NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

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Centers for Disease Control

National Institute for Occupational Safety and 

Health

Advisory Board on Radiation and Worker Health

Subcommittee for Procedure Review

Wednesday, February 13, 2019 

The subcommittee convened telephonically at 10:30 

a.m. Eastern Standard Time, Josie Beach, Chair,

presiding.
. 

2 

Members Present: 

Josie Beach, Chair

Loretta Valerio, Member

Paul L. Ziemer, Member

Also Present: 

Ted Katz, Designated Federal Official

Ron Buchanan, SC&A

Dave Allen, NIOSH

Bob Anigstein, SC&A

Bob Barton, SC&A 

Kathy Behling, SC&A

Elizabeth Brackett, ORAU Team

Nancy Chalmers, ORAU Team

Mark Fishburn, ORAU Team

Darin Hekkala, ORAU Team

Stu Hinnefeld, NIOSH

Rose Gogliotti, SC&A

Tom Labone, ORAU Team

Megan Lobaugh, NIOSH

Lori Marion-Moss, Niosh

David Marsh, ORAU Team

Wade Morris, ORAU Team

Jenny Naylor, HHS

Jim Neton, NIOSH

Tim Taulbee, NIOSH

Tim Vitkus, ORAU Team

Rob Winslow, ORAU Team
. 

3 

Contents

Centers for Disease Control National Institute for 

Occupational Safety and Health Advisory Board on 

Radiation and Worker Health Subcommittee for 

Procedure Review Wednesday, February 13, 2019 1

Welcome/Roll Call 5

Carryover Items from October 31, 2018 SCPR 

Meeting 6

DCAS-RPT-005, Alternative Dissolution 

Models for Insoluble Pu-239 7

DCAS-TIB-013, Selected Geometric 

Exposure Scenario Considerations for 

External DR at Uranium Facilities 11

ORAUT-OTIB-0029, Internal Dosimetry 

Coworker Data for Y-12 13

ORAUT-OTIB-0044, Historical 

Evaluation of the Film Badge Dosimetry 

Program at Y-12 Part 1 - Gamma 

Radiation 17

ORAUT-OTIB-0046, Historical 

Evaluation of the Film Badge Dosimetry 

Program at Y-12: Part 3 - Beta Radiation

17

SC&A Presentations of Previously-Submitted 

Reports to the SCPR 20

ORAUT-OTIB-0086, Internal Dosimetry 

for Coworker Data Completeness Test

20

DCAS-PER-076 (ST4), Aliquippa Forge 

Subtask 4 (Case Reviews) 23

DCAS-PER-081 (ST4), Hooker 

Electrochemical Subtask 4 (Case 
. 

4 

Reviews) 26

DCAS-PER-062: OTIB-0052 Revisions

36

DCAS-PER-077 (ST4), Simonds Saw 

Subtask 4 47

DCAS-PER-073, Birdsboro Steel 53

ORAU-OTIB-088, External Dose 

Reconstruction 87

DCAS-PER-080 (ST4), General Steel 

Industries (GSI) Subtask 4 (case 

reviews) 92

ORAUT-OTIB-0006: Dose 

Reconstruction from Occupationally 

Related Diagnostic X-Ray Procedures

106

ORAUT-OTIB-0045: Historical 

Evaluation of the Film Badge Dosimetry 

Program at the Y-12 Plant in Oak Ridge, 

Tennessee: Part 2 - Neutron Radiation

116

Adjourn 124
.

5

Proceedings

(10:31 a.m.)

Welcome/Roll Call

Mr. Katz: So, I'm guessing we have NIOSH and ORAU 

folks on the line. Let me get started with roll call. 

Before I do roll call, let me address -- we deal with a 

whole bunch of different documents here.

Just to make sure, I don't believe that we're dealing 

with any documents relate to anyone's conflicts, but 

I'm not 100 percent certain of that. I've scanned 

them all and I didn't notice any sites.

But let me just, for safety sake, note that, for Josie -

- Josie's our Chair -- Hanford is a conflict. The 

documents related to Hanford are a conflict.

For Paul, ORNL, that's a conflict. And the only one 

other that's really pertinent, could be, is LANL after 

2000, the year 2000.

Member Ziemer: Right.

Mr. Katz: Right.

And then, Loretta is basically, for Loretta it's just 

everything in New Mexico and Pantex, but that's it for 

Loretta.

I don't think we're going to address any of those 

documents. But, anyway, if they come up, then those 

individuals will recuse themselves for their conflicts.

So, we have the three Members of the 

Subcommittee. So, we have a quorum, and I'll note 

that we have to have all three Members to have a 

quorum. Josie is the Chair.

And so, I'll go on from there to see who we have on 

for NIOSH/ORAU.
.

6

(Roll call.)

Mr. Katz: Okay. And then, we don't have any public 

comment session, but if we have any members of the 

public who are in attendance, now would be the time.

Okay. Then, I think since everyone is staff who is on, 

or a Board Member. I probably don't need to say this 

but the materials that can be posted for this meeting 

are posted on the NIOSH website. And there will be 

some other materials that cannot that will be 

presented via Skype. So, you folks probably need 

your Skype on. I know Bob Anigstein has a 

presentation on one of the documents that he would 

like to do through Skype. So, you might want at some 

point to get onto Skype for this meeting and explore 

that. We have the Skype connection there. It can be 

forwarded to some other desks.

Okay. Josie, it's your meeting.

Carryover Items from October 31, 2018 SCPR 

Meeting

Chair Beach: Okay. Thank you, Ted.

It looks like we have a very full agenda today. We're 

scheduled to go until 3:30. I'm assuming that's okay 

with everybody. We'll do a lunch break in between.

Kathy, I thought we would start with the carryover 

items and just get a brief update on those before we 

start in on the -- I know we have some new items to 

be presented. So, does that work for you guys?

Ms. Behling: That's fine with me, Josie, yes. Would 

you like me to get started?

Chair Beach: Yes.

Member Ziemer: That's good for me, Ziemer.

Chair Beach: What was that, Paul?
.

7

Member Ziemer: I said it was good for me, Ziemer.

Chair Beach: Perfect. Thank you.

And, Loretta, you're okay with that, I assume?

Member Valerio: That works for me, yes.

DCAS-RPT-005, Alternative Dissolution Models for 

Insoluble Pu-239

Chair Beach: Okay. So, we'll just start down the 

agenda with RPT-005.

Ms. Behling: Yes, and I can lead with that. But RPT005 is Alternative Dissolution Models for Insoluble 

Plutonium-239.

And what had happened is, we reviewed this report. 

It was reviewed by Joyce Lipsztein. And we resolved 

all of the issues. There were initially two findings that 

were changed to observations, and they are still in 

abeyance.

And just prior to the October meeting, we received 

an updated report from NIOSH, an updated Report 5 

from NIOSH. And I had contacted Joyce, and she 

reviewed the original report to look at and review this 

revision, just to ensure that these two observations 

were addressed in a satisfactory manner.

However, Joyce has been on travel for several weeks 

and has not had access to her government computer. 

So, unfortunately, I'm going to have to ask if we can 

carry this item over to the next meeting.

Mr. Katz: Well, you cannot carry it to the next 

meeting because it's under this contract, but you can 

get it done, you have to get it done this month.

Ms. Behling: Okay. I was wondering about that. Yes, 

I can contact Joyce and make sure that she sends out 

a memo or a White Paper, whatever she feels she 

needs to do --
.

8

Mr. Katz: Sure.

Ms. Behling: -- by the end of this month. Okay?

Mr. Katz: Yes, that would be great. Thank you.

Ms. Behling: Okay. Very good. We'll handle it that 

way, and I apologize for that.

Chair Beach: And we've had discussion on it. So, I 

think we were just waiting for her and that memo. Is 

she off travel now? Do you know, Kathy?

Ms. Behling: I think she's going to be back shortly. 

I've been in communications with her, but I will 

certainly work with her and get something in your 

hands before the end of the month.

Chair Beach: Okay. That sounds great. Thank you.

Dr. Neton: Kathy, this is Jim.

Ms. Behling: Yes?

Dr. Neton: There were one finding and one 

observation. And the one finding that was changed to 

an observation is the one that Joyce was reviewing, 

which had to do with the selection of curves, the 

clearance curves for Mound.

The other one was just a typo that we fixed. I wonder 

if it would be just as good now to close that one, if 

that's okay. It was really just to change two words in 

the procedure for this document, unless you would 

rather wait and do them both at the same time.

Ms. Behling: Do you mind if we wait and do them 

both?

Dr. Neton: Yes, that's okay.

Ms. Behling: Yes. I am showing still two observations, 

although both of the observations do have to do with 

that Mound Case 13.
.

9

Dr. Neton: Well, no, one was actually a typo where 

we said they should be used as defaults for Mound 

and Savannah River Site. And we deleted Savannah 

River Site because it was just a cut-and-paste error.

Ms. Behling: Yes. Okay, yes, I see that down there.

Dr. Neton: That's the only thing that we really 

affected there.

Ms. Behling: Okay.

Mr. Katz: You can close that. There's nothing to that.

Chair Beach: That one's the 02, correct?

Ms. Behling: Yes.

Chair Beach: Yes.

Ms. Behling: That's Observation 2. Yes, all right, 

that's fine. We'll close that.

Mr. Katz: Yes. I assume that's okay with the Work 

Group. It seems straightforward.

Chair Beach: Yes, that seems fine. Paul and Loretta, 

you're fine with that?

Member Valerio: Yes.

Member Ziemer: Yes, I'd be fine with that. I think we 

should close it right away.

Chair Beach: Okay.

Ms. Marion-Moss: Josie, this is Lori.

I just wanted to point out one thing, that the title of 

that document is not Insoluble Plutonium-239. It's 

238.

Ms. Behling: Okay. Thank you. I'm sorry.

Chair Beach: Okay, we'll make note of that. Thank 
.

10

you.

Ms. Behling: And would you like me to go on, Josie?

Chair Beach: Yes, please.

Ms. Behling: Okay. The next item under the carryover 

list is the --

Member Ziemer: Let me interrupt just a moment. If 

that is correct that it's 238, then we need to go back 

into earlier documents which continued to call that 

239. For example, carryover information identified 

that, I think, as 239 also, did it not? I'm looking back 

just trying to pick that up.

Chair Beach: Which carryover? Are you talking about 

the agenda, or?

Member Ziemer: Yes, the title for this one, 005. I'm 

trying to look back into the earlier notes to see how 

we titled that, if the title is incorrect as well in the 

documents. It's not critical now, but --

Mr. Katz: Yes, so I think, Kathy, if you just will check? 

I mean, the agendas don't need to be sorted at this 

point, but if you'd check to make sure that the SC&A 

documents are titled appropriately?

Chair Beach: Yes, I'm looking at the SC&A document 

now from January 2017. It lists it correctly as 238.

Member Ziemer: Okay. Thanks, Josie.

Chair Beach: The table summary that Kathy sent out 

has 239.

Ms. Behling: Yes, I'm sorry, that's my mistake.

Member Ziemer: Thank you.

Chair Beach: Looks good, Paul. Thanks.

Mr. Katz: Yes, thanks.
.

11

DCAS-TIB-013, Selected Geometric Exposure 

Scenario Considerations for External DR at Uranium 

Facilities

Ms. Behling: Okay. And if we move on, then, to

DCAS-TIB-013, actually, I will turn this over to Jim 

Neton.

There was one finding -- this is Selected Geometric 

Exposure Scenario Considerations for External Dose 

Reconstruction at Uranium Facilities -- and there was 

a Finding 4 that is still in progress. The finding had to 

do with the procedure underestimates the maximum 

correction factor to be applied to badge readings.

And I believe we had a fairly long discussion on this 

during the last meeting. Bob Anigstein made a 

presentation, and Jim Neton had a thorough followup discussion that he was going to include into the 

BRS. And I did look at the BRS this morning, and I 

see that Jim has included some wording there. But 

I'll turn this over to Jim.

Chair Beach: Okay. That sounds great. Thank you.

Dr. Neton: Okay. Thanks, Kathy.

Yes, this is not a long follow-up discussion, although 

we don't necessarily disagree with SC&A's findings in 

principle. But what I put into the BRS is what Josie 

suggested. It is that the completion on this finding is 

going to be contingent upon the issuance of OTIB-89, 

which is describing NIOSH's implementation of the 

revised dose conversion coefficient contained in ICRP 

116. So, it didn't make sense for us to go and revise 

the dose conversion factors, to, then, have to go back 

again once TIB-89 came out and redo them. So, 

we're waiting until the completion of TIB-89, and, as 

I indicated in the BRS, that's currently scheduled to 

be completed in the beginning of 2019. So, it really 

is sort of just a placeholder I put in there that says 

it's going to be a little while before we're done with 
.

12

this finding.

Mr. Katz: Can I just, for clarity -- so, is this something 

where the solution is already -- I don't recall --

discussed and understood, and it's just in abeyance, 

or is it actually that you have to work it out when you 

do that new document?

Dr. Neton: I think the nature, some of the findings 

are going to be taken care of when we do ICRP 116. 

We are going to have organ-specific dose conversion 

factors that didn't really exist under the old 

methodology, and that was part of what SC&A's 

findings related to.

Mr. Katz: Okay. So, then, it's not really in abeyance 

yet, but --

Dr. Neton: Yes, it's in progress, is what I would call 

it.

Mr. Katz: In progress, right?

Dr. Neton: Yes.

Chair Beach: Yes, and that's how it's listed in the BRS 

also.

Mr. Katz: Okay. Thanks.

Member Ziemer: So, that would remain in progress? 

This is Ziemer.

Dr. Neton: Correct, yes.

Chair Beach: Yes. Yes.

Dr. Neton: Yes, until we get 116 done.

Mr. Katz: And what's the timing of that?

Dr. Neton: June. June.

Mr. Katz: Okay. Thanks. Okay. So, then, if you have 

a meeting before June, there's no point having this 
.

13

on the agenda.

Member Ziemer: Now will that also require an SC&A 

review, then, before we see it again?

Chair Beach: I would say yes.

Mr. Katz: Yes, we might as well, right? We might as 

well. Yes, when that comes out, I can task it for 

SC&A, so that we get SC&A to have a look at it before 

we discuss it at the Subcommittee, which means it 

will be sometime in the fall probably that the 

Subcommittee takes it up.

Chair Beach: Okay. That sounds reasonable.

Mr. Katz: Yes.

ORAUT-OTIB-0029, Internal Dosimetry Coworker 

Data for Y-12

Ms. Behling: Okay. Are we ready to move on to OTIB29?

Chair Beach: Yes.

Ms. Behling: All right. OTIB-29 is the Internal 

Dosimetry Coworker Data for Y-12. And again, there 

was one outstanding finding that had to do with this 

Monday morning collection of urine samples. And we 

had a discussion on this during the last meeting, and 

the finding is still in progress. And I believe the 

follow-up action was for NIOSH to prepare a White 

Paper to address this issue and to satisfy our 

concerns. I did not see that White Paper. I didn't see 

it attached to OTIB-29 on the BRS. Perhaps I missed 

something.

Chair Beach: Yes, I looked for it and didn't see it.

Mr. Allen: This is Dave Allen.

You didn't miss anything. We didn't put together a 

White Paper yet. After the last meeting, looking at 
.

14

the BRS and looking at the transcripts, it was real 

confusing to me exactly what it was and whether 

everybody's on the same page as to what they 

wanted to see.

For the issue, there's kind of two different topics. One 

is the concept that, if you have some percentage of 

samples not taken on Monday, that it greatly 

diminishes the collection you would make. And the 

other topic is how many samples were not taken on 

Monday, essentially, throughout the different years 

at Y-12.

And it really seems like, on that first part, over the 

years we've had agreement and, then, didn't have 

agreement and, then, did have agreement. And it 

seemed like some people were under the belief that 

we had agreement on that and it's just the second 

part that we needed to do. And others, I'm not so 

sure. There was never any formal closing or any 

official agreement on even that first topic. So, I kind 

of needed to figure out exactly what it was the 

Subcommittee was expecting in this White Paper.

Ms. Behling: Would it be beneficial for SC&A to go 

back and clearly state what we are looking for? This, 

again, would be Joyce Lipsztein. I could get her 

involved, if the Board would like us to do that.

Mr. Katz: Well, listen, I mean, as Dave was 

suggesting, this is an old -- I mean, part of it, this 

was dealt with years and years ago already, unless 

there's something special about Y-12 with respect to 

Monday morning --

Mr. Allen: I went back and looked, and this one was 

originally dealt with in 2005, and then, it was 

resurrected and picked up again in 2009. And as you 

probably remember, 2005 for sure and to some 

extent 2009, we weren't very good at formally closing 

issues. And even 2009, we weren't real good at 

formal documentation and White Papers being saved 
.

15

in the BRS or somewhere, where it's very difficult to 

follow the trails as far as what we discussed and 

what, if anything, was closed. We could even bounce 

back and forth from 2009 to where in one meeting 

we had agreement on that first topic, and the next 

meeting they didn't.

So, it's almost to the effect of, if you want to go back 

to the trail, it's almost unrecoverable and we're kind 

of starting from scratch on this. So, it depends on 

what the Subcommittee wants and what everybody's 

memory is.

Member Ziemer: This is Ziemer.

I recall that Joyce had some concerns about this 

issue. I thought SC&A had some White Paper or 

something on it. You didn't find anything, Kathy, on 

that at SC&A?

Ms. Behling: Well, I was actually looking -- at the last 

meeting we had discussed that NIOSH was going to 

prepare a White Paper, and I was looking for that. I 

can go back and dig through the records, also, and 

see if there was a White Paper prepared by Joyce. 

But I agree with you, Paul, I know that she still has 

some issue with this Monday morning sampling, and 

perhaps it is strictly associated with Y-12. But I can, 

like I said, go back and try to resurrect the concern 

that she still has.

Dr. Neton: This is Jim.

I don't really recall Joyce ever producing a White 

Paper on this, but I do recall a series of email 

communications on this issue. I looked for them and 

I couldn't find them. But Joyce provided us, through 

email, some examples I think, is what we had.

Ms. Behling: Yes.

Dr. Neton: But I cannot find them.
.

16

Ms. Behling: Okay. It sounds to me, if you're in 

agreement with this, that the easiest path forward is 

for me to discuss this with Joyce, have her clearly put 

her concerns, you know, go back and put her 

concerns down, and present that to you, so that we 

can move forward with this issue once again.

Mr. Katz: I think you also need to put in there the 

transcript, what was already discussed and agreed 

to. Because I do recall that this was responded to by 

NIOSH. So, I missed the point where it was 

resurrected, but I thought it was responded to and it 

was pretty clear that it was a no, never mind, the 

Monday, because of the way -- there was a whole 

logic to it that was discussed at one of those 

meetings, but you can find that.

Ms. Behling: Okay. I will search through the 

transcripts then.

Mr. Katz: Okay.

Chair Beach: Well, and probably when this stuff is 

going back and forth, if NIOSH would have sent out

a memo or an email letting SC&A know, and the 

Subcommittee, that you were having issues with this, 

we could have maybe resolved this prior to this 

meeting.

Mr. Katz: Yes, true, but --

Chair Beach: So, just something for the future, just 

so we're not stuck carrying it over again when it could 

have been easily handled possibly.

Mr. Katz: Yes.

Ms. Behling: Okay. All right. So, I am ready to go on 

to OTIB-44, if there's no other questions.

Chair Beach: Okay, and we're clear on what -- you're 

going to take that on and then send, before the end 

of the month again, something out --
.

17

Ms. Behling: Yes.

Chair Beach: -- with whatever the question is? Okay. 

Thank you.

ORAUT-OTIB-0044, Historical Evaluation of the Film 

Badge Dosimetry Program at Y-12 Part 1 - Gamma 

Radiation

Ms. Behling: Yes, I will.

Okay. ORAUT-OTIB-0044, and this is, again, the Y12 plant. And it has to do with the film badge 

dosimetry program for gamma radiation. And Ron 

Buchanan reviewed this OTIB and made a 

presentation at the last meeting.

During his presentation, he identified four findings 

and four observations, and those are in the BRS and 

they're in progress, I believe. And we were just 

waiting for some response from NIOSH, and I'm not 

sure if you've had an opportunity to do that. I didn't 

see anything in the BRS.

ORAUT-OTIB-0046, Historical Evaluation of the Film 

Badge Dosimetry Program at Y-12: Part 3 - Beta 

Radiation

Dr. Neton: Yes, this is Jim.

Both 44 and 46 are still undergoing the internal 

development. They've been assigned. I believe we 

have a completion date now.

Lori, do you have that date?

Ms. Marion-Moss: The estimated completion date is 

approximately in June of this year.

Dr. Neton: Right. That's what I thought. So, they're 

on the schedule, but there's competing demands on 

people's time, and they're in progress. Hopefully, 

they'll be finished by June.
.

18

I believe the same thing applies to OTIB-64 review 

as well. All those few Y-12 issues are being worked 

on by the same staff.

Mr. Katz: Okay. So, on 44, 46, and 64. And it would 

be good, either Lori or Kathy, whoever picks up the 

BRS, when we have proposed delivery dates, it would 

be good if we just put that note in there, if there's a 

place for it in the BRS, because, then, when you look 

there, you'll know this isn't going to be ready for the 

next meeting or it is, whichever.

Ms. Behling: That's a good idea, Ted. In fact, when I 

update the BRS from this meeting, I will include that 

in our statement.

Mr. Katz: Yes. That's sounds great. Thanks.

Member Valerio: So, Ted or Josie, this is Loretta.

Would those also require an SC&A review?

Chair Beach: Yes.

Mr. Katz: There's always that. There's always that.

Chair Beach: Yes.

Mr. Katz: But, then, I can task those things at a 

meeting.

Member Valerio: Okay.

Mr. Katz: So, I can task SC&A.

Member Valerio: Okay. Thank you.

Mr. Katz: Yes. Thanks.

Ms. Behling: Okay. So, it looks like that concludes all 

of the carryover items, because you've addressed 

now all of the Y-12, which was OTIB-44, OTIB-46 and 

OTIB-64.

So, if you are ready, SC&A has submitted some
.

19

additional reports to the Subcommittee that haven't 

been presented yet. And we can start with ORAU 

Report 86, which was done by Ron Buchanan.

Chair Beach: Yes, that sounds good. Is there a 

presentation with that?

Ms. Behling: Yes, there is.

Chair Beach: Okay.

Ms. Behling: And, Ron, are you ready?

Dr. Buchanan: Let me get off mute here and pull this 

up here. Okay.

Rose, can you present that on the screen?

Chair Beach: I'm seeing it, Rose.

Is everyone else seeing it?

(Chorus of yes.)

Dr. Buchanan: Let me get it in order here. This is a 

little out of order of what I had set up.

Ms. Behling: Is it possible to make that bigger on the 

screen or is that it?

Member Ziemer: It's a little hard to read. Maybe we 

can blow our own screens up. Let's see.

Ms. Behling: Yes.

Member Ziemer: Yes, if you hit Full Screen, it will get 

bigger.

Ms. Gogliotti: Exactly. And there's also something 

that will expand the frame at the upper right-hand 

corner of the Skype. It's two arrows.

Are people able to see it now?

Member Valerio: Yes.
.

20

Mr. Katz: This is just the document, anyway.

Ms. Behling: That's correct, yes.

Member Ziemer: I found if you hit Actual Size, it gets 

bigger also.

Ms. Behling: Yes.

SC&A Presentations of Previously-Submitted Reports 

to the SCPR

ORAUT-OTIB-0086, Internal Dosimetry for Coworker 

Data Completeness Test

Dr. Buchanan: This report was assigned to SC&A in 

October of 2017, and it's the Internal Dosimetry 

Coworker Data Completeness Test Report. It was 

issued in September of 2017.

And so, this was a test of, looking at the coworker 

sampling to see if it fit certain criteria and could be 

used as a, in coworker models. And so, Harry also 

worked on the mathematics of this. In the report 

there on page 6 and page 7, we go through kind of a 

rundown of what the mathematics that were used in 

that, in the OTIB, and then that just kind of 

summarizes it for you because it's pretty detailed.

And so, we look at our evaluation starting, actually, 

on page 7. We had no findings. We went through the 

math of this and determined that they did use an 

appropriate test and set it up correctly, used common 

and defined terms. Hence we had no findings in this. 

We did have a couple of observations. The 

observations are shown there on page 8.

We would just like to emphasize that, although we 

agree with what they said -- and we went through 

this before: how do you set these parameters? What 

is the allowable risk involved in both the producer, 

the one that produces the coworker data, and the 

person using the coworker data to make a model?
.

21

And so, you have a producer risk. You've got a 

consumer risk, and you've got acceptable errors and 

unacceptable errors. Just to refresh your memory a 

little bit, we went through this in the past to look at 

what is acceptable and we did some research, and 

some of the other people did some research, too, and 

did not find any accepted values, that 95 percentile, 

or something like that. We did find that NIOSH used 

a recommendation of 2.5 percent risk on both the 

producer and the consumer, and a simple error risk 

of 2.5 percent and overall error risk of 5 percent. It 

seemed to be somewhat in the norm. There doesn't 

seem to be good guidance there, but we found that 

these were acceptable.

We just wanted to emphasize in Observation 1 there 

on page 8 of our report that these are variables that 

can be set by the users, and they seem to be 

reasonable, that they can be changed. And so, you 

would throw away or accept more data, depending 

on where you set risk values at.

Observation 2 was the fact that they used the term 

original dataset, that they referred to a computerreadable dataset in electronic form that was provided 

from a hard copy. And this is kind of confusing. We 

always think of an original as, to me, the handwritten 

cards or the original printout of a computer, or 

something like that. And so, it was a little bit 

confusing to the reader until you had read the whole 

document a time or two and got it straight in your 

mind.

Observation 3, we see that there seemed to be an 

error there in n, the number used. They said 25 and 

it should have been 24, but that looked more like an 

editorial error. And so, it did not really impact results.

And so, overall, although this is a fairly short review 

presentation, we did do all the legwork on it and find 

out that it was appropriate and really had no issues 

on the findings or various observations in this review.
.

22

Chair Beach: Okay. Thank you, Ron.

Any questions from the Subcommittee Members?

Member Valerio: I don't have any questions, Josie.

Member Ziemer: No, that's fairly straightforward. I 

assume they'll change that to 24. But, other than 

that, it looks reasonable.

Chair Beach: Okay. And then, I'm not sure how to 

handle the observations. NIOSH, have you had a 

chance to look at this?

Dr. Neton: Yes. This is Jim.

We appreciate the fact that there were no findings, 

and the first two observations, really we note them, 

but I don't think we're going to change our procedure 

because of them. And the third one is literally a typo, 

and I don't know that it's worth -- this is a point of 

procedure actually now, whatever it is -- revising it 

for that change in the value.

Member Ziemer: It doesn't change what you're going 

to do, does it?

Dr. Neton: No, it doesn't change anything. It's really 

just a reference of a number --

Member Ziemer: Right.

Dr. Neton: -- and it's addressing a table. And we 

could certainly fix that the next time the procedure is 

revised, but I would think that we accept these 

observations and they could be closed.

Chair Beach: Yes, that was kind of my thought also, 

with a note that, when you revise it, that you can look 

at that.

Are we in agreement with that, Loretta and Paul, that 

this can be noted; it can be noted in the BRS that this 

was discussed and the findings all closed?
.

23

Member Ziemer: Well, observations closed, yes.

Member Valerio: Yes, close the observations, right.

Chair Beach: Observations, yes.

Member Ziemer: I'm good, yes.

Chair Beach: Okay. Sounds like we're all in 

agreement with that.

And, Kathy, can you go back and do that at the end 

of the meeting?

Ms. Behling: Yes. Yes, I will. I will close these three 

observations.

Chair Beach: Okay. Thank you.

Member Ziemer: Okay.

DCAS-PER-076 (ST4), Aliquippa Forge Subtask 4 

(Case Reviews)

Ms. Behling: Okay. Now we're going to move on to 

DCAS-PER-076, and this is our Subtask 4 Report.

And I will wait for Rose to pull that up.

Mr. Katz: And while she's pulling it up, just to note, 

since we're talking about cases here, don't speak too 

much about particulars.

Ms. Behling: Yes.

Mr. Katz: Yes. Thanks.

Ms. Behling: Yes. Okay. And as Ted said, this is a 

case review. PER-76 is a PER associated with the 

Aliquippa Forge facilities that rolled uranium. And I'll 

give you just a little bit of history as to what we 

reviewed on the Aliquippa Forge.

Back in 2014, NIOSH had issued PER-45 that had to 

do with Rev 1 of the Aliquippa Forge TBD, and SC&A 
.

24

did review that. That review resulted in eight findings 

and two observations. Ultimately, NIOSH revised the 

TBD. Rev 2 of the TBD addressed the issues 

associated with PER-45 findings, and the Revision 2 

of the TBD resulted in PER-76. And since the TBD had 

been reviewed and the changes to Rev 2 incorporated 

our findings from Rev 1, the only thing we had 

suggested that we needed to do to follow up is the 

Subtask 4, to do a Subtask 4 case, so review one 

case that was impacted by these changes.

So, that is what this report presents. Now since the 

PER focuses on changes to internal and external dose 

in the residual period, we recommended that we 

review either two cases that had doses assigned for 

external during the residual period or internal during 

the residual period, or if one case satisfied both, we 

would review one case. And that is what we did; we 

reviewed one case.

If we go down to page 7, this particular worker 

worked with Aliquippa Forge for roughly 10 years. 

There were no dosimetry records. And therefore, the 

doses were based on the Aliquippa Forge exposure 

matrix.

If we scroll down to Table 2-1, during this process we 

evaluated both the original doses and the reworked 

doses, and those doses and the PoCs are shown in 

Table 2-1. As can be seen there, obviously, this case 

was not compensated.

You can also see there was a significant increase in 

the external dose and only a slight increase in the 

PoC. And I'll explain a little bit of that, the review for 

that, a little later.

In looking at the original external dose, the exposure 

matrix at that time used Table 13 values and DCF 

values from IG-001, the External Dose 

Reconstruction Implementation Guide. We looked at 

those doses and calculated the dose that you see in 
.

25

the table. Those doses were entered into IREP as a 

log-normal distribution with a geometric standard 

deviation of 1.5.

The original internal dose, they also used inhalation 

and ingestion values from Table 13. They compared 

solubility types M and S, and it was determined that 

M resulted in a higher dose. That value, it was a 

modest dose, as was shown in Table 2-1, and that 

dose was entered into IREP as a log-normal 

distribution with a GSD of 3.

The reworked external dose, the TBD, the exposure 

matrix changed to data being included in Table 5-1. 

And so, they pulled information out of Table 5-1, used 

the DCFs again from IG-001, and it resulted in a 

much higher dose, in fact, a 42-fold increase. The 

significant increase in the external dose is due to 

changing the starting air concentration or air sample 

in the residual period. The air sample had been 

treated as part of the operational period, and now it 

was including the residual period. And so, that 

resulted in these significantly higher external doses.

The reworked internal dose, also data came out of 

Table 5-1 for inhalation and ingestion. Again, type M 

solubility was selected as resulting in the higher 

doses. For inhalation/ingestion, they use an F1 value 

that is a maximum value, and it looks at all the 

absorption types and assigns the highest for the 

selected organ. And again, that dose increased only 

slightly.

SC&A reviewed all those assumptions and considered 

them reasonable. We also went in and did our own 

calculations, as shown on page 9 of the report. We 

were able to match NIOSH's numbers. So, we have 

no findings with the external dose.

And internal dose, also, we went into the CADW 

inputs. We verified that everything was entered into 

the CADW correctly, and we were also able to confirm 
.

26

the doses that were calculated for internal dose. So, 

there were no findings with this review of one 

impacted case.

Are there any questions?

Chair Beach: Kathy, this is Josie.

It looks straightforward to me. I have no questions 

at this time.

Paul or Loretta?

Member Valerio: I have no questions.

Member Ziemer: No questions here.

Chair Beach: Okay. That was unanimous, no 

questions.

Ms. Behling: Okay. I will just make a note in the BRS 

that we did do the Subtask 4 report, there were no 

findings, and the Board accepted this report, the 

Subcommittee accepted the report.

Chair Beach: Okay. That sounds great. Thank you.

Ms. Behling: Very good.

Mr. Katz: Excellent, Kathy.

DCAS-PER-081 (ST4), Hooker Electrochemical 

Subtask 4 (Case Reviews)

Ms. Behling: Okay. Thank you.

We will move on to DCAS-PER-81, which is the 

Hooker Electrochemical Subtask 4. This is Ron 

Buchanan.

Dr. Buchanan: Great. Ron Buchanan of SC&A.

If you can pull that report up, Rose or Kathy, whoever 

is at the projector?
.

27

Okay. So, this was a Hooker Electrochemical PER. 

There have been three revisions to this OTIB for 

Hooker Electrochemical, technical-based documents, 

since it was issued in 2011. And so, considering this, 

all the cases had to be gone back and reviewed and 

reevaluated to see if they needed a rework.

And so, we find now the problem with these smaller 

sites is that it's kind of difficult to find a case that sets 

the criteria of the PER, the dates, internal/external, 

different conditions, and fall between 40 and 50 

percent. And so, some of these cases, some of these 

sites only like have maybe 100 cases, and a lot of 

them fall below 45 percent. So, that doesn't leave too 

many to select from.

In this case, there were only three that even came 

close to meeting criteria of greater than 45 percent 

PoC. And so, we recommended selecting one that fell 

between 45 and 50 percent, and then, there was only 

one there and there were a couple that fell above 52 

percent. So, we recommended selecting one of those. 

So, NIOSH did provide us, in January of 2018, two 

cases, the one that fell between 45 and 50 percent 

and one that fell above 52 percent. So, those were 

the two cases we reviewed, and we reviewed those 

in accordance with the directive of reviewing, and we 

only looked at the things that were changed by the 

PER.

Now, in this case, the PER did cover quite a few 

things, in that the external and internal changed for 

both the operation and residual period. So, there was 

a case that we found that had some of these changes 

in it.

And so, if we look at the first case on page 7 there, 

we see that this represented a Hooker worker that 

worked there quite a few years in the early years of 

its operation and had several cancers. The initial dose 

reconstruction for this under the old guidance was 

done in 2012. And so, it was reworked in 2017 to 
.

28

consider the changes in doses according to the 

revised TBD.

The original dose reconstruction, the PoC fell between 

45 and 50 percent, and the reworked fell between 45 

and 50 percent. It increased about a percent and a 

half, but still not over 50 percent.

So, if we go down and look on page 7 of our report, 

we see that Table 2-1 there summarizes it for you. 

And it compares the original dose reconstruction to 

the recent one done under the PER-81. We see that 

the doses for the different cancer sites did increase 

slightly for both internal and external, and the PoCs 

for each increased slightly, but not significantly that 

it would change the outcome of the case.

So, we did go through the workings of this. Page 8 

there lists the original external dose and the original 

internal dose, and how they were determined, and 

the combined PoCs, total dose and PoCs. And then, 

page 9 describes the rework of the external and 

internal doses, and we used Table 7 of the revised 

TBD there, at least in 2016. And we did the 

calculations as it prescribed and compared that with 

NIOSH's dose assignment and the total PoC. We see 

were in close agreement and had no issues or 

observations in that section.

And for the details of the calculations, it is on page 

10. We see that we did have one observation on 

external. We went through the calculations and we 

found that, although not wrong, it was unusual, in 

that the dose conversion factor for the skin, it's 

usually used as 1.0, according to OTIB-17. However, 

this case used the dose conversion factor for skin out 

of the IG-001 recommendations.

And so we wondered why. We looked at several other 

cases for Hooker and found out -- and I list it there 

on that page, the next, the case numbers -- and 

found out that that was used, the IG-001 dose 
.

29

conversion factors for skin was used in those cases 

also. So, we listed it in an observation because we 

were wondering why that was done, where it 

normally used 1.0 from OTIB-17. That was the 

observation for the external dose for the first case.

Page 11 shows the internal dose, talks about it. The 

internal dose mainly changed because the inhalation 

rate changed from 2.2 to 3.2 dpm per day in the 

inhalation, and the ingestion increased to 34.2 dpm 

per day. Both of these were increases. So, you would 

expect the dose from the previous dose 

reconstruction to increase in the reworked dose 

reconstruction.

And we went through and did these calculations using 

the IMBA program for the particular cancer sites. We 

derived the same internal doses as the reworked case 

from NIOSH showed. And so, we had no issues with 

the final version and the final dose assignments for 

internal dose.

However, again, sometimes we have to go back and 

calculate some other things to see if it makes sense. 

And we found that the internal dose for the skin 

actually was higher in the previous dose 

reconstruction than it was in this dose reconstruction. 

Now, for the other cancer, it went up, which we would 

expect, and agreed in both cases with what we would 

calculate.

So, the bottom line is it's not obvious from the 

documentation available how the higher value in the 

first dose reconstruction, why it was higher than in 

NIOSH's second dose reconstruction for the skin. And 

so, although it didn't affect the outcome, we agree 

with their outcome of the dose assignments and the 

PoC, it just remains to see why that was higher 

previously. It wasn't obvious from the documentation 

in the original dose reconstruction why that would be 

higher. And so, that was Case Number 1. That was a 

45-to-50-percent PoC, and that was the only one, out 
.

30

of all of the 100 cases, that fell in that area.

We did evaluate one greater than 52 percent, and the 

problem with that, as we show on page 12 there, was 

that the worker worked at two different sites. And in 

the reworked dose reconstruction, they had just used 

the dose from the second site and not reworked the 

Hooker site because they didn't need to. The 

reworked dose from changes that had taken place in 

the other site the worker worked at gave a very large 

PoC, and they didn't need to include any more dose 

from the Hooker. And so, there was nothing really to 

check on the dose reconstruction because they 

weren't charged with reviewing the other sites, the 

dose reconstruction under PER-81.

And so, in essence, we had no issues, had no 

findings, and just had the two observations, which I 

had previously mentioned about the dose conversion 

factor and the higher internal dose from the previous 

dose reconstruction; didn't see why it was higher in 

the previous one than in the second one when the 

intake increased.

And so, that concludes my presentation in this case.

Chair Beach: Okay. Good presentation. Thank you, 

Ron.

I guess I have a question. Is there directions to the 

dose reconstructors to use the IG-001 instead of the 

TIB-0017, or can the dose reconstructor use either 

one?

Dr. Buchanan: I can't answer that question, Josie, 

and that is our question.

Chair Beach: I thought NIOSH made --

Member Ziemer: Well, I was a little puzzled, also, by 

this, although it didn't have much effect.

Jim or someone, can you clarify exactly what's going 
.

31

on here?

Dr. Neton: This is Jim. I thought Dave Allen or Tim 

might be able to help out on that question.

Apparently not.

Mr. Katz: Is Dave on the line?

Member Ziemer: Just the fact that the number hasn't 

been affected much or is there some rationale for 

selecting one versus the other?

Dr. Neton: Is Dave or Tim on the line still?

Chair Beach: Are you muted?

Dr. Taulbee: Yes, I'm here. This is Tim.

I'm sorry, could you repeat what the question is?

Chair Beach: It's just within Ron's Observation 1 

where the dose reconstructor used the IG-001 

instead of OTIB-17. I was just wondering if there was 

direction to the dose reconstructor just giving the 

leeway to use either or if there was a reason why IG001 was used.

Dr. Taulbee: I would have to go into more details or 

do more research to actually know why they chose to 

not use one. But, in general, OTIB-17 was intended 

to replace, basically, the DCFs that were in IG-1. And 

so, my opinion, not going into the details here, OTIB17, the DCF of 1, is what should have been used here. 

But, again, I don't know without going into more 

details.

Mr. Katz: Okay. Who's the lead for Hooker normally 

at DCAS? Tim or Jim?

I mean, I don't recall from work group meetings who. 

Is it Dave Allen or is it --

Dr. Neton: Dave has been working on the Hooker 
.

32

issues.

Mr. Katz: That's what I thought.

Dr. Neton: I don't know if Dave is not there or --

Mr. Katz: Yes, maybe someone could just get a hold 

of Dave and get him back on the line at some point 

because he may be able to clear this up.

Dr. Neton: The PERs are normally his bailiwick.

Mr. Katz: Yes. Okay. So, if someone can just get him 

back on the line at some point during the meeting, 

that would be great.

Dr. Neton: We'll do that.

Mr. Katz: Maybe close this out, this question.

Ms. Marion-Moss: I just sent it to him.

Mr. Katz: Oh, okay. Thanks. Thanks, Lori.

Chair Beach: And then, on the second observation, 

Ron, you're just wondering why that dose went up? 

And SC&A couldn't pinpoint on why that was based?

Dr. Buchanan: Yes. This is Ron Buchanan again.

Yes. The intake increased, and yet the dose 

decreased from the original dose reconstruction. So, 

we couldn't find out why the original dose was high 

as it was because we didn't calculate that high a dose 

for the original dose when we went back and tried to 

rework it. And we calculated the same dose they did 

in the rework and we agree with that in the final, but 

the original one done earlier, we couldn't duplicate it. 

And also, why was it higher -- when the intake 

increased, but the dose went down, that was our 

question to them.

And it really was kind of borderline on whether we 

should go back to the original dose reconstruction, 
.

33

but when trying to match it and make logic of it, it 

wasn't obvious why the original internal dose was 

greater than the final one, when the intake increased.

Chair Beach: Right.

Member Ziemer: The bottom line on that one is 

you're really trying to verify the final one anyway.

Dr. Buchanan: Right.

Member Ziemer: The rework. So, it sort of, in a 

sense, doesn't matter what the original one was.

Dr. Buchanan: Correct. Unless it didn't include 

something that should have been included in it, like 

it was in the original.

Member Ziemer: Yes.

Mr. Allen: Dave Allen. My phone completely died. I 

had to find a new one and dial in.

Mr. Katz: That's all right.

Chair Beach: Darn it.

Mr. Allen: Yes, I think Stu's locked up on him, too. 

There's something wrong with our system here.

Chair Beach: Well, I'm glad you got back on.

Did you get a chance to see what the question was?

Mr. Allen: I know what the two observations are. I 

heard right to the end of Ron's presentation.

Mr. Katz: So, Dave, the first question is, why in these 

cases did we use IG-1 instead of OTIB-17?

Mr. Allen: Right. If you look at --

Mr. Katz: Are you on speaker phone? There's an 

incredible echo.
.

34

Mr. Allen: Yes, I know there is and I am, but it's quiet 

in the office here. That got better. Can everybody 

hear me now?

Chair Beach: Yes.

Mr. Katz: That's better.

Mr. Allen: Okay. Good.

As far as that Observation Number 1, the purpose of 

OTIB-17, or the title even in OTIB-17, is for 

evaluating film badge doses. Whereas, Hooker was 

actually a modeled dose.

And the difference being, as I understand it, with the 

shallow dose on the film badge, you never really 

know for sure if it's beta dose or some very lowenergy photon dose. So, the favorable approach at 

that point is to assume that it's a beta dose as far as 

the dose conversion factor goes. That gives DCF of 1 

instead of something lower.

But, as far as when you're modeling the dose, by 

definition, you know what it is you've modeled and 

you can go ahead and use IG-1, which is what we 

normally do with Hooker.

Hopefully, that answers it anyway.

Mr. Katz: That seems pretty clear.

Mr. Allen: Then, as far as Observation Number 2 with 

the lymphatic and the skin systems, what you see 

with the dose reconstruction, the original one was a 

very high-end efficiency measure, I guess you would 

say, to where, with the prescriptive intake like that, 

you would find out if a lymphatic system type S is the 

favorable absorption type. Whereas, with the skin, it 

was type M.

And what we've done is rerun, with the prescriptive 

ones, we rerun to make these organ intakes, and 
.

35

then, you use the favorable one.

(Telephonic interference.)

Mr. Katz: Your phone line is gone again.

Mr. Allen: All right. That's a little better now.

In general, we will try to say that it's one solubility 

type that a person inhaled, which is what we did with 

the PER. So, in the PER what you see is a type S 

solubility for both the skin and the lymphatic dose. In 

dose reconstruction you see that it looks like we even 

had two different types of material. It was type S for 

lymphatic, type M for skin, which is an 

overestimating assumption. So, it was an efficiency 

measure. That's the difference, and that's why you 

see the skin dose drop quite a bit between the dose 

reconstruction and the PER.

And I hope that answered the question.

Mr. Katz: Yes, that makes sense.

Chair Beach: Yes. SC&A or Ron, any other questions 

with the explanation?

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

No, I understand on the internal. On the dose 

conversion factor, you say you used the IG-001 

because it was the model dose, as opposed to OTIB17, because that was based on film badge and could 

have been beta dose. How is model dose -- don't you 

originally obtain that data from the film badges, 

though? So, wouldn't it be subject to the same 

problem?

Mr. Allen: If the information originally came from film 

badges, yes, but that's not what Hooker was. Hooker 

was like an MCNP type of calculation.

Dr. Buchanan: Oh, okay. Thank you.
.

36

I'm okay with that, Josie.

Chair Beach: Okay. Any questions from Paul or 

Loretta?

Member Ziemer: No, I think that clears it up for me. 

I think we can close this out.

Chair Beach: Okay. Yes, I was just going to suggest 

that.

And, Loretta, are you okay with that?

Member Valerio: Yes, I'm good with closing it. That 

was a good explanation. Thank you.

Chair Beach: Okay. So, we are closed for the Hooker.

And we are ready to move on to 062.

DCAS-PER-062: OTIB-0052 Revisions

Ms. Behling: Okay. This is Kathy Behling again.

And this is PER-062. PER-62 has to do with revisions 

to OTIB-52. OTIB-52 is Parameters to Consider When 

Processing Claims for Construction Trade Workers.

Now, under our review of the PER, our initial review, 

we look at a total of five Subtasks, but we look at the 

first three Subtasks, and then, make a 

recommendation under Subtask 4 as to doing 

reworked claims. And you can see, on page 5, our 

Subtasks 1 through 3.

Now I'm going to start out on page 7 with Subtask 1. 

Subtask 1 has to do with the circumstances that 

necessitated the PER. OTIB-52 was issued to provide 

guidance for reconstructing doses to unmonitored 

construction trade workers, and they use site-specific 

coworker data and multiply that by a 1.4 adjustment 

factor.

Now there is a fairly complex history that I'll try to 
.

37

work through here. To start with, in 2007, OTIB-52, 

PC-1, the page change revision, was issued. And that 

page change was issued to change guidance with 

regard to penetrating/non-penetrating and internal 

dose pathways.

SC&A was tasked to review OTIB-52, Rev 00, in 

2006. As a result of that review, there were 16 

findings that were identified, and they are shown on 

page 7 and 8 of the report.

Then in November of 2007, PER-14 was issued. PER14 addressed adjudicated construction trade worker 

claims at DOE sites where coworker models had not 

been established. And so, that was the reason for the 

issuance of PER-14.

Then, on February of 2011, Rev 1 of OTIB-52 was 

issued. That addressed some of the initial 16 findings 

that SC&A had on Revision 00.

In July of 2011, SC&A reviewed OTIB-52, Rev 1. We 

were actually tasked during that review to determine 

which of SC&A's original findings were addressed in 

Rev 1 and to provide recommendations to the 

Subcommittee as to the status of the remaining 

findings.

Then, in March of 2012, SC&A reviewed PER-14. That 

resulted in a total of six findings. Three were 

conditional because we weren't able to confirm some 

of the data.

This, then, resulted in the review of -- oh, this review 

led to NIOSH issuing Rev 2 of OTIB-52. That was 

issued in 2014 and, ultimately, resulted in this PER, 

PER-62, to address the changes in both Rev 1 and 

Rev 2 of OTIB-52.

So, SC&A reviewed the information leading up, 

obviously, to the issuance of this PER, and we agree 

with NIOSH's changes and the need for this PER.
.

38

And now, if we move on to Subtask 2, Subtask 2 

shows corrective -- or it talks about corrective actions 

that NIOSH did to establish the sites that were 

involved, that were affected by these changes and, 

also, the number of cases.

So, initially, to establish the applicable sites, NIOSH 

generated Table 3-1. Let's see here. Okay. They 

established a list where the coworker data had been 

developed using monitored workers, and in sites 

where PERs were planned or already issued, they 

were not included in PER-62.

So, in the table, those that you see that are marked 

yes were considered in this PER. Those were the sites 

that were looked at in this particular PER.

And then, step 2 of their process was to determine 

the population of claims at each site. First, our 

review, SC&A's review, we looked at the entire list of 

sites where there's covered employment under the 

EEOICPA. And we compared that to Table 3-1, and 

we did determine that NIOSH accurately captured all 

the sites.

But I did have one observation. I couldn't see any 

documentation that the Albany Research Center, that 

there was a forthcoming PER for that. Now Albany 

Research Center is one of those, quote -- I should call 

it template or where the guidance, the dose 

reconstruction guidance is actually embedded in dose 

reconstruction reports. So, I'm not quite sure why I 

didn't see any documentation, but maybe it has to do 

with the fact that there's no standalone document for 

the Albany Research Center. But that was one thing 

that came to my attention.

For assessing the number of cases, SC&A doesn't 

have access to all of the IT tools that NIOSH does. 

But, based on doing a search of NOCTS, I was able 

to get an approximate, get close to NIOSH's 

numbers. So, I felt comfortable with that.
.

39

Also, SC&A reviewed the three PERs listed in Table 

3.1 and confirmed that the PERs were issued after 

OTIB Rev 2. And those were associated with 

Bridgeport Brass, Electro Metallurgical Company and 

Paducah Gaseous Diffusion Plant.

Since SC&A can't assess forthcoming PERs, we also 

included an observation that's more of a 

recommendation. I just thought, in order for us to 

follow through to ensure that all of these sites that 

need to be assessed get assessed, perhaps we could 

maintain a list of those sites, be informed when a PER 

is issued, and, obviously, maybe review the PERs, as 

we have in the past, to assess the selection of the 

reworked cases were adequately captured for all 

potential construction trade workers. So, that's 

Observation 2. We had no findings with the 

methodologies.

Okay. And we'll go on to Subtask 3. Subtask 3 is 

NIOSH's approach for identifying the number of DRs 

requiring rework. What NIOSH did is they developed 

a list of keywords for identifying construction trade 

workers, and those keywords are listed in the first 

paragraph under Subtask 4, and include things like 

crafts and teamsters and boilermakers and 

pipefitters, and so on. Those keywords were used to 

query dose reconstruction reports and NOCTS.

NIOSH also went an extra step to do a text search of 

dose reconstruction reports for cases and sites using 

the names of the sites that were considered under 

this PER. And all of that keyword and text searching 

of dose reconstruction reports and NOCTS resulted in 

the identification of 1,969 potential cases.

The population was reduced because, and if we scroll 

down a little bit, in going through those cases, some 

were duplicates. Some cases the PoCs were greater 

than 50 percent. In some cases, the dose 

reconstruction was already under review. Several 

were already compensated under an SEC. Some of 
.

40

the cases were Nevada Test Site cases with 

employment starting after 1957, which I believe all 

workers were monitored at that point in time, so it 

didn't apply. And also, the Clinton Engineering Works 

employment did not include 1949 and -- I mean, '48 

and '49 timeframe. So, based on reducing that 1,969 

initial cases, that resulted in about 1,006 cases.

And SC&A reviewed the keyword list, and we thought 

it was thorough and accurate. As I said, since we 

don't have the ability to assess the cases or do a word 

search in the dose reconstruction reports -- and in 

talking to David Allen, I think their IT people spent 

about three days coming up with the cases for that. 

Therefore, our assessment is limited to the 

methodology and criteria that was employed, but we 

do agree with what NIOSH's approach was. So, there 

were no findings associated with Subtask 3.

And then, finally, Subtask 4 is where we determined 

how many cases should be looked at that were 

potentially impacted. We're just recommending --

well, there were, as I said, 1,006 cases. One case 

that was recalculated resulted in greater than 52 

percent; 992 resulted in less than 45 percent, and 

there was one case with a PoC between 45 and 50 

percent. It just seems that that would be maybe the 

logical case to review, the one case with a PoC 

between 45 and 50 percent. And so, that was our 

recommendation under Subtask 4.

And that concludes our review of PER-62.

Chair Beach: Okay. Kathy, you got a complicated 

one, didn't you?

(Laughter.)

Ms. Behling: Yes. The history, yes, was somewhat 

complicated, and it was a struggle to try to do some 

of the searches. And I do appreciate David Allen's 

help on explaining how their IT people went about 
.

41

that. So, I felt satisfied that that was done 

adequately.

Chair Beach: Okay. So, let's move back to the 

observations in the first part, the Subtask 2. Any 

comments or questions on either of those 

observations, on SC&A's conclusions?

Ms. Behling: And, Josie, I don't know if I can just 

interject a second here, but David Allen probably 

would -- I hope he's still on the line. He could 

probably answer my question about the one site 

where I didn't see any documentation data; PER was 

forthcoming.

Chair Beach: Yes, for the Albany Research Center?

Ms. Behling: Yes, yes.

Chair Beach: Okay. And that's why I was hoping 

NIOSH could chime in here.

Mr. Allen: Yes, this is Dave Allen. I can't answer that 

one, too.

Chair Beach: Okay.

Mr. Allen: I'm not sure how to answer it. But, when 

we put that list together for this PER, we were looking 

at anything that we were using the coworker analysis 

for, any coworker doses. And that does include 

Albany Research Center.

Then, once we started going through the PER, we 

looked at the Albany Research Center and found an 

unusual situation there. OTIB-52 correction factors 

apply to the measured dose, but not to the missed 

dose. As it turns out, Albany Research Center, at the 

time we used the coworker, really doesn't have much 

of any exposure. And all, 100 percent, of the film 

badges we used were non-detectable. So, 

essentially, the entire coworkers is just a missed 

dose, and there is no OTIB-52 correction. So, there 
.

42

was really no reason to do a PER associated with that 

OTIB-52. And that was after we had put it into this 

PER to say that it did have a coworker.

So, it left me in this strange position. I'm not quite 

sure how to close this gap other than we need to get 

it on the transcript here today, that, as Kathy said, 

there is no PER forthcoming because, as it turns out, 

there really is no effect.

Chair Beach: Okay. I mean, that makes sense. That's 

a reasonable explanation of why it wouldn't have 

been on the list.

Member Ziemer: This is Ziemer.

Can you remind us, what did they do in Albany 

Research Center or what was the size of the work 

with the materials?

Mr. Allen: Well, it's actually kind of a pretty ugly one. 

They did a lot with some uranium, thorium, what they 

call rare earth, in like the '50s, et cetera. But the site 

was a government site that fell under the Bureau of 

Mines, Department of the Interior. As such, it's not 

covered under EEOICPA.

Later, they did some work for Y-12 in 1971 or '72, a 

small amount of work. I'm trying to think. At that 

point, they were -- somehow that became covered. I 

have to look. I can't recall the details, but somehow 

that was no longer Bureau of Mines, I think, at that 

point. But, somehow, this became covered.

Member Ziemer: So, it was a very limited covered 

time?

Mr. Allen: Yes. And then, after that time, later, I think 

maybe around 2000 or maybe in the 1990s, it 

became part of the Department of Energy. It is 

actually a national lab now, but their work is with 

primarily biomass fuels, which I'm told means, 

essentially, trying to find a way of burning sawdust 
.

43

to get energy out of it.

But they also have remediation going on from the 

past nuclear operations back in the '50s. That was 

when it was Bureau of Mines. So, it gets very, very 

muddy as far as what was going on, et cetera.

The timeframe where we got the coworker, as I 

recall, it's during this remediation period where DOE 

ended up taking some liability or responsibility for 

cleaning up that work from the '50s. Even though 

that work is not really covered under the OTIB, it's 

still covered under FUSRAP. They were cleaning that 

up with their own contractors. They were not using 

Albany Research Center employees, which is what we 

would be covering. So, it gets very muddy, but we 

did a coworker with Albany Research Center 

employees that were badged, and none of them had 

any recordable dose. Well, like I said, everything 

about that site is strange and it gets very confusing.

Chair Beach: Yes, it sure does.

Mr. Allen: Did that answer your question, Paul?

Member Ziemer: Yes. I couldn't remember even 

seeing much about this before. But it doesn't really 

impact much. I guess in terms of what we're looking 

at here, it doesn't have much impact on the bottom 

line in terms of these observations here.

Chair Beach: No, it doesn't.

And then, anything else on 1?

Observation 2. Have I still got everybody?

Mr. Katz: Yes, you do.

Chair Beach: Maintaining a table. Dave or anyone, 

can you comment on that?

Ms. Behling: Well, Josie, this is Kathy.
.

44

That is just something that I thought just so that we 

can keep a list and sort of check off the list that, okay, 

a PER has been listed for -- because there's 20 sites 

that we're expecting, and maybe only 19 now, based 

on David's explanation. But I just thought, because 

we usually look at the PERs, but maintaining a list 

ensures that, yes, all right, we're going to check that 

one off to ensure that the OTIB-52 issue was 

addressed at that site.

Mr. Katz: So, I think that that one, SC&A, you guys 

can just keep a list --

Ms. Behling: Yes.

Mr. Katz: -- of which ones you haven't looked at for 

this item. And when you look at the PER, you can also 

address this.

Ms. Behling: Correct. Right.

Mr. Katz: When you can task the PERs -- there's 

really nothing more that anybody needs to worry 

about. SC&A can keep this item on their to-do list for 

when they check a PER for other uses.

Ms. Behling: Yes, exactly.

Chair Beach: So, the table you created on page 10, 

that Table 3-1, that's a pretty good table to start 

with. I don't know if NIOSH or someone knows that 

one is coming out, maybe --

Mr. Katz: I don't think it's worth -- I mean, they 

might as well, when they're going to review the PER, 

they can make a decision at this point.

Chair Beach: Yes.

Mr. Katz: But they don't need a special notice in that.

Ms. Behling: Okay. And am I correct, then, in 

assuming that we should be taking the Albany 

Research Center off of this list?
.

45

Mr. Katz: Right.

Ms. Behling: Okay. And I'll make note of that, that 

that was the discussion for Observation 1, in the BRS.

Mr. Katz: Right. That's good.

Chair Beach: Okay. And then, I think we can close 

these two observations, is that correct?

Ms. Behling: Okay.

Mr. Katz: Right. Well, I guess accept the report, right, 

because there's no findings?

Chair Beach: Yes.

Mr. Katz: If that's good with the whole 

Subcommittee.

Chair Beach: Yes.

Member Ziemer: Yes, I agree.

Member Valerio: That's fine with me.

I do have one question, though. On Table 3-1, on 

some of these sites that there's a PER forthcoming, 

do we have any kind of a timeframe on when these 

will be ready, especially from some of the sites that 

we're actively working on?

Mr. Allen: This is Dave Allen, NIOSH.

I think that almost answered the question here. 

Some of these sites are under an active review by the 

Board, and a PER is usually something we put 

together after the document has been revised and 

everything is said and done. We shouldn't have to go 

through for each change, and then, go through all 

these cases again for the next change, et cetera, et 

cetera. We try to make sure it's at some final version 

and we're not going to be changing it in the near 

future before we start the PER.
.

46

Mr. Katz: Right.

Mr. Allen: So, it comes down to various Board groups 

as far as how close we are to closing an issue and 

whether I could even guess how close we are.

Mr. Katz: Yes. So, anyway, the answer is, no, we 

don't have a timeline.

(Laughter.)

Chair Beach: Okay. And our next review is for -- I 

know it's Bob Anigstein's Birdsboro Steel.

Are we ready for a break before we get to that or is 

everybody ready? Because I think that one will 

maybe take a little while.

Mr. Katz: Yes. What does everybody want to do? It's 

just coming to noon right now.

Member Valerio: Either way works for me, Josie.

Chair Beach: Okay. How about you NIOSH folks? You 

guys are at the lunch hour.

Dr. Neton: This is Jim. I could use a break for lunch.

Chair Beach: Okay. So, do you want to take a halfhour or an hour?

Dr. Neton: A half-hour works for me.

Chair Beach: Okay. Great. I'm good for a half-hour. 

Ted, are you okay with that?

Mr. Katz: A half-hour? Sure. Whatever. That's fine.

Chair Beach: So, everybody's fine for a 12:30 

restart?

Member Valerio: That was a half-hour, Josie?

Chair Beach: Yes.
.

47

Mr. Katz: Yes.

Member Valerio: That works for me.

Member Ziemer: I'm good.

Chair Beach: Okay. Let's break for a half-hour.

Mr. Katz: Okay. See you at 12:30.

(Whereupon, the above-entitled matter went off the 

record at 11:56 a.m. and resumed at 12:32 p.m.)

DCAS-PER-077 (ST4), Simonds Saw Subtask 4

Mr. Katz: Let's skip over maybe to Simonds Saw. 

There's no finding. So, it should make it easier in 

terms of whatever Dave might be required to do.

Ms. Behling: This is Kathy Behling.

It is PER-77, which is Simonds Saw, is Bob Barton, 

and I am just emailing him right now because --

Mr. Barton: Hi, Kathy. I'm on the phone.

Ms. Behling: Okay. Thank you.

Mr. Barton: Yes, no problem.

Ms. Behling: So, we're ready to start PER-77, Bob.

Mr. Barton: Okay. So, this is for Simonds Saw and 

Steel. It is obviously the steel mill that operated from 

early 1948 through 1957 built near Niagara Falls. 

They rolled uranium and occasionally thorium, just to 

give a little background on it.

So, I think probably the best thing to do would be to 

start on page 6, kind of briefly go over what the main 

updates were to the TBD that started this whole PER.

So, if we're looking at page 6, really both the external 

and internal dose assignments for both operational 

and the residual period were updated in the most 
.

48

recent TBD. And if we look at -- we're on page 6 --

you can see that, for the occupational period, the 

external and internal intake rates were modified and 

recalculated, so that instead of having a distribution, 

we essentially have 50th and 95th percentile values. 

Again, that's both for the external dose rates and 

internal intakes during the occupational period.

And the TBD now contains very explicit instructions 

that you assign the 50th percentile to any sort of 

administrative workers and you have to assign the 

95th percentile to operational workers. So, that's for 

the occupational period.

For the residual period, both the internal or external 

dose assignments were both reevaluated. And one of 

the main things that changed was the exposure time, 

which is obviously significant in the residual period. 

It went from 2,000 hours to 2500 hours.

So, when we went through and said, okay, based on 

these changes, what kind of criteria do we want for 

cases to look at, basically, it was three main criteria; 

this is also on page 6. We wanted to look at a 

production worker or production workers with at least 

some employment either in the operational period or 

residual period, or both.

We also wanted a worker classified as administrative 

because, again, one of those main changes was going 

from a distribution which would have been assigned 

to every worker to delineating between the 50th and 

95th percentiles, depending on what type of worker 

category you fell into.

So, if we can move along to page 7, I obviously can't 

say much about this, but it describes some specifics 

about the case. What happened is, as I said, one of 

the criteria we were looking for was to go over a dose 

reconstruction for the administrative category. But, 

as it turns out, none of the dose reconstruction 

assignments were actually evaluated using that 50th 
.

49

percentile. So, they were basically all considered 

operational workers.

So, we ended up with a single case that had the 

requisite employment in both periods, as you can see 

here. Okay. And if we can scroll down on that page, 

Table 1, you can kind of see the differences in doses 

from the original dose reconstruction, again, looking 

at Table 1.

We derive dose reconstruction through Revision 2 of 

the TBD, and we see there's pretty significant 

increases in both -- well, mainly in the external dose 

and, also, the internal dose increased a little bit. And 

the total dose went up by about a factor of 7.

One of the changes here that might look a little weird 

is the original dose reconstruction assigned a medical 

x-ray dose, and a revised x-ray dose is not assigned. 

And that's sort of a programmatic policy that comes 

out of OTIB-79, which is Guidance on Assigning 

Occupational X-Ray Dose.

Essentially, what it says, if you had x-rays 

administered on the actual site, then they must be 

accounted for, or if it's unknown, they must be 

accounted for. But, in this case, there's 

documentation that shows that, for any sort of 

medical exam, they were sent offsite to a local 

hospital.

So, we can move on and talk about the assessment 

of external doses. Really what I want to talk about is 

what the differences are between these. I believe 

that is in Section, yes, in Section 2.2.2, which is at 

the bottom of page 8. It starts with those bullets 

there.

And the main difference is, obviously, the worker is 

assumed to be an operations worker. So, under the 

new TBD, we assigned the 95th percentile as a 

constant; whereas, before it was assigned as 
.

50

essentially the 50th percentile, which is the lognormal GSD. And those GSDs were really exposurescenario-dependent, you know, air submersion, 

direct exposure from the uranium billets and/or rods.

Both DRs actually use the same external dose rate 

for the residual period, but, obviously, as I said, the 

new DR assumes 2500 hours at that exposure rate, 

as opposed to 2,000 hours. So, that would increase 

the dose fairly significantly.

They changed the geometry, because if you're in a 

residual period and you're assuming that you're 

basically submerged in this cloud of radioactivity for 

the purposes of external dose, they change the 

geometry to isotropic; whereas, before we see AP 

geometry.

The dose correction factor was chosen to be the 

midpoint value rather than an max value. So, that 

would lower the doses some. I think really what 

happens is, when you start to get into that best 

estimate territory, you really don't want to expect to 

choose more realistic exposure failures as opposed to 

bounding values in an overestimate case.

Another change was that, towards the end of this 

Energy employee's career, they didn't work the full 

year. So, again, I think this is another sort of bestestimate approach; whereas, in the first dose 

reconstruction, dose was assigned for that entire final 

year of employment. Whereas, in the revised, it was 

prorated based on the amount of the year that that 

worker was actually employed.

As I said before, any sort of medical x-rays were 

removed from the dose reconstruction as a 

programmatic policy change.

So, as far as the external exposure, we went in, we 

checked all the IREP inputs. The total doses were 

increased maybe by almost a factor of 7, and we had 
.

51

no problems with that. We really had no findings on 

the external dose, the changes, and it seemed to be 

all in line with the TBD revision.

I can move on to internal dose or I can take questions 

at this point.

Chair Beach: I think you can go ahead and move on, 

Bob.

Mr. Barton: Okay. This Energy employee was not 

monitored. So, coworker intakes were going to be 

assigned. Similar to the external exposures, the 

internal intakes were prorated to the last day of 

employment. The operational period intakes were 

assumed to extend to the end of 1957, and that's a 

change in the TBD where the operational period was 

extended a year per Revision 2. This dose 

reconstruction was actually done with Revision 0. So, 

I believe that change of extending the operational 

period one year happened in Revision 1. So, that was 

one change.

Obviously, the 95th percentile intake was applied 

because this worker was considered a production 

worker. That was one of the main changes, was the

breakout of that distribution into essentially two bins 

based on what your job classification was.

If we scroll to figure 1, what I'm showing here is the 

increase in uranium intake rates. As you can see, it's 

very significant once you get into that residual period 

that, even in the operational period, they're all higher 

for this individual because now we're using the 95th 

percentile.

Another change was that technetium-99 was added 

to the recycled uranium contaminants. Previously, 

only plutonium and neptunium had been included, 

but it's pretty common practice now, I think, to 

evaluate all three of those main recycled uranium 

contaminants. So, that was one change.
.

52

Thorium was removed. The original dose 

reconstruction occurred prior to SEC-157. So, during 

an operational period, thorium dose reconstruction is 

no longer possible and feasible. So, that was 

removed from the dose reconstruction.

But there was still thorium intakes evaluated for the 

residual period, which were assumed to be, roughly, 

1 percent of the uranium intake rates. And that was 

sort of based on documentation of production.

Also, some thorium daughters were added that 

weren't included in the original dose reconstruction.

So, adding all these changes, I ran IMBA, came out 

with a total internal dose just slightly less than 1 rem. 

And that's .87 rem, which is slightly higher than the 

NIOSH dose of .85 rem, but the doses are very close. 

I'm not sure where that slight difference resides. I 

know in the files provided by NIOSH the workers that 

were used were -- and I ran IMBA directly, and I think 

it took roughly 25 to 30 IMBA runs to get all the 

contaminants in there, and then, you added it up all 

in an Excel file. So, it could be a bounding issue or it 

could have been possibly human error on my part 

cutting and pasting it. I'm not sure, but it's pretty 

small. So, in evaluating that internal dose, SC&A had 

no findings.

Are there any questions? That's pretty much it. This 

one was a fairly simple one.

Chair Beach: Thanks, Bob. Good report.

I don't have any questions. Do you, Paul and Loretta, 

have any?

Member Valerio: I don't have any.

Member Ziemer: I don't.

Chair Beach: Okay. That's a unanimous no questions 

from either Paul or Loretta.
.

53

And I would move that we accept this report and 

close -- there's no finding or no observation to close, 

but we can just close it out officially in BRS, that we 

accepted the report.

Member Ziemer: I agree.

Chair Beach: And Dave, are you back in the building 

or are you still outside?

Mr. Allen: I just walked back in. I'm still trying to 

warm up.

Chair Beach: Okay. Well, I'm glad they didn't keep 

you out there too long. Take a minute and go ahead 

and put Bob's slides or presentation back up. That 

maybe will give you time to get back to your office.

Mr. Allen: Oh, I'm in here. I sat down already.

Chair Beach: Oh, okay. Perfect.

Jim's probably glad he stayed home today.

Dr. Neton: Yes, I am. I'm glad I stay home most 

Wednesdays.

Chair Beach: Most Wednesdays? Oh, good.

All right. It looks like Bob's report is back up. So, Bob,

whenever you're ready.

Dr. Anigstein: Okay. Is my presentation visible?

Member Ziemer: Yes.

DCAS-PER-073, Birdsboro Steel

Dr. Anigstein: Okay. I want a word of caution. There 

was a version of this presentation that was posted on 

the web, on the DCAS website. And this is slightly 

different.

One difference is it includes some material that would 

not have been allowed in the presentation on the 
.

54

web. And so, when I come to material that is 

protected, you'll see it is in red. That's mostly a 

reminder to me not to vocalize, but everybody can 

read the data, but I won't be speaking it. As I said, 

this is not exactly what you will -- if you downloaded 

it, what was sent out, this is not exactly the same.

This is the review of DCAS-PER-073, which is the 

Birdsboro Steel Foundry and Machine Company. 

Since this is probably not familiar -- it certainly 

wasn't familiar to me before I started -- let me go 

into a quick background of the history of this facility. 

This I downloaded from the Historical Society of 

Pennsylvania website.

While it was open, Birdsboro Steel Foundry and 

Machine Company in Birdsboro, Berks County, 

Pennsylvania -- later changed its name to the 

Birdsboro Corporation -- was known as the oldest 

foundry in the United States, tracing its roots back to 

William Bird's New Pine Forge, founded in 1740.

Birdsboro Steel provided products to the United 

States military for every major conflict through the 

Korean War. The company closed in 1988 after a 

lengthy strike and an inability to increase to compete 

with increasing foreign steel imports.

The first minor observation is the name of the facility 

somehow got corrupted. All the contemporary 

documentation from the 1950s calls it, according to 

the posting from the Historical Society of 

Pennsylvania, which I downloaded just very recently, 

it's the Birdsboro Steel Foundry and Machine 

Company. And somehow, in 1987, there was a huge 

memo, handwritten, elimination recommendation, 

which correctly identified the owner as the Birdsboro 

Steel -- they use an ampersand sometimes -- & 

Machine Company.

And just to go into what the meaning really means, 

a steel foundry, for those who are not in the business, 
.

55

is a facility that pours cast steel into molds, as 

opposed to a steel mill which rolls the steel. So, this 

was a steel foundry because that's what they did.

And they also had a second business where they 

made machinery for other steel mills, for their own 

use and other steel mills, rolling mills. And therefore, 

they called it the and Machine Company. And 

somehow the ampersand got mislocated and it's 

since then been called, referred to in the 

documentation as Birdsboro Steel and Foundry, 

which, frankly, doesn't make any sense. It's not a 

steel and foundry; it's a steel foundry.

Anyway, that's just a suggestion that it is possible for 

NIOSH to change the name without running into legal 

problems. And I'm going to refer to it as the 

Birdsboro Steel Foundry and Machine Company.

Mr. Katz: Yes, Bob, however DOE lists it is the name 

that we have to live with. But certainly we could send 

a note to DOE about what its correct name might be, 

but we have to run by the facility name that is given 

by DOE.

Dr. Anigstein: I was afraid of that, but I raised my 

point anyway.

Mr. Katz: But, anyway, thank you.

Dr. Anigstein: Now the only documentation -- this is 

very sparse documentation -- the only 

documentation about AWE operations at this facility 

is that there was a record of a shipment of eight 

assorted pieces of uranium billets, weighing 346 

pounds total, that were received from Birdsboro for 

storage at the Lake Ontario Ordnance Works. That's 

a facility that was run by the New York office of the 

Atomic Energy Commission, the AEC.

And so, nothing else is known about this, except they 

just noted in one of their weekly or monthly reports, 

you know, with all the ins and outs, everything that 
.

56

was shipped to that facility, everything else that was 

shipped out of the facility, it's just listed as just like 

a one-line notation about the 346 pounds.

The other thing we do know is that Birdsboro was 

involved in the design of a rolling mill for Fernald, 

which is a logical choice since they built machinery 

for rolling steel, and therefore, they would have the 

expertise, despite it's not an AWE facility, but this is 

an engineering design.

And it's my opinion -- and actually, it coincides with 

the opinion of the author of Appendix BB, Rev 0, 

which was that these were rolling. These billets were 

the results of rollings at Birdsboro.

Again, just as a matter of definition, a billet, which 

can be shaped as a cylinder usually or it could be a 

rectangular prism, is an intermediate product 

between an ingot and the final product, in this case 

uranium fuel rods. So, first, they take the ingot and 

close it down to a billet, and then, later in another 

operation, they turn it into a rod, which is long and 

much thinner.

The other documented instance of AWE activity is 

that there were five 1-to-2-inch-thick wafers, 

presumably of uranium, that were shipped to 

Birdsboro from Model City, New York, which is, 

essentially, the location of the Lake Ontario Ordnance 

Works. There was a letter dated February 1st 

notifying someone at Birdsboro that this material has 

been shipped. So, it could have been that day or it 

could have been prior to that day. My guess is it will 

be the same day; they made the shipment and then 

they sent out the letter.

They were described in detail. They gave the weight 

of each of these five pieces, and they were weights 

that ranged from 1.9 to 2.5 pounds, for a total of 11.5 

pounds.
.

57

And there's nothing about what it was for except, as 

it says here, as I point out here, that it says, after 

completion of work -- they don't say what the work 

is -- this office should be contacted before disposition 

of material. AEC was very, very diligent about 

tracking every bit of uranium since it was considered 

precious material at the time.

And there is no documentation of its purpose. NIOSH 

speculated that these were subject to microscopic 

analyses of grain structure, which is reasonable. 

These are small pieces, and there was such an 

analysis performed on uranium rods rolled at a 

Bethlehem Steel plant in Lackawanna, New York, that 

was reported in the trip report. There's no reference 

that this has been done at Birdsboro, but it's 

plausible.

So, now I'm going to go back to our task. Subtask 1 

was to assess NIOSH's evaluation and categorization 

of the issues that necessitated DCAS-PER-073 and its 

potential impact on dose reconstruction.

I will give, again, background now of NIOSH activity. 

The first document of this, the relevant document,

was TBD-6000, Rev 0, produced by Battelle under 

contract to NIOSH, which gave generic guidance for 

AWEs that worked uranium and thorium. It was 

issued December 13th, 2006.

Then, in November 21st, 2007, again, the Battelle 

contractor issued Appendix B, Rev 0, that specifically 

addressed the operations at Birdsboro. Then, in 

2011, TBD-6000, Rev 1, was issued, and I believe 

the main author was Dave Allen.

And following that, four years later, June 2nd, 2015, 

there was an Appendix B -- I'm used to saying BB 

because that's ESI -- Appendix B, Rev 1. According 

to the blurb on the cover page, it was revised for 

conformancy with TBD-6000, Rev 1. However, once 

you read it, it's a complete rewrite. There's very little 
.

58

carryover from the Appendix B, Rev 0.

And I point out a comparison here. So, there were 

only two years that were the covered period. They 

thought at one time there was a suspicion there could 

have been activity in 1962, but that was later 

dismissed as not likely there was uranium there.

So, we see that the operations were different in the 

two years, at least as far as the Rev 1 or Rev 0 was 

concerned. And so, the inhaled intake went down 

from 209 picocuries per day to 42.9. That's so in '52, 

it also went down, but not as much.

However, the ingested intake went up significantly 

from 1.95 to 30. So, it was about a 15-fold factor in 

'51 and an enormous increase, about 200-fold, in 

1952.

External exposure was small to begin with, a millirem 

per year range, and it didn't change much. It went 

down a little from Rev 0 to Rev 1.

So, the operational period was two years. It was not 

possible -- given this, it was not possible for NIOSH 

to exclude any cases by period of employment or 

otherwise, because NIOSH could not a priori say, 

well, will the doses be smaller because the inhaled 

intake went down or will they be larger because the 

ingested intake went up? And part of it would always 

refer to what organ we're talking about. Lungs, 

obviously, are most sensitive to inhaled intake; the 

alimentary tract is more sensitive to the ingested 

intake.

Consequently, since it was not possible to exclude 

any cases, and there were only four claims during the 

covered period -- there was a fifth one that was 

outside the covered period that was disqualified --

the simplest thing was to simply redo all four cases.

Going on to our next subtask, assess NIOSH's -- so, 

Subtask 1, we agree with NIOSH's decision about 
.

59

how to address this. Subtask 2, to assess NIOSH's 

specific method of corrective action. Again, the 

reason stated for revising Appendix B was a revision 

to TBD-6000. However, a comparison of the revised 

TBD showed there were really no significant changes 

in the exposure pathways for organs other than skin 

that would affect the Birdsboro Site Profile. However, 

NIOSH did perform a fundamental revision of the 

exposure scenarios, based on a reassessment of the 

handling and working of uranium at Birdsboro, 

resulting in major changes in exposure scenarios.

Another fundamental change was in the methodology 

used to address the ingestion pathway. In Appendix 

B, where, one, NIOSH postulated that Birdsboro had 

received the uranium in order to perform microscopic 

analyses of metal surfaces, NIOSH assumed that 

Birdsboro cut the pieces to prepare samples for 

analysis and that the work took 8.8 hours, which is 

one-fifth of the 44-hour workweek assumed for this 

period in TBD-6000.

NIOSH postulated that Birdsboro received the billets 

on April 17th, the earliest date that billets were 

produced at Simonds Saw and Steel in support of 

design at Fernald's rolling mill. The machining of the 

billets at Birdsboro was assumed to take place on the 

same day. The machining of the five wafers was 

assumed to take place on February 1st, '52, the date 

of the AEC letter notifying Birdsboro of the shipment.

First, again, is an historical note for Observation 2. 

The standard workweek being 8.8 hours is based on 

a misinterpretation. The 44-hour week, which was 

assumed for a certain period in the early '50s by TBD6000, was based on work that was done 8 hours a 

day Monday through Friday and working half a day 

on Saturday, which was common practice. There is 

documentation for that, and actually, I can even cite 

personal experience, having been working during 

that period of time. That was common. So, again, it 

does not change things very much, but it is an 
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60

anomaly.

The other observation that mixes the dates of 

operation, and will have a trivial effect on the 

estimated basis, but these scenarios should be 

plausible. The billets were rolled in Lockport, New 

York, on April 17th. They could not have been 

machined at Birdsboro 300 miles away on the same 

day, especially it's in a machine, but it assumes it 

takes an entire workday. So, a more likely date would 

be two days later, April 19th, allowing one day for 

shipping after the rolling. It makes a very slight 

difference in the exposure probably.

Then, the wafers in 1952 were shipped by Railway 

Express from Model City, New York, over 300 miles, 

from Birdsboro. So, if the letter would have been 

written the day the metal was shipped, the wafers 

could not have -- it is implausible the wafers could 

have been machined on the same day. If it fell on a 

Friday and we assume a full day of machining, the 

earliest likely date would be February 4th, the 

following Monday. So, we recommend that NIOSH 

adopts April 19th as the date for processing 346 

pounds of billets and February 4th for working on the 

five wafers.

All right. Now we're getting to the dose analysis. 

Occupational internal dose, they nailed this one. 

NIOSH assumed an air concentration with geometric 

mean of 3,160 dpm per cubic meter, which is the 

daily weighted average for a surface grinder taken 

from TBD-6000 during operations in both '51 and '52. 

The airborne activity settled to the floor at a rate of 

7.5 times 10 to the minus 4 meters per second. 

Calculated surface contamination of about 75,000 

dpm per square meter. This activity then became 

resuspended. Using a resuspension factor of 10 to 

the minus 5 per meter, NIOSH derived an airborne 

activity of 0.751 dpm per cubic meter would reduce 

the calculated intake during the working hours 

following the first operation in 1951 until the second 
.

61

operation in 1952.

The second surface grinding operation, assumed to 

have taken place on February 1st, also generated 

airborne activity settled to the floor, doubling the 

previous level of surface contamination, which, in 

turn, doubled the airborne activity due to 

resuspension during the main operating period.

SC&A performed a revised analysis of the rates. We 

assumed that if the billets in 1951 were rolled at --

that these were test rollings done at Birdsboro. So, 

we used the daily weighted average of the rolling 

operator, which was higher than that of the surface 

grinder during the 8-hour workday, and during the 8-

hour workday under 8.8 hours, on April 1951. We 

assumed, again, during the activity, during an 8-hour 

period, resulting in a surface contamination of 76,000 

dpm per square meter as opposed to 75,000 that 

NIOSH had, which resulted in the resuspended 

airborne activity of 0.761, slightly higher dpm per 

cubic meter.

The rest of the intake calculations parallel those 

performed by NIOSH, except we assume that a 

surface grinding of wafers took place on February 

4th, '52, and the workdays were 8 hours on 

weekdays and 4 hours on Saturdays. We calculated 

the actual workweek following the rolling or 

machining of uranium based on the calendar for 

assessing intakes of resuspended activities. As a 

result of this activity, there is an increase for the total 

intake in 1951, but a decrease in 1952, for a decrease

of approximately 3.4 percent of the total inhaled 

intake, assuming somebody worked during both 

years.

So, the observation is the methodology used by 

NIOSH had a net effect of slightly overestimating the 

inhaled intakes of uranium, but we don't consider 

that to be a major -- we did not make that a finding 

for this. It did not have a major impact.
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62

Next, we turn to the ingested intakes. According to 

NIOSH OCAS-TIB-009, it's not suitable for estimating 

adjusted intakes because the uranium sheeting 

operation was short duration. It would not have 

allowed the uranium airborne sufficiently long to 

achieve equilibrium, which is assumed in OCAS-9, in 

TIB-9.

So NIOSH instead estimated ingestion on the basis of 

the calculated surface activity levels, assuming an 

ingestion rate of 1.1 times 10 to the minus 4 square 

meters per hour, meaning whatever is the 

contamination, which is just slightly over -- it comes 

out to like 1.1 square centimeters. So, whatever is 

the contamination on 1.1 square centimeters on 

accessible surfaces -- it would be the floor as well as 

the work surfaces -- this would be the amount 

ingested per hour.

So, I just did an example calculation here. Given the 

surface activity concentration calculated by NIOSH in 

'51, the ingestion rate would be 8.26 dpm per hour, 

which I'm just confirming that, this calculation.

We compared this methodology with that in OCASTIB-009, cited three pathways that contribute to the 

ingested intake. The first is -- I'm just listing it for 

technical completeness -- the first is Mode 1. That is 

the ingestion of material that is inhaled. So, it is 

coughed -- so, some of them inhaled things that's 

coughed up and swallowed, is one that's a main 

mechanism. And that need not be considered 

because the inhalation pathway already accounts for 

that. The ICRP lung model assumes a certain fraction 

of reflux into the mouth and swallowing.

The second is the position of the airborne activity on 

the beverage cup. And the third is the hand-to-mouth 

transfer from a contaminated surface, which 

corresponds to the NUREG-5512 mechanism.

During the prolonged operation up here, which is 
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63

when the TIB-92 had been used, the two latter 

pathways, Mode 2 and Mode 3, by coincidence, 

happened to be approximately equal contributions. 

But when there are no uranium operations, the 

airborne activity is greatly reduced. So, it is very 

little, very small. So, the fallout onto the beverage 

cup would be negligible. However, the Mode 3 would 

still work. There is still contamination on the surfaces 

and there is still the hand-to-mouth transfer of the 

contamination.

So, usually OTIB-9 is simply, TIB-9 is simply quoted 

as, I think, 20 percent of the airborne activity is 

ingested every day. But if you go into the details and 

use the equations that are presented in the 

document, and follow the calculations, it assumes 

that 10 percent of the activity on the worker's hand, 

which is given an area of 4 by 6 inches, is ingested, 

and the surficial activity of that hand was equal to 

that on the surface, contaminated. He puts his hand 

down, picks up dirt, and somehow during the next 

hour or during the rest of the day, that gets 

transferred.

Using that same surface contamination level and 

applying TIB-9, we have an ingestion rate of 14.5 just 

through Mode 3, the same hand-to-mouth transfer 

that is assumed by the NUREG/CR-5512. We would 

have 14.5 dpm per hour for an 8-hour day instead of 

8.26. So, this is inconsistent because TIB-9 has been 

used extensively for many things. And just because 

this was after the cessation of operations does not 

invalidate the hand-to-mouth transfer of the surface 

contamination.

So, it's not claimant-favorable. We're making this 

observation for two reasons. One is that this is an 

overarching issue that applies to other sites and 

should be applied in a wider context. Also, this is, 

again, technical point, but I think it is very significant. 

It's important. It is that the ingestion, the datum was 

correctly cited; 1.1 times 10 to the minus 4 is the 
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64

correct number. The source, however, is incorrect, in 

that it's NUREG-5512, Volume 3, is where this value 

appeared, not Volume 1.

Now this may sound like it would be like a trivial 

distinction, except that the history of this -- well, 

there was Volume 1 and 2 came out in '92. These 

were in support of NRC's clearance rule. They wanted 

to release a previously used facility for unrestricted 

use. By '99 -- but there were models in that and there 

were also values given which were not based on very 

much data. I mean, they basically had, well, we have 

values of 10 to the minus 4, we have values of 10 to 

the minus 3, so we'll settle on 10 to the minus 4, 

which was not very rigid.

However, the NRC then commissioned Sandia 

Laboratory to specifically investigate the parameters 

to be used in the models, and this was a very 

thorough study of details. It came out with a lot of 

data points and constructed a probability density 

function and found 1.1 was the average. So, even 

though the numbers are very different, it's much 

better supported, it's much more acceptable.

And so, consequently, I have to confess, at the 

beginning, we said, well, why are they getting away 

from TIB-9 if that was already used? This is a very 

thoroughly researched value and this is a good value. 

So, we concur that this is acceptable to be used for 

Birdsboro TBD.

Next, we go to the external exposure from 

penetrating radiation. Now, first, we have exposure 

to uranium metal. And NIOSH assumed the operator 

handled the uranium metal for one week in '51 and 

again in '52. And the standard TBD-6000 approach, 

distance of 1 foot, 50 percent of the work time for the 

duration for an operator. But, for '51, they assumed 

the source was a short billet, and 52, they assumed 

the source was a slug.
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65

Well, the table here is taken -- it's consistent with the 

TBD-6000, but it goes beyond it. Because that table 

-- I believe it's Table 6.1 -- is based on a report in 

Radiation Protection Dosimetry that was 

commissioned by NIOSH and was by Jerry Anderson, 

who I believe it was a NIOSH staff member, and 

Nolan Hertel, a professor at Georgia Tech, and 

calculated Bremsstrahlung doses from natural 

uranium and did research on several cases. It was all 

based on physical measurements, all computerized 

measurements, computerized analysis using MCNP.

And the long billet is much more consistent with the 

billets, with the pieces of billets that they handled in 

1951. The outer diameter of 5 inches is what was 

produced at Simonds, I believe it's Simonds Saw. And 

the weight of 376 pounds is very close to the 346 

pounds of the billets. So, I propose that -- well, it's 

true, it was cut up into five pieces, or eight pieces. 

But I propose that this is a better guide than the short 

billet which is thicker, much lighter, much less 

weight. So, I propose that we use the dose rate of 

.703 millirem per hour on the long billet as opposed 

to the .461 for the short billet.

And that includes these two values. Yes, that's the 

per hour and then the annual dose has added to it 

the .0462 millirem from contaminated surfaces in 

'51.

For '52, NIOSH adopted the exposure from the slug. 

And the slug is a hollow -- it's called the Clinton slug 

also. Clinton was the code name for Oak Ridge during 

the war. And it's a hollow cylinder which definitely 

does not correspond to the wafers that were 

examined in '52. And a flat plate would be a better

representation. The plate has the weight of 6.87 

pounds, which is in the same ballpark, at the 11.5 for 

the separate -- now these were separate pieces.

So, you probably wouldn't have been exposed -- it 

wouldn't have been a single site, but there could have 
.

66

been several, more than one being handled. And if 

you had to choose between these sites, this would 

be, to my mind, the more plausible. And the dose 

rate, the annual dose goes from 1.28 millirem to 5.21 

millirem. Now, again, these are not highly significant 

doses for purposes of reconstruction, but 

nevertheless I think it's actually more correct.

Again, I just down below -- I've already gone over 

that.

Next, we have the exposure -- and here is the most 

significant part of the analysis -- exposure to 

radiographic sources. NIOSH did not address other 

sources of exposure that were documented that they 

were present at Birdsboro at the time of the uranium 

work.

Kathy interviews survivors of one worker and others. 

They said, reported the use of radium, cobalt-60, xray machines and the betatron. But what is 

particularly telling is a verbal description of a 

photograph showing the use of sources that was 

consistent with the fish pole technique for radium 

radiography. And I will allow everyone online who has 

access to Skype to read the red text, which I would 

not be allowed to read out loud.

However, the operation mentioned here is quite 

consistent of these photographs which were -- well, 

actually, it's from an NRC Brochure 52, I believe. But 

we had to kind of borrow from the ORAU museum at 

Oak Ridge because they had a better copy and we 

had permission to use it.

So, you see a worker handling a source here, taking 

it out of its shielded container. And here, you have a 

simulation of a worker holding a source at the end of 

a long pole -- that's what we call a fish pole, referred 

to as a fish pole -- during the exposure. Now this is a 

posed photograph because, actually, you could not 

get a good radiograph because the worker's hand is 
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67

just not steady enough and exposures sometimes 

take hours.

And here again is the photograph from 1940. 

Actually, it's from a book published in about 1940, I 

believe, '40-41, again, showing, and you can see, the 

background, the radiant dangers involved, which is 

consistent with the survivors' testimony here and 

probably more radioactive signs. And so, it's quite 

clear that there were radiographic sources.

Further evidence is I conducted an interview with a 

former worker whose name was furnished by you 

during -- one of the claimants. And he said there was 

a betatron. He did work later. It was not during the 

covered period, but not that much later, just a couple 

of years later. He reported they had a betatron, a 

500-millicurie radium source and a cobalt-60 source. 

There are more details that I'm not allowed to voice 

here.

Next piece of evidence is a document that was found 

at the University of Illinois at Urbana-Champaign, 

which I should list by one of the advocates for 

workers at GSI, actually, who did his research in 

betatrons. And he sent me a page that lists AllisChalmers betatrons. The document was dated 

December 26th, 1952.

And it states that Birdsboro Foundry had a 22-

megavolt betatron installed in '52. So, it probability 

would have been towards the end of the operational 

period but nevertheless it needs to be considered.

And then, further documentation is a published 

volume put out by the Steel Founders' Society of 

America, published in 1961, that Birdsboro had nondestructive test facilities comprising a 24-megavolt 

betatron. That's not a mistake. What Allis-Chalmers 

did -- we know that from the researchers -- they first 

produced betatrons with a 22-megavolt acceleration 

and, later, by changing from an electrical circuitry, I 
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68

think the capacitors, they were able to do it at 24. 

So, they went out into the field and made field 

modifications, and they had 24-megavolt betatron, 

and ended up with a 25-megavolt betatron.

And they also had a 300-kVp x-ray machine, which is 

consistent with what GSI had; a 200-millicurie cobalt 

source, which is also -- that was the strength -- I 

didn't list it here, but that was also what the former 

worker that was interviewed also said, by the time he 

was using it, it had decayed to 200 millicurie. So, with 

a 5.8-year half-life, depending on what year you're 

talking about, you can see what the strength was. 

And 500 milligrams of radium, which is, you know, a 

milligram of radium is just about the same as a 

millicurie.

Also, just based on research that we've done, 

particularly with GSI, over the years, a facility in 

those days that does steel casting almost necessarily 

will have radiographic sources because the castings 

are subject to defects, inclusions of slag material that 

gets caught in the thing. And a customer is not going 

to want to have a casting with defects. So, they will 

actually require as part of the package that's 

delivered to them the casting be accompanied by 

certification that it has been x-rayed and they 

actually send the films, or copies of the film, to show, 

yes, here it is; it's a nice, clean casting. Of course, 

sometimes the castings aren't clean, and they go in 

and dig them out, dig out the imperfections and fill it 

in, just like a dentist will fill a cavity in a tooth which 

he diagnoses through an x-ray.

So, it would be illogical of them not to have had three 

radiation sources. We do know that GSI, which, 

incidentally, was also furnishing castings for the 

military, we know that they had radium and later a 

betatron at the operation. So, this is just completely 

reasonable.

In which case, since there was no one really from 
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69

Birdsboro that we can interview that was there during 

that time -- there was one worker who was alive at 

the time of the CATI interviews. He will be into his 

nineties. I made a cursory attempt to call him, but 

didn't succeed. So, I didn't follow it up.

Having spent a great deal of time on the part of 

NIOSH and SC&A and Board Members in developing 

exposure matrixes with GSI, I will propose that the 

same external exposures -- that this would constitute 

surrogate data that could be applied to Birdsboro, 

because the main source of this exposure and this 

triangular distribution, the three values that were 

developed for the early years at GSI, these would 

serve as surrogate data.

And these would be limiting values. So, they don't 

include the exposure to uranium metal that we talked 

about before because these are in roentgens per 

year; the other one is in milliroentgens per year or 

millirem per year, actually. So, there would be a 

trivial contribution of the values. So, there's no need 

to add the uranium.

Similarly for 1952, since we know the betatron was 

installed sometime in '52, and the DCAS practice is 

usually to give credit for the whole year when there 

is a source, in addition to this -- because we assumed 

for GSI that the same worker that did radiography 

with radium also part of the time was operating, part 

of his time was operating the betatron -- and so, we 

have this 5 rad per year air kerma from 30 keV 

photons, residual radiation after the betatron was 

shut off that was adopted for GSI.

Now the neutron dose is slightly lower than for GSI, 

because GSI, we assumed that they were 

radiographing uranium. Well, we know they were 

radiographing uranium. Here they were not, most 

likely. So, consequently, the neutron dose would just 

be from the normal radiography of steel in the 

betatron room, and the workers are very effectively 
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70

shielded against photon radiation. There are these 

10-foot-thick walls. But it does not completely shield 

them from neutron radiation. So, there was a neutron 

dose that was applied, but it's smaller than what was 

applied to GSI, based only on this steel radiography.

And then, we might as well, if there should be any 

administrative personnel -- and there aren't at the 

moment, but maybe future cases -- we could adopt 

the same exposures, the same external exposure as 

at GSI of like 571 millirem per year for the two years.

So, this is the only finding. They neglected to address 

the external exposures to documented radiographic 

sources.

Now we turn to beta dose though. None of the cases 

that were -- none of the claims for Birdsboro at the 

present time include skin cancer, but, nevertheless, 

the TBD needs to address skin doses just in case such 

a claim should come up.

And so, we agree with the NIOSH assumption that 

the beta dose, the non-contact beta dose, so the rest 

of the body other than the hands and forearms, 

should be 10 times the photon dose. We did some 

MCNP calculating and found this is a reasonable 

assumption, provided we use that shape that was 

recommended by SC&A. And then, plus the beta dose 

from contaminated surfaces that was calculated by 

NIOSH is a small contribution.

So, we end up with .703 millirem per hour times 10, 

times 44 hours per year, 50 percent, and add the 

4.48. We end up with 159 millirem, for a beta dose 

of 51.

For '52, we agree with the beta dose that NIOSH --

consistent with analysis of the uranium wafer.

Again, we make this an observation since the 

changes in skin dose would be small compared to the 

large dose -- I mean the large external doses 
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71

mentioned just before also affect the skin. So, when 

you have several roentgens per year to the skin, the 

difference of a few tens of millirem are not very 

significant. They should be addressed, but we don't 

think it was important enough to be a finding.

Next, we turn to Subtask 3, which is to evaluate the 

PER-stated approach identifying the number of dose 

reconstructions required for the evaluation of dose. 

So, NIOSH searched all computed claims and verified 

employment at Birdsboro site that had a probability, 

PoC, of less than 50 percent. They found four claims.

SC&A tried to verify. We looked at the Department of 

Labor Birdsboro webpage. We found five cases. 

However, once we investigated the NOCTS, we saw 

there were five claimants, but one of whom was 

outside the covered period. So that we agree with 

NIOSH's identification of four cases.

And we went through them to see, well, how are 

these going to be affected by this PER? So, even 

though we were not tasked with a case audit, but 

since we have to look at these cases to see whether 

they were properly identified, we just did a summary 

examination of the case.

And the first one in the order in which they were 

performed, they were, even prior to TBD-6000 and 

relied on OTIB-0004, which specified maximum 

plausible intakes and external exposures. And the 

intakes and doses were orders of magnitude greater 

than those in Appendix B, Rev 1.

Then there was a second DR that the report was 

issued after TBD-6000, Rev 0, but prior to Appendix 

B, Rev 1, or Rev 0. And the DR relied on TBD-6000 

for external exposures. Intakes were based on data 

from Simonds Saw scaled to the ratio of the masses 

of uranium handled at Birdsboro Simonds Saw.

Then, the third DR was performed. The date on the 
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72

cover was after Appendix B, Rev 0, but it did not use 

Appendix B, Rev 0. The external doses were based 

on OTIB-4. The internal, just like the previous case, 

based on Simonds Saw. And both of these DRs had 

intakes orders of magnitude lower than Appendix B, 

Rev 0 or Rev 1.

The fourth one was the only DR based on the intakes 

and external exposures in Appendix B, Rev 0.

So, our observation is that DR Number 1 could have 

been excluded from the PER, or you can say, well, 

there's such a large overestimate of the doses and it 

was still denied compensation, they could have said 

they don't need to review it. But it was probably 

simpler just to go ahead and do all four cases.

So, we have no findings pertaining to the 

identification of claims that were impacted by DCASPER-073.

Okay. Subtask 4, we were not tasked with doing a 

Subtask 4 review, but we were by extension expected 

to come up with recommendations that the Work 

Group, the Subcommittee could use in deciding 

whether to assign out a Subtask 4 and how to select 

the cases.

So, as usual in a Subtask 4 review, we need to audit 

cases that present a range of parameters that 

adequately characterize the cases evaluated by 

NIOSH. Since we had already performed a cursory 

examination of the PER reports, which is on the 

previous page, and it was very easy to do since the

cancer site appeared on the cover page, we simply 

looked at the actual cases to determine the selection 

criteria.

I can't voice this, but these are the four cases. 

They're different. One, two, three, four, five different 

organs. These two are really part of the same large 

structure, but they're considered separate organs 
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73

and separate cancers.

So, this gives you a wide range of cancer types. Also, 

in two of the cases there are two cancers. So, it will 

give us an opportunity to see, to verify that the PoC 

was correctly calculated by combining the PoCs of the 

two individual cancers, and we would have the --

Mr. Katz: Bob?

Dr. Anigstein: Excuse me?

Mr. Katz: Can I just interject here? I mean, the 

criteria for selecting cases to review --

Dr. Anigstein: I'm sorry, say it again?

Mr. Katz: Can I interject here? I mean, the criteria 

for selecting cases for Subtasks 4 are expected to be 

just based on how do you evaluate the changes 

made, really not these other factors. So, all we need 

is the generic criteria, what changes need to be 

evaluated by a case. That's it.

Dr. Anigstein: Okay. Okay. Whatever. This is the end.

I will just say, usually, when we're asked to prepare 

a memo, a separate memo, suggesting how the cases 

should be selected. I thought I would combine this.

Anyway, this is the end of the presentation. So, I will 

be happy to answer questions.

Mr. Katz: Okay.

Chair Beach: Thanks, Bob.

There's a lot of questions. But one, in particular, back 

on your Finding 6. I'm looking for my notes real 

quick. Observation 7, you talked about that being an 

observation, and if NIOSH based it on the long billet 

-- and NIOSH will have to answer whether they agree 

with that or not. If they don't use the long billet, does 

that turn that into a finding, in your mind, or?
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74

Dr. Anigstein: Probably not because this would be a 

-- the major, if they do accept the finding, the major 

source of radiation dose would be the radiographic 

sources. So, these become minor, minor changes. 

So, it's always a tossup whether to call something a 

finding or an observation.

Chair Beach: Right.

Mr. Katz: Okay. Because it shouldn't be a tossup 

really. Observations are cases where it doesn't affect 

the correctness of the dose reconstruction. Findings 

are when the dose reconstruction is incorrect. You're 

just producing a dose, a dose estimate that's 

incorrect. So, it actually should be pretty clear-cut.

If a dose is trivial, then it can be an observation. But 

if a dose is substantive, then it's a finding. That's the 

way we categorize these.

Dr. Anigstein: Okay. I guess it could be a borderline 

case where even -- I mean, an insignificant dose is 

defined as less than a millirem that we don't even 

talk about. But here, we have 159 millirem, and I 

suspect -- I didn't calculate what the NIOSH dose is, 

probably more like 100. So, that could make a 

difference.

So, it would be a recommendation that we should 

change this to a finding?

Mr. Katz: If 59 millirems is substantive in terms of 

the dose, in terms of probability of causation 

estimate, then yes. If not, no. But I leave that to --

you guys are the experts on what matters.

Dr. Anigstein: I'm sorry, I'm not sure I followed.

Mr. Katz: Okay. So, you're saying 59 millirem 

difference. If there is a 59 millirem difference that 

can change the outcome of a dose reconstruction, 

then it is a finding.
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75

Dr. Anigstein: Yes. Okay.

Mr. Katz: If 59 millirem is as trivial as 1 millirem, in 

effect, for a PoC sake, then you can leave it as an 

observation.

Dr. Anigstein: All right. I agree with that. I accept 

that.

Mr. Katz: Yes.

Dr. Anigstein: So, do I need to do anything, or?

Member Ziemer: No.

(Laughter.)

Member Ziemer: Well, let's ask some other questions 

first maybe.

Mr. Katz: Yes.

Member Ziemer: First of all, let me ask, did NIOSH 

consider any cleanup occurring after these sources 

are handled?

Dr. Anigstein: I don't believe so. Dave could answer 

that.

Mr. Allen: Okay. This is Dave Allen.

Could you repeat that?

Member Ziemer: I'm asking whether any cleanup was 

considered after whatever tests were made. So, I'm 

a little confused. For example, it says that NIOSH 

assumed the operator handled the uranium metal for 

a week. But, elsewhere, it implied that whatever was 

done was done in a day. And whether it is a day or a 

week, was there any cleanup that occurred? Are we 

saying that the total handling time for a year was 

basically 8 to whatever it was, 8 and a half hours in 

a year?
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76

Mr. Allen: As I recall -- I might not be clear right on 

this -- but I think we accounted for handling metal 

for one day, and then, accounted for the 

contamination for the rest of the year.

Member Ziemer: Okay. So, that's what wasn't clear 

to me. So, you're assuming that they worked in a 

contaminated area for the full year without cleanup 

or with cleanup?

Mr. Allen: We did not account for any cleanup.

Dr. Anigstein: I believe my recollection of this is that 

the machining took a day, consequently you had this 

airborne activity for a day and settling out for a day.

Member Ziemer: Right.

Dr. Anigstein: But it stayed there the rest of the -- in 

other words, it started when the first metal was 

worked in 1951 and it continued through the end of 

'52, and then, it just abruptly stops. There is no 

residual period.

And the handling was for purposes of external, and 

so forth. External exposure purposes, the handling 

took a week. For internal, for the generation of the 

dust, the machining or rolling, or whatever it was, 

took a day.

Member Ziemer: So, in essence, if there's no cleanup 

and there's residual activity sitting around for the 

year, then we end up having to account for the 

radiographic sources for the full year, even though 

they only handled the uranium for a day, is that 

correct?

Dr. Anigstein: Well, if the '51 to '52, if the covered 

period --

Member Ziemer: Yes, but I'm really asking you, is 

there really a defined covered period already in place 

that assumes it's a full year?
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77

Mr. Allen: This is Dave Allen.

I think I know what you're asking. Right now, the 

DOL covered period is 1951 and 1952.

Member Ziemer: Got you. That is, we end up dealing 

with those radiographic sources, we suddenly jump 

to some pretty big doses?

Mr. Allen: Right. And as Bob pointed out in his 

presentation, the actual work is more like a day or a 

week in '51 and --

Member Ziemer: Right.

Mr. Allen: -- and one day in '52.

Member Ziemer: Is there some reason to think that 

they didn't do any cleanup, and would that change 

things much?

Mr. Allen: I don't know if it will. I mean, as far as 

dose testing goes, it's just dose from that 

contamination left over from one day. It didn't 

amount to --

Member Ziemer: It didn't amount to much by itself?

Mr. Allen: Right.

Member Ziemer: Okay.

Mr. Allen: I think I know where you're going, and it's 

--

Member Ziemer: Well, I'm concerned about the 

numbers are going to be pretty big from the other 

stuff.

Mr. Allen: Yes, and it's always been kind of a question 

mark with the Department of Energy, or the 

Department of Labor, with these intermittent jobs as 

far as, if you worked one day in '51 and one day in 

'52, is the whole year covered; is the whole time 
.

78

period in between covered?

Member Ziemer: Yes, yes.

Mr. Allen: I mean, I think we could probably get them 

to end the covered period in February of '52, but 

they've still got the 1951 to 1952. I'm not sure how 

they deal with it.

But that does bring up, I mean, I would like to 

respond to the one finding anyway, the radiography, 

if I could.

Member Ziemer: Well, I think you're going to have to 

respond to that because that's substantial if you are 

saying two years.

Chair Beach: I don't know if we should take these one 

at a time. Like the first observation, I'm assuming we 

can close that because we -- I mean, yes, NIOSH can 

change whatever the name on their documentation, 

where appropriate, but we can't change the way it's 

been designated.

Member Ziemer: No, no, I understand that.

Chair Beach: Yes.

Member Ziemer: It just wasn't clear to me in talking 

about handling things for a day, assuming a week --

Chair Beach: Right.

Member Ziemer: -- and then, adding -- I think Bob is 

quite right in raising the issue of the radiographic 

sources. We certainly had that issue at General Steel 

Industries and that's still the idea. It sounds like at 

least -- I don't know to what extent we can actually 

clarify that everything that you named there actually 

was there. I mean, we can -- it's likely that they 

were, but do we know the sizes of the sources that 

they had, for example?

Mr. Katz: Well, I guess before we get into that, could 
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79

we hear from Dave? There's some big issues here.

Mr. Allen: Yes, this is Dave Allen.

And that's the exact point. I mean, we did look at this 

a little bit when we were putting this together 

because we did have some information that they had 

a betatron. What we found was that the Army Corps 

of Engineers let a contract -- essentially, the Army 

was going to take over this plant and start making 

tanks, and the Army Corps of Engineers put a 

contract out to expand this facility in order to do that.

That expansion was to include putting on the Corps 

of Engineers in extreme tight order or quality control 

which included a betatron machine. But that contract 

wasn't put out until -- it was signed March 7th of 

1952, and the contract wasn't completed until June 

of 1954. So, it does not appear that the betatron was 

there during the actual AEC work there, 1951 into 

February of '52.

Member Ziemer: See, that's a very important point 

in this thing that could definitely change the 

numbers.

Mr. Allen: That's why I've been trying to get in here. 

We looked at that and decided the betatron wasn't 

there during that timeframe. The rest of the stuff as 

far as radium and cobalt sources, all the information 

we have essentially comes after that timeframe. It 

may or may not apply during, but we don't know.

We came to the decision that we were not going to 

include the radiography until we know or at least had 

some reason to believe that it was there in February 

of '52 at least. And right now, everything we have 

says the 1960s it was there and 1954 it was there, 

but we don't have anything that really says it was 

there prior to February of '52. That's why --

Dr. Anigstein: Dave, I saw that same information that 

you're citing. But what convinced me was this listing 
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80

of Allis-Chalmers betatron where they listed it as 

installed in 1952, this one piece of paper.

Mr. Allen: And that's possible, but the expansion that 

it was going to be used on wasn't completed until '54, 

and the contract to build that building and install it 

wasn't signed until March of '52, which comes after 

the February of '52.

Dr. Anigstein: But the use of -- again, I agree that 

there was some ambiguity there. But the fact that 

they needed the castings that they were doing, had 

been making ever since the beginning, and they had 

been steel casting I think starting during World War 

II. It's just industry practice was to do radiographs, 

and the simplest way of doing the radiograph was 

with radium. So, the things that were --

Mr. Allen: That's interesting. I'm sorry, Bob.

Dr. Anigstein: No. I mean, to think that they would 

be sending out the castings without any quality 

control is just not --

Mr. Allen: But the other interesting thing about this 

site was that the Navy controlled it during World War 

II. They allowed Birdsboro to start using it in, I 

believe it's '46. They allowed Birdsboro to use what 

was the storage areas for what they called pressed 

steel operations, not castings, but pressed steel.

And then, Birdsboro leased the casting area to PennOhio Steel Corp, a different company altogether. 

There's actually some legal cases in there about the 

property tax. But I don't know for sure when PennOhio Steel stopped using that, but I know they were 

using that area in '49 and '50, and it seems like it all 

stopped when the Army decided to take over and 

start expanding the plant, so that they could build the 

tanks.

Dr. Anigstein: There were actually two facilities, two 

separate buildings. There was a Birdsboro foundry 
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81

and there was something called armor cast, which 

was built, which was on the same site, which was 

built during World War II by the Navy for the use of 

the Navy. And the thing is, the Birdsboro was a 

foundry from back in the 18th century. So, they did 

not stop making castings.

Mr. Allen: It actually seems like they did, like they 

went to go there, Penn-Ohio Steel, and they were 

using the storage areas for pressed steel.

Member Ziemer: Let's see, I think we're going to 

need some more detail on this. We obviously can't 

solve this issue today.

Mr. Allen: Yes, I think I can put together something 

and send it out. Like I said, nothing is going to be a 

definitive story here, but I think it came down, for us 

anyway, it came down to the idea that we can't really 

show that any of this was there in '52. We can always 

revise the TBD later, if we find some information.

Mr. Katz: So that sounds good, to get a written 

response from NIOSH.

Mr. Allen: Yes.

Mr. Katz: Yes.

Chair Beach: Okay. So, on the finding, I understand 

we need to get a response from NIOSH. Do we want 

to wait to close out any of the observations until after 

we get that back?

Dr. Neton: This is Jim.

I think some of those observations are going to 

require some kind of writing because --

Chair Beach: Yes.

Dr. Neton: -- some of them do involve some fairly 

technical nuances in our program.
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82

Chair Beach: Okay. Well then, we'll just go ahead and 

wait on those.

Then, Ted, this is affecting Subtask 4. We're going to 

hold off on tasking any of those, is that correct, 

today?

Mr. Katz: Yes. There's not much point really in 

tasking that, given the murkiness of where this is 

headed.

Chair Beach: Because I definitely on this one -- on 

PER-062 was one that was recommended as Subtask 

4 tasking. And I guess I'm just questioning even 

tasking that with contract employees.

Mr. Katz: Well, yes, we can't actually task anything 

today. Okay

Chair Beach: That's what I thought.

Mr. Katz: Yes. But you can certainly let your wishes 

be known about Subtask 4 because the 

Subcommittee won't be meeting for at least another 

three months, but yes.

Chair Beach: Right. Okay.

Mr. Katz: Yes.

Chair Beach: I think that's the only one. So, on this 

one, we're going to wait and NIOSH will take this and

answer the observations and Finding 1, correct?

Mr. Katz: Yes. Right.

Chair Beach: Okay.

Ms. Marion-Moss: Josie, this is Lori.

I have a question, and I don't know who can answer 

it. But has Appendix B been reviewed by the AWE 

Work Group?
.

83

Chair Beach: I believe it's the TBD-6000 Work Group, 

is that correct?

Mr. Katz: It is TBD-6000, but no is the answer.

Ms. Marion-Moss: The answer is no?

Mr. Katz: I don't think we ever --

Member Ziemer: We never did Birdsboro.

Ms. Marion-Moss: Oh, okay, never Birdsboro.

Mr. Katz: That's why this is all coming up. That's why 

this is all coming up now.

Ms. Marion-Moss: Yes. Okay. Thank you.

Chair Beach: Okay. So, we're going to leave those 

findings as open or in progress?

Mr. Katz: Yes, I think in progress is good.

Chair Beach: In progress? Yes.

Any other questions, Loretta?

Member Valerio: I had one question, and I'm trying 

to find it. Was the operational period the entire year 

1951?

Mr. Allen: Currently, DOL has it listed as 1951 and 

1952. They have a knack of just making whole years 

unless you ask them to narrow it down to some 

specific dates. As it was with this one, we were just 

doing the two-day operations thing and whether it 

was the rest of the year on the residual 

contamination or not didn't much matter. So, we 

never asked them to try to narrow that down.

If that becomes part of the issue with radiography, et 

cetera, we can probably do that. I think there's 

enough information for them to narrow it down to 

February of '52. But, currently, it's --
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84

Member Valerio: So, in this finding looking at dose, 

for the residual contamination would the 2,000 hours 

of exposure be used or the 2500, because they were 

working an extended workweek by working that halfday on Saturday?

Mr. Allen: I think the 1952 I believe we are using 

2200 hours a year, if I recall. And yes, we're currently 

using the entire year, but almost all of it is just the 

residual contamination there, exposure from that. 

It's pretty small.

Member Valerio: Okay.

Chair Beach: Okay. And then, Bob, the last question, 

I wasn't 100 percent clear. Are we going to change 

one of the observations to a finding or are we --

Dr. Anigstein: Yes.

Chair Beach: Okay.

Mr. Katz: Yes, I don't think you need to reissue a 

report for that. I think you can just capture that in 

the BRS.

Ms. Behling: I will do that.

Dr. Anigstein: I'm sorry, capture that in an email?

Mr. Katz: In the BRS.

Dr. Anigstein: Oh, the BRS, right. Okay. Okay, Kathy 

can handle that.

Ms. Behling: I can take care of that.

Chair Beach: Okay. Anything more on Birdsboro?

Ms. Marion-Moss: This is Lori.

Which one is going to turn into a finding, which 

observation?

Dr. Anigstein: Seven.
.

85

Ms. Marion-Moss: Seven, okay, thank you.

Member Ziemer: Was that the issue of the 58 

millirem?

Mr. Katz: Yes.

Dr. Anigstein: That was just -- I didn't actually 

calculate it. I didn't actually have a number in front 

of me. It was just a rough observation.

Member Ziemer: Using Ted's criteria, I don't see that 

going to a finding.

Mr. Katz: Okay. That was my question to you all. I 

didn't really get an answer. But if that doesn't move 

the needle, then it can stay as an observation.

Chair Beach: Yes, maybe SC&A needs to look at that 

and --

Member Ziemer: Compared to the radiographic 

sources, 58 millirem is almost negligible.

Dr. Anigstein: I agree.

Member Ziemer: It's not normal if it is.

Mr. Katz: Right. Well, as I said, if it doesn't move the 

needle, then you can keep it as an observation. 

That's the criterion for deciding.

Member Ziemer: I think the thing that's going to 

move the needle is going to be the radiographic 

source.

Dr. Anigstein: Oh, absolutely.

Mr. Katz: Right, but that may or may not actually 

come into play after Dave gets back to us, and maybe 

even DOE, on this matter.

Member Ziemer: Yes, yes.

Chair Beach: Okay. So, am I hearing that we're 
.

86

leaving seven observations and one finding at this 

time?

Member Ziemer: I would --

Chair Beach: It wasn't clear.

Member Ziemer: I would suggest leaving it as an 

observation, but --

Mr. Katz: Okay.

Member Ziemer: SC&A is going to deal with it, right?

Mr. Katz: Right, correct.

Chair Beach: Okay. Then, Kathy, cancel that change, 

I guess, at this point.

Ms. Behling: I'm taking notes.

(Laughter.)

Chair Beach: Yes. Okay. And I wasn't clear. That's 

why I asked the question.

Ms. Behling: I'm glad you did, yes, ask it.

Chair Beach: Okay. So, are we ready to move on to 

the next item, Idaho National Lab?

Ms. Behling: No, that was an old agenda. That's been 

removed, and I apologize for including that initially.

The next one on the list, actually, is PER-80.

Now, Bob, do you want to take --

Dr. Anigstein: Could I request a five-minute break?

Ms. Behling: Absolutely, yes.

Dr. Anigstein: Okay. I'll be back.

Ms. Behling: In fact, I was going to say Ron Buchanan 

is up for the next three. So, he may want a break 
.

87

also.

Ron, are you prepared to do OTIB-88?

Dr. Buchanan: Yes.

Ms. Behling: Okay. So, we will move, then, ahead to 

ORAU-OTIB-88, the External Dose Reconstruction.

Chair Beach: Okay. Is everybody okay with that?

Member Ziemer: Yes.

Member Valerio: Yes.

ORAU-OTIB-088, External Dose Reconstruction

Dr. Buchanan: Okay. This is Ron Buchanan with 

SC&A.

And if you could bring up our report on OTIB-88, 

External Dose Reconstruction? And I'll wait until you 

get it up there.

Okay. This was an OTIB that was released that was 

to replace Procedure 6. And this is OTIB-88, External 

Dose Reconstruction, issued in September of 2018. 

It was to replace Procedure 6 by the same title which 

was issued in 2006.

And it was also to facilitate cancellation of Procedure 

60, Occupational Onsite Ambient Dose 

Reconstruction for DOE Sites, issued in 2006.

So, we evaluated this revision. Actually, it's a new 

OTIB -- it replaces Procedure 6 -- 88. And so, OTIB88, again. I'll give a brief outline, and I do this 

generally because I realize most don't have time to 

read all of these detail. I'll try to give you an idea of 

what it contains before we get into the evaluation, 

which starts in Section 3 on page 6.

And we evaluated the technical approach, methods 

used and documentation in OTIB-88. We found that 
.

88

it was reasonable and useful, presented some good 

guidelines for the dose reconstructor, in Figure 2-1, 

and had no -- really -- problems with the approach.

We did do the evaluation of the methods used, and 

we agree with that and found them useful and the 

equations correct and the math correct.

We did have one important observation, Number 1. 

Maybe NIOSH can shed some light on this. But I know 

in my past dose reconstruction I used the reference 

to Procedure 60 a lot to determine external dose for 

site-specific locations. And if this is going to replace 

that, then that information I feel should be brought 

in. So, Observation 1 is that we need to retain the 

information in Procedure 60, Attachments A, B and 

C, in some form or another, because OTIB-88 lacks 

that information. And so, the dose reconstructor 

would have to go to each site and find out what the 

ambient dose was, what the policy was.

The appendix in Procedure 60 is very useful and it 

gives each site, a summary of each site, and it gives 

when, the Appendix A gives when that site included 

the external ambient dose in the dosimetry badge 

readings and not for almost all the major sites. And 

so, it's very useful. So, I would strongly suggest that 

somehow the information in appendix of Procedure 

60 be included in OTIB-88. And so, that was the only 

major observation.

Section 3.3, on page 7 of our report, it appears that 

there might be a factor of 2 that was included that 

shouldn't have been. Now this was just an example 

calculation. So, we didn't count it as a finding, just 

an observation on page 21 of OTIB-88.

We see that on page 20 it states three times the 95th 

percentile is derived by multiplying the number zero 

by the LOD value. However, on page 21, they divide 

it by 2 for the 95th percentile. And so, it appears to 

us that this should be not divided by 2, and it would 
.

89

increase -- in that example it would increase the 95th 

percentile dose by some fraction. And so, while it's 

not important as far as the dose reconstructor 

construction instructions, if you read this and applied 

it, it would be too low of a dose.

So, that was the only two items. Other than that, we 

had no issues with OTIB-88, but strongly suggest 

that that information be included in it that would be 

eliminated by eliminating Procedure 60.

Any questions on that?

Chair Beach: Okay. Good report.

Any questions? And if not, does NIOSH have a 

comment on it?

Dr. Neton: This is Jim.

I've read the review, but I do not have an opinion at 

this point. I wonder if anyone, either Tim Taulbee or 

anyone from ORAU, cares to comment on these two 

observations.

Dr. Taulbee: This is Tim Taulbee.

I guess one thing that I would like to point out, and 

that is that I guess I disagree a little bit with Ron as 

far as the information would be lost if we cancel 

Procedure 60, because it does appear in other 

procedures or other Technical Basis Documents. So, 

I don't believe the information will be lost. Will it be 

less useful or less easy to find? Perhaps.

And that's something that we could take and think 

about a little bit here from that standpoint as to 

whether we want to try and keep it all consolidated 

in one place or let it go out to the individual site 

Technical Basis Documents, which is really where it 

should reside if somebody is doing a dose 

reconstruction. That's the whole reason we have the 

Site Profiles. You've got all of the different chapters, 
.

90

all of those different Technical Basis Documents, all 

in one place. And so, that's kind of the goal of why 

that would be moving out there.

But I do see some merit with of Ron was pointing out 

of keeping them all in one place, so that somebody 

could look it up easily, and I think that's something 

we can think about.

Chair Beach: Okay. Thank you.

Any other questions?

Mr. Fishburn: This is Mark Fishburn with ORAU.

I thought I would point out, also, that on the second 

observation on the equation error, that Ron was 

correct, and that the equation is being used correctly 

by the dose reconstructors, but it was put in the 

Attachment A incorrectly. So, we will get that revised.

Chair Beach: Okay. And then, shall we just wait for a 

memo after you look at the first observation and 

determine if that is something you want to maybe --

anyway, just give us an idea of what you decide on 

that.

Mr. Katz: We can just get an email from them on 

what they decide to do, but I don't think we need to 

hold this open for that.

Chair Beach: Yes. Okay.

Mr. Katz: It's just an observation in my --

Chair Beach: Right, right, right. Okay. Then, I'm fine 

with that. We'll leave it to NIOSH to send out an email 

just informing us what they decide.

And if the Subcommittee agrees, we can close both 

of these observations.

Member Ziemer: Right. So, Observation 2 will be 

corrected.
.

91

Chair Beach: Yes, we just heard that.

And Observation 1 closed, and then, we'll hear from 

NIOSH on an email.

Everybody agree with that?

Member Ziemer: Yes.

Member Valerio: Yes.

Chair Beach: Okay. Loretta?

Member Valerio: Yes.

Chair Beach: Okay. Then, Kathy, can we just do a 

little housekeeping for a sec?

Mr. Katz: So, we accept this document, right? Accept 

this report?

Chair Beach: Yes. Correct, yes.

Mr. Katz: Right.

Chair Beach: Sorry, I didn't use those words.

Mr. Katz: No, that's okay.

Chair Beach: And then, just a housekeeping item for 

Kathy on the RPRT-0079. I know you said that that 

was a mistake. But when I look it up in the BRS, it 

shows as open. Can you just close that, just to take 

care of that, to finish that?

Ms. Behling: Actually, 79 went to a work group.

Chair Beach: Okay. So, then, we need to put it as 

transferred. There's no findings, but it just shows as 

an open item for us.

Ms. Behling: Yes, I will. I will do that, correct.

Chair Beach: Okay. Thank you.
.

92

DCAS-PER-080 (ST4), General Steel Industries 

(GSI) Subtask 4 (case reviews)

Okay. And then, if Bob's back, we'll move back to 

PER-80, 080, General Steel.

Dr. Anigstein: Okay. Is it showing up on the screen?

Mr. Katz: Yes.

Dr. Anigstein: Okay, so this is a Subtask 4 review of 

five cases reevaluated by NIOSH using TBD-6000 

Appendix BB Revisions 2 and 3.

Okay. So I'm going to fill in background information 

and then we'll talk about the case. Two of the 

Subcommittee Members are intimately familiar with 

GSI Appendix BB but Ms. Valerio may not be.

So I'm just going quickly over the history of the --

not of the site, but of the analysis of the site.

Member Ziemer: -- on the screen yet, Bob.

Dr. Anigstein: Excuse me?

Member Ziemer: Are you going to put something on 

the screen? I'm not seeing it.

Dr. Anigstein: You're not seeing it.

Mr. Katz: It's there now. It just popped up.

Member Ziemer: Here it comes maybe.

Chair Beach: Rose just put it up.

Dr. Anigstein: The screen should say background 

information, is that --

Mr. Katz: Yes, the screen. It says five cases. It's the 

report.

Dr. Anigstein: Yes, that was the -- I just -- no, not 

the report. I have a presentation even though it 
.

93

hasn't been posted.

Mr. Katz: Yes, it's not on the screen.

Dr. Anigstein: Just a second. Give me a second.

Chair Beach: Yes, and after doing that, Bob, if you 

haven't sent that out could you send that to Ted also? 

Your presentation. 

Mr. Katz: I don't think Bob can hear us. Bob, are you 

there? Bob, are you back? Maybe he's finding it to 

send it to Rose or whoever's running the screen.

Dr. Anigstein: Is it there now?

Chair Beach: Yes, Bob, it's there now.

Mr. Katz: Yes, it's there. And Bob, will you please 

send me both this and the prior presentation?

Dr. Anigstein: Will do.

Mr. Katz: Thanks, thanks.

Dr. Anigstein: Okay. I should now be on page 2. Is 

that what everybody sees? Background information.

Mr. Katz: Yes.

Chair Beach: Yes.

Dr. Anigstein: Okay. So, the first documentation on 

GSI came out in June 25, 2007. It was Appendix BB 

Rev 0. It was reviewed by SC&A. 

There was information -- we used information from 

meetings and interviews with former GSI employees 

and their applicants.

We performed independent analyses of exposures 

and doses and we had 13 findings.

We jump forward to June 23, 2014. DCAS put out 

Appendix BB Rev 1, which incorporated new 
.

94

information resulting from new analyses.

This was reviewed by SC&A and we had 10 findings.

Then there was DCAS-PER-057 March 11, 2015 which 

was based on Revision 1 and we evaluated all 

previously completed findings.

And SC&A did a sub task for review of DCAS-PER-057 

and resulted in four findings.

Then there was Appendix -- DCAS put out Appendix 

BB Rev 2 May 26, 2016. They resolved 8 of the 10 

findings on Revision 1. 

And then there was a Revision 3 came out in February 

2017 which resolved the two remaining findings. So, 

there were no open findings. 

DCAS-PER-080 was based on Revisions 2 and 3. 

Three is for -- if anyone doesn't realize it or doesn't 

remember was really just wording changes from 

Revision 2. Nothing really major. Clarifications. But 

so that's why it was Revision 2 and 3 and again they 

reevaluated all previously completed findings.

So SC&A audited five cases selected by NIOSH and 

the DRs affected by PER-080 and our job was to 

answer two questions. One was, was the exposure 

scenarios and DR methodology in Rev 3 applied 

correctly.

I'm just going to say Rev 3 because Rev 3 

encompasses Rev 2. And was the methodology 

consistent with NIOSH practices for other claimants 

and for other work sites.

And again now we're going to see a great deal of red 

on here because these are case reviews which I can't 

talk about in detail.

So the first case, they have the job, you see the job 

category. And we conclude that based on his job 
.

95

description the worker worked inside the plant and 

was assigned -- and was therefore correctly assigned 

to the operator category. Anyone inside the plant 

according to BB will be considered an operator unless 

proven otherwise.

The period of employment spanned -- there were two 

periods of employment. The first one was during the 

AEC operations and the second one was during the 

residual period.

Here we showed the cancer and the date of diagnosis. 

The POC under the original dose reconstruction which 

was done under Rev 0 and then do POC under the 

PER, it jumped almost threefold but nevertheless was 

not compensable.

So we reviewed the external doses shown during the 

AEC period. So the target organ for the external dose 

was correctly identified by NIOSH. 

The external exposure rate was based on the latter 

part of the AEC period. I think I can tell you this is 

the dose given to everyone. So 9,000R per year. It 

doesn't identify the worker.

The dose conversion factor depended on the organ 

and was -- the surrogate organ that was used 

correctly.

And it was entered as a fixed distribution and then 

the dose was prorated since the EE did not work an 

entire year. Each year was not a full year, prorated 

to reflect this period of employment.

Our comments are that NIOSH used a fixed value of 

the dose conversion factor.

Member Ziemer: Hold on, Bob.

Dr. Anigstein: Excuse me?

Member Ziemer: Hold on just a second. Annual 
.

96

exposure rate 9,000R?

Dr. Anigstein: Yes. For one year. Annual exposure 

rate -- oh, I'm sorry.

Member Ziemer: Not 9,000 surely.

Dr. Anigstein: Sorry. That was a comma, should have 

been a period.

Member Ziemer: Right.

Dr. Anigstein: Sorry. I'm sorry. Thank you for 

catching it. I think it was one place instead of 9,000R.

Member Ziemer: Basically 9R per year.

Dr. Anigstein: 9.002. Okay. So then they used the 

fixed value which appears to be inconsistent with the 

uncertainty distribution recommended by OCAS-IG001 which recommends a log-normal distribution on 

the DCF.

However, in the present case the fixed value was 

appropriate because our MCNP simulations showed 

that for this exposure scenario 85 percent of the 

exposure is from photon energies greater than 

250keV.

Whereas NIOSH assigned a DCF 430 to 250keV. So 

the maximum DCF for exposure to photon in this 

energy range is much lower than the one that NIOSH 

used. 

So therefore the DCF that they used yields a 

bounding estimate. And considering that with a 

bounding estimate a fixed value would be 

appropriate.

However, we would suggest should there be any 

future revision that maybe this should be explained 

so that the reader doesn't say why did they use a 

fixed value.
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97

And the doses, we found the doses to the organ in 

question were correctly assigned.

During the residual period the exposure rate for 

everyone during the residual period -- again, this is 

a typo. It's 0.2925MR per year I believe. I'm not quite 

certain.

Dave Allen, do you remember was that MR or R per 

year? It looks high.

Mr. Katz: You know, when you send me the 

presentation you can correct it if it needs correcting, 

Bob, instead of worrying about it now.

Dr. Anigstein: Right. I believe -- right, I will do that. 

Okay. So then we had the exposure multiplied by the 

dose conversion factor for photons and an AP 

orientation. And these are for this particular organ. 

These are the DCFs for the 30 to 250keV and the 

more than 250keV. That was divided.

And so these exposure rates or bounding estimates 

for the DCF was correctly applied as fixed values. 

Again, the doses were prorated to reflect duration of 

the employment during the residual period.

Next we turn to neutron doses. The neutron ambient 

dose equivalent, actually I could -- it's in the TBD was 

751 millirem per year.

And then you multiply by the dose conversion factor 

for the organ in question. And this was based on 

neutrons with energies less than 10keV.

And this is claimant-favorable for all the organs listed 

in OCAS-IG-001. And therefore it was used even 

though the neutrons were most likely higher energy. 

So this is a bounding estimate and therefore again 

doses are appropriately entered as fixed values. And 

they were prorated to reflect the EE's period of 

employment.
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98

Next, internal doses. Internal doses we audited as we 

do by doing independent calculations using the DCAL 

computer code, which we have verified gives very 

close to the same values as IMBA.

We calculated doses for each calendar year from 

inhaled and ingested intakes of U-234 as listed in 

Appendix BB. So in our model we start with the first 

day of employment and end on the day before the 

cancer diagnosis.

And using a surrogate organ we found notable 

differences for some areas. And we presume that 

these differences stem from the methodology in the 

chronic annual dose CAD notebook that assigned 

daily doses during the partial exposures, uniformly 

during the entire calendar year.

In other words they take the total annual -- they take 

daily intakes, multiply by the number of days if it's 

less than a full year and then spread them out over 

the whole year therefore reducing -- keeping the 

annual intake the same, but reducing the daily 

intake.

And the total calculated dose for the period from the 

beginning of employment until date of diagnosis was 

I'll just say a few millirem in both cases.

And the numbers matched within -- the total 

numbers matched within the significant figures here.

So given that this was a small value and good 

agreement between the total dose discrepancies in 

the annual would have no impact on this case. So we 

confirmed that NIOSH correctly calculated the total 

internal dose to the organ in question.

External doses from medical X-rays. There was one 

chest X-ray during each year of the operational 

period the EE was employed. The acute organ dose 

was assigned for each year.
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99

It was assigned as a normal distribution with a 

standard deviation that was equal to 30 percent of 

the mean dose. And we confirmed this was correctly 

done.

Going on to the second case. The job description 

again indicates that he worked inside the plant and 

was correctly assigned the operator category.

His employment started during the AEC period and 

then continued into the residual period. 

His diagnosis organ and date is given here. The POC 

again jumped by about threefold and was still not 

compensable.

And the external photon doses during the AEC period 

were based on the target organ was correct, were 

based on the triangular uncertain distribution, which 

is listed here during the first year of employment.

The DCF was applied for 30 to 250keV photons and 

the AP orientation entered as a triangular 

distribution. And the dose was prorated to reflect the 

period of employment.

He was also given an air kerma dose of -- everybody 

during this period got the air kerma dose of 5.112 rad 

per year from 30keV photon. And this was applied to 

the organ in question with the appropriate DCF. And 

was entered into IREP as a constant distribution. 

And the doses were again prorated to reflect the 

period of employment.

Member Ziemer: And Bob, you have the 9,000R in 

here again.

Dr. Anigstein: Yes, I see that.

Member Ziemer: You need to correct that.

Dr. Anigstein: Will do. Then the external dose during 

the residual period, we have an exposure rate that 
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100

I'm going to check and make sure we got the right 

units here.

The exposures were divided equally between photons 

up to 32-250 and 250keV, multiplied photons using 

the DCFs for the organ in question.

Again these are bounding estimates so the DCFs are 

correctly applied as fixed values.

And finally the neutron dose rate was taken from 

Appendix BB Table 8 multiplied by the DCF for 

neutrons for the organ in question.

And DCFs again less -- energies less than 10keV. 

Claimant-favorable and the bounding estimates.

And this is pretty much repetition from the previous 

case. The fixed value was used. It appears to be 

inconsistent but in fact it's correct. 

The triangular distribution, the reason for the fixed 

value for the external exposures, '52 to '62 -- not this 

worker, but for -- generally, generically was based on 

the radiography of steel castings using sealed 

radium-226 sources.

The average photon energy of radium-226 in the 

sealed source with its progeny is 655keV. And since 

the DCF was used for 32-250keV photons this is 

highly claimant-favorable because the maximum DCF 

attributable.

So therefore the derived doses represent bounding 

estimates and so a fixed value of DCF is appropriate.

NIOSH correctly assigned doses to the organ in 

question from external exposure from the AEC 

period.

Next, internal doses. So we audited internal doses 

again using the computer code, calculated doses for 

each calendar year from inhaled and ingested 
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101

intakes. This from first day of employment until the 

day before diagnosis.

Now, in this case the NIOSH dose for the first year 

was 15 percent higher than our calculated value. The 

smaller values in some subsequent years.

We hypothesize that the differences are from how 

NIOSH supported intakes the years of partial 

exposure. So since the internal dose is a significant 

fraction of the total dose, this now becomes 

important in this case.

And so we performed new analyses to try to replicate 

what we think NIOSH did. And so we changed our 

model to distribute the intakes over the entire year 

even though the EE worked for less than an entire 

year, but then reduced the daily intakes.

We reduced the daily intakes and kept the annual 

intake the same. And doing this we were able to 

match the NIOSH doses within 1 percent. So we 

believe we were correct in our assumption that this 

is how NIOSH did their analysis, spreading out the 

intakes over an entire year when there was only a 

fraction of a year of exposure.

And this was a subject of a finding in our review of 

the previous PER-057 which is the PER for Appendix 

BB Rev 1. And we're told that the CAD tool could only 

accommodate full year of exposures and that the DR 

analyst therefore had to change the daily intakes to 

account for shorter exposure by prorating them.

And this issue was discussed at a meeting of the 

Procedures Subcommittee on January 10, 2017, and 

Dave Allen said that the CAD at that time, that the 

CAD tool has been revised. It is now able to model 

actual daily intakes and the actual beginning and end 

dates.

So we examined the spreadsheets that are part of 

this CAD tool in the current DR, and we found that 
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102

the dates and the actual daily intakes were correctly 

listed. However, the tool used for its internal 

calculation -- it still used the earlier version of the 

tool by distributing the intakes over the entire year.

So apparently the tool was simply changed to simplify 

the -- the DR analyst didn't have to do this by hand. 

The tool did it for them. But it still used the 

assumption that the worker was exposed for an 

entire year to a lower daily intake.

So our observation is that NIOSH used an efficiency 

measure to estimate doses. We made this 

observation because the total internal doses -- the 

total over the period of years calculated by NIOSH 

and SC&A agree within three-tenths of a percent. 

And since -- given the good agreement the POC was 

significantly less than 50 percent. The difference in 

annual doses was not likely to affect the 

compensation decision. However, the methodology 

could affect the outcomes in doses where the POC is 

much closer to 50 percent.

Next, external doses from medical X-rays. These 

were correctly assigned for each year of the 

operational period with a normal distribution --

standard deviation correctly computed.

So then -- we already know that there was somewhat 

repetition between the first case and second case, 

but there were significantly different -- it should have 

been discussed.

The next three cases are really unremarkable. The 

same comments apply. So instead of going through 

each case in detail, I'll simply say that the sources --

the source of exposure were similar to those 

addressed in the first two cases and there were trivial 

differences between NIOSH and SC&A analysis.

I want to jump to a summary, jump to the end, the 

summary of the five cases. So we have here in the 
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103

first column the case numbers, the job descriptions, 

the dates of employment, the -- there's two periods 

of employment, this one has one period, this one has 

again two periods.

The organs were different organs for each one. That 

will give us a range of dose models. And this is of 

interest because the first three, I believe, were done 

under Appendix BB Rev 0, and the dose changed 

about threefold in each case.

The last two had previously been done, the -- initial 

DR under Rev 1, and in one case the dose went down, 

in another case the dose went up, but not greatly. 

Same general ballpark. And again the POC in the first 

three cases was just about three times higher 

whereas in the last two cases there were minor 

differences in the POC.

And so now I'll go back to my summary and 

conclusions. We audited the five cases selected by 

NIOSH from 71 claims that have been reevaluated.

The PER addressed changes in doses prescribed by 

Rev 1, 2 and 3. At least one of the prescribed doses 

during each year of operational period increased after 

Rev 1. So NIOSH was correct in evaluating all GSI 

claims with DR that were completed before February 

9, 2017.

The date of issuance of -- type of revisions -- Revision 

3 with employment during operation period and the 

POC less than 50 percent.

SC&A had previously reviewed DCAS-PER-057 

following Revision 1. Review produced three findings 

and several observations. These findings arose out of 

methods used by NIOSH to implement Rev 1, not 

from failure to follow prescriptions. Others included a 

review of the job category included -- assigned to 

each worker.

Current review showed all five workers had been 
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104

properly assigned to the operator category, external 

organ doses conformed with external exposure 

specified in Rev 3 and with guidelines for converting 

those exposures to organ doses in OCAS-IG-001.

Inhaled and ingested intakes of uranium were 

correctly assigned for the calculation of internal dose. 

Doses from medical X-rays were correctly assigned 

in each case.

In summary, we find that NIOSH correctly 

implemented changes to the DR methodology in 

Appendix BB Rev 3 and therefore fulfilled the intent 

and purpose of DCAS-PER-80.

Any questions? 

Chair Beach: Very thorough report, Bob. Thank you. 

We only had one observation, correct?

Dr. Anigstein: Yes.

Chair Beach: Any questions from Subcommittee 

Members?

Member Ziemer: I have none. Appreciate all the work 

you did on this, Bob.

Dr. Anigstein: Thank you.

Chair Beach: Yes, very detailed. Loretta?

Member Valerio: I don't have any questions. And 

again, thank you for a very detailed report.

Chair Beach: And then any comments from NIOSH on 

the observation? 

Mr. Allen: This is Dave Allen. All I can say is Bob is 

right. I reported previously that the tool was changed 

to where it would do the daily things now. As it turned 

out I had a misunderstanding about that change. It's 

actually the tool is doing prorating like we were doing 

outside the tool before. 
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105

But our guys have been instructed to anything that 

falls within their best estimate, the 45-52 percent 

range that they need to use IMBA instead of using 

that tool for the internal dose.

Even though like Bob pointed out, I mean, it's usually 

a small difference. The biggest difference is the first 

year, and then it tends to get smaller and smaller as 

you get like five years away. It's pretty much the 

same total dose.

But they have been instructed now to use IMBA 

instead of that tool.

Chair Beach: Okay. And is that something you'll 

change if that's revved ever?

Mr. Allen: If what part is revved? If what is revved?

(Simultaneous speaking.)

Chair Beach: Go ahead.

Mr. Katz: I was just going to say the TBD, if the TBD 

were updated. 

Mr. Allen: The TBD doesn't mention which tools to 

use. The TBD gives the right number, it's just our 

method on implementing that was to use this CADW 

tool.

Chair Beach: Okay, that makes sense, and it sounds 

like you've corrected that in-house. So does the 

Subcommittee agree to close -- accept SC&A's report 

and close this?

Member Ziemer: Yes, I agree.

Member Valerio: Yes, I agree.

Chair Beach: So the only thing, Bob, if you would 

make your corrections to the slides and send those 

to Ted that'll complete this.
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106

Dr. Anigstein: Yes, I'll do that.

Chair Beach: Thank you very much.

Dr. Anigstein: I'll probably do it tomorrow.

Chair Beach: Okay. And are we ready to move on or?

Mr. Katz: Would anyone like a comfort break?

Chair Beach: That's what I was just going to ask.

Dr. Anigstein: I'm going to sign off since I don't 

expect any further questions.

Chair Beach: Okay.

Mr. Katz: Thanks, Bob.

Dr. Anigstein: Very good, okay.

Mr. Katz: Five minutes okay? Ten minutes? Tell me 

what works for everyone else.

Chair Beach: Ted, let's go 10 minutes and take a 

break.

Mr. Katz: Okay. So, 10 minutes, so about 10 to we'll 

restart.

Chair Beach: Okay.

Mr. Katz: Okay, thanks.

(Whereupon, the above-entitled matter went off the 

record at 2:40 p.m. and resumed at 2:52 p.m.)

ORAUT-OTIB-0006: Dose Reconstruction from 

Occupationally Related Diagnostic X-Ray Procedures 

Dr. Buchanan: Okay, this is Ron Buchanan of SC&A. 

And we're on the home stretch here. So we're looking 

at OTIB-6, well it's actually OTIB-0006 Revision 5 

issued 2018.
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107

Now, this replaces Revision 4 which was issued in 

2011. And so you can see I think the initial one was 

back in '04 or '05, something like that. So it's been 

revised a number of times.

And so what we're looking at is the latest revision, 

and we reviewed this very recently. And so I'm going 

to present a summary of our evaluation. Now, as you 

can imagine this is entitled Dose Reconstruction for 

Occupational Medical X-ray Procedures.

And so it's a lengthy document, 114 pages I believe. 

So there's plenty of room for evaluation on this. And 

I tried to provide -- and a lot of meat to it, so I tried 

to provide in section 2 there starting on page 5 some 

of the information. 

And one thing I want to clarify is kerma is the kinetic 

energy release in unit mass. And -- had run into that 

before. We don't use that too much in our 

presentation.

And we see that we start our evaluations on page 7. 

And we have evaluated the technical approach used 

and the documentation in OTIB-0006. And so we'll 

discuss these items.

And we find -- so we broke this down, the technical 

approach, into several areas. And one was equations 

and units.

And so we agreed with them in general. Just 

observation 1 there on page 7 could use some 

clarification on the dose conversion factor units in 

Appendix B Tables B-1, 2 and 3. The captions on 

those tables have a factor of 10 to the minus 3, and 

we really couldn't see where that applied, why it was 

there and what it applied to because all the units 

other than that cancel each other out.

Member Ziemer: Is somebody moving the Skype to 

the right pages? Okay, here it comes.
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108

Dr. Buchanan: Page 7 is where I'm at now. So that 

was an observation, and we'd just like to have NIOSH 

address if that was a typo or a misunderstanding of 

why that should be applied. So that was the 

equations and units.

The terminology. Since this dealt with a lot of 

different terms, we compared it to other documents 

used for medical X-ray and found out it was 

consistent and didn't have anything new or unusual 

in it so we agree with that.

Now I'll move on to the technical information starting 

on page 8. And so as you can imagine, this document 

contained pages and pages of tables. And so what we 

did was we did a preliminary review of it all to see if 

it was technically correct and appeared reasonable, 

and then went back and selected some of the values 

and tried to determine where they came from.

For example, if they listed a given dose or a given 

distance and gave a reference, we tried to find out if 

that was correct or not compared to other references 

or the references they gave. And so these are listed 

as observations in that some of these things we need 

clarification of how these -- where they came from or 

how they were derived.

And so observation 2 on page 8 there, the chest 

thickness. They listed Table 3-1 of OTIB-0006 chest 

thickness is 24 centimeters. We don't have an issue 

with that because we looked at other references and 

we find it ranges in 20 to 25 and 20 to 26. 

However, in the previous revision of OTIB-0006, 

Revision 4 in 2011 they used a chest thickness of 23 

centimeters. And so we just wondered why that was 

changed. That was observation number 2.

Observation number 3 was a similar thing. The 

difference in the source and its distance. Again, Table 

3-1 of OTIB-0006 lists an SID for the cervical spine 
.

109

lateral procedure of 72 inches or 183 centimeters, 

and then footnote B it states that this is done to 

reduce magnification.

We didn't really understand that since ICRP 

Publication 34 lists a SID difference of 102 

centimeters for both the lateral and AP view for the 

cervical spine X-ray. And so we was wondering why 

that was a different value than what the ICRP 

recommended.

Now on page 8 again observation 4 needs some 

references and derivation for kerma values listed in 

Table 4-1. So this is kind of a problem area when you 

have a table with a lot of values in it and they give 

some references. I understand NIOSH can't give a 

mathematical derivation of everything they have in 

the table.

However, some of these references they provide are 

hundreds of pages long. So it's hard to back check to 

where the value if they give a value in the Table 4-1, 

where it was derived from because we're not sure 

where they got it even if a reference is stated 

because it's, like I say, hundreds of pages.

And then sometimes -- and there's a conversion that 

goes from exposure to kerma. And so how they --

what values they used as the original raw data.

I'm not sure how this could be solved other than if I 

had the PDF page it would certainly help to trace it 

back. And some of the ones that weren't obvious how 

they derived those values.

Now, observation 5 again on page 8 is a little simpler 

to address. The thoracic and cervical spine dose 

assignment after 1970 needs clarification because 

Table D-1 lists the dose conversion factors for 

determining the dose equivalence from this X-ray 

view through 1970, but that doesn't say anything 

about after 1970 whereas like for the chest -- section 
.

110

does. 

Just need clarification on if this means that this view 

is supposed to be used afterwards or just through 

1970 kind of like the PDF exposure wasn't used after 

a certain period in the '50s. Need clarification of when 

this is supposed to be used or not used.

Okay, and then we have observation 6 on page 9. 

And this is references for the breast dose. OTIB-0006 

Table B-3 footnote E and Table B-13 footnote F list a 

reference of Huda and Bissessur as the reference for 

the breast.

However, that reference only provides -- the only 

time it mentions breast in that whole document it 

uses a factor of 0.1 for the lumbar spine AP and 0.00 

for the lumbar spine lateral.

And so it was not obvious how the values in Table B13 page 107 for the breast was derived using that 

particular reference. I don't know if it's an incorrect 

reference or they did the calculations and it's not 

obvious how they derived those values.

And so that brings us to observation 7. This is kind of 

like the last one I gave. Because we feel that we need 

to retain the important values on attachment C of 

Procedure 0061.

I bring this in, Procedure 0061 into OTIB-0006 

because I understand -- it's my understanding that 

Procedure 61 is going to be -- well, it doesn't contain 

attachment C of the older Procedure 61.

And it says okay, we didn't include attachment C in 

the latest revision of Procedure 61 because you can 

use the information in OTIB-0006.

Unfortunately OTIB-0006 does not contain the detail 

that the older revision procedure 61 had in 

attachment C. And let me explain this a little bit.
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111

In X-ray dose reconstruction you have mainly the 

entry skin dose usually to the back, and so to 

determine the dose to other organs it's basically the 

skin you have to know what the remote dose is and 

other things. And so it isn't just one value.

And so you run into several scenarios when you do 

the dose reconstruction as I list on page 9 there. 

Three scenarios.

Okay, one is that the site provides complete skin dose 

information for various skin locations. Some of the 

bigger sites, DOE sites provide this. They'll have it for 

the ankle, for the chest, whatever, for a PA chest Xray or a lateral. And so that's good. You can use that. 

You don't need Procedure 61.

Now, some sites don't provide any X-ray information 

so you have to default to OTIB-0006 which provides 

all these default values for the different skin

locations. So those two are pretty clear cut.

Then you come to situation 3 where a site provides 

some information. They have like the entrance skin 

dose. But they don't go to the full table of skin doses 

and provide all the remote and exit skin doses and 

stuff.

So in that case you have to work with the entrance 

skin dose and use the equation in the older Procedure 

61 Rev 3 of 2010 Attachment C to look up those 

tables and look at the different doses, the exit skin 

dose, the remote skin dose and such.

And so this information -- if Procedure 61 Rev 3 of 

2010 Attachment C is no longer used or no longer 

available and OTIB-0006 and the revised Procedure 

61 does not contain those equations.

Now, perhaps NIOSH has those in their computer and 

they bring them up and stuff, but anybody looking 

from outside does not have a document to support it.
.

112

And so I would recommend that the information in 

Attachment C of Procedure 61 Rev 3 2010 somehow 

be retained in the revised Procedure 61 or included 

in OTIB-0006 because it's -- the revised 61 says to 

use OTIB-0006 if you need it.

And so that's my recommendation on observation 7. 

Unless I'm missing something somewhere that this 

information in Attachment C is being carried forward.

Now, so that was the seven observations. I had no 

findings. Mathematically and everything dose values 

was correct. And of course dose reconstructors 

probably won't be looking to see where all this 

information came from, Table 4-1 and such, but we 

did in our evaluation. 

Now, on page 10 we have the documentation. A long 

document. Minor editorial issues such as referring to 

the old table numbers in the previous revision was 

carried over to Revision 5 and such, or missing words 

that make a sentence incomplete or paragraph that 

need correcting.

Now, it's up to you if you want me to go through each 

one of these in detail, but they're mainly an editor 

can go through and see what the problem is and 

change it. There really isn't any dose reconstruction 

issue to discuss at this point.

So, Josie, do you want me to go through each one or 

just leave that to NIOSH to look at that?

Chair Beach: I would say no unless somebody else 

would like to have those read out. Hearing none --

oh, go ahead, Loretta, sorry.

Member Valerio: Sorry, Josie. I was going to say I 

don't think we need to have them read out.

Chair Beach: Yes, I don't either. Okay. So do you 

have anything else, Ron, then?
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113

Dr. Buchanan: No, that's all the presentation for 

OTIB-0006.

Chair Beach: Okay, nice job. Good presentation. 

Sounds like it was a hefty document to go through.

Dr. Buchanan: Yes, it encompasses quite a bit.

Chair Beach: Yes. So any questions from the other 

Subcommittee Members?

Member Ziemer: It obviously is not clear what the 

sort of default values are on these issues.

Chair Beach: Right.

Member Ziemer: I would think that most of these 

would be fairly simple. Well, let me ask Jim or one of 

the other NIOSH people.

In most cases you don't have all the personal 

information like chest thickness for the people in 

question. So you would be defaulting to some sort of 

standard man and standard woman value. Isn't that 

correct?

Dr. Neton: That's correct. This is Jim.

Member Ziemer: Okay. So it sounds like SC&A is 

having some difficulty in actually clarifying what the 

choice of values are.

I can understand that they might change some and 

actually if you had information even on gender --

well, you have gender information. But on perhaps 

some other factors you may go to particular tables.

But for the most part it seems like there's pretty 

simple default values. You just need to clarify where 

they came from.

Mr. Allen: Dr. Ziemer, this is Dave Allen. I think on 

that particular one and maybe some of the others 

what it amounts to is the document describes where 
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114

the numbers came from and what parameters were 

used, and it describes that we used 24 centimeters 

for chest wall thickness and then came up with a lung 

dose or whatever dose.

Member Ziemer: Right, right.

Mr. Allen: And that particular one if I remember right 

we noticed in the last revision that I think -- I could 

get this wrong, but I think it was -- we were using 24 

centimeters for most of the calculations, but we 

found a couple where we actually used 23.

We wanted to make that consistent which is what the 

change was. I may have that backwards, but as I 

recall that's what the change was.

Dr. Lobaugh: Yes, Dave, it went from 23 centimeters 

in the previous revision to 24 in this current one. And 

like you said there were some -- sorry, this is Megan 

Lobaugh.

There were some inconsistencies throughout the 

document. But then also comparing to some more 

recent information that came out, ICRP 110 the voxel 

phantom, the 24 agrees closely with that as well. So 

that was one thing that we did look at in deciding 

whether to go with the 23 or the 24.

Dr. Neton: This is Jim. I think -- my understanding is 

that this TIB is undergoing internal revision as we 

speak for other issues, internal consistency issues 

and others.

It makes sense to me that we will look at these seven 

observations and incorporate them as they make 

sense in this revision that's underway and report 

back as to which ones we considered and 

incorporated, which ones we didn't feel were 

particularly useful for clarity.

Member Ziemer: Yes, and I suppose if there's a 

reference that's pretty extensive you might have to 
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115

call out a particular section of the reference so 

someone can easily pick up where the value came 

from.

Dr. Neton: Yes, those kind of changes seem pretty 

straightforward.

Member Ziemer: Yes.

(Simultaneous speaking.)

Member Ziemer: -- easily solved.

Chair Beach: That sounds reasonable, Jim. So it is 

under review right now. Do you have a completion 

date or anything in mind?

Dr. Neton: Megan or Dave might know better. I don't.

Mr. Allen: I don't think we're to that point yet. We've 

got a few items that Megan's already working on, and 

then this came out, and I think she's already itemized 

some of this, but I don't think we're really. You know, 

like I said most of them are pretty simple.

But I don't think we're really ready to commit to a 

particular date at this point.

Chair Beach: Okay. So then we'll leave this in 

NIOSH's hands and then to report back on your 

progress at a later date.

Mr. Allen: Sounds right to me.

Ms. Behling: Josie, this is Kathy Behling. And so these 

seven observations will go into in progress in status?

Chair Beach: Yes.

Mr. Katz: Right.

Chair Beach: Okay. So if we're ready we have two 

more left. How's the timing? I know we said we'd be 

done at 3:30. Are we sticking to that?
.

116

Mr. Katz: I need to stick to the 3:30, yes.

Chair Beach: Okay. Do we have time to do either of 

these before the 3:30, or should we hold those over 

to the next meeting and identify another date? I don't 

know if we can do that. Can we, Ted?

Mr. Katz: Well, if we can get one of these in let's do 

it. Otherwise let's talk about the next date. But I don't 

know how long either of these will take.

Chair Beach: Okay. So Kathy, I guess I'll ask you of 

that.

Mr. Katz: Actually, there's three, right? There's three. 

There are three. There's OTIB-0006, 0045, and Peek 

Street.

Ms. Behling: We just covered the OTIB-0006.

Mr. Katz: Oh, I'm sorry.

Chair Beach: Forty-five and then Peek Street. 

(Simultaneous speaking.)

Chair Beach: Kathy, what do you think? Get either 

one of those done in --

Ms. Behling: Ron, I'll get your opinion on OTIB-0045. 

I do not think we can get in Peek Street.

Dr. Buchanan: I think I can do 45 in about 10 

minutes.

Mr. Katz: Okay. Well, why don't we go ahead and 

knock that off then. If that's okay with you, Josie.

Chair Beach: Yes, that's perfectly fine.

ORAUT-OTIB-0045: Historical Evaluation of the Film 

Badge Dosimetry Program at the Y-12 Plant in Oak 

Ridge, Tennessee: Part 2 - Neutron Radiation

Dr. Buchanan: Okay. If you want to bring up OTIB-
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0045, I've got it here.

Okay. OTIB-0045 is a historical evaluation of the film 

badge dosimetry program at Y-12 in Oak Ridge, 

Tennessee, Part 2 neutron radiation issued 

November of 2009.

Okay, this folds into OTIB-0044, 46 and 64 for Y-12 

which we talked about previously in the last meeting 

and was alluded to earlier in this meeting. And so this 

was done in 2009. And so we did a brief overview of 

it again in section 2. We'll go to page 8 which is our 

evaluation. 

Now, before we start talking about this we need to 

just briefly remind ourselves neutron is a little more 

difficult to measure in that especially in the NTA film 

days, back in the earlier days that the film being able 

to detect neutrons fell below threshold, usually 

around a half or 0.7 MeV. Anything below that was 

lost since you couldn't count the star -- in the film.

And so this came out later after this was used for a 

number of years. And so what they essentially do, 

you have to go and look at the neutron energy 

spectrum and try to estimate how many fell below 

that threshold so we can make a correction factor to 

increase your reading to cover those ones that were 

missed.

And so this is the reason that we have to go into more 

detail on neutron measurements. And we see that we 

will evaluate the statistical method used, the 

technical analysis, and documentation used in OTIB0045.

Now, essentially what OTIB-0045 did, it took 375, 

about that many positive neutron dose results from 

Y-12 over the years that NTA film was used and 

analyzed those in view of the different neutron 

energy fields that were possible at Y-12, derived an 

N over P value, a neutron to photon ratio so that they 
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could use that.

Most everybody was monitored for gamma rays and 

their photons and had fairly good readings, so they 

can do an N over P and assign then a neutron dose 

in addition to the photon dose.

And so what we wanted to do was number one 

evaluate how -- the statistical method they used, 

how they went about doing it, and then some of the 

N over P values, how those were derived and of 

course the documentation will be important.

And so the first thing is the statistical method. They 

used maximum likelihood to analyze this data.

And we had done a fairly thorough review of that in 

OTIB-0024 previously and applying it to this 

document we found that it was acceptable, and we 

found it was applied correctly and had no findings in 

the statistical method used.

We did have one observation in that there seemed to 

be an inconsistency in the GSD, geometric standard 

deviation values listed in Table 7-1.

They did the QQ plots in the figures, showed those 

and it's summarized in 7, the results in 7, in Table 7-

1.

And the GM values were identical. The GSD values 

were slightly larger in the table than they were in 

their respective QQ plots.

So we don't know if there's a reason for that or if that 

was just a mislabeling in the plots or the table. So 

that was our observation number one on page 8.

Now, as I say neutron response of NTA film depends 

on the energy spectrum of the neutron. And so what 

we had to do -- what NIOSH did was go in and look 

at the major sources of neutrons at Y-12 during this 

period.
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And these were four major sources, and one was an 

86 inch cyclotron that operated in the '50s through 

1961.

And so they broke this down. We're looking at page 

8 here, the 86 inch cyclotron. We see that they broke 

it down into the dose equivalent, about 46 percent 

fell in the lower energy 0.1 to 2 MeV and about 54 

percent in the 2 to 20 MeV.

And so they estimated that 30 percent of the 

neutrons fell below the 0.7 MeV threshold NTA film. 

So this gives you a correction factor there of 1.4. So 

you multiply your measured value by 1.4 to include 

all the neutron dose.

And then the angular dependency, if NTA film is 

irradiated from the front or the side at an angle its 

response is different. And so the overall correction 

factor was 1.3, and that was obtained from a 

previous NIOSH document we have evaluated and 

agreed with.

So you have to take the 1.3 times 1.4 and end up 

with 1.8 for the neutron dose correction factor. And 

we agree with that. 

And that was also recommended in OTIB-0051 page 

8-1 -- Table 8-1. And so we agreed with the cyclotron 

correction factor.

Now, the next one -- so we do this for each of the 

major sources. The encapsulated neutron sources 

and the chemical operation area. So these are the 

three major areas here.

And so we look at the encapsulated neutron sources. 

We know that we have our alpha N reaction in 

californium-252.

The alpha N reaction creates neutrons centered 

around 4 MeV, californium around 2 MeV. So what 

percent falls below the threshold there.
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Okay, we agree on the angular dependency. No 

problem there. What percent falls below the 

threshold?

Well, we have finding 1 there. We found that --

there's inconsistency in the threshold for the shielded 

encapsulated sources found in OTIB-0045 of 40 

percent compared to OTIB-0051 which said there's 

51 percent.

And so they give a higher correction factor, an overall 

correction factor of 2.7 compared to 2.2 in OTIB0045.

And we feel that their correction factor for shielded 

neutrons -- for californium source would be okay 

because it's a lower energy and it's also -- the 

unshielded sources, californium sources.

But if it's moderated you had more neutrons of lower 

energy and it's below the threshold. So we had that 

finding 1.

We go on then to the chemical operation area where 

it had uranium hexafluoride stored in a storage area. 

And we had a very similar issue there, finding 2, 

inconsistency in the NTA threshold missed fractions -

- chemical operation area.

OTIB-0051 recommends 54 percent and 45 

recommends 1.7 which is 40 percent. So we 

summarize this on Table 1 on page 10 at the bottom 

there. We compared OTIB-0045 and OTIB-0051 

recommendation in that table. 

We have some agreement on the californium source, 

86 inch cyclotron, but the shielded neutron sources 

and the enriched uranium sources we see a 

disagreement in those. So that was the two findings. 

Now, another issue was deriving the N over P ratio. 

Fortunately they provided a lot of good data in this 

document, the actual dosimetry readings by 
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121

department they went to.

In OTIB-0045 they eliminated two departments, 

production and chemical department and production 

processing department. They had all positive neutron 

doses and no new gamma doses which isn't 

physically possible. Probably they recorded it as zero 

if it was below LOD value on the gamma.

And they -- OTIB-0045 removed that data. And we

went to try and see if that were technically 

reasonable, and we agreed that that looked like an 

abnormality and should be removed.

We looked at other departments that might fit in that 

category. We did find machine maintenance shop, 

department 2003 had several neutron readings like 

this that OTIB-0045 did not remove.

However, out of 375 data points it wasn't really 

significant, and it had a very, very slight claimantfavorability so we didn't include that as a finding or 

observation.

We pretty much agree with their derivation of interval 

P values. Did have an observation number 2 on page 

12 which we need clarification -- I think the dose 

reconstructor needs clarification on some things.

And observation 2 there which concerned -- didn't 

really affect outcome. It just wasn't stated if a 

minimum gamma dose was used for the neutron to 

gamma derivation of the dose if it fell and zero was 

recorded.

Was this applied to all the values that were calculated 

or just to the four departments that it was talking 

about in that section. A fairly simple question, we just 

need clarification.

And then the last item was on page 12 there, 

assignment of neutron dose, observation 3. It would 

be very helpful for DR and have consistency in dose 
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122

reconstruction if the exact time period to use these N 

over P values was stated in the OTIB because it 

mentions several times on '50 to '80, '50 to 1961 or 

something.

And so we need an exact month and date that it's 

supposed to start at -- Table 7-1 applies to and an 

exact month and year. So it would be applied 

uniformly.

And then we had a couple of minor documentation 

which was carryover from the old revision into the 

new revision. And that's it in a nutshell.

Chair Beach: Okay. Thanks, Ron. Any questions? I 

know that was quick.

Member Ziemer: Ron, this is Paul. What was the 

shielding material for the neutrons? Was it always 

water or paraffin or something? How consistent were 

the shielding materials when you looked at those 

ratios?

Dr. Buchanan: Well, they were usually hydrogenous 

materials of some kind, usually paraffin for most of 

the calibration sources and tech sources and stuff. 

Usually paraffin with a cadmium jacket.

Member Ziemer: So they always used the cadmium

jackets?

Dr. Buchanan: I couldn't say for sure at Y-12.

Member Ziemer: Well, I'm just wondering whether 

there was a consistency in the -- because a lot of 

times they use just the hydrogenous materials. 

Sometimes they use the cadmium or some other 

absorbent, neutron-absorbent material like 

cadmium.

But I'm just wondering the consistency on that in 

establishing those ratios.
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Dr. Buchanan: No, I -- I don't know.

Member Ziemer: Can't answer that. Okay.

Chair Beach: Okay, any comments from NIOSH? 

Dr. Neton: No. This is Jim. I think this is lumped into 

that other category of the review of the beta gamma 

which is the neutron component. We'll address these 

all at the same time.

Chair Beach: All together. So add this to the 44, 46, 

and 64 list?

Dr. Neton: Correct.

Chair Beach: That sounds reasonable. So we're going 

to hold over the template for Peek Street until the 

next meeting.

A couple of -- just for the Subcommittee on tasking, 

I know we can't task right now, but it's something we 

could -- potentially Ted could send out a tasking.

The one that came up was PER-062 Subtask 4. 

NIOSH recommended -- or I'm sorry, SC&A 

recommended one case for Subtask 4. Do 

Subcommittee Members agree with that or have any 

concerns?

Member Ziemer: Fine with that.

Member Valerio: I agree, Josie.

Chair Beach: Okay. So, Ted, is that something you 

can just make a note of?

Mr. Katz: Yes.

Chair Beach: On the technical guidance there was 

two documents that SC&A recommended reviewing. 

Is that something we can discuss now, Ted, to see if 

we --
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124

Mr. Katz: We can discuss it. I'm almost out of time 

here. But we really need to get -- from NIOSH about 

-- since we don't really know exactly what's what with 

these.

So you have the input from SC&A in this table as to 

why they're suggesting it be reviewed, but it would 

be helpful to have a perspective from NIOSH as to 

whether this makes sense.

Chair Beach: Is that something that NIOSH can just 

send out an email again to the --

Mr. Katz: Yes. That would work fine. The PER-087 of 

Battelle-TIB-5000, if you could just give us your 

thoughts about whether these are ready for SC&A 

review, appropriate for SC&A review given what is 

already under the bridge and so on and what's going 

on, that would be very helpful. Then I can handle this 

after we have another contract.

(Simultaneous speaking.) 

Mr. Katz: That sounds good.

And then I don't think we can schedule at this point 

because we don't really have much on our plate. So 

I think we need to wait till we build up enough of the 

stock of material.

Adjourn

Chair Beach: Okay, that makes sense. All right, well 

then I would say we are ready to adjourn.

Mr. Katz: Yes, and thanks for a very productive 

meeting.

(Whereupon, the above-entitled matter went off the 

record at 3:30 p.m.)