lab, and specifically the verification and 
97

validation study that was done.

So getting into a little bit of the background here, going 

way back to July of 2015, NIOSH had released Revision 1 

of the SEC-00219 Evaluation Report, and actually they 

released a Revision 2 in February of 2017, but essentially 

the Class definition remained the same. 

It was split into essentially two periods, you know, the 

period from January 1st, 1963 to February 28th, 1970, 

and then the period from March 1st, 1970 to December 

31st, 1974. 

So that Class definition specifically reads as "All 

employees of the Department of Energy, its predecessor 

agencies and their contractors and subcontractors who 

worked at the Idaho National Laboratory (INL) in Scoville, 

Idaho and who (a) were monitored for external radiation 

at the Idaho Chemical Processing Plant (CPP) (at least one 

film badge or TLD dosimeter from CPP), or between 

January 1, 1963 and February 28, 1970."

Well, I skipped a little bit there. So there's Part A is 

essentially you need to have CPP-specific dosimetry 

badge to be included as part of the Class, along with the 

requisite 250 days. 

Part B, again that's for the second period, that's from 

March 1970, December 1974, all you need is an INLspecific dosimetry badge, which could be really from any 

location at INL. It could be from Test Area North, Central 

Facilities, etcetera. 

In March of 2016, the Advisory Board recommended that 

the second part of that Class definition, which is from 

early 1970 through 1974 be accepted, and again that's 

the section of the Class definition that only requires an 

INL-specific dosimetry badge, not a Chemical Processing 

badge.

Concerns remained at that time about the requirement 

for the specific CPP badge, because that's obviously a 

higher bar to be set. Some preliminary investigations with 

NIOSH and SC&A, we determined that the temporary and 

visitor badges were not being appropriately included in 

the Energy Employees Dosimetry File. That is, when 

Department of Labor or NIOSH makes a request to DOE, 

you would get dosimetry results. 
98

But if it was a temporary badge and specifically a 

temporary badge that had not registered a positive dose, 

those were not being correctly attributed to the claim, 

which is obviously problematic if your Class definition 

depends on that information. 

So in response to that, INL and DOE began a very 

significant coding effort, because all of these temporary 

badges and visitor cards are still located in hard copy form 

at the site. So it was a question of properly coding and 

indexing them, so that now when requests were made for 

a given individual's dosimetry file, all of the correct 

temporary badges should be included.

Despite this, the INL Work Group still had some concerns 

remaining about the implementation and the 

effectiveness of such a massive coding effort, and really 

it stems from these visitor cards or temporary badges. 

They really represent the same thing.

They're handwritten on small index cards, you know, 

about the size or the area of a matchbook, and since 

they're handwritten, you have legibility issues. You could 

have some name misspellings or name variations. 

Sometimes they would use nicknames as opposed to the 

full claimant's name, or sometimes they would actually 

use the middle name as if it was the first name, and any 

other types of human error that would be involved in 

taking a handwritten record and coding and indexing that 

so they can identify it at a later date.

Here's an example of one such card. This is actually the 

front and the back of the card. So on the left side is the 

front of the card and as you can see, it just says "Visitor 

Exchange." It has "CPP Area" stamped on it. All the other 

entries are obviously redacted, but you can tell that they 

are handwritten.

The back of the card actually contains the result. In this 

case it was zero. The date, presumably the date it was 

read, but it could also be the report date. We're not 

entirely certain on that, and then that last alphanumeric 

sequence at the bottom, we don't necessarily know what 

that means.

So the Work Group tasks SC&A with developing and then 

executing a verification and validation study, to sort of 
99

test this coding and indexing effort, to see how effective 

it is. We delivered our proof of principle in September 

2016, and it was first discussed in May of 2017.

At that time, the Work Group requested that we expand 

what was essentially a proof of principle to a larger 

section of the claimant population before we actually went 

and executed any of this proposal.

So we expanded it and presented that to the Work Group 

in August of 2017. The full proposal included a total of 

228 potential candidates, and nearly 1,800 temporary 

badges. The Work Group because that's obviously a very 

onerous task, the Work Group elected to begin the 

process with 30 claims that we at SC&A had categorized 

as likely being the most beneficial to this study.

Essentially, they had a larger number of badges that we 

could check. We also wanted to look for diversity of 

employers, subcontractors and different job categories. 

So NIOSH began submitting the request to INL to have 

these updated dosimetry files sent in the fall of 2017, with 

a cover letter that basically said what we were doing here.

It said, "This case is part of a group of 30 cases that are 

being reviewed, in order to evaluate a concern raised by 

the Advisory Board on Radiation Worker Health. Although 

INL previously provided dosimetry responses for this EE, 

we are requesting that INL perform a new record search 

and provide a full radiological record for this EE in order 

to completely address the ABRWH's concern. It would be 

extremely helpful if the full dosimetry/radiological record 

were provided."

And the purpose of this cover letter, it turns out, was the 

staff in INL who was doing the research was commonly 

making the mistake of they saw that research had already 

done for the claim, but were sending the old file, which 

didn't include all these temporary badges which had been 

recently coded.

But based on the first few claimant dosimetry records we 

got back from the site, it was pretty evident that there 

was a problem with the whole process, and it was not 

being correctly implemented. So DOE/INL was notified of 

the issue and a second round of requests were made last 

spring. In July of last year, we provided a status 
100

evaluation. We had 18 of the 30 claimants with updated 

dosimetry records.

So rather than wait for the full set of 30, we decided to 

go ahead and look at those 18 as sort of an interim 

analysis. It was evident that two of those 18 claims that 

we were able to evaluate, that the system really was still 

not functioning properly.

One case had been missing all 31 of the visitor badges 

that SC&A had identified, and the other case only had 6 

of 49 of the temporary badges we identified correctly 

included in their file, which is about 12 percent.

So NIOSH resubmitted a request for a third time for these 

two claims, along with requests for the remaining 12 that 

we had not yet received records for, and we got all of 

those for all 30 claims as part of the V&V proposal by midOctober, and that's of last year.

So here are the overall results. In total, we looked at 671 

total visitor badges that covered those 30 claims who 

were in the first part of the V&V study, and 634 of those 

671 had been correctly included in the updated dosimetry 

files, which is between 94 and 95 percent. 

Half the claims, so 15, had 100 percent of the visitor 

badges that SC&A had identified correctly included in their 

updated dosimetry records. 

In an update on those two cases that I had mentioned 

from last July that were clearly problematic, the one case 

that had none of the badges included improved from none 

of the 31 to 30 of the 31, which is roughly 97 percent, 

and the other case improved from 12 percent inclusion to 

96 percent inclusion.

Another thing we did besides just checking badges based 

on the name and the employer, where you want to have 

an exact name match and an exact employer match, we 

were noticing some name variations, and that was one of 

the concerns as I mentioned that the Work Group had, 

when you have a handwritten record and someone's 

writing down a name. Did they spell it correctly? Are there 

variations?

So among that group of 30 claimants, we actually had 51 

additional badges in which we had seen what we felt were 
101

name variations, where it seemed potentially or likely that 

that was the actual claimant, but with a name variation; 

would those still be included correctly in the file?

And only 15 of those variations, 15 of the 51 that SC&A 

had defined were actually included in the updated files, 

which is a little under 30 percent. However, we also took 

the view from the other side and said okay, we identified 

some name variations. Some of them weren't included, 

but what about other name variations that are in there 

that we hadn't identified, that DOE when they did their 

research and sent the record, they identified and 

included? In other words, how much leeway do we have 

when they go to select which records are actually 

attributable to the claims?

We found that additional name variations in 22 of the 30 

V&V claims that again, SC&A had not identified but DOE 

had, and so that was 66 variations in total. One 

interesting thing in this last bullet on this slide is that 

sometimes the name variation, you have the same name 

variation for multiple badges. 

For example, if you had John Doe and one of the -- two 

of the John Doe badges didn't have H in the first name. 

One time it might be included and another time it wouldn't 

be included so it wasn't necessarily consistent. So even 

when you had the same name variation, it wasn't always 

either included or not included. There's a mix in there.

So I guess in summary, for the V&V analysis, again for 

the 671 badges that we had identified exactly by name 

and employer, we had -- they were correctly included in 

the file 94.5 percent of the time. The average if you look 

at just the claims, so the average among the 30 claims, 

the number's almost identical at about 94.3 percent are 

correctly included.

And again as I said, half the claims had 100 percent 

inclusion of their identified temporary badges. The two 

cases with significant issues identified in July improved 

from 12 percent to 96 percent, and zero percent to 97 

percent.

And again, the name variations identified by SC&A

showed that about 29 percent of those variations were 

included. But we also identified 66 additional name 
102

variations that we hadn't identified, and some of these 

were likely not identified because they weren't actually on 

CPP badges. But they were still included in the file. So we 

wanted to note that there is sort of some expansion when 

they go search for these records, to include some of name 

variations.

And this final bullet, all 30 cases had at least one CPP 

badge during the period of interest, again talking about 

1963 through the early part of February 1970, which is 

the criteria for inclusion.

The workgroup met this past March, March 25th. If you 

were paying attention to Santa Susana, it was also the 

date of that workgroup meeting, so it was a pretty busy 

day for me. Part of that discussion, you know, was what 

happened here? We had to have these multiple 

submissions to really get to these numbers in the high 

90s.

What NIOSH had determined is that early issues with the 

implementation were really related to staffing turnover 

that was going on at the time. They were understaffed 

and also some key pieces that are part of that team that 

researches claims were moving on to different jobs. So 

they determined that it wasn't really a systemic problem, 

but really an issue of staffing.

And they also mentioned or discussed that when we're 

talking about the chance of missing a monitored worker 

who also spent 250 days of covered employment inside 

the facility is very unlikely. The workgroup generally 

agreed with that. 

So the workgroup recommended that the Advisory Board 

accept Part A of NIOSH's proposed Class definition, and 

that's again, that's for workers who are monitored for 

external radiation at the Idaho Chemical Processing Plant. 

At least one film badge or TLD dosimeter from CPP 

between January 1st, 1963 and February 28th, 1970 and 

obviously as I mentioned, Part B of that definition has 

already been accepted. Are there any questions?

Mr. Katz: Board Members in the room, questions? 

Member Ziemer: Bob, this is Paul. I have a question. So 

it took a lot of persistence and multiple requests to get up 

to the 95 percent or whatever it ended up being at the 
103

right end of things. But you're now pretty confident that 

in this, I'll start with the Department of Labor, wanted in 

the requesting part, we're pretty confident that we're 

going to achieve those kind of results now on regular, 

single requests?

Mr. Barton: I can really only comment on the tests that 

we've put it to. So these 30 claims, I guess as far as the 

nuances of what the site is doing now as far as record 

requests and how they've sort of filled in what was clearly 

a deficiency in the implementation of it, and over to you 

Tim. I think you probably have more information on it.

Dr. Taulbee: This is Tim Taulbee. 

Mr. Katz: Is that mic live?

Dr. Taulbee: Is it live? 

Mr. Katz: Okay.

Dr. Taulbee: Dr. Ziemer, what ended up happening with 

those two particular cases was during a staffing, we kind 

of changeover of more inexperienced staff. They relied on 

what they had submitted before instead of going back to 

our original request of develop the full record again, which 

is what we had requested.

And what they weren't quite aware of is that in doing so, 

those temporary badges would be picked up. So by kind 

of repeating what they had done before for us, that was 

why those were missed. At least that's what we can 

discern from that particular exercise. But then when we 

re-requested it, that's when we got the 96 and 97 

percent.

Member Ziemer: Right. I understand that. I'm just going

forward in the future, part of this then is the training of 

the people who have to provide the records? Is that, is 

that part of the issue, or is it a manpower issue?

Dr. Taulbee: It's actually, and I guess in my sense neither 

from that standpoint. The training is certainly, you know, 

always an issue whenever you have new staff. But in this 

particular case, this was add-on to their existing system. 

So this was a case of them not going back to that original 

system and pulling the index.
104

Member Ziemer: Got you, okay. I just wanted to assure 

myself that there's confidence now that we'll capture all 

these records in the future, and I think you're saying yes. 

We have a pretty high level of confidence that this is a 

thing of the past now?

Dr. Taulbee: Yes sir, and one of the other things that I 

wanted to point out, and I believe Ms. Beach brought this 

up during the workgroup meeting, was you know, is it 

possible that we could miss, you know, some again from 

this particular standpoint?

What I want to kind of walk through a little bit here is the 

actual process. When a claimant files a claim with the 

Department of Labor, they're going to request from the 

Department of Energy, did this person work at CPP? 

If they go through this records review and say they 

missed the CPP badge from that standpoint, the next step 

for that claim is to be forwarded to NIOSH, where we get 

the full workup again. So there is actually a built-in 

second check here from that standpoint.

Member Ziemer: Yeah, I got that.

Mr. Katz: Thank you, Tim.

Member Ziemer: Thank you.

Mr. Katz: Josie, did you have a -- or I couldn't tell. Or 

David or anyone.

Member Beach: I was going to ask about those checks 

and balances, and Tim beat me to it. So thank you, Tim.

Mr. Katz: Thanks. David, did you have a question?

Member Richardson: Yeah. I guess I'm thinking about 

different parts of this, because you described, I've made 

like a 2 by 2 table, where SC&A and the lab's response 

both agreed. You said there were 634 of those. SC&A said 

there were 671 total, so that meant that there were 37 

records where the site didn't identify those but SC&A had.

And then there were 66 records where the site said that 

it was a name match, and SC&A said it didn't. So I mean, 

one way is to talk about, you know, run across either the 

row or the column and say well, in total 94 percent of 671 
105

are identified. But like the -- where you both agreed that 

a record occurred was 634, and there were 103 where at 

least one of you disagreed.

Mr. Barton: Almost. There's sort of two different tests this 

was put on. There was the group of the 671 where it was 

an exact name match and exact match to the employer 

of the claimant. We were fairly certain that that badge 

represented that claimant. As a secondary analysis, we 

also identified additional badges that had name variations 

on them, and that's where that 66 number comes in. So 

it's two, two separate analyses.

Member Richardson: But the 37 of the 671 were not 

returned to you? They returned 634 of the 671?

Mr. Barton: That's correct.

Member Richardson: So if we're going to take yours as 

the gold standard and there's agreement on 634 of those, 

they omitted 37 and they returned another 66. I mean, 

I'm just trying to get the number. It's basically one-sixth 

of them are not agreed upon by both.

Mr. Barton: I don't think it's appropriate to mix the name 

variation study with the 671.

Member Richardson: Well, but that's -- you posed a 

question. These are the workers; return to me their work 

history, and that is the information which would be 

returned. That's what the idea of the exercise was, right?

Mr. Barton: Right.

Member Richardson: So we believe that 66 of those were 

-- let's say at least you were not taking a strict kind of 

gold standard of the truth on those?

Mr. Barton: I think the number you really want to look at 

is at 94.5 percent, because those are the ones where 

we're certain that that's the claimant, and they did not 

return five-and-a-half percent that we had identified.

Member Richardson: So that would be the sensitivity, and 

my question is about the specificity. That's another part 

of the -- of characterizing the accuracy of the test. I mean 

I just -- and I'm just working my head through.
106

Mr. Barton: Sure. 

Member Richardson: Oh, and another question. Is this --

there's been a huge effort to computerize this 

information, and we've been focusing on information 

about area or location of the worker, which will be derived 

from this information. Does this change the dosimetry 

information for the site? Were these doses included 

previously for workers? Are there recorded doses? Have 

they been computerized, and how is that getting 

integrated?

Mr. Katz: Tim?

Dr. Taulbee: Sure, I can answer. I'll answer that one. All 

of these temporary badges that got added under this 

coding effort were all zero doses from that standpoint, 

zero external doses. All of them that had positive doses 

had previously been coded, and we had always been 

getting those. It was this group of zero doses that the site 

didn't initially code.

Mr. Barton: So you could essentially be talking about 

missed dose wasn't being included?

Mr. Katz: Other Board Member questions? Yeah, 

someone's typing on the phone. Someone is typing on the 

phone. If you would mute your phone, star six, then that 

wouldn't interfere with everyone else's hearing please. 

And you're still typing unmuted. Again, mute button, star 

six to mute your phone. Thanks. They stopped typing, 

okay.

So if there are no other questions, the workgroup has a 

motion, which doesn't need a second because it's coming 

from the workgroup, to add this Class to the SEC as 

recommended by NIOSH. So is there further discussion 

about that motion before we take a vote?

Member Lockey: Mr. Chairman, I mean Ted, one 

question. Is it 220? Are you talking about 220 people? Is 

that what it is?

Mr. Barton: When we expanded the proposal, what we 

basically found is we could identify 228 people from 

among the 28 or from among the temporary badges. We 

selected 30 of those 228 as what SC&A felt were going to 

be most beneficial as far as the number of badges to 
107

check. So a higher number of badges and also a diversity 

of employer and job category.

Member Lockey: Okay.

(Off-microphone comments.)

Mr. Katz: Yeah, absolutely, Josie.

Member Beach: So just a quick question I think maybe 

for Tim. Saying this goes through today and we pass this, 

and we find later that individuals are not -- they said I 

worked there, but their TLD didn't get found in the 

system. What kind of -- what would the process be at that 

point for that individual? Because it would be one or two 

people, I would say.

Dr. Taulbee: Well first, we would look at their dosimetry 

in total.

Member Beach: So but how would they let somebody 

know? How would we know that there was an issue, 

because I mean 96, 97 percent is great, but that still 

leaves those, that four percent. So how would that person 

be recognized is what I'm looking for?

Dr. Taulbee: Since we would need for that person to 

identify. So I guess during the CATI for one. But if it's a 

survivor, there's no way for them to let us know from that 

standpoint. We do hve all of these records in the SRDB, 

and so, by the way, they're organized, if they can narrow 

down a time period we can go through manually and look 

at every single one and see is there just like name 

mismatch or something along those lines during the dose 

reconstruction process to verify.

So if they put into their CATI that they worked at CPP, we 

could go to those CPP temporary badges and then go 

through and look for them, to see if there is one of these 

name variations or something that did end up getting 

missed. But that would be the way I can see that 

happening.

Mr. Katz: And just to clarify, the four percent is four 

percent of the badges, but not four percent of the 

individuals. None of the individuals were missed by this 

process.
108

Dr. Taulbee: Right. If I can expand upon that, keep in 

mind that we have printed copies for all of the routine 

workers that are there, so there isn't any of this 

handwriting potential issue. These badges apply to the 

temporary workers. These are the people who didn't 

routinely work at CPP. 

So these are your visitors that come in, and that's this 

group that we're getting 95 percent of the badge readings 

correct on with the visitors. The others, like I said, they're 

printed, hard copy printouts from a computer file, and 

those are very easy to read and very easy to identify.

And again, the Class definition only requires one badge 

over this whole time period. Most of these badges are for 

a few days, a week, up to about a month is the maximum. 

So to get to 250 days in CPP, which we're not requiring. 

We're requiring 250 days onsite as a visitor, but the 

likelihood of us missing 12 at CPP for one person is very 

unlikely.

Mr. Katz: Any other discussion of the motion?

(No response.)

Mr. Katz: Okay, then. I'm going to roll call vote. So the 

motion is to add the Class per the NIOSH definition. 

Anderson?

Member Anderson: Yes.

Mr. Katz: Beach?

Member Beach: Yes.

Mr. Katz: Mr. Clawson's recused. Field?

Member Field: Yes.

Mr. Katz: Kotelchuck?

Member Kotelchuck: Yes.

Mr. Katz: Lockey?

Member Lockey: Yes.

Mr. Katz: Richardson?
109

Member Richardson: Yes.

Mr. Katz: Roessler?

Member Roessler: Yes.

Mr. Katz: Schofield?

Member Schofield: Yes.

Mr. Katz: Valerio?

Member Valerio: Yes.

Mr. Katz: And Ziemer?

Member Ziemer: Yes.

Mr. Katz: It's unanimous, with one recusal. The motion 

passes and thank you very much. The Class is added, and 

this will make a real difference for quite a number of folks 

at INL. Thank you.

The next session is the SEC Update, and I think we can 

just roll right into it.

(Off-microphone comments.)

Mr. Katz: Welcome back, Brad. Yes, I see you've come 

back. We missed you. 

(Off-microphone comments.)

Mr. Katz: Are you ready LaVon?

Mr. Rutherford: I am ready. I'm just not working --

Mr. Katz: Grady's still not ready.

Mr. Rutherford: He isn't quite ready yet. See, Zaida and I 

are both playing with this at the same time. 

(Laughter.)

(Pause.)

Mr. Katz: Do you want me to go to some other business 

while you're -- does this look like it's a long road? Okay. 

Let's take care of some other business while we're 

awaiting. So, because the next session after this, I mean, 
110 

LaVon's presentation is useful for part of what we had to 

deal with.

Oh, wait. Are we there? Yeah, there it is. Okay, good. 

Sorry. Back to LaVon.

SEC Petitions Status Update

Mr. Rutherford: All right. I'm LaVon Rutherford. I'm going 

to give the SEC update for NIOSH. 

Mr. Katz: Does Zaida need to give you control?

Mr. Rutherford: Yeah, I think so. 

Mr. Katz: Someone just ask Zaida to pass the baton. 

Mr. Rutherford: This is the hardest I've ever had to do my 

presentation.

(Off-microphone comments.)

Mr. Rutherford: Okay. We routinely do this presentation 

at every Advisory Board meeting. It helps the Advisory 

Board prepare for future Work Group meetings and Board 

meetings. We're going to talk about petitions and 

evaluation, area qualification under evaluation, currently 

under Board review, and potential 83.14s. 

Next slide, please. To date, we've had 251 petitions. As 

you can see it, we have no petitions in the qualification 

process at this time, and we have two petitions under 

evaluation and 149 complete and 10 petitions with the 

Advisory Board.

Next slide. Okay. One petition under evaluation is 

Lawrence Livermore. This is actually a continuation of an 

existing SEC. We reserved the period 1990 to 2014. We 

have been doing data captures and reviewing data. We 

anticipate completing this addendum later this year, in 

November.

Thank you. Y-12 Plant. This is a new petition, 1977 to 

1994. This actually qualified based on the basis where we 

added the Class up through '76. We just recently got this 

petition and we qualified it -- actually, we provided the 

basis to the petitioner to qualify this petition.

We've been working on this evaluation. We anticipate 
111

completing this in July of this year and presenting it in 

August, at the August Board meeting. 

Next slide, please. Okay. Petitions under Advisory Board 

review. These are Hanford. This is SEC-56. We are still 

reviewing documentation to determine whether prime 

contractor's radiological control program were meeting 

bioassay commitments. We've been doing a lot of 

activities with Hanford recently. The Work Groups met. 

We've gone through the issues matrix, identified -- we've 

narrowed that down. We've been doing data captures and 

we're putting forth a lot of effort to get this one moving.

Savannah River Site. We've been putting out some 

documents, coworker documents, and other White 

Papers. I think there's going to be a lot of activity on this 

as well this year.

Los Alamos National Lab. We recently issued a White 

Paper on NC ID 484 and our assessment. We are also 

working on our path forward, mixed fission activation 

products and exotics, and we'll be prepared for a future 

Work Group meeting.

Next slide. Sandia National Lab. We just heard that 

presentation. 

Idaho National Lab, we just heard that presentation as 

well. 

Argonne National Lab West, we are working to resolve 

issues raised by SC&A and the Work Group. 

And Area IV Santa Susana, we just heard that recently 

today.

Next slide. Metals & Controls. A lot of activity going on 

here as well. We've been working on papers on 

petitioners' issues, thorium, a thorium paper, welding and 

thorium welding paper, and those reports are coming out 

very soon. We're also going to work on, once we've met 

with the Work Group and kind of get agreement on a path 

forward, we are revising our Evaluation Report as well.

DeSoto Avenue Facility. We're working to resolve issues 

raised by SC&A and the Work Group. 

And Superior Steel we will be discussing a little later.
112

Okay, next slide. Now, this actually used to be in a big 

table format and it made it easier for our 508 compliance 

to kind of change that. This actually is the sites and the 

years. These are sites that have had some kind of Board 

action, but have action time period remaining to close out 

a petition.

For example, Hanford. We've had a number of Classes 

added at Hanford, but we still have this question of '84 to 

'90 for the primes. Savannah River Site, 1973 to 2007. 

Los Alamos National Lab. Again, we've added up through 

1995 and we've got to address the '96 through 2005. 

Sandia National Lab, again, we discussed earlier '97 to 

2011. INL, this will change a little bit after our recent --

just this past discussion.

Next slide, please. Lawrence Livermore National Lab. 

Again, this is the remaining period on that evaluation, 

1990 to 2014. 

Argonne National Lab West. There actually has been no 

real action on here, but this is the entire time period, 1958 

to 1979.

Area IV Santa Susana is the '91 to '93. 

Metals & Controls, this is the residual period. The 

operational period was already added. 

And DeSoto Avenue Facility of 1965 to 1995.

Okay, next slide. All right. We are working on an 83.14. 

We do plan to present this one at the August meeting. 

This is for the West Valley Demonstration Project. We're 

looking at the AWE period of 1966 to 1973. We have a 

residual period that follows that 1973 period. 

We do have questions that we have sent -- prepared a 

letter to send to the Department of Energy concerning 

whether some of the operational years should be included 

-- or some of the residual years should be included in the 

operational years. 

If we move forward with this one, complete it, and 

ultimately at some point the Department of Energy comes 

back and adds years, we'll just do another 83.14 and add 

those years. And that's it. That's all I've got. Questions?
113

Mr. Katz: Thank you, LaVon. Josie.

Member Beach: Thanks, LaVon. Did you mention Argonne 

East? I see West mentioned twice, but --

Mr. Rutherford: We don't have an active petition for 

Argonne East.

Member Beach: So we're just looking at --

Mr. Katz: Yeah, Site Profile work. 

Member Beach: Oh, okay, thank you.

Mr. Rutherford: Yeah, correct. Ultimately, if the Site 

Profile during that review identifies something, we'll move 

forward.

Mr. Katz: Yeah. Other questions for -- he's running away, 

but do you have any other questions for LaVon before --

from any of the Board Members on the line? 

(No response.)

Mr. Katz: Okay, then, thank you very much. Okay. We 

have quite a bit of time, and I would suggest we just plow 

right into the work session and take a longer break with 

whatever time we have left over, unless anyone needs a 

comfort break now. 

Someone does? Okay. So let's take a comfort break, 

sorry. So why don't we just go ahead and do that right 

now, and if we can get back here in ten minutes, and then 

you get another break after the work session. Thanks. So, 

ten minutes. 

(Whereupon, the above-entitled matter went off the 

record at 2:43 p.m. and resumed at 2:56 p.m.) 

Board Work Session

Mr. Katz: Okay, welcome back. Short break, and we're 

moving right into the Board's work session. 

Okay. So, first things first. We have scheduling, 

scheduling issues. We have both -- we need a location for 

August, and then we need to set dates for a year out for 

teleconference and Board meeting. So let's talk about 

locations first. Hold on one second.
114

(Pause.)

Mr. Katz: Yeah, that's what I have in mind actually. 

Member Beach: Where?

Mr. Katz: So it hasn't been set yet, Josie. Hold on one sec.

(Off-microphone comments.)

Mr. Katz: I need to bring up my notes. Okay. 

So, again, this is a Board work session, and folks that are 

on the line, please mute your phones, by the way, 

because that will be better for you too. Press *6 to mute 

your phone if you don't have a mute button on your 

phone. *6. That will mute your phone for this conference 

line. 

Okay. Locations. So, I went through a number of things 

as to possibilities. LaVon mentioned a couple of that 

would make sense in the way we think about these things. 

So he mentioned that Y-12 is going to be ready for 

consideration by the Board in August. That's an 83.13.

So that's Oak Ridge, and that makes a certain amount of 

sense then to go there and be able to hear from folks 

associated with that petition, who would be affected by 

that petition. There's also an 83.14 that he mentioned for 

West Valley. So, that's the Buffalo area. We haven't been 

up there in a while.

I mean, I guess, between the two, my only thought about 

that is, between the 83.13 and .14, it makes a little more 

sense to be somewhere for 83.13, maybe, in terms of 

being able to get information from people related to the 

petition, since there's a petitioner involved.

Okay. So, beyond those, the ones I looked at and didn't 

think they were ready for prime time, INL we just 

addressed adding the Class. That was sort of a major 

thing in our lap. There's other work to do, by all means, 

and there's been some more work, for example, related 

to the Burial Grounds that's been considered by the Work

Group. But there's nothing that seems ripe for getting 

public input or what have you related to INL for the 

summer, even though it's a great place to go in the 

summer. 
115

Okay. Hanford. Hanford there are a number of significant 

issues, but they don't seem to be ripe for August, from 

what I've heard from the staff at least. And, Joe, if you 

have any different thoughts about that, Joe's sort of the 

SC&A -- yeah, he's shaking his head, so he's in agreement 

about that.

LANL. I thought about LANL. The issue there is that we 

haven't yet had, and couldn't, because we're not ready to 

have the Work Group meeting to deal with a major -- well, 

there's two things. There's a report that's being reviewed 

by SC&A. The major thing is this air monitoring data that 

is thought of as a path forward for that. And there's a plan 

getting developed for that that should be delivered 

shortly. It hasn't been delivered yet, though, so we 

haven't had the Work Group meeting yet. And then once 

it's delivered and we have a plan forward, then there's 

the time it requires to actually execute that plan.

(Off-microphone comment.)

Mr. Katz: Are you trying -- it doesn't sound on.

Mr. Rutherford: Hello?

Mr. Katz: There you are.

Mr. Rutherford: Okay. Yeah, and I will say we are 

initiating some data capture efforts right now. And Los 

Alamos has indicated that they will give us a date on May 

3rd when they will have those data captures ready for us 

to go review data, and I will make the Work Group aware 

of that. So I don't anticipate August being good either.

Mr. Katz: Okay, okay. That's what we wanted to 

ascertain. Thank you, LaVon. 

(Off-microphone comment.)

Mr. Katz: Okay. But at least we'll have -- we'll see 

progress there. Savannah River Site's another one I 

thought about. Not so much to collect information; we've 

been there many times back in the past for that, because 

now, at this point, what we're trying to wrap up is the 

analyses related to making decisions on Savannah River 

Site.

And the issue there is that SC&A is working on reviewing 
116 

material as rapidly as they can as it's coming out from 

NIOSH, and they are looking at the coworker models 

already. And there's another document that's important 

related to this, another issue related to the data 

underlying coworker models that's coming out from -- it 

hasn't come out yet from NIOSH, though. 

And while NIOSH would like to address SC&A's review as 

quickly as they can, when they can't it's sort of hard to 

predict the steps forward in terms of how quickly that will 

happen. The timing is like --

(Telephonic interruption.)

Mr. Katz: Hello. Someone's not on mute that should be. 

But, anyway, the bottom line is that it would be cutting it 

right on the edge there, and we'd rather not do that. That 

doesn't make much sense. So, and Augusta in the 

summer is warm. Living in Atlanta, I could tell you that 

much. Okay.

So, those are the sites that I've given thought to. If Board 

Members have other thoughts about other sites, I guess 

that's what I want to hear from first, and otherwise let's 

talk about the two that I think make the most sense. 

Okay. So, again, we have Y-12. That's an 83.13. and we 

have 83.14 for West Valley. That's Buffalo area. So what 

are your thoughts about between the two?

Member Beach: I think Oak Ridge myself, the 83.13.

Member Clawson: Oak Ridge.

Member Schofield: Have we been to Buffalo?

Mr. Katz: We have. I mean, not recently. We had a lot of 

AWE work in Buffalo some years ago. So we've been up 

there quite a bit, but we haven't been there in a while. 

But it's an 83.14, so the presumption is that we're adding 

it. 

So I'm hearing nods in the room. And how about on the 

line, Paul and Gen and Bill and Loretta?

Member Ziemer: This is Paul. My preference would be Oak 

Ridge. 
117

Member Field: Oak Ridge sounds good.

Member Roessler: This is Gen. I say Oak Ridge.

Mr. Katz: Okay.

Member Valerio: This is Loretta. I say Oak Ridge as well.

Mr. Katz: Okay, okay. Oak Ridge it is. Okay, Oak Ridge in 

August, and the dates right now are the 21st and 22nd. 

And my guess right now is that it will probably be a little 

more than a day. 

I'll just remind you about a couple of things. One, we need 

every year our ethics training, so that will be when we will 

get that done. And then we also have, as I mentioned 

earlier, the rulemaking related to the shift of ICD codes. 

So we'll need to take that up, even though I don't expect 

that to be a very difficult session, because, -- as 

presented, it's largely a technical issue. But just the 

same, we need to have a session on that. Yes?

Member Kotelchuck: But I hope to have a draft of the 

Secretary's Report.

Mr. Katz: Right, and that's the other thing, is that Dr. 

Kotelchuck has been working on the Secretary's Report, 

another interim report on dose reconstruction reviews, 

and that should be -- we will have a Dose Reconstruction 

Subcommittee meeting before August in May.

Member Kotelchuck: May 23rd.

Mr. Katz: May 23rd. So we hope if that goes well that we'll 

have a draft report ready for the Board. So, yeah, it's 

sounding like more of a day and a half meeting, and we'll 

also expect to have Santa Susana SEC again. Then we 

may also have DeSoto ready then. So there are a number 

of sessions ready.

Okay. So, that's it. And then scheduling dates. So, 

teleconference. We're looking for the next teleconference, 

which is as yet unscheduled. That's February of next year. 

So, February, the week of February 17th is what we will 

be looking at. 

Member Ziemer: February 17th.
118

Mr. Katz: Folks on the line, there's some people talking 

who should be muted. Please mute your phone. Press *6 

to mute your phone if you don't have a mute button. 

Member Beach: So, February 18th? Is that what you're 

suggesting, Tuesday?

Mr. Katz: So any Wednesday, Tuesday. Wednesday, all 

good, whatever your preference is.

Member Beach: Either.

Mr. Katz: So the 18th Josie just suggested, is the 18th 

good for -- is the 18th bad for anybody?

Member Kotelchuck: That's a Tuesday, right?

Mr. Katz: That's a Tuesday. Does that work?

Member Kotelchuck: Yeah.

Member Beach: Maybe we should do Wednesday. He has 

a hard time on Tuesdays.

Mr. Katz: Okay. We don't want Brad to have a hard time. 

We'd like to have Brad to have a hard time, but not this 

kind of hard time. Okay. So the Wednesday, that's the 

18th.

Member Beach: The 19th.

Mr. Katz: Oh, 19th? Sorry. 

Member Beach: Yeah. 

Mr. Katz: Exactly. 

Participant: That's a conference call, right?

Mr. Katz: February 19th teleconference, 11 o'clock. Okay. 

And then for the face-to-face meeting, the approximate 

date is around the week of April 20th. So I think the 20th's 

probably a Monday. So we usually shoot for -- so the 22nd 

to 23rd. How's that for people, April 22-23?

Member Kotelchuck: Okay. Yeah, 22-23. No, I was 

thinking about tying it up with the weekend, but we don't 

usually do that. 22-23 sounds good.
119

Mr. Katz: And folks on the phone, does that sound all 

right, April 22-23?

Member Ziemer: Just before we decide, do we know when 

Easter and Passover are next year?

Member Beach: I just checked. I was just looking. Palm 

Sunday is on the 5th so --

Mr. Katz: Easter's the 12th.

Member Kotelchuck: Right, and make sure we don't do 

Passover.

Member Beach: So that would be clear.

Mr. Hinnefeld: Ted, this really doesn't affect me, but by 

our calendar there's a NIOSH lead team meeting that 

week.

Mr. Katz: Oh, that's all right.

Mr. Hinnefeld: All right, that's okay?

Mr. Katz: I don't mind. 

(Laughter.)

(Off-microphone comments.)

Mr. Katz: Are you saying the 15th and 16th would be 

better? Is that what you're saying? Well but I can just 

raise it. Let's see. What about the April 15th-16th? How 

does that look on people's schedules?

Member Kotelchuck: Tax day.

Participant: Yeah, that's not good.

Mr. Katz: Don't pay your taxes. 

(Laughter.)

(Off-microphone comments.)

Mr. Katz: Okay. So maybe that's not so good. 

Member Kotelchuck: It's not a good time.

Mr. Katz: All right. Going, going, gone. April 22nd-23rd. 
120

Okay, thank you for all that. 

Okay. So let's go to Work Group reports, and then I'll do 

wrap with the public comments after that. So I think I will 

officially get through some of these without help, because 

I know nothing is reportable yet.

So, Ames, nothing reportable. 

Argonne East, nothing reportable yet. Blockson, nothing 

reportable yet. 

And, by all means, contradict me if I'm mistaken. But, 

Brookhaven National Lab, nothing's reportable yet. 

Carborundum. The Work Group wrapped up with the 

Board. There is some work ongoing there. I can just save 

Dr. Roessler the trouble of -- there is some work 

undergone. SC&A's looking at, if you recall, there's some 

modeling getting done, very technical work. And SC&A, 

Bob Anigstein's looking at that now and should be 

reporting out by the end of the month. So we'll be having 

a Work Group meeting some point after that, and 

hopefully we'll wrap up the Site Profile work on 

Carborundum. 

Okay. Dose Reconstruction Review Methods. 

Member Kotelchuck: Nothing.

Mr. Katz: Nothing there, right.

Member Kotelchuck: Nothing planned. 

Member Beach: Ted, did you say Brookhaven or did we 

just skim by?

Mr. Katz: I said there was nothing to report yet but is --

Member Beach: There's supposed to be a TBD review out 

on 6/26/19.

Mr. Katz: Right.

Member Beach: So I guess that's the only thing, keeping 

that all plugged in there.

Mr. Katz: Thanks. Okay. We've retired several Work 

Groups. We've finally retired formally Fernald, and Grand
121 

Junction was already retired. 

Hanford, there's some work ongoing. Brad.

Member Clawson: Yeah. Actually, they're doing some 

data capture this week, and I believe next week, and 

they're supposed to be getting us a report out fairly soon.

Mr. Katz: Okay. And I think there's a lot of interest in 

trying to move forward on Hanford. 

I know we've talked about briefly, but is there anything 

more anyone wants to mention, Phil, on INL than this?

Member Schofield: Not at this point, no.

Mr. Katz: Okay. Lawrence Berkeley. Paul?

Member Ziemer: Let's see. Am I on hold?

Mr. Katz: No, you're open. I hear you.

Member Ziemer: I'll just report that the Work Group had 

a teleconference earlier this month on April 5th. We are 

working through a number of issues from the SC&A 

review of the Site Profile. We made pretty good progress, 

but there's still a number of open issues we'll be dealing 

with as we move forward. 

I'm not going to go into any detail now. Perhaps at the 

Oak Ridge meeting we'll have some additional detail. I 

don't think we'll give a full report until we've gotten all 

the issues closed. But we made pretty good headway 

earlier this month.

Mr. Katz: Thank you, Paul. 

And LANL we've talked about. 

Metals & Controls. Josie, is there more you want to add 

about that? There was a little from LaVon on that.

Member Beach: We've got the write-up, the questions 

that you submitted. So, we got that at the end of March, 

and we are expecting the thorium and welding White 

Paper at the end of this month, actually on the 25th. The 

response to the petitioners isn't expected until June. And 

then I think the dates may be incorrect. They say the final 

ER draft is expected in May, but I really don't think we'll 
122

see that until after the Work Group finishes up. So, is that 

correct?

Mr. Katz: Here comes LaVon.

Mr. Rutherford: The June date's incorrect. That paper's 

much farther along than that. But you are correct. The 

Evaluation Report would come out after those papers.

Member Beach: Okay, yeah, because your website's --

Mr. Katz: So you're saying May, a May ballpark?

Mr. Rutherford: Yeah, I will -- as soon as I get an updated 

date, I will pass that on to you, Josie.

Member Beach: Okay, thanks.

Mr. Katz: Okay, and then we'll be having a Work Group 

meeting. Okay. So that means also very likely we'll have 

Metals & Controls on the agenda for -- well, I can't 

presuppose what's going to be in the reports, but it's a 

good chance we could have Metals & Controls on the 

agenda for August. It will be a busy August maybe.

Member Beach: Yeah.

Mr. Katz: Mound.

Member Beach: Mound, we're just still waiting for that 

external TBD, and the new date is 4/4 but we're past that. 

So there's no update on that date at this time.

Mr. Katz: Okay, and Nevada?

Member Beach: None forthcoming it sounds, it looks like.

Mr. Katz: Nevada Test Site.

Member Clawson: We're still waiting. 

Mr. Katz: We're still waiting for a little bit to get wrapped 

up between -- who's the lead for NTS? Mark. But what did 

the Board coordination report say about NTS in terms of 

--

(Off-microphone comments.)

Mr. Katz: Yeah. SC&A did a review and we're waiting on 
123

one piece of that, at least, to be responded to. 

Mr. Rutherford: Yeah. Currently, we're still working on 

that response. I don't have a date right now on that.

Mr. Katz: Okay, all right. 

ORNL, X-10. Gen?

Member Roessler: I've heard nothing new on that. Maybe 

if Lara's on the phone she can respond.

Mr. Katz: Lara is right here in the room. Thanks, Gen.

Dr. Hughes: Yeah. That's correct. We don't have any 

update right now. We're still working on the responses to 

SC&A comments on Report-90. This will take a few 

months to develop, because they were rather extensive.

Mr. Katz: Okay, good. Okay, and then we have a number 

of retired sites, and we are on to -- well, Portsmouth, 

Paducah, K-25, we're still awaiting some piece there. 

Rocky Flats.

Member Kotelchuck: LaVon informs me that the folks at 

Rocky -- the folks at NIOSH are going to be looking at the 

last four boxes of data at LANL about Rocky Flats, which 

is very good. And remember we had that earlier 

discussions where there were a number of things that 

hadn't been looked into. 

I'm happy to say that, after we made the decision, NIOSH 

followed through and looked at the boxes and has gone 

through nearly all of them. One more trip, I hope, and

that will be done.

Mr. Katz: That's super. Thank you. Okay. Sandia we've 

been on that. 

Santa Susana, we've done that. Savannah River Site, I 

chatted about that. Is there -- there's nothing much more 

to say. There's been -- there's a lot of work that's coming 

to fruition, so there will be Work Group activity and so on. 

Probably Work Group at least. There will be Work Group 

activity very likely before the Board meeting. But, if not, 

closely after the next Board meeting, which is great to see 

that coming forward. 
124

Science Issues. Oh, this is our time now. So, just to 

remind everyone from the last Board meeting, we had a 

discussion about DDREF, and a presentation by Stu -- or 

a discussion by the Board Members. And after that, as we 

discussed at the Board meeting, Dr. Richardson, who 

leads the Science Issues Work Group, distributed a 

memorandum with findings. And, David, you could take 

over from here.

Member Richardson: Thank you. Yeah, just to very briefly 

go through the chronology, the Oak Ridge Center for Risk 

Analysis developed a fairly lengthy report on the topic of 

dose and dose rate effectiveness factors in support of 

calculations of Probability of Causation for this program. 

And so that came out in 2017. We've had discussions of 

those drafts, as well as presentations of the content, an 

earlier discussion of it.

And surprisingly for such a technical issue, the topic has 

generated a lot of attention recently in the peer-reviewed 

scientific literature. And what we've ended up with is a 

draft memo that was circulated to the Working Group, and 

I believe is --

Mr. Katz: The whole Board.

Member Richardson: The whole Board. Would you like me 

to read that in, the text of that?

Mr. Katz: Yeah, if you would. And just to note that all of 

the Board Members responded individually on this. There 

wasn't discussion, of course, the discussion happened at 

the Board meeting. But just to indicate their support for 

what's in this memorandum and summary of findings.

Member Richardson: Okay. So I'll read the text. "The 

Advisory Board on Radiation and Worker Health is 

submitting comments pertaining to use of the Dose and 

Dose Rate Effectiveness Factor, DDREF, to support 

calculations for determining Probability of Causation 

(PoC) under the EEOICPA.

"Board Members bring a range of experiences and 

expertise to this task, and we were able as a Board to 

assess the approach used by NIOSH and described in 

detail in Coker 2018 and the report by Oak Ridge Center 

for Risk Analysis." What follows are eight points. 
125

"Use of the DDREF is currently implemented in NIOSH's 

approach to determining Probability of Causation and is 

represented by a distribution of values. The report 

prepared by the Oak Ridge Center for Risk Analysis 

proposes a similar but somewhat shifted distribution of 

values. That report concludes that the available evidence 

is uncertain with regards to DDREF. 

"This distribution in the report by the Oak Ridge Center 

for Risk Analysis has been discussed in the literature, and 

other distributions have been discussed in recent 

literature associated with work by the International 

Commission on Radiation Protection.

"We agree that the literature on low dose protracted 

radiation-associated cancer risks are evolving and 

encompass a range of estimates. The report by the Oak 

Ridge Center for Risk Analysis proposes a distribution with 

a mean and median that are closer to one than the current 

distribution used in the program.

"The literature suggests uncertainty between lines of 

evidence, and may suggest a model for uncertainty that 

reflects a mixture of distributions. NIOSH aims to use the 

best available science and methods to address

determination of PoC. 

"The Board notes a difference between compensation and 

protection decisions and radiobiological research. NIOSH 

has recommended postponing implementation of a 

revised DDREF distribution to allow for additional 

information based on ongoing studies, and to allow for a 

concurrent update of IREP risk models and assumptions.

"The Board agrees with NIOSH's recommendation and 

suggests that this issue should be monitored for future 

consideration. The ABRWH appreciated the opportunity to 

comment on the report and its proposed revision of 

DDREF as used in determining PoC. Sincerely."

Mr. Katz: Thank you. Thank you. So, that's entered into 

the record. And I don't think it requires any more 

discussion, unless any Board Members want to say 

anything more. But everyone concurred with that memo. 

Member Kotelchuck: Right.

Mr. Katz: Okay, then. Thank you very much, Dr. 
126

Richardson, for that. 

Member Richardson: Just for the record, one comment I 

received was to add an additional citation to the draft of

the memo, that Paul Ziemer suggested, and I've added 

that, and I'll circulate that with the updated reference list 

to you.

Mr. Katz: Thank you. Yeah, which thankfully you didn't go 

through the reference list, but that will be included in the 

record, too, so that’s that -- and I think we'll just take this 

memo also and put it on the NIOSH website separately, 

so that you don't have to go to the transcript to find out 

what was said. So we'll get this up on the website shortly.

Okay, then. Let's see where we are now. 

Okay. Andy is the Chair of SEC Issues Work Group, but 

there's been no action there to talk about. 

And next we go to Dr. Kotelchuck with the Subcommittee 

on Dose Reconstruction.

Member Kotelchuck: Well, we will begin meeting again on 

May 23rd, and basically we're going to go over the 

number of blinds that have been completed. I think it's 

like 25. And then there's a new set of dose 

reconstructions for us to go over, Set 26. And I hope to, 

as I noted, I hope to submit a draft of the report to the 

Secretary at the May 23rd meeting. 

Mr. Katz: Terrific, thank you. And on to Procedures 

Review. Josie.

Member Beach: Okay. I have three pages written up, but 

I think I'm going to shorten it just a bit. 

The Subcommittee met on February 13th. We had four 

carryover items, none of which were officially closed. So 

I'm not going to go into those. I think I'll go into these, 

the ones that we ended up closing.

We had ten new reports that were submitted to the 

Subcommittee by SC&A. Of those, I think we closed out 

about four, but most of those were the Subtask 4s. The 

OTIB-0086 internal dosimetry for coworker data 

completion test. SC&A had no findings with that. They did 

have three observations. The first one was variables can 
127

be set by the user. The second one, original data set 

terms confusing to the reader. And, of course, these are 

abbreviated; the full transcript is available. And the third 

one was an editorial edit error. NIOSH agreed to make 

the changes the next time the procedure is reviewed, and 

the Work Group agreed with that and closed all those 

observations. 

The second one was PER-0076. It was a Subtask 4 at a 

uranium rolling facility and Aliquippa Forge. SC&A 

reviewed one case that was impacted by the changes to 

the TBDs for internal and external dose in the residual 

period. There was no findings or observations. 

The Subcommittee accepted that report and we closed 

that officially. Those should all be updated in the BRS 

also. 

So, the PER-0081 was also a Subtask 4. That was a 

Hooker, Revision 3. SC&A reviewed two cases with no 

finding and two observations for that. The first one was 

on external. It wasn't wrong, but it was unusual in the 

way that dose conversion factor for the skin, usually used 

as a 1.0 according to OTIB-0017. Normally or -- they 

normally use the OTIB-0017. In this case they used IG001. A lot of discussion on that.

The second observation is why the dose went up. Intake 

increased, yet dose decreased from the original dose 

reconstruction. Again, that was discussed and the 

Subcommittee was convinced by that discussion and we 

closed that Subtask 4.

Mr. Katz: Josie.

Member Beach: Yes.

Mr. Katz: Let me make your task easier, I think. Because 

for document reviews that are like Site Profile type 

documents and so on, after the Procedure Subcommittee 

closes them, they'll have to be reported out to Board in 

more full fashion, and everybody will understand it, and 

understand how that review was closed.

Member Beach: Okay.

Mr. Katz: For the PERs, I mean, these details about the 

case reviews really, unless you've read the whole PER and 
128

the case reviews --

Member Beach: You wouldn't know.

Mr. Katz: -- it's hard to follow. So I think you don't need 

to report out those.

Member Beach: Okay.

Mr. Katz: Just which ones, which procedures have been 

put to bed by the Procedures Review, and any new ones 

that are coming on. I think if you tell the Board that 

information that will keep them up to date with how we're 

doing.

Member Beach: Okay, all right. So I think I'll carry that 

over to the next time then, since new --

Mr. Katz: Yeah, sure.

Member Beach: But I do want to report on my last item, 

is NIOSH, they updated the BRS to capture findings that 

may arise after the Subcommittee completes their review 

and presents their findings to the full Board. The BRS now 

is capable of capturing and distinguishing between both 

the Subcommittee findings and the full Board findings and 

issues. 

So that is something that was just updated after our last 

meeting. I looked at that. It was a good point to bring 

that up and capture the differences between the two 

groups.

Mr. Katz: Right.

Member Beach: Okay, thank you.

Mr. Katz: Right. In fact, in some cases we've already been 

recording the Board action, yeah, so that's a great 

improvement and thank you to the Board for helping get 

that improvement made, and, of course, to NIOSH for 

doing the work. 

Okay. TBD-6000, that's Paul.

Member Ziemer: Right. I don't have anything to report on 

TBD-6000.

Mr. Katz: Right. We do have some work underway that 
129 

will go before that Work Group, but that work isn't ready 

yet.

Member Ziemer: Right.

Mr. Katz: That Work Group will be meeting at some point 

this summer, I expect. 

And then the Uranium Refining AWEs, which Andy is the 

Chair, but there's no report, I could say, for that. 

Then Use of Surrogate Data, that is also Paul. I don't 

believe there's anything to report, but Paul if you want to 

correct me.

Member Ziemer: No, I have nothing to report.

Mr. Katz: All right, and that takes care of the Work 

Groups. Thank you, everybody. 

Okay, then. Now I will run through public comments.

Public Comment

Mr. Katz: So these are public comments from our 

December Board meeting. 

Okay. We had comments related to Santa Susana Area IV 

and DeSoto, in part related to Boeing's record responses 

and DOE responding about trying to work out issues with 

Boeing, and NIOSH is supporting DOE's effort in that.

Okay. We had a -- I think I addressed this, actually, at 

the meeting. I did, so I don't need to address it now. It 

was a Hanford discussion about expediting matters at 

Hanford, and we are working on that. 

Okay, and we had Rocky Flats. We had a comment about 

-- okay. We've already heard a report about that. It 

relates to the boxes that were to be reviewed, and we 

heard they're down to their last four boxes on that. Dr. 

Kotelchuck reported on that. We also had a comment, 

which I think I addressed it in real-time, about petitions 

that don't qualify. 

Okay. Savannah River, we had a comment, which was 

also addressed in real-time, about extending the petition. 

Stu had addressed that, because the petition had been 

specific to construction workers. Okay. Another comment 
130

about Savannah River related to hoping to see progress, 

and we've talked about that. And I have spoken with the 

commenter about this, who's keeping in touch with me 

about that. 

And then, similarly, about LANL and Sandia. We've talked 

about those. They're looking for progress. That's from the 

person we heard from on behalf of Senator Udall, Ms. 

Jacquez-Ortiz, hoping just to see as rapid progress as 

possible and we know where we are with that.

Hugh Stephens had commented -- I think I addressed 

that in real-time; I did, yeah -- about Superior Steel 

getting assigned to a Work Group, which we did, we had 

done. And some other comments he had made in person 

had been addressed at the meeting related to breathing 

zone samples.

Metals & Controls, a number of comments. The summary 

about Metals & Controls from the petitioner, those are 

getting addressed. There's going to be a whole White 

Paper addressing the petitioner's comments related to 

that. So that will be directly responsive to the comments. 

And, yeah. That takes us to the end of the comments. Any 

questions from Board Members on any of these?

Okay, then. I do believe that takes us through all of our 

Board work sessions. We have Superior Steel updates. 

That begins at 5:15, and let's try to get here five minutes 

ahead of that so we can deal with that in proper time. In 

the meantime, we are in recess.

(Whereupon, the above-entitled matter went off the 

record at 3:36 p.m. and resumed at 5:14 p.m.) 

Mr. Katz: All right. Before we get started on our last 

session before the public comments, which is Superior 

Steel SEC, this is an update. It's not a conclusory session 

here. We're just getting caught up. And, also, this is an 

opportunity for people in the Pittsburgh area to learn 

about what we're doing here related to this local site. So, 

it's in progress.

Before we get to that, let me just check and see that we 

have our Board Members on the line. So --

Member Ziemer: Paul Ziemer here.
131 

Mr. Katz: Thank you, Paul. 

Member Field: Bill Field.

Mr. Katz: Thanks, Bill.

Member Roessler: Gen here.

Mr. Katz: And Gen, thanks.

Member Valerio: Loretta here.

Mr. Katz: And Loretta. You sound like -- Loretta, you 

sound like you're in the room. Thanks. And then, Andy, 

are you on too?

Member Kotelchuck: No, Andy is away.

Mr. Katz: No, I know. He was going to join us -- I traded 

emails with him. He was going to get on by phone from 

the airport. Okay, I don't hear him, but I wanted to make 

certain we had a quorum, and we do. And so --

Mr. J. Palastro: This is John Palastro.

Mr. Katz: I'm sorry?

Mr. J. Palastro: John Palastro.

Mr. Katz: Oh, okay, thank you.

Mr. J. Palastro: John Palastro.

Mr. R. Palastro: Rich Palastro.

Mr. Katz: Right. Thank you very much. And, for the 

petitioners, let me let you know that we're going to have 

a couple of presentations here to bring you up to date 

with what's going on with this petition evaluation, and 

then you'll have an opportunity to comment as well. 

But, like I said, you may not have been on the phone, but 

this is really an update session today, to let everybody 

know where we are, and to hear whatever comments you 

might have to the petitioners and their representative. 

So, carry on. Thanks.
132 

Superior Steel Company, SEC Petition No. 247

Dr. Lobaugh: Hi, everyone. My name is Megan Lobaugh, 

and I'm the HP from DCAS that worked on the Evaluation 

Report for Superior Steel, SEC-247. So, can everyone 

hear me on the phone?

Mr. Katz: I think so.

Member Ziemer: Yes.

Dr. Lobaugh: Great. So, this is just going to be a quick 

recap of what I presented in December. In that 

presentation, you found out that we evaluated this SEC 

petition and found that dose reconstruction is feasible. 

But I'll just go through a quick summary of what we talked 

about in December, and a quick summary of the 

Evaluation Report.

The Superior Steel Company site is nearby here in 

Carnegie, Pennsylvania. It's a series of five 

interconnected buildings that you can see here in this 

picture on the right. They were contracted with the AEC 

to do uranium rollings, specifically for reactor fuel 

elements, and their covered period for our program is 

broken into two sections.

So, the AWE period, which is the operations period when 

their contract was valid or active, January 1st, 1952 

through December 31st, 1957. And then there's a residual 

radiation period from January 1st, 1958 through the 

present, and that's through the present because no fullscale remediation has occurred at the site.

These two pictures show the processing areas, just in 

schematic form. Again, as I said, they did uranium rolling 

specifically for fuel elements of reactors, and the 

processing starts on the right side of the picture with the 

salt bath and progresses all the way to the left.

So the top picture is more general and points out some 

areas that are discussed in some of the source documents 

that we used, and then the bottom specifically shows the 

uranium rolling process. So, starting with the salt bath 

where the uranium was heated up, then a run-out table 

and roughing mill, roughing roll, through a brushing 

station where the salt was brushed off, and then finishing 

sands. So this is just a quick schematic of how that 
133

processing would go.

Some specifics for the SEC-247 petition. It was a 83.14, 

or Form B, petition that we received May 1st, 2018. The 

petitioner requested class was all workers who worked in 

any area at the Superior Steel Company facility in 

Carnegie, Pennsylvania during the period from January 

1st, 1952 through December 31st, 1957.

So this coincides with the entire operations period, the 

entire AEC contract period. There was an F-1 basis that 

radiation exposure is potentially incurred by members of 

the proposed Class were not monitored, either through 

personal monitoring or through area monitoring. We 

qualified that petition on July 19th, 2018 with the 

qualified Class given there. 

There are several pieces of information that we at DCAS 

need to do a dose reconstruction, and the first one we are 

interested in is exposure time. So this would be the 

contract period or the amount of time that radioactive 

material was onsite, and then also, you know, the time 

per day that a worker would be exposed. 

So the information that we used, typically, is contract 

information. So these first two, first three bullets, 

actually, kind of go over some of the contract information 

we have, just a quick summary. So, we know the contract 

number. Unfortunately, we don't have a copy of the 

contract. But we know that their contract was awarded 

around the same time as Metals and Controls. So Metals 

& Controls has kind of become a surrogate contract for 

several evaluations that have been done for this AEC 

contract that was written for Superior Steel.

We do know the effective date is June 27th, 1952, and we 

know that contract ended September 30th, 1957. One 

note that I have here is there is evidence that the fission 

material accounting station -- something AEC uses to 

account for the amount of material onsite -- that authority 

wasn't withdrawn until the end of November 1957.

So, even though their contract to do rolling ended in 

September, they could have had material onsite through 

November. So this is, I would assume, part of the 

reasoning why DOL goes through the end of 1957 as that 

operations period.
134 

This contract was a cost plus fixed fee contract. So what 

that means is it was intermittent work. There wasn't, you 

know, daily uranium rolling done. It was on demand and, 

as AEC needed and had a need for them, they would send 

uranium to be rolled.

We have information about the payments, the annual 

payments from 1952 through '57, and we have a total 

payments made to Superior Steel through '57. 

So we used that information. I'm not going into the 

specifics of our proposed DR methodology in this talk 

today, but we provided some information in the 

Evaluation Report about how we would use that 

information.

The CATI information that we have from the dose 

reconstruction claims that we've already worked tells us 

that overtime work was very common at the site. So 

that's another assumption that we would make in any 

proposed DR methods that we have.

So, aside from exposure time, we need to know about the 

radiological sources that were present onsite. The 

majority of the rolling that was done for the AEC was 

natural uranium metal. We have evidence of one AEC 

rolling campaign that involved some enriched uranium, 

and that was actually six slabs amongst a total number of 

slabs that day that included natural and enriched 

uranium. But we know of six slabs of enriched uranium, 

enriched at about 1.5 percent, that were rolled as part of 

one of the campaigns. 

One other thing to note is that, since this uranium rolling 

occurred after 1952, one of the default assumptions that 

we make is the uranium metal could be recycled. So what 

that means is there could be other radiological 

contaminants within that material, and we account for 

that in how we assign the dose. 

The thorium, I'll talk a little bit about this and try not to 

for too long, but we found evidence that the AEC awarded 

Superior Steel a license to have, transfer, and use 

thorium metal.

The initial request for this license by Superior Steel 

requested 700 pounds of thorium to be used. That initial 

request, I think, was in the March timeframe of 1956, if 
135 

I'm correct, and they had actually a license amendment, 

again, another request for unlimited amounts about a 

month or two later.

And we have seen no evidence of thorium being shipped 

to or shipped from Superior Steel. So we don't think that 

a commercial, large-scale rolling activity occurred, and 

we don't see any contamination in the radiation surveys 

that were done as part of remediation, potential 

remediation efforts post the operations period.

So, in the 1980s up through about 2015, 2016, 

remediation surveys -- radiological surveys were done for 

remediation purposes and they don't show thorium 

contamination onsite. So that's what leads us to believe 

that there was never large scale thorium rolling onsite.

But because of the initial license amendment saying 700 

pounds, and then the request for unlimited quantities 

mentioning test rollings that were done with thorium, we 

assume that at least 700 pounds of thorium were rolled.

So, that's the radiological sources that are present. So, 

what about the levels that are possible? There we used 

monitoring data. So, what monitoring data do we have 

available? For internal exposure, we know there's no in 

vitro or in vivo results, and there's no evidence of an 

internal dosimetry monitoring program for Superior Steel. 

But there are four campaigns of air monitoring that the 

Health and Safety Laboratory from the AEC did during 

uranium rolling that they were performing for the AEC. So 

there are four dates where HASL went out and took some 

air samples. The two campaigns in 1955 including 

breathing zone samples as well. The two in '53 were 

general area samples. 

For external exposure, there is again no external 

dosimetry results and there's no indication of an external 

dosimetry monitoring program onsite. We also don't see 

any indication of area monitoring that was done. 

So, in these cases, NIOSH relies on the process 

information that we have. So, what processes were done, 

what source material was onsite, which this information 

for us is coming from the AEC contract information that 

we have, the radiological material licensing that we have, 

the processing that we know was done onsite, and the 
136 

type of material.

So we have information for all of these, from all of these 

sources that will feed into our assumptions for dose 

reconstruction.

Member Richardson: Just to clarify, I thought you didn't 

have the contract.

Dr. Lobaugh: We don't have the specific contract, but we 

have the surrogate contract for Metals & Controls, which 

was awarded for the same time -- for the same type of 

work that was done.

Member Richardson: Okay.

Dr. Lobaugh: And we have an analysis of that contract for 

other remediation purposes, FUSRAP and Army Corp of 

Engineers analysis of the contract as well. I will say, too, 

sorry, we have the licensing contract information. So we 

have material licensing information for the site too.

So, for dose reconstruction feasibility, NIOSH has 

sufficient air data and process information to bound 

internal and external doses from the uranium rolling from 

the AEC contract. We have sufficient information, process 

information to bound internal and external dose from the 

small-scale commercial thorium metal rolling operation.

What I didn't mention in this presentation now, but I 

spoke about in December, we do not have specific data 

to thorium. But what we propose to do in that case is a 

mass loading approach, where we would take the -- we 

would calculate the mass that was loaded on the air 

samples during the uranium rolling, which would have 

been very similar to the processing that was done to the 

thorium rolling, and we would convert that to a thorium 

activity in order to assign intake from thorium.

And this is very similar. This is the same approach that 

was done at Bridgeport Brass, but at Bridgeport Brass we 

are actually reducing that number based on the 

throughput of thorium versus uranium metal rolling that 

was done. In this case, we're proposing just to do a direct 

comparison.

Given the information that we found and evaluated during 

this Petition Evaluation, the Site Profile for Superior Steel 
137

will be updated with this additional information that we've 

captured. 

To speak specifically to the petition basis that we received 

for internal monitoring, the petition basis was a quote 

directly from the Site Profile for Superior Steel. And this 

was, individual uranium urinalysis data are unavailable 

for Superior Steel workers and none are known to exist. 

When personal internal monitoring data are unavailable, 

NIOSH uses air monitoring data from worker breathing 

zones in work areas. This is in accordance with our 

implementation guide.

For Superior Steel Company, we have sufficient sitespecific air monitoring data and process data to calculate 

estimates of worker internal uranium doses with sufficient 

accuracy. And, as I mentioned before, the airborne mass 

loading calculations, we can perform airborne mass 

loading calculations using the available uranium process 

air data to estimate worker internal thorium doses.

The petition basis for external monitoring again came 

from the Site Profile for Superior Steel. And this quote

was, "No external dosimetry results are available for 

Superior Steel employees. When personal and area 

external monitoring data are unavailable, NIOSH uses 

workplace information." So the source term information, 

the process information that I spoke about, we use all of 

that information to estimate dose in accordance with our 

implementation guide.

So, specifically, we have sufficient applicable site-specific 

information using the methods that we've laid out in 

Battelle TBD-6000 to model the potential external 

uranium exposures. For thorium, we would also model 

these exposures in accordance with that Battelle TBD6000. So we would use the methods and assumptions and 

defaults in TBD-6000 to model the thorium exposure.

Here is just a summary of our feasibility findings. With 

that, I'll take any questions.

Mr. J. Palastro: You're using -- this is John Palastro. You're 

using --

Mr. Katz: Excuse me, John. At this point what we do is we 

have Board discussion, and we will get to petitioner 

comments after that. 
138

Mr. J. Palastro: Okay.

Mr. Katz: But we actually have another presentation, and 

then we'll have petitioner comments.

Mr. J. Palastro: Okay.

Mr. Katz: You're welcome. Before we get to that, let me 

just ask Board Members. Do you want to hear from Rose, 

SC&A's update on where they are with their evaluation 

first, and then do both Megan and Rose at the same time 

with questions? Or is that --

(Off-microphone comments.)

Mr. Katz: Yeah. So why don't we hear from Rose, and 

then we'll have questions from both of them, and then 

we'll go on to the petitioners. Rose, are you on the line?

Ms. Gogliotti: Okay. Yes, I'm here. I'm trying to get 

control of the screen here.

Mr. Katz: Okay. Right now, Rose, you're not even a mouse 

squeak of volume. 

Ms. Gogliotti: Can you hear me now?

Mr. Katz: That's better, yeah.

Ms. Gogliotti: I'm sorry. I'm losing my voice. and I'm 

normally soft spoken, so I'm going to do my best here.

Mr. Katz: Yes, you are soft spoken.

Ms. Gogliotti: All right. When I put this together, I didn't 

realize Megan was going to give her presentation. and she 

did a great introduction and summary of what I wanted 

to talk about. But some of these slides are going to be a 

little redundant, so I will move through those a little 

quickly.

My name is Rose Gogliotti. I am a health physicist at 

SC&A and --

Mr. Katz: Rose, you're really light.

Ms. Gogliotti: I've got my hand speaker on and -- okay.

Mr. Katz: That's better.
139

Ms. Gogliotti: Can you hear me now?

Mr. Katz: That's better, thanks.

Ms. Gogliotti: My name is Rose Gogliotti, and I'm a health 

physicist with SC&A. I'm in charge of the main evaluation 

for SC&A in this process. As mentioned and introduced, 

we're talking about Superior Steel here, and it's located 

in Carnegie, Pennsylvania, so not far from where you're 

currently meeting.

It was a metal processing facility and the site was selected 

among three principal contractors involved in AEC's initial 

fuel element development program, and that was to 

fabricate strip and plate steel elements for reactors. They 

had a cost plus fixed fee contract for intermittent, on 

demand rolling.

What that means is they were paid a fixed price per rolling 

mill hour, and only performed rolling when it was 

requested of them. The site had roughly 100 employees 

at any given time, and the covered period extends from 

1952 to the end of 1957.

Megan went over these dates, but I will call out that the 

main reason the petitioner has requested this result or 

this evaluation was that there's no urinalysis data and 

there's also no dosimetry data. The petition did qualify for 

evaluation and they were qualified based on almost 

exactly the same language as requested.

NIOSH put out their Petition Evaluation Report in 

November of 2018, and discussed it at the Board meeting 

in 2018, in December. At that time, SC&A was tasked to 

do review. We are in the process of finishing up our review 

now, and so I can't give you final review details. However, 

I will highlight some of the main concerns that we have 

throughout my presentation. I hope to have that out by 

the end of the month, but it just depends on editing 

schedules currently. 

In order to do our review, we reviewed documentation in 

the Site Research Database. We read quite a bit of 

documentation, but I will call out some of the most 

important things that we found. The Health and Safety 

Laboratory, the HASL monitoring studies, there's four of 

them. There's also the U.S. Army Corps of Engineers, a 

preliminary assessment study, as well as several other 
140

pre-remediation studies to quantify exactly how much 

residual contamination remained on the site. And there's 

also the thorium licensing communications.

We did review 100 percent of CATI reports. The vast 

majority of those were conducted with survivors rather 

than actual employees. We also reviewed the Superior 

Steel TBD, and that's the current revision. NIOSH has 

indicated that they will be revising that documentation, 

but it's helpful for background information. And we 

reviewed TBD-6000 in the context of this report That's 

the general AWE uranium TBD. 

Now, the source term at Superior Steel, there were two 

main areas of source term. The first is the biggest one, 

and that's the uranium. And we know, based on the 

contracting, that they performed some variation of salt 

bathing, rolling, brushing, shaping, cutting, stamping, 

and coiling of uranium metal.

The records indicate that this was predominantly natural 

uranium. There was one small campaign that Megan 

mentioned of six slabs of enriched uranium that was 

processed onsite. Also, based on the time period, it was 

likely recycled uranium, and that is accounted for in the 

NIOSH documentation.

As I mentioned previously, there was no internal or 

external monitoring for uranium that was done onsite. 

However, we do have the four HASL studies. Two were 

done in 1953 and another two were done in 1955. These 

studies have roughly 17 breathing zone samples and 144 

processed air samples, and these are relied on 

extensively to quantify the source term.

Additionally, during the course of the SEC evaluation, it 

was discovered that there was some thorium processing 

done onsite. The initial TBD did not mention thorium at 

all, but during the course of discovery it was found that 

there was a single thorium processing that was done 

onsite, and that was included.

This is thorium processing that was done for a commercial 

client, Babcock & Wilcox, on March 27th of 1956. The site 

applied to receive licensing for thorium, and this was a 

short-term license to do exploratory thorium milling. 

Shortly thereafter, the site applied to have an amended 
141

license to include forging, rolling, finished rolling, and 

cutting of unlimited quantities of thorium, and that was 

granted on April 30th of 1956.

In that communication, they mentioned a test rolling. So 

we do know that some rolling was done, but we don't have 

a lot of details beyond that. The site was licensed to 

possess up to 700 pounds of thorium, which correlates to 

four ingots of material. In the initial licensing application, 

it was indicated that they intended to only use one of the 

ingots; however, they wanted four just in case. 

So it's likely that they used less than 700 pounds, but 

NIOSH goes ahead and assumes that they used the 

maximum 700 pounds for that rolling. Despite them 

requesting an extended licensing, we don't see any 

evidence of additional rollings that were done. We don't 

see receipt or shipping of materials or work orders that 

would support thorium work in a more commercial scale.

Additionally, there's no evidence of thorium 

contamination found during the remediation efforts to 

quantify how much material was onsite at the time. 

So, because I think it's really easy to get lost in the dates, 

I put together a timeline. So, the contract was awarded 

on June 27th of 1952, so roughly seven months after the 

covered period begins. And it was terminated on 

September 30th, 1957. So, three months or so before the 

close of the covered period. And this is fairly common with 

covered periods, only because it allows for, as Megan 

mentioned, material coming onsite before the contract 

and material leaving after the contract. They did have 

their fissile material station authority withdrawn in 

November of 1957, so we do believe at that time uranium 

was not present onsite. 

The other dates I want to highlight are the two 1953 HASL 

monitoring air samples, and then also the two 1955 HASL 

monitoring air samples. What's important here is only 

that they were done prior to thorium coming onto site.

Now, in evaluating this SEC petition, there are a number 

of challenges. Obviously, the biggest one would be that 

there is no worker monitoring, and that's the reason that 

the petitioners requested this evaluation. So, there's no 

internal or external monitoring.
142

Air sampling was only done on a few limited occasions, 

those four dates that we mentioned. The original contract 

documentation was destroyed. And then there's minimal 

information regarding thorium onsite. So, despite that, 

NIOSH has their approach for reconstructing internal dose 

for uranium.

In order to do this, they make a number of key 

assumptions. The first, which I believe is the most 

important assumption, is the length of time that was 

spent milling per year. Now, we know that the site 

performed demand milling, but the exact amount of time 

that they spent milling is not documented anywhere.

And so NIOSH approached this problem through the use 

of annual contract billing. Megan mentioned they do have 

the amount that was billed per year, and from that 

information they try and back into the number of milling 

hours that were performed.

The challenge with this approach, however, is that 

contract documentation was completely destroyed, so the 

cost per milling hour is unknown. In the absence of a 

known milling rate, NIOSH assumes a milling hourly rate 

of $132 per milling hour, and that is the Vulcan Crucible 

& Steel or Aliquippa Forge hourly milling rate in 1948. 

Using that, they result in 414 milling hours per year, and 

NIOSH rounds that up to a more claimant-favorable 500. 

Now, I think this is important for several reasons, the first 

being, to SC&A's knowledge -- I queried John Mauro, 

who's our AWE expert extensively on this -- the bounding 

source term has not been done based on contract billings 

in combination with another site's billing rate data in the 

manner that it's being done here.

We understand the rationale for doing this, but we believe 

that the Board will eventually want to weigh in on the 

acceptability of using data in this way. The closest 

similarity that we could find in the other AWE sites was at 

GSI, and at GSI they used contract billing rates to 

estimate employee work hours. So, slightly different but 

a similar approach.

Finally, although the data being used here does not meet 

the Board's criteria to be called surrogate data, because 

it's exposure -- or it's not exposure data and instead it's 
143 

the billing rate, I do believe that there's enough parallels 

with the Board's -- with the term surrogate data that it 

does need to be evaluated against at least some of the 

Board's surrogate data criteria.

In our review, we do provide a surrogate data evaluation. 

In that, we find that the results are generally very 

plausible and we agree that it makes sense. However, we 

think that there needs to be additional justification for the 

process similarities between Vulcan Crucible and Superior 

Steel, because Vulcan Crucible rolled rods while Superior 

Steel rolled strips. We're just not positive on the impact 

of billing price for the difference in process.

We did do a cursory look, and the only other site I was 

able to find with a milling rate hour was Joslyn 

Manufacturing Company, and they have a milling rate of 

$88 per hour. If you were to use that billing rate, you 

would increase your number of mill hours by over 200. 

Now, Joslyn also was rolling rods rather than strips, so 

I'm not sure how applicable that is, but that will be a 

source of future discussion. 

Then, with the milling time established, NIOSH intends to 

use air concentration results from the four HASL studies, 

and for that they assume 100 percent of uranium is U234, and they'll account for RU using the TBD-6000 

guidance.

Now, to assign the distribution, NIOSH asserts that the 

1953 and 1955 HASL studies represent separate exposure 

distributions, and they say that because the geometric 

mean associated with the 1953 air data is statistically 

higher than that of the 1955 data. So NIOSH intends to 

assign two air distributions, one from the start of 

operations through May 1955, and the second for the 

remaining time period of operations.

Now, to evaluate this, we broke up the data into the 1953 

and the 1955 data, and here you see a histogram showing 

the air monitoring data overlapping and showed by year. 

I realize this is a little hard to see. I ran into some 508

compliance issues and had to change my graph. But, from 

that, we see very similar distributions.

I just want to point out that there are several very high 

values and they are important to us. But for the sake of 
144 

looking out the distribution, we can zoom in and shorten 

the bandwidth. Here we see that the 1953 and 1955 data 

follow a very similar distribution in terms of where this 

data -- how it falls on the histogram.

To further evaluate this, we broke the data out into box 

plots based on the actual year -- or the actual survey 

results. This is a box plot. If you're not familiar with box 

plots, the basic premise is the data is ordered, and 25 

percent of the data is placed through each segment of the 

box plot. 

So, 25 percent of the lower tail, 50 percent in the center 

box, and the upper 25 percent is in the upper tail. It's 

difficult to make out from this visualization, so I'll zoom 

in momentarily. But I want to point out that three of the 

four highest values fall in 1953.

So, statistically, you would expect, if you delete three of 

the four highest values, you're going to have a different 

geometric mean. But when we actually zoom in on these 

results closer, we notice a few things, the first one being 

that the May 1955 results are significantly lower than the 

other two, three studies.

But I also want to point out that the September 1955 

results are not that statistically different from the 1953 

samples. And when you actually look into the HASL 

studies, they do discuss this. And we find out that there 

was a change in process between the May and September 

sampling results.

At some time in that process, they included slab brushing 

into their process, and the slab brushing of the slab oxides 

resulted in a considerable amount of airborne uranium 

oxide contamination. And it also exposed the bare metal 

to air oxidation throughout the rest of the milling process.

And I will point out, I think, that I forgot to mention 

earlier, the May 1955 results, they are statistically lower 

and the HASL studies did also point out that was because 

of the introduction of man cooling fans. However, those 

gains that they saw in the 1955, or the May 1955, were 

lost in the September 1955, and that's because of the 

change in process.

Based on this, I think it's difficult to draw the conclusion 

that the May and September results are different enough 
145 

from the '53 results that they need to fall into their own 

distributions. And that impacts a number of things down 

the line that we'll also discuss here.

Now, thorium is a little bit easier. For the internal thorium 

dose, despite its commercial use for thorium it is covered 

under EEOICPA, just during that AWE covered period. And 

to monitor internal exposures, NIOSH assumed that the 

material was thorium-232 and its daughters were in 

secular equilibrium. 

There's a single ten-hour rolling period, and this is likely 

bounding for four ingots of uranium or thorium, 

considering the site regularly rolled over 30 slabs of 

uranium in a day.

NIOSH will establish the thorium air concentration using 

a mass loading approach similar to what was done at 

Bridgeport Brass. Megan mentioned this already, but in 

that process the mass loading of thorium was correlated 

to the mass loading of uranium.

For Bridgeport Brass, we used ten percent, and SC&A did 

evaluate that in 2017. However, in this approach they're 

using a more claimant-favorable assumption that the 

thorium mass is equal to the uranium mass. They're also 

using a resuspension rate of the standard 1E to the 

negative-5, and that's used throughout the complex, and 

the source term depletion based on OTIB-0070. And 

they're assuming that the end of the thorium or the date 

of the first thorium licensing all the way through the end 

of operations. 

For external uranium exposure, NIOSH is using 500 

rolling hours and TBD-6000 default worker assumptions, 

as well as the FGR-12 dose conversion factors. This 500 

number is based on the billing cost and the rates 

calculation that we discussed previously for internal 

uranium. And I think that number is questionable, but for 

this, NIOSH is using that approach and they're applying 

that to both direct rolling and submersion.

There's also an assumption of 500 hours of storage using 

the external one meter dose rates from TBD-6000. And 

that assumes 250 hours of pre-storage and 250 hours of

post-storage. I think this number is also going to be the 

subject of some discussion. If you assume the 500 hours 
146 

rolling, then you also have to assume that it was one tenhour rolling per week, which would mean that the 

material was brought onsite the day before the rolling was 

rolled and left the following day. And when you look at 

the shipping results and the material present onsite, I 

don't believe you can draw that conclusion. NIOSH also 

assumed the remaining time on the site, 2,000 hours of 

post-rolling, and that's using both direct exposure and 

submersion. For external thorium, NIOSH is again using 

the ten hours of rolling that was previously assumed, and 

that's a single day of rolling, and the TBD-6000 guidance 

for both direct and submersion. They also assume 190 

hours of storage time for the thorium, and that equates 

to the 19 days in between the initial thorium license and 

the request for future thorium licensing. And that's a tenhour work day, so 19 times 10.

For the remaining operations period, NIOSH is assuming 

post-rolling and using direct exposure and submersion 

using the TBD-6000 guidance and also the FGR-12 Dose 

Conversion Factors.

And, finally, occupationally required X-ray examinations. 

SC&A did extensive research. We found no evidence of 

examinations being conducted, and that it includes no 

evidence of X-ray equipment was onsite, as well as no 

references to employees being required to have X-rays.

We did review all the CATIs and there was no statements 

indicating that examinations were performed. And that's 

similar to what NIOSH found. However, they intend to 

assign a pre-employment annual and termination medical 

X-ray dose for all employees during the AWE operational 

period. And, to do that, they're going to use OTIB-6, 

which we see used throughout the complex. On face 

value, that seems like the most claimant-favorable 

approach. But, in light of the Board's dedication in recent 

years to increase the consistency across sites, I do 

wonder if that's consistent with the remaining AWEs, 

because I don't believe that all AWEs that have no 

evidence of examinations are assigned annual preemployment and termination medical X-rays.

And that wraps up my presentation. Are there any 

questions?

Mr. Katz: So, thanks, Rose. Your voice held up just fine. 
147 

That worked. So, now, questions for either Megan or Rose 

from Board Members in the room?

Mr. J. Palastro: Yeah, Megan, this is John Palastro. 

Mr. Katz: No, John, John, John. You'll be up after we have 

questions for the people who've just presented. So, hang 

in there, hang in there, and then we'll call on you, okay?

Mr. J. Palastro: Okay.

Mr. Katz: Thanks.

Member Beach: Can I go?

Mr. Katz: Yeah, Josie.

Member Beach: I was interested in the surrogate data and 

can you give me the years that you're using the Vulcan 

Crucible Steel data? Is it the same timeframe or --

Ms. Gogliotti: That's from 1948, is the study.

Member Beach: '48 'til -- is it just that year?

Ms. Gogliotti: Oh, I'm sorry. The Vulcan Crucible & Steel, 

that value was from the 1948 contract. But it's being 

applied to all years in this contract.

Member Beach: So it was only for 1948, but it's being 

used for '53 through '57, right? Is that correct?

Ms. Gogliotti: Correct.

Member Beach: Okay, thank you.

Dr. Lobaugh: But how we actually do that is we -- if I can 

just point out here. So we know the total contract 

information, that they were paid $356,849 through that 

whole time period, 1952 to '57. And then looking at the 

annual payments for fiscal year 1954 through 1957, the 

year with the maximum payment was 1956 at $217,246. 

So a majority of what they were paid was paid in 1956. 

We have indications that part of these payments would 

have been towards equipment upgrades and things like 

that, but we don't have specific numbers for that. So what 

we do is we take that number and we assume -- or 

actually we look at that number and we know that there 
148 

is other things influencing that. Because the other 

payments for the three years were consistently in the 

range of $40- to $55,000 per year. 

So, since we don't see any indication of an increase in 

production in that year either, so, 1956, looking at our 

Table 7-1 which lists all the rollings that we have 

information about, we say that that number really isn't all 

production.

And then we use the highest payment for the other three 

years, which is fiscal year 1957 at $54,632, and that's 

how we come up with 414 mill hours.

Mr. Katz: Thanks. 

Member Richardson: So, to clarify, because at first I 

thought that the contract, both of you referred to it as a 

cost plus fixed fee contract, and that can include 

investments in upgrades of equipment?

Dr. Lobaugh: Yes.

Member Richardson: Okay.

Dr. Lobaugh: Yes, it can.

Member Richardson: And so over none of it can you 

actually separate out those investment costs from the 

hourly. So you're just making --

Dr. Lobaugh: A total assumption that all of the money, 

except for that year where it was much higher in 1956, 

we assume that it's all milling hours. So no equipment 

payments.

Member Richardson: And there's no indication that it's 

equipment. It's just an assumption because it's higher?

Dr. Lobaugh: No. There is indication that they were 

requesting equipment from the AEC. We just cannot tie it 

directly to any specific amount that they received, or even 

specifically to 1956. But we do have indication that they 

were requesting additional equipment.

Specifically, some of the other equipment that we see that 

we know they installed, such as the man cooling fans and 

other things like that. But there was a request for actually 
149 

improving the rolling equipment as well. So, that could be 

tied to that 1956 fee.

Mr. Katz: Other questions in the room or for Board 

Members on the line? Board Members.

Member Roessler: This is Gen. No questions, but those 

were two nice presentations.

Mr. Katz: Thank you, Gen. 

Member Richardson: Could I ask about the thorium 

contracts? It seems like the basis for thinking that the 

activity was limited to 700 pounds of thorium is to some 

extent the absence of information, not the presence of 

information. So the absence of either contamination 

found or the absence of contracts related to thorium. 

It made me wonder about if you were just to change that, 

what sort of -- there's a lot of information that seems to 

be absent, just because all the contracts, as stated, all 

the contracts were destroyed. There would be similar 

information absent about uranium. So how does the 

absence of information about contracts relating to 

thorium provide a basis for believing that there were only 

700 pounds of thorium ever worked with there?

Dr. Lobaugh: So, one thing, the initial AEC contract is 

what was destroyed. We have other, like I said, the 

licensing contract with the AEC or the licensing 

information for AEC. And even though, yes, we're basing 

the fact that there was no large-scale thorium rolling 

based on the fact of absence of information, we're basing 

the fact that thorium rolling occurred based on the 

information we do have.

So, we have the licensing amendment that Superior Steel 

requested at the end of April requesting the unlimited 

quantities, and in that they say they did test rollings. So 

that's how we know it happened. So, that's the 

information we do have about what did happen.

Member Richardson: But that seems to be the one sort of 

-- so you do have a piece of information which was the 

request to go from 700 pounds to unlimited, and that's 

taken as the basis, the documentary basis for thinking 

that there was never more than 700 pounds?
150 

Dr. Lobaugh: Yes, no. The basis for not having more than 

700 pounds is the fact that there is no contamination 

seen. There's uranium contamination seen in the 

remediation surveys that were done, and we would 

expect, if a large scale thorium rolling operation occurred, 

we would see thorium contamination in a similar pattern 

onsite, and we don't see that.

There was another point I wanted to make about what 

you were saying. If it comes back to me, I'll say it. But, 

so, the lack of contamination tells us that there was no 

large scale thorium, and -- oh, that's what it was. As Rose 

said, which I didn't mention in my talk, the license 

agreement was for commercial work.

So this was not AEC work. The thorium work was not AEC 

work. So the thorium work would only be covered during 

the AWE operations period, during the AEC contract 

period.

Member Richardson: Right.

Dr. Lobaugh: So that was just another point I wanted to 

make.

Mr. Katz: Josie.

Member Beach: So, Rose made a point of saying that the 

two samples that were done by HASL were done before 

the thorium was onsite, and then you just mentioned the 

contamination. There wasn't any. What sort of surveys 

were done looking for the thorium?

Dr. Lobaugh: Yeah. So let me actually just turn to that. 

We have a table within the ER report where we list the 

surveys that were done. I'm just going to flip to it quickly. 

These were post-operations, and I think the first one was 

in 1980. 

It's on page 22 of the Evaluation Report, if you have it.

Member Beach: I do.

Dr. Lobaugh: So this is the listing of the radiological 

surveys that were performed at the Superior Steel site, 

and these were done in support of FUSRAP and other 

remediation efforts that will hopefully be happening 

onsite. So the first one was in 1980, and then the most 
151 

recent one was in 2014.

So we have five surveys that were done. Now as we point

out, I believe it's in the appendix or attachment to this 

Evaluation Report, we discuss a little bit more about what 

measurements were done and whether the thorium would 

be seen.

I think the most telling one would be the most recent 

survey, 2014, where gamma scan surveys were done with 

sodium iodide detectors. In there, that's where we see 

the lack of thorium contamination. 

We see natural thorium in natural distributions around the 

facility, where we see elevated levels of uranium in a 

spatial distribution that we would expect for large-scale 

rolling. So did that answer your question, Josie?

Member Beach: So from '57, you have no survey data 

until --

Dr. Lobaugh: No. 

Member Beach: -- '80s?

Dr. Lobaugh: Yeah, that's correct.

Member Beach: Thank you.

Mr. Katz: Other questions? 

All right then. Now it's time for petitioners' comments. So 

the Palastros, I think let's start with you first on the line?

Mr. J. Palastro: Yeah. 

(Simultaneous speaking.)

Mr. Katz: And if you'd just introduce -- would you please 

just introduce which -- I don't -- which Palastro we're 

hearing from. 

Mr. J. Palastro: Can you hear me?

Mr. Katz: Yeah. I just don't know your name, your full 

name.

Mr. J. Palastro: John.
152 

Mr. Katz: John, thank you.

Mr. J. Palastro: You're assuming that the material came 

in one day, they rolled it, and it left the next day. Is that 

correct? On your report.

Dr. Lobaugh: Not necessarily. So we make an assumption 

of the total amount of time that the material would have 

been onsite. 

Mr. J. Palastro: Well --

Dr. Lobaugh: Go ahead.

Mr. J. Palastro: Keep in mind that there was a lot of scrap 

come off of that, and they had a rail car there, and they 

put all our scrap in a rail car. And that material was also

radioactive, and it sat there until the rail car was full.

Dr. Lobaugh: Okay. I made a note of that. Thank you.

Mr. J. Palastro: And the other question I had was if you 

don't have any documentation of any readings taken at 

Superior Steel, my father worked there and I was in that 

mill 100 times. You're using a different environment to 

base your studies on.

Superior Steel was a very confined area. So anything that 

had more square footage than Superior Steel would have 

had a lower, a lower volume of radiation as far as their 

milling and brushing and shearing. That's the questions I 

have. I don't know how you can use the area from 

somewhere else for Superior. And am I correct? I'm 

assuming that you took a different place?

Dr. Lobaugh: No. So, John, what we're proposing to do or 

what we currently do in the TBD and what we're proposing 

to do is use the site-specific air monitoring data that we 

have from the HASL studies. So that's the Health and 

Safety Laboratory with the AEC. They performed four 

campaigns where they came out when uranium was being 

rolled for the AEC contract, and they performed air 

sampling throughout the facility.

So we're proposing to use the site-specific data for 

Superior Steel to determine internal exposures for the 

workers at Superior Steel. For external dosimetry, what 

we are proposing to do or what we do is use TBD-6000, 
153 

which is a default calculation for uranium rolling and 

uranium processing for the entire program that we run 

here with EEOICPA. 

And then for the thorium, we would use those same 

methods and assumptions, but using the thorium 

information we have for Superior Steel.

Mr. J. Palastro: Okay. Thank you.

Mr. R. Palastro: This is Rich Palastro. You had mentioned 

you made an assumption regarding overtime. Our father 

worked a tremendous amount of overtime during that 

period of time. How would you have calculated that or 

utilized information like that? I mean how do you make 

that assumption? I mean --

Dr. Lobaugh: So what we do in cases of overtime is we 

assume that the workers are working onsite for ten hours 

per day. 

Mr. R. Palastro: Well he worked two shifts many times.

Dr. Lobaugh: So --

Mr. R. Palastro: Which would mean that he worked a lot 

more than ten hours.

Mr. J. Palastro: 16 hours.

Mr. R. Palastro: 16 hours, yeah.

Dr. Lobaugh: So for our typical assumptions and 

approaches, we do have different -- for specifically 

external dosimetry I'll speak about, we have different 

rates based on the number of hours. So we have eight 

hours, ten hours, and then I think 12 hour days. Is that 

correct? Yeah. Or -- yeah, assuming --

Mr. J. Palastro: I'm not sure I understand what that 

meant.

Dr. Lobaugh: So what that means is we make the 

assumption that the employee is onsite working, being 

exposed for those number of hours per day, and then we 

actually apply that for every day of the year, whether it's 

a Saturday or Sunday or holiday or not.

Mr. J. Palastro: So it's 16 versus 10. He's still only going 
154 

to get credit for 10?

Dr. Lobaugh: For specifically to Superior Steel, what we 

proposed was ten hours per day. But that's how we ended 

up with the 500 hours total per year, if that makes sense. 

So our assumption at Superior Steel is that the rolling 

itself took place for 500 hours per year, and then that the 

employees were onsite for a total of 2,500 hours per year.

Mr. J. Palastro: Can I correct you on that for a minute? 

Usually in a mill, they don't work two hours over or four 

hours over, because there's another shift coming on. 

What they'll do is they'll work a whole shift. If you're going 

to work overtime, you're going to -- what they call double 

wide. You're going to work 16 hours. So to assume that 

they would only work ten hours is not right.

Because when a steelworker works over, it's very unlikely 

that they're going to work two or four hours. What 

happens is they're on a special project and they want to 

keep these guys on the job because they're better at it 

than somebody else, so they work 16 hours.

Dr. Lobaugh: Okay, yeah. We'll take this into 

consideration.

Mr. J. Palastro: Thank you.

Mr. Katz: Okay, and if we have other comments from the 

Palastros before we go on to Hugh? Okay then.

Mr. R. Palastro: No. I don't have any more.

Mr. J. Palastro: I don't have any more either.

Mr. Katz: Thanks. All right. Thank you very much for your 

comments. It's these sort of comments from folks are 

very helpful. Hugh.

Mr. J. Palastro: Thank you for your help.

Mr. Stephens: Thank you. I appreciate the opportunity to 

address the Board. I think there was at page 37 of 55 of 

the SEC Petition Evaluation Report a reference to Simonds 

Saw and Steel in Lockport, New York, and perhaps 

maybe, Megan, you could comment on that. This would 

be with respect to the external dosimetry data.
155 

Dr. Lobaugh: Yeah. So currently, what is done in our 

current Site Profile is a surrogate approach using Simonds 

Saw and Steel data to calculate that external dose rate 

that we were just talking about. Does that -- so basically 

we've used data that was measured at Simonds Saw and 

Steel in the current TBD, and apply that for Superior 

Steel.

What we're proposing going forward is actually using our 

TBD-6000, which is our default assumptions for uranium 

processing facilities. At the time that this was -- this TBD 

was drafted, I don't believe we had consensus on TBD6000. So that's why we used a surrogate site.

Mr. Stephens: Thank you. I think we've tried to obtain 

with a FOIA request information from the Department of 

Energy showing this sampling data, and apparently there 

was some sort of mix-up as between CDC and the 

Department of Energy, and that's being worked out right 

now.

So we should get that information relatively soon. I spoke 

with someone named Emily Fitzgerald from CDC. She's 

resending everything to the Department of Energy, and 

so we should get those documents. I think, you know, our 

concern which is similar to the concern expressed by a 

number of the Board Members, is the use of the absence 

of evidence as evidence of the absence of exposure.

And we complain about that regularly, and I think this is 

another example of what's happening there. We have four 

air sampling reports that are going to take the place of 

about five years' worth of data, and there's really no 

indication of whether the days when the contamination 

was the worst, whether those days were included in those 

four days.

And so I don't know how we do the statistical analysis to 

determine sufficient accuracy. I think that between 1952 

and 1957 there were relatively sophisticated methods of 

measuring radiation exposure with workers, and for one 

reason or another the Department of Energy didn't use 

those.

And I think the Department of Energy on some level has 

an obligation here to base a decision to deny a claim on 

accurate information, on relatively complete information. 
156 

And I don't think that what we're dealing with here is 

terribly complete information. 

I'm not too sure, but I suspect that no one will get paid 

at Superior Steel based on the estimates. I don't know 

the answer to that question; maybe some of you do. But 

I think on some level, no one will be paid on very weak 

evidence, as far as I can tell from this point.

We are going to pursue this, continue to kind of look at 

these issues as I know the Board will, and we hope to be 

included in the process, and this is a very early -- this is 

an early part of that process. And so I will leave off there, 

and thank you again for the opportunity to address the 

Board.

Mr. Katz: Thank you. All right then. So there's really no 

tasking to be done. The tasking's already been done. The 

work is underway, and we will sort out at what point it 

makes sense to have a Work Group meeting. But just the 

general process forward for that is SC&A will complete its 

evaluation and submit it, and then NIOSH will have some 

time to digest that and prepare, and then we'll be ready 

for -- and there may be some iterative back and forth 

response to clarify matters.

But then at that point we'll have a Work Group discussion 

about the SC&A review of the ER. And again, it's the TBD6000 Work Group, which has dealt with a lot of sites just 

like this one. 

I don't mean that in an insulting way. I know they're not 

identical, but they were involved in the same processes, 

and so this Work Group has a lot of experience with these 

sites with a similar nature of records deficiencies and all 

that.

Okay. So we have a public comments session, and let me 

just say a few -- let's see what time it is. It's 6:15. So 

we're already into the public comment session, which is 

fine. But let me check. 

Can someone go back to Zaida and see if she has any 

sign-ups for that from here? I don't see any faces, unless 

someone wants to waive their hand, of someone who --

no one had signed up earlier at least. Let's see if Zaida 

has someone.
157 

None, okay. So I don't have any commenters in the room. 

So we go straight to the phone line, and generally 

speaking we like if there are folks on the line, we've 

already heard from the petitioners. But if there are other 

folks on the line who have comments related to Superior 

Steel, I would like to hear from them first, and then we'll 

go on to any other commenters, regardless of what site 

they may have an interest in.

Okay. So I'm not hearing anyone from Superior Steel with 

comments beyond the petitioners. Let me just check 

before I go into the preliminaries about -- do we have any 

commenters on the line at all?

Okay. It sounds very quiet. All right. So then it sounds 

like we don't have any public comments, but we do have 

one commenter. Jim Neton, Dr. Neton wants to address 

the group.

Dr. Neton: Yeah. I'd just like to say a few words. I have 

been to 60 plus Advisory Board -- in-person Advisory 

Board meetings since the first one. I think I've missed 

two, and I've spoken on the record I'm sure at every one. 

So I couldn't let it go this meeting without getting on the 

record some way or another.

So first I'd just like to thank the Board for the great sendoff today, with the plaque and the salute, the card and 

the cake. That was very nice, and I'm sure Stu 

appreciated it much as well as I did. I'd also like to say 

that I really was honored to work with the Advisory Board. 

A very professional organization. It's been a good 19 

years, and I'll miss it. It's a rare opportunity that a person 

like myself gets to work on a program from the very 

inception, a federal program, and carry it through to 

where it is now, and for that I feel lucky, and I'm grateful 

for that as well.

I must say I also appreciated working with the others, 

other programs, the Department of Labor, Department of 

Energy, SC&A. Even though we've had some contentious 

discussions, I think it was great that we worked collegially 

to work things out, and I think we're in a good spot now.

I think Tim Taulbee is a great person to carry things 

forward. I think Tim is the first health physicist we hired, 

Larry Elliott and I hired in the program. So there was 
158 

three of us in the very beginning, we were just 

reminiscing, with 8,000 cases and no contractor.

So things are a lot different now than they were. But it's 

been a great experience for me. I'm probably not going 

away. I will work with the program from time to time. As 

questions arise, I'll be happy to help them out. So you 

may hear me on the phone or see me occasionally, but 

not a lot. I'd like to retire with a lot of time on my hands 

to pursue other opportunities. So with that again, I thank 

you all. It's been a great, great pleasure working with 

you.

Mr. Katz: Well, thank you, Jim.

(Applause.)

Adjourn

Mr. Katz: We were lucky to have you. Alright, and that's 

a nice note to adjourn on. Thank you everybody for all 

the hard work that went into the meeting.

(Whereupon, the above-entitled matter went off the 

record at 6:19 p.m.)